PERMIT MEMORANDUM 2007-154-TV DRAFT 10
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM October 10, 2007
TO: Phillip Fielder, P.E., Permits and Engr. Group Manager
THROUGH: Matt Paque, Supervising Attorney
THROUGH: Kendal Stegmann, Senior Environmental Manager
THROUGH: Jarrod Gregg, Self Disclosure Coordinator
THROUGH: Richard Kienlen, P.E., Engr. Mgr. II, New Source Permits Section
THROUGH: Peer Review, Herb Neumann, ROAT
THROUGH: Peer Review, Hal Wright, ROAT
FROM: David Pollard, P.E., ROAT
SUBJECT: Evaluation of Permit Application No. 2007-154-TV
Tristar Compression, L.P.
Quinton Compressor Station
SW/4 Sec. 35-T8N-R18E, Pittsburg County (Lat. 37.117° N; Long. 95.400° W)
Directions: Travel approximately 1.5 miles west of town of Quinton on State Highway 31. Facility is on north side of highway, behind oilfield equipment storage yard.
SECTION I. INTRODUCTION
Tristar Compression, L.P. (Tristar or applicant) submitted a Part 70 permit application dated July 23, 2007, and received July 26, 2007, as part of a self disclosure for an existing compressor station facility (SIC 4922) constructed without a permit and having a potential to emit (PTE) at major source levels. The facility will be permitted as a major source, after Tier II permit processing.
The Quinton Compressor Station was originally constructed in the 1930s or 1940s through 1981 and was most recently operated by Southeast Transmission & Compression Company. Tristar Compression, L.P. recently acquired the property. The facility consists of two separate but contiguous compressor units (referenced as the East and West Units) and a small booster unit, located on 28.7 acres of land approximately 1.5 miles west of Quinton, Oklahoma. On-site equipment includes eleven reciprocating internal combustion engines, storage tanks for fresh and used lube oils, one 500-gallon methanol tank, and one 4,400-gallon produced water aboveground storage tank.
The Quinton Compressor Station has not previously held an air quality construction or operating permit. Based on all eleven compressor engines operating 8,760 hours/year, maximum potential NOX emissions are 253.9 tons/year (TPY).
SECTION II. FACILITY/PROCESS DESCRIPTION
The Quinton Compressor Station provides compression for a local natural gas gathering system located in the Quinton-Featherston Gas Field. The facility gathers low-pressure (2-25 psi), sweet, dry field gas (average energy value of 1,015 BTU/scf) from local wells in the Quinton-Featherston Gas Field and compresses it into an Oklahoma Natural Gas (ONG) delivery point located on the west side of the facility. The facility currently processes approximately 11.0 MMCFD of field gas. Maximum process capability is 16.0 MMCFD.
Incoming field gas typically has an inlet pressure of 2-25 psi. Water content of inlet gas is 50-80 gallons per million cubic feet (MMCF). The facility provides two-stage compression and outlet gas pressure is 325-350 psi. Water content of the outlet gas at the delivery point is 20-30 gallons/MMCF. Produced water drops out in the discharge separators which dump to the produced water storage tank prior to the gas delivery point.
Based on a gas analysis provided by ONG, the purchaser, none of the units at this facility are in volatile hazardous air pollutant (VHAP) service. The facility is an area source for hazardous air pollutants (HAP), emitting < 10 tons per year (TPY) of a single HAP (formaldehyde). The facility does not conduct extraction of natural gas liquids (NGLs) from field gas or fractionation of natural gas liquids and has no dehydrators or amine units.
SECTION III. EQUIPMENT
EUG 1 – Facility-wide and Fugitives
This EUG includes requirements that apply across the facility as well as to specific EUGs, including OAC 252:100-19, 25, and 29.
EUG 2 – Compressor Engines
This EUG includes combustion emissions from the compressor engines. Each of the compressor engines is fitted with a muffler and vertical exhaust stack. Engine No. 2 is used as a backup engine. It is grandfathered and has no permit limits. Appendix D of the application summarizes engine stack data for Ajax Models DPC-230, DPC-280, DPC280 LE and DPC-60. Since air dispersion modeling was not required for this permit, that information is not duplicated in this memorandum.
