Permit Number: P010XXXX
Facility Name: Ohio Shale Gas Well
Facility ID: 0000000000
Oil and Gas Production Site and/or Gas Gathering Compressor Station, 7/29/11 DRAFT GP
Terms Last Revised: 6/02/2016
Permit Template for Area Sources Only
File name: HH.63.docx
Note: Search for “XX” to fill in the lb/hr &TPY limits
Last Revised: 7/26/11
Natural Gas Process Plant
With
Part 63, Subpart HH
Part 60, Subpart KKK
Part 60, Subpart VV
1. Emissions Unit: Natural Gas Process Plant, P001
Operations, Property and/or Equipment Description:
P001 / Glycol dehydration unit (includes contact tower or absorption column and glycol dehydration unit reboiler) and Gas-condensate-glycol (GCG) separator (flash separator) controlled by an enclosed combustion or a vapor recovery devicea) This permit document constitutes a permit-to-install issued in accordance with ORC 3704.03(F) and a permit-to-operate issued in accordance with ORC 3704.03(G).
(1) For the purpose of a permit-to-install document, the emissions unit terms and conditions identified below are federally enforceable with the exception of those listed below which are enforceable under state law only.
a. None.
(2) For the purpose of a permit-to-operate document, the emissions unit terms and conditions identified below are enforceable under state law only with the exception of those listed below which are federally enforceable.
a. None.
b) Applicable Emissions Limitations and/or Control Requirements
(1) The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.
/ Applicable Rules/Requirements / Applicable Emissions Limitations/Control Measures /a. / OAC rule 3745-31-05(A)(3), as effective 11/30/01 / Emissions of Volatile Organic Compounds (VOC) shall not exceed:
XX lb/hr and
XX tons/year.
See b)(6)(a)
b. / OAC rule 3745-31-05(A)(3)(a)(ii),
as effective 12/01/06 / See b)(6)b.
c. / Part 63, Subpart HH, National Emission Standards for HAP from Oil and Natural Gas Production Facilities,
40 CFR 63.771(c)
or
ORC 3704.03(T) / The emissions from the glycol dehydration unit shall be vented through a closed-vent system, designed and operated with no detectable emissions, to a control device meeting the requirements of §63.771(d).
d. / OAC rule 3745-17-07(A)(1)(a) / The emission limitation specified by this rule is less stringent than the emission limitation established pursuant to 40 CFR 63.771(c) for a closed-vent system.
(2) Additional Terms and Conditions
a. The permittee has satisfied the Best Available Technology (BAT) requirements pursuant to OAC paragraph 3745-31-05(A)(3), as effective November 30, 2001, in this permit. On December 1, 2006, paragraph (A)(3) of OAC rule 3745-31-05 was revised to conform to ORC changes effective August 3, 2006 (S.B. 265 changes), such that BAT is no longer required by State regulation for NAAQS pollutant less than ten tons per year. However, that rule revision has not yet been approved by U.S. EPA as a revision to Ohio’s State Implementation Plan (SIP). Therefore, until the SIP revision occurs and the U.S. EPA approves the revision to OAC rule 3745-31-05, the requirement to satisfy BAT still exists as part of the federally–approved SIP for Ohio. Once U.S. EPA approves the December 1, 2006 version of 3745-31-05, then these emission limits/control measures no longer apply.
b. These rule paragraphs apply once U.S. EPA approves the December 1, 2006 version of OAC rule 3745-31-05 as part of the State Implementation Plan.
i. The Best Available Technology (BAT) requirements under OAC rule 3745-31-05(A)(3) do not apply to the Sulfur Dioxide (SO2), Nitrogen Oxides (NOx), Particulate Emissions (PE) and Carbon Monoxide (CO) from this air contaminant source since the uncontrolled potential to emit for SO2, NOx, PE and CO are less than ten tons per year.
c. The estimated emissions of hazardous air pollutants (HAP), calculated from the designed maximum natural gas and hydrocarbon liquid throughput to the glycol dehydration units and losses from the storage vessels with the potential for flash emissions, demonstrate this facility to be an “area source” of HAP.
[40 CFR 63.760(a)] and [40 CFR 63.761]
d. The gas stream from the glycol dehydration unit reboiler vent and glycol dehydration unit process vent shall be vented through a closed-vent system to a control device meeting the requirements of §63.771.
[40 CFR 63.771] and/or [ORC 3704.03(T)]
e. The provisions of 40 CFR Part 60 Subpart HH shall apply at all times, except during startups, shutdowns, malfunctions, and periods of non-operation. The owner/operator shall not shut down equipment that is required to be utilized for compliance during times when emissions are being routed to such equipment. The owner/operator shall implement, to the extent reasonably available, measures to prevent or minimize emissions to the maximum extent possible during startup, shutdown, and malfunctions.
