State Registration Number Michigan Department of Environmental Quality Air Quality Division RENEWABLE OPERATING PERMIT ROP Number B8337 STAFF REPORT MI-ROP-B8337-2015 ANR PIPELINE COMPANY - MUTTONVILLE COMPRESSOR STATION SRN: B8337 Located at 36555 29 Mile Road, Lenox Township, Macomb, Michigan 48044 Permit Number: MI-ROP-B8337-2015 Staff Report Date: February 9, 2015 This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions of the Renewable Operating Permit (ROP). Page: 1
TABLE OF CONTENTS February 9, 2015 STAFF REPORT 3 March 16, 2015 STAFF REPORT ADDENDUM 8 Page: 2
State Registration Number B8337 Michigan Department of Environmental Quality Air Quality Division RENEWABLE OPERATING PERMIT February 9, 2015 STAFF REPORT ROP Number MI-ROP-B8337-2015 Purpose Major stationary sources of air pollutants, and some non-major sources, are required to obtain and operate in compliance with an ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan s Administrative Rules for Air Pollution Control pursuant to Section 5506(1) of Act 451. Sources subject to the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a stationary source s applicable requirements and compliance with them by consolidating all state and federal air quality requirements into one document. This Staff Report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the draft ROP terms and conditions including citations of the underlying applicable requirements, an explanation of any equivalent requirements included in the draft ROP pursuant to Rule 212(5), and any determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the stationary source. General Information Stationary Source Mailing Address: ANR Pipeline Company - Muttonville Compressor Station 36555 29 Mile Road Lenox Township, Michigan 48044 Source Registration Number (SRN): B8337 North American Industry Classification System 486210 (NAICS) Code: Number of Stationary Source Sections: 1 Is Application for a Renewal or Initial Issuance? Renewal Application Number: 201400114 Responsible Official: Mr. Randall Schmidgall Vice President, U.S. Gas Pipeline and Storage Operations 832-320-5511 AQD Contact: Mr. Erik Gurshaw, Environmental Quality Analyst 586-753-3743 Date Application Received: July 14, 2014 Date Application Was Administratively Complete: July 31, 2014 Is Application Shield In Effect? Yes Date Public Comment Begins: February 9, 2015 Deadline for Public Comment: March 11, 2015 Page: 3
Source Description ANR Pipeline Company is a subsidiary of TransCanada Corporation. ANR's Muttonville Compressor Station stores pipeline quality natural gas during the spring and summer months and withdraws the same gas during the fall and winter months as it is needed for residential and commerical heating purposes. The gas is supplied by Great Lakes Gas Transmission Company. The natural gas is stored in the Gray Niagaran Formation at a depth of approximately 1,600 feet. The natural gas field is approximately onequarter of a mile wide, three-quarters of a mile long, and twenty five feet thick. The facility has two 3200 HP, 2 stroke lean burn natural gas-fired reciprocating internal combustion engines (RICEs) which drive compressors to pump natural gas into and out of the underground storage cavern. Natural gas is pumped into the Gray Niagaran Formation from early March until early November and is withdrawn from early November until early March of the following year. The flow of natural gas into the pipelines is initially free flow during the withdrawal season, but the gas has to be pumped out later in the season as the pressure within the storage cavity decreases. During the storage period, the natural gas absorbs hydrocarbons and moisture while in the formation. To comply with federal regulations, the natural gas must be dehydrated prior to being pumped back into the pipelines. The facility has installed a glycol dehydration system to treat natural gas prior to it being sent into the pipeline system. In the glycol dehydration process, natural gas is pumped into one of two towers where it crosses a series of glycol trays. The glycol in these trays absorbs moisture and hydrocarbons in the natural gas and the clean gas is then sent to a Great Lakes Transmission Company pipeline. The rich (dirty) glycol containing moisture and hydrocarbons accumulates at the bottom of each tower and is sent to a 3-Phase Separator which separates heavy hydrocarbons from the glycol. From the 3-Phase Separator, the resulting glycol is sent through a particulate filter, a charcoal filter, and another particulate filter before being sent to a reboiler unit. The reboiler drives off water from the glycol at 375 to 385 degrees Fahrenheit. The resulting clean glycol (lean glycol) is recirculated back to the glycol towers. The water vapor from the reboiler is condensed and sent to a condensate tank. Vapors from the condensate tank are sent to the thermal oxidizer. Condensate is pumped from the condensate tanks to one of two brine tanks when necessary. Either the thermal oxidizer or the condenser is required to be in operation when the glycol dehydration system is being used. The condenser is only used during thermal oxidizer malfunction events. The following table lists stationary source emission information as reported to the