OKLAHOMA DEPARTMENT OF ENVIRONMENTAL … · Web viewThe gas stream is then compressed by three (3) 1,215-hp Waukesha 5790GL natural gas fired 4-stroke lean-burn compressor engines

DraftOKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITYAIR QUALITY DIVISION

MEMORANDUM May 5, 2005

TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality Division

THROUGH: Eric Milligan, P.E., Existing Source Permits Section

THROUGH: Dale Becker, P.E., New Source Permits Section

THROUGH: Peer Review

FROM: Ellis Fischer, P.E., New Source Permits Section

SUBJECT: Evaluation of Permit Application No. 2003-326-OEnogex Gas Gathering, L.L.C.TRM Compressor Station (SIC 4922)NE1/4 Section 21, T13N, R22W, Roger Mills CountyFrom Cheyenne, Oklahoma, travel six (6) miles east, one (1) mile south, two (2) miles east, then ¼ mile south into facility.

INTRODUCTION

Enogex Gas Gathering, L.L.C. (Enogex) has submitted an application for a minor source operating permit. The facility is currently operating under SOP #20, Option II as determined in Applicability Determination No. 93-207-AD (M-1) issued August 8, 1997. Consent Order No. 02-360 was signed and filed with ODEQ on October 28, 2002 requiring submittal of a Title V operating permit application requesting issuance of a “synthetic minor” source permit for the facility to resolve non-compliance issues. The facility is responsible for compression and dehydration of natural gas that is transported via pipeline (SIC 4922, NAIC 48621). The facility consists of three (3) compressor engines, one (1) glycol dehydrator, one (1) glycol dehydrator reboiler, two (2) condensate storage tanks, and various support operations. Under this permit all the compressor engines will have federally enforceable emission limits and emission control devices. There are no compressor engines that are exempt either by the “Drake” exemption or otherwise “grandfathered” exemptions. Federally enforceable emission limits will allow the facility to remain below major source emissions thresholds and operate as a minor source.

PROCESS DESCRIPTION

The facility is a natural gas gathering compressor station responsible for gas compression into a pipeline. Natural gas dehydration and storage of produced condensate occurs on-site as well. Natural gas is transported to the facility via a pipeline gathering system. The gas stream enters the facility through inlet separators, where produced condensate and some water are removed

DraftPERMIT MEMORANDUM 2003-326-O

from the inlet stream. The gas stream is then compressed by three (3) 1,215-hp Waukesha 5790GL natural gas fired 4-stroke lean-burn compressor engines. After the inlet gas passes through the compressors, the gas enters the glycol dehydrator before exiting the facility for transmission via pipeline.

The glycol dehydrator is used to remove water from the gas before the gas exits the facility. In the dehydration process, gas passes through the contactor vessels where water is absorbed by the glycol. The “rich” glycol containing water goes to the triethylene glycol (TEG), where heat is used to boil off the water. The heat in the reboiler is supplied by a 0.50 MMBtu/hr burner, which exhausts to the atmosphere. The dehydrator still vent currently vents to atmosphere.

In addition to the three (3) compressor engines and one (1) glycol dehydrator with associated reboiler, the facility is equipped with two (2) 400-bbl condensate storage tanks which collect condensate from the inlet separators.

EQUIPMENT

Internal Combustion EnginesEU Make/Model Serial # Const. DateE-1 1,215-hp Waukesha 5790GL (Lean-Burn) C-11154/1 1994E-2 1,215-hp Waukesha 5790GL (Lean-Burn) C-11051/2 1994E-3 1,215-hp Waukesha 5790GL (Lean-Burn) C-10855/1 1994

Glycol Dehydration UnitEU Description MMBTUH Const. DateE-4 Glycol Dehydrator Still Vent N/A 1994E-5 Glycol Dehydrator Reboiler 0.50 1994

