PERMIT MEMORANDUM 2003-281-TVR DRAFT 13
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY DRAFT
AIR QUALITY DIVISION
MEMORANDUM June 2, 2005
TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality
THROUGH: Ing Yang, P.E., New Source Permits Section
THROUGH: Grover Campbell, P.E., Existing Source Permits Section
THROUGH: Peer Review
FROM: Roya Sharifsoltani, New Source Permits Section
SUBJECT: Evaluation of Permit Application No. 2003-281-TVR
Mustang Gas Products LLC
Humphrey Compressor Station, (SIC 1321)
Section 19, T23N, R6W, Garfield County, Oklahoma
Directions: From intersection of US Highway 81 and US Highway 64 north of Enid proceed north for 0.25 miles then proceed west on a county road for 0.4 mile. Facility is 0.3 miles north of the road.
SECTION I. INTRODUCTION
Mustang Gas Products LLC has submitted an application for renewal of the Title V Permit No. 96-412-TV for the Humphrey Compressor Station (SIC Code 1321). The facility was constructed in pre-1972 and is a natural gas compression facility. The facility contained two 495-hp White-Superior 6G825 compressor engines, and a glycol dehydration unit with a 0.125 MMBTUH reboiler. A grandfathered engine EU-CM-4 was replaced and a modification was submitted to establish emission limits for the new engine, which will be incorporated into this permit.
SECTION II. EQUIPMENT
This facility currently contains two 495-hp White-Superior 6G825 compressor engines, a glycol dehydration unit with a 0.125 MMBTUH reboiler, and additional tanks and auxiliary equipment which are insignificant. Emission units have been arranged into Emission Unit Groups (EUGs) as outlined below.
EUG-01 Grand Fathered Compressor Engine
EU / Point / Description / HP / Serial # / Const. DateCM-1 / CM-1 / White-Superior 6G825 / 495 / 19091 / Pre-1972
EUG-02 Internal Combustion Engine
EU / Point / Description / HP / Serial # / Const. DateCM-4 / CM-4 / White-Superior 6G825 w/cc* / 495 / 19247 / 1999
* Catalytic converter
EUG-03 Glycol Regenerator* Vent
EU / Point / Description / Construction DateEU-TEGV-1 / P-TEGV-1 / Vent 1 / 1986
*The glycol unit is not equipped with a flash tank or other emission control devices.
EUG-04 Glycol Reboiler
EU / Point / Description / MMBTH / Construction DateEU-TEGH-1 / P-TEGH-1 / Glycol Reboiler / 0.125 / 1986
EUG-05 Tanks
EU / Point / Description / Gallons / Construction DateEU-TK-2 / EU-TK-2 / Condensate / 8,820 / pre-1972
EU-TK-3 / EU-TK-3 / Condensate / 8,820 / pre-1972
EU-TK-4 / EU-TK-4 / Condensate / 8,820 / pre-1972
EU-TK-9 / EU-TK-9 / Methanol / 660 / pre-1972
EUG-06 Fugitives
EU
/ Type of Equipment / Const. DateEU-FUG-1 / Process Piping Fugitives / pre-1972
EU-LOAD-1 / Condensate Truck Loading / pre-1972
EU / Number Items / Type of Equipment
Fugitives / 84 / Valves
80 / Flanges
7 / Pumps
10 / Other
SECTION III. EMISSIONS
Emissions estimates for the 495-hp White-Superior 6G825 (CM-1) compressor engine is based on continuous operation and manufacturer’s data (18.0 gr/hp-hr NOx, 18.0 gr/hp-hr CO, 1.0 gr/hp-hr VOC). Emissions estimates for the 495-hp White-Superior 6G825 (CM-4) compressor engine with catalytic converter is based on continuous operation and manufacturer’s data (3.0 gr/hp-hr NOx, 3.0 gr/hp-hr CO, 1.0 gr/hp-hr VOC). Reboiler combustion emissions are based on AP-42 (7/98), Table 1.4-1. Emission estimates for the glycol dehydrators were calculated using the GRI-GLYCalcTM program, a recent gas analysis for the facility, a lean glycol circulation rate of 2.50 gpm, a gas throughput of 3.0 MMSCFD, and 25% safety factor over modeled values. Fugitive VOC emissions are based on EPA’s 1995 Protocol for Equipment Leak Emission Estimates (EPA-453/R-95-017) and an estimated number of components and VOC content, and loading emissions are based on AP-42 (1/8), Section 5.2-5 and throughput of 201,759 gallon/yr. Tank emissions are based on AP-42 (1/95), Section 7.1 and throughput of 201,759 gallon/yr. Flashing emissions are estimated using Vasquez-Beggs.
