PERMIT MEMORANDUM NO. 2005-082-O DRAFT 9
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM September 16, 2005
TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality Division
THROUGH: Eric Milligan, P.E., Engineering Section
THROUGH: Dale Becker, P.E., New Source Permits Section
THROUGH: Peer Review
FROM: John Howell, E.I., Existing Source Permits Section
SUBJECT: Evaluation of Permit Application No. 2005-082-O
Anadarko Petroleum Corporation
Norge-Marchand Unit Battery No. 5
Section 35, T7N, R8W
Grady County, Oklahoma
Directions: From the intersection of Highways 9 and 81 (northwest of Chickasha, Oklahoma), 3.5 miles west on Highway 9, then 2.5 miles south on county road. Lease road is on west side of road.
INTRODUCTION
Anadarko Petroleum Corporation has submitted a Title V application requesting issuance of a “synthetic minor” operating permit for the Norge-Marchand Unit Battery No. 5, a previously unpermitted facility. The application was required as partial resolution of an Enforcement case (ID #2091). Potential unrestricted emissions of VOCs and HAPs from the facility exceeded the major source thresholds. Control equipment [a vapor recovery unit (VRU)] has been installed, so that controlled PTE no longer exceeds the major source levels. NESHAP, Subpart HH, Oil and Natural Gas Production Facilities, was determined to be not applicable. A Title V operating permit is therefore not necessary.
FACILITY DESCRIPTION
The facility is an oil and gas field production unit that receives production streams from wells in the surrounding area. The wellhead streams are routed to an inlet low pressure separator. The liquid stream is routed to a free water knockout (FWKO) unit and the oil is then sent to heater-treaters for further water removal. The water is stored in four 400-bbl produced water storage tanks and then pumped to a nearby salt water disposal station. Oil is routed to storage tanks (equipped with a VRU), then pumped through a LACT unit and offsite by pipeline. All gas streams from the separator, FWKO, heater-treaters, and VRU are routed to a low pressure sales gas line. The water and oil pumps and VRU compressor are driven by electric motors. Daily production at full capacity at this facility is anticipated to be 1,250 barrels of crude oil and 1.88 MMSCF of natural gas. A list of equipment with potential for significant emissions is presented in Table 1 below.
Table 1: Equipment Description
ID / Equipment Type / Rating / Control EquipmentTK1 / Fixed roof oil storage tank / 300-bbl / VRU
TK2 / Fixed roof oil storage tank / 300-bbl
TK3 / Fixed roof oil storage tank / 300-bbl
TK4 / Fixed roof oil storage tank / 300-bbl
TK5 / Fixed roof oil storage tank / 280-bbl
TK6 / Fixed roof oil storage tank / 280 -bbl
HT1 / Heater-treater / 0.5 MMBTUH / Evolved gas-VRU / Gas-fired burner-None
HT2 / Heater-treater / 0.5 MMBTUH / Evolved gas-VRU / Gas-fired burner-None
FWKO / Free water knockout unit / -- / VRU
EMISSIONS
Emission estimates are based on maximum operation of 8,760 hrs/yr. Estimated working and breathing losses from the crude oil storage tanks are based on the EPA TANKS4.0 program and total annual throughput of 456,250 bbl/yr. To be conservative, the throughput was divided evenly among the six tanks. (In practice, one of the tanks is the “primary” storage vessel with the remainder used as overflow storage.) Flashing losses were estimated using the HYSIS process simulation software. Emissions from the tanks are controlled by the VRU with an estimated efficiency of 98%. Evolved gas from the heater-treaters and FWKO is routed to the low pressure gas gathering system. In the event of a system upset, the gas from the heater-treaters and FWKO is routed to the oil tanks and thus controlled via the VRU.
Process piping fugitive emission estimates were prepared from an estimated component count, a recent gas analysis, and emission factors taken from EPA’s “Protocol for Equipment Leak Emission Estimates” (November 1995, EPA-453/R-95-017). Emissions from the 0.5 MMBTUH burners in the heater-treaters were determined from AP-42 (7/98), Table 1.4-1 and Table 1.4-2. Table 2 provides a summary of facility-wide emissions.
Table 2: Air Emissions
Source / NOx / CO / VOClb/hr / TPY / lb/hr / TPY / lb/hr / TPY
TK11, Fixed roof oil storage tank, 300-bbl / -- / -- / -- / -- / -- / 11.4
TK21, Fixed roof oil storage tank, 300-bbl / -- / -- / -- / -- / -- / 11.4
TK31, Fixed roof oil storage tank, 300-bbl / -- / -- / -- / -- / -- / 11.4
TK41, Fixed roof oil storage tank, 300-bbl / -- / -- / -- / -- / -- / 11.4
TK51, Fixed roof oil storage tank, 280-bbl / -- / -- / -- / -- / -- / 11.4
TK61, Fixed roof oil storage tank, 280-bbl / -- / -- / -- / -- / -- / 11.4
HT11, Heater-treater, 0.5 MMBTUH / 0.04 / 0.16 / 0.03 / 0.13 / <0.01 / 0.01
HT11, Heater-treater, 0.5 MMBTUH / 0.04 / 0.16 / 0.03 / 0.13 / <0.01 / 0.01
Process Piping Fugitives / -- / -- / -- / -- / 1.62 / 7.08
Total Emissions / 0.08 / 0.32 / 0.06 / 0.26 / 1.64 / 75.5
1Equipped with VRU.
HAP emissions from the facility were estimated using the HYSIS process simulation software. Controlled emissions of HAPs are estimated to be 1.2 TPY.
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. This facility is now subject to this requirement.
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. Upon issuance of this permit, this facility will meet the conditions for a “synthetic minor” facility operating permit because there will be no emission of any regulated pollutant of 100 TPY or more. Permit conditions are appropriate, requiring use of emission controls (VRU) to ensure the source remains minor.
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.
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 fuel-burning equipment. Particulate emission limits are based on maximum design heat input rating. Appendix C specifies a PM emission limitation of 0.60 lbs/MMBTU for equipment with a heat input rating of 10 MMBTUH or less. AP-42, Table 1.4-2 (7/98), lists the total PM (PM10, PM2.5, and PM Condensable) emissions for natural gas combustion to be 0.0076 lbs/MMBTU. This permit requires the use of natural gas for all fuel-burning equipment to ensure compliance.
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 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 averaged over 3 hours. This is equivalent to approximately 0.2-weight percent sulfur in the fuel gas, which is equivalent to 2,000 ppm sulfur. The permit requires the use of pipeline-quality natural gas (i.e., composed of at least 70% methane by volume or have a gross calorific value between 950 and 1,100 BTU per SCF, and contains 0.5 grains or less of total sulfur per 100 SCF—8.5 ppmv @ 20° C), natural gas (i.e., composed of at least 70% methane by volume or have a gross calorific value between 950 and 1,100 BTU per SCF, and contains 20.0 grains or less of total sulfur per 100 SCF—343 ppmv @ 20°C) or a gaseous fuel (i.e., no composition or BTU criteria) with a maximum sulfur content of 20 grains/100 SCF—343 ppmv @ 20°C for all fuel-burning equipment to ensure compliance with Subchapter 31. 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 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 processes 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]
Part 3 requires VOC 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. However, petroleum stored or processed prior to lease custody transfer is exempt from the requirements of this subchapter. This facility is therefore exempt from these requirements.
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 and is not subject to this requirement.
Part 5 limits the VOC content of coatings used in coating lines or operations. Any painting operation will involve maintenance coating of buildings and equipment and emit less than 100 pounds per day of VOCs and is exempt.
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 all effluent water separator openings, which receive water containing more than 200 gallons per day of any VOC, to be sealed or the separator to be equipped with an external floating roof or a fixed roof with an internal floating roof or a vapor recovery system. The free water knockout unit at this facility is a sealed vessel not open to the atmosphere.
Part 7 also requires all reciprocating pumps and compressors handling VOCs to be equipped with packing glands that are properly installed and maintained in good working order and rotating pumps and compressors handling VOCs to be equipped with mechanical seals. All of the pumps and compressors at this facility are subject to these requirements.
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.