PERMIT MEMORANDUM 2004-340-O Proposed 2

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM July 1, 2005

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

THROUGH: Ing Yang, P.E., New Source Permits Section

THROUGH: Grover Campbell, P.E., Existing Source Permits Section

THROUGH: Peer Review

FROM: Constance Burris, E.I., Existing Source Permits Section

SUBJECT: Evaluation of Permit Application Number 2004-340-O

Enogex Gas Gathering, L.L.C.

Cox City Compressor Station

SE/4, Section 28, T3N, R5W, Grady County

Directions: From Marlow, drive 13 miles East on Highway 29 to Wrights Corner. Then drive 4 ½ miles North and West into facility.

SECTION I. INTRODUCTION

Enogex Gas Gathering, L.L.C. (Enogex) has requested a renewal of the Title V operating permit for this facility. The facility is currently operating under Permit No. 99-321-TV, which was issued on July 18, 2000. The facility was originally constructed in 1995 and is a natural gas compressor station (SIC 4922) located in an attainment area.

The permitted emission sources are: two 1,100-hp White 8GTLX compressor engines, a 1,085-hp Caterpillar G3516TA compressor engines, two 1,200-hp Waukesha L7042GSI with catalytic converters and air/fuel ratio (AFR) controllers; a 0.35 MMBTUH glycol dehydrator, and two 300-barrel condensate tanks.

The applicant has requested that the Title V renewal permit incorporate the following changes to facility equipment and operations:

·  Remove E-810 (Waukesha L7042GSI with catalytic converter).

·  Remove E-DEH (Glycol Dehydrator Vent).

·  Remove E-HTR1 (Glycol Dehydrator Reboiler).

·  Remove T-2 (300-bbl Condensate Tank).

·  Add two 400-bbl Condensate Tanks (T-2, T-3).

·  Enogex is requesting the status of the facility be changed from a Title V major source to a synthetic minor source.

The removal of E-10, E-DEH, E-HTR1, and T-2 will change the facility’s emissions from 109.94 TPY of NOx, 120.49 TPY of CO, and 42.17 TPY of VOC to 93.17 TPY of NOx, 97.84 TPY of CO, and 62.46 TPY of VOC.

SECTION II. FACILITY DESCRIPTION

The facility currently consists of four compressor engines: two 1,100-hp White 8GTLX, one 1,085-hp Caterpillar G3516TALE, one 1,232-hp Waukesha L7042GSI with catalytic converter and air/fuel ratio (AFR) controller, one 300-bbl condensate tank, two 400-bbl condensate tanks, and various support operations. Field-grade natural gas with less than 159 ppm sulfur is the only fuel used, with the engines being operated continuously.

SECTION III. EQUIPMENT

Internal Combustion Engines

EU
/ Make/Model / hp / Serial # /
Inst. Date
E-195 / White 8GTLX
lean burn / 1,100 /
282809
/ 12/95
E-207 / White 8GTLX
lean burn / 1,100 /
284359
/ 1/98
E-199 / Caterpillar G3516TA
lean burn / 1,085 /
3RC00915
/ 7/98
E-809 / Waukesha L7042GSI
catalytic converter/AFRC / 1,232 /
350572
/ 2/99

Fugitives

Type of Equipment / Number Items
Valves / 220
Flanges / 242
Compressor Seals / 80
Relief Valves / 60
Pump Seals / 20

Tanks

Point
/
Contents
/
Gallons
/
Inst. Date
T-1 / Condensate / 12,600 / 1983
T-2 / Condensate / 16,800 / 2000
T-3 / Condensate / 16,800 / 2000


Condensate Loading

EU
/
Contents
/
Annual Throughput,
gallons/yr
LOAD1 / Condensate / 450,000

SECTION IV. EMISSIONS

Emissions estimates for the White 8GTLX, Caterpillar G3516TA, and the Waukesha L7042GSI compressor engines are based on continuous operation and manufacturers’ data. The stated values are based on optimum engine performance under Enogex’s system conditions and verified by periodic emission testing and monitoring by portable analyzer. Fugitive VOC emissions are based on EPA’s 1995 Protocol for Equipment Leak Emission Estimates (EPA-453/R-95-017), an estimated number of components and VOC content. The VOC emissions for the condensate tanks are estimated using EPA TANKS 4.0 program. The VOC flash emissions are estimated using the Vasquez-Beggs solution gas/oil ratio correlation method. Truck loadout emissions are based on AP-42 (01/95), Section 5.2, “Transportation and Marketing of Petroleum Liquids.”

Emission Factors

Engine / NOx / CO / VOC
g/hp-hr / g/hp-hr / g/hp-hr
Waukesha L7042GSI / 2.50 / 2.00 / 0.15
White 8GTLX / 2.00 / 2.50 / 0.75
Caterpillar G3516TA / 2.00 / 2.00 / 0.48
Total Potential Emissions
Source / NOx / CO / VOC
lb/hr / TPY / lb/hr / TPY / lb/hr /
TPY
E-195, White 8GTLX / 4.85 / 21.24 / 6.06 / 26.55 / 1.82 / 7.97
E-207, White 8GTLX / 4.85 / 21.24 / 6.06 / 26.55 / 1.82 / 7.97
E-199, Caterpillar G3516TA / 4.78 / 20.95 / 4.78 / 20.95 / 1.15 / 5.03
E-809, Waukesha L7042GSI1 / 6.79 / 29.74 / 5.43 / 23.79 / 0.41 / 1.78
TANKS2 / - / - / - / - / - / 32.82
LOAD1 / - / - / - / - / - / 1.28
FUG-1 / - / - / - / - / 1.28 / 5.61
TOTAL
/ 21.27 / 93.17 / 22.33 / 97.84 / 13.97 / 62.46

1With a catalytic converter and air/fuel ratio controller

2Combined emissions from working, breathing losses and flash emissions

Brake-specific fuel consumption for the two White 8GTLX lean burn engines has been listed at 7,100 BTU/hp-hr for a fuel consumption of 7,810 SCFH per engine. Air emissions from each engine are discharged through a stack 12 inches in diameter, 20 feet above grade, at a rate of 7,739 ACFM at 990oF. Moisture content of stack gases has been estimated at 9% from fuel usage and the stoichiometric ratio of two SCF of water per SCF of natural gas fuel.

Brake-specific fuel consumption for the Caterpillar G3516TA lean burn engine has been listed at 7,534 BTU/hp-hr for a fuel consumption of 8,174 SCFH per engine. Air emissions from the engine are discharged through a stack 12 inches in diameter, 20 feet above grade, at a rate of 6,173 ACFM at 862oF. Moisture content of stack gases has been estimated at 11% from fuel usage and the stoichiometric ratio of two SCF of water per SCF of natural gas fuel.

Brake-specific fuel consumption for the Waukesha L7042GSI engine with catalytic converter and air-to-fuel ratio controller has been listed at 7,800 BTU/hp-hr for a fuel consumption of 9,360 SCFH per engine. Air emissions from each engine are discharged through a stack 12 inches in diameter, 20 feet above grade, at a rate of 6,967 ACFM at 1,125oF. Moisture content of stack gases has been estimated at 13.8% from fuel usage and the stoichiometric ratio of two SCF of water per SCF of natural gas fuel.

SECTION V. HAZARDOUS AIR POLLUTANTS AND TOXIC AIR CONTAMINANTS

The rich-burn, internal combustion engines will have emissions of air toxics, the most significant being formaldehyde, a Category “A” air toxic with de minimis threshold levels of 0.57 lb/hr and 0.6 TPY, and a MAAC of 12 mg/m3, 24-hour basis. AP-42, Section 3.2 lists speciated organic compound emission factors for 4-cycle rich-burn and lean-burn natural gas stationary engines. Emissions of formaldehyde for the White 8GTLX engines were calculated using the 4-stroke lean-burn emission factor of 0.0528 lb/MMBTU from AP-42 (7/00), Section 3.2. Emissions of formaldehyde for the Caterpillar G3516TA engine were calculated using an emission factor of 0.29 g/hp-hr based on verbal information provided by Caterpillar. Emissions of formaldehyde for the Waukesha L7042GSI engine were calculated using an emission factor of 0.015 g/hp-hr, based on manufacture’s data and a 70% control efficiency for the catalytic converter. Total formaldehyde emissions are above the de minimis levels.

Formaldehyde Emissions

EU / Source / lb/hr / TPY
E-195 / White 8GTLX / 0.41 / 1.81
E-207 / White 8GTLX / 0.41 / 1.81
E-199 / Caterpillar G3516TA / 0.69 / 3.04
E-809 / Waukesha L7042GSI / 0.04 / 0.18
Total / 1.55 / 6.84


SECTION VI. OKLAHOMA AIR QUALITY 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]

Primary Standards are in Appendix E and Secondary Standards are in Appendix F of the Air Pollution Control Rules. 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 Part 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 C, Subpart Ca, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, and Appendix G. These standards are covered 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. Emission inventories were submitted and fees paid for previous years as required.

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 HAPs will not exceed 10 TPY for any one HAP or 25 TPY for any aggregate of HAPs, the facility is defined as a minor source.

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 or 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]

This subchapter limits particulate emissions from fuel-burning equipment with a rated heat input of 10 MMBTUH and less to 0.6 lb/MMBTU. For 2 cycle/4 cycle engines, AP-42 (7/00), Section 3.2 lists the total PM emissions to be 0.0091 lbs/MMBTU. The permit requires the use of natural gas for all fuel-burning equipment to ensure compliance with Subchapter 19.

This subchapter also limits emissions of PM from industrial processes. Per AP-42 factors, there are no significant PM emissions from any industrial activities at this facility.

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]

No discharge of greater than 20% opacity is allowed except for short-term occurrences which 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 little possibility of exceeding the opacity 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 will not cause a problem in this area, 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 equipment (constructed after July 1, 1972). For gaseous fuels the limit is 0.2 lb/million BTU 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.

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 0.2 lb of NOx per MMBTU. There are no equipment items that exceed the 50 MMBTUH threshold.

OAC 252:100-35 (Carbon Monoxide) [Not Applicable]

This facility has none of the affected sources: 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]

Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400-gallons or more and storing VOC with a vapor pressure above 1.5 psia to be equipped with a permanent submerged fill pipe or with an organic vapor recovery system. The condensate tanks are equipped for bottom fill or submerged fill.

Part 3 requires 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 coatings of used in coating lines or operations. Any painting operation will involve maintenance coatings of buildings and equipment and emit less than 100 Part 7 requires fuel-burning and refuse-burning equipment to be operated to minimize emissions of VOC. The equipment at this location is subject to this requirement.

Part 7 requires pumps or compressors handling VOCs to be equipped with vapor control devices. The equipment at this location is subject to this requirement.

Part 7 requires effluent water separators which receive water containing more than 200-gallons per day of any VOC to be equipped with vapor control devices. There is no effluent water 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.