Compressor Engines
EU ID / EP ID / Unit / Serial # / Construct DateCE-2/S-1 / Cooper Engine No. 2, DPC 230, 221-hp / 65107 / 1965
CE-5/S-2 / Cooper Engine No. 5, DPC 280, 269-hp / 74981 / 1978
CE-8/S-3 / Cooper Engine No. 8, DPC 280, 269-hp / 75094 / 1978
CE-9/S-4 / Cooper Engine No. 9, DPC 280, 269-hp / 75232 / 1978
CE-10/S-5 / Cooper Engine No. 10, DPC 280, 269-hp / 76239 / 1980
CE-11/S-6 / Cooper Engine No. 11, DPC 280, 269-hp / 76237 / 1980
CE-12/S-7 / Cooper Engine No. 12, DPC 280, 269-hp / 76242 / 1980
CE-13/S-8 / Cooper Engine No. 13, DPC 280, 269-hp / 77337 / 1981
CE-14/S-9 / Cooper Engine No. 14, DPC 280, 269-hp / 77339 / 1981
CE-15/S-10 / Cooper Engine No. 15, DPC 280, 269-hp / 77425 / 1981
CE-21/S-11 / Cooper Engine No. 21, DPC 60, 58-hp / 76142 / 1979
EUG 3 - Insignificant and Trivial Activities
This EUG includes emissions from product storage tanks resulting from breathing and working losses, and flash emissions from wastewater storage tanks. It also includes emissions from any miscellaneous process piping fugitives from valves, seals, flanges, and connections associated with all compressor systems, storage tanks and equipment located on the facility site.
Insignificant Activities
The insignificant activities identified and justified in the application are duplicated below. Appropriate recordkeeping of activities having the potential to emit no more than 5 TPY (actual) of any criteria pollutant is required. Recordkeeping demonstrating compliance is specified in the permit conditions.
EU ID / Unit and Contents / Capacity / Install DateT-4 / Methanol Storage Tank - Methanol / 500-gal / 1990s
Trivial Activities
Trivial activities are any individual or combination of air emissions units that are considered inconsequential and are on a list approved by the Administrator and contained in Appendix J. The following Trivial Activities do not require recordkeeping. There are and will be miscellaneous storage tanks for new and used lube oils, corrosion inhibitors, possible other products, and ethylene glycol, which is injected into the gas lines to prevent freezing. There is no dehydration unit at the facility.
SECTION IV. EMISSIONS
EUG 1 – Facility-wide and Fugitives
Limitations on opacity and fugitive dust are found in the applicability section of this memorandum. Emissions calculations for this EUG are not practically quantifiable.
EUG 2 – Compressor Engines
A representative of Ajax/Cooper indicated that the DPC 230 and 280 engines manufactured during and following the 1970s were two-cycle, lean burn by design. However, the term “lean burn” applies only to the extent that the engines typically operate with no less than 14% excess O2 in the exhaust due to the engine configuration. A gas injection valve piped directly into the cylinder head combined with intake combustion air supplied from the back side of the piston, results in consistent metering of the air and fuel to maintain the desired excess O2. The term “clean-burn” technology is a registered trademark of Cooper Energy Systems and refers to engines designed to reduce NOX by operating at even higher air-to-fuel ratios. These engines are designated with an “LE” suffix and require modification of the combustion chamber to promote stable combustion. Tristar installed a clean burn kit on Compressor Engine No. 13 to achieve the clean burn technology. Manufacturer’s data indicates that the difference between a DPC-280 and a DPC-280 LE is a drop of 82% in NOX emissions and 8% in CO emissions.
Emissions were calculated based on manufacturer’s emissions factors and 8,760 hours of continuous operation with no controls except that Engine No. 2 (E-2/S-1) will be a standby engine. Permit limits are therefore based on operating ten engines. As illustrated by the calculations, total combined NOX emissions (maximum potential to emit) from the engines were calculated by the applicant to be above the Prevention of Significant Deterioration threshold.
