PERMIT MEMORANDUM NO. 2006-160-TV DRAFT 13
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM May 4, 2007
TO: Phillip Fielder, P.E., Engr. Mgr. III, Air Quality Division
THROUGH: Matt Paque, Supervising Attorney, Air Quality Division
THROUGH: Richard Kienlen, P.E., Engr. Mgr. II, New Source Permits Unit
THROUGH: Kendal Stegmann, Sr. Environmental Manager, Compliance and Enforcement
THROUGH: Herb Neumann, P.E., Regional Office at Tulsa
THROUGH: David Pollard, P.E., Regional Office at Tulsa
FROM: Harold Wright, Regional Office at Tulsa
SUBJECT: Evaluation of Permit Application No. 2006-160-TV
CenterPoint Energy Field Services, Inc. (CEFS)
Southeast Spiro Compressor Station Dehydrator
Section 36, T9N, R25E, Le Flore County (Lat. 35.211º N – Long. 94.607º W)
Driving directions: From Spiro, south past the Spiro Filtration Plant approximately 1.3 miles to CenterPoint SE Spiro sign. Turn right and go about 0.2 miles past chicken houses to facility on south side of road.
SECTION I. INTRODUCTION
CenterPoint Energy Field Services, Inc. (CEFS) submitted an application to establish a Title V operating permit for a dehydrator collocated with a natural gas compressor station owned and operated by CenterPoint Energy Gas Transmission Co. (CEGT), (SIC Code 4922). For the compressor portion of the facility, constructed in 1964, the engines and associated equipment are currently operating under Permit No. 97-359-TV. There is a renewal permit in-house for this TV (No. 2003-097-TVR), which is currently in public review. It will also be reviewed by EPA before it can be approved.. Changes that have occurred since the issuance of the original Title V operating permit for the engines are concerned with dehydration equipment owned and operated by NorAm Field Services (NFS), which was changed to CEFS. CEFS owns and operates the 1.5 MMBTUH glycol regeneration unit, one drip tank (which catches small amounts of water from the dehydrator) and one glycol storage tank. CEFS and CEGT will each have separate Title V permits for their portions of the facility. This is the initial TV permit for CEFS. Emission inventories will be required for both facilities. CEFS and CEGT will only pay fees for their own equipment. Per Appendix I of OAC 252:100-8, added emission units rated at less than 5 MMBTUH are considered insignificant. Only physical changes that are significant modifications must have a construction permit. Any other changes in this permit are due to updated emission factors and additions or removal of equipment.
SECTION II. FACILITY DESCRIPTION
Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) in the equipment section. Field natural gas is the primary fuel for the dehydrator owned and operated by CEFS. Natural gas enters the facility and is routed through a separator. The separated gas is then compressed by the CEGT compressor engines, passes through the CEFS glycol dehydration unit to further remove moisture and is sent on via pipeline. The separated produced water is sent to the CEFS storage tank for eventual shipment off-site via tank truck.
CEGT presently has two 550-hp Caterpillar G398TA engines in compressor service and associated tanks, which will operate under Permit No. 2003-097-TVR, when approved.
Although the parent corporation, CenterPoint Energy Resources Corporation (CERC), owns CEFS and CEGT as wholly owned subsidiaries, it does not control the day-to-day operations at the station. CEFS and CEGT are collocated, but have separate management and employees. CEGT owns the produced water tank but it is operated by CEFS. Aggregated emissions are used to determine the HAP status of the facility.
SECTION III. EQUIPMENT
EUG 1 and 2 were used in Permit No. 2003-097-TVR.
EUG 4, 5, 6 (Dehydrator equipment is operated under this Permit No. 2006-160-TV)
EUG 4, 5, & 6 Dehydrator equipmentEU / Point / Make/Model / Bbl / Serial # / Const. Date
SN10 / SN10 / CEFS Glycol Dehydrator Reboiler / 1974
SN11 / SN11 / CEFS Dehydrator Still Column Vent / 1974
SN12 / SN12 / CEFS Glycol Tank / 10 / 1974
SN13 / SN13 / CEFS Drip Tank / 12 / 1974
SN03* / SN03 / Produced Water / 210
* owned by CEGT but operated by CEFS
EUG 3 Fugitives are based on the same assumptions for both Permit Nos. 2003-097-TVR (CEGT) and 2006-160-TV (CEFS).
EU / Number Items / Type of Equipment
Fugitives / 15 / Valves (Gas)
63 / Flanges (Gas)
5 / Other (Gas)
Total / 83
SECTION IV. EMISSIONS
EUG 3 Fugitive VOC Emissions (both permits)Equipment / % C3+ / Leak Factor
(lb/hr/component) / (lb/hr) / TPY
Gas Service
15 Valves / 10.0 / 0.00990 / 0.01 / 0.07
63 Flanges / 10.0 / 0.00086 / 0.01 / 0.02
2 Other / 10.0 / 0.01940 / 0.00 / 0.01
Liquid Service
5 Valves / 10.0 / 0.01940 / 0.01 / 0.04
Sub Total / 0.03 / 0.14
“Total Potential Emissions” for Dehydrator Part of Facility
NOx / CO / VOC / PMEU / Lb/hr / TPY / Lb/hr / TPY / Lb/hr / TPY / Lb/hr / TPY
SN10 / 0.14 / 0.63 / 0.12 / 0.53 / 0.001 / 0.03 / 0.01 / 0.05
SN11 / - / - / - / - / 0.06 / 0.28 / - / -
Fugitives / - / - / - / - / 0.03 / 0.14 / - / -
TOTAL / 0.14 / 0.63 / 0.12 / 0.53 / 0.09 / 0.45 / 0.01 / 0.05
Hazardous air pollutant (HAP) emissions were speciated from the engines using factors based on GRI HAPCalc 3.01. Note that total HAP are below the 10 TPY individual threshold for major status under 40 CFR 63.2. However, to determine the HAP major source status of the facility, emissions from the engines and dehydrator shall be consolidated. In an application for the dehydrator (permitted separately), the HAP emissions are negligible.
Pollutant / CAS # / 2 Engine Emissions, TPYAcetaldehyde / 75-07-0 / 0.26
Acrolein / 107-02-8 / 0.16
Benzene / 71-43-2 / 0.02
1,3-Butadiene / 106-99-0 / 0.01
Formaldehyde / 50-00-0 / 1.61
Methanol / 67-56-1 / 0.08
Toluene / 108-88-3 / 0.02
Xylene / 1330-20-7 / 0.01
Others / N/A / 0.06
Total HAP / 2.23
Uncontrolled Glycol Dehydrator Vent Emissions (Point ID#: DEHY-SV)
Basis: from GLY-Calc 4.0
Contaminant / CAS # / Dehydrator Vent, (lb/hr) / Dehydrator Vent, (TPY)Methane / 74818 / 10.8771 / 47.6417
Ethane / 74840 / 0.2183 / 0.9562
Propane / 74986 / 0.0301 / 0.1318
i-butane / NA / 0.0338 / 0.1480
n-pentane / 109660 / 0 / 0.0000
Other hexanes / NA / 0 / 0.0000
Benzene / 71432 (HAP) / 0 / 0.0000
Toluene / 108883 (HAP) / 0 / 0.0000
Ethylbenzene / 71432 (HAP) / 0 / 0.0000
Xylenes / 108883 (HAP) / 0 / 0.0000
Other HAPs / NA / 0 / 0.0000
Total VOC / 0.0639 / 0.2798
HAPs = 0
NA = Not available
No HAP emissions come from the CEFS permit. The total HAP emissions for the engines and dehydrator are 2.23 TPY. Therefore, the facility is not a HAP major source.
SECTION V. INSIGNIFICANT ACTIVITIES
The insignificant activities identified and justified in the application are duplicated below. Appropriate record keeping of activities indicated below with “*” is specified in the Specific Conditions.
1. * Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel which are either used exclusively for emergency power generation or for peaking power service not exceeding 500 hours/year. None identified but may be used in the future.
2. Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 MMBTUH heat input (commercial natural gas). The 1.5 MMBTUH dehydrator reboiler is on-site. Others may be used in the future.
3. Emissions from stationary internal combustion engines rated less than 50-hp output. None identified but may be used in the future.
4. * 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. None identified but may occur in the future.
5. * Emissions from fuel storage/dispensing equipment operated solely for facility-owned vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day period. None identified but may occur in the future.
6. Gasoline and aircraft fuel-handling facilities equipment, and storage tanks except those subject to new source performance standards and standards in OAC 252:100-37-15, 39-30, 39-41, 39-48. None identified at the present time.
7. Emissions from produced water tanks with a design capacity of 400 gallons or less in ozone attainment areas. The 8,820-gal produced water tank is located on-site and is owned by CEGT and operated by CEFS. No other produced water tanks are located on-site but others may be used in the future.
8. * Emissions from storage tanks constructed with a capacity less than 39,894 gallons which store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. Tanks SN13 and SN14 have capacities less than 39,894 gallons and store products having a vapor pressure less than 1.5 psia.
9. Cold degreasing operations utilizing solvents that are denser than air. None identified but may be used in the future.
10. * Non-commercial water washing operations (less than 2,250 barrels/year) and drum crushing operations of empty barrels less than or equal to 55 gallons with less than three percent by volume of residual material. None identified at the present time.
11. Hazardous waste and hazardous materials drum staging areas. None identified but may occur in the future.
12. Sanitary Sewage collection and treatment facilities other than incinerators and Publicly Owned Treatment Works (POTW) Stacks or vents for sanitary sewer plumbing traps are also included (i.e. lift stations). None identified but may be used in the future.
13. * Surface coating operations which do not exceed a combined total usage of more than 60 gallons/month of coatings, thinners, and clean-up solvents at any one emission unit. None identified but may be used in the future.
14. Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including hazardous waste satellite (accumulation) areas.
15. 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. None identified but may be used in the future.
16. * Activities that have the potential to emit no more than 5 TPY (actual) of any criteria pollutant. This includes the dehydrator emissions. There may be more in the future.
SECTION VI. OKLAHOMA AIR QUALITY 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 September 1, 2005, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B, Subpart C, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, Subpart BBBB, Subpart DDDD, Subpart HHHH and Appendix G. NSPS 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. This is a new Title V permit for the dehydrator and associated equipment owned by CEFS. CEGT and CEFS will only pay fees for their own equipment.
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 that result in emissions not authorized in the permit and that exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior notification to AQD and may require a permit modification. Insignificant activities refer to those individual emission units either listed in Appendix I 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 HAP that the EPA may establish by rule
Emission limitations and operational requirements necessary to assure compliance with all applicable requirements for all sources are taken from the permit application, or developed from the applicable requirement.
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.