DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM November 2, 2009 TO: THROUGH: THROUGH: THROUGH: FROM: SUBJECT: Phillip Fielder, P.E., Permits and Engineering Group Manager Kendal Stegmann, Senior Environmental Manager Phil Martin, P.E., Engineering Section Peer Review, Herb Neumann/Hal Wright, ROAT David Pollard, ROAT Evaluation of Permit Application No. 2009-255-TVR2 ONEOK Gas Gathering, L.L.C. McCurtain Compressor Station SE/4 of Section 15, T8N, R20E, Haskell County (Lat. 35.179/Long. -95.172) Directions: Approximately 1-1/2 to 2 miles north of Kinta on Highway 2, find Sans Bois Rd., a blacktop road going east and a dirt road going west. Turn east on Sans Bois Rd. and travel approximately 1 to 1-1/4 miles to S. Fish Creek Rd., a north-south dirt/gravel road. Turn north on S. Fish Creek Rd. and follow approximately 1 to 1-1/4 miles to an easterly bend, then approximately 1 to 1-1/4 miles to a northerly bend, then approximately ¾ to 1 mile to an easterly bend, then approximately ½ to ¾ mile to the Cantrell Lease entrance (currently operated by El Paso). Turn north on gravel lease road and travel approximately ¼ to ½ miles to the McCurtain Compressor Station entrance. SECTION I. INTRODUCTION ONEOK Gas Gathering, L.L.C. (OGG) (applicant), subsidiary of ONEOK, Inc., submitted an application for their second Title V permit renewal, received by Air Quality Division on August 5, 2009. The facility is a booster station for a large natural gas gathering system (SIC 1311). The facility emits more than 100 TPY of a regulated pollutant and is subject to Title V permitting requirements. The facility currently operates under Permit No. 2002-301-TVR, issued on May 19, 2005. The facility was originally constructed in 1972, with additional equipment installed in 1973, 1975, and 1978. The additional details concerning the permitting history of the facility can be found in that permit.
PERMIT MEMORANDUM 2009-255-TVR2 DRAFT 2 The following changes were authorized under Permit No. 2002-301-TVR. Glycol dehydration unit D-1, rated for 60 MMSCFD natural gas throughput, was replaced by D-1.2, rated at 10 MMSCFD natural gas throughput and glycol dehydration unit D-3, rated for 25 MMSCFD natural gas throughput, was removed. The designated service of tanks T-1 and T-2 was changed from condensate/water to wastewater. References to the Standard Industrial Code of 4922 were changed to 1311 to reflect that the facility is a gas gathering facility. A federally enforceable limit on benzene was included in the permit. Finally, emissions calculations were adjusted to reflect the changes in equipment and type of service. There was a slight decrease in combustion emissions as a result of removal of D-3. Working/breathing losses, flash gas, and loading losses for emissions of volatile organic compounds (VOCs) from tanks T-1 and T-2 were all eliminated because of the change in designation of service to wastewater. This one change resulted in a decrease in VOC emissions of 50.24 tons per year (TPY). SECTION II. FACILITY/PROCESS DESCRIPTION As noted in the introduction, the facility is a natural gas compression station operated for the primary purpose of gas gathering (SIC 1311). The facility receives field gas from other ONEOK-affiliated gathering facilities/compressors and/or producing wells located in numerous surrounding counties in southeast Oklahoma. The gas is compressed and transported via pipeline to various ONEOK-affiliated locations in eastern Oklahoma for distribution to end users. There are six stationary internal combustion engines in compressor service and two glycol dehydration units. There are two operating scenarios for the facility, one whereby natural gas is treated through triethylene glycol (TEG) dehydration units for moisture removal prior to compression and one whereby the TEG dehydration units are bypassed prior to compression. Only the scenario generating the most emissions is described here. For this scenario, field-grade natural gas is the primary fuel with the engines being operated continuously. Natural gas enters the facility through inlet separators, where free liquids (water) are removed. Wastewater collected from the separator and interstage scrubbers is routed to tanks T-1 and T-2, designated as wastewater storage, and then transported off-site for disposal. Natural gas then flows to the TEG dehydration units where moisture (water entrained in the gas) is removed from the gas prior to compression of the gas. Lean glycol is injected into the top of the contact tower as untreated natural gas enters the bottom. The design parameters of the contact tower and the countercurrent flow of the two streams provides the contact efficiency and retention time sufficient for water to be absorbed by the glycol from the wet gas. The rich (water-laden) glycol is transferred to an accumulator tank and then a reboiler/regenerator where the water is cooked (or distilled) from the glycol. Gas separated in the accumulators is used as fuel. From the reboilers, regenerated lean glycol is pumped back into the contact towers by a natural gas pressure powered injection pump on D-2 and either an electric powered pump (primary) or a gas injection pump (backup) on D-1.2. Vapors generated from the D-1.2 glycol regenerator are vented to Tank T-1 and vapors generated from the D-2 glycol regenerator are vented to an 8 -wide x 12 -long x 4 -deep concrete vault. These vapors contain mostly water and some VOCs with a trace of glycol.
