PERMIT MEMORANDUM NO. 2002-382-O DRAFT 11
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM April 13, 2006
TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality
THROUGH: Grover Campbell, P.E., Existing Source Permits Section
THROUGH: Phil Martin, P.E., New Source Permits Section
THROUGH: Peer Review
FROM: Roya Sharifsoltani, New Source Permits Section
SUBJECT: Evaluation of Permit Application No. 2002-382-O
Western Gas Resources, Inc.
Clyde Compressor Station (SIC 1311)
SW/4 of Section 35, T28N, R6W, Grant County
Located 5 miles west of Medford on SH 11 and 3 miles north of SH 11
½ mile past town of Clyde
INTRODUCTION
Western Gas Resources, Inc. (WGR) on September 4, 2002 submitted an application for a Title V renewal permit for the Clyde Compressor Station. WGR recently removed a compressor engine from this site and has requested that a “synthetic minor” operating permit be issued for the facility rather than renewing the Title V permit. The modification includes removal of a Caterpillar G3516LE compressor engine (EU5) from the Clyde Compressor Station, increasing condensate throughput, converting TK-803 from ethylene glycol to condensate, and adding flashing emissions.
FACILITY DESCRIPTION
The facility (SIC 1311) is currently operating under Permit No. 96-357-TV issued on March 5, 1998 and Permit No. 96-357-C (M-1) issued on October 5, 2001. The construction permit authorized the installation of two 1,680-hp Waukesha L7044GSI engines but two 1,340-hp Caterpillar G3516LE units with lower emissions were installed instead and one was removed recently. WGR installed catalytic converters on the existing three Waukesha L7042GSI engines (C-1, C-2, C-3) on December 5, 2003. This facility have three 1,232-hp Waukesha L7042 GSI, one 1,340-hp Caterpillar G3516LE, and a glycol dehydration unit with a 0.75 MMBTUH reboiler. There are three VOC storage tanks at the site. The description of the equipment is presented in the table below.
EQUIPMENT
Internal Combustion Engines
Point / Make/Model / Const. DateC-1 / 1,232-hp Waukesha L7042 GSI w/cc* / 6/1984
C-2 / 1,232-hp Waukesha L7042 GSI w/cc* / 6/1984
C-3 / 1,232-hp Waukesha L7042 GSI w/cc* / 10/1984
C-4 / 1,340-hp caterpillar G3516LE / 12/2003
*w/cc with catalytic converter
Glycol Dehydration Unit Reboiler
Point / Make/Model / MMBTU/hr / Const. DateH-401 / Glycol Reboiler / 0.75 / 1984
Glycol Dehydration Unit Still Vent W/ Condenser
Point / Make/Model / Const. DateH-401SV / Dehydration Still Vent/Condenser / 1997
Storage Tanks
Point / Contents / Barrels / GallonsT-1 / Condensate / 210 / 8,820
T-2 / Condensate / 210 / 8,820
T-5 / Condensate / 210 / 8,820
T-8 / Slop Water (UST) / 238 / 9,996
Fugitive VOC Emissions
Component / Quantity / Emission Factor(lbs/hr/comp.) / Potential Emissions (TPY)
Gas/Vapor Valve / 336 / 0.00992 / 3.32
Liquid Valve / 34 / 0.0055
Connector in Gas Services / 1,208 / 0.00044 / 0.65
Connector in Liq. Services / 124 / 0.00046
Pump Seal / 3 / 0.02866 / 0.38
Flange/Conn./Gas / 604 / 0.00086 / 0.46
Flange/Conn./Liq. / 62 / 0.00024
Other in Gas Service / 54 / 0.0194 / 0.86
Other in Liq. Service / 1 / 0.0165
Open-Ended Lines in Gas Service / 71 / 0.00441 / 0.28
Open-Ended Lines in Liq. Service / 3 / 0.0031
Total / 5.95
Stack Parameters
EU / Source
(make/model) / Height
(feet) / Diameter
(inches) / Flow
(ACFM) / Temperature (deg F)
1-3 / Waukesha L7042 GSIU / 16 / 10 / 5,377 / 1,055
4 / Caterpillar G3516LE / 16 / 10 / 7,685 / 855
H-401 / Glycol Reboiler / 10 / 6 / 435 / 800
EMISSIONS
Emissions estimates for the 1,232-hp Waukesha L7044 GSI engines with catalytic converters are based on continuous operation and the following factors (2.0 g/hp-hr NOX, 2.0 g/hp-hr CO, 1.0 g/hp-hr VOC). Emissions estimates for the 1,340-hp caterpillar G3516LE are based on continuous operation and the following factors (2.0 g/hp-hr NOX, 2.0 g/hp-hr CO, 0.5 g/hp-hr VOC). Emission estimates for the glycol dehydrator were calculated using the GRI-GLYCalcTM Version 4.0 program, a recent gas analysis for the facility, a lean glycol circulation rate of 3.50 gpm, a gas throughput of 19.0 MMSCFD. The glycol dehydration unit is equipped with a flash tank and a condenser. The flash tank off-gases are routed to the inlet separator and the condenser is vented to the reboiler firebox with an estimated control efficiency of 98%. Estimated emissions for the tanks are based on AP-42 (1/95), Chapter 7.1, a throughput of 382,410 gallons/year, and were calculated using TANKS 4.0. Flash emissions from the tanks were estimated using the Vasquez Beggs Equation. 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 a recent gas analysis. Estimated emissions from the truck loading are based on AP-42 (1/95), Chapter 5.2.
