### M EMORANDUM

DATE: April 17, 2012

SUBJECT: Changes to Risk Assessment Facility Information for the Oil and Natural Gas

Production and Natural Gas Transmission and Storage Source Categories

FROM: Greg Nizich, EPA/OAQPS/SPPD/FIG

TO: Air and Radiation Docket

, ID No. EPA

- HQ

- OAR

- 2010

- 0505

The purpose of this memorandum is to update facility information pertaining to the risk review for the following source categories: Oil and Natural Gas National Emission Standards for HAP (NESHAP)

– 40 CFR 63, subpart HH and the Natural Gas Transmission and Storage NESHAP

– 40 CFR 63, subpart HHH

. These updates are made in response to c omments received on the changes proposed for these rules published in the Federal Register on August 23, 2011

. The risk assessment is performed to address statutory requirements under section 112(f) of the Clean Air Act.

1.0 FACILITY UPDATES FOR OIL AND NATURAL GAS PRODUCTION

Table 1 shows the emissions sources from proposal with the highest maximum individual risk for cancer (MIR) , based on allowable emissions, with corrections/updates since propos al noted

. This information was documented at proposal in Table A

- 1 of Docket ID No. EPA

- HQ

OAR

- 2010

- 0505

- 0055

.

Table 2 shows the emissions sources at proposal with the highest maximum individual risk for cancer (MIR) and corrections noted since proposal based on actual emissions

.

### Table 1. Revisions to Facility Data Following Proposal – Allowable Emissions.

A B C D E F G H I J

Facility MIR Cancer Risk

from Source ID/HAP Cancer Risk

From Other
Points Controlled

Dehydrator
Benzene Emissions (tpy) Factor for 1 tpy

Benzene Adjustment Adjusted Cancer

Risk From Overcontrolled
Point MACT Allowable

MIR at Facility Due to Dehy 1 tpy Limit (from risk modeling results) (from risk

modeling results) (Column D -

Column E) (from NEI data) (1/Column G) (Column E * Column H) (Column F +

Column I) Comments ONG_NEICA1115664 DN0022 Benzene 1.42E-05 1.39E-05 3.00E-07 0.2916 3.43 4.75E-05 4.78E-05 This unit is a small glycol dehydration unit. a ONG_NEIOK2038 DN0001 Benzene 6.88E-06 4.37E-06 2.51E-06 0.8400 1.19 5.20E-06 7.71E-06 ONG_NEILA13789 DN0008 Benzene 6.12E-06 1.54E-07 5.97E-06 0.6128 1.63 2.50E-07 6.22E-06 ONG_NEI7410 DN0006 Benzene 2.98E-06 1.65E-06 1.33E-06 0.5160 1.94 3.20E-06 4.52E-06 ONG_NEICA0592118 DN0027 Benzene 2.23E-06 1.26E-06 9.75E-07 0.0744 13.45 1.69E-05 1.79E-05 Facility shutdown per EPA’s Emission Inventory System

ONG_NEIMIB9135 DN0005 Benzene 2.03E-06 1.19E-07 1.91E-06 0.1416 7.06 8.40E-07 2.75E-06 ONG_NEILA0770023 DN0004 Benzene 1.54E-06 1.32E-07 1.41E-06 0.1425 7.02 9.29E-07 2.34E-06 ONG_NEILA0450042 DN0004 Benzene 1.37E-06 3.96E-08 1.33E-06 0.0310 32.30 1.28E-06 2.61E-06 ONG_NEI2TX42343 DN0002 Benzene 1.19E-06 3.34E-07 8.58E-07 0.1032 9.69 3.23E-06 4.09E-06 ONG_NEIMIB9142 DN0009 Benzene 1.16E-06 1.05E-07 1.06E-06 0.0619 16.14 1.69E-06 2.75E-06 ONG_NEI8007 DN0051 Benzene 1.05E-06 2.99E-08 1.02E-06 0.0129 77.52 2.32E-06 3.56E-04 Facility is an area source per comment letter. b
ONG_NEI8007 DN0005 Benzene 1.05E-06 1.53E-08 1.03E-06 0.00004 23071.24 3.53E-04 Incorrect values were corrected for this unit as

0.01290 77.52 1.19E-06 shown. ONG_NEIMIB9160 DN0008 Benzene 8.61E-07 1.28E-07 7.33E-07 0.1310 7.64 9.79E-07 1.71E-06 ONG_NEICO1230184 DN0001 Benzene 8.13E-07 1.91E-07 6.23E-07 0.2240 4.46 8.51E-07 1.47E-06 ONG_NEIMIB9136 DN0005 Benzene 7.59E-07 1.74E-07 5.86E-07 0.2371 4.22 7.32E-07 1.32E-06 ONG_NEIAL10190 DN0002 Benzene 7.27E-07 4.97E-07 2.30E-07 0.5700 1.75 8.72E-07 1.10E-06 ONG_NEI12819 DN0001 Benzene 7.12E-07 6.06E-07 1.06E-07 0.6640 1.51 9.13E-07 1.02E-06 ONG_NEI11191 DN0007 Benzene 6.30E-07 3.27E-07 3.03E-07 0.8500 1.18 3.85E-07 6.88E-07 ONG_NEI2CO0552 DN0001 Benzene 6.15E-07 6.53E-08 5.49E-07 0.5000 2.00 1.31E-07 6.80E-07 ONG_NEI12047 DN0005 Benzene 5.01E-07 3.33E-07 1.68E-07 0.2368 4.22 1.41E-06 1.57E-06 ONG_NEI7787 DN0002 Benzene 4.92E-07 9.99E-08 3.92E-07 0.9817 1.02 1.02E-07 4.93E-07 ONG_NEI11921 DN0003 Benzene 4.87E-07 1.50E-07 3.38E-07 0.0166 60.13 9.00E-06 9.34E-06 ONG_NEIOK2529 DN0015 Benzene 4.64E-07 6.75E-09 4.58E-07 0.0558 17.93 1.21E-07 5.79E-07 ONG_NEIAL0530007 DN0002 Benzene 4.60E-07 5.35E-08 4.06E-07 0.8600 1.16 6.22E-08 4.68E-07 ONG_NEI13271 DN0005 Benzene 4.56E-07 3.95E-07 6.16E-08 0.1580 6.33 2.50E-06 2.56E-06 ONG_NEICO1230048 DN0003 Benzene 4.42E-07 6.98E-08 3.72E-07 0.3060 3.27 2.28E-07 7.84E-07 ONG_NEICO1230048 DN0004 Benzene 4.42E-07 4.39E-08 3.98E-07 0.1925 5.19 2.28E-07 ONG_NEITXRUA0156 DN0004 Benzene 3.68E-07 1.90E-07 1.78E-07 0.2840 3.52 6.68E-07 8.46E-07 ONG_NEI2TX1520 DN0001 Benzene 2.70E-07 2.67E-07 3.10E-09 0.1324 7.55 2.01E-06 2.02E-06 ONG_NEI2CO045363 DN0003 Benzene 2.59E-07 2.26E-07 3.31E-08 0.2050 4.88 1.10E-06 1.19E-06 ONG_NEI2CO045363 DN0001 Benzene 2.59E-07 1.39E-08 2.45E-07 0.2050 4.88 6.79E-08 ONG_NEITX383004K DN0003 Benzene 1.96E-07 1.65E-08 1.79E-07 0.1100 9.09 1.50E-07 3.29E-07 Facility ID Source ID HAP



### 2

### Table 1. Revisions to Facility Data Following Proposal – Allowable Emissions.

A B C D E F G H I J

Facility MIR Cancer Risk

from Source ID/HAP Cancer Risk

From Other
Points Controlled

Dehydrator
Benzene Emissions (tpy) Factor for 1 tpy

Benzene Adjustment Adjusted Cancer

Risk From Overcontrolled
Point MACT Allowable

MIR at Facility Due to Dehy 1 tpy Limit (from risk modeling results) (from risk

modeling results) (Column D -

Column E) (from NEI data) (1/Column G) (Column E * Column H) (Column F +

Column I) Comments Facility ID Source ID HAP ONG_NEITXRGJ0139 DN0003 Benzene 1.73E-07 2.97E-08 1.44E-07 0.0431 23.20 6.89E-07 8.33E-07 ONG_NEI2OK285 DN0004 Benzene 1.68E-07 6.69E-09 1.61E-07 0.0294 34.00 2.27E-07 3.88E-07 ONG_NEIMI14392 DN0009 Benzene 1.66E-07 9.18E-09 1.57E-07 0.0265 37.68 3.46E-07 5.03E-07 ONG_NEILA0070200$8 DN0001 Benzene 1.50E-07 4.57E-08 1.05E-07 0.0464 21.53 9.83E-07 1.09E-06 ONG_NEIMI055B915 DN0008 Benzene 1.28E-07 7.38E-08 5.42E-08 0.1416 7.06 5.21E-07 5.75E-07 ONG_NEI13316 DN0001 Benzene 1.25E-07 1.25E-07 -1.00E-15 0.0700 14.29 1.78E-06 1.78E-06 ONG_NEICO0186 DN0001 Benzene 1.15E-07 1.28E-13 1.15E-07 0.0005 2000.00 2.56E-10 1.15E-07 ONG_NEITX067CG00 DN0002 Benzene 1.06E-07 4.84E-08 5.73E-08 0.1007 9.93 4.80E-07 5.38E-07 ONG_NEILA0070200$6 DN0002 Benzene 1.05E-07 2.37E-08 8.14E-08 0.0155 64.60 1.53E-06 1.61E-06 ONG_NEIMIN6015 DN0015 Benzene 8.57E-08 2.97E-08 5.60E-08 0.1600 6.25 1.86E-07 4.07E-07 ONG_NEIMIN6015 DN0006 Benzene 8.57E-08 2.00E-08 6.56E-08 0.1080 9.26 1.86E-07 ONG_NEI6456 DN0007 Benzene 8.41E-08 1.59E-13 8.41E-08 0.0009 1100.50 1.75E-10 8.44E-08 ONG_NEI6456 DN0016 Benzene 8.41E-08 1.10E-13 8.41E-08 0.0008 1214.28 1.34E-10 ONG_NEI2TX39520 DN0003 Benzene 7.89E-08 6.64E-08 1.25E-08 0.2868 3.49 2.31E-07 2.44E-07 ONG_NEITX42345 DN0001 Benzene 7.80E-08 1.17E-08 6.63E-08 0.0376 26.58 3.11E-07 3.77E-07 ONG_NEI2TX20371 DN0003 Benzene 7.56E-08 7.07E-08 4.94E-09 0.1328 7.53 5.32E-07 5.37E-07 ONG_NEI13085 DN0003 Benzene 6.12E-08 4.04E-08 2.08E-08 0.1622 6.17 2.49E-07 2.70E-07 ONG_NEI7785 DN0006 Benzene 4.87E-08 4.51E-10 4.82E-08 0.5000 2.00 9.02E-10 5.06E-08 ONG_NEI7785 DN0002 Benzene 4.87E-08 1.51E-10 4.85E-08 0.1670 5.99 9.02E-10 ONG_NEI7785 DN0005 Benzene 4.87E-08 1.51E-10 4.85E-08 0.1670 5.99 9.02E-10 ONG_NEI6453 DN0015 Benzene 4.27E-08 6.15E-11 4.27E-08 0.1633 6.12 3.76E-10 4.30E-08 ONG_NEIMIB5587 DN0005 Benzene 4.09E-08 1.93E-09 3.90E-08 0.0814 12.29 2.37E-08 6.26E-08 ONG_NEI11771 DN0004 Benzene 3.91E-08 2.25E-09 3.69E-08 0.0026 388.22 8.74E-07 9.10E-07 ONG_NEITX18630 DN0019 Benzene 3.75E-08 2.07E-10 3.73E-08 0.1685 5.93 1.23E-09 4.27E-08 ONG_NEITX18630 DN0017 Benzene 3.75E-08 1.81E-10 3.73E-08 0.0904 11.06 2.00E-09 ONG_NEITX18630 DN0018 Benzene 3.75E-08 1.72E-11 3.75E-08 0.9147 1.09 1.89E-11 ONG_NEITX18630 DN0016 Benzene 3.75E-08 9.25E-12 3.75E-08 0.0159 62.89 5.82E-10 ONG_NEITX18630 DN0011 Benzene 3.75E-08 3.14E-12 3.75E-08 0.0038 261.01 8.19E-10 ONG_NEITX18630 DN0009 Benzene 3.75E-08 6.82E-13 3.75E-08 0.0007 1410.47 9.62E-10 ONG_NEI7449 DN0008 Benzene 3.19E-08 1.58E-08 1.60E-08 0.0891 11.22 1.78E-07 1.94E-07 ONG_NEI12270 DN0006 Benzene 3.17E-08 1.48E-09 3.02E-08 0.0054 185.19 2.75E-07 3.05E-07 ONG_NEITXRHX1519 DN0001 Benzene 2.86E-08 2.76E-08 1.04E-09 0.0001 10000.00 2.76E-04 2.76E-04 ONG_NEI11924 DN0003 Benzene 2.69E-08 8.82E-10 2.60E-08 0.0088 113.64 1.00E-07 1.26E-07 ONG_NEI6483 DN0003 Benzene 2.62E-08 1.32E-08 1.30E-08 0.0093 107.01 1.41E-06 1.42E-06