TanksEU Contents Gallons Const. Date

E-6 Condensate 16,800 1994E-7 Condensate 16,800 1994

FUG-1 Process Piping (Fugitives)Process Unit Number of Units Const. Date

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Valves/Gas 100 1994Flanges/Gas 110 1994Compressor Seals 40 1994Relief Valves/Gas 25 1994Valves/Liquid 10 1994Flanges/Liquid 11 1994Pump Seals/Liquid 5 1994Relief Valves/Liquid 2 1994Pump Seals/Heavy Liquid 10 1994

L-1 LoadingEU Contents Throughput Gallons Service Type

L-1 Condensate Truck Loading 200,000 Dedicated Normal Service

EMISSIONS

Engines

Emissions estimates for the 1,215-hp Waukesha 5790GL engines are based on continuous operations (8,760 hr/yr for each engine) and manufacturers data for the 1,215-hp Waukesha 5790GL 4-stroke lean-burn compressor engines (NOx = 2.65 g/hp-hr, CO = 2.65 g/hp-hr, VOC = 1.00 g/hp-hr).

Brake-specific fuel consumption for a 1,215-hp Waukesha 5790GL 4-stroke lean-burn compressor engine has been listed at 8,850 SCFH. Air emissions from each engine is discharged through a stack 12 inches in diameter, 19 feet above grade, at a rate of 6,100 ACFM at 679 F. Moisture content of stack gases has been estimated at 10% from fuel usage and the stoichiometric ratio of two SCF of water per SCF of natural gas fuel.

Glycol Dehydrator

Glycol dehydrator regenerator (reboiler) emissions are based on AP-42 (3/98) Chapter 1.4 with glycol dehydrator still vent emissions based on the GRI-GLYCalc 4.0 analysis, with a maximum natural gas flow rate of 22.0 MMSCFD and a maximum glycol circulation flow rate of 3.5 gal/min.

Condensate Tanks

Condensate tank emissions are based on EPA TANKS 4.0 computer software. Tank flashing emissions are based on Vasquez-Beggs Gas to Oil Correlation. The condensate tanks have a combined maximum throughput of 200,000 gallons/year.

Fugitives

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Fugitive VOC emissions are based on EPA’s 1995 “Protocol for Equipment Leak Emission Estimates” (EPA-453/R-95-017, Table 2-4).

Condensate Truck Loading

Condensate truck loading emissions are based on emissions factors from AP-42 (1/95), Section 5.2-4 “Emissions Factors for Petroleum Liquid Rail Tank Cars and Tank Truck”. Annual emissions for all equipment are based on continuous operations.

Total Potential Emissions

EU SOURCE NOx CO VOClb/hr TPY lb/hr TPY lb/hr TPY

E-1 1,215-hp Waukesha 5790GL (Lean-Burn) 7.10 31.09 7.10 31.09 2.68 11.73E-2 1,215-hp Waukesha 5790GL (Lean-Burn) 7.10 31.09 7.10 31.09 2.68 11.73E-3 1,215-hp Waukesha 5790GL (Lean-Burn) 7.10 31.09 7.10 31.09 2.68 11.73E-4 Glycol Dehydrator Still Vent --- --- --- --- 9.14 40.04E-5 Glycol Dehydrator Reboiler 0.05 0.21 0.04 0.18 0.01 0.01

Condensate Tanks w/Flash --- --- --- --- --- 18.92FUG-1 Process Piping Fugitives --- --- --- --- 0.36 1.57L-1 Condensate Truck Loading --- --- --- --- --- 0.57TOTAL 21.35 93.48 21.34 93.45 17.55 96.30

Toxic Air Contaminants

Engines

The internal combustion engine has emissions of toxic air contaminants, the most significant being formaldehyde, a Category A air toxic with de minimis levels of 0.57 lbs/hr and 0.60 TPY, and a MAAC of 12 µg/m3 (24-hr average). Uncontrolled emission of formaldehyde was calculated for a lean-burn 1,215-hp Waukesha 5790GL engine using the 4-stroke lean-burn engine factor of 0.26 g/hp-hr per stack test results including a safety factor. Formaldehyde emissions are above the Category A de minimis level for this source. The table below lists estimated formaldehyde emissions for the compressor engines.

