PERMIT MEMORANDUM 2005-238-TVR 13

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM December 15, 2005

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

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

Phil Martin, P.E., New Source Permits Section

THROUGH: Peer Review

FROM: David Schutz, P.E., New Source Permits Section

SUBJECT: Evaluation of Permit Application No. 2005-238-TVR

Mustang Gas Products LLC

Kingfisher West Compressor Station

Sec. 11-T15N-R9W, Kingfisher County

Driving Directions: from the intersection of U.S. 81 and Hwy. 33, proceed west on Hwy. 33 for approximately 10.5 miles. Turn south on a county road and travel for approximately four miles. Turn west on a county road and proceed for approximately 0.5 miles until reaching the facility.

SECTION I. INTRODUCTION

Mustang Gas Products LLC (Mustang) has requested renewal of their current Part 70 operating permit for the Kingfisher West Compressor Station (SIC 1311). The facility is currently operating under Permit No. 97-252-TV (M-1) issued May 16, 2002.

In addition to renewing the permit, the following changes will be made in the renewal:

-  Revise a federally-enforceable condition pertaining to the emissions limits on the TEG dehydration system; these limits were established to avoid any potential questions regarding the Oil and Gas MACT applicability. This modification will also update the memorandum and specific conditions to reflect current permitting guidelines.

-  Provides for operation of one engine with a catalytic converter in exchange for eliminating a limit on hours of operation for another engine. There will be a net decrease in potential emissions of the facility, and PSD procedures are not applicable since currently-permitted emissions are below 250 TPY of each regulated pollutant.

Since the facility emits more than 100 TPY of a regulated pollutant, it is subject to Title V permitting requirements. Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) in the following outline. Field-grade natural gas is the primary fuel with the engines being operated continuously.


SECTION II. EQUIPMENT

Emission units have been arranged into Emission Unit Groups (EUGs) as outlined following. Emission units that emit the same regulated air pollutants, trigger the same applicable requirements, share the same compliance demonstration methods, and share the same proposed compliance assurance certifications are combined as one EUG.

EUG-1 Facility Wide

This emission unit group is facility-wide. It includes all emission units and is established to discuss the applicability of those rules or compliance demonstrations which may affect all sources within the facility.

EUG-2 Permitted Compressor Engines

EU / Point / Description / HP / Serial # / Constuction Date
EU-CM-2 / P-CM-2 / Waukesha L7042GU / 850 / 308609 / 1981
EU-CM-3 / P-CM-3 / Waukesha L7042GSI / 1,232 / 354534 / 1980
EU-CM-4 / P-CM-4 / Waukesha L7042GSI / 1,232 / 318554 / 1980

The various engines used to be in separate EUGs, so there is a gap in the EUG sequence.

EUG-5 Glycol Dehydrator

EU / Point / Description / Construction Date
EU-TEGV-1 / P-TEGV-1 / Still vent / 1980

EUG-6 Glycol Dehydrator Reboiler

EU / Point / Description / MMBTUH / Construction Date
EU-TEGH-1 / P-TEGH-1 / Firetube Reboiler / 0.5 / 1980

EUG-7 Storage Tanks

EU / Point / Description / Capacity (gallons) / Construction Date
EU-TK-2 / P-TK-2 / Condensate Tank / 12,690 / 1980
EU-TK-3 / P-TK-3 / Lube Oil Tank / 8,820 / 1980
EU-TK-4 / P-TK-4 / Antifreeze Storage Tank / 1,066 / 1980
EU-TK-5 / P-TK-5 / Triethylene Glycol Tank / 2,417 / 1980
EUG-8 Miscellaneous-Process Piping Fugitives
Component / Service / Number of Components / VOC Percent in Stream
Valves / Gas / 536 / 3.49%
Valves / Light Liquid / 35 / 65.6%
Pump Seals / Light Liquid / 7 / 95.5%
Flanges / Gas / 569 / 3.49%
Flanges / Light Liquid / 42 / 65.6%
Compressor Seals / All / 17 / 3.49%
Relief Valves / All / 3 / 3.49%

EUG-9 Loading Emissions

EU / Point / Description / Volume, bbl/yr* / Const. Date
EU-TL-1 / P-TL-1 / Condensate Loading / 1,474.52 / 1980

* Throughput is the maximum throughput from 2003, 2004, and 2005 plus a 100% safety factor.

SECTION III. EMISSIONS

Engine emissions are based on manufacturer’s data (EU-CM-2: 12.0 g/hp-hr NOx, 12.0 g/hp-hr CO, and 1.0 g/hp-hr VOC; EU-CM-3: 2.0 g/hp-hr NOx, 3.0 g/hp-hr CO, and 0.4 g/hp-hr VOC; EU-CM-4: 2.0 g/hp-hr NOx, 3.0 g/hp-hr CO, and 0.4 g/hp-hr VOC). The glycol reboiler emissions are based on AP-42 (7/98), Tables 1.4-2 and 1.4-3, with tank emission based on the EPA Tanks3 program. Tank emission also includes tank truck loading emissions based on AP-42 (1/95), Table 5.2-5. VOC emissions from the glycol dehydrator still vent are based on GRI-GLYCalc 3.0 analysis with a maximum gas throughput of 10 MMSCFD and a lean glycol pump rate of 1.5 gpm. Both flashing and loading losses were calculated using the maximum condensate throughput from 2002 through 2004 and applying a safety factor of 100%. Loading emissions were calculated using AP 42 emission factors assuming gasoline RVP 10 from Tables 5.2-1 and 7.1-2, while flashing emissions were calculated using the Vasquez-Beggs correlation and DEQ default values.

EMISSIONS

EU / NOx / CO / VOC
lb/hr / TPY / lb/hr / TPY / lb/hr / TPY
CURRENT
EU-CM-2 / 22.49 / 62.96 / 22.49 / 62.96 / 1.87 / 5.25
EU-CM-3 / 5.43 / 23.79 / 8.15 / 35.69 / 1.20 / 5.23
EU-CM-4 / 32.59 / 142.76 / 32.59 / 142.76 / 2.72 / 11.90
EU-TEGH-1 / 0.04 / 0.15 / 0.007 / 0.03 / 0.003 / 0.01

EU-TEGV-1

/ - / - / - / - / 5.77 / 25.26
EU-TK-2 / - / - / - / - / 0.16 / 0.68
EU-FUG-1 / - / - / - / - / 0.54 / 2.37
TOTALS / 60.55 / 229.66 / 63.237 / 241.44 / 12.263 / 50.7

PROPOSED

EU-CM-2 / 22.49 / 98.76 / 22.49 / 98.76 / 1.87 / 8.23
EU-CM-3 / 5.43 / 23.79 / 8.15 / 35.69 / 1.20 / 5.23
EU-CM-4 / 5.43 / 23.79 / 8.15 / 35.69 / 1.20 / 5.23
EU-TEGH-1 / 0.04 / 0.15 / 0.007 / 0.03 / 0.01 / 0.01

EU-TEGV-1

/ - / - / - / - / 2.01 / 8.84
EU-TK-2 / - / - / - / - / 0.53 / 2.28
EU-FUG-1 / - / - / - / - / 0.54 / 2.37
EU-TL-1 / - / - / - / - / 0.04 / 0.16
TOTALS / 33.39 / 146.49 / 38.80 / 170.17 / 7.40 / 32.35
NET CHANGES / -27.16 / -83.17 / -24.44 / -71.27 / -4.86 / -18.35

Brake-specific fuel consumption, stack dimensions, and the air emissions for the engines are listed following. Moisture contents of stack gases have been estimated from the stoichiometric ratio of two cubic feet of water in exhausts per cubic foot of methane fuel.

Engine / Stack Height
feet / Stack
Diameter
inches / Stack
Flow
ACFM / Stack
Temperature
oF / Fuel Usage SCFH / Moisture Content
EU-CM-2 / 20 / 12 / 2,790 / 900 / 6,500 / 20%
EU-CM-3 / 21 / 12 / 4,202 / 960 / 9,375 / 20%
EU-CM-4 / 15 / 12 / 4,205 / 960 / 9,375 / 20%

Dehydration units using glycol desiccants emit benzene, toluene, ethyl benzene, xylene, and n-hexane from the glycol reboiler vapor stack. The applicant has analyzed the incoming gas for the concentrations of BTEX, estimating HAP emissions using the GRI-GLYCalc program. The following table lists estimates of HAPs emissions based on a gas throughput of 10 MMSCF/day and a glycol recirculation rate of 1.5 gal/minute and a condenser on the still vent. The facility is below the major source threshold for HAPs.

Pollutant

/ Potential Emissions
lb/hr TPY
Benzene / 0.16 / 0.69
Toluene / 0.43 / 1.89
Ethyl benzene / 0.05 / 0.22
Xylene / 0.38 / 1.68
n-Hexane / 0.02 / 0.08

For the engines, the primary HAP of concern is formaldehyde. Estimates of formaldehyde emissions are based on factors in AP-42 (7/00), Section 3.2.

Formaldehyde Emissions

EU / Description / Fuel Usage MMBTUH / Emission Factor,
lb/MMBTU / Formaldehyde
lb/hr / TPY
EU-CM-2 /

Waukesha L7042GU

/ 6.5 / 0.0205 / 0.133 / 0.584
EU-CM-3 / Waukesha L7042GSI / 9.4 / 0.0205 * / 0.048 / 0.211
EU-CM-4 / Waukesha L7042GSI / 9.4 / 0.0205 * / 0.048 / 0.211
/ TOTALS / 0.229 / 1.006

* assumes 75% control from catalytic converter.


SECTION IV. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified in the application and listed in OAC 252:100-8, Appendix I, are listed below. Record keeping for activities indicated with “*” is required in the Specific Conditions.

1.  *Storage tanks with less than or equal to 10,000 gallons capacity that store volatile organic liquids with a true vapor pressure less than or equal to 1.0 psia at maximum storage temperature. There are one 8,820 gallon lube oil tank, one 1,066 gallon antifreeze storage tank, and one 2,417 gallon triethylene glycol tank on site.

2.  * Emissions from crude oil and condensate storage tanks with a capacity of less than or equal to 420,000 gallons that store crude oil and condensate prior to custody transfer. Tank TL-2 storescondensate prior to custody transfer and has a capacity of 12,600-gallons.

3.  * Emissions from crude oil and condensate marine and truck loading equipment operations at crude oil and natural gas production sites where the loading rate does not exceed 10,000 gallons per day averaged over a 30-day period. The facility will load any condensate recovered into tank trucks.

4.  *Activities having the potential to emit no more than 5 TPY (actual) of any criteria pollutant. None identified but may occur 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. In addition, modeled emissions of the facility demonstrate that the facility would not have a significant impact on air quality.

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 252:100-8 (Permits for Part 70 Sources) [Applicable]

Part 5 includes the general administrative requirements for Part 70 permits. 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 that either are on the list in Appendix I (OAC 252:100) or whose actual calendar year emissions do not exceed the following limits:

·  5 TPY of any one criteria pollutant

·  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 single HAP that the EPA may establish by rule

Emission limits for the facility are based on the previous Title V permit and the permit modification application.

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 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]

This subchapter specifies a particulate matter (PM) emissions limitation of 0.6 lb/MMBTU from indirect fired fuel-burning units with a rated heat input of 10 MMBTUH or less. AP-42 (7/98), Table 1.4-2, lists the total PM emissions for natural gas to be 7.6 lb/MMft3 or about 0.0076 lb/MMBTU. For 4-cycle rich burn engines burning natural gas, AP-42 (7/00), Table 3.2-3 lists the total PM emissions as 0.009 lb/MMBTU. The permit requires the use of natural gas for all fuel-burning equipment to ensure compliance with Subchapter 19. Since only natural gas is burned at the facility, compliance with the standard is assured without any special monitoring provisions.