PERMIT MEMORANDUM 2009-255-TVR2 DRAFT 3 The treated gas then passes through six compressor units driven by the six gas-fired reciprocating engines listed below, to compress the gas into the pipeline. Compressed gas is transported offsite by pipeline for distribution. As noted above, alternatively, the inlet gas may bypass the TEG dehydration units and go straight into the compression system. SECTION III. EQUIPMENT Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) in the following outline. EUG 1 Grandfathered/Exempted Internal Combustion Engines EU Point Make/Model Horsepower Maximum RPM Serial # Construct Date C1 S1 Superior 6G-825 600 900 20309 1972 C2 S2 Superior 6G-825 600 900 20310 1972 C3 S3 Superior 8G-825 800 900 20764 1973 C4 S4 Superior 8G-825 800 900 20762 1973 C5 S5 Superior 8G-825 800 900 20763 1973 C6 S6 Superior 8G-825 800 900 273239 1978 EUG 2 Glycol Dehydrators and Reboilers EU Point Make/Model MMBTU/hr Construct Date D-1.2/H-1.2 S7a/S7b Barnharts 0.50 March 2006 D-2/H-2 S8a/S8b Ball-Reid 0.75 1975 D - denotes dehydrator and is associated with VOC emissions from the accumulator tank. H - denotes heater and is associated with combustion emissions and VOC emissions from the regenerator. Tanks T1, T2, T3, T4, T6, and T7 are all non-regulated tanks and processes and were removed from EUG3. T1 and T2 are designated as wastewater service only. The other tanks removed from EUG3 stored unused product having negligible, or essentially no emissions. EUG 3 Tanks EU Point Contents Barrels Gallons T5 S14 Methanol 24 1,000 EUG 4 Fugitives Point Approximate Number of Items Type of Equipment S17 15 Compressor Seals 10 Pump Seals 150 Valves 300 Flanges 20 Relief Valves 5 Open Ended Lines
PERMIT MEMORANDUM 2009-255-TVR2 DRAFT 4 SECTION IV. EMISSIONS Emission estimates for the engines are based on manufacturer s data and operator s experience. Emission estimates for the TEG reboilers are based on continuous operation and emission factors from AP-42 (7/98) Tables 1.4-1 and 1.4-2. Emissions from the TEG regenerator still vents and from the D-1.2 flash tank were calculated using GRI-GLYCalc, Version 4.0. Working/breathing losses, flash gas, and loading losses for emissions of VOCs from tanks T-1 and T-2 were all eliminated because of the change in designation of service to wastewater. Emissions of VOCs for process piping fugitives from valves, seals, flanges, and connections were estimated using component counts and type of service, and EPA s document, 1995 Protocol for Equipment Leak Emission Estimates, EPA-453/R-95-017, Table 2-4, Oil and Gas Production Operations Average Emission Factors. EUG 4 Fugitive VOC Emissions Equipment Emission Factor Emissions % C 3+ * (lb/hr/source) (lb/hr) TPY 15 Compressor Seals 10 0.01940 0.0291 0.1275 10 Pump Seals 10 0.00529 0.0053 0.0232 150 Valves 10 0.00992 0.1488 0.6518 300 Flanges 10 0.00086 0.0258 0.1130 20 Relief valves 10 0.01940 0.0388 0.1699 5 Open Ended Lines 10 0.00441 0.0022 0.0097 Total Fugitive Emissions 0.2500 1.0951 *Recent gas analysis indicates 0.7331% VOC by weight. emissions estimate. 10% used in calculations to provide conservative Emissions Summary NO X CO NMHC Point lb/hr TPY lb/hr TPY lb/hr TPY S1 15.87 69.52 15.87 69.52 0.33 1.45 S2 15.87 69.52 15.87 69.52 0.33 1.45 S3 21.16 92.70 21.16 92.70 0.44 1.93 S4 21.16 92.70 21.16 92.70 0.44 1.93 S5 21.16 92.70 21.16 92.70 0.44 1.93 S6 21.16 92.70 21.16 92.70 0.44 1.93 S7a (1) 0.00 0.00 0.00 0.00 1.11 4.87 S7b 0.05 0.21 0.04 0.18 0.00 0.01 S8a (1) 0.00 0.00 0.00 0.00 0.35 1.52 S8b 0.07 0.32 0.06 0.27 0.00 0.02 S14 0.00 0.00 0.00 0.00 0.00 0.03 S17 0.00 0.00 0.00 0.00 0.25 1.10 TOTAL 116.5 510.37 116.48 510.29 4.13 18.17 (1) Includes BTEX from still vents as discussed below and a 400% contingency for total VOCs.
PERMIT MEMORANDUM 2009-255-TVR2 DRAFT 5 Hazardous Air Pollutant Emissions The TEG dehydration units are used to dry excess moisture from the natural gas. The TEG units use glycol desiccants that emit benzene, toluene, ethyl benzene, xylene (BTEX), and n-hexane absorbed from the natural gas, which are vented from the glycol reboiler vapor stack. These compounds are regulated as hazardous air pollutants (HAPS). Gas analyses submitted with the application indicate that the gas stream does not contain any BTEX. However, gas composition can change over the life of the producing formation or whenever a production well is recompleted in another formation. As noted in the introduction, the applicant requests a federally enforceable limit on benzene. The internal combustion engines have emissions of HAPs, the most significant being formaldehyde. Uncontrolled emissions of formaldehyde from the reciprocating engines were calculated using EPA reference method stack test data conducted on August 17, 2004. Additional information concerning the test is provided in the compliance section of this memorandum. Other HAPs emitted from the reciprocating engines were calculated using the 4- stroke rich-burn factors from AP-42 (7/00), Table 3.2-1. The table below lists estimated HAP emissions for the six engines combined. Pollutant Estimated Emissions lb/hr TPY Benzene 0.05 0.24 Toluene 0.02 0.08 Ethylbenzene 0.00 0.00 Xylene 0.01 0.03 Formaldehyde 0.49 2.12 Acrolein 0.09 0.39 Acetaldehyde 0.10 0.42 Total HAPs 3.28 Modeling for compliance with Subchapter 41 was not required for this permit. However, the results of formaldehyde modeling from the previous permit were retained to demonstrate compliance with the ambient SO 2 standards of Subchapter 31 by analogy. Conclusions concerning SO 2 emissions follow the discussion of formaldehyde. For the first screen model, AQD performed Screen3 modeling to determine the ambient impacts of formaldehyde. Using visually estimated building dimensions and the above emission rate calculated from AP-42, a maximum 24-hour groundlevel concentration (GLC) of 14 μg/m 3 (maximum 1-hr GLC of 35 μg/m 3 ) was obtained. On August 17, 2004, the applicant performed stack testing on Engine No. C-5, one of the 800-hp engines. The results of these tests are discussed in the COMPLIANCE section. A contingency factor was added to the test results for input into screen modeling for each engine to arrive at a total combined formaldehyde emission rate of 0.0610 grams/second (0.48 lbs/hr). Again, screen modeling to determine the ambient impacts of formaldehyde was performed using Screen3, which typically yields conservatively higher GLCs.
PERMIT MEMORANDUM 2009-255-TVR2 DRAFT 6 Point Source (make/model) Stack Parameters/Modeling Results Dia. Flow Velocity (inches) (acfm) (fps) Stack Ht. (feet) Temp. ( F) Emiss. Rate (g/s) 1-hr GLC (μg/m 3 ) S1 Superior 6G-825 23.46 8 3,466 26.4 1,250 0.0083 5.296 S2 Superior 6G-825 23.46 8 3,466 26.4 1,250 0.0083 5.296 S3 Superior 8G-825 26.33 10 4,608 35.2 1,340 0.0111 3.460 S4 Superior 8G-825 26.33 10 4,608 35.2 1,340 0.0111 3.460 S5 Superior 8G-825 26.33 10 4,608 35.2 1,340 0.0111 3.460 S6 Superior 8G-825 26.33 10 4,608 35.2 1,340 0.0111 3.460 Total Emission Rates and GLCs 0.0610 24.432 The total maximum 1-hour impact of the engines combined was calculated to be 24.43 g/m 3 at a distance of 55 meters. Note that this was the emission rate of formaldehyde that was modeled. The six compressor engines burning pipeline grade natural gas with a sulfur content no greater than 343 ppmv would have SO 2 emissions of roughly 2 lbs/hr. Using the ratio of sulfur emissions to formaldehyde emissions and multiplying by the GLC obtained from the modeling illustrates compliance for all SO 2 standards. Averaging Time Multiplying Factor Concentration at 0.5 lbs/hr Concentration at 2 lbs/hr Subchapter 31 Standard 1-hour 1.0 24 g/m 3 96 g/m 3 1,200 g/m 3 3-hour 0.9 22 g/m 3 88 g/m 3 650 g/m 3 8-hour 0.7 17 g/m 3 68 g/m 3 NA 24-hour 0.4 10 g/m 3 40 g/m 3 130 g/m 3 Annual 0.08 2 g/m 3 8 g/m 3 80 g/m 3 SECTION V. TRIVIAL ACTIVITIES The following activities are trivial. Any activity to which a State or federal applicable requirement applies is not trivial even if included on the trivial activities list. No recordkeeping is required for those operations which qualify as Trivial Activities. 1. Emissions from lube oil, seal oil, or hydraulic fluid storage tanks and equipment as long as not emitting VOCs or HAPs. Tank T4 stores lube oil. 2. Storage and use of chemicals unless otherwise regulated by an applicable state or federal regulation. These chemicals include, but are not limited to: alum, ammonia, biocides, corrosion inhibitors, dechlorination chemicals, inorganic salts, acids or bases to include caustic and sulfuric acid, coagulants, flocculants, precipitants, surfactants, anti-foam chemicals, sealing inhibitors, oxygen scavengers, phosphates, polyelectrolytes, limestone slurry, lime and lime slurry, flue gas desulfurization system slurry, and sulfur slurry; propane and acetylene under pressure. Storage and use of products or equipment for maintaining motor vehicles operated at the site (including but not limited to antifreeze and fuel additives)
PERMIT MEMORANDUM 2009-255-TVR2 DRAFT 7 not regulated under Title VI, CFC rules). Tank T3 stores unused glycol product. Tank T6 stores corrosion inhibitor. Tank T7 stores biocide. Emissions from any of these tanks would be trivial. 3. Emissions from tanks containing separated water produced from oil and gas operations. Tanks T1 and T2 store produced wastewater associated with oil and gas operations. 4. Lubricants and waxes used for machinery and other equipment lubrication and emission from lubricating oil or hydraulic fluid storage tanks and equipment. Tank T4 stores lube oil. 5. Surface coating for maintenance purposes such as roll/brush/pad coating, painting with aerosol cans, spray airless, and conventional spray painting. 6. Touch-up painting operations where paints/coatings are applied at less than one quart per hour. SECTION VI. INSIGNIFICANT ACTIVITIES The insignificant activities identified and justified in the application are duplicated below. Any activity to which a State or federal applicable requirement applies is not insignificant even if included on the insignificant activities list. Appropriate recordkeeping of activities indicated below with an asterisk (*) is specified in the Specific Conditions. 1. Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 MMBtu/hr heat input (commercial natural gas). 2. * Activities having the potential to emit no more than 5 TPY (actual) of any criteria pollutant. SECTION VII. OKLAHOMA AIR POLLUTION CONTROL RULES OAC 252:100-1 (General Provisions) Subchapter 1 includes definitions but there are no regulatory requirements. [Applicable] OAC 252:100-2 (Incorporation by Reference) [Applicable] This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal Regulations listed in OAC 252:100, Appendix Q. These requirements are addressed in the Federal Regulations section. OAC 252:100-3 (Air Quality Standards and Increments) [Applicable] Subchapter 3 enumerates the primary and secondary ambient air quality standards and the significant deterioration increments. At this time, all of Oklahoma is in attainment of these standards. OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Applicable] Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission inventories annually, and pay annual operating fees based upon total annual emissions of regulated pollutants. Emission inventories were submitted and fees paid for previous years as required.
PERMIT MEMORANDUM 2009-255-TVR2 DRAFT 8 OAC 252:100-8 (Permits for Part 70 Sources) [Applicable] Part 5 includes the general administrative requirements for Part 70 permits. Any planned changes in the operation of the facility that result in emissions not authorized in the permit and that exceed the Insignificant Activities or Trivial Activities thresholds require prior notification to AQD and may require a permit modification. Insignificant activities refer to those individual emission units either listed in Appendix I or whose actual calendar year emissions do not exceed the following limits. 5 TPY of any one criteria pollutant 2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any threshold less than 10 TPY for a HAP that the EPA may establish by rule Emission limitations and operational requirements necessary to assure compliance with all applicable requirements for all sources are taken from the operating permit application, developed from the applicable requirement, or taken from the operating permit. OAC 252:100-9 (Excess Emissions Reporting Requirements) [Applicable] Except as provided in OAC 252:100-9-7(a)(1), the owner or operator of a source of excess emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following working day of the first occurrence of excess emissions in each excess emission event. No later than thirty (30) calendar days after the start of any excess emission event, the owner or operator of an air contaminant source from which excess emissions have occurred shall submit a report for each excess emission event describing the extent of the event and the actions taken by the owner or operator of the facility in response to this event. Request for affirmative defense, as described in OAC 252:100-9-8, shall be included in the excess emission event report. Additional reporting may be required in the case of ongoing emission events and in the case of excess emissions reporting required by 40 CFR Parts 60, 61, or 63. OAC 252:100-13 (Open Burning) [Applicable] Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in this subchapter. OAC 252:100-19 (Particulate Matter (PM)) [Applicable] Section 19-4 regulates emissions of PM from the combustion of fuel in any new and existing fuel-burning unit, with emission limits based on maximum design heat input rating. Fuelburning unit is defined in OAC 252:100-19 as any internal combustion engine or gas turbine, or other combustion device used to convert the combustion of fuel into usable energy. Thus, the compressor engines and the re-boilers on the TEG dehydrator units are subject to the requirements of this subchapter. Appendix C specifies a PM emission limitation of 0.60 lb/mmbtu for all equipment at this facility with a heat input rating of 10 Million BTU per hour (MMBTUH) or less. All fuel-burning equipment at this facility is rated less than 10 MMBtu/hr. AP-42 (7/00), Sec. 3.2 lists the total PM emissions from 4-stroke rich burn natural gas-fired engines to be 0.0095 lbs/mmbtu, which demonstrates compliance for the engines. Table 1.4-1 lists natural gas TPM emissions to be 7.6 lbs/million scf or about 0.0076 lbs/mmbtu, which demonstrates compliance for the TEG unit reboilers.
PERMIT MEMORANDUM 2009-255-TVR2 DRAFT 9 OAC 252:100-25 (Visible Emissions and Particulates) [Applicable] No discharge of greater than 20% opacity is allowed except for short-term occurrences that consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. When burning natural gas there is very little possibility of exceeding these standards. OAC 252:100-29 (Fugitive Dust) [Applicable] No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the property line on which the emissions originated in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or to interfere with the maintenance of air quality standards. Under normal operating conditions, this facility has negligible potential to violate this requirement; therefore it is not necessary to require specific precautions to be taken. OAC 252:100-31 (Sulfur Compounds) [Applicable] Part 2 limits emissions of sulfur dioxide from any one existing source or any one new petroleum and natural gas process source subject to OAC 252:100-31-26(a)(1). Ambient air concentrations of sulfur dioxide at any given point shall not be greater than 1,300 g/m 3 in a 5-minute period of any hour; 1,200 g/m 3 for a 1-hour average; 650 g/m 3 for a 3-hour average; 130 g/m 3 for a 24- hour average; or 80 g/m 3 for an annual average. The six compressor engines burning pipeline grade natural gas with a sulfur content no greater than 343 ppmv would have SO 2 emissions of roughly 2 lbs/hr. As discussed previously, modeling was done for the previous permit. Using the ratio of sulfur emissions to formaldehyde emissions and multiplying by the GLC obtained from the modeling illustrates compliance for all SO 2 standards. Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1, 1972). For gaseous fuels the limit is 0.2 lb/mmbtu heat input averaged over 3 hours. For fuel gas having a gross calorific value of approximately 1,000 Btu/scf, this limit corresponds to fuel sulfur content of approximately 1,203 ppmv. Thus, the limitation of 343 ppmv sulfur in a field gas supply imposed to maintain compliance with the Part 2 SO 2 ambient standard for existing engines will be in compliance with this part for new engines. The permit requires the use of pipeline-grade natural gas or field gas with a maximum sulfur content of 343 ppmv for all fuelburning equipment to ensure compliance with Subchapter 31. OAC 252:100-33 (Nitrogen Oxides) [Not Applicable] This subchapter affects gray iron cupolas, blast furnaces, basic oxygen furnaces, petroleum catalytic cracking units, and petroleum catalytic reforming units. There are no affected sources. OAC 252:100-35 (Carbon Monoxide) [Not Applicable] None of the following affected processes are located at this facility: gray iron cupola, blast furnace, basic oxygen furnace, petroleum catalytic cracking unit, or petroleum catalytic reforming unit.