SourceEstimated Emissions

lb/hr TPYThree (3)1,215-hp Waukesha 5790GL Compressor Engines 2.10 9.15

The emission rates of formaldehyde exceeded the Category A de minimis levels for the three (3) 1,215-hp Waukesha L5790GL compressor engines. BACT analysis was submitted by Enogex to show control efficiency, cost analysis, compare available technologies, and environmental impact for the uncontrolled emissions of formaldehyde. Currently, there are no control technologies that have been developed specifically to control HAPs and toxic emissions from

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reciprocating engines. BACT is acceptable for formaldehyde as no add-on control. A facility-wide modeling was conducted for formaldehyde using the SCREEN3 model. The following table shows the results, which are in compliance with MAAC.

MAAC Compliance Modeling Result for Formaldehyde

Pollutant ToxicCategory

Emission Rate Modeled

Impact,g/m3

MAAC,g/m3

In Compliance?

lb/hr TPYFormaldehyd

e A 2.10 9.15 11.29 12.0 Yes

Glycol Dehydrator

Hazardous air pollutants (HAP) emissions were estimated using the GRI GLYCalc 4.0 software program for the glycol dehydrator and a 5% safety factor to account for variability in the natural gas composition, resulting in the following table. Note that total HAP is well below the 10 TPY individual HAP threshold for major status under 40 CFR 63.2. No toxic air contaminant exceeds the OAC 252:100-41 Category A de minimis thresholds.

Pollutant CAS # HAP Toxic Category

De Minimis Levels Estimated Emissionslb/hr TPY lb/hr TPY

n-Hexane 110-54-3 Yes C 5.6 6 1.42 6.2Benzene 71-43-2 Yes A 0.57 0.6 0.10 0.44Toluene 108-88-3 Yes C 5.6 6 0.36 1.57Ethyl-benzene 100-41-4 Yes C 5.6 6 0.03 0.12

Xylene 1330-20-7 Yes C 5.6 6 0.31 1.36

Total HAPs 2.22 9.69

OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable]Subchapter 1 includes definitions but there are no regulatory requirements.

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 252:100-4 (New Source Performance Standards) [Not Applicable]Federal regulations in 40 CFR 60 are incorporated by reference as they existed on July 1, 2002, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B, Subpart

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C, Subpart Ca, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, and Appendix G. These requirements are addressed in the “Federal Regulations” section.

OAC 252:100-5 (Registration, Emission 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. Required annual information (Turn-Around Document) shall be provided to Air Quality.

OAC 252:100-7 (Permits for Minor Facilities) [Applicable]Subchapter 7 sets forth the permit application fees and the basic substantive requirements of permits for minor facilities. Since criteria pollutant emissions are less than 100 TPY for each pollutant, and emissions of Hazardous Air Pollutants (HAP) will not exceed 10 TPY for any one HAP or 25 TPY for any aggregate of HAP, the facility is defined as a minor source. As such, BACT is not required.

OAC 252:100-9 (Excess Emission Reporting Requirements) [Applicable]In the event of any release which results in excess emissions, the owner or operator of such facility shall notify the Air Quality Division as soon as the owner or operator of the facility has knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10) working days after the immediate notice is given, the owner operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility.

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) [Applicable]Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment, with emission limits based on maximum design heat input rating. 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. For heaters, boilers, etc. AP-42 (7/98) Table 1.4-2 lists the total PM emissions for natural gas to be 7.6 lb/MMCF or about 0.0076 lb/MMBTU. The 1,215-hp Waukesha 5790GL 4-stroke lean-burn compressor engines are subject to the requirements of this subchapter. For a 4-stroke lean-burn engine, AP-42 (7/00), Section 3.2 lists the total PM emissions to be 0.00528 lbs/MMBTU. This permit requires the use of natural gas for all fuel-burning equipment to ensure compliance with Subchapter 19.