[40 CFR 63.762(a), (b), and (c)]
f. The facility must prepare a startup, shutdown, and malfunction plan, as required in §63.6(e)(3), if not meeting the exemptions in §60.764(e), i.e., having an average flowrate of natural gas to the glycol dehydration greater than 85,000 scm/day or having an actual average benzene emission rate from the glycol dehydration process vent more than 0.90 MG/year, and if also located in a UA plus offset and UC boundary (as defined in §63.761).
[40 CFR 63.762(d) and (e)]
(3) Additional Terms and Conditions (#1) for units:
1. using triethylene glycol; and
2. with an actual annual average flowrate of natural gas to the glycol dehydration unit of ≥85,000 scm/day or actual average emissions of benzene ≥0.90 MG/year; and
3. located within a UA plus offset and UC Boundary (as defined in 40 CFR 63.761)
#1 / Applicable Rule / Requirement1. / 40 CFR 63.760(b)(2); and
40 CFR 63.764(d)(1) / The triethylene glycol (TEG) dehydration unit is an affected source subject to Part 63, Subpart HH for oil and natural gas production facilities.
(4) Additional Terms and Conditions (#2) for units:
1. using triethylene glycol;
2. with an actual annual average flowrate of natural gas to the glycol dehydration unit of ≥85,000 scm/day or actual average emissions of benzene ≥0.90 MG/year; and
3. NOT located within a UA plus offset and UC Boundary (as defined in 40 CFR 63.761)
#2 / Applicable Rule / Requirement1. / 40 CFR 63.760(b)(2); and
40 CFR 63.764(d)(2) / The triethylene glycol (TEG) dehydration unit is an affected source subject to Part 63, Subpart HH for oil and natural gas production facilities.
(5) Additional Terms and Conditions (#3) for units:
1. using triethylene glycol;
2. with an actual annual average flowrate of natural gas to the glycol dehydration unit of <85,000 scm/day or actual average emissions of benzene <0.90 MG/year
#3 / Applicable Rule / Requirement1. / 40 CFR 63.760(b)(2); and
40 CFR 63.764(e)(1) / The glycol dehydration unit is exempt from the control requirements of 40 CFR 63.764(d) because the actual annual average flowrate of natural gas to the glycol dehydration unit is less than 85,000 scm/day OR the actual average emissions of benzene from the glycol dehydration unit process vent is less than 0.90 megagram/year.
(6) Additional Terms and Conditions (#4) for units: NOT using triethylene glycol
#4 / Applicable Rule / Requirement1. / 40 CFR 63.760(b)(2) / A dehydration unit is not an affected area source subject to Part 63 Subpart HH if it is not using triethylene glycol, which must be documented in the permit application.
c) Operational Restrictions
(1) Operational Restrictions (#1) for units:
1. using triethylene glycol; and
2. with an actual annual average flowrate of natural gas to the glycol dehydration unit of ≥85,000 scm/day or actual average emissions of benzene ≥0.90 MG/year; and
3. located within a UA plus offset and UC Boundary (as defined in 40 CFR 63.761)
#1 / Applicable Rule / Requirement1. / 40 CFR 63.764(d)(1)(i) / The TEG dehydration unit must be equipped with a control device that meets the requirements of 40 CFR 63.765 and 40 CFR 63.771(d).
2. / 40 CFR 63.771(c) and (d)(1)(iii); and
40 CFR 63.765 / Emissions from the TEG dehydration unit* must be vented through a closed-vent system to a control device meeting the requirements of §63.771(d); the collection system and control device must be designed and operated with no detectable emissions and operated at all times the TEG dehydration unit is in operation.
3. / 40 CFR 63.771(c)(3); and
40 CFR 63.773(c)(2)(iv) / Each bypass device to the closed-vent system must be installed with a flow indicator which takes a reading once every 15 minutes and is installed with an alarm (for any bypass); or must install a car-seal or lock-and–key mechanism on the bypass device to maintain the bypass valve in a closed position.
4. / 40 CFR 63.771(d)(1)(iii) / A flare, used to demonstrate compliance, must be designed and operated in accordance with §63.11(b), except the net heating value of the gas shall instead be computed from the equation found in §60.485(g)(4).
(2) Operational Restrictions (#2) for units:
1. using triethylene glycol;
2. with an actual annual average flowrate of natural gas to the glycol dehydration unit of ≥85,000 scm/day or actual average emissions of benzene ≥0.90 MG/year; and
3. NOT located within a UA plus offset and UC Boundary (as defined in 40 CFR 63.761)
#2 / Applicable Rule / Requirement1. / 40 CFR 63.764(d)(2) / The TEG dehydration unit shall be operated such that the glycol circulation rate does not exceed the optimum circulation rate determined in accordance with this paragraph.
