PERMIT MEMORANDUM NO. 2004-298-TVR DRAFT 13
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM March 31, 2005
TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality Division
THROUGH: David Schutz, P.E., New Source Permit Section
Ing Yang, P.E., New Source Permit Section
THROUGH: Peer Review
FROM: Grover R. Campbell, P.E., Existing Source Permit Section
SUBJECT: Evaluation of Permit Application No. 2004-298-TVR
Natural Gas Pipeline Company of America
Compressor Station No. 156
Section 14, T7N, R15W, Kiowa County
Located 2 miles south of Mountain View on Hwy 115
SECTION I. INTRODUCTION
Natural Gas Pipeline Company of America (a subsidiary of Kinder Morgan, Inc.) owns and operates Compressor Station 156 (SIC 4922). The facility is an existing major stationary source. The original Part 70 permit, Permit No. 96-372-TV, was issued on April 21, 2000. Permit No. 96-372-TV (M-1) was issued on May 20, 2004 when one of the “grandfathered” engines was replaced with a new permitted engine. The company has requested renewal of the Part 70 permit.
The facility was originally constructed in 1959. The facility consists of two “grandfathered” internal combustion engines in compressor service, one permitted internal combustion engine in compressor service, a 5.25 MMBtu/hr boiler, and miscellaneous tanks. The two “grandfathered” internal combustion engines are 4-stroke lean-burn 3,240-hp Cooper Bessemer LSV-12 engines. The permitted engine is a 4-stroke lean-burn 3,550-hp Caterpillar G3612 engine that is subject to NESHAP Part 63, Subpart ZZZZ.
Changes in this permit from Permit No. 96-373-TV (M-1) include: replaced tank E5/P5 with tank E30/P30, removed tank E9/P9 that never existed, replaced tank E1/P1 with tank E31/P31, updated applicable requirements and specific conditions for engine E5, and general reorganization of the permit specific conditions.
SECTION II. EQUIPMENT
EUG 1. Engines
EU / Point / Make/Model / Hp /Serial #
/ Construction DateE2 / P2 / Cooper Bessemer LSV-12 / 3,240 / 6006 / 1959
E3 / P3 / Cooper Bessemer LSV-12 / 3,240 / 6007 / 1959
E5 / P5 / Caterpillar G3612 * / 3,550 / BKE00238 / 2004
E10 / P10 / Cummins GTA-855 / 270 / 25161449 / 1988
* Replaced “grandfathered” engine Serial # 6008 in 2004. New engine is equipped with AFRC and oxidation catalyst.
EUG 2. Boiler
EU / Point / Make/Model / MMBtu/hr / Construction DateE11 / P11 / Boiler / 5.25 / 1959
EUG 3. Tanks
EU / Point / Contents / GallonsE6 / P6 / Used Oil / 2,538
E7 / P7 / Lube Oil / 9,024
E8 / P8 / Lube Oil / 1,295
E30 / P30 / Ambitrol / 1,515
E31 / P31 / Condensate / 1,000
EUG 4. Fugitives
EU / Point / Number Items / Type of EquipmentE20 / P20 / 200 / Valves
598 / Flanges
30 / Open Ended Lines
12 / Pumps
48 / Other
Condensate Loading
EUG 5. Blowdown
EU / Point / Activity / Construction DateE21 / P21 / Equipment Blowdown / 1959
Stack Parameters
EU / SourceMake/Model / Height,
ft / Diameter,
in / Flow,
ACFM / Temperature,
°F /
E2 / Cooper Bessemer LSV-12 / 50 / 18 / 18,000 / 950
E3 / Cooper Bessemer LSV-12 / 50 / 18 / 18,000 / 950
E5 / Caterpillar G3612 / 47.5 / 24 / 24,300 / 860
E11 / Boiler / 30 / 16 / 656 / 700
SECTION III. EMISSIONS
Criteria Emissions
All emission estimates are based on continuous operation. Potential emission estimates for engines E2 and E3 are based on manufacturer’s emission data for NOX: 11.0 g/hp-hr, CO: 1.4 g/hp-hr, and VOC: 0.44 g/hp-hr. Potential emission estimates for engine E5 are based on manufacturer’s data for NOX: 0.7 g/hp-hr, CO: 2.5 g/hp-hr; and VOC: 0.98 g/hp-hr. Actual emission estimates for engine E5 are based on catalyst manufacturer’s warranted emission reductions of 93% for CO and 80% for formaldehyde. Emission estimates for the boiler are based on continuous operation and AP-42 (7/98), Tables 1.4-1 and 1.4-2. Fugitive VOC emissions are based on EPA’s 1995 Protocol for Equipment Leak Emission Estimates (EPA-453/R-95-017) Table 2-4, estimates of the number of process components, and an estimated fraction of VOC. Emissions from the emergency generator, 8 space heaters, tanks, and blowdown are all insignificant. VOC emissions from the loading of condensate into tank trucks and from the condensate storage tank are both insignificant based on a throughput of 8,760 barrels per year of condensate (95% water and 5% hydrocarbon).