### 3

### Table 1. Revisions to Facility Data Following Proposal – Allowable Emissions.

A B C D E F G H I J

Facility MIR Cancer Risk

from Source ID/HAP Cancer Risk

From Other
Points Controlled

Dehydrator
Benzene Emissions (tpy) Factor for 1 tpy

Benzene Adjustment Adjusted Cancer

Risk From Overcontrolled
Point MACT Allowable

MIR at Facility Due to Dehy 1 tpy Limit (from risk modeling results) (from risk

modeling results) (Column D -

Column E) (from NEI data) (1/Column G) (Column E * Column H) (Column F +

Column I) Comments Facility ID Source ID HAP ONG_NEILA0690006 DN0001 Benzene 2.53E-08 1.08E-08 1.46E-08 0.1075 9.30 1.00E-07 1.15E-07 ONG_NEITX161629 DN0004 Benzene 2.38E-08 6.21E-09 1.76E-08 0.0139 71.78 4.46E-07 8.68E-07 ONG_NEITX161629 DN0006 Benzene 2.38E-08 5.72E-09 1.81E-08 0.0139 71.78 4.11E-07 ONG_NEI7694 DN0006 Benzene 2.21E-08 1.81E-08 3.92E-09 0.0820 12.20 2.21E-07 2.25E-07 ONG_NEI6512 DN0004 Benzene 2.14E-08 1.38E-08 7.55E-09 0.0163 61.35 8.47E-07 8.55E-07 ONG_NEITX157312F DN0001 Benzene 1.76E-08 2.11E-10 1.74E-08 0.2916 3.43 7.24E-10 1.81E-08 ONG_NEILA0075 DN0001 Benzene 1.68E-08 2.38E-10 1.66E-08 0.7280 1.37 3.26E-10 1.72E-08 ONG_NEILA0075 DN0002 Benzene 1.68E-08 1.52E-11 1.68E-08 0.0464 21.53 3.26E-10 ONG_NEITX039692 DN0003 Benzene 1.64E-08 6.35E-09 1.00E-08 0.0161 62.11 3.94E-07 4.04E-07 ONG_NEI7998 DN0010 Benzene 1.63E-08 1.91E-09 1.44E-08 0.5200 1.92 3.66E-09 1.81E-08 ONG_NEILA0123 DN0001 Benzene 1.48E-08 5.70E-10 1.43E-08 0.4980 2.01 1.14E-09 1.65E-08 ONG_NEILA0123 DN0002 Benzene 1.48E-08 5.29E-11 1.48E-08 0.0464 21.53 1.14E-09 ONG_NEI13106 DN0003 Benzene 1.38E-08 7.77E-10 1.30E-08 0.0130 76.92 5.97E-08 7.28E-08 ONG_NEITX039674 DN0002 Benzene 1.33E-08 5.69E-09 7.64E-09 0.0156 64.27 3.66E-07 3.73E-07 ONG_NEITX039675 DN0002 Benzene 1.29E-08 5.69E-09 7.23E-09 0.0156 64.28 3.66E-07 3.73E-07 ONG_NEITX039676 DN0003 Benzene 1.29E-08 5.69E-09 7.20E-09 0.0156 64.27 3.66E-07 3.73E-07 ONG_NEI12503 DN0002 Benzene 1.21E-08 2.71E-09 9.41E-09 0.0600 16.67 4.52E-08 5.46E-08 ONG_NEI7375 DN0001 Benzene 1.20E-08 1.36E-12 1.20E-08 0.0005 2000.00 2.72E-09 1.48E-08 ONG_NEITX25152 DN0006 Benzene 9.01E-09 2.37E-09 6.64E-09 0.0143 70.12 1.66E-07 3.38E-07 ONG_NEITX25152 DN0004 Benzene 9.01E-09 5.92E-10 8.42E-09 0.0036 280.50 1.66E-07 ONG_NEITXRPE0106 DN0007 Benzene 6.91E-09 1.61E-13 6.91E-09 0.0008 1291.99 2.08E-10 7.12E-09 ONG_NEITX461006C DN0022 Benzene 6.42E-09 9.40E-12 6.42E-09 0.0431 23.22 2.18E-10 6.63E-09 ONG_NEI2TX39139 DN0002 Benzene 4.86E-09 1.11E-10 4.75E-09 0.1621 6.17 6.84E-10 5.43E-09 ONG_NEIOK2720 DN0003 Benzene 4.85E-09 8.63E-13 4.85E-09 0.0074 134.58 1.16E-10 4.96E-09 ONG_NEI6855 DN0004 Benzene 4.52E-09 8.73E-10 3.64E-09 0.0200 50.00 4.36E-08 4.73E-08 ONG_NEI2TX1619 DN0005 Benzene 4.51E-09 3.37E-09 1.14E-09 0.0600 16.67 5.61E-08 1.13E-07 ONG_NEI2TX1619 DN0015 Benzene 4.51E-09 2.62E-10 4.25E-09 0.0047 213.69 5.61E-08 ONG_NEITX215294O DN0001 Benzene 4.32E-09 1.49E-11 4.30E-09 0.2004 4.99 7.43E-11 4.38E-09 ONG_NEITXRSQ0088 DN0002 Benzene 4.24E-09 1.41E-10 4.10E-09 0.6009 1.66 2.34E-10 4.34E-09 ONG_NEILA1010013 DN0001 Benzene 4.07E-09 2.98E-11 4.05E-09 0.0825 12.12 3.61E-10 4.75E-09 ONG_NEILA1010013 DN0002 Benzene 4.07E-09 1.69E-11 4.06E-09 0.0470 21.28 3.60E-10 ONG_NEI7436 DN0002 Benzene 3.62E-09 5.83E-12 3.62E-09 0.0220 45.45 2.65E-10 4.40E-09 ONG_NEI7436 DN0010 Benzene 3.62E-09 3.84E-12 3.62E-09 0.0145 68.97 2.65E-10 ONG_NEI7436 DN0011 Benzene 3.62E-09 3.84E-12 3.62E-09 0.0145 68.97 2.65E-10



### 4

### Table 1. Revisions to Facility Data Following Proposal – Allowable Emissions.

A B C D E F G H I J

Facility MIR Cancer Risk

from Source ID/HAP Cancer Risk

From Other
Points Controlled

Dehydrator
Benzene Emissions (tpy) Factor for 1 tpy

Benzene Adjustment Adjusted Cancer

Risk From Overcontrolled
Point MACT Allowable

MIR at Facility Due to Dehy 1 tpy Limit (from risk modeling results) (from risk

modeling results) (Column D -

Column E) (from NEI data) (1/Column G) (Column E * Column H) (Column F +

Column I) Comments Facility ID Source ID HAP ONG_NEILA0750033 DN0002 Benzene 2.24E-09 1.27E-10 2.11E-09 0.2322 4.31 5.49E-10 3.08E-09 ONG_NEILA0750033 DN0003 Benzene 2.24E-09 1.27E-10 2.11E-09 0.2322 4.31 5.49E-10 ONG_NEITX371016P DN0003 Benzene 2.22E-09 9.23E-11 2.13E-09 0.0036 274.42 2.53E-08 2.75E-08 ONG_NEITXRCI0100 DN0005 Benzene 1.80E-09 2.87E-12 1.80E-09 0.0114 87.72 2.52E-10 2.05E-09 ONG_NEILA2210126$2 DN0001 Benzene 1.69E-09 1.21E-11 1.68E-09 0.0155 64.60 7.79E-10 2.46E-09 ONG_NEI6094 DN0001 Benzene 1.69E-09 2.85E-10 1.40E-09 0.1410 7.09 2.02E-09 5.36E-09 ONG_NEI6094 DN0002 Benzene 1.69E-09 3.05E-11 1.66E-09 0.0155 64.60 1.97E-09 ONG_NEITX461002K DN0006 Benzene 1.64E-09 2.52E-12 1.64E-09 0.0079 126.58 3.19E-10 1.95E-09 ONG_NEITXRPE0042 DN0005 Benzene 1.37E-09 1.07E-10 1.27E-09 0.1000 10.00 1.07E-09 2.33E-09 ONG_NEILA0098 DN0003 Benzene 1.37E-09 4.13E-10 9.53E-10 0.0020 500.00 2.07E-07 2.07E-07 ONG_NEI11929 DN0004 Benzene 1.18E-09 1.03E-11 1.17E-09 0.0116 86.21 8.89E-10 2.94E-09 ONG_NEI11929 DN0005 Benzene 1.18E-09 1.02E-11 1.17E-09 0.0115 86.96 8.89E-10 ONG_NEI2TX07156 DN0001 Benzene 1.16E-09 4.10E-14 1.16E-09 0.0001 10000.00 4.10E-10 1.57E-09 ONG_NEILA1090032 DN0001 Benzene 6.54E-10 5.08E-11 6.04E-10 0.0619 16.15 8.21E-10 1.42E-09 ONG_NEITX461001M DN0006 Benzene 5.50E-10 1.65E-12 5.49E-10 0.0256 39.01 6.42E-11 6.13E-10 ONG_NEI2TX07186 DN0006 Benzene 5.37E-10 1.14E-11 5.25E-10 0.0278 35.97 4.11E-10 9.37E-10 ONG_NEI12470 DN0002 Benzene 4.52E-10 1.10E-10 3.42E-10 0.0055 182.43 2.00E-08 2.04E-08 ONG_NEI7500 DN0001 Benzene 7.09E-11 5.37E-11 1.72E-11 0.0001 10000.00 5.37E-07 5.37E-07

a Memorandum from Nizich, G., to EPA Docket ID EPA-HQ-OAR-2010-0505. Supplemental Facility Information Obtained from Various State/Local Agencies and Additional Analysis. March 20, 2012.

b Comment letter from API. EPA Docket No. EPA-HQ-OAR-2010-0505-4266. page 184. * shading incidates facilities with more than one glycol dehdrator controlled to less than 1 tpy benzene



### 5

### 6

Table 2 . Revisions to Facility Data Following P roposal

– Actual Emissions

.

Facility Name NEI Facility ID Cancer MIR Pollutant Source ID Corrections Made Since Proposal

Sun E&P NEI21361 2.88E

- 05 POM 75002 WH0003 Facility is no longer operating per SCAQMD

Hillcrest Beverly Oil NEI20769 2.20E

- 05 Benzene OM0022 Facility is an area source per SCAQMD

Hillcrest Beverly Oil NEICA0371191 2.11E

- 05 Benzene FO0023 Facility is an area source per SCAQMD

Alta Mesa

, East Bay CS NEI12443 1.82E

- 05 Benzene DU0007 Facility is an area source per TCEQ

.

Alta Mesa

, East Bay CS NEI12443 1.82E

- 05 Benzene DU0002 Facility is an area source per TCEQ and unit not operating. Plains E&P NEICA2683753 1.76E

- 05 Benzene EN0061 Facility is an area source per SCAQMD

Plains E&P NEICA2683753 1.76E

- 05 Benzene EO0067 Facility is an area source per SCAQMD Vintage Production NEICA1115664 1.42E

- 05 Benzene DN0022 Highest MIR in the 112(f)(2) assessment following revisions. Aera Energy NEICA1115662 1.39E

- 05 Naphthalene FO0151 Aera Energy NEICA1115662 1.39E

- 05 Naphthalene FO0145 SCAQMD

– South Coast Air Quality Management District; TCEQ

– Texas Commission for Environmental Quality

### 7

2.0 FACILITY UPDATES FOR NATURAL GAS TRANSMISSION AND STORAGE

Table 3 shows the top 8 emissions sources at proposal based on maximum individual risk for cancer (MIR) with corrections since proposal noted.

Table 3 . Revisions to Facility Data after P roposal.

Facility Name NEI Facility ID Cancer MIR Pollutant Source ID Corrections Made Since Proposal

Bradley CS NEIWV1090017 8.77E

- 05 Benzene DU0001 Facility is an area source per WV DAQ permit fact sheet

Danville CS NEIWV0050020 6.94E

- 05 Benzene DU0001 Facility is an area source per WV DAQ permit fact sheet Dominion

- Cornwell CS NEIWV0051 1.57E

- 05 Benzene FO0002 Highest MIR in the 112(f)(2) assessment following revisions

. Petal Gas Storage Facility NEIMS1678 7.45E

- 06 Benzene OM0001 Facility shutdown per EPA’s Emission Inventory System

Horsemill CS NEIWV20071 6.40E

- 06 Benzene DU0002 Facility is an area source per WV DAQ permit fact sheet

Horsemill CS NEIWV20071 6.40E

- 06 Benzene DU0001 Facility is an area source per WV DAQ permit fact sheet

Bonham CS NGT_NEIWV0390046 3.22E

- 06 Benzene DU0001 Facility shutdown per EPA’s Emission Inventory System Questar

- Skull Creek NGT_NEICO11678 3.20E

- 06 Benzene DU0004 Fac ility is an area source per CO permit info.

WV DAQ

- West Virginia Department of Air Quality



### 3.0 SUMMARY OF CHANGES TO FACILITY DATA

As a result of the corrections made in response to comments

, and additional facility evaluation, the maximum MIR is now driven by actual emissions, not allowable. T he highest MIR for the Oil and Natural Gas Production major source category is 10

- in

- 1

- million and the highest MIR for the Natu ral Gas Transmission and Storage major source category is 20

- in

- 1

- million.

Attachments :
Alta Mesa permit application information Bradley Compressor Station WVDAQ Fact Sheet Danville Compressor Station WVDAQ Fact Sheet Horsemill Compressor Station W VDAQ Fact Sheet Questar

– Skull Creek CDPHE Fa ct She etfile:///C|/Brad/Oil%20&%20Gas/Docket/Final%20Rule/Alta%20Mesa%20Services.htm [4/17/2012 12:51:40 PM] 

### GroupWise WebPublisher



## Section 1 - Document

GENERAL INFORMATION Regulated Entity No.: RN100542273 Project Type: Permit by Rule Application
Customer Reference No.: CN603506403 Date Received by TCEQ: June 15, 2011
Account No.: MH-0150-F Date Received by Reviewer: August 22, 2011 City/County: Bay City, Matagorda County Physical Location: 2603 Nichols Ave

CONTACT INFORMATION Responsible Official/ Primary Contact Name and Title: Ms. Lori O Boyle

Regulatory Compliance Phone No.:

Fax No.: (281) 530- 0991

(281) 530- 5278 Email: LOBOYLE@ALTAMESA.NET

Technical Contact/ Consultant

Name and Title: Mr. Stan Seale

Senior Associate Phone No.:

Fax No.: (409) 755- 2900

(409) 755- 2904 Email: STAN.SEALE@WOLCOTTENVIRONMENTAL.COM

GENERAL RULES CHECK YES NO COMMENTS

Is confidential information included in the application? X

Are there affected NSR or Title V permits for the project? X O-786 will be voided upon issuance of this registration, as the removal of ENG-2 resulted in minor source emissions rates.

Is each PBR > 25/250 tpy? X

Are PBR sitewide emissions > 25/250 tpy? X

Are there permit limits on using PBRs at the site? X

Is PSD or Nonattainment netting required? X

Do NSPS, NESHAP, or MACT standards apply to this registration? X MACT ZZZZ and NSPS JJJJ apply to the engine.

MACT HH applies to the dehydrator for recordkeeping requirements only. Does NOx Cap and Trade apply to this registration? X

Is the facility in compliance with all other applicable rules and regulations? X ENG-1 is compliant with the 2.0g/hp hr limit for NOx and 3.0 g/hp-hr for CO required for major sites. However, the upper limits required by 117 are the limits established by 117.305 where the limit must be the lower of any applicable permit limit in a permit issued before January 2, 2001. The only limit in SE7 (5/8/72) is horsepower.

DESCRIBE OVERALL PROCESS AT THE SITE Alta Mesa Services, LP (AMS) owns and operates the East By City Compression Station in Matagorda County. At the site, gas and liquids are received from upstream production facilities. Separators at the site separate the gas from the received liquids in the pipeline. The gas received at the site is compressed prior to being introduced into a glycol dehydration system, where entrained water and liquids are removed from the gas stream. Any condensates/oils from the gas are routed to the gunbarrel tank for further separation. The oil, water and condensates are routed to the respective storage tanks for storage, until being removed from the site via truck loadout.