PERMIT MEMORANDUM 2009-255-TVR2 DRAFT 10 OAC 252:100-37 (Volatile Organic Compounds) [Part 7 Applicable] Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with an organic vapor recovery system. There are no tanks storing either product or wastes meeting this criteria. Part 3 requires VOC loading facilities with a throughput equal to or less than 40,000 gallons per day to be equipped with a system for submerged filling of tank trucks or trailers if the capacity of the vehicle is greater than 200 gallons. This requirement does not apply to this facility because it was built prior to the effective date and no VOC loading is conducted. Part 5 limits the VOC content of coating used in coating lines or operations. This facility will not normally conduct coating or painting operations except for routine maintenance of the facility and equipment, which is not an affected operation. Part 7 also regulates water effluent separators that receive water containing more than 200 gallons per day of VOC. There is no water effluent separator at this location. OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Applicable] This subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in areas of concern (AOC). Any work practice, material substitution, or control equipment required by the Department prior to June 11, 2004, to control a TAC, shall be retained, unless a modification is approved by the Director. Since no AOC has been designated there are no specific requirements for this facility at this time. OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable] This subchapter provides general requirements for testing, monitoring and recordkeeping and applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To determine compliance with emissions limitations or standards, the Air Quality Director may require the owner or operator of any source in the state of Oklahoma to install, maintain and operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All required testing must be conducted by methods approved by the Air Quality Director and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests. Emissions and other data required to demonstrate compliance with any federal or state emission limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any required testing or monitoring not conducted in accordance with the provisions of this subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. The following Oklahoma Air Pollution Control Rules are not applicable to this facility: OAC 252:100-11 Alternative Reduction not eligible OAC 252:100-15 Mobile Sources not in source category OAC 252:100-17 Incinerators not type of emission unit OAC 252:100-23 Cotton Gins not type of emission unit
PERMIT MEMORANDUM 2009-255-TVR2 DRAFT 11 OAC 252:100-24 Feed & Grain Facility not in source category OAC 252:100-39 Nonattainment Areas not in a subject area OAC 252:100-47 Landfills not in source category SECTION VIII. FEDERAL REGULATIONS PSD, 40 CFR Part 52 [Not Applicable] This is an existing PSD Major Source. PSD does not apply to this project since there are no emission increases. The significance levels for the applicable pollutants are CO - 100 TPY, NO X - 40 TPY, SO 2-40 TPY, VOC - 40 TPY, PM - 25 TPY, PM 10-15 TPY, LEAD - 0.06 TPY. NSPS, 40 CFR Part 60 [Not Applicable] Subparts K, Ka, Kb, VOL Storage Vessels. The methanol (1,000-gallon) storage tank is less than the applicable thresholds for these rules and is therefore not subject. Tanks T1 and T2 store produced wastewater. Subpart GG affects stationary gas turbines. There are none at this facility. Subpart KKK sets standards for natural gas processing plants which are defined as any site engaged in the extraction of natural gas liquids from field gas, fractionation of natural gas liquids, or both. This site does not engage in this type of activity. Subpart LLL, Onshore Natural Gas Processing: SO 2 Emissions. This subpart affects sweetening units and sweetening units followed by sulfur recovery units. This facility does not have a sweetening unit. Subpart JJJJ, Stationary Spark Ignition Internal Combustion Engines (SI-ICE), promulgates emission standards for all new SI engines ordered after June 12, 2006, and all SI engines modified or reconstructed after June 12, 2006, regardless of size. None of the engines at this facility were constructed, modified, or reconstructed after the effective date of the rule. NESHAP, 40 CFR Part 61 [Not Applicable] There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium, coke oven emissions, mercury, radionuclides, or vinyl chloride except for trace amounts of benzene. Subpart J, Equipment Leaks of Benzene, concerns only process streams that contain more than 10% benzene by weight. Analysis of Oklahoma natural gas indicates a maximum benzene content of less than 1%. NESHAP, 40 CFR Part 63 [Subpart HH and ZZZZ Applicable] Subpart HH, Oil and Natural Gas Production Facilities. This subpart applies to triethylene glycol (TEG) dehydration units at area sources and affected emission points that are located at facilities that are major sources of HAP emissions and either process, upgrade, or store hydrocarbons prior to the point of custody transfer or prior to which the natural gas enters the natural gas transmission and storage source category. For the purposes of this subpart, natural gas enters the natural gas transmission and storage source category after the natural gas processing plant, when present. If no natural gas processing plant is present, natural gas enters the natural gas transmission and storage source category after the point of custody transfer. There is no natural gas processing plant and the facility is not located prior to the point of custody transfer. However, AQD considers the first compressor downstream of the wellhead(s)