Emissions of formaldehyde for the each of Waukesha L7042 GSIU engines were calculated using Air Pollution Testing Inc. formaldehyde emission factor of 0.00157 lb/MMBTU for a rich burn engine with catalytic converter. Emissions of formaldehyde for the Caterpillar G3516LE were calculated using Caterpillar’s formaldehyde emission factor of 0.3 g/hp-hr. Total formaldehyde emissions are below the major source levels.
Emissions of HAPs From Engines
Source / Pollutant / EMISSIONSlb/hr / TPY
1,232-hp Waukesha L7042 GSI w/cc* / Formaldehyde / 0.015 / 0.064
1,232-hp Waukesha L7042 GSI w/cc* / Formaldehyde / 0.015 / 0.064
1,232-hp Waukesha L7042 GSI w/cc* / Formaldehyde / 0.015 / 0.064
1,340-hp caterpillar G3516LE / Formaldehyde / 0.886 / 3.88
Total / 0.93 / 4.08
Dehydration units using glycol desiccants will emit benzene, toluene, ethyl benzene, xylene, and n-hexane from the glycol reboiler vent stack. These emissions are summarized in the table below. All emissions of HAPs are below the major source levels
Dehydrator HAP Emissions
Pollutant / Emissionslb/hr / TPY
Benzene / <0.01 / 0.02
Toluene / <0.01 / <0.01
Ethylbenzene / ND* / ND*
Xylene / ND* / ND*
n-Hexane / <0.01 / <0.01
Total HAPs / 0.03 / 0.04
*ND not detected
Facility Wide Emissions
NOX / CO / VOClb/hr / TPY / lb/hr / TPY / lb/hr / TPY
Current Emissions
Waukesha L7042 GSI W/CC / 5.43 / 23.79 / 5.43 / 23.79 / 1.20 / 5.23
Waukesha L7042 GSI W/CC / 5.43 / 23.79 / 5.43 / 23.79 / 1.20 / 5.23
Waukesha L7042 GSI W/CC / 5.43 / 23.79 / 5.43 / 23.79 / 1.20 / 5.23
Waukesha L7044 GSI W/CC / 7.41 / 32.45 / 7.41 / 32.45 / 1.85 / 8.11
Waukesha L7044 GSI W/CC / 7.41 / 32.45 / 7.41 / 32.45 / 1.85 / 8.11
Dehydration Unit Reboiler / 0.09 / 0.39 / 0.08 / 0.34 / 0.01 / 0.02
Dehydration Unit / --- / --- / --- / --- / 0.04 / 0.20
Tanks / --- / --- / --- / --- / 2.86 / 12.53
Fugitives / --- / --- / --- / --- / 1.36 / 5.90
Truck Loading / --- / --- / --- / --- / --- / 1.28
Subtotal / 31.20 / 136.66 / 31.19 / 136.61 / 11.57 / 51.84
Emissions After the Modification
1,232-hp Waukesha L7042 GSI w/cc / 5.43 / 23.79 / 5.43 / 23.79 / 2.72 / 11.90
1,232-hp Waukesha L7042 GSI w/cc / 5.43 / 23.79 / 5.43 / 23.79 / 2.72 / 11.90
1,232-hp Waukesha L7042 GSI w/cc / 5.43 / 23.79 / 5.43 / 23.79 / 2.72 / 11.90
1,340-hp caterpillar G3516LE / 5.91 / 25.88 / 5.91 / 25.88 / 1.48 / 6.47
Dehydration Unit Reboiler / 0.09 / 0.40 / 0.08 / 0.34 / 0.01 / 0.02
Dehydration Unit / --- / --- / --- / --- / 0.03 / 0.13
Condensate tanks* / --- / --- / --- / --- / 5.83 / 25.48
Methanol Tank (T-3)* / --- / --- / --- / --- / --- / 0.03
Slop Water (T-8)* / --- / --- / --- / --- / --- / 0.76
Fugitives / --- / --- / --- / --- / 1.36 / 5.95
Truck Loading / --- / --- / --- / --- / --- / 1.90
Total Emissions After Modification / 22.29 / 97.65 / 22.28 / 97.59 / 16.87 / 76.44
Emissions Increases/Decreases / -8.91 / -39.01 / -8.91 / -39.02 / 5.30 / 24.60
*Emissions include working, breathing, and flashing losses.
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]
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 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 addressed 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 have been submitted and fees paid for the past years.
OAC 252:100-7 (Permits for Minor Sources) [Applicable]
Subchapter 7 sets forth the permit application fees and the basic substantive requirements of permits for minor facilities. This facility meets the conditions for a minor facility operating permit because there is no emission of any regulated pollutant of 100 TPY or more. Control technology is already present in the form of catalytic converters. Permit conditions are appropriate requiring periodic testing to ensure the source remains minor. After this permit is issued, this facility will be a “synthetic minor” facility.
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 following the malfunction or release. 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]
This subchapter specifies a PM emissions limitation of 0.6 lbs/MMBTU from fuel-burning units with a rated heat input of 10 MMBTUH or less. For 4-stroke rich burn natural gas-fired engines, AP-42 (7/00), Sec. 3.2 lists the total PM emissions for natural gas to be 0.0194 lbs/MMBTU. The permit requires the use of natural gas for all fuel-burning units to ensure compliance with Subchapter 19.
OAC 252:100-25 (Visible Emissions and Particulate Matter) [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. The permit requires the use of natural gas for all fuel-burning equipment to ensure compliance with Subchapter 25.
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/MMBTU heat input. This is equivalent to approximately 0.2 weight percent sulfur in the fuel gas which is equivalent to 2,000 ppmw sulfur. Thus, a limitation of 343 ppmv 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 343 ppmv 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]