DESCRIBE PROJECT AND INVOLVED PROCESS AMS has represented that the site maintains multiple historical standard exemptions for various facilities at the site. However, AMS is requesting the update of all facilities at the site and registration of the site by 106.352 and 106.512.

OIL AND GAS FACILITY GENERAL INFORMATION Natural Gas Throughput (MMSCF/day): 17 H 2 S Content of Inlet Gas: 2 ppmv (highest H2S from water flash) Oil/Condensate Throughput (bbl/day): 80 Is the gas sweet or sour? Sweetfile:///C|/Brad/Oil%20&%20Gas/Docket/Final%20Rule/Alta%20Mesa%20Services.htm [4/17/2012 12:51:40 PM] Produced Water Throughput (bbl/day): 2000 Is this site operational/producing? Yes
PI-7 or PI-7 CERT? CERT Has the site been registered before? No

EQUIPMENT/PROCESSES AT SITE
Number of each: Compressor Engines: 1 Glycol dehydrators: 1 VRU: 0 Separators: 1+ Amine units: 0 Other: Gunbarrel (1) Storage Tanks: 7 Heater Treaters: 0 Other:
Truck Loading: 1 Flares: 0 Other:

30 TAC §106.352 RULE CHECK REQUIREMENTS YES, NO,

or n/a OTHER / COMMENTS

If the site conditions the natural gas (with a glycol dehydrator, amine unit, sulfur recovery unit, etc.), it handles less than two long tons per day of sulfur compounds (1 long ton = 2240 pounds).

Long tons per day sulfur compounds = (MMSCF/day of inlet gas)*(MW of inlet gas)*(H 2 S wt fraction)

(0.84896) Yes Long tons per day of sulfur compounds = ___0.001____

(1) All compressors will meet the requirements of 106.512. Yes See 512 rule check. (1) All flares will meet the requirements of 106.492. N/A
(2) Total emissions, including process fugitives, combustion unit stacks, separator, or other process vents, tank vents, and loading emissions from all such facilities constructed at a site under this section, will be equal to or below 25 tons per year (tpy) each of sulfur dioxide (SO 2 ), all other sulfur compounds combined, or all volatile organic compounds (VOC) combined; and 250 tpy each of nitrogen oxide and carbon monoxide.

Emissions of VOC and sulfur compounds other than SO 2 must include gas lost by equilibrium flash as well as gas lost by conventional evaporation. Yes See emissions summary

(3) If the facility handles sour gas, it will be located at least 1/4 mile from any recreational area or residence or other structure not occupied or used solely by the owner or operator of the facility or the owner of the property upon which the facility is located. N/A

(4) Total emissions of sulfur compounds, excluding sulfur oxides, from all vents will be equal to or below 4.0 pounds per hour (lb/hr). Yes
(4) The height of each vent emitting sulfur compounds meets the following requirements, and is in no case less than 20 feet: (NOTE: other values may be interpolated)

H 2 S (lb/hr) Minimum Vent Height (ft)

0.27 20

0.60 30

1.94 50

3.00 60

4.00 68 Yes

(5) If the site handles sour gas, the company will register the site by submitting Form PI-7 or PI-7-CERT before operations begin. N/A

STORAGE TANKS
Tank Identifier (EPN) Capacity of Tank Throughput (bbl/day) Contents of Tank Working and breathing Loss Calculation Method Flash Loss Calculation Method Comments

TNKVNT 400bbl 80 Condensate Tanks 4.0 GOR Gunbarrel
TNKVNT 400bbl 80 Condensate Tanks 4.0 N/A 1st tank in sales series. 2nd oil tank is not normally operated.
WTRTNK 400bbl 2000 Produced Water Tanks 4.0 GWR Assumed total throughput in one tank. 99% emissions reduction for Tanks 4.0 using RVP5.

TANKS 4.0 SOFTWARE [FOR ESTIMATING WORKING AND BREATHING LOSSES FROM STORAGE TANKS] Tank Identifier (EPN) Throughput (gallons/year)

(pg. 1 of report) Turnovers per year

(pg. 1 of report) Mixture/

Component

(pg. 2 of report) Basis for VP Calculations

(pg. 2 of report) Vapor MW

(pg. 2 of report) Results (lb/year)

(last page of report)file:///C|/Brad/Oil%20&%20Gas/Docket/Final%20Rule/Alta%20Mesa%20Services.htm [4/17/2012 12:51:40 PM] TNKVNT 2,000,000 124.42 Crude RVP 5 Opt. 4 RVP 5 50 3,282
TNKVNT 1,300,000 59.42 Crude RVP 5 Opt. 4 RVP 5 50 3,656
WTRTNK 31,000,000 1,928 Crude RVP 5 Opt. 4 RVP 5 50 19,868 Please explain any controls or reductions in calculated emissions: 1% of 19,868lb/yr of water VOC assumed to be representative of water.

GAS OIL RATIO (G.O.R.) METHOD [FOR ESTIMATING FLASH LOSSES FROM STORAGE TANKS] Laboratory Analysis Included (“Gas Evolved From HC Liquid Flashed”)? Yes Date of Sample: 2/9/2011 Analysis from actual site or representative site? Actual If from representative site, justification as to why appropriate: N/A Gas-Oil-Ratio (SCF of flash gas per barrel of liquid produced): 15.10 Oil or Condensate throughput (bbl/day): 80 Oil/Condensate API Gravity: 38.20 Separator Pressure (psig): 54 RVP: 2.19 Separator Temperature (°F): 70 Flash Gas Molecular Weight (lb/lb-mole): 27.20 Flash Gas VOC content (weight %): 44.94 Flash Gas H 2 S content (wt %): 0.0001
Flash Gas VOC emissions, lb/hr: 1.60 Flash Gas H 2 S emissions, lb/hr: <0.01 Flash Gas VOC emissions, tpy: 7.04 Flash Gas H 2 S emissions, tpy: <0.01

GAS WATER RATIO (G.W.R.) METHOD [FOR ESTIMATING FLASH LOSSES FROM STORAGE TANKS] Laboratory Analysis Included (“Gas Evolved From Water Flashed”)? Yes Date of Sample: 2/9/2011 Analysis from actual site or representative site? Actual If from representative site, justification as to why appropriate: N/A Gas-Water-Ratio (SCF of flash gas per barrel of liquid produced): 0.6 Water throughput (bbl/day): 2000 Oil/Condensate API Gravity: N/A Separator Pressure (psig): 54 RVP: N/A Separator Temperature (°F): 82 Flash Gas Molecular Weight (lb/lb-mole): 28.86 Flash Gas VOC content (weight %): 19.40 Flash Gas H 2 S content (wt %): 0.0002
Flash Gas VOC emissions, lb/hr: 0.72 Flash Gas H 2 S emissions, lb/hr: <0.01 Flash Gas VOC emissions, tpy: 3.17 Flash Gas H 2 S emissions, tpy: <0.01

TRUCK LOADING [EMISSIONS CALCULATED USING L L =(12.46)(S)(P)(M)/(T) EQUATION FROM AP-42, SECTION 5.2-4]
What is being Loaded S P

(psia) M

(lb/lb-mole) T

(°R) L L

(lb VOC/1000 gallons loaded) Hourly Loading Rate

(gallons/hour) Annual Loading Rate (gallons/year) Hourly Emissions

(lb/hr) Annual Emissions

(tpy)

Oil 0.6 4.6 50 529.82 3.245 6400 1,226,000 14.95 1.69 Please explain any controls or reductions in calculated emissions: Underestimated by 0.30tpy.

GLYCOL DEHYDRATOR (STILL VENT) EMISSIONS CALCULATED USING GRI-GLYCALC
EPN: DEHY1 Laboratory Gas Sample Analysis Included? Yes Was it an extended analysis?

(Including at least C8+ and BTEX?) Yes

Date of Sample: 5/5/2010 Location at site where gas sample was taken: Inlet dehydrator Gas Flow Rate (MMSCF/day): 17 Lean Glycol Flow Rate (gpm): 0.138 Absorber/Contactor Pressure (psig): 850 Flash Tank Pressure (psig): N/A Absorber/Contactor Temperature (°F): 88 Flash Tank Temperature (°F): N/A How are regenerator emissions controlled and what control efficiency is claimed? 98% with condenser and reboiler firebox. How are flash tank (if present) emissions controlled and what control efficiency is claimed? N/A
VOC HAPS Benzene

lb/hr tpy lb/hr tpy lb/hr tpy
Uncontrolled Regenerator Emissions: 3.09 13.53 2.33 10.20 0.29 1.25 Controlled Regenerator Emissions: 0.06 0.27 0.05 0.20 0.01 0.03 Flash Tank Off Gas (uncontrolled):

-- -- -- -- -- -- Flash Gas Emissions (controlled):

-- -- -- -- -- -- TOTAL EMISSIONS (SUM OF CONTROLLED): 0.27 0.20 0.03
Because a glycol dehydrator is present, MACT HH is applicable.file:///C|/Brad/Oil%20&%20Gas/Docket/Final%20Rule/Alta%20Mesa%20Services.htm [4/17/2012 12:51:40 PM] (A) Record keeping requirement only if throughput is less than 3 MMscf/day OR Benzene emissions are less than 1.0 tpy. Yes

(B) Throughput is 3 MMscf/day or greater OR Benzene emissions are 1.0 tpy or greater. Emissions reduction requirements of HH apply. (Note compliance method if provided in original submission.) No

30 TAC §106.512 RULE CHECK REQUIREMENTS YES, NO, or n/a OTHER / COMMENTS

(1) The engines or turbines have been registered with Form PI-7 or PI-7-CERT within 10 days of the start of construction.

Engines and turbines rated less than 240 horsepower (hp) need not be registered, but must meet paragraphs (5) and (6) of this section, relating to fuel and protection of air quality. Yes Horsepower of engine(s) = 667

. (1) Table 29 has been submitted for each proposed gas or liquid fuel-fired stationary internal combustion reciprocating engine. Yes
(1) Table 31 has been submitted for each proposed gas turbine. N/A
(2) Any engines rated greater than 500-hp will meet the requirements of subparagraphs (A) - (C) of this paragraph.
(2)(A) Emissions of nitrogen oxides (NO x ) will not exceed the following limit:

Check which limit applies: Actual NOx Emissions = g/hp-hr.

(2)(A)(i) 2.0 grams per horsepower-hour (g/hp-hr) under all operating conditions for any gas-fired rich-burn engine; Yes

(2)(A)(ii) 2.0 g/hp-hr at manufacturer's rated full load and speed, and other operating conditions, except 5.0 g/hp-hr under reduced speed, 80-100% of full torque conditions, for any spark-ignited, gas-fired lean-burn engine, or any compression-ignited dual fuel-fired engine manufactured new after June 18, 1992; N/A

(2)(A)(iii) 5.0 g/hp-hr under all operating conditions for any spark-ignited, gas-fired, lean-burn two-cycle or four-cycle engine or any compression-ignited dual fuel-fired engine rated 825 hp or greater and manufactured after September 23, 1982, but prior to June 18, 1992; N/A

(2)(A)(iv) 5.0 g/hp-hr at manufacturer's rated full load and speed and other operating conditions, except 8.0 g/hp-hr under reduced speed, 80-100% of full torque conditions for any spark-ignited, gas-fired, lean-burn four-cycle engine, or any compression-ignited dual fuel-fired engine that was manufactured prior to June 18, 1992, and is rated less than 825 hp; or was manufactured prior to September 23, 1982; N/A

(2)(A)(v) 8.0 g/hp-hr under all operating conditions for any spark-ignited, gas-fired, two-cycle lean-burn engine that was manufactured prior to June 18, 1992, and is rated less than 825 hp; or was manufactured prior to September 23, 1982; N/A

(2)(A)(vi) 11.0 g/hp-hr for any compression-ignited liquid-fired engine. N/A

(2)(B) The engine requires an automatic air-fuel ratio (AFR) controller in order to meet the NOx limits in subparagraph (2)(A). Yes
(2)(B) The engine requires an automatic air-fuel ratio (AFR) controller in order to meet the following requirements:

An AFR controller shall be deemed necessary for any engine controlled with a non-selective catalytic reduction (NSCR) converter and for applications where the fuel heating value varies more than ± 50 British thermal unit/standard cubic feet from the design lower heating value of the fuel. If an NSCR converter is used to reduce NO x , the automatic controller shall operate on exhaust oxygen control. Yes

2)(C) The records specified in (2)(C) of this PBR will be created and maintained by the owner or operator for a period of at least two years, made available, upon request, to the commission and any local air pollution control agency having jurisdiction. Yes

(3) Any gas turbine rated greater than 500-hp will meet the requirements of subparagraphs (A) and (B) of this paragraph. N/A Horsepower of turbine(s)=

. (3)(A) Emissions of NO x will be less than or equal to 3.0 g/hp-hr for gas-firing. N/A Actual NOx Emissions = g/hp-hr. (3)(B) The turbine meet all applicable NO x and sulfur dioxide (SO 2 ) (or fuel sulfur) emissions limitations, monitoring requirements, and reporting requirements of NSPS Subpart GG--Standards of Performance for Stationary Gas Turbines. N/A
(4) Any engine or turbine rated less than 500 hp or used for temporary replacement purposes is exempt from the emission limitations of paragraphs (2) and (3) above.

Temporary replacement engines or turbines shall be limited to a maximum of 90 days of operation after which they shall be removed or rendered physically inoperable. N/A Horsepower=

.

Temporary?

. (5) The gas fuel will be limited to: sweet natural gas or liquid petroleum gas, fuel gas containing no more than ten grains total sulfur per 100 dry standard cubic feet, or field gas. Yes Type of fuel= Sweet natural gas

.

Sulfur content of fuel gas (gr/100 dSCF):

. (6) Compliance with National Ambient Air Quality Standard (NAAQS) in the area of the proposed facility has been demonstrated. Yes Which method was used (A, B, or C)? A

. (6)(A) Ambient sampling or dispersion modeling, accomplished pursuant to guidance obtained from the executive director, was used to demonstrate NAAQS:

Engine Identifier / EPN Max. Hourly Concentration of NO 2 /NOx Max. Annual Concentration of NO 2 /NOx NO 2 /NOx Ratio Annual NO 2 Concentrationfile:///C|/Brad/Oil%20&%20Gas/Docket/Final%20Rule/Alta%20Mesa%20Services.htm [4/17/2012 12:51:40 PM] (from Screen3 modeling)

(μg/m 3 ) (Max. Hourly Conc. X 0.08)

(μg/m 3 ) (from table below) (Max. Annual Conc. X NO 2 /NO x Ratio)

(μg/m 3 )
ENG-1 27.26 2.18 0.4 0.872 Background Concentration for County = 25
TOTAL = 25.872

Is total below NAAQS limit for NO 2 of 100 μg/m 3 (y s/no)? Yes

Unless otherwise documented by actual test data, the following nitrogen dioxide (NO 2 )/NO x ratios shall be used for modeling NO 2 ;

Device NO x Emission Rate (g/hp-hr) NO 2 /NO x Ratio IC Engine Less than 2.0 0.4 IC Engine 2.0 thru 10.0 0.15 + (0.5/Q) IC Engine Greater than 10.0 0.2
Turbines 0.25 IC Engine with catalytic converter 0.85

Q = NOx emission rate (g/hp-hr)

(7) The engine or turbine will not be used to generate electricity. Yes
(7) If NO to the above question, do any of the following apply?

