NO'I'ICE OF PRELIMINARY DECISION FOR THE PROPOSED ISSUANCE OF EMISSION REDUCTION CREDITS

Transcription

1 Bakersfield Californian Bakersfield Californian NO'I'ICE OF PRELIMINARY DECISION FOR THE PROPOSED ISSUANCE OF EMISSION REDUCTION CREDITS NOTICE IS HEREBY GIVEN that the San Joaquin Valley Unified Air Pollution Control District solicits public comment on the proposed issuance of Emission Reduction Credits to Crimson Resource Management for shutting down and replacing two natural gas-fired engines serving hydraulic well pumps (S & '-38) with electrical motors, at the Greely Lease within Crimson's Kern County Light Oil Central stationary source. The quantity of ERCs proposed for banking is 52 Ib-VOClyear, 18 Ib-NOxIyear, and 850 I b-colyear. The analysis of the regulatory basis for this proposed action, Project #S , is available for public inspection at and the District office at the address below. Written comments on this project must be submitted within 30 days of the publication date of this notice to DAVID WARNER, DIRECTOR OF PERMIT SERVICES, SAN JOAQUIN VALLEY UNI'FIED AIR POLLU'I'ION CONTROL DISTRICT, FLYOVER COURT, BAKERSFIELD, CA

2 San Joaquin Valley AIR POLLUTlDN CONTROL DISTRICT HEALTHY AI R LIVINGw DCT Debra Sovay Crimson Resource Management 5001 California Ave, Bakersfield, CA Re: Notice of Preliminary Decision - Emission Reduction Credits Project Number: S Dear Ms. Sovay: Enclosed for your review and comment is the District's analysis of Crimson Resource Management's application for Emission Reduction Credits (ERCs) resulting from shutting down and replacing two natural gas-fired erlgines serving hydraulic well pumps (S & '-38) with electrical motors, at the Greely Lease within Crimson's Kern County Light Oil Central stationary source. The quantity of ERCs proposed for banking is 52 Ib-VOCIyear, 18 Ib-NOxIyear, and 850 Ib-COIyear. 'The notice of preliminary decision for this project will be published approximately three days from the date of this letter. Please subrr~it your written comments on this project within the 30-day public comment period which begins on the date of publication of the public notice. Thank you for your cooperation in this matter. If you have any questions regarding 'this matter, please contact Mr. Steve Davidson of Permit Services at (661) Sincerely, a Da. Warner (pirector of Permit Services Enclosures Seyed Sadredin ~xec'utive OirectorlAir Pollution Control Officer Northern Region Central Region (Main Office) Southern Region 4800 Enterprise Way 1990 E. Gettysburg Avenue Flyover Court Modesta, CA Fresno, CA Bakersfield, CA Tel: (209) FAX: ( Tel: (559) FAX: Tel: FAX:

3 San Joaquin Valley d AIR POLLUTION CONTROL DISTRICT qnrc HEALTHY AIR LIVING" OCT 0 P 2010 Mike Tollstrup, Chief Project Assessment Branch Stationary Source Division California Air Resources Board PO Box Sacramento, CA Re: Notice of Preliminary Decision - Emission Reduction Credits Project Number: S Dear Mr. Tollstrup: Enclosed for your review and comment is the District's analysis of Crimson Resource Management's application for Emission Reduction Credits (ERCs) resulting from shutting down and replacing two natural gas-fired engines serving hydraulic well pumps (S & '-38) with electrical motors, at the Greely Lease within Crimson's Kern County Light Oil Central stationary source. The quantity of ERCs proposed for banking is 52 Ib-VOCIyear, 18 Ib-NOxIyear, and 850 Ib-COIyear. The notice of preliminary decision for this project will be published approximately three days from the date of this letter. Please submit your written comments on this project within the 30-day public comment period which begins on the date of publication of the public notice. Thank you for your cooperation in this matter. If you have any questions regarding this matter, please contact Mr. Steve Davidson of Permit Services at (661) Sincerely, b David Warner Director of Permit Services Enclosure Seyed Sadredin Executive DirectorlAir Pollution Control Officer Northern Region Central Region (Main Office) Southern Region 4800 Enterprise Way 1990 E. Gettysburg Avenue Flyover Court Modesto. CA Fresno. CA Bakersfield. CA Tel: 1209) FAX: Tel: (559) FAX: 1559) Tel: FAX:

4 San Joaquin Valley d AIR POLLUTION CONTROL DISTRICT HEALTHY AIR LIVINGIM OCT 0 B 2010 Gerardo C. Rios (AIR 3) Chief, Permits Office Air Division U.S. E.P.A. - Region IX 75 Hawthorne Street San Francisco, CA Re: Notice of Preliminary Decision - Emission Reduction Credits Project Number: S Dear Mr. Rios: Enclosed for your review and comment is the District's analysis of Crimson Resource Management's application for Emission Reduction Credits (ERCs) resulting from shutting down and replacing two natural gas-fired engines serving hydraulic well pumps (S & '-38) with electrical motors, at the Greely Lease within Crimson's Kern County Light Oil Central stationary source. The quantity of ERCs proposed for banking is 52 Ib-VOCIyear, 18 Ib-NOxIyear, and 850 Ib-COIyear. The notice of preliminary decision for this project will be published approximately three days from the date of this letter. Please submit your written comments on this project within the 30-day public comment period which begins on the date of publication of the public notice. Thank you for your cooperation in this matter. If you have any questions regarding this matter, please contact Mr. Steve Davidson of Permit Services at (661) Sincerely, David Warner Director of Permit Services Enclosure Seyed Sadredin Executive OirectorIAir Pollution Control Officer Northern Region Central Region (Main Office) Southern Region 4800 Enterprise Way 1990 E. Gettysburg Avenue Flyover Court Modesto, CA Fresno, CA Bakersfield. CA Tel: 1209) FAX: 1209) Tel: (559) FAX: (559) Tel: FAX:

5 EMISSION REDUCTION CREDIT BANKING APPLICATION REVIEW Facility Name: Crimson Resource Management' Mailing Address: 5001 California Avenue, Suite 206 Bakersfield, CA Contact Name: Debra Sovay Telephone: (557) ext. 11 Facility: S-2918 Permit Numbers: S , and '-38 ERC Certificate Numbers: S , '-2, and '-3 Project Number: S Date Received: May 12,2010 Date Complete: August 30,2010 Engineer: Date: Lead Engineer: Steve Davidson September 9, Allan Phillips, Supervising AQE 1. SUMMARY: Crimson Resource Management has permanently shut down and replaced two natural gas-fired engines serving hydraulic well pumps (S & '-38) with electrical motors. Crimson Resource Management is requesting emission reduction credit (ERC) banking certificates for VOC, NOx, and CO. The following emission reductions have been found to qualify for banking: II. APPLICABLE RULES: Rule 2201 New and Modified Stationary Source Review Rule (June 10, 2010) Rule 2301 Emission Reduction Credit Banking (December 21, 1992)

6 Crimson Resource Management $48, Ill. PROJECT LOCATION: The two IC engines are located at tank setting in the Greely Lease within Crimson's Kern County Light Oil Central stationary source. S S SEl4 Section 12, Township 29S, Range 26E MDB&M. NWl4 Section 18, Township 29S, Range 26E MDB&M. IV. METHOD OF GENERATING EMISSION REDUCTIONS: The emission reductions are being generated by replacing two naturallfield gas-fired engines powering compressors (S , and '-38) with permit exempt electrical motors. Equipment Shut down: V. CALCULATIONS: A. Assumptions and Emission Factors The actual emissions will be calculated for each of the calendar quarters in the baseline period. The Historical Actual Emissions (HAE) will be calculated using actual fuel use data and source test results. The applicant provided monthly fuel use data for the subject engines from the second quarter 2008 through the first quarter Rule 2201 section 3.22 specifies the Historical Actual Emissions must be discounted for any emission reduction which is: 1. Required or encumbered by any laws, rules, regulations, agreement, orders, or permits 2. Attributed for a control measure noticed for workshop, or proposed or contained in a State Implementation plan

7 Crimson Resource Management S-48, Proposed in the District's adopted air quality plan for attaining the reductions required by the California Clean Air Act. The following tables lists the VOC, NOx, and CO emissions based on two sets of source tests for the permit units. (See Appendix B). The HAE for emission calculated from the second quarter 2008 through the second quarter 2009 will be based on the October 2007 source test. The HAE for emission from the third quarter 2009 through the first quarter 2010 will be based on the July 2009 source test. Source Test Date ppm 02) VOC 50h IblMMBtu ppm (I 02) NOx IbIMMBtu CO ppm (' 50h 02) IblMMBtu No other rules have emission limits more strict than the source test results. There are no control measures noticed for workshop or include in the air quality attainment plan that apply to this unit. B. Baseline Period Determination Per the following sections of Rule 2201, baseline period is defined as: two consecutive years of operation immediately prior to submission of the complete application; or another time period of at least two consecutive years within the five years immediately prior to submission of the complete application as determined by the APCO as more representative of normal operation; Engine S was shut down in March 31, Engine S was shut down April The baseline period for both engines shall be Second Quarter 2008 through first quarter (see fuel usage records Appendix C).

8 Crimson Resource Management S-48, C. Historical Actual Emissions (HAEL The average fuel use per calendar quarter is determined from fuel use records supplied by the applicant as shown in the tables below (see fuel use records in Appendix C): Total Fuel Use Average Fuel Use Year Total Fuel Use Average Fuel Use Q Q Q Q Assumptions for Fuel usage: Gas hhv = 1000 Btufdscf (typical) Because two source test were performed during the baseline periods. Emissions per quarter will be based on the most relevant source test to each quarter. The following example calculation shows how the emissions are calculated: HAE = [(Emissions factor from the relevant source test) x (heat input per quarter)] Example Equation 2nd quarter, 2008: NOx = [(EF) x (Heat Input)] NOx = [( b/MMbtu) x (1 51,507 scf) x (1 000 Btufdscf)] = 4.5 Iblqtr

9 ~ - Crimson Resource Management S Quarterlv NOx HAE: ria- 2 ~ t r m 8 3m Qtr '" Qtr Q tr 2009 ( I "a Qtr " Qtr '" Qtr ' ~ t2010 r 1 ~ ' I.- I I HAE (Total/2) I " Qtr ~ '"tr ' Qtr I Total I 2 I 0 I 2 I 2 I HAE (TotalR) I

10 Crimson Resource Management S-48, Quarterlv VOC HAE: 1 '' Qtr "a Qtr a Qtr "' ~ t2009 r 1' Qtr m Qtr '"tr S'Qtr2010p I HAE (Totall2)

11 Crimson Resource Management S48, Quarterlv CO HAE: Calendar Qtr 2" Qtr Qtr " Qtr 2008 IS Qtr "" Qtr " Qtr '"tr st Qtr

12 Crimson Resource Management 5-48, Proiect HAE: S Total HAE D. Actual Emissions Reductions (AER).Actual Emissions Reductions are calculated as follows: AER = HAE - PE2 Where: HAE = Historic Actual Emissions PE2 = Post-project Potential to Emit 'The engines in this project were replaced by electric motors; therefore, PE2 = 0 IbIQtr and AER = HAE. E. Air Quality Improvement Deduction (AQID) Actual Emission Reductions must be discounted by 10% for Air Quality Improvement. Sample calculation: Q1 NOx Ib = AERX (0.1) - (6 lb) X (0.1) Ib

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32