EU/EP / Unit / NOX / CO / NMHC
(lbs/hr) / (TPY) / (lbs/hr) / (TPY) / (lbs/hr) / (TPY)
E-2/S-1 / DPC 230, 221-hp* / 2.1 / 9.4 / 1.2 / 5.1 / 0.9 / 3.8
CE-5/S-2 / DPC 280, 269-hp / 6.8 / 29.6 / 0.8 / 3.4 / 0.7 / 3.1
CE-8/S-3 / DPC 280, 269-hp / 6.8 / 29.6 / 0.8 / 3.4 / 0.7 / 3.1
CE-9/S-4 / DPC 280, 269-hp / 6.8 / 29.6 / 0.8 / 3.4 / 0.7 / 3.1
CE-10/S-5 / DPC 280, 269-hp / 6.8 / 29.6 / 0.8 / 3.4 / 0.7 / 3.1
CE-11/S-6 / DPC 280, 269-hp / 6.8 / 29.6 / 0.8 / 3.4 / 0.7 / 3.1
CE-12/S-7 / DPC 280, 269-hp / 6.8 / 29.6 / 0.8 / 3.4 / 0.7 / 3.1
CE-13/S-8 / DPC 280, 269-hp / 1.2 / 5.2 / 0.8 / 3.6 / 0.7 / 3.1
CE-14/S-9 / DPC 280, 269-hp / 6.8 / 29.6 / 0.8 / 3.4 / 0.7 / 3.1
CE-15/S-10 / DPC 280, 269-hp / 6.8 / 29.6 / 0.8 / 3.4 / 0.7 / 3.1
CE-21/S-11 / DPC 60, 58-hp / 0.6 / 2.5 / 0.2 / 1.0 / 0.1 / 0.6
Totals / 58.3 / 253.9 / 8.6 / 36.9 / 7.3 / 32.3
* Standby engine E-2/S-1 is grandfathered and has no permitted emission limits.
EUG 3 – Insignificant and Trivial Activities
Working and Breathing Losses
EPA Tanks 4.0 was used to calculate working and breathing loss emissions from the tanks. This resulted in emissions of 0.85 TPY from new and used oil storage tanks, which are based on crude oil properties (RVP 5) and therefore likely conservatively high. Emissions of methanol were calculated to be 31 lbs/yr (0.02 TPY).
Other Negligible Emissions
A gas analysis submitted with the application shows that 99.42 mol% of the gas processed at the facility is comprised of methane, ethane, CO2, and N2, while C3+ components comprise only 0.582 mol% of the gas stream. A calculation of VOC emissions from process piping and components would therefore likely indicate that these emissions are negligible. The facility makes no condensate. Therefore VOC emissions from breathing/working losses and flash gas from tanks, and loading losses, as well as any hazardous air pollutants associated with these operations are all negligible. Any hydrocarbon emissions from production and loading of wastewater would also be negligible.
Hazardous Air Pollutant Emissions (HAP)
The internal combustion engines have emissions of HAP, the most significant being formaldehyde. Uncontrolled emissions of formaldehyde were calculated using the manufacturer’s emission factor of 0.3 g/bhp-hr and the applicable engine power ratings. The table below lists estimated formaldehyde emissions for the engines.
Formaldehyde Emissions
Source / Power Input (bhp) / Formaldehyde(lbs/hr) / (TPY)
1 engine - Cooper, DPC 230, 221-hp (standby engine) / 221 / 0.1 / 0.6
9 engines - Cooper, DPC 280, 269-hp / 269 / 1.6 / 7.0
1 engine - Cooper, DPC 60, 58-hp / 58 / 0.1 / 0.2
Total Formaldehyde Emissions / 1.8 / 7.8
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 252:100-2 (Incorporation by Reference) [Not Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal Regulations. These requirements are addressed in the “Federal Regulations” section.
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 252:100-5 (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. Required annual information (Turn-Around Document) shall be provided to Air Quality.
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 operating 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.
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. Appendix C specifies a PM emission limitation of 0.60 lbs/MMBTU for all equipment at this facility with a heat input rating of 10 Million BTU per hour (MMBTUH) or less. Fuel-burning equipment is defined in OAC 252:100-19 as any internal combustion engine or gas turbine, or other combustion device used to convert the combustion of fuel into usable energy. Thus, the engines are subject to the requirements of this subchapter.
All equipment is rated less than 10 MMBtu/hr. AP-42 (7/00), Sec. 3.2 lists the total PM emissions from 2-stroke lean burn natural gas-fired engines to be 0.01 lbs/MMBtu, which demonstrates compliance for the Cooper compressor engines.