EUG 4. Fugitive VOC Emissions
Equipment / Number of Items / Fraction VOC, wt % / lb/hr / TPYValves / 200 / 10 / 0.20 / 0.88
Flanges / 598 / 10 / 0.051 / 0.23
Pumps / 12 / 10 / 0.034 / 0.15
Open ended lines / 30 / 10 / 0.013 / 0.06
Other / 48 / 10 / 0.093 / 0.41
Total
/ 0.39 / 1.7Total Potential Emissions
EU
/ NOX / CO / VOClb/hr / TPY / lb/hr / TPY / lb/hr / TPY
E2 / 78.6 / 344 / 10.0 / 43.8 / 3.14 / 13.7
E3 / 78.6 / 344 / 10.0 / 43.8 / 3.14 / 13.7
E5 / 5.48 / 24.0 / 19.6 / 85.8 / 7.67 / 33.6
E11 / 0.50 / 2.19 / 0.42 / 1.8 / 0.03 / 0.12
E31 / - / - / - / - / 0.83 / 3.6
Fugitives / - / - / - / - / 0.39 / 1.7
Loading / - / - / - / - / - / 0.11
Total
/ 163 / 714 / 40.0 / 175 / 15.2 / 66.5Controlled Emissions for Engine E5
EU
/Point
/ NOX / CO 2 / VOC 3lb/hr / TPY / lb/hr / TPY / lb/hr / TPY
E5 1 / P5 / 5.48 / 24.0 / 1.37 / 6.00 / 5.14 / 22.5
1. With oxidation catalyst and AFRC.
2. Based on CO reduction of 93%.
3. Based on 80% reduction of formaldehyde and 0% reduction of VOC for total VOC reduction of 33%.
HAP and TAC Emissions
The internal combustion engines have 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 emissions of formaldehyde for engines E2 and E3 were estimated using the 4-stroke lean-burn emission factor of 0.0528 lb/MMBtu from AP-42 (7/00), Table 3.2-2 as verified in “Formaldehyde from Natural Gas Fired Reciprocating Engines and Turbines” by Air Pollution Testing, Inc. (July 2002). A specific fuel consumption of 6,650 Btu/hp-hr was used to calculate a heat input of 21.5 MMBtu/hr for engines E2 and E3. Controlled emissions of formaldehyde for engine E5 were estimated based on engine manufacturer’s data (0.40 g/hp-hr) and the oxidation catalyst manufacturer’s warranted reduction efficiency of 80%. As shown in the following table, total formaldehyde emissions are above de minimis levels.
Ambient impacts of formaldehyde were calculated using the latest version of EPA’s “SCREEN3” air dispersion model. Stack parameters for engines E2 and E3 are: 18 inches diameter, 18,000 ACFM at 950oF, and 50 feet above grade. Stack parameters for engine E5 are: 30 inches diameter, 24,300 ACFM at 860oF, and 48 feet above grade. The compressor engines building dimensions are: 60 feet wide, 40 feet high, and 115 feet long. A maximum 24-hour average ground level concentration (GLC) of 11.6 mg/m3, based on summing the individual engine maxima, demonstrates compliance with the MAAC.