Emission factors for the engines are listed below.
Engine Emissions Factors
Source / NOx (g/hp-hr) / CO (g/hp-hr) / VOC (g/hp-hr)495-hp White-Superior 6G825 (CM-1) / 18 / 18 / 1
495-hp White-Superior 6G825 (CM-4) w/cc / 3 / 3 / 1
Fugitive Emissions
Equipment / %C3+ / Emission Factor / lb/hr / TPY84 Valves / 10 / 0.00992 / 0.0833 / 0.3649
80 Flanges / 10 / 0.00086 / 0.0069 / 0.0302
7 Pumps / 10 / 0.02866 / 0.0201 / 0.0880
10 Other / 10 / 0.01940 / 0.0194 / 0.0850
Total Fugitive Emissions / 0.1297 / 0.5681
Facility-wide permitted emissions of criteria pollutants are listed in below.
Permitted Air Emissions
Source / NOx / CO / VOClb/hr / TPY / lb/hr / TPY / lb/hr / TPY
495-hp White-Superior 6G825 (CM-1) 1 / 19.64 / 86.04 / 19.64 / 86.04 / 1.09 / 4.78
495-hp White-Superior 6G825 (CM-4) w/cc / 3.27 / 14.34 / 3.27 / 14.34 / 1.09 / 4.78
0.125 MMBTUH Dehy. Reboiler (TEGH-1) / 0.01 / 0.04 / 0.01 / 0.04 / <0.01 / <0.01
Dehy. Still Vent / Reboiler (TEGV-1) / --- / --- / --- / --- / 5.40 / 23.72
210-bbl Condensate Tank (TK-2) / --- / --- / --- / --- / 0.24 / 1.06
210-bbl Condensate Tank (TK-3) / --- / --- / --- / --- / 0.24 / 1.06
210-bbl Condensate Tank (TK-4) / --- / --- / --- / --- / 0.18 / 0.82
Menthol Tank (TK-9) / --- / --- / --- / --- / --- / 0.03
Process piping fugitives / --- / --- / --- / --- / 0.13 / 0.57
Truck loading losses / --- / --- / --- / --- / 0.31 / 1.37
Condensate Flashing Losses / --- / --- / --- / --- / 2.3 / 10.1
Total Emissions / 22.92 / 100.42 / 22.92 / 100.42 / 10.99 / 48.3
1 “grandfathered” unit with no emission limitations.
Brake specific fuel consumption for the 495-hp White-Superior 6G825 (CM-1) has been listed at 7,500 BTU/hp-hr for a fuel consumption of 3,713 SCFH. Air emissions from each engine will be discharged through a stack 0.8 feet in diameter, 20 feet above grade, at a rate of 3,084 ACFM at 1,000°F.
Brake specific fuel consumption for the 495-hp White-Superior 6G825 (CM-4) with catalytic converter has been listed at 7,500 BTU/hp-hr for a fuel consumption of 3,713 SCFH. Air emissions from each engine will be discharged through a stack 0.8 feet in diameter, 20 feet above grade, at a rate of 3,084 ACFM at 1,000°F.
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). Emissions of formaldehyde were calculated for the 495-hp White-Superior 6G825 using the 4-stroke rich-burn engine factor of 0.0205 lb/MMBTU from AP-42 (7/00), Section 3.2, for a heat input of 3.71 MMBTUH. The table below lists estimated formaldehyde emissions for the compressor engines. A HAP oxidation efficiency of 70% was estimated for the catalytic converter. Total formaldehyde emissions are below the de minimis levels.
Emissions of Toxics From Engines
Source / Pollutant / Toxicity Category / De MinimisLevels / EMISSIONS
lb/hr / TPY / lb/hr / TPY
(C-1) / Formaldehyde / A / 0.57 / 0.6 / 0.08 / 0.33
(C-2) / Formaldehyde / A / 0.57 / 0.6 / 0.02 / 0.1
Total / 0.10 / 0.43
Dehydration units using glycol desiccants will emit benzene, toluene, ethyl benzene, xylene, and n-hexane from the glycol reboiler vent stack. Benzene is a Category A toxic, while the others are Category C toxics. These emissions are summarized in Table below.
Dehydrator HAP Emissions
Pollutant / ToxicCategory / CAS
Number / MAAC / De Minimis / Emissions
µg/m3 / lb/hr / TPY / lb/hr / TPY*
Benzene / A / 71432 / 32 / 0.57 / 0.6 / 0.65 / 2.84
Toluene / C / 108883 / 37,668 / 5.6 / 6.0 / 1.17 / 5.15
Ethylbenzene / C / 100414 / 43,427 / 5.6 / 6.0 / 0.30 / 1.31
Xylene / C / 13300207 / 43,427 / 5.6 / 6.0 / 1.48 / 6.50
n-Hexane / C / 110543 / 17,628 / 5.6 / 6.0 / 0.10 / 0.43
Total HAPs / 3.7 / 16.23
All emissions of toxics are below the de minimis levels except for benzene and xylene. Emissions of these toxic compounds were modeled using EPA’s SCREEN3 air dispersion model. The calculated maximum concentration from SCREEN3 modeling study is expressed as 1-hour average figure. In order to convert the 1-hour average to a 24-hour average for comparison, the time-scaling factor 0.4 is used. The maximum calculated benzene and xylene impacts were 41 and 95 μg/m3 (24-hour average), respectively. The ambient impact for benzene is not in compliance with the MAAC of 32 μg/m3. The ambient impact for xylene is in compliance with the MAAC of 43,427 μg/m3.
SECTION IV. INSIGNIFICANT ACTIVITIES
The insignificant activities identified and justified in the application are duplicated below. Records are available to confirm the insignificance of the activities. Appropriate recordkeeping of activities indicated below with “*” is specified in the Specific Conditions.
1. Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 MMBTU/hr heat input (commercial natural gas). The dehydration unit’s reboiler is rated less than 0.125 MMBTUH and others may be used in the future.
2. Emissions from stationary internal combustion engines rated less than 50-hp output. None identified but may be used in the future.
3. * Storage tanks with a capacity less than or equal to 10,000 gallons that store volatile organic liquids with a true vapor pressure less than or equal to 1.0 psia at maximum storage temperature.
4. 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. Unloading of the condensate tank into tank trucks is less than 10,000 gallons/day. Emissions from tank unloading were based on approximately 201,759 gallons per year.
5. * 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. The condensate tanks store condensate prior to custody transfer and each has a capacity of less than 420,000 gallons.
6. * Emissions from storage tanks constructed with a capacity less than 39,894 gallons which store a VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. All of the tanks at the facility, other than the condensate tanks, have capacities less than 39,894 gallons and store products having a vapor pressure less than 1.5 psia.
7. Hand wiping and spraying of solvents from containers with less than 1 liter capacity used for spot cleaning and/or degreasing in ozone attainment areas. This activity is conducted as part of maintenance.
8. Activities that have the potential to emit no more than 5 TPY (actual) of any criteria pollutant.
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, Emission 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 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 a single HAP that the EPA may establish by rule
· 0.6 TPY of any one Category A toxic substance
· 1.2 TPY of any one Category B toxic substance
· 6.0 TPY of any one Category C toxic substance
Emissions limitations have been incorporated from the permit application and the initial Title V operating permit.
OAC 252:100-9 (Excess Emission and Malfunction 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.