EU Source Maximum Heat Input, (MMBTUH)

Appendix C Emission Limit, (lbs/MMBTU)

Potential Emission Rate, (lbs/MMBTU)

E-1 1,215-hp Waukesha 5790GL (Lean-Burn) 8.85 0.60 0.0095

E-2 1,215-hp Waukesha 5790GL 8.85 0.60 0.0095

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(Lean-Burn)

E-3 1,215-hp Waukesha 5790GL (Lean-Burn) 8.85 0.60 0.0095

E-5 Glycol Dehydrator Reboiler 0.50 0.60 0.0076

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 originate 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 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 5 limits sulfur dioxide emissions from new petroleum or natural gas process equipment (constructed after July 1, 1972). For gaseous fuels, the limit is 0.2 lb/MMBTU heat input. This is equivalent to approximately 0.2-weight percent sulfur in the fuel gas, which is equivalent to 2,000-ppm sulfur. Thus, a limitation of 159-ppm sulfur in a field gas supply will be in compliance. The permit requires the use of pipeline-grade natural gas or field gas with a maximum sulfur content of 159 ppm for all fuel-burning equipment to ensure compliance with Subchapter 31. Initial compliance testing of the fuel sulfur content and further testing whenever the gas supplier or gas field is changed will be used to ensure compliance with this limitation. Part 5 also limits hydrogen sulfide emissions from new petroleum or natural gas process equipment (constructed after July 1, 1972). Removal of hydrogen sulfide in the exhaust stream, or oxidation to sulfur dioxide, is required unless hydrogen sulfide emissions would be less than 0.3 lb/hr for a two-hour average. An analysis of inlet gas to this facility showed no hydrogen sulfide content.

OAC 252:100-33 (Nitrogen Oxides) [Not Applicable]This subchapter limits new gas-fired fuel-burning equipment with rated heat input greater than or equal to 50 MMBTUH to emissions of 0.20 lbs of NOx per MMBTU, three-hour average. There are no equipment items that exceed the 50 MMBTUH threshold.

OAC 252:100-35 (Carbon Monoxide) [Not Applicable]None of the following affected sources are located at this facility: gray iron cupola, blast furnace, basic oxygen furnace, petroleum catalytic cracking unit or petroleum catalytic reforming unit.

OAC 252:100-37 (Volatile Organic Compounds) [Applicable]

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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. The two 400-bbl condensate tanks at this facility is subject to this part.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 facility does not have the physical equipment (loading arm and pump) to conduct this type of loading. Therefore, this requirement is not applicable. 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 exempt.Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize VOC emissions. Temperature and available air must be sufficient to provide essentially complete combustion. The compressor engines are designed to provide essentially complete combustion of organic materials.Part 7 also requires all rotating pumps or compressors handling VOC to be equipped with mechanical seals or other equipment of equal efficiency. All reciprocating pumps or compressors handling VOC are to be equipped with packing glands that are properly installed and in good working order such that emissions from the drain recovery system are limited to two cubic inches of VOC in any 15 minute period at standard conditions per pump or compressor. The equipment at this location is subject to this requirement.Part 7 also regulates water separators that receive water containing more than 200 gallons per day of VOC. There is no separator at this location.

