Permit Number: [Permit Number]
Facility ID: [Facility ID]
Working Copy of a Permit in Progress
General Permit 17.1 Template
Reciprocating Compressor for Natural Gas Service
B. Facility-Wide Terms and Conditions
The following are the terms and conditions for a General PTI to be issued to a Title V facility
1. All the facility-wide terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
a) None
2. The emissions unit contained in this permit must comply with various federal New Source Performance Standards (NSPS). The complete NSPS requirements may be accessed via the internet from the Electronic Code of Federal Regulations (e-CFR) website http://www.ecfr.gov or by contacting the appropriate Ohio EPA District Office or local air agency. The permittee must comply with the applicable requirements of 40 CFR Part 60 Subpart OOOOa as they apply to the emissions source.
3. Records related to this PTIO may be maintained at an off-site location (e.g. regional office), provided they are made accessible when the need arises, otherwise by the next business day upon Ohio EPA request (or made viewable electronically on-site and submitted to Ohio EPA within 24 hours).
C. Emissions Unit Terms and Conditions
Note: The following are the terms and conditions for a General PTI to be issued to a Title V facility
1. Reciprocating Natural Gas Compressor], [P001]
Operations, Property and/or Equipment Description:
Reciprocating compressor constructed, modified, or reconstructed after 9/18/15 and located between the wellhead and the point of custody transfer to the natural gas transmission and storage segment, and designed to be driven by an engine or motor of less than or equal to 3800 horsepower. Includes emissions from normal compressor operation, and blowdown and other releases from periodic maintenance activities, as well as leakage through closed valves and vents during periods of either intermittent or prolonged shutdown of the compressor.
a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
(1) None
b) Applicable Emissions Limitations and/or Control Requirements
(1) The specific operations(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. 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 June 30, 2008 / Volatile organic compound (VOC) emissions shall not exceed 0.22 tons per month averaged over a 12-month rolling period.
See c)(2) and c)(3).
b. / 40 CFR Part 60 Subpart OOOOa
In accordance with 40 CFR 60.5365a(c), this emissions unit is a reciprocating compressor subject to the Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution.
40 CFR 60.5385a / Meet all applicable requirements of 40 CFR Part 60, Subpart OOOOa upon initial startup.
c. / OAC rule 3745-31-05(E) / The compressor shall be designed with a capture and control system designed to control emissions from the rod packing seals (if the alternative of periodic seal replacement is not selected), compressor isolation valves, and compressor blowdown vents. This requirement can be met by either (1) a design that captures 100% of the gasses from these sources, and routes them to a flare designed for 95% destruction, or (2) a design that first routes the high pressure gasses to a low pressure line (like a fuel gas system, or a product pipeline) in order to reduce the gas pressure prior to venting to atmosphere of the remaining lower pressure gas such that at least 90% of the gasses are recovered. The above design requirements shall be met at all times that pressure is present at the inlet or discharge isolation valve, including periods of either intermittent or prolonged shutdown of the compressor.
(2) Additional Terms and Conditions
a. None.
c) Operational Restrictions
(1) The permittee of a reciprocating unit shall reduce emissions from rod packing by either periodically replacing the rod packing according to the schedule under 40 CFR Part 60 Section 60.5385a, or by operating a rod packing emissions collection system under negative pressure and routing emissions to a process through a closed vent system that meets the requirements of 40 CFR Part 60 Section 5411a(a) at all times when pressure is present at the inlet or discharge isolation valve.
[40 CFR 60.5385a(a)], [40 CFR 60.5410a(c)], [40 CFR 60.5415a(c)(3)], and [40 CFR 60.5370a(a)]
(2) Gas from a maintenance blowdown event shall be routed to a low-pressure fuel or production system prior to blowdown to atmosphere or shall be routed to a flare.
(3) At all times when the reciprocating compressor is maintained in a depressurized state, the leakage passing through the isolation valves and released from the compressor through blowdown vents or other routes shall be routed to a low-pressure fuel or production system or to the flare.
(4) The permittee shall minimize the frequency and size of blowdown events by conducting routine operation and maintenance activities in a manner consistent with safety and good air pollution control practices.
(5) The permittee of a reciprocating unit shall demonstrate continuous compliance with the requirements of this permit by conforming to the applicable requirements of 40 CFR Part 60 Section 5415a.
d) Monitoring and/or Recordkeeping Requirements
(1) The permittee shall perform initial and subsequent annual inspections of the closed vent system, covers, and bypass devices installed on the reciprocating compressor as prescribed by 40 CFR Part 60 Section 5416a.
[40 CFR 60.5420a(c)(3)], [40 CFR 60.5385a(b) and (d)], [40 CFR 60.5410a(c)(1) and (4)], [40 CFR 60.5415a(c)(1)], and with [ORC 3704.03(T)]
(2) The permittee shall maintain monthly records of the following information, except when compressor blowdowns are recycled/recompressed to the inlet and/or controlled by 100%:
a. number of compressor blowdown events;
b. mole fraction of each VOC component in the gas stream using a representative analysis;
c. the volume of gas emitted from all compressor blowdown events for each month, in scf;
d. the rolling, 12-month summation of the volume of gas emitted from all compressor blowdown events, in scf;
e. number of hours of operation of the compressor;
f. number of hours that the compressor is not operating, but is kept in a pressurized state; and
g. number of hours that the compressor is not operating and is depressurized, but has line pressure at the isolation valves.