(A) The engines or turbines are used to provide power for the operation of facilities registered under the Air Quality Standard Permit for Concrete Batch Plants;

(B) The engines or turbines satisfy the conditions for facilities permitted by rule under Subchapter E of this title (relating to Aggregate and Pavement);

(C) The engines or turbines are used exclusively to provide power to electric pumps used for irrigating crops.

(D) The engine is for on site use only and it is located where the electric grid is not readily available or where it is not economically feasible to connect to the electric grid. N/A

NATURAL GAS FIRED COMPRESSOR ENGINE Engine Identifier

(EPN / name) Engine Information Pollutant Source of Emission factor Emission Factor before controls Type of Control Device Control efficiency Emission Factor after controls Emissions (lb/hr) Emissions (tpy)

ENG-1 / Waukesha 7042GL Horsepower: 667 NMNEHC MFG 0.20 g/hp-hr 0.29 1.29
Fuel Consumption (Btu/hp-hr): 8940 NOx RACT

-- NSCR

-- 2.0 2.94 12.87 2 or 4 stroke,

Rich or Lean Burn: 4 / Rich CO RACT

-- NSCR

-- 3.0 4.41 19.31

Hours of Operation per year: 8760 PM 10 AP-42 0.000588lb/MMbtu 0.12 0.51

Vendor Data Sheet Included? (required if ≥ 500-hp ) No* SO 2 AP-42 0.01940 lb/MMbtu <0.01 0.02

Date of Manufacture or Reconstruction: MFG 1968 CH 2 O AP-42 0.0528 lb/MMbtu 0.32 1.38

Does NSPS, Subpart JJJJ apply? Yes Why or why not?

If yes, how will requirements be met? Reconstruction commenced after June 12, 2006.

Does MACT, Subpart ZZZZ apply? Yes Why or why not?

If yes, how will requirements be met? Applies to area sources.

*Data sheet was not requested due to the age of the engine and unavailability of old vendor data sheets. Although the 7042GL is a common model, newer data sheets are not representative of older variants.file:///C|/Brad/Oil%20&%20Gas/Docket/Final%20Rule/Alta%20Mesa%20Services.htm [4/17/2012 12:51:40 PM] COMMUNICATION LOG
Date Time Name/Company Subject of Communication
8/23/2011 8:30AM Mr. Stan Seale

Wolcott & Associates The reviewer contacted Mr. Seale questioning why ENG-2 was referenced on the historical standard exemption page but was not mentioned anywhere in the project as operating at the site or removed. Mr. Seale explained that the engine has been removed from the site.

8/23/2011 9:38AM Mr. Stan Seale

Wolcott & Associates The reviewer contacted MR. Seale and explained that working and standing losses for the oil sales tanks and produced water tanks were needed. The reviewer explained that it is the assumption that total site throughput is routed to the gunbarrel for further separation.

The reviewer explained that one tanks 4.0 run based on 80bbl/day of oil and one tanks run based on 2000bbl/day of water only accounts for working and standing of the gunbarrel, while working and standing of the storage tanks are absent.

Mr. Seale explained that he would look into the setup of the liquids. The reviewer explained that the distribution of the liquids varies, whether the tanks are in a series or parallel.
8/23/2011 9:50AM Mr. Stan Seale

Wolcott & Associates Mr. Seale contacted the reviewer and explained that after further discussion with the field operator, production has dropped dramatically to 5 barrels per day. Mr. Seale explained that production may increase back to about 15-20 barrels per day. Mr. Seale questioned how to proceed. The reviewer explained that maintaining the 80 barrel throughput would certify allowable emissions to that throughput in-case the well is worked over and production increases again.

Mr. Seale also explained that only the oil is routed to the gunbarrel for further separation. The water is routed to the water tanks and the throughput is less that represented. The reviewer confirmed that maintaining the 2000bpd representation would be conservative and running a Tanks 4.0 for each tank while assuming 1% emissions would yield negligible sitewide increases.

Mr. Seale also explained that after gunbarrel separation, the 5bpd is routed to only one of the storage tanks, as the other oil tank at the site is rarely used. Mr. Seale proposed representing a conservative 80bpd run for this one tank. The reviewer explained that this would be conservative.
8/23/2011 10:36AM Mr. Stan Seale

Wolcott & Associates The reviewer received a Tanks 4.0 run for the oil sales tank assuming 1,300,000 gallons of oil per year.

EPN / Description Screen 3 model distance Maximum Hourly Concentration of NOx (from screen 3 model)
ENG-1 145 meters 27.63 Background Concentration of Region / County = 75 ug/m3 - Montgomery County / Region 12
Total = 102.63 Is the total limit below the hourly NAAQS Limit of 188 ug/m3 (yes/no)? Yes
Notes: No NO2 ratio utilized as a conservative estimate.

ESTIMATED EMISSIONS
EPN / Emission Source Specific VOC or Other Pollutants VOC NOx CO PM 10 PM 2.5 SO 2 Other*

lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy
ENG1 / Waukesha 7042 HCHO 0.29 1.29 2.94 12.87 4.41 19.30 0.12 0.51 0.12 0.51 <0.01 0.02 0.32 1.38 MSS / Maintenance Startup and Shutdown 6.53 0.11

RBLR1 / Reboiler <0.01 0.01 0.07 0.30 0.02 0.08 <0.01 0.01 <0.01 0.01 <0.01 <0.01
DEHY1 / Dehydrator 0.06 0.27
FUG1 / Fugitives 0.95 4.16
LU1 / Loading 20.38 1.69

VENTK / Condensate and Gunbarrel Tanks 1.98 10.51

WTRTNK / Water Tanks 0.75 3.27

TOTAL EMISSIONS (TPY): 21.30 13.17 19.38 0.52 0.52 0.02 1.38

MAXIMUM OPERATING SCHEDULE: Hours/Day 24 Days/Week 7 Weeks/Year 52 Hours/Year 8760

*HCHO has been represented to be included in VOC. HCHO > VOC because the HCHO is based on an AP-42 factor that has no correlation to the manufactures estimated VOC factor.

SITE REVIEW / DISTANCE LIMIT Yes No Description/Outcome Date Reviewed by Site Review Required? X Not required by rule. August 23, 2011 E. Townsend

PBR Distance Limits Met? N/A No distance limit, sweet site. August 23, 2011 E. Townsend

TECHNICAL REVIEWER PEER REVIEWER FINAL REVIEWERfile:///C|/Brad/Oil%20&%20Gas/Docket/Final%20Rule/Alta%20Mesa%20Services.htm [4/17/2012 12:51:40 PM] SIGNATURE: image See Hard Copy.

PRINTED NAME: Mr. Elliot Townsend N/A Ms. Anne Inman, P.E., Manager
DATE: August 23, 2011 August 23, 2011

BASIS OF PROJECT POINTS POINTS
Base Points:106.352 2.0 Project Complexity Description and Points:

106.512

Received > 30 days old

Complete < 14 days

117 compliance

TRV Tables X 6 0.5

1.0

1.0

0.25

1.5

Technical Reviewer Project Points Assessment: 6.25 Final Reviewer Project Points Confirmation:



## Headers

TECHNICAL REVIEW: AIR PERMIT BY RULE

Permit No.: 96584 Company Name: ALTA MESA SERVICES LP APD Reviewer: Mr. Elliot Townsend Project No.: 166526 Unit Name: East Bay City Compressor Station PBR No(s).: 106.352 2000-SEP-04 TO 2011-FEB-27, 106.512



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## GroupWise WebPublisher



# Section 1 - Document

August 23, 2011

MS LORI O BOYLE

REGULATORY COMPLIANCE

ALTA MESA SERVICES LP

15021 KATY FREEWAY

HOUSTON TX 77094-

Permit by Rule Registration Number: 96584

Location/City/County: 2603 Nichols Ave, Bay City, Matagorda County

Project Description/Unit: East Bay City Compressor Station

Regulated Entity Number: RN100542273

Customer Reference Number: CN603506403

New or Existing Site: Existing

Affected Permit (if applicable): None
Renewal Date (if applicable): None

Alta Mesa Services, LP has certified the emissions associated with the East Bay City Compressor Station under Title 30 Texas Administrative Code §§ 106.352 (9/4/2000) and 106.512 (6/13/2001). For rule information see:

www.tceq.texas.gov/permitting/air/nav/numerical_index.html

Planned MSS emissions for 24 engine blowdowns and 12 annual miscellaneous line vents have been reviewed. These authorized MSS emissions are included on the emissions table. No other planned MSS emissions have been represented or reviewed. The company is also reminded that these facilities may be subject to and must comply with other state and federal air quality requirements. In addition, under the General Requirements for all Permit by Rules, § 106.2 states that particular requirements only apply “where construction is commenced on or after the effective date of the relevant permit by rule.”

All analytical data generated by a mobile or stationary laboratory to support the compliance with an air permit must be obtained from a NELAC (National Environmental Laboratory Accreditation Conference) accredited laboratory. For additional information regarding the laboratory accreditation program, please see the following Web site which includes the accreditation and exemption information:

www.tceq.texas.gov/compliance/compliance_support/qa/env_lab_accreditation.htmlfile:///C|/Brad/Oil%20&%20Gas/Docket/Final%20Rule/alta%20mesa%20services2.htm [4/17/2012 12:52:06 PM] 

### This certification is taken under the authority delegated by the Executive Director of the TCEQ. If you have questions, please contact Mr. Elliot Townsend at (512) 239-4042.

Sincerely, Certified Sitewide Emissions:

VOC 21.30 tpy HCHO (included in VOC) 1.38 tpy NO x 

### 13.17 tpy
CO 19.38 tpy PM 10 

### 0.52 tpy
PM 2.5 

### 0.52 tpy
SO 2 

### 0.02 tpy

Anne M. Inman, P.E., Manager

Rule Registrations Section

Air Permits Division

cc: Air Section Manager, Region 12 - Houston

Project Number: 166526 

# Headers

Bryan W. Shaw, Ph.D., Chairman

Buddy Garcia, Commissioner

Carlos Rubinstein, Commissioner

Mark R. Vickery, P.G., Executive Director 

# Texas Commission on Environmental Quality

Protecting Texas by Reducing and Preventing Pollution



### Ms. Lori O Boyle

August 23, 2011

Page



# Footersfile:///C|/Brad/Oil%20&%20Gas/Docket/Final%20Rule/alta%20mesa%20services2.htm [4/17/2012 12:52:06 PM] P.O. Box 13087 • Austin, Texas 78711-3087 • 512-239-1000 • tceq.texas.gov

How is our customer service? tceq.texas.gov/goto/customersurvey

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### West Virginia Department of Environmental Protection Division of Air Quality 

# Fact Sheet

For Final Renewal Permitting Action Under 45CSR30 and Title V of the Clean Air Act

Permit Number: R30-10900017-2007 Application Received: January 3, 2005 Plant Identification Number: 10900017 Permittee: Cabot Oil and Gas Corporation Facility Name: Bradley Station Mailing Address: 900 Lee Street, Suite 500 Charleston, WV 25301-1774 Issued: November 27, 2007

Physical Location: Fanrock, Wyoming County, West Virginia UTM Coordinates: 443.55 km Easting • 4,155.3 km Northing • Zone 17 Directions: From the town of Pineville, travel west on WV State Route 97 for approximately 14 miles and then turn south (left) onto Brier Creek Road. Once on Brier Creek Road, travel 4 miles to the compressor station on the right.

Facility Description Bradley Compressor Station is a natural gas tran smission facility covered by Standard Industrial Classification (SIC) Code 4922. The station has the potential to operate twenty-four (24) hours per day, seven (7) days per week and fifty-two ( 52) weeks per year. The station consists of one (1) dehydrator with a reboiler, one (1) 515 HP natural gas compressor engine, one (1) 1100 HP natural gas compressor engine, one (1) 1150 HP natural gas compressor engine, and seven (7) storage tanks of various sizes.Title V Fact Sheet R30-10900017-2007 Page 2 of 5 Cabot Oil and Gas Corporation • Bradley Station

West Virginia Department of Environmental Protection • Division of Air Quality 

### Emissions Summary

Plantwide Emissions Summary [Tons per Year]

Criteria Pollutants Potential Emissions 2005 Actual Emissions

Carbon Monoxide (CO) 103.89 88.76

Nitrogen Oxides (NO X ) 60.66 52.49

Particulate Matter (PM 10 ) 1.45 0.5781

Total Particulate Matter (TSP) 1.45 0.5781

Sulfur Dioxide (SO 2 ) 0.09 0.0264
Volatile Organic Compounds (VOC) 32.95 25.66

PM 10 is a component of TSP.

Hazardous Air Pollutants Potential Emissions 2005 Actual Emissions

Formaldehyde 7.37 2.03

Total HAPs 13.8 3.13

Some of the above HAPs may be counted as PM or VOCs.



### Title V Program Applicability Basis This facility has the potential to emit 103.89 Tons per Year of CO. Due to this facility's potential to emit over 100 tons per year of criteria pollutant, Cabot Oil and Gas Corporation is required to have an operating permit pursuant to Title V of the Federal Clean Air Act as amended and 45CSR30.



### Legal and Factual Basis for Permit Conditions The State and Federally-enforceable conditions of the Title V Operating Permits are based upon the requirements of the State of West Virginia Operating Permit Rule 45CSR30 for the purposes of Title V of the Federal Clean Air Act and the underlying applicab le requirements in other state and federal rules.

This facility has been found to be subject to the following applicable rules:

Federal and State: 45CSR2 Opacity requirement for dehydrators 45CSR6 Open burning prohibited. 45CSR10 Sulfur Oxides emissions 45CSR11 Standby plans for emergency episodes. 45CSR13 New Source Permit WV Code § 22-5-4 (a) (14) Th e Secretary can requ est any pertinent information such as annual emission inventory reporting. 45CSR30 Operating permit requirement. 40 C.F.R. Part 61 Asbestos inspection and removal 40 C.F.R. Part 82, Subpart F Ozone depleting substances

State Only: 45CSR4 No objectionable odors. 45CSR17 Particulate fugitiveTitle V Fact Sheet R30-10900017-2007 Page 3 of 5 Cabot Oil and Gas Corporation • Bradley Station

West Virginia Department of Environmental Protection • Division of Air Quality Each State and Federally-enforceable condition of the draft Title V Operating Permit references the specific relevant requirements of 45CSR30 or the applicable requirement up on which it is based. Any condition of the draft Title V permit that is enforceable by the State but is not Federa lly-enforceable is identified in the draft Title V permit as such.