OAC 252:100-41 (Hazardous Air Pollutants and Toxic Air Contaminants) [Applicable]Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted by reference as they exist on July 1, 2003, with the exception of Subparts B, H, I, K, Q, R, T, W and Appendices D and E, all of which address radionuclides. In addition, General Provisions as found in 40 CFR Part 63, Subpart A, and the Maximum Achievable Control Technology (MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, J, L, M, N, O, Q, R, S, T, U, W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR, SS, TT, UU, VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN, OOO, PPP, QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC, GGGG, HHHH, JJJJ, NNNN, OOOO, QQQQ, RRRR, SSSS, TTTT, UUUU, VVVV, WWWW, XXXX, BBBBB, CCCCC, FFFFF, JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP, QQQQQ, and SSSSS are hereby adopted by reference as they exist on July 1, 2003. These standards apply to both existing and new sources of HAPs. These requirements are covered in the “Federal Regulations” section.Part 5 is a state-only requirement governing toxic air contaminants. New sources (constructed after March 9, 1987) emitting any category “A” pollutant above de minimis levels must perform a BACT analysis, and if necessary, install BACT. All sources are required to demonstrate that emissions of any toxic air contaminant that exceed the de minimis level do not cause or contribute to a violation of the maximum acceptable ambient concentration (MAAC). The initial Part 70 permit and emission estimates submitted for this permit shows that BTEX and n-hexane, and other toxic air contaminant emissions are below their respective category de minimis emission thresholds. No estimate of formaldehyde emissions were required in the initial Part 70

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permit. However, as noted in Section IV above, facility-wide formaldehyde emissions exceed the annual TPY threshold for Category A. The applicant performed ISCST3 modeling to demonstrate that the ground level concentration (GLC) of formaldehyde does not exceed the MAAC.

Pollutant MAAC GLCFormaldehyd

e 12 μg/m3 11.29 μg/m3

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 eligibleOAC 252:100-15 Mobile Sources not in source categoryOAC 252:100-17 Incinerators not type of emission unitOAC 252:100-23 Cotton Gins not type of emission unitOAC 252:100-24 Feed & Grain Facility not in source categoryOAC 252:100-39 Nonattainment Areas not in a subject areaOAC 252:100-47 Landfills not type of source category

FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not Applicable]PSD does not apply.

NSPS, 40 CFR Part 60 [Not Applicable]

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Subpart Kb, VOL Storage Vessels. This subpart regulates hydrocarbon storage tanks larger than 19,813 gallons capacity and built after July 23, 1984. There are no storage tanks greater than 19,813 gallons at the site.Subpart GG affects stationary gas turbines with a heat input at peak load of greater than or equal to 10.7 gigajoules per hour (10 MMBTUH) based on the lower heating value (LHV) of the fuel and that commenced construction, reconstruction, or modification after October 3, 1977. There are no gas turbines at the facility.Subpart VV, Equipment Leaks of VOC in the Synthetic Organic Chemical Manufacturing Industry. The equipment is not in a SOCMI plant.Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. The facility does not engage in natural gas processing.Subpart LLL, Onshore Natural Gas Processing: SO2 Emissions. This subpart affects sweetening units and sweetening units followed by sulfur recovery units. This facility does not have a sweetening unit.

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, only affects process streams that contain more than 10% benzene by weight. All process streams at this facility are below this threshold.

NESHAP, 40 CFR Part 63 [Not Applicable]Subpart HH, Oil and Natural Gas Production Facilities. This facility is not a major source of HAP, as defined in 40 CFR 63.2.Subpart HHH, Natural Gas Transmission and Storage. This facility is not a major source of HAP, as defined in 40 CFR 63.2.Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE), This subpart was published in the Federal Register on June 15, 2004. It affects the following RICE with a site rating greater than 500 brake horsepower and which are located at a major source of HAP emissions: existing, new, and reconstructed spark ignition 4 stroke rich burn (4SRB) RICE, any new or reconstructed spark ignition 2 stroke lean burn (2SLB) or 4 stroke lean burn (4SLB) RICE, or any new or reconstructed compression ignition (CI) RICE. This facility is not a major source of HAPs.

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). More information on this federal program is available on the web page: www.epa.gov/ceppo.

Stratospheric Ozone Protection, 40 CFR Part 82 [Applicable]This facility does not produce, consume, recycle, import, or export any controlled substances or controlled products as defined in this part, nor does this facility perform service on motor (fleet) vehicles that involves ozone-depleting substances. Therefore, as currently operated, this facility is not subject to these requirements. To the extent that the facility has air-conditioning units that apply, the permit requires compliance with Part 82.