Michigan Air Emissions Reporting System (MAERS) in the 2013 submittal. TOTAL STATIONARY SOURCE EMISSIONS Pollutant Tons per Year Carbon Monoxide (CO) 2.36 Lead (Pb) 0 Nitrogen Oxides (NO x ) 18.18 Particulate Matter (PM) 0.29 Sulfur Dioxide (SO 2 ) 0.005 Volatile Organic Compounds (VOCs) 1.06 Individual Hazardous Air Pollutants (HAPs) ** NA Total Hazardous Air Pollutants (HAPs) 0.45 **As listed pursuant to Section 112(b) of the federal Clean Air Act. In addition to the pollutants listed above that have been reported in MAERS, the potential to emit of Greenhouse Gases (GHG) in tons per year of CO2e (carbon dioxide equivalents) is less than 100,000. CO2e is a calculation of the combined global warming potentials of six GHG (carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride). Page: 4
See Parts C and D in the ROP for summary tables of all processes at the stationary source that are subject to process-specific emission limits or standards. Regulatory Analysis The following is a general description and history of the source. Any determinations of regulatory nonapplicability for this source are explained below in the Non-Applicable Requirement part of the Staff Report and identified in Part E of the ROP. The stationary source is located in Macomb County, which is currently designated by the U.S. Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants. The stationary source is subject to Title 40 of the Code of Federal Regulations (CFR), Part 70, because the potential to emit of carbon monoxide and nitrogen oxides exceeds 100 tons per year. The facility is also considered a major source of Hazardous Air Pollutants (HAPs) because it has the potential to emit more than 10 tons of formaldehyde per year and has the potential to emit more than 25 tons of aggregate HAPs per year. No emission units at the stationary source are currently subject to the Prevention of Significant Deterioration (PSD) regulations of Part 18, Prevention of Significant Deterioration of Air Quality of Act 451 or 40 CFR 52.21 because the process equipment was constructed/installed prior to June 19, 1978, the promulgation date of the PSD regulations. EUGLYCDEHYDE is subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart HHH for Natural Gas Transmission and Storage Facilities since it is considered to be an existing small glycol dehydration unit at a major source of Hazardous Air Pollutants. A small glycol dehydration unit is defined as a unit with an actual annual average natural gas flow rate of less than 283.0 thousand standard cubic meters per day or actual annual average benzene emissions of less than 0.90 Mg/year as determined pursuant 40 CFR 63.1282(a). NESHAP Subpart HHH was modified on October 15, 2012, to include small glycol dehydration units meeting the aforementioned criteria. The effective compliance date of the rule is October 15, 2015. EUCOMPENGINE1 and EUCOMPENGINE2 are Clark Model TLAD8 natural gas-fired 3,200 horsepower engines which were installed in January 1975 and January 1976, respectively. These engines are subject to the NESHAP for Stationary Reciprocating Internal Combustion Engines (RICE) promulgated in 40 CFR Part 63, Subparts A and ZZZZ since they are existing (constructed prior to December 19, 2002) 2-stroke lean-burn RICEs with site ratings of greater than 500 horsepower. The standard, however, exempts existing two-cycle, learn burn RICE engines with greater than 500 horsepower located at a major source of HAP emissions from the emission and operating limitations of the regulation. EUCOMPENGINE1 and EUCOMPENGINE2 are not subject to Subpart to the New Source Performance Standards (NSPS) for Stationary Spark Ignition Internal Combustion Engines since they were manufactured prior to June 12, 2006. EUMVGENERATOR is a Waukesha Model L1616GSIU 402 horsepower four-stroke rich burn natural gas-fired, spark ignited emergency generator used by the station in the event of a power outage. The generator was installed in 1974 and is, therefore, considered to be an existing engine subject to the RICE NESHAP promulgated in 40 CFR Part 63, Subparts A and ZZZZ. Specifically, the engine is subject to the operating requirements within this subpart. EUMVGENERATOR was listed as being exempt from Permit to Install requirements in the company s previous ROP application, but was included in the ROP renewal application since NESHAP Subpart ZZZZ became applicable to it during the renewal cycle. EUMVGENERATOR is not subject to Subpart to the New Source Performance Standards (NSPS) for Stationary Spark Ignition Internal Combustion Engines since it was manufactured prior to June 12, 2006. Page: 5
EUMVBOILER1 and EUMVHEATERS are classified as existing sources by NESHAP Subpart DDDDD for Industrial, Commercial, and Institutional Boilers and Process Heaters. EUMVBOILER1 is a 4.2 MMBtu/ hour Kewanee FK2.0-952-G natural gas-fired boiler installed in 1974. EUHEATERS are 3 6.5 MMBtu/hr Sivalls natural gas-fired heaters used during free-flow natural gas withdrawal to heat the gas stream prior to pressure regulation. EUBOILER1 and EUHEATERS are subject to tune-up, a facility energy assessment, and reporting and recordkeeping requirements by the compliance deadline of January 31, 2016, of NESHAP Subpart DDDDD. EUMVBOILER1 and EUMVHEATERS were listed as being exempt from Permit to Install requirements in the company s previous ROP application, but they were included in the ROP renewal application since NESHAP Subpart DDDDD became applicable to them during the renewal cycle. The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all applicable requirements and are consistent with the "Procedure for Evaluating Periodic Monitoring Submittals." No emission units are subject to the federal Compliance Assurance Monitoring rule under 40 CFR Part 64, because all emission units at the stationary source either do not have a control device or those with a control device do not have potential pre-control emissions over the major source thresholds. Please refer to Parts B, C and D in the draft ROP for detailed regulatory citations for the stationary source. Part A contains regulatory citations for general conditions. Source-wide Permit to Install (PTI) Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a footnote designation in the integrated ROP/PTI document. The following table lists all individual PTIs that were incorporated into previous ROPs. PTIs issued after the effective date of ROP No. MI-ROP-B8337-2010 are identified in Appendix 6 of the ROP. 579-96 PTI Number Streamlined/Subsumed Requirements This ROP does not include any streamlined/subsumed requirements pursuant to Rules 213(2) and 213(6). Non-applicable Requirements Part E of the ROP lists requirements that are not applicable to this source as determined by the AQD, if any were proposed in the ROP Application. These determinations are incorporated into the permit shield provision set forth in Part A (General Conditions 26 through 29) of the ROP pursuant to Rule 213(6)(a)(ii). Processes in Application Not Identified in Draft ROP The following table lists processes that were included in the ROP Application as exempt devices under Rule 212(4). These processes are not subject to any process-specific emission limits or standards in any applicable requirement. Page: 6
Exempt Emission Unit ID Description of Exempt Emission Unit Rule 212(4) Exemption Rule 201 Exemption EUMVSPACEHEATER1 Three (3) 0.01 MMBtu/hour R 336.1212(4)(b) R 336.1282(b)(i) natural gas-fired Bruest space heaters EUMVSPACEHEATER2 0.024 MMBtu/hour natural gasfired R 336.1212(4)(b) R 336.1282(b)(i) Bruest space heater EUMVSPACEHEATER3 0.025 MMBtu/hour natural gasfired R 336.1212(4)(b) R 336.1282(b)(i) Bruest space heater EUMVWTRHEATER1 0.05 MMBtu/hour natural gasfired R 336.1212(4)(b) R 336.1282(b)(i) water heater EUMVAMBITROL 4,700 gallon Ambitrol Tank, T-1 R 336.1212(4)(c) R 336.1284(i) EUMVTEGMAINT 3,700 gallon Maintenance Glycol R 336.1212(4)(c) R 336.1284(i) Tank, T-11 EUMVTEG 9,000 gallon Triethylene Glycol R 336.1212(4)(c) R 336.1284(i) Tank, T-12 EUMVBRINETANKS Two (2) 8,820 gallon Brine R 336.1212(4)(c) R 336.1284(e) Storage Tanks, T-5 and T-6 EULUBE 9,200 gallon Lube Oil Tank, T-7 R 336.1212(4)(c) R 336.1284(e) EULUBEMAINT 1,000 gallon Maintenance Oil R 336.1212(4)(c) R 336.1284(e) Tank, T-8 EUUSEDOIL 1,000 gallon Used Oil Tank, T-9 R 336.1212(4)(c) R 336.1284(e) EUMVCONDENSATE 1,100 gallon Condensate Tank, R 336.1212(4)(c) R 336.1284(e) T-10 EULUBEOIL Two (2) 100 gallon Lube Oil R 336.1212(4)(c) R 336.1284(e) Tanks EUMVTEMPTANK 4,368 gallon Temporary Tank R 336.1212(4)(c) R 336.1284(e) This draft ROP does not contain any terms and/or conditions that the AQD and the applicant did not agree upon pursuant to Rule 214(2). Compliance Status The AQD finds that the stationary source is expected to be in compliance with all applicable requirements as of the effective date of this ROP. Action taken by the MDEQ, AQD The AQD proposes to approve this ROP. A final decision on the ROP will not be made until the public and affected states have had an opportunity to comment on the AQD s proposed action and draft permit. In addition, the USEPA is allowed up to 45 days to review the draft ROP and related material. The AQD is not required to accept recommendations that are not based on applicable requirements. The delegated decision maker for the AQD is Christopher Ethridge, Southeast Michigan District Supervisor. The final determination for ROP approval/disapproval will be based on the contents of the ROP Application, a judgment that the stationary source will be able to comply with applicable emission limits and other terms and conditions, and resolution of any objections by the USEPA. Page: 7
State Registration Number Michigan Department of Environmental Quality Air Quality Division RENEWABLE OPERATING PERMIT ROP Number B8337 March 16, 2015 STAFF REPORT ADDENDUM MI-ROP-B8337-2015 Purpose A Staff Report dated February 9, 2015, was developed in order to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments received on the draft ROP during the 30-day public comment period as described in R 336.1214(3). In addition, this addendum describes any changes to the draft ROP resulting from these pertinent comments. General Information Responsible Official: AQD Contact: Mr. Randall Schmidgall Vice President, U.S. Gas Pipeline and Storage Operations 832-320-5511 Mr. Erik Gurshaw, Environmental Quality Analyst 586-753-3743 Summary of Pertinent Comments No pertinent comments were received during the 30-day public comment period. Page: 8