The Secretary's authority to require standards under 40 C.F. R. Part 60 (NSPS), 40 C.F. R. Part 61 (NESHAPs), and 40 C.F.R. Part 63 (NESHAPs MACT) is provided in West Virginia Code §§ 22-5-1 et seq., 45CSR16, 45CSR15, 45CSR34 and 45CSR30.



### Active Permits/Consent Orders

Permit or Consent Order Number Date of Issuance Permit Determinations or Amendments That Affect the Permit (if any)

R13-2127E August 07, 2007

Conditions from this facility's Rule 13 permit(s) governing construction-related specifications and timing requirements will not be included in the Title V Operatin g Permit but will remain inde pendently enforceable under the applicable Rule 13 permit(s). All other conditions from this facility's Rule 13 pe rmit(s) governing the source's operation and compliance have been incorporated into this Title V permit in acco rdance with the "General Requirement Comparison Table B" which may be downloaded from DAQ's website.



### Determinations and Justifications

According to the following calculation, compliance w ith FERC (Federal Energy Regulatory Commission) limit for total sulfur of 20 grains/100 cu.ft will assure compliance with 45CSR10 limit of 2000 ppm SO 2 : (20grains of S/100 cu.ft of gas) x (1lb/7000 grains) x (1lbmol S/32 lb S) x (1lbmol SO 2 /1lbmol S) x (385.1 cu.ft of gas/1lbmol gas) x 10 6 = 343 ppm of SO 2 . Compliance with FERC limit for H 2 S of 0.25 grains/100 cu.ft will assure compliance with 45CSR10 limit of 50 grains/100 cu.ft. Pipeline quality natural gas has very low H 2 S content and total sulfur includes H 2 S. Hence H 2 S is not required to be tested at the inlet gas stream.

According to 45 CSR §2-11, Dehydrator Reboiler (001-04) is exempt from MRR (Monitoring, recordkeeping and reporting) requirements because Dehydrator Reboile r’s heat input is less than ten (10) million B.T.U’s per hour.

Since the last modification of this permit WVDEP has determined that 45CSR10 is not applicable to the engines. Engines are not subject to 45CSR10 requirements listed in the R13-2127E permit.

45CSR13 criteria pollutant limits and HAP limits were derived based on amount of natural gas used and dry natural gas processed by the Dehy. Hence meeting the limits set by 45CSR13 permit for natural gas used and dry natural gas processed by the Dehy shall show compliance with 45CSR13 criteria pollutant limits and HAP limits.

R13-2127E issued on August 7, 2007 has obsolete condition 4.1.5 stating that two superior engines shall be permanently removed and replaced by a new Caterpillar engine. Superior engines had been removed and replaced by a new Caterpillar engine in year 2005. He nce, R13-2127E condition 4.1. 5 is not in this Title V permit.Title V Fact Sheet R30-10900017-2007 Page 4 of 5 Cabot Oil and Gas Corporation • Bradley Station

West Virginia Department of Environmental Protection • Division of Air Quality 

### Non-Applicability Determinations The following requirements have been determined not to be applicable to the subject facility due to the following:

40 CFR 64 – None of the emission units at this facility have add-on controls; Hence CAM is not applicable to any of the emission units.

There are no applicable requ irements for tanks because there are no tanks with a volume equal to or greater than 75 m 3

.
According to Dehy tests performed in early 2006 this facility is not a major source of HAPs. Also the facility has 45CSR13 limit of less than 1 ton of Benzene emissions per year. Due to less than 1 ton of benzene emission per year the facility is exempt from Natural Gas Area Source MACT. The facility shall show compliance with benzene limit accord ing to Section 5.1. 7 of the permit.

The facility is not a major source of HAPs, hence the engines are not subject to 40 C.F.R 63 Subpart ZZZZ.



### Request for Variances or Alternatives
None



### Insignificant Activities

Insignificant emission unit(s) and activities are identified in the Title V application.



### Comment Period Beginning Date: October 10, 2007 Ending Date: November 9, 2007

All written comments should be addressed to the following individual and office:

U.K.Bachhawat Title V Permit Writer West Virginia Department of Environmental Protection Division of Air Quality 601 57 th Street SE Charleston, WV 25304



### Procedure for Requesting Public Hearing During the public comment period, any interested pe rson may submit written co mments on the draft permit and may request a public hearing, if no public hearing has already been scheduled. A request for public hearing shall be in writing and shall state the nature of th e issues proposed to be raised in the hearing. The Secretary shall grant such a request for a hearing if he/she concludes that a public hearing is appropriate. Any public hearing shall be held in the general area in which the facility is located.



### Point of Contact U.K.Bachhawat West Virginia Department of Environmental Protection Division of Air Quality 601 57 th Street SE Charleston, WV 25304 Phone: 304/926-0499 ext. 1256 • Fax: 304/926-0478Title V Fact Sheet R30-10900017-2007 Page 5 of 5 Cabot Oil and Gas Corporation • Bradley Station

West Virginia Department of Environmental Protection • Division of Air Quality 

### Response to Comments (Statement of Basis) Not applicable.

### West Virginia Department of Environmental Protection Division of Air Quality 

# Fact Sheet

For Draft/Proposed Renewal Permitting Action Under 45CSR30 and

Title V of t he Clean Air Act

Permit Number: R30

- 00500020

- 2011 Application Received: June 2, 2011 Plant Identification Number: 005

- 00020 Permittee: Cranberry Pipeline Corporation Facility Name: Danville Compressor Station Mailing Address: Suite 401, Five Penn Center West

Pittsburgh, Pa 15276

- 0120

Physical Location: Danville, Boone County, West Vir ginia UTM Coordinates: 422.07 km Easting • 4,214.25 km Northing • Zone 17 Directions: Travel south on US

- 119 toward Madison. Bear left onto CR

- 7/03 (Left Fork) for approximately 2.4 miles. Turn left on CR

- 119/07 (Lick Creek) for approximately 0.9 miles to the station entrance.

Facility Description Danville Compressor Station is a natural gas production facility cover ed by Standard Industrial Classification (SIC) Code 1311 . The station has the potentia l to operate twenty

- four (24) hours per day, seven (7) days per week, fifty

- two (52) weeks per year. The station consists of one (1) TEG dehydrator with flare , one (1) dehydrator reboiler, three (3) 400 HP natural gas compressor engines , one ( 1 ) 800 HP

na tural gas compressor engine

, t wo ( 2 ) 810 HP natural gas compressor engines , one 155 hp emergency generator and two ( 2 ) storage tanks of various sizes.Title V Fact Sheet R30

- 00500020

- 2011 Page 2 of 7

Cranberry Pipeline Corporation  Danville Compressor Station

West Virginia Department of Environmental Protection  Division of Air Quality 

### Emissions Summary

Plantwide Emissions Summary [Tons per Year]

Regulated Pollutants Potential Emissions 2010 Actual Emissions

Carbon Monoxide (CO) 50.18 49.72

Nitrogen Oxides (NO X ) 233.58 231.58

Particulate Matter (PM 10 ) 3.62 3.59

Total Particulate Matter (TSP) 3.62 Not reported

Sulfur Dioxide (SO 2 ) 0 .08 0.07

Volatile Organic Compounds (VOC) 16.14 15.86

PM 10 is a component of TSP.

Hazardous Air Pollutants Potential Emissions 2010 Actual Emissions

Formaldehyde 6.25 6.18

Total HAPs 9.15 8.98

Some of the above HAPs may be counted as PM or VOCs.



### Title V Program Applicability Basis This facility has the potential to emit 2 33.58 tons per year of Nitrogen Oxide . Due to this facility's potential to emit over 100 tons per year of criter ia pollutant

, Cranberry Pipeline Corporation is required to have an operating permit pursuant to Title V of the Federal Clean Air Act as amended and 45CSR30.



### Legal and Factual Basis for Permit Conditions The State and Federally

- enforceable conditions of the Title V Operating Permits are based upon the requirements of the State of West Virginia Operating Permit Rule 45CSR30 for the purposes of Title V of the Federal Clea n Air Act and the underlying applicable requirements in other state and federal rules.

This facility has been found to be subject to the following applicable rules:

Federal and State: 45CSR2 Indirect Heat Exchangers 45CSR6 Open burning prohibited. 45CSR10 E mission of sulfur oxides 45CSR11 Standby plans for emergency episodes. 45CSR13 Construction Permit 45CSR16 New stationary sources. WV Code § 22

- 5

- 4 (a) (14) The Secretary can request any per tinent information such as annual emission inventory reporting. 45CSR30 Operating permit requirement. 40 C.F.R. Part 60, Subpart JJJJ Stationary spark ignition IC engines. 40 C.F.R § 60.18 NSPS Flare requirements 40 C.F.R. Part 61 Asb estos inspection and removal 40 C

. F

. R

. Part 63, Subpart ZZZZ RICE MACT 40 C

. F

. R

. Part 63, Subpart HH Oil and Natural Gas Production Facilities MACTTitle V Fact Sheet R30

- 00500020

- 2011 Page 3 of 7

Cranberry Pipeline Corporation  Danville Compressor Station

West Virginia Department of Environmental Protection  Division of Air Quality

40 C.F.R. Part 82, Subpart F Ozone depleting substances

State Only: 45CSR4 No objecti onable odors. 45CSR17 Control fugitive particulate matter

Each State and Federally

- enforceable condition of the Title V Operating Permit references the specific relevant requirements of 45CSR30 or the applicable requirement upon which it is based . Any condition of the Title V permit that is enforceable by the State but is not Federally

- enforceable is identified in the Title V permit as such.

The Secretary's authority to require standards under 40 C.F.R. Part 60 (NSPS), 40 C .F.R. Part 61 (NESHAPs), and 40 C.F.R. Part 63 (NESHAPs MACT) is provided in West Virginia Code §§ 22

- 5

- 1 et seq., 45CSR16, 45CSR34 and 45CSR30.



### Active Permits/Consent Orders

Permit or Consent Order Number Date of Issuance Permit Determinations or Amendm ents That Affect the Permit (if any)

R13

- 2585B 02/26/2010

Conditions from this facility's Rule 13 permit(s) governing construction

- related specifications and timing requirements will not be included in the Title V Operating Permit but will remain independently enforceable under the applicable Rule 13 permit(s). All other conditions from this facility's Rule 13 permit(s) governing the source's operation and compliance have been incorporated into this Title V permit in accordance wi th the "General Requirement Comparison Table B " which may be downloaded from DAQ's website.



### Determinations and Justifications Boilerplate changes: The following changes have been made due to boilerplate changes:

a . Section 2.1.4 has been added to defin e “rolling yearly total”. b . Section 3.1.1 has been changed to reflect new 45CSR§6

- 3.1 language.

c . Section 3.1.2 has been changed to reflect new 45CSR§6

- 3.2 language

. d

. Section 3.1.3 regarding asbestos and the citation of the section have been c hanged due to change in boilerplate.

e

. Paragraph d has been added to section 3.3.1 to reflect boilerplate change requiring reporting of stack test results. f . Sections 3.5.3 and 3.5.5 are changed to include electronic report submittal to EPA.

Chan ges to the existing permit besides boilerplate changes:

1. 40 C.F.R. Part 63 Subpart HH

– National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities.

a) Applicability and designation of affected source :

First, it should be noted that the applicability of this MACT is not limited only to major sources of HAPs; area sources may also be subject. The rule applies to an owner or operator of emission points listed under 40 C.F.R. §63.760(b) located at facili ties that meet the applicability criteria 40 C.F.R. §§63.760(a)(1) and either (a)(2) or (a)(3) of that section.

Criterion 40 C.F.R. §63.760(a)(1) applies to, “Facilities that are major or area sources of hazardous air pollutants (HAP) as defined in 40 C.F .R. §63.761.” The facility is not a major source of HAPs; therefore, it is an area source in accordance with the definition of area source under 40 C.F.R. §63.2. The facility meets the first criterion.Title V Fact Sheet R30

- 00500020

- 2011 Page 4 of 7

Cranberry Pipeline Corporation  Danville Compressor Station

West Virginia Department of Environmental Protection  Division of Air Quality Criterion 40 C.F.R. §63.760(a)(2) applies to, “Faci lities that process, upgrade, or store hydrocarbon liquids prior to the point of custody transfer.” The facility does not process hydrocarbon liquids as defined in 40 C.F.R. §63.761; therefore, it does not meet this criterion.

Criterion 40 C.F.R. §63.760 (a)(3) applies to, “Facilities that process, upgrade, or store natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user. For the purposes of this subpart, natura l gas enters the natural gas transmission and storage source category after the natural gas processing plant, when present. If no natural gas processing plant is present, natural gas enters the natural gas transmission and storage source category after the point of custody transfer.” Clearly, this facility processes natural gas. Furthermore, it processes the natural gas prior to the point that the gas enters the transmission and storage source category.

Danville Compressor Station meets the facility appl icability criteria 40 C.F.R. §§63.760(a)(1) and (a)(3). The particular emission point that is subject to Subpart HH is covered by 40 C.F.R. §63.760(b)(2), which “includes each triethylene glycol (TEG) dehydration unit located at a facility that meets the criteria specified in paragraph (a) of this section.” According to the Process Description included with the application, “ After compression, the wet gas is transferred to a triethylene glycol (TEG) dehydration unit, where excess water is removed from the natural gas stream ....” Since the facility’s dehydration unit is a triethylene glycol dehydration unit, it meets the applicability criterion set forth in 40 C.F.R. §63.760(b)(2), and as such Dehy (001

- 09) is subject to the applicable requirements of 40 C.F .R. 63 Subpart HH.

The facility is not located in an Urban

- 1 county as defined in 40 C.F.R. §63.761. Since the measured distance of the facility is more than 2 mile s from the census 2000 Urban Area, the compressor station is not located within a UA plus offset and UC area, as defined in 40 C.F.R. §63.761.

The dehy was constructed in 2004.

Based upon these criteria, and in accordance with 40 C.F.R. §63.760(f)( 5 ), the Subpart HH compliance date is January 5, 2009 . Refer to permit condition 6.1.21. The pe rmit condition 6.1.21 has been added in accordance with 40 C.F.R. §63.760.

b) Applicable Subpart HH General Standards :

Permit conditions 6.1.22, 6.1.23, 6.2.5, 6.3.1, 6.3.2, 6.4.6, 6.4.7 & 6.5.1 have been added to incorporate 40 C.F.R. 63 Subpart HH s tandards applicable to this facility. Detailed discussions are stated below:

Permit condition 6.1.22 has been added to address 40 C.F.R. §63.764 requirements.

