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PERMIT MEMORANDUM 2004-004-O 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.

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 SO2 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.

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.

Formaldehyde Emissions

Source / Estimated Emissions
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 mg/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.


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.

Equipment

/ Maximum Heat Input each, (MMBTUH) / Appendix C Emission Limit, (lbs/MMBTU) / Potential Emission Rate 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.

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 mg/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.