PERMIT MEMORANDUM 2009-255-TVR2 DRAFT 12 to be a production facility. Even though the TEG dehydration unit at this facility is considered an affected source it is exempt from the requirements of 63.764(c)(1) and (d) since the criteria 63.764(e)(1)(i) or (ii) are met. However, the facility must maintain records of the de minimis determination as required in 63.774(d)(1). The applicable recordkeeping requirements have been incorporated into the permit. Subpart HHH, Natural Gas Transmission and Storage. This subpart affects Natural Gas Transmission and Storage Facilities. It applies to emission points that are located at facilities that are major sources of HAP emissions, as defined in this subpart, and that transport or store natural gas prior to entering the pipeline to a local distribution company or to a final end user. The affected source is each glycol dehydration unit. The owner or operator of a facility that does not contain an affected source is not subject to the requirements of this subpart. The facility is not a major source of HAP emissions and as noted above, this facility is in the production category. Therefore, this subpart does not apply. Subpart EEEE, Organic Liquids Distribution (Non-Gasoline). This subpart affects organic liquid distribution (OLD) operations only at major sources of HAPs with an organic liquid throughput greater than 7.29 million gallons per year (173,571 barrels/yr). No saleable condensate is produced from the facility. Therefore, there are no affected tanks or processes at this facility. Subpart ZZZZ, This subpart affects RICE that are located at sources that are major and area sources of HAP emissions. The facility is an existing area source of HAP emissions and is therefore an affected source under this subpart. However, at this time, the only requirements for area sources are those incorporated from other subparts, including NSPS JJJJ. The engines at this facility were manufactured and installed prior to the affected dates. Therefore, there are no requirements for this facility under either this Subpart ZZZZ or NSPS JJJJ. CAM, 40 CFR Part 64 [Not Applicable] This part applies to any pollutant-specific emission unit at a major source that is required to obtain an operating permit, for any application for an initial operating permit submitted after April 18, 1998, that addresses large emission units, or any application that addresses large emission units as a significant modification to an operating permit, or for any application for renewal of an operating permit, if it meets all of the following criteria. It is subject to an emission limit or standard for an applicable regulated air pollutant It uses a control device to achieve compliance with the applicable emission limit or standard It has potential emissions, prior to the control device, of the applicable regulated air pollutant of 100 TPY No active control devices, as defined by this part, are used at this facility. Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable] This facility will not process or store more than the threshold quantity of any regulated substance (Section 112r of the Clean Air Act 1990 Amendments). The definition of a stationary source does not include naturally occurring hydrocarbon reservoirs. More information on this federal program is available on the web page: www.epa.gov/ceppo.
PERMIT MEMORANDUM 2009-255-TVR2 DRAFT 13 Stratospheric Ozone Protection, 40 CFR Part 82 [Not Applicable] These standards require phase out of Class I & II substances, reductions of emissions of Class I & II substances to the lowest achievable level in all use sectors, and banning use of nonessential products containing ozone-depleting substances (Subparts A & C); control servicing of motor vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations which meet phase out requirements and which maximize the substitution of safe alternatives to Class I and Class II substances (Subpart D); require warning labels on products made with or containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons (Subpart H). Subpart A identifies ozone-depleting substances and divides them into two classes. Class I controlled substances are divided into seven groups; the chemicals typically used by the manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform (Class I, Group V). A complete phase-out of production of Class I substances is required by January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs. Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances, scheduled in phases starting by 2002, is required by January 1, 2030. This facility does not utilize any Class I & II substances. SECTION IX. COMPLIANCE Inspection An inspection was conducted on October 19, 2009, by David Pollard of Air Quality, accompanied by Tim Needham of ONEOK. The facility was constructed as represented in the application and was keeping required records. Testing (Formaldehyde) Engine emission tests were conducted on August 17, 2004, for Engine No. C-5, one of the large, 800-hp engines using EPA Method M-323 for formaldehyde, EPA Reference Method 3A for O 2, and EPA Reference Method 19 for mass emission rates. The results of the tests yielded an average hourly emission rate of 0.04 lbs/hr. Tier Classification and Public Review This application has been determined to be a Tier II based on the request for renewal of an operating permit for a major source for which a Title V operating permit is required. The applicant has submitted an affidavit that they are not seeking a permit for land use or for any operation upon land owned by others without their knowledge. The affidavit certifies that the applicant has a current lease or easement which is given to accomplish the permitted purpose.
PERMIT MEMORANDUM 2009-255-TVR2 DRAFT 14 The applicant published the Notice of Filing a Tier II Application in The Stigler News Sentinel, on October 15, 2009. The notice stated that the application was available for public review at the Stigler-Haskell County Library located at 402 NE 6 th Street, Stigler, Oklahoma 74462, or at the Air Quality Division s main office located at 707 North Robinson, Oklahoma City, Oklahoma. No comments were received on the application. This site is not within 50 miles of another states border. The status of all permit actions is available to the public in the Air Quality section of the DEQ Web Page at http://www.deq.state.ok.us. Fee Paid Title V renewal application fee of $1,000. SECTION X. SUMMARY This facility was constructed as described in the application. There are no active Air Quality compliance or enforcement issues that would affect the issuance of this permit. Issuance of the operating permit is recommended, contingent on Public and EPA review.