Since the compressor station is not located within a UA plus offset and UC, it appears that r equirements of 40 C.F.R. §63.764(d)(2) would apply to the dehydration unit. However, the dehydration unit meets the exemption criterion in 40 C.F.R. §63.764(e)(1)(ii); therefore, the dehydration unit is not subject to 40 C.F.R. §63.764(d).

According to 40 C.F.R. §63.764(e)(1), the permittee must maintain records of the determination of these criteria in accordance with 40 C.F.R. §63.774(d)(1). Since the benzene emissions justify the exemption, 40 C.F.R. §63.774(d)(1)(ii) (condition 6.4.7) is the applica ble requirement to maintain records of actual average benzene emissions as determined in accordance with 40 C.F.R. §63.772(b)(2) (condition 6.3.2 ). Furthermore, there are specific methods under 40 C.F.R. §63.772(b) that must be adhered to in order to veri fy the criteria for this exemption.

The facility meets the exemption criteria under 40 C.F.R. §63.764(e)(1)(ii); therefore, records of actual average benzene emissions must be kept pursuant to 40 C.F.R. §63.774(d)(1) [Section 6. 4.7 has been added to permi t in accordance with 40 C.F.R. §63.764(d)(1)].Title V Fact Sheet R30

- 00500020

- 2011 Page 5 of 7

Cranberry Pipeline Corporation  Danville Compressor Station

West Virginia Department of Environmental Protection  Division of Air Quality Section 6.1. 23 has been added to make the permittee aware that if benzene emissions from the dehy exceed 1 tpy of benzene , the dehy will be subject to 40 C.F.R. §63.764(d) ( 2 ) (i) through (iii) (in section 6 .1. 22 of the permit).

Section 6.2.5 is added for monitoring and recording actual operating parameters associated with the dehydration system i n order to demonstrate compliance with the area source status, as well as the 1 ton per year benzene exemption pr ovided under 6.1.22(e)(1)(ii) using GRI

- GLYCalc V3 or higher.

Section 6.3.1 has been added for sampling and analyzing the wet gas composition which will be used as input to GRI

- G L Y C alc in section 6.2.5.

Section 6.4.6 has been added to maintain records of all monitoring data, wet gas sampling, and annual GLYCalc emission estimates for the purpose of documenting compliance with the emission limitations, HAP major source thresholds, as well as the 1 ton per year benzene exemption

.

Section 6.5.1 has been ad ded for t he permittee to submit by March 31 st of the following year, an emission summary for the dehydration unit (DEHY) and shall include an actual annual average emission estimate for the calendar year of the sample

.

2. Flare Testing:

Due to success ful compliance testing of the flare in 2006 to show compliance with 40 C.F.R. § 60.18(f), Sections 6.3.1 and 6.3.2 of the existing permit were deleted. The flare testing results stated that the assist gas flow rate has to be at least 7000 scfd to show compl iance with the section 6.1.6 requirement for the net heating value of gas being combusted being 300 Btu/scf; hence sections 6.2.6 and 6.4.8 are being added to assure that assist gas (natural gas) flow rate fed to the flare shall not be less than 7000 scfd.

3. Compliance Plan:

The p ermittee sampled and performed a new wet gas analysis on August 1, 2011. The new gas analysis and subsequent G LYCalc emission s report show ed a violation of R13

- 2585B limits for Hexane, Toluene and Xylene as shown in the follo wing table:

Pollutant 45CSR13 permit limit Gl YC alc results based on new gas analysis

Lb/hr tpy Lb/hr tpy

Benzene 0.0032 0.014 0 0

Hexane 0.002 0.009 0.0273 0.1196

Toluene 0.005 0.02 0.0318 0.1391

Xylene 0.005 0.02 0.052 0.2278

Section 6.6.1 has been added for a compliance plan which states that the permittee shall submit a 45CSR13 /Title V modification to reflect the change in emissions as predicted using the recent wet gas analysis taken on August 1, 2011

.

4. 40 C

. F

. R

. 63 Subpart ZZZZ

- This rule is applicable to facilities that own or operate stationary reciprocating internal combustion engines (RICE) at major and area sources of HAP. A major source of HAP emissions is a plant site that has a potential to emit 10 tons/yr of a single HAP, or 2 5 tons/yr aggregate HAP s

. An area source of HAP emissions is a source that is not a major source. This facility has the potential to emit less than 10 tons/yr single HAP, and 25 tons/yr aggregate HAP s ; hence this facility is an area source of HAPs.Title V Fact Sheet R30

- 00500020

- 2011 Page 6 of 7

Cranberry Pipeline Corporation  Danville Compressor Station

West Virginia Department of Environmental Protection  Division of Air Quality a) Applicability of 40 C

. F

. R

. 63 Subpart ZZZZ to EG

- 1 : Emergency Generator EG

- 1 will be considered a new engine at an area source since construction commence d in 20 10 . Per 40 C.F.R

. §63.6590(c) (Section 8.1.3 of the permit), the engine shall meet the requirem ents of subpart ZZZZ by meeting the requirements of 40 C

. F

. R

. Part 60, Subpart JJJJ. No further requirements apply under Subpart ZZZZ.

b) Applicability of 40 C

. F

. R

. 63 Subpart ZZZZ to Engines #1, 2, 3 & 4 ( Emission point ID(s): 001

- 02, 001

- 03, 001

- 05 & 001

- 06 )

– Section 10 has been added to the permit to specify which sections of 40 C.F.R. 63 Subpart ZZZZ are applicable to Engines #1, 2, 3 & 4. Engines #1, 2 & 3 are existing (Constructed before 6

- 12

- 2006) non

emergency SI 2SLB < 500 HP located at an Are a Source of HAP. Engine # 4 is an existing (Constructed before 6

- 12

- 2006) non

- emergency SI 2SLB > 500 HP located at Area Source of HAP.

Section 10.1.1 of the permit

– Th ese are existing stationary SI RICE (constructed before 6

- 12

- 2006) located
at an area s ource of HAP emissions and according to 40 C.F.R. §63.6595, the permittee must comply with the applicable emission limitations and operating limitations no later than October 19, 2013 ; Also the permittee must meet the applicable notification requirements i n 40 C.F.R. § 63

. 6645 and in 40 CFR part 63

, subpart A.

Section s 10.1.2 to 10.1.5, 10.2.1, 10.4.1 & 10.5.1 have been added to the permit to address applicable sections of 40 C.F.R. 63 Subpart ZZZZ

. In section 10.1.2 (a) reference to operation limitations in Table 1b and 2b is taken out because they are not applicable.

c) Applicability of 40 C

. F

. R

. 63 Subpart ZZZZ to Engines # CE

- 5 & CE

- 6 ( Emission point ID(s): 001

- 10 & 001

- 11)

– Section 1 1 has been added to the permit to specify which sections of 40 C.F.R . 63 Subpart ZZZZ are applicable to Engines # CE

- 5 and CE

- 6

. Engines # CE

- 5 & CE

- 6 are existing (Constructed before 6

- 12

- 2006) non

- emergency SI 4SLB > 500 HP located at Area Source of HAP.

Section 11.1.1 of the permit

- This is an existing stationary SI R ICE (constructed before 6

- 12

- 2006) located at an area source of HAP emissions and according to 40 C.F.R. §63.6595

, the permittee must comply with the applicable emission limitations and operating limitations no later than October 19, 2013. Also the permitt ee must meet the applicable notification requirements in 40 C.F.R. § 63 .6645 and in 40 C

. F

. R

. P art 63

, subpart A.

Section s 1 1 .1.2 to 11.1.7, 11.2.1, 11.3.1 to 11.3.3, 11.4.1 & 11.5.1 to 11.5.2 have been added to the permit to address applicable sections of 40 C.F.R. 63 Subpart ZZZZ

.
5. Flare is subject to 45CSR § 6

- 4.3. Section 6.1.1 has been changed to streamline 45CSR § 6

- 4.3 requirements with 40 C.F.R. § 60.18 requirements.

6. Section 9.0 (40CFR60 Subpart JJJJ requirements for EG

- 1) has been modified to elimin ate requirements not applicable to EG

- 1.



### Non

- Applicability Determinations The following requirements have been determined not to be applicable to the subject facility due to the following:

There are no Greenhouse Gas Clean Air Act r equirements for this facility because the facility has not made any changes that triggered a PSD permit modification

.

40 CFR 64 (CAM Rule)

– This is the second permit renewal for this facility. The facility was found not to be subject to CAM at the time o f first renewal.Title V Fact Sheet R30

- 00500020

- 2011 Page 7 of 7

Cranberry Pipeline Corporation  Danville Compressor Station

West Virginia Department of Environmental Protection  Division of Air Quality Since the last renewal a 1 5 5.2 hp Kohler generator was added in 2010

. T he catalytic converter for this generator is i nherent p rocess e quipment according to the definition in 40 C.F.R § 64.1 and is not a control device; hence according to 4 0 C.F.R § 64.2, CAM is not applicable to this generator. Flare was installed in 2005. Potential emissions of VOC and HAPs from dehydration unit were below major source threshold before the flare was installed; hence according to 40 C.F.R § 64.2, CAM is not

a pplicable to the flare.



### Request for Variances or Alternatives
None



### Insignificant Activities Insignificant emission unit(s) and activities are identified in the Title V application.



### Comme nt Period Beginning Date: N ovember 23, 2011 Ending Date: D ecember 23, 2011

All written comments should be addressed to the following individua l and office:

U.K.Bachhawat Title V Permit Writer West Virginia Department of Environmental Protection Division of Air Quality 601 57 th Street SE Charleston, WV 25304



### Procedure for Requesting Public Hearin g During the public comment period, any interested person may submit written comments on the draft permit and may request a public hearing, if no public hearing has already been scheduled. A request for public hearing shall be in writing and shall state t he nature of the issues proposed to be raised in the hearing. The Secretary shall grant such a request for a hearing if he/she concludes that a public hearing is appropriate. Any public hearing shall be held in the general area in which the facility is l ocated.



### Point of Contact U.K.Bachhawat West Virginia Department of Environmental Protection Division of Air Quality 601 57 th Street SE Charleston, WV 25304 Phone: 304/926

- 0499 ext. 12 56 • Fax: 304/926

- 0478



### Response to Comments (Statement of Basis) Not applicable.

### West Virginia Department of Environmental Protection Division of Air Quality 

# Fact Sheet

For Draft/Proposed Renewal Permitting Action Under 45CSR30 and

Title V of t he Clean Air Act

Permit Number: R30

- 03900075

- 2012 Application Received: June 21, 2011 Plant Identification Number: 03900075 Permittee: Cranberry Pipeline Corporation Facility Name: Horsemill Compressor Station Mailing Address: 102 Third Street

Glasgow , WV 2 5086

Physical Location: Cedar Grove, Kanawha Coun ty, West Virginia UTM Coordinates: 461.61 km Easting • 4232.07 km Northing • Zone 17 Directions: From U.S. Route 60 in Cedar Grove, turn onto Kelly's Creek Road. Travel approximately 0.25 miles and turn left into Horsemill H ollow.

Facility Description Horsemill Compressor Station is a natural gas gathering facility covered by Standard Industrial Classification (SIC) Code 1389. The station has the potential to operate twenty

- fo ur (24) hours per day, seven (7) days per week, fifty

- two (52) weeks per year. The station consists of one (1) 600 HP natural gas compressor engine, one (1) 800 HP natural gas compressor engine, a glycol dehydration unit and 4 tanks of various sizes.Title V Fact Sheet R30

- 03900075

- 2012 Page 2 of 5

Cranberry Pipeli ne Corporation  Horsemill Compressor Station

West Virginia Department of Environmental Protection  Division of Air Quality 

### Emissions Summary

Plantwide Emissions Summary [Tons per Year]

Regulated Pollutants Potential Emissions 2010 Actual Emissions

Carbon Monoxide (CO) 24.40 3.90

Nitrogen Oxides (NO X ) 202.71 32.31

Parti culate Matter (PM 10 ) 2.16 0.14

Total Particulate Matter (TSP) 2.16 0.14

Sulfur Dioxide (SO 2 ) 0.04 < 0.01

Volatile Organic Compounds (VOC) 18.84 2.06

PM 10 is a component of TSP.

Hazardous Air Pollutants Potential Emissions 2010 Actual Emissions

Total HAPs 2.14 0.43

Some of the above HAPs may be counted as PM or VOCs.



### Title V Program Applicability Basis This facility has the potential to emit over 100 tons of NOx. Due to this facility's potential to emit over 100 tons per year of a criteria pollutant , Horsemill Compressor Station is required to have an operating permit pursuant to Title V of the Federal Clean Air Act as amended and 45CSR30.



### Legal and Factual Basis for Permit Conditions The State and Federally

- enforceable conditions of the Title V Operating Permits are based upon the requirements of the State of West Virginia Operating Permit Rule 45CSR30 for the purposes of Title V of the Fe deral Clean Air Act and the underlying applicable requirements in other state and federal rules.

This facility has been found to be subject to the following applicable rules:

Federal and State: 45CSR2 Control of particulate matt er from indirect heat exchangers 45 CSR6 Open burning prohibited 45CSR11 Standby plans for emergency episodes. 45CSR13 Permits for construction, modification, relocation, etc WV Code § 22

- 5

- 4 (a) (14) The Secretary can request any per tinent information such as annu al emission inventory reporting 45CSR30 Operating permit requirement 40 C.F.R. Part 61 Asbestos inspection and removal 40 C.F.R. Part 63 Subpart HH NESHAP: Oil & Natural Gas Production Facilities. 40 C.F.R. Part 63, Subpart ZZZZ RICE MACT 40 C.F.R. Part 82, Subpart F Ozone depleting substances

State Only: 45CSR4 No objectionable odors. 45CSR17 Control of fugitive particulate matterTitle V Fact Sheet R30

- 03900075

- 2012 Page 3 of 5

Cranberry Pipeli ne Corporation  Horsemill Compressor Station

West Virginia Department of Environmental Protection  Division of Air Quality Each State and Federally

- enforceable condition of the Title V Operating Permit references the specific relevant requirements of 45CSR30 or the applicable requirement upon which it is based. Any condition of the Title V permit that is enforceable by the State but is not Federally

- enforceable is identi fied in the Title V permit as such.

The Secretary's authority to require standards under 40 C.F.R. Part 60 (NSPS), 40 C.F.R. Part 61 (NESHAPs), and 40 C.F.R. Part 63 (NESHAPs MACT) is provided in West Virginia Code §§ 22

- 5

- 1 et seq., 45CSR16, 45CSR34 and 45CSR30.



### Active Permits/Consent Orders

Permit or Consent Order Number Date of Issuance Permit Determinations or Amendments That Affect the Permit (if any)

R13

- 2808A 4/11/11 N/A

Conditions from this facility' s Rule 13 permit(s) governing construction

- related specifications and timing requirements will not be included in the Title V Operating Permit but will remain independently enforceable under the applicable Rule 13 permit(s). All other conditions from this facility's Rule 13 permit(s) governing the source's operation and compliance have been incorporated into this Title V permit in accordance with the "General Requirement Comparison Table B ," which may be downloaded from DAQ's website.



