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  1. 1. DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM February 1, 2005 TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality THROUGH: Richard Kienlen, P.E., Engr. Mgr. II, New Source Permits Section THROUGH: Peer Review, Judy Cupples FROM: Herb Neumann, Regional Office at Tulsa SUBJECT: Evaluation of Permit No. 2004-004-O BP America Production Company Red Oak Compressor Station West (SIC #1311) Section 17, T6N, R21E, Latimer County, Oklahoma Driving Directions: Travel on US 270 east into Red Oak. Take first available paved road to north (not OK 82), ½ mile to “T”, ½ mile west, then approximately 3 miles north and west (this becomes N4455), turn west again at E1395, ½ mile to Section 17, look for site. INTRODUCTION Applicant submitted an operating permit application for the Red Oak Station West, received by DEQ on April 19, 2004. Red Oak West was constructed in 1994 and has been operating without a permit. The current permit effort satisfies conditions of Consent Order 04-393 and will serve as the first operating permit for the facility. PROCESS DESCRIPTION AND EQUIPMENT The facility is a natural gas gathering compressor station consisting of two compressors, seven tanks, and a fuel gas heater. Fugitive emissions from piping components are treated as an emission unit for this analysis. An inlet scrubber separates produced water from the natural gas. Natural gas from the producing wells is lean and there is no measurable condensate production, thus no flash emissions or condensate loading. The facility operates on a continuous basis (8,760 hours per year). Emission sources are grouped as follows. I. Internal Combustion Engines Unit ID HP Make/Model/Serial No. Type Const. Date COMP1 1,232 Waukesha L7042GSI/244670 Turbocharged 4SRB Feb 1999 COMP2 1,232 Waukesha L7042GSI/316341 Turbocharged 4SRB June 1998 Both units are fitted with catalytic converters and air/fuel ratio controllers.
  2. 2. PERMIT MEMORANDUM 2004-004-O DRAFT 2 II. Tanks Unit ID Capacity Contents Const. Date PWTK1 300 barrels Produced water 3/94 LUBETK1 300 gallons Lube oil 3/94 LUBETK2 300 gallons Lube oil 3/94 ANTIFRZTK1 300 gallons Antifreeze (Ambitrol) 3/94 ANTIFRZTK2 300 gallons Antifreeze (Ambitrol) 3/94 USEDOILTK1 300 gallons Used oil 3/94 USEDOILTK2 300 gallons Used oil 3/94 III. Fugitives Various piping components, including valves, flanges and others, are considered. A list is found in the “Facility Emissions” section below. IV. Fuel gas heater This natural gas-fired unit is rated at 0.5 MMBTUH. FACILITY EMISSIONS I. Internal Combustion Engines Emission estimates for the two engines are based on continuous operations (8,760 hours per year) and manufacturer’s data for NOx, CO, and NMHC. PM and SO 2 factors are taken from Table 3.2-3 of AP-42 (7/00). Brake-specific fuel consumption is listed at 7,577 BTU/hp-hr and the heat content of the fuel stream is 1,002 BTU/CF, so fuel consumption is 9,321 SCFH at 1,000 RPM. Air emissions from the engine are discharged through a stack ten inches in diameter and 14.5 feet above grade at a rate of 5,377 ACFM and 1,055 °F. Emission Factors NOX CO NMHC PM10 SO2 2.6 g/hp-hr 2.25 g/hp-hr 0.3 g/hp-hr 0.0194 lb/MMBTU 0.000588 lb/MMBTU Pollutant Emissions (each engine) Total Emissions Lb/hr TPY TPY NOX 7.06 30.9 61.9 CO 6.11 26.8 53.6 NMHC 0.81 3.57 7.14 PM10 0.18 0.79 1.59 SO2 0.01 0.02 0.05 II. Tanks The production company applies an arbitrary non-zero condensate factor to all produced water in the formations under consideration. Use of this factor (925 lb of VOC/MMCF) for the produced water tanks yields only 0.0058 lbs/hr or 0.026 TPY of VOC. Loading losses and flash emissions are not calculated because the produced water is very close to fresh, with no sheen or indications of hydrocarbon content.
  3. 3. PERMIT MEMORANDUM 2004-004-O DRAFT 3 III. Fugitives Fugitive emissions are estimated using Table 2-4 of EPA’s “Protocol for Equipment Leak Emission Estimates” (11/95, EPA-453/R-95-017). Gas analysis shows the mol wt% of C3+ to be 0.90%. The following table shows estimated numbers of components and calculation results. Source Number Leak Factors (kg/hr) VOC Emissions (TPY) Compressors Seals 12 0.00880 0.0092 Flanges 238 0.00039 0.0081 Open Ended Lines 16 0.00200 0.0028 Pump Seals 8 0.00240 0.0017 Valves 248 0.00450 0.0969 Total VOC Emissions 0.12 IV. Fuel gas heater Emission factors from Tables 1.4-1 and 2 of AP-42 (7/98) yield negligible results, as follow. Pollutant Emissions Lb/hr TPY NOX 0.05 0.22 CO 0.04 0.18 NMHC <0.01 0.01 PM10 <0.01 0.02 SO2 <0.01 <0.01 Facility-Wide Emissions (TPY) Source NOX CO NMHC PM10 SO2 Engines 61.9 53.6 7.14 1.59 0.05 Tanks - - 0.03 - - Fugitives - - 0.12 - - Fuel heater 0.22 0.18 0.01 0.02 <0.01 Totals 62.1 53.7 7.30 1.61 0.05 The engines have emissions of air toxics, 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 maximum acceptable ambient concentration (MAAC) of 12 µg/m3 (24-hr average). The Table 3.2-3, AP-42 (7/00) value of 0.0205 lbs/MMBTU was used to calculate emissions of formaldehyde for the two engines, ignoring any effects of the catalytic converter, and each engine’s emissions exceeds the annual Category A de minimis level. EPA’s Screen3 air dispersion modeling program was used to calculate ground level concentrations (GLC) of formaldehyde for comparison with the MAAC. A maximum one-hour concentration of 2.5 µg/m3 was found for each emission point at a distance of 358 feet from the source. Achieving conservatively high results by simply adding the GLCs together and using Screen3’s transform factor to arrive at 24-hour values yields a total GLC of 2 µg/m3. Details of the model are presented in tabular form following the emission table.
  4. 4. PERMIT MEMORANDUM 2004-004-O DRAFT 4 Formaldehyde Emissions Estimated Emissions Source lb/hr TPY COMP 1 0.19 0.84 COMP 1 0.19 0.84 Totals 0.38 1.68 INPUT PARAMETERS Vertical stack Pollutant: Formaldehyde Height: 14.5 ft. Emission Rate: 0.192 lbs/hr Diameter: 10 in. Velocity: 164 fps Fenceline Distance: 0 ft. Stack Temperature: 1,005 °F Land Use: Rural Ambient Temperature: 68 °F Terrain: Flat Background Concentration: 0.0 µg/m3 MODELING OPTIONS Source: Continuous Steady-state Isolated Point Meteorology: All Stabilities & Wind Speeds Downwash: Yes Mixing Height: Regulatory Cavity: Regulatory Default Receptors: Flat 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 addressed 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. Required annual information (Turn-Around Document) shall be provided to Air Quality.
  5. 5. PERMIT MEMORANDUM 2004-004-O DRAFT 5 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. Since criteria pollutant emissions are less than 100 TPY for each pollutant, and emissions of Hazardous Air Pollutants (HAP) will not exceed 10 TPY for any one HAP or 25 TPY for any aggregate of HAP, the facility is defined as a minor source. As such, BACT is not required. 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 new and existing fuel-burning equipment, with emission limits based on maximum design heat input rating, as found in Appendix C. Fuel- burning equipment is defined in OAC 252:100-1 as “combustion devices used to convert fuel or wastes to usable heat or power.” The two Waukesha engines are subject to the requirements of this subchapter. Table 3.2-3 of AP-42 (7/00) lists the total PM emissions from these engines to be 0.00991 lbs/MMBTU. The permit requires the use of natural gas for all fuel-burning units to ensure compliance with this section. Maximum Heat Input Appendix C Emission Potential Emission Rate Equipment each, (MMBTUH) Limit, (lbs/MMBTU) each, (lbs/MMBTU) COMP1, 2 9.34 0.6 0.0194 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 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 has negligible potential to violate this requirement; therefore it is not necessary to require specific precautions to be taken.
  6. 6. PERMIT MEMORANDUM 2004-004-O DRAFT 6 OAC 252:100-31 (Sulfur Compounds) [Applicable] Part 2 limits the ambient air impact of hydrogen sulfide (H2S) emissions from any existing source or new source to 0.2 ppm for a 24-hour average (equivalent to 280 µg/m3). An analysis of inlet gas to this facility showed no hydrogen sulfide content. 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 lbs/MMBTU heat input. This is equivalent to approximately 0.2-weight percent sulfur in the fuel gas, which is equivalent to 2,000-ppm sulfur. Thus, a limitation of 159-ppm 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 159 ppm for all fuel-burning equipment to ensure compliance with Subchapter 31. Compliance testing of the fuel sulfur content whenever the gas supplier or gas field is changed will be used to ensure compliance with this limitation. Part 5 also limits hydrogen sulfide emissions from new petroleum or natural gas process equipment (constructed after July 1, 1972). Removal of hydrogen sulfide in the exhaust stream, or oxidation to sulfur dioxide, is required unless hydrogen sulfide emissions would be less than 0.3 lbs/hr for a two-hour average. An analysis of inlet gas to this facility showed no hydrogen sulfide content. 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, 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 storage tanks constructed after December 28, 1974, with a capacity of 400-gallons or more and storing 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. There are no liquids with vapor pressure greater than 1.5 psia stored at this facility. Part 5 limits the VOC content of coating used in coating lines or operations. This facility will not normally conduct coating or painting operations except for routine maintenance of the facility and equipment, which is exempt. Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize VOC emissions. Temperature and available air must be sufficient to provide essentially complete combustion. The engines at this facility are designed to provide essentially complete combustion of organic materials. Part 7 requires all rotating pumps or compressors handling VOC to be equipped with mechanical seals or other equipment of equal efficiency. All reciprocating pumps or compressors handling VOC are to be equipped with packing glands that are properly installed and in good working order such that emissions from the drain recovery system are limited to two cubic inches of VOC in any 15 minute period at standard conditions per pump or compressor. The equipment at this location is subject to this requirement.
  7. 7. PERMIT MEMORANDUM 2004-004-O DRAFT 7 Part 7 regulates effluent water separators that receive water containing more than 200 gallons per day of VOC. There is no effluent water separator at this facility. The separator removes water from the gas stream. 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. Part 5 is a state-only requirement governing toxic air contaminants. New sources (constructed after March 9, 1987) emitting any category “A” pollutant above de minimis levels must perform a BACT analysis, and if necessary, install BACT. All sources are required to demonstrate that emissions of any toxic air contaminant that exceed the de minimis level do not cause or contribute to a violation of the maximum acceptable ambient concentration (MAAC). As discussed in the Emissions section above, emissions of formaldehyde, a Category A toxic, are above the de minimis threshold for each engine. Modeling performed in the earlier discussion shows that ground level concentrations of formaldehyde are well below the MAAC. Since the Air Quality Division (AQD) is in the process of reviewing and proposing significant changes to Subchapter 41, the permit will be issued without the BACT review. However, the permit may be re-opened to address compliance with the final rule. OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable] This subchapter provides general requirements for testing, monitoring and recordkeeping and applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To determine compliance with emissions limitations or standards, the Air Quality Director may require the owner or operator of any source in the state of Oklahoma to install, maintain and operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All required testing must be conducted by methods approved by the Air Quality Director and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests. Emissions and other data required to demonstrate compliance with any federal or state emission limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any required testing or monitoring not conducted in accordance with the provisions of this subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.