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http://www.epa.gov/ceppo


COMPLIANCE

Tier Classification and Public Review

This application has been classified as Tier II based on the Statewide Settlement Consent Order No. 02-360, issued October 28, 2002.

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 notified the current owner of the land on which to accomplish the permitted purpose.

The applicant published the “Notice of Filing a Tier II Application” in the Cheyenne Star, a weekly newspaper, in the City of Cheyenne, Roger Mills County, Oklahoma on October 30, 2003. The notice stated that the application could be reviewed at the Cheyenne Public Library, 201 South Cearlock Avenue in Cheyenne, Oklahoma, or at the Air Quality Division’s main office. A draft permit will be made available for public review in another published notice. This facility is located within 50 miles of the Oklahoma-Texas border. Notice has been provided to the State of Texas of the draft permit.

Information on all permit actions is available for review by the public in the DEQ web page: www.deq.state.ok.us

Inspection

Ellis Fischer, AQD, accompanied by Stephen Henderson, Supervisor Air Quality Environmental Health & Safety of Enogex Gas Gathering, L.L.C., conducted a facility inspection on July 29, 2004. The facility was operating as described in the permit application and supplemental materials. Identification plates with serial numbers are attached to each engine. Records are maintained on-site at the Elk City office, Elk City, OK.

TestingStack testing for each of the 1,215-hp Waukesha 5790GL engines was conducted on February 23 and 26, 2004, and shows compliance with the applicable emission limitations. The test results are shown in the following table.

EU Engine/TurbinePermit Limits Test Results

DateNOx CO NOx COlb/hr lb/hr lb/hr lb/hr

E-1 1,215-hp Waukesha 5790GL (Lean-Burn) 7.10 7.10 0.91 5.96 2/23/04E-2 1,215-hp Waukesha 5790GL (Lean-Burn) 7.10 7.10 1.37 5.75 2/23/04E-3 1,215-hp Waukesha 5790GL (Lean-Burn) 7.10 7.10 1.62 6.95 2/26/04

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Fee PaidPermit application fee of $2,000 ($1,500 for the construction fee and $500 for the operating permit fee).

SECTION IX. SUMMARY

This facility is constructed as described in the permit application and supplemental materials. Ambient air quality standards are not threatened at this site.

There is an active AQD enforcement case (ID #1193) concerning this facility, based upon the fact it was a potential major source operating without a permit. The TRM facility was included in Global Consent Order No. 02-360, which will be partially satisfied by the requirements of this permit. Compliance and Enforcement concur with the issuance of the permit. Issuance of the operating permit is recommended, contingent upon public and EPA review.

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PERMIT TO OPERATEAIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

Enogex Gas Gathering, L.L.C. Permit Number 2003-326-OTRM Compressor Station

The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on June 1, 2004, with supplemental information received at various other times as requested. The Evaluation Memorandum, dated May 5, 2005, explains the derivation of applicable permit requirements and estimates of emissions; however, it does not contain operating limitations or permit requirements. Continuing operation under this permit constitutes acceptance of, and consent to, the conditions contained herein.

1. Points of emissions and emissions limitations for each point:

Total Potential Emissions

EU SOURCE NOx CO VOClb/hr TPY lb/hr TPY lb/hr TPY

E-1 1,215-hp Waukesha 5790GL Compressor Engine 7.10 31.09 7.10 31.09 2.68 11.73E-2 1,215-hp Waukesha 5790GL Compressor Engine 7.10 31.09 7.10 31.09 2.68 11.73E-3 1,215-hp Waukesha 5790GL Compressor Engine 7.10 31.09 7.10 31.09 2.68 11.73E-4 Glycol Dehydrator Still Vent --- --- --- --- 9.14 40.04E-5 Glycol Dehydrator Reboiler 0.05 0.21 0.04 0.18 0.01 0.01

Two (2) 400-bbl Condensate Tanks and Flash --- --- --- --- --- 18.92FUG-1 Process Piping Fugitives --- --- --- --- 0.36 1.57L-1 Condensate Truck Loading --- --- --- --- --- 0.57

2. The fuel-burning equipment shall use pipeline-grade natural gas or field gas with a maximum sulfur content of 159 ppm.

3. The permittee shall be authorized to operate this facility continuously (24 hours per day, every day of the year)

4. Each engine at the facility shall have a permanent identification plate attached which shows the make, model number, and serial number.

5. At least once per calendar quarter, the permittee shall conduct tests of NOx and CO emissions in exhaust gases from each engine and from each replacement engine/turbine that runs for more than 220 hours during that calendar quarter when operating under representative conditions for that period. Annual testing is required for each engine/turbine if it runs for more than 220 hours during a calendar quarter. Engines/turbines shall be tested no sooner than 20 calendar days after the last test. Testing shall be conducted using a portable analyzer in accordance with a protocol meeting the requirements of the latest AQD “Portable Analyzer Guidance” document, or an equivalent method approved by Air Quality. When four consecutive quarterly tests show the

Draft

DraftSPECIFIC CONDITIONS 2003-326-O

engine/turbine to be in compliance with the emissions limitations shown in the permit, then the testing frequency may be reduced to semi-annual testing. Likewise, when the following two consecutive semi-annual tests show compliance, the testing frequency may be reduced to annual testing. Upon any showing of non-compliance with emissions limitations or testing that indicates that emissions are within 10% of the emission limitations, the testing frequency shall revert to quarterly. Reduced testing frequency does not apply to engines with catalytic converters.

6. When engine testing shows emission levels in excess of the lb/hr limits in Specific Condition No. 1, the owner or operator shall comply with the provisions of OAC 252:100-9 for excess emissions during start-up, shutdown, and malfunction of air pollution control equipment. Requirements of OAC 252:100-9 include prompt notification to AQD and prompt commencement of repairs to correct the condition of excess emissions.

7. The permittee shall keep records of operations as listed below. These records shall be retained on-site or at a local field office for a period of at least two years following dates of recording, and shall be made available to regulatory personnel upon request.

a. Periodic testing of the engines for NOx and CO emissions.b. Hours of operation the engines if less than 220 hours per quarter and not tested.c. Gas analysis for current sulfur content (updated whenever supply changes).d. Throughput for the 400-bbl condensate tanks (monthly and 12-month rolling totals).e. The natural gas throughput of the facility (monthly average).

8. All volatile organic compound (VOC) tanks with a capacity of 400 gallons or more and storing a liquid which has a vapor pressure of 1.5 psia or greater shall be equipped with a permanent submerged fill pipe or an organic vapor recovery system.

9. Replacement (including temporary periods of 6 months or less for maintenance purposes), of internal combustion engines or turbines with emissions limitations specified in this permit with engines/turbines of lesser or equal emissions of each pollutant (in lbs/hr and TPY) are authorized under the following conditions.a. The permittee shall notify AQD in writing no later than 10 days after start-up of the

replacement engine(s)/turbine(s). Said notice shall identify the old engine/turbine and shall include the new engine/turbine make and model, horsepower rating, fuel usage, stack flow (ACFM), stack temperature (F), stack height (feet), stack diameter (inches), and pollutant emission rates (g/hp-hr, lb/hr, and TPY) at maximum horsepower for the altitude/location.

b. Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be conducted to confirm continued compliance with NOx and CO emissions limitations. A copy of the first quarter testing shall be provided to AQD within 60 days of start-up of each replacement or additional engine/turbine. The test report shall include the engine fuel usage, stack flow (ACFM), stack temperature (oF ), stack height (feet), stack diameter (inches), and pollutant emissions rates (g/hp-hr, lbs/hr, and TPY) at maximum rated horsepower for the altitude/location.

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DraftSPECIFIC CONDITIONS 2003-326-O

c. Replacement equipment and emissions are limited to equipment and emissions that are not subject to NSPS, NESHAP, or PSD.