### Determinations and J ustifications

Changes made to the most recent version to this Title V Permit are summarized below:

1. Miscellaneous The year installed date for Emission Units Engine #1 and #2 have been changed from 1993 to 1983 and 1985, respectively. This corrects the previous version. The Greenhouse Gas Reporting Requir ements have been removed from Conditions 3.1.10 and 3.5.11. Updates have been made to the Permit boilerplate.

2. 40CFR63, Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines The facility is subject to the area source requirements of this Subpart. The compliance date for these conditions unless specified elsewhere in the Permit is October 19, 2013. The facility has two engi nes (#1 and #2) that are subject to this Subpart. They are non

- emergency four stroke rich burn engines that are greater than 500 brake horsepower and operate more than 24 hours per year. Condition 7.1.1 has been added and limits the formaldehyde concentra tion emissions. Condition 7.1.2 has been added to ensure proper operation of the control device. Condition 7.1.3 has been added to show initial compliance of the formaldehyde concentration. Condition 7.1.4 has been added to ensure proper operation and m aintenance of the affected units. Condition 7.1.5 has been added to demonstrate continuous compliance with the formaldehyde concentration limits. Condition 7.2 .1 has been added to specify monitoring CO and either CO 2 or oxygen at the inlet and outlet of th e control device, as well as proper operation of the monitoring device. Condition 7.2.2 has been added to require continuous monitoring to show compliance with the formaldehyde emissions, and to not use bad data. Condition 7.3.1 has been added and specifie s the testing that is required for the initial performance test. Condition 7.3.2 has been added and specifies how the test is conducted.Title V Fact Sheet R30

- 03900075

- 2012 Page 4 of 5

Cranberry Pipeli ne Corporation  Horsemill Compressor Station

West Virginia Department of Environmental Protection  Division of Air Quality Condition 7.3.3 has been added and requires subsequent performa nce tests be completed every 8,76 0 hours, or 3 years, wh ichever comes first. Condition 7.4.1 has been added and requires recordkeeping for notification, reporting, performance tests, and the continuous monitoring data. Con dition 7.5.1 has been added and requires reports for things such as deviations, malfunctio ns, and compliance reporting. Condition 7.5.2 has been added and specifies the dates of notifications.



### Non

- Applicability Determinations The following requirements have been determined not to be applicable to the subject facility due to the following: 1. Greenhouse Gas Tailoring Rule This is a renewal Title V Permit and there have been no changes that would have triggered a PSD permit. As such, there are no applicable GHG permitting requirements.



### Request for Variances or Alternatives
None



### Insignificant Activities Insignificant emission unit(s) and activities are identified in the Title V application.



### Comment Period Beginning Date: January 26, 2012 Ending Date: February 27, 2012

All written comments should be addressed to the following individual and office:

Mike Egnor Title V Permit W riter West Virginia Department of Environmental Protection Division of Air Quality 601 57 th Street SE Charleston, WV 25304



### Procedure for Requesting Public Hearing During the public comment period, any interested person may submit written comments on the draft permit and may request a public hearing, if no public hearing has already been scheduled. A request for public hearing shall be in writing and shall state the nature of the issues proposed to be raised in the hearing. The Secretary shall grant such a request for a hearing if he/she concludes that a public hearing is appropriate. Any public hearing shall be held in the general area in which the facility is located.



### Point of Contact Mike Egnor West Vir ginia Department of Environmental Protection Division of Air Quality 601 57 th Street SE Charleston, WV 25304 Phone: 304/926

- 0499 ext . 1208 • Fax: 304/926

- 0478



### Response to Comments (Statement of Basis) ( Choose ) Not applicab le.Title V Fact Sheet R30

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- 2012 Page 5 of 5

Cranberry Pipeli ne Corporation  Horsemill Compressor Station

West Virginia Department of Environmental Protection  Division of Air Quality OR Describe response to comments that are received and/or document any changes to the final permit from the draft/proposed permit.081/0049 Page 1 of 12 

### TECHNICAL REVIEW DOCUMENT For MODIFICATION TO OPERATING PERMIT 97OPMF194

Questar Pipeline Company

– Skull Creek Dew Point Plant

(Formerly Known as the Powder Wash Dew Point Plant) Moffat County Source ID 0810049

Prepared by Blue Parish July 2011 ; Updated October 20, 2011

I. Purpose

This document establishes the basis for decisions made regarding the requested modifications to the Operating Permit for the Skull Creek Dew Point Plant

. This document provides information describing the type of modification and the changes made to the permit as requested by the source and the changes made due to the Division’s analysis. This document is designed for reference during review of the proposed permit by EPA and for future reference by the Division to aid in any addi tional permit modifications at this facility. The conclusions made in this report are based on the information provided in the original request for modification submitted to the Division

on May 17, 2011 and various e

- mail correspondence and telephone conve rsations with the source. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this ope rating permit application have been reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction Permits, and have been found to meet all applicable substantive and procedural requirements. This operating permit incorporates and shall be considered to be a combined construction/operating permit for any such revision, and the permittee shall be allowed to operate under the revised conditions upon issuance of this operating permit without applying for a revision to this permit or fo r an additional or revised construction permit.

II. Description of Permit Modification Request

Questar Pipeline Company (QPC) proposes to modify the existing facility by installing a Joule

- Thompson valve and piping, a low temperature three

- phase separator, an NGL product stabilizer tower with reboiler (heated by hot oil system), an electrically powered stabilizer overheads compressor, an NGL product cooler, a hot oil system with 1.65 MMBtu/hour heater a nd a gas

- gas exchanger. QPC also proposes to replace the

e xisting 375 hp Waukesha F3521GU engine used to generate electric power with a 607 hp Caterpillar G3412TA engine and to install a new emergency backup engine for power generation. The Natural Gas Liquids (NGL) product load

- out pump and meter will also be up graded. The modifications will allow the existing cold separator to operate at a lower temperature which will improve efficiency. Emission units at the facility affected by the modification include:Questar Pipeline Company

– Skull Creek Dew Point Plant Operating Permit No. 97OPMF194 Technical Review Document

– Renewal 1, Modification 3

081/0049 Page 2 of 12 

### • GEN1

– new Caterpillar G3412TA engine (natural gas

- fire d) , equipped with Non

Selective Catalytic Reduction (NSCR)

**•** GEN2

– new Cummins GTA855B emergency backup engine (natural gas

- fired)

**•** P503

– Glycol Skid: increase gas throughput from 60 MMscfd to 70 MMscfd, and modify operating parameters of the unit

**•** F701

– F ugitive Components: although the total component count will be modified by the installation/modification of equipment, the existing permitted limit of 10 tons per year VOC is sufficient to handle the new component count and will not be modified in this ac tion.

**•** TRK01

– Truck Loading of NGLs (new point): based on the requested amount of NGL loaded out, VOC emissions are above APEN thresholds of 2 tons per year (Regulation No. 3, Part A, Section II.D.1.a), and are therefore subject to the permitting requirem ents of Regulation No. 3, Part B.

**•** The n ew hot oil system heater (1.65 MMBtu/hr) Is exempt from APEN reporting requirements by Reg No. 3, Section A, II.D.1.k (less than 5 MMBtu/hr). This unit qualifies as an insignificant activity for operating permit purp oses (Reg No. 3, Part C, Section IIE.3.k) In addition to the upgrades noted above, QPC requested that the produced water pit be removed from the insignificant activities list (it has been replaced with a subsurface liquid knockout tank) and to change the name of the facility from Powder Wash Dew Point Plant to Skull Creek Dew Point Plant. These additional changes were requested in an email received on July 28, 2011. QPC also notified the Division on July 15, 2011 of a change in the responsible official. Colorado Regulation No. 3, Part C, Section X.A identifies those modifications that can be processed under the minor permit modification procedures. Specifically, minor permit modifications “are not otherwise required by the Division to be processed as a

s ignificant modification” (Colorado Regulation No. 3, Part C, Section X.A.6). The Division requires that “any change that causes a significant increase in emissions” be processed as a significant modification (Colorado Regulation No. 3, Part C, Section I.B. 36.h.(i)). Emission increases from the new and modified equipment are less than the PSD significance levels, and none of the monitoring requirements in the existing permit are being relaxed or removed. Questar submitted an application on May 17

, 2011 req uesting that the modification be pr ocessed as a minor modification; the Division agrees that the proposed changes qualify as a minor modification.

Emissions for the project are included in Attachment 1 at the end of this document.
Note that the facility ha d previously requested a minor modification on March 29, 2011 related to the GEN 1 engine. On January 11, 2011, the facility temporarily replaced the P303 engine with the current Waukesha F3521GU model engine (also 375 hp) with the intention of sending th e P303 unit offsite for routine maintenance. During the maintenance activities, it was discovered that the original unit had reached the end of its useful life and could not be placed back in service. The purpose of the March 2011Questar Pipeline Company

– Skull Creek Dew Point Plant Operating Permit No. 97OPMF194 Technical Review Document

– Renewal 1, Modification 3

081/0049 Page 3 of 12 

### permit modification was to permit the Waukesha F3521GU as a permanent replacement to the P303 Unit. The Division prepared a draft permit for this modification which completed a 45 day review period at EPA on May 19, 2011. However, the March 2011 permit revision was never actual ly issued as it is being superseded by the modification described herein.
Applicable Requirements

– GEN1 (Caterpillar G3412TA Natural Gas

- Fired, 4SRB Reciprocating Internal Combustion Engine Site Rated at 607 hp)
40 CFR 60 Subpart JJJJ

- Standards of Perfo rmance for Stationary Spark Ignition Internal Combustion Engines
Based on the APEN received on May 17, 2011, the date of manufacture for this engine is in 2009. It is th erefore subject to the following emission standards:

**•** NOx

– 2.0 g/hp

- hr

**•** CO

– 4.0 g/hp

- h r

**•** VOC

– 1.0 g/hp

- hr Subpart JJJJ requires an initial performance test and subsequent testing every 3 years or 8,760 hours, for engines not certified by the manufacturer. The owner or operator must keep a maintenance plan and maintenance records.

40 CFR 63 Subpart ZZZZ: National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines

The Skull Creek Dew Point facility is an area (not major) source of Hazardous Air Pollutants (HAPs). This unit is categorized as a new engine at an area source (commenced construction after 6/12/2006 as per § 63.6590(a)(2)(iii) ) . Subpart ZZZZ does not include specific requirements for new engines at area sources but instead requires that they meet the requirements of 40 CFR 60 S ubpart JJJJ ( § 63.6590(c)(1)).

Colorado Regulation No 7, Section XVII

– Statewide Controls for Natural Gas

- Fired R ec iprocating Internal Combustion E ngines Section XVII.E.2 contains the requirements applicable to new, modified and relocated engines, and Section XVII.E.3 contains requirements for existing engines. According to Regulation No. 7, Section XVII.B. 4 : Condensate tanks, dehydrators and internal

com bustion engines that are subject to an emissions control requirement in a federal maximum achievable control technology (“MACT”) standard under 40 CFR Part 63, a Best Available Control Technology (“BACT”) limit, or a New Source Performance Standard under 4 0 CFR Part 60 are not subject to this Section XVII. Therefore Regulation No. 7 requirements are not applicable.

40 CFR 64

– Compliance Assurance Monitoring (CAM)
This engine is equipped with NSCR for control of NO x 

### and VOC emissions. The potential to emit for NO x 

### of the engine, without controls, exceeds major source levels and the engine is subject to an annual limit on NO x 

### emissions. The unit is not a Large Pollutant

- specific Emissions Unit (controlled NO x 

### emissions are less than 100 tpy). ForQuestar Pipeline Company

– Skull Creek Dew Point Plant Operating Permit No. 97OPMF194 Technical Review Document

– Renewal 1, Modification 3

081/0049 Page 4 of 12 

### this unit, the CAM plan is required to be submitted as part of an application for renewal of the operating permit ( § 64.5(b)).
Other Applicable Requirements

**•** Emissions of air pollutants shall not exceed the following limitations based on rolling 12

- month totals (as re quested in an APEN submitted May 17 , 2011 ):

o NO x 

### 5.86 tpy

o CO 11.72 tpy

o This engine is not a synthetic minor source in and of itself, and does not change the status of the facility with respect to operating permit, PSD or MACT applicability; therefore, monthly limits are not included.

**•** Natural gas consumption shall not exceed 35.3 MMscf per year based on rolling 12

- mont h totals as requested in an APEN submitted Ma y 17 , 2011 ).

**•** Emissions shall not exceed 20% opacity (Colorado Regulation No. 1 , Section A.II.1). Reg 1, Section A.II.4 also includes a 30% opacity requirement that applies to fire building, cleaning of fire boxes, soot blowing, start

- up, Process Modification or Adjustment of Control Equipment. F ire building, cleaning of fire boxes and soot blowing do not apply to this unit

. The control equipment does not control particulate matter, and t he Division considers start

- ups and process modifications for this unit unlikely to occur for longer than six minutes. Therefore, the 30% opacity requirement is not included in the permit.

**•** Periodic monitoring requirements are included in the permit to monitor compliance with the emission and fuel consumption limits, including: verification of heat content of the gas, inlet catalyst temperature, pr essure drop across the catalyst, milivolt reading of the AFR and oxygen concentration in the engine exhaust. The permit also includes requirements for maintenance when catalyst inlet temperature and/or pressure drop falls outside the specified range.

**•** Quar terly portable monitoring for NO x 

### and CO will be required as per the Division’s standard protocol.

**•** Reg 3, Part B, Section IV.G.4.a.(i) thru (ii) requires that c onstruction of a source must commence within 18 months of initial approval permit issuance date or within 18 months of date on which such construction or activity was scheduled to commence as stated in the application

. This condition, along with the requirements to notify the Division of startup and to certify compliance, apply to both new engines a nd are included as new condition 9 in Section II of the permit.
Applicable Requirements

– GEN2 (Cummins GTA855B Natural Gas

- Fired, 4SRB Reciprocating Internal Combustion Engine Site Rated at 354 hp)
This engine is an emergency generator and its Potential t o Emit (PTE) is calculated at 500 hours per year in accordance with EPA’s September 6, 1995 memo (“Calculating Potential to Emit (PTE) for Emergency Generators”).Questar Pipeline Company

– Skull Creek Dew Point Plant Operating Permit No. 97OPMF194 Technical Review Document

– Renewal 1, Modification 3

081/0049 Page 5 of 12 

### 40 CFR 60 Subpart JJJJ

- Standards of Performance for Stationary Spark Ignition Internal Comb ustion Engines Based on the APEN received on May 17, 2011, the date of manufacture for this engine is in 1995. Subpart JJJJ does not apply to owners or operators of emergency engines greater than 25 hp manufactured before January 1, 2009

. 40 CFR 63 Subpar t ZZZZ: National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
The Powder Wash Dew Point facility is an area (not major) source of Hazardous Air Pollutants (HAPs). This unit is categorized as a n ew engine at an area source (commenced construction after 6/12/2006 as per § 63.6590(a)(2)(iii) ) . Subpart ZZZZ does not include specific requirements for new engines at area sources but instead requires that they meet the requirements of 40 CFR 60 Subpart JJJJ ( § 63.6590(c)(1)). Since no requirements apply under NSPS JJJJ, it is presumed that no requirements apply under MACT ZZZZ. Colorado Regulation No 7, Section XVII

– Statewide Controls for Natural Gas

- Fired R ec iprocating Internal Combustion E ngines

Sect ion XVII.E.1 of Reg. 7 states: The requirements of this Section XVII.E. shall not apply to any engine having actual uncontrolled emissions below permitting thresholds listed in Regulation Number 3, Part B. Potential NO x 

### , VOC and CO emissions for this

eme rgency engine are less than 10 tons per year each, which are below the threshold of Part B, Section II.D.1.c.(iii)(B)

. 40 CFR 64

– Compliance Assurance Monitoring (CAM) This engine is not equipped with a control device and is not subject to CAM.