  8. 8. PERMIT MEMORANDUM 2004-004-O DRAFT 8 The following Oklahoma Air Pollution Control Rules are not applicable to this facility: OAC 252:100-11 Alternate Reduction not eligible OAC 252:100-15 Mobile Sources not in source category OAC 252:100-17 Incinerators not type of emission unit OAC 252:100-23 Cotton Gins not type of emission unit OAC 252:100-24 Feed & Grain Facility not in source category OAC 252:100-39 Nonattainment Areas not in subject area OAC 252:100-47 Landfills not type of source category FEDERAL REGULATIONS PSD, 40 CFR Part 52 [Not Applicable] PSD does not apply. Final total emissions are less than the major source threshold of 250 TPY of any single regulated pollutant and the facility is not one of the 26 specific industries with a threshold of 100 TPY. NSPS, 40 CFR Part 60 [Not Applicable] Subpart Kb, VOL Storage Vessels. This subpart regulates hydrocarbon storage tanks larger than 19,813 gallons capacity and built after July 23, 1984. There are no tanks of this size at the facility. Subpart GG, Stationary Gas Turbines. The compressors here are powered by reciprocating engines. Subpart VV, Equipment Leaks of VOC in the Synthetic Organic Chemical Manufacturing Industry. The equipment is not in a SOCMI plant. Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. The facility does not engage in natural gas processing. Subpart LLL, Onshore Natural Gas Processing: SO2 Emissions. This subpart affects sweetening units and sweetening units followed by sulfur recover units. This facility does not have a sweetening unit. NESHAP, 40 CFR Part 61 [Not Applicable] There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium, coke oven emissions, mercury, radionuclides, or vinyl chloride except for trace amounts of benzene. Subpart J Equipment Leaks of Benzene, concerns only process streams that contain more than 10% benzene by weight. Analysis of Oklahoma natural gas indicates maximum benzene content less than 1%. NESHAP, 40 CFR Part 63 [Not Applicable] Subpart HH, Oil and Natural Gas Production Facilities. This subpart applies to affected emission points that are located at facilities that are major sources of HAPs and either process, upgrade, or store hydrocarbons prior to the point of custody transfer or prior to which the natural gas enters the natural gas transmission and storage source category. The facility is a minor source of HAPs.
  9. 9. PERMIT MEMORANDUM 2004-004-O DRAFT 9 Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart was published in the Federal Register on June 15, 2004, and affects existing, new, and reconstructed spark ignition 4-stroke rich-burn (4SRB) RICE, new or reconstructed spark ignition 2-stroke lean-burn (2SLB) RICE, new or reconstructed 4-stroke lean-burn (4SLB) RICE, and new or reconstructed compression ignition (CI) RICE, with a site-rating greater than 500 brake horsepower, that are located at a major source of HAP emissions. This facility is not a major source of HAPs. Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable] This facility will not process or store more than the threshold quantity of any regulated substance (Section 112r of the Clean Air Act 1990 Amendments). More information on this federal program is available on the web page: www.epa.gov/ceppo. COMPLIANCE Tier Classification This application has been classified as Tier II because the facility had potential to be a major source and did not file for a synthetic minor permit in a timely fashion. The result of this permit action will be an operating permit for a minor source facility. Public notice of filing of this application was published in the Latimer County New-Tribune on December 23, 2004, and in the Latimer County Today on December 23, 2004. The application was available for review at the Wilburton Public Library and at the AQD main office in Oklahoma City. Public notice of the 30-day public review opportunity for the draft permit will be published in another newspaper when the draft permit is available. Information on all permit actions is available for review by the public in the Air Quality section of the DEQ Web Page: www.deq.state.ok.us The applicant has submitted an affidavit that they are not seeking a permit for land use or for any operation upon land owned by others without their knowledge. The affidavit certifies that the applicant has a current lease that is given to accomplish the permitted purpose and that the landowner has been notified by certified mail. Inspection The facility was inspected on April 9, 2004, by Helen King of Oklahoma Air Quality. This was a full compliance evaluation and gave rise to the need for permitting. All information necessary to permitting was obtained or requested during this visit and subsequent conversations, so no further inspection is necessary. Facility annual throughput for 2003 was 5.9 BCF, or approximately 16.1 MMCFD. Actual 2003 operating hours for the units included 8,074 for COMP1, 7,907 for COMP2, and 648 for a temporary unit. Testing Engine emission tests were conducted on December 15, 2004 using a portable engine analyzer. Engine test results were provided and are in compliance with the applicable permit limits. These results and the operating conditions at the time of the tests are listed in the following tables. Permit Limitations Test Results Source Test Date NOX (lb/hr) CO (lb/hr) NOX (lb/hr) CO (lb/hr) 1,232-hp COMP1 7.06 6.11 3.13 1.86 12/15/04 1,232-hp COMP2 7.06 6.11 2.10 1.96 12/15/04
  10. 10. PERMIT MEMORANDUM 2004-004-O DRAFT 10 Unit RPM HP Suction pressure Discharge pressure COMP1 914 984 58 psig 360 psig COMP2 920 989 60psig 330 psig Fee Paid Synthetic minor source operating permit Tier II processing fee of $2,000. SUMMARY The facility was constructed as described in the permit application. Ambient air quality standards are not threatened at this site. There are no longer any active Air Quality compliance or enforcement actions concerning this facility. Issuance of the minor source operating permit is recommended, contingent upon public comment and EPA review.