10. Total condensate throughput for the two (2) 400-bbl condensate storage tanks shall not exceed 200,000 gallons in any 12-month period.

11. The glycol dehydrator unit shall be installed and operated as follows:a. The lean glycol recirculation rate shall not exceed 3.5 gallons per minute.b. The natural gas throughput of the glycol dehydration unit shall not exceed 22.0

MMSCFD (monthly average).

12. This permit supersedes all previous Air Quality permits for this facility, which are now null and void.

3

Stephen Henderson Permit No. 2003-326-OManager Air Quality, Environmental, Health & Safety Permit Writer: Ellis FischerEnogex Gas Gathering, L.L.C.P. O. Box 24300, MC E656Oklahoma City, OK 73124-0300

SUBJECT: Facility: TRM Compressor StationLocation: NE1/4 Section 21, T13N, R22W, Roger Mills County, OklahomaDate Received: October 22, 2003

Dear Mr. Henderson:

Air Quality Division has completed the initial review of your operating permit application referenced above. This application has been determined to be a Tier II. In accordance with 27A O.S. § 2-14-302 and OAC 252:4-7-13(c) the draft permit is now ready for public review. The requirements for public review of the draft permit include the following steps, which you must accomplish:

1. Publish at least one legal notice (one day) in at least one newspaper of general circulation within the county where the facility is located. (Instructions enclosed).

2. Provide for public review (for a period of 30 days following the date of the newspaper announcement) a copy of the draft permit at a convenient location within the county of the facility.

3. Send AQD a written affidavit of publication for the notice from Item #1 above together with any additional comments or requested changes which you may have for the permit application within 20 days of publication.

After public review, a Proposed Permit will be submitted for EPA review. Contingent on public and EPA review, the permit will be issued as a minor operating permit. The permit review time is hereby tolled pending the receipt of the affidavit of publication. Thank you for your cooperation. If you have any questions, please refer to the permit number above and contact the permit writer at (405) 702-4100.

Sincerely,

Dawson Lasseter, P.E., Chief EngineerAIR QUALITY DIVISION

Enclosurecc: Roger Mills County DEQ Office

Texas Commission on Environmental QualityOperating Permits Division (MC 163)P.O. Box 13087Austin, TX 78711-3087

Subject: Operating Permit No. 2003-326-OEnogex Gas Gathering, L.L.C.TRM Compressor Station (SIC 4922)NE1/4 Section 21, T13N, R22W, Roger Mills CountyDirections: From Cheyenne, Oklahoma, travel six (6) miles east, one (1) mile south, two (2) miles east, then ¼ mile south into facility.Date Received: October 22, 2003Permit Writer: Ellis Fischer

Dear Sir / Madame:

The subject facility has requested an operating permit under 40 CFR Part 70. Air Quality Division has completed the initial review of the application and prepared a draft permit for public review. Since this facility is within 50 miles of the Oklahoma - Texas border, a copy of the proposed permit will be provided to you upon request.

Thank you for your cooperation. If you have any questions, please refer to the permit number above and contact me or the permit writer at (405) 702-4100.

Sincerely,

Dawson Lasseter, P.E.Chief EngineerAIR QUALITY DIVISION

PART 70 PERMIT

AIR QUALITY DIVISIONSTATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY707 N. ROBINSON STREET, SUITE 4100

P.O. BOX 1677OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit Number: 2003-326-O

ENOGEX GAS GATHERING, L.L.C.,

having complied with the requirements of the law, is hereby granted permission to operate

the TRM Compressor Station in NE1/4 Section 21, T13N, R22W, Roger Mills County,

Oklahoma

Subject to the following conditions, attached:

[X] Standard Conditions dated on October 31, 2003

[X] Specific Conditions

_________________________________

Director, Air Quality Division Date

DEQ Form #100-885 Revised 2/15/05

Documents

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL … · Web viewThe gas stream is then compressed by three (3) 1,215-hp Waukesha 5790GL natural gas fired 4-stroke lean-burn compressor engines