At the end of each year or PER reporting period, the permittee shall calculate the emissions from compressor maintenance blowdowns and from dynamic (i.e., operating) seal or packing leakage, static (i.e. non-operating but pressurized) seal or packing leakage, and isolation valve (non-operating and depressurized) through-leakage using the calculations in the Testing Section, and shall maintain the record of the emission estimates for a period of five years.
e) Reporting Requirements
(1) The permittee shall submit deviation reports that identify any of the following occurrences:
a. All exceedances of the VOC and other permit emissions limitations, and the other requirements under sections c)(1) through (5) and d)(1) through (2).
(2) The deviation reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.
(3) Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center: Air Services online web portal.
(4) The permittee shall submit an initial annual report within 90 days after the end of the initial compliance period as determined according to 40 CFR 60.5410. Subsequent annual reports are due on the same date each year following the initial report. The annual reports shall include the following information:
a. company name and address of the affected facility;
b. identification of each affected facility included in the annual report*;
c. beginning and ending dates of the reporting period;
d. the identification of each reciprocating compressor;
e. the cumulative number hours of operation or the number of months of operation since initial startup of the reciprocating compressor, or since the effective date of the NSPS, whichever is later;
f. records of any deviations; and
g. certification of the responsible official of truth, accuracy, and completeness.
* One report for multiple affected facilities may be submitted provided the report contains all of the information required and clearly identified for each.
[40 CFR 60.5420a(b)(1) and (4)], [40 CFR 60.5410a(c)(2) and (3)], [40 CFR 60.5385a(d)], and [40 CFR 60.5415a(c)(2)]
(5) The permittee shall submit to the appropriate district or local office of the EPA Division of Air Pollution Control notification of:
a. the date construction or reconstruction of the emissions unit is commenced, no later than 30 days after such date; and
b. notification of any physical or operational change to the existing facility which may increase the emission rate of any air pollutant to which the standard applies (unless that change is specifically exempted under the NSPS or in 40 CFR 60.14(e)) shall be postmarked 60 days before the change is commenced (or as soon as practicable) and shall include information describing the precise nature of the change, productive capacity of the facility before and after the change, and the expected completion date of the change.
The Director may request additional relevant information subsequent to this notice.
[40 CFR 60.5410a(c)(2)] and [40 CFR 60.7(a)(1) and (4)]
f) Testing Requirements
(1) Compliance with the Emissions Limitations and/or Control Requirements specified in section b) of these terms and conditions shall be determined in accordance with the following methods:
Emissions Limitation:
Volatile organic compound (VOC) emissions shall not exceed 0.22 tons per month averaged over a 12-month rolling period.
Applicable Compliance Method:
Compliance with the VOC emissions limitation shall be based upon the following calculation and the recordkeeping requirements in d)(2):
VOC (tons/month) = sum of the following for each VOC component:
= [molecular weight x ((volume of gas emitted/month) x (mole fraction of each VOC component/month)) / molar volume conversion] x (1 ton/2,000 pounds) x (1- control factor)
Where:
Control factor = 0.90 for blowdown and venting of isolation valve through-leakage; and 0.90 for dynamic and static reciprocating rod packing leakage, unless the alternative of periodic rod packing replacement allowable under 40 CFR Part 60 Section 60.5385a is selected, in which case the control factor for rod packing leakage is 0.0 (zero).
Volume of gas emitted/month = emission rate, scf/hr x (total applicable hours/month)
Emission rate (uncorrected by MMW) =
50 scf/hr per rod packing assembly in a reciprocating compressor while operating;
75 scf/hr per rod packing assembly in a reciprocating compressor while pressurized but not operating;
1400 scf/hr through an isolation valve being used to keep a compressor in a depressurized state;
150 scf/hr through a vent valve being used to keep a non-operating compressor in a pressurized state.
Emission rate corrected by mean molecular weight = uncorrected rate x (17/MMW)**0.5
The above emission rates originate with a series of GasStar documents published by U.S. EPA. The GasStar documents are at
https://web.archive.org/web/20150905125527/http:/www.epa.gov/gasstar/documents/ll_compressorsoffline.pdf
The equation for correction by molecular weight originates with the Ohio EPA Air Division.
For blowdowns, standard volume emitted from each event is computed as a function of the volume of the compressor interior and associated piping and fixtures evacuated; the actual temperature and pressure; the gas compressibility factor according to non-ideal gas calculations; an estimate of the liquid, if any, flashed or evaporated; and an estimate of the gas volume, if any, required to flush the interior to purge it of atmospheric contamination prior to restoration of system pressure.
molecular weight = constant, in lb/lb-mole;
volume of gas emitted/month = from records specified in d)(1)c, in scf;
mole % of each VOC component/month = from analysis required in d)(1)b, in %; and
molar volume conversion = 379.5 scf/lb-mole, at 60 deg F and 1 atm.
(2) Compliance with Emissions Limitations and/or Control Requirements specified in section b) of these terms and conditions shall be determined in accordance with the following methods:
a. Design Efficiency:
Install a system (low pressure flare, high pressure flare, routing to fuel line, etc.) suitable for control of maintenance blowdown events and leakage through closed vent or isolation valves with 90 percent capture and control efficiency for VOC.
Applicable Compliance Method:
Compliance is demonstrated by the system manufacturer’s design efficiency of 90% percent capture and control efficiency.
b. Alternative Design Efficiency:
Install a flare or other device to perform 100 percent capture of leakage through closed vent or isolation valves and reduce the quantity of VOC by at least 95 percent prior to release to the atmosphere, by combustion
Applicable Compliance Method
Compliance is demonstrated by the equipment manufacturer’s design efficiency with 100 percent capture and greater than or equal to 95 percent control efficiency.
g) Miscellaneous Requirements
None.
Page 1 of 9