  11. 11. DRAFT PERMIT TO OPERATE AIR POLLUTION CONTROL FACILITY SPECIFIC CONDITIONS BP America Production Company Permit Number 2004-004-O Red Oak Compressor Station West The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on April 19, 2004. The Evaluation Memorandum dated February1, 2005, explains the derivation of applicable permit requirements and estimates of emissions; however, it does not contain operating limitations or permit requirements. Continuing operation under this permit constitutes acceptance of, and consent to, the conditions contained herein. 1. Points of emissions and emission limitations for each point. NOx CO VOC Sources lb/hr TPY lb/hr TPY lb/hr TPY Waukesha L7042GSI 1,232 hp (COMP1) 7.06 30.9 6.11 26.8 0.81 3.57 Waukesha L7042GSI 1,232 hp (COMP2) 7.06 30.9 6.11 26.8 0.81 3.57 The COMP1 serial # is 244670, and the COMP2 serial # is 316341. Both engines are equipped with catalytic converters. 2. The fuel-burning equipment shall be fueled only with pipeline-quality natural gas or with field gas with a maximum sulfur content of 159 ppm. 3. The permittee shall be authorized to operate the facility 24 hours a day, every day of the year. 4. The engines at the facility shall have a permanent identification plate attached, showing a unique identifier, such as the make, model number, and serial number. 5. At least once per calendar quarter, the permittee shall conduct tests of NO x and CO emissions in exhaust gases from each engine in Specific Condition No. 1 and from each replacement engine/turbine when operating under representative conditions for that period. Testing is required for any engine/turbine that runs for more than 220 hours during that calendar quarter. Engines/turbines shall be tested no sooner than 20 calendar days after the last test. Testing shall be conducted using a portable analyzer in accordance with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method approved by Air Quality. When four consecutive quarterly tests show the engine/turbine to be in compliance with the emissions limitations shown in the permit, then the testing frequency may be reduced to semi-annual testing. Likewise, when the following two consecutive semi-annual tests show compliance, the testing frequency may be reduced to annual testing. Upon any showing of non-compliance with emissions limitations or testing that indicates that emissions are within 10% of the emission limitations, the testing frequency shall revert to quarterly. Reduced testing frequency does not apply to engines with catalytic converters.
  12. 12. SPECIFIC CONDITIONS 2004-004-O DRAFT 2 6. The permittee shall maintain a record of operations as listed below. These records shall be retained on-site or at a local field office for a period of at least two years following the dates of recording and shall be made available to regulatory personnel upon request. a. Results of the required emissions testing of each engine and each replacement engine/turbine. b. Analysis of current fuel gas sulfur content (updated whenever the supply changes). c. O&M log for any engines not tested in each 6-month period. d. Operating hours of engines/turbines that operated less than 220 hours and were not tested in a quarter. 7. Replacement (including temporary periods of up to six months for maintenance purposes), of an engine with emissions limitations specified in this permit with engines/turbines of lesser or equal emissions of each pollutant (in lbs/hr and TPY) is authorized under the following conditions. a. The permittee shall notify AQD in writing within 10 days of the startup of the replacement engine(s)/turbine(s). Said notice shall include the date of the change, the new engine(s)/turbine(s) make, model, serial number, horsepower, fuel usage, stack flow (ACFM), stack temperature (°F), stack height (feet), stack diameter (inches), and pollutant emissions rates (g/hp-hr, lb/hr, and TPY) at maximum rated horsepower for the altitude/location. b. Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be conducted to confirm continued compliance with NOx and CO emission limitations. A copy of the first quarter testing shall be provided to AQD within 60 days of start-up of each replacement or additional engine/turbine. The test report shall include the engine(s)/turbine(s) fuel usage, stack flow (ACFM), stack temperature (oF), stack height (feet), stack diameter (inches), and pollutant emission rates (g/hp-hr and TPY) at maximum rated horsepower for the altitude/location. c. Replacement of equipment and emissions are limited to equipment and emissions that are not subject to NSPS, NESHAP, or PSD review. 8. When periodic compliance testing shows engine/turbine exhaust emissions in excess of the lb/hr limits in Specific Condition Number 1, the permittee shall comply with the provisions of OAC 252:100-9 for excess emissions during start-up, shutdown, and malfunction of air pollution control equipment. Requirements of OAC 252:100-9 include immediate notification and written notification of Air Quality and demonstrations that the excess emissions meet the criteria specified in OAC 252:100-9.