DRAFT PERMIT TO OPERATE AIR POLLUTION CONTROL FACILITY SPECIFIC CONDITIONS ONEOK Gas Gathering, L.L.C. McCurtain Compressor Station Permit Number 2009-255-TVR2 The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on August 5, 2009. The Evaluation Memorandum dated November 2, 2009, explains the derivation of applicable permit requirements and estimates of emissions; however, it does not contain operating limitations or permit requirements. Continuing operations under this permit constitutes acceptance of, and consent to, the conditions contained herein: 1. Points of emissions and limitations for each point: [OAC 252:100-8-6(a)(1)] EUG 1: Emission units C1 and C2 are grandfathered (constructed prior to any applicable rule). Emission units C3, C4, C5, and C6 were exempted by regulation. For these internal combustion engines, there are no emission limits but they are limited to the existing equipment items as they are. EU Point Make/Model Hp Maximum RPM Serial # C1 S1 Superior 6G-825 600 900 20309 C2 S2 Superior 6G-825 600 900 20310 C3 S3 Superior 8G-825 800 900 20764 C4 S4 Superior 8G-825 800 900 20762 C5 S5 Superior 8G-825 800 900 20763 C6 S6 Superior 8G-825 800 900 273239 EUG 2: Glycol dehydrator D-2 is grandfathered (constructed prior to any applicable rule) and is limited to the existing equipment items as it is. EUG 2 Glycol Dehydrators and Reboilers EU Point Make/Model MMBTU/hr Construct Date D-1.2/H-1.2 S7a/S7b Barnharts 0.50 March 2006 D-2/H-2 S8a/S8b Ball-Reid 0.75 1975 a. The dehydration units are exempt from the requirements of 63.764(c)(1) and (d) provided the following criteria continue to be met. i. 63.764(e)(1)(i) The actual annual average flowrate of natural gas to each glycol dehydration unit is less than 85 thousand standard cubic meters per day (3 million standard cubic feet) as determined by the procedures specified in 63.772(b)(1); OR ii. The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0.90 megagram per year (0.99 tons per year), as determined by the procedures specified in 63.772(b)(2).
SPECIFIC CONDITIONS 2009-255-TVR2 DRAFT 2 iii. Permittee shall maintain records of the de minimis determination as required in 63.774(d)(1). NO X CO VOC EU lb/hr TPY lb/hr TPY lb/hr TPY D-1.2 1.11 4.87 H-1.2 0.05 0.21 0.04 0.18 0.00 0.01 EUG 3: Storage tank VOC emissions are estimated based on existing equipment items but do not have a specific limitation. EU Point Contents Barrels Gallons T5 S14 Methanol 24 1,000 EUG 4: Fugitive VOC emissions are estimated based on existing equipment items but do not have a specific limitation. Point Approximate Number of Items Type of Equipment S17 15 Compressor Seals 10 Pump Seals 150 Valves 300 Flanges 20 Relief Valves 5 Open Ended Lines 2. The fuel-burning equipment shall be fired with natural gas as defined in NSPS GG/KKKK having 343 ppmv or less total sulfur. Compliance can be shown by the following methods: a current gas company bill, lab analysis, stain-tube analysis, gas contract, tariff sheet, or other approved methods. Compliance shall be demonstrated at least once annually. [OAC 252:100-31] 3. The permittee shall be authorized to operate this facility continuously (24 hours per day, every day of the year). [OAC 252:100-8-6(a)] 4. Each piece of fuel-burning equipment (except the dehydrator units) shall have a permanent identification plate attached, which shows the make, model number, and serial number. [OAC 252:100-43] 5. The permittee shall keep records of operations as listed below to verify Insignificant Activities. These records shall be kept on-site for a period of at least five years following dates of recording and shall be made available to regulatory personnel upon request. No recordkeeping is required for those operations which qualify as Trivial Activities. [OAC 252:100-8-6 (a)(3)(b)] a. Activities having the potential to emit no more than 5 TPY (actual) of any criteria pollutant.
SPECIFIC CONDITIONS 2009-255-TVR2 DRAFT 3 6. The permittee shall maintain records of operations as listed below. These records shall be maintained on-site or at a local field office for at least five years after the date of recording and shall be provided to regulatory personnel upon request. [OAC 252:100-43], [OAC 252:100-8-6(a)(3)(B)] a. Operation and maintenance (O&M) records for those grandfathered/exempted emission units identified in EUG 1, which have not been modified. Such records shall at a minimum include the dates of operation, maintenance, type of work performed, and the increase, if any, in emissions as a result. b. Records, as described in Specific Condition No. 2, to demonstrate compliance with OAC 252:100-31, updated annually or when the gas supply source changes. c. Records required by NESHAP Subpart HH. 7. No later than 30 days after each anniversary date of the issuance of the original Title V permit (February 6, 1998), the permittee shall submit to Air Quality Division of DEQ, with a copy to the US EPA, Region 6, a certification of compliance with the terms and conditions of this permit. [OAC 252:100-8-6(c)(5)(A), (C) & (D)] 8. This permit supersedes all other Air Quality permits for this facility, which are now null and void.
MAJOR SOURCE AIR QUALITY PERMIT STANDARD CONDITIONS (July 21, 2009) SECTION I. DUTY TO COMPLY A. This is a permit to operate / construct this specific facility in accordance with the federal Clean Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. 2-5-112] B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma Department of Environmental Quality (DEQ). The permit does not relieve the holder of the obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or ordinances. [Oklahoma Clean Air Act, 27A O.S. 2-5-112] C. The permittee shall comply with all conditions of this permit. Any permit noncompliance shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement action, permit termination, revocation and reissuance, or modification, or for denial of a permit renewal application. All terms and conditions are enforceable by the DEQ, by the Environmental Protection Agency (EPA), and by citizens under section 304 of the Federal Clean Air Act (excluding state-only requirements). This permit is valid for operations only at the specific location listed. [40 C.F.R. 70.6(b), OAC 252:100-8-1.3 and OAC 252:100-8-6(a)(7)(A) and (b)(1)] D. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. However, nothing in this paragraph shall be construed as precluding consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for noncompliance if the health, safety, or environmental impacts of halting or reducing operations would be more serious than the impacts of continuing operations. [OAC 252:100-8-6(a)(7)(B)] SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS A. Any exceedance resulting from an emergency and/or posing an imminent and substantial danger to public health, safety, or the environment shall be reported in accordance with Section XIV (Emergencies). [OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)] B. Deviations that result in emissions exceeding those allowed in this permit shall be reported consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements. [OAC 252:100-8-6(a)(3)(C)(iv)] C. Every written report submitted under this section shall be certified as required by Section III (Monitoring, Testing, Recordkeeping & Reporting), Paragraph F. [OAC 252:100-8-6(a)(3)(C)(iv)]
MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 2 SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING A. The permittee shall keep records as specified in this permit. These records, including monitoring data and necessary support information, shall be retained on-site or at a nearby field office for a period of at least five years from the date of the monitoring sample, measurement, report, or application, and shall be made available for inspection by regulatory personnel upon request. Support information includes all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. Where appropriate, the permit may specify that records may be maintained in computerized form. [OAC 252:100-8-6 (a)(3)(b)(ii), OAC 252:100-8-6(c)(1), and OAC 252:100-8-6(c)(2)(B)] B. Records of required monitoring shall include: (1) the date, place and time of sampling or measurement; (2) the date or dates analyses were performed; (3) the company or entity which performed the analyses; (4) the analytical techniques or methods used; (5) the results of such analyses; and (6) the operating conditions existing at the time of sampling or measurement. [OAC 252:100-8-6(a)(3)(B)(i)] C. No later than 30 days after each six (6) month period, after the date of the issuance of the original Part 70 operating permit or alternative date as specifically identified in a subsequent Part 70 operating permit, the permittee shall submit to AQD a report of the results of any required monitoring. All instances of deviations from permit requirements since the previous report shall be clearly identified in the report. Submission of these periodic reports will satisfy any reporting requirement of Paragraph E below that is duplicative of the periodic reports, if so noted on the submitted report. [OAC 252:100-8-6(a)(3)(C)(i) and (ii)] D. If any testing shows emissions in excess of limitations specified in this permit, the owner or operator shall comply with the provisions of Section II (Reporting Of Deviations From Permit Terms) of these standard conditions. [OAC 252:100-8-6(a)(3)(C)(iii)] E. In addition to any monitoring, recordkeeping or reporting requirement specified in this permit, monitoring and reporting may be required under the provisions of OAC 252:100-43, Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean Air Act or Oklahoma Clean Air Act. [OAC 252:100-43] F. Any Annual Certification of Compliance, Semi Annual Monitoring and Deviation Report, Excess Emission Report, and Annual Emission Inventory submitted in accordance with this permit shall be certified by a responsible official. This certification shall be signed by a responsible official, and shall contain the following language: I certify, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. [OAC 252:100-8-5(f), OAC 252:100-8-6(a)(3)(C)(iv), OAC 252:100-8-6(c)(1), OAC 252:100-9-7(e), and OAC 252:100-5-2.1(f)]
MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 3 G. Any owner or operator subject to the provisions of New Source Performance Standards ( NSPS ) under 40 CFR Part 60 or National Emission Standards for Hazardous Air Pollutants ( NESHAPs ) under 40 CFR Parts 61 and 63 shall maintain a file of all measurements and other information required by the applicable general provisions and subpart(s). These records shall be maintained in a permanent file suitable for inspection, shall be retained for a period of at least five years as required by Paragraph A of this Section, and shall include records of the occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected facility, any malfunction of the air pollution control equipment; and any periods during which a continuous monitoring system or monitoring device is inoperative. [40 C.F.R. 60.7 and 63.10, 40 CFR Parts 61, Subpart A, and OAC 252:100, Appendix Q] H. The permittee of a facility that is operating subject to a schedule of compliance shall submit to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for achieving the activities, milestones or compliance required in the schedule of compliance and the dates when such activities, milestones or compliance was achieved. The progress reports shall also contain an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventive or corrective measures adopted. [OAC 252:100-8-6(c)(4)] I. All testing must be conducted under the direction of qualified personnel by methods approved by the Division Director. All tests shall be made and the results calculated in accordance with standard test procedures. The use of alternative test procedures must be approved by EPA. When a portable analyzer is used to measure emissions it shall be setup, calibrated, and operated in accordance with the manufacturer s instructions and in accordance with a protocol meeting the requirements of the AQD Portable Analyzer Guidance document or an equivalent method approved by Air Quality. [OAC 252:100-8-6(a)(3)(A)(iv), and OAC 252:100-43] J. The reporting of total particulate matter emissions as required in Part 7 of OAC 252:100-8 (Permits for Part 70 Sources), OAC 252:100-19 (Control of Emission of Particulate Matter), and OAC 252:100-5 (Emission Inventory), shall be conducted in accordance with applicable testing or calculation procedures, modified to include back-half condensables, for the concentration of particulate matter less than 10 microns in diameter (PM 10 ). NSPS may allow reporting of only particulate matter emissions caught in the filter (obtained using Reference Method 5). K. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required by 40 C.F.R. Part 60, 61, and 63, for all equipment constructed or operated under this permit subject to such standards. [OAC 252:100-8-6(c)(1) and OAC 252:100, Appendix Q] SECTION IV. COMPLIANCE CERTIFICATIONS A. No later than 30 days after each anniversary date of the issuance of the original Part 70 operating permit or alternative date as specifically identified in a subsequent Part 70 operating permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a certification of compliance with the terms and conditions of this permit and of any other applicable requirements which have become effective since the issuance of this permit. [OAC 252:100-8-6(c)(5)(A), and (D)]