2. / ORC 3704.03(T) / Emissions from the TEG dehydration unit* shall be vented through a closed-vent system to a control device meeting the requirements of §63.771(d); the collection system and control device must be designed and operated with no detectable emissions and operated at all times the TEG dehydration unit is in operation.
3. / ORC 3704.03(T) / A flare, used to demonstrate compliance, must be designed and operated in accordance with §60.18(c) to (f), except the net heating value of the gas shall instead be computed from the equation found in §60.485(g)(4).
(3) Operational Restrictions (#3) for units:
1. using triethylene glycol;
2. with an actual annual average flowrate of natural gas to the glycol dehydration unit of <85,000 scm/day or actual average emissions of benzene <0.90 MG/year
#3 / Applicable Rule / Requirement1. / ORC 3704.03(T) / Emissions from the TEG dehydration unit* must be vented through a closed-vent system to a control device meeting the requirements of §63.771(d); the collection system and control device must be designed and operated with no detectable emissions and operated at all times the TEG dehydration unit is in operation.
2. / ORC 3704.03(T) / A flare, used to demonstrate compliance, must be designed and operated in accordance with §60.18(c) to (f), except the net heating value of the gas shall instead be computed from the equation found in §60.485(g)(4).
(4) Operational Restrictions (#4) for units: NOT using triethylene glycol
#4 / Applicable Rule / Requirement1. / ORC 3704.03(T) / Emissions from the glycol dehydration unit* must be vented through a closed-vent system to a control device meeting the requirements of §63.771(d); the collection system and control device must be designed and operated with no detectable emissions and operated at all times the glycol dehydration unit is in operation.
2. / ORC 3704.03(T) / A flare, used to demonstrate compliance, must be designed and operated in accordance with §60.18(c) to (f), except the net heating value of the gas shall instead be computed from the equation found in §60.485(g)(4).
* The glycol dehydration unit process vent means the glycol dehydration unit reboiler vent and the vent from the GCG separator
(5) A closed-vent system, designed and operated with “no detectable emissions”, shall route all gases, vapors, and fumes from the glycol dehydration unit to a control device meeting the requirements of §63.771. Each bypass device to the closed-vent system shall meet the requirements of §63.771(c)(3). The control device shall be operated during all period of operation of the glycol dehydration unit.
[40 CFR 63.771(c) and (d)] or [ORC 3704.03(T)]
(6) The permittee shall install, operate, and maintain a monitoring instrument (with an accuracy of plus or minus 2% or better) to directly measure and record the natural gas flow rate to the glycol dehydration unit. The daily average natural gas flow rate shall be recorded and averaged at the end of every month* until the actual annual daily average flowrate can be calculated at the end of 12 months of operation.
[40 CFR 63.772(b)(1)] for [40 CFR 63.764(e)(1)]
(7) The process vent to the glycol dehydration unit shall be connected to a control device through a closed-vent system which shall be operated and maintained to comply with the following requirements:
a. The closed-vent system shall be designed and operated with “no detectable emissions”, as indicated by an instrument reading of less than 500 ppmv above background, as measured by the method specified in Method 21, 40 CFR Part 60 Appendix A. If using triethylene glycol in the dehydration unit, the closed-vent system shall be monitored for compliance with this limitation initially upon startup and annually thereafter.
b. The closed-vent system shall be operated at all times when emissions may be vented to it.
[40 CFR 63.772(c)] or [ORC 3704.03(T)]
(8) If using a flare to demonstrate compliance with Part 63 Subpart HH and to control HAP emissions from the glycol dehydration unit, the exhaust gases from the gas-condensate-glycol (GCG) separator and glycol dehydration unit reboiler vents shall be routed to the flare through a closed-vent system. The flare shall be operated with a flame present at all times when gases are vented to it. The presence of a pilot flame shall be monitored using a thermocouple or other heat sensing monitoring device equipped with a continuous recorder to detect the presence of a flame. The flare shall be designed and operated in accordance with §63.11(b).
[40 CFR 63.764(e)(1)], [40 CFR 63.771(d)(1)(iii)], [40 CFR 63.773(d)(3)(i)(C)], [40 CFR 60.18(c) through (f)], and/or [40 CFR 63.11(b)]
(9) If using an enclosed combustion device to demonstrate compliance with Part 63 Subpart HH, e.g., a thermal or catalytic vapor incinerator, boiler, or process heater, the control device shall: