Air Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
B6478 / STAFF REPORT / MI-ROP-B6478-2016
DTE Gas Company - Belle River Mills Compressor Station
SRN: B6478
Located at
5440 Puttygut Road, China, Saint Clair County, Michigan 48054-2014
Permit Number: MI-ROP-B6478-2016
Staff Report Date: October 19, 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).
TABLE OF CONTENTS
OCTOBER 19, 2015 - STAFF REPORT 3
DECEMBER 9, 2015 - STAFF REPORT ADDENDUM 9
Michigan Department of Environmental QualityAir Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
B6478 /
OCTOBER 19, 2015 - STAFF REPORT
/ MI-ROP-B6478-2016Purpose
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: / DTE Gas Company - Belle River Mills Compressor Station5440 Puttygut Road
China, Michigan 48054-2014
Source Registration Number (SRN): / B6478
North American Industry Classification System (NAICS) Code: / 221210
Number of Stationary Source Sections: / 1
Is Application for a Renewal or Initial Issuance? / Initial IssuanceRenewal
Application Number: / 201500031
Responsible Official: / Tom Anderson, Manager - Transmission and Storage Operations
313-256-6476
AQD Contact: / Robert Elmouchi, Environmental Quality Analyst
586-753-3736
Date Application Received: / February 13, 2015
Date Application Was Administratively Complete: / March 2, 2015
Is Application Shield In Effect? / YesNo
Date Public Comment Begins: / October 19, 2015
Deadline for Public Comment: / November 18, 2015
Source Description
The DTE Gas Company, Belle River Mills (BRM) Compressor Station located at 5440 Puttygut Road, China, Michigan, is a natural gas storage and transmission facility. DTE Gas Company owns and operates several facilities in Michigan, which are used for both natural gas storage and transmission. DTE's Belle River Compressor Station receives sweet natural gas from various suppliers across the United States and Canada, which it stores in its natural underground storage field. The underground storage field is used as reservoir during the warmer non-heating months to ensure DTE's customers will receive an uninterrupted supply of natural gas during the cooler heating months. Some of the engines at this facility are also used to boost the pipeline transmission pressure of natural gas as needed per transmission conditions and customer demand.
The Belle River facility consists of five various sized horse power (HP) natural gas-fired 2-cycle lean burn reciprocating internal combustion engines (RICE), two 1,480 HP 4-cycle lean burn RICE, two natural gas-fired 4-cycle lean burn emergency generator RICE, one Low-NOx 15,000 HP natural gas-fired turbine engine, three natural gas fired boilers, seven process heaters, seven storage tanks, and one cold cleaner. The installation of two natural gas-fired turbines, one 10,915 HP and one 6,130 HP, has been approved per PTI no. 32-15. The natural gas-fired 2-cycle lean burn RICE and the three turbine engines (including the two aforementioned turbines pending installation) are used to increase the pressure of the natural gas to inject it into the underground storage field. The two 1,480 HP 4-cycle lean burn RICE are part of the refrigeration plant and are part of a process designed to remove heavy hydrocarbons during the withdrawal cycle when the field gas contains an unacceptable amount of heavy hydrocarbons. The turbine engines can be configured to inject or withdraw natural gas from the storage field by changing the attached centrifugal compressor. The majority of emissions from this storage facility are associated with the RICE and turbine engines.
The following table lists stationary source emission information as reported to the Michigan Air Emissions Reporting System (MAERS) for the year 2014.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant / Tons per Year /Carbon Monoxide (CO) / 136.1
Nitrogen Oxides (NOx) / 417.8
Particulate Matter (PM) / 12.8
Sulfur Dioxide (SO2) / 0.3
Volatile Organic Compounds (VOCs) / 43.3
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 181,091 tons. CO2e is a calculation of the combined global warming potentials of six GHG (carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride).
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 non-applicability 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 Saint Clair County, which is currently designated by the U.S. Environmental Protection Agency (USEPA) as attainment 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 (NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC) exceeds 100 tons per year.
The potential to emit of any single HAP (formaldehyde) regulated by the federal Clean Air Act, Section 112, is equal to or more than 10 tons per year.
the potential to emit of GHG is 100,000 tons per year or more calculated as CO2e and 100 tons per year or more on a mass basis.
The source is subject to 40 CFR Part 60 Subpart JJJJ, standards of performance for stationary spark ignition internal combustion engines.
FGRULE818ENGINES at the stationary source was subject to review under the Prevention of Significant Deterioration regulations of PART 18, PREVENTION OF SIGNIFICANT DETERIORATION OF AIR QUALITY, OF ACT 451 because at the time of New Source Review permitting the potential to emit of was greater than tons per year.
EU014, EU015 and EU016 were installed prior to August 15, 1967. As a result, this equipment is considered "grandfathered” and is not subject to New Source Review (NSR) permitting requirements. However, future modifications of this equipment may be subject to NSR.
Although EU017 and EU018 were installed after August 15, 1967 (June 1972), this equipment was exempt from New Source Review (NSR) permitting requirements per R36(c) at the time it was installed. However, modifications of these emission units began, respectively, in 2007 and 2008 in order to comply with Rule R336.1818 (Rule 818) and therefore this equipment became subject to NSR.
EUREFRIGPLANT at the stationary source is subject to the New Source Performance Standards for Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants promulgated in 40 CFR, Part 60, Subparts A and KKK.
EUREFRIGPLANT was evaluated to determine if it is subject to 40 CFR Part 61 Subpart V, National Emission Standards for Equipment Leaks. A rough analysis by AQD staff, based upon gas analysis data, appeared to indicate that the fluid contained or in contact with the equipment is expected to have less than 0.5 percent volatile hazardous air pollutant (VHAP) by weight. Additionally, per an e-mail received by the AQD from the applicant on January 13, 2009, the VHAP concentration is expected to be less than 1 percent. The AQD calculated VHAP value and the applicant’s calculated VHAP value appear to be in agreement and both values appear to indicate the VHAP concentration throughout EUREFRIGPLANT will be less than 1 percent, which is less than 10% of the applicability threshold. Therefore, this facility does not appear to be subject to 40 CFR Part 61 Subpart V.
EUDEHY at the stationary source is subject to the Maximum Achievable Control Technology Standards for National Emission Standards for Hazardous Air Pollutants from Natural Gas Transmission and Storage Facilities promulgated in 40 CFR Part 63 Subparts A and Subpart HHH. 40 CFR Part 63 Subpart HHH was revised in 2014. New applicable conditions have been added to this emission unit table.
EU014, EU015, EU016, EU017, EU018, EUBUGENSETTURBIN and EUEMERGENZBLDG at the stationary source are subject to the Maximum Achievable Control Technology Standards for National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines promulgated in 40 CFR, Part 63, Subparts A and ZZZZ.
EUENGINER1 and EUENGINER2 are subject to the New Source Performance Standards for Stationary Spark Ignition Internal Combustion Engines per § 60.4230(4)(i) promulgated in 40 CFR, Part 60, Subpart JJJJ because the emission units were manufactured after July 1, 2007.
FGTURBINES are subject to the New Source Performance Standards for Stationary Combustion Turbines per § 60.4305(a) promulgated in 40 CFR, Part 60, Subpart KKKK because the heat input at peak load is equal to or greater than 10.7 gigajoules (10 MMBtu) per hour, based on the higher heating value of the fuel, which commenced construction, modification, or reconstruction after February 18, 2005. Emission testing frequency is specified per 40 CFR 60.4400. The testing frequency may vary according to performance test results.
FGENGINES
In order for the Source to demonstrate compliance with Rule 301, the AQD has placed limitation on the fuel which may be burned in the RICE. The permit contains no requirements for opacity because the facility is allowed to combust only natural gas in these RICE and the combustion of natural gas should result in no visible emissions, thus resulting in compliance with Rule 301. It is also important to note that EU017 and EU018 in this flexible group are also in FGRULE818ENGINES, which also includes R301 as a UAR.
EUREFRIGPLTBLR, EUZBLDGBLR, EUAUXBLDGBLR, EULT3BLR, EULT1BLR, EUTECHBLDGBLR, EUBATHHTR, EUHMOHTR, EUNUGHTR, EUSUGHTR, EUE36LINEHTR, EUW36LINEHTR andEU24LINEHTR are subject to 40 CFR Part 63 Subpart DDDDD (Industrial, Commercial, and Institutional Boilers and Process Heaters MACT). These emission units are in flexible group FG5DBOILERS and are existing Gas 1 Fuel Subcategory boilers and process heaters that utilize only natural gas. These existing boilers or process heaters must comply with 40 CFR Part 63 Subpart DDDDD no later than January 31, 2016, except as provided in 40 CFR 63.6(i).
At this time, there are no GHG applicable requirements to include in the ROP. The mandatory Greenhouse Gas Reporting Rule under 40 CFR Part 98 is not an ROP applicable requirement and is not included in the ROP.
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."
The emission limitation or standard for carbon monoxide from EUENGINER1 and EUENGINER2 at the stationary source are exempt from the federal Compliance Assurance Monitoring (CAM) regulation under 40 CFR, Part 64, because 93% CO (formaldehyde surrogate) destruction efficiency is addressed by 40 CFR 63 subpart ZZZZ. Therefore, EUENGINER1 and EUENGINER2 are exempt from CAM requirements for carbon monoxide.
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-B6478-2010 are identified in Appendix 6 of the ROP.
PTI Number /105-94 / 206-01 / 155-06D / 165-07
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.
ExemptEmission Unit ID / Description of
Exempt Emission Unit / Rule 212(4)
Exemption / Rule 201
Exemption /
EU00042 / EULENNOXFURN#1 / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00043 / EULENNOXFURN#2 / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00044 / EULENNOXFURN#3 / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00046 / EUJOHNSONFUR#1 / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00047 / EUJOHNSONFUR#2 / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00048 / EUJOHNSONFUR#3 / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00052 / EUSOLARBLDGHTR / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00053 / EURADHTR#1RPR / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00054 / EURADHTR#2RPR / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00055 / EURADHTR#3WELD / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00056 / EURADHTR#4WELD / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00057 / EURADHTR#5GAR / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00064 / EUPUMPBLDGHTR / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00065 / EUSTOCKRMHTR#1 / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00066 / EUSTOCKRMHTR#2 / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00067 / EUHOTWTRREPAIR / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00069 / EUHOTWTRCONTRL / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00070 / EUDEHYCATHTR#1 / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00071 / EUDEHYCATHTR#2 / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00072 / EUDEHYCATHTR#3 / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00073 / EUDEHYCATHTR#4 / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00074 / EUDEHYCATHTR#5 / R 336.1212(4)(b) / R 336.1282(b)(i)
EU00075 / EUDEHYCATHTR#6 / R 336.1212(4)(b) / R 336.1282(b)(i)
Draft ROP Terms/Conditions Not Agreed to by Applicant