Other Applicable Requirements

**•** Emissions of air pollutants shall not exceed the following limitations based on rolling 12

- month totals (as requested in an APEN submitted Ma y 17 , 2011 ):

o NO x 

### 3.83 tpy

o CO & VOC

– NA. Actual emissions are less than APEN reportable th resholds; therefore limits are not included in the permit.

o This engine is not a synthetic minor source in and of itself, and does not change the status of the facility with respect to operating permit, PSD or MACT applicability; therefore, monthly limits are not included.

**•** Hours of operation shall not exceed 500 per year based on rolling 12

- month totals as requested in an APEN submitted Ma y 17 , 2011.

**•** Emissions shall not exceed 20% opacity (Colorado Regulation No. 1, Section A.II.1). Reg 1, Section A.II.4 a lso includes a 30% opacity requirement that applies to fire building, cleaning of fire boxes, soot blowing, start

- up, Process Modification or Adjustment of Control Equipment. Fire building, cleaning of fire boxes and sootQuestar Pipeline Company

– Skull Creek Dew Point Plant Operating Permit No. 97OPMF194 Technical Review Document

– Renewal 1, Modification 3

081/0049 Page 6 of 12 

### blowing do not apply to this unit . The control equipment does not control particulate matter, and the Division considers start

- ups and process modifications for this unit unlikely to occur for longer than six minutes. Therefore, the 30% opacity requirement is not included in the permit.

**•** Reg 3, Part B, Section IV.G.4.a.(i) thru (ii) requires that construction of a source must commence within 18 months of initial approval permit issuance date or within 18 months of date on which such construction or activity was scheduled to commence as st ated in the application. This condition, along with the requirements to notify the Division of startup and to certify compliance, apply to both new engines and are included as new condition 9 in Section II of the permit.
Applicable Requirements

– TRK01 (T ruck Loadout from Pressurized Storage Tanks)
The facility use d GRI HAPCalc 3.0 to estimate emissions from truck loadout from pressurized tanks. HAPCalc is based on equations from from AP

- 42 Chapter 5, 5 th 

### edition. An emission factor based on the HAPCalc results will be used to monitor compliance with the emission limit based on throughput. Calculations are based on loading in vapor balance service, with all captured vapors recycled to the pressurized tank. The facility is not a major source of HAPs so 4 0 CFR Subpart EEEE does not apply.
Applicable Requirements

– P503 (Glycol Skid)
The facility is increasing max potential gas throughput from 60 MMscfd to 70 MMscfd and increasing the glycol recirculation rate from 1.7 to 2.5 gpm. Other operational paramet ers for the unit are also changing so that the emission limit is not affected by this modification.

III. Discussion of Modifications Made

**•** Updated Section I (General Activities and Summary) and the appendices containing the reporting formats to address the rep lacement engine, the new emergency backup engine, and truck loadout from pressurized tanks.

**•** Updated the responsible official information on the page following the cover page in accordance with a notification from the source received July 15, 2011

**•** Added a n ew set of Conditions (Section II, Condition 6) for the replacement generator engine (new GEN1)

**•** Added a new set of Conditions (Section II, Condition 7) for the new emergency backup generator engine (new GEN2)

**•** Added a new set of Conditions (Section II, Condition 8) for condensate loadout from pressurized tanks

**•** Added a set of Conditions (Section II, Condition 9) addressing Regulation No 3, Part B construction requirements for the new enginesQuestar Pipeline Company

– Skull Creek Dew Point Plant Operating Permit No. 97OPMF194 Technical Review Document

– Renewal 1, Modification 3

081/0049 Page 7 of 12 

### • Updated Section II, Condition 2 ( dehydrator ) to address an incre ase in gas throughput of 10 MMscfd and updated the operating parameters for the unit.

**•** Updated Appendix A to include the hot oil system heater as an insignificant activity and to replace the produced water pit with the subsurface knock out tank.

**•** Throughout: changed the facility name from Powder Wash Dew Point Plant to Skull Creek Dew Point Plant.

**•** Note that the existing GEN1 engine (Waukesha F3521GU) remains in the permit under Section II, Condition 1 so that it may be operated until the new engine is in pla ce. Condition 6.8 requires the existing GEN1 engine to be removed upon startup of the new unit, and for the Division to be notified.

IV. Update

– October 20, 2011

The EPA review period ended on September 18, 2011. Following this review period, the applicant noted the following errors on the proposed permit:

**•** The Table in Section II, Condition 6.1 had a typo and should read “Portable Flue Gas Analyzer” instead of “Portable Fuel Gas Analyzer”

**•** The frequency for pressure drop across the catalyst for GEN 1 is not specified (Condition 6.5.2). Note the frequency should have been monthly, in accordance with current Division policy for engines operating with with controls at Title V facilities. The first correction is typographical. Addition of the monitorin g frequency is a clarification and does not reduce the stringency of the monitoring in the proposed permit. Therefore, these corrections are being incorporated directly into the permit and no additional review period is determined to be necessary.Questar Pipeline Company

– Skull Creek Dew Point Plant Operating Permit No. 97OPMF194 Technical Review Document

– Renewal 1, Modification 3

081/0049 Page 8 of 12 

### ATTAC HMENT 1

- Emissio n Calculations and Factors for the new GEN1 (Caterpillar G3412GA)

Point Summary of Criteria Emissions (tpy) Proposed Control Efficiency NOx 95.4% VOC 50.0% CO NA SOx 0.0% TSP 0.0% PM10 0.0% PM2.5 0.0% Total HAPs* 50.0%

Point Summary of Hazardous Air Pollutants (lb/yr)

HAP Name Proposed Control Efficiency Formaldehyde 50.0% Methanol 50.0% Acetaldehyde 50.0% Acrolein 50.0% Benzene 50.0% 1,3-Butadiene 50.0% Toluene 50.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus * * 26

* * 22 103 51 103 62 31 62 * * 119 109 54 109 *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.

Uncontrolled

Requested Controlled Requested PTE 800 400 800 0.4 0.4 0.4 0.0 0.0 0.6 0.4 0.4 0.4 0.4 0.4 0.4 8.8 11.7 11.7 0.0 0.0 0.0 127.2 5.9 127.2

8.2 4.1 8.2 Uncontrolled

Requested Controlled Requested PTE

Emission Factor Sources

NOx VOC CO Formaldehyde SOx TSP PM10 PM2.5 Other Pollutants AP-42; Table 3.2-3 (7/2000); Natural Gas No Control AP-42; Table 3.2-3 (7/2000); Natural Gas 50% control for HAPs AP-42; Table 3.2-3 (7/2000); Natural Gas No Control AP-42; Table 3.2-3 (7/2000); Natural Gas No Control AP-42; Table 3.2-3 (7/2000); Natural Gas No Control mfg JJJJ limits mfg JJJJ limits AP-42; Table 3.2-3 (7/2000); Natural Gas APEN mfg JJJJ limits Uncontrolled ControlledQuestar Pipeline Company

– Skull Creek Dew Point Plant Operating Permit No. 97OPMF194 Technical Review Document

– Renewal 1, Modification 3

081/0049 Page 9 of 12 

### ATTACHMENT 1

- Emissio n Calculations and Factors for the new GEN2 (Cummins GTA855F)

Point Summary of Criteria Emissions (tpy) Proposed Control Efficiency
NOx 0.0% VOC 0.0% CO 0.0% SOx 0.0% TSP 0.0% PM10 0.0% PM2.5 0.0% Total HAPs* 0.0%

Point Summary of Hazardous Air Pollutants (lb/yr)

HAP Name Proposed Control Efficiency Formaldehyde 0.0% Methanol 0.0% Acetaldehyde 0.0% Acrolein 0.0% Benzene 0.0% 1,3-Butadiene 0.0% Toluene 0.0% Uncontrolled

Requested Controlled Requested PTE
3.83 3.8 3.8 0.27 0.3 0.3 0.65 0.6 0.6 0.00 0.0 0.0

*Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.

Uncontrolled

Requested Controlled Requested PTE 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

* * 5

* * 4 * * 32

* * 4

* * 2

*Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus * * 1

* * 1

Emission Factor Sources

NOx VOC CO Formaldehyde SOx TSP PM10 PM2.5 Other Pollutants Uncontrolled Controlled mfg no control mfg no control mfg no control AP-42; Table 3.2-3 (7/2000); Natural Gas no control AP-42; Table 3.2-3 (7/2000); Natural Gas No Control AP-42; Table 3.2-3 (7/2000); Natural Gas No Control AP-42; Table 3.2-3 (7/2000); Natural Gas No Control AP-42; Table 3.2-3 (7/2000); Natural Gas No Control AP-42; Table 3.2-3 (7/2000); Natural Gas no controlQuestar Pipeline Company

– Skull Creek Dew Point Plant Operating Permit No. 97OPMF194 Technical Review Document

– Renewal 1, Modification 3

081/0049 Page 10 of 12 

### ATTACHMENT 1

- Emissio n Calculations and Factors for TRK01 (truck load out from pressurized tanks)

Emission Calculation Method: GRI HAPCalc 3.0

Point Summary of Emissions (tpy) Proposed Control Efficiency VOC 0.0% Benzene 0.0% Toluene 0.0% Ethylbenzene 0.0% Xylenes 0.0% n-Hexane 0.0% Total HAPs

HAPs - lbs/year Unc. Cont Benzene 10.4 10.4 Toluene 3 3 Ethylbenzene 0.2 0.2 Xylenes 0.2 0.2 n-Hexane 1172.8 1172.8 0.59 0.6 0.70368 0.6 0.6 0.7 0.00 0.0 0.00012 0.00 0.0 0.00012 0.01 0.0 0.00624 0.00 0.0 0.00180 Uncontrolled

Requested Controlled Requested PTE 4.6 4.6 5.5Questar Pipeline Company

– Skull Creek Dew Point Plant Operating Permit No. 97OPMF194 Technical Review Document

– Renewal 1, Modification 3

081/0049 Page 11 of 12 

### ATTACHMENT 1

- Emissio n Calculations and Factors for P503

– 70 MMscfd Dehydrator

Operational Parameters Req. gas throughput 70.00 MMscfd Inlet Gas Pressure 750.00 psig Inlet gas temperature 54 °F
Flash Tank Pressure Flash Tank Temp Inlet Gas Water 7 lb/MMscf Max Condenser Temp Condenser Pressure Cold Sep pressure 550 psig Cold Sep temp 0 °F Lean Glycol Water 20 % Glycol Flow Rate 2.5 gpm

Emission Calculation Method: GLYCalc 4.0 Combustor Efficiency: 90.0%

Point Summary of Emissions (tpy) Proposed Control Efficiency VOC 90.0% Benzene 90.0% Toluene 90.0% Ethylbenzene 90.0% Xylenes 90.0% n-Hexane 90.0% Total HAPs 90.0%

GLYCalc output - at max design glycol pump rate of 2.5 gpm*

flash regen flash regen flash regen VOC 5.8069 0.58069 0.900 Benzene 1.5916 0.15916 0.900 Toluene 0.3069 0.03069 0.900 Ethylbenzene 0.0201 0.00201 0.900 Xylenes 0.2995 0.02995 0.900 n-Hexane 0.0498 0.00498 0.900 * VOC and HAPs are in tpy from the regenerator emissions reports.

HAP Emissions in lb/year Unc. Cont. Benzene 3183.2 318.32 Toluene 613.8 61.38 Ethylbenzene 40.2 4.02 Xylenes 599 59.9 n-Hexane 99.6 9.96 uncontrolled Controlled Control Efficiency 0.0 0.0 2.3 0.2 0.2 0.0 0.0 0.0 0.0 0.3 0.0 0.0 1.6 0.2 0.2 0.3 0.0 0.0 5.8 0.6 0.6 Uncontrolled Controlled Requested PTEQuestar Pipeline Company

– Skull Creek Dew Point Plant Operating Permit No. 97OPMF194 Technical Review Document

– Renewal 1, Modification 3

081/0049 Page 12 of 12 POINT Description NOx VOC Fug VOC CO Reporta ble HAPs Total HAPs NOx VOC Fug VOC CO Report able HAPs Total HAPs REMARKS

010 P503 Glycol Skid 0.6 0.2 0.2 5.8 1.6 2.3 Increase throughput from 60 to 70, change op parameters to run colder; no change to emission limit 018 F701 Fugitives 10.0 0.0 0.1 10.0 0.0 0.1 No change to emission limit 023 T1681 Condensate Tank 4.7 0.1 0.2 4.7 0.1 0.2 APEN update/due date reset 027 GEN1 Generator Engine 5.9 4.1 11.7 0.3 0.3 127.2 8.2 8.8 0.5 0.6 New 028 GEN2 Backup generator engine 3.8 0.3 0.6 0.0 0.0 3.8 0.3 0.6 0.0 0.0 New 029 TRK01 Condensate Loadout 4.6 0.6 0.6 5.5 0.6 0.6 New TOTAL 9.7 14.3 10.0 12.4 1.1 1.5 131.0 24.6 10.0 9.4 2.8 3.8

Emission Increase due to upgrade project: NOx: 9.7 VOC 9.9 CO: 12.4 Increase due to GEN1 is based on controlled emissions since there are federally enforceable emissions limits (NSPS JJJJ) Increase due to GEN2 is based on a PTE calculated at 500 hours per year in accordance with EPA's policy on emergency backup generators 

### Controlled Emissions Uncontrolled Emissions

Increase due to TRK01 is based on the uncontrolled PTE, which is assumed at a throughput rate of 120% of the requested value and calculated using the same equation (i.e., vapor balance is assumed integral to the process and not an add on control)