  13. 13. MINOR SOURCE PERMIT TO OPERATE / CONSTRUCT AIR POLLUTION CONTROL FACILITY STANDARD CONDITIONS (October 31, 2003) A. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma Department of Environmental Quality (DEQ) in accordance with and under the authority of the Oklahoma Clean Air Act. The permit does not relieve the holder of the obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or ordinances. This specifically includes compliance with the rules of the other Divisions of DEQ: Land Protection Division and Water Quality Division. B. A duly issued construction permit or authorization to construct or modify will terminate and become null and void (unless extended as provided in OAC 252:100-7-15(g)) if the construction is not commenced within 18 months after the date the permit or authorization was issued, or if work is suspended for more than 18 months after it is commenced. [OAC 252:100-7-15(f)] C. The recipient of a construction permit shall apply for a permit to operate (or modified operating permit) within 60 days following the first day of operation. [OAC 252:100-7-18(a)] D. Unless specified otherwise, the term of an operating permit shall be unlimited. E. Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this facility is required and shall be made in writing by the transferor within 10 days after such date. A new permit is not required. [OAC 252:100-7-2(f)] F. The following limitations apply to the facility unless covered in the Specific Conditions: 1. No person shall cause or permit the discharge of emissions such that National Ambient Air Quality Standards (NAAQS) are exceeded on land outside the permitted facility. [OAC 252:100-3] 2. All facilities that emit air contaminants are required to file an emission inventory and pay annual operating fees based on the inventory. Instructions and forms are available on the Air Quality section of the DEQ web page. www.deq.state.ok.us [OAC 252:100-5] 3. All excess emissions shall be reported to the Director of the Air Quality Division as soon as practical during normal office hours and no later than the next working day following the malfunction or release. Within ten (10) business days further notice shall be tendered in writing containing specific details of the incident. [OAC 252:100-9] 4. Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in the Open Burning subchapter. [OAC 252:100-13] 5. No particulate emissions from new fuel-burning equipment with a rated heat input of 10 MMBTUH or less shall exceed 0.6 lbs/MMBTU. [OAC 252:100-19] 6. 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
  14. 14. MINOR SOURCE STANDARD CONDITIONS October 31, 2003 2 three such periods in any consecutive 24 hours. In no case shall the average of any six- minute period exceed 60% opacity. [OAC 252:100-25] 7. No visible fugitive dust emissions shall be discharged 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. [OAC 252:100-29] 8. No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2 lbs/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur dioxide. [OAC 252:100-31] 9. Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or greater under actual conditions shall be equipped with a permanent submerged fill pipe or with an organic material vapor-recovery system. [OAC 252:100-37-15(b)] 10. All fuel-burning equipment shall at all times be properly operated and maintained in a manner that will minimize emissions of VOCs. [OAC 252:100-37-36] 11. Except as otherwise provided, no person shall cause or permit the emissions of any toxic air contaminant in such concentration as to cause or to contribute to a violation of the MAAC. [OAC 252:100-41] G. Any owner or operator subject to provisions of NSPS shall provide written notification as follows: [40 CFR 60.7 (a)] 1. A notification of the date of when construction of an affected facility will be commenced postmarked no later than 30 days prior to such date. 2. A notification of the anticipated date of initial start-up of an affected facility postmarked no more than 60 days nor less than 30 days prior to such a date. 3. A notification of the actual date of initial start-up of an affected facility postmarked within 15 days after such date. 4. If a continuous emission monitoring system is included in the construction, a notification of the date upon which the test demonstrating the system performance will commence, along with a pretest plan, postmarked no less than 30 days prior to such a date. H. Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected facility or any malfunction of the air pollution control equipment. [40 CFR 60.7 (b)] I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all measurements and other information required by this subpart recorded in a permanent file suitable for inspection. This file shall be retained for at least five years following the date of such measurements, maintenance, and records. [40 CFR 60.7 (d)] J. Any owner or operator subject to the provisions of NSPS shall conduct performance test(s) and furnish to AQD a written report of the results of such test(s). Test(s) shall be conducted within 60 days after achieving the maximum production rate at which the facility will be operated, but not later than 180 days after initial start-up. [40 CFR 60.8]
  15. 15. PERMIT AIR QUALITY DIVISION STATE OF OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY 707 N. ROBINSON, SUITE 4100 P.O. BOX 1677 OKLAHOMA CITY, OKLAHOMA 73101-1677 Issuance Date: Permit No.: 2004-004-O BP America Production Company, having complied with the requirements of the law, is hereby granted permission to operate the Red Oak Compressor Station West located at Section 17, T6N, R22E, in Latimer County, Oklahoma, subject to the following conditions, attached: [X] Standard Conditions dated October 31, 2003 [X] Specific Conditions _____________________________________________Chief Engineer, Air Quality Division
  16. 16. Jayne Gates, Arkoma Asset Manager BP America Production Company P.O. Box 3092, MC2.168 Houston, TX 77253-3092 Re: Operating Permit No. 2004-004-O Red Oak Compressor Station West Dear Ms. Gates: Enclosed is the permit authorizing operation of the referenced facility. Please note that this permit is issued subject to standard and specific conditions, which are attached. These conditions must be carefully followed since they define the limits of the permit and will be confirmed by periodic inspections. Also note that you are required to annually submit an emissions inventory for this facility. An emissions inventory must be completed on approved AQD forms and submitted (hardcopy or electronically) by March 1st of every year. Any questions concerning the form or submittal process should be referred to the Emissions Inventory Staff at (405) 702-4100. Thank you for your cooperation in this matter. If we may be of further service, please contact our office at (918) 293-1600. Air Quality personnel are located in the DEQ Regional Office at Tulsa, 3105 E. Skelly Drive, Suite 200, Tulsa, OK, 74105-6370. Sincerely, Herb Neumann AIR QUALITY DIVISION copy: Latimer County DEQ Office Encl.
  17. 17. Jayne Gates, Arkoma Asset Manager BP America Production Company P.O. Box 3092, MC2.168 Houston, TX 77253-3092 SUBJECT: Permit Number: 2004-004-O Facility: Red Oak Compressor Station West Location: Section 17, T6N, R21E, near Red Oak, Latimer County Dear Ms. Gates: Air Quality Division has completed the initial review of your permit application referenced above. Pursuant to the terms of Consent Order 04-393, this application is being processed under the provisions of Tier II. In accordance with 27A O.S. § 2-14-302 and OAC 252:4-7-13, the enclosed draft permit is now ready for public review. The requirements for public review include the following steps that you must accomplish: 1. Publish at least one legal notice (one day) in at least one newspaper of general circulation within the county where the facility is located. (Instructions enclosed) Please provide this office with a copy of your proposed notice for possible comment before submitting it to the newspaper. 2. Provide for public review (for a period of 30 days following the date of the newspaper announcement) a copy of this draft permit and a copy of the application at a convenient public location within the county of the facility. Facility offices are not acceptable locations. 3. Send to AQD a copy of the proof of publication notice from Item #1 above together with any additional comments or requested changes that you may have on the draft permit. Thank you for your cooperation. If you have any questions, please refer to the permit number above and contact me at (918) 293-1624. Sincerely, Herb Neumann AIR QUALITY DIVISION Enclosures