Formaldehyde Emissions from Engines
Source /Description
/Formaldehyde
/ Maximum GLClb/hr / TPY / mg/m3
E2 / 3240-hp Cooper Bessemer LSV-12 / 1.14 / 5.0 / 4.0
E3 / 3240-hp Cooper Bessemer LSV-12 / 1.14 / 5.0 / 4.0
E5 * / 3550-hp Caterpillar G3612 / 0.63 / 2.8 / 3.6
Total / 2.91 / 12.8 / 11.6
* With air-to-fuel ratio controller and oxidation catalyst.
SECTION IV. INSIGNIFICANT ACTIVITIES
The insignificant activities identified and justified in the application are duplicated below. Appropriate record keeping of activities indicated below with “*” is specified in the Specific Conditions.
1. * Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel, which are either used exclusively for emergency power generation or for peaking power service not exceeding 500 hours/year. There is a 270-hp natural gas fired Cummins GTA-855 natural gas fired engine located on-site which is used for emergency power generation.
2. Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 MMBtu/hr heat input using commercial natural gas. There are eight space heaters located on-site which are rated less than 5 MMBtu/hr. Other space heaters, boilers, process heaters, and emergency flares may be used in the future.
3. Emissions from stationary internal combustion engines rated less than 50-hp output. None identified but may be used in the future.
4. * Emissions from storage tanks constructed with a capacity less than 39,894 gallons which store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. The ambitrol and lube oil tanks have capacities less than 39,894 gallons and store products having a vapor pressure less than 1.5 psia.
5. * Activities that have the potential to emit no more than 5 TPY (actual) of any criteria pollutant. A natural gas-fired boiler rated at 5.25 MMBtu/hr, equipment blowdowns, condensate loading, and condensate tank emissions. All these activities have emissions of less than 5 TPY and are located on-site. Other activities may be used in the future.
SECTION V. 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 Part 60 are incorporated by reference as they exist 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 requirements are covered in the “Federal Regulations” section.
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.
OAC 252:100-8 (Permits for Part 70 Source) [Applicable]
This facility meets the definition of a major stationary source since it emits regulated pollutants in excess of 250 TPY. NSR was not required for this “grandfathered” facility. A Part 70 operating permit is required. Any planned changes in the operation of the facility which result in emissions not authorized in the permit and which exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior notification to AQD and may require a permit modification. Insignificant activities mean individual emission units, to which a state or federal requirement does not apply, that either are on the list in Appendix I (OAC 252:100), or whose actual calendar year emissions do not exceed the following limits:
a. 5 TPY of any one criteria pollutant
b. 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 any HAP that the EPA may establish by rule
c. 0.6 TPY of any one Category A toxic substance
d. 1.2 TPY of any one Category B toxic substance
e. 6.0 TPY of any one Category C toxic substance
All of the requested changes for this TV renewal permit are minor and do not require a construction permit.
OAC 252:100-9 (Excess Emissions 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. Part 70/Title V sources must report any exceedance that poses an imminent and substantial danger to public health, safety, or the environment as soon as is practicable. Under no circumstances shall notification be more than 24 hours after the exceedance.
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 particulate matter (PM) from new and existing fuel-burning equipment, with emission limits based on maximum design heat input rating. Fuel-burning equipment is defined in OAC 252:100-1 as “combustion devices used to convert fuel or wastes to usable heat or power.” Engines E2, E3, and E5 are subject to the requirements of this subchapter. The most stringent PM limitation is 0.10 lb/MMBtu/hr. AP-42 (7/00) Table 3.2.2 lists uncontrolled total PM emissions from 4-stroke lean-burn natural gas-fired engines as 0.000077 lbs/MMBtu, which is in compliance. The permit will require the use of natural gas in these engines to insure compliance with this subchapter.