MEMORANDUM 

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 comments 

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 proposal

noted. This information was documented at proposal in Table A-1 of Docket ID No. EPA-HQOAR-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 + 

Facility ID Source ID HAP Column I) Comments

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 + 

Facility ID Source ID HAP Column I) Comments

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 + 

Facility ID Source ID HAP Column I) Comments

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 Proposal – 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 Proposal.

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

Facility 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. The highest 

MIR for the Oil and Natural Gas Production major source category is 10-in-1-million and the 

highest MIR for the Natural 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 WVDAQ Fact Sheet

Questar – Skull Creek CDPHE Fact Sheet
file:///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 H2S Content of Inlet Gas: 2 ppmv (highest H2S from water flash)

Oil/Condensate Throughput (bbl/day): 80 Is the gas sweet or sour? Sweet
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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)*(H2S 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 SO2 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)

 H2S (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)
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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 H2S content (wt %): 0.0001

Flash Gas VOC emissions, lb/hr: 1.60 Flash Gas H2S emissions, lb/hr: <0.01

Flash Gas VOC emissions, tpy: 7.04 Flash Gas H2S 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 H2S content (wt %): 0.0002

Flash Gas VOC emissions, lb/hr: 0.72 Flash Gas H2S emissions, lb/hr: <0.01

Flash Gas VOC emissions, tpy: 3.17 Flash Gas H2S emissions, tpy: <0.01

TRUCK LOADING [EMISSIONS CALCULATED USING LL=(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)

LL

(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.
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(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 NOx , 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 NOx 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 (SO2 ) (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 NO2/NOx Max. Annual Concentration of NO2/NOx NO2/NOx Ratio Annual NO2 Concentration
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(from Screen3 modeling)

(μg/m3)

(Max. Hourly Conc. X 0.08)

(μg/m3)

(from table below) (Max. Annual Conc. X NO2/NOx Ratio)

(μg/m3)

ENG-1 27.26 2.18 0.4 0.872

Background Concentration for County = 25

TOTAL = 25.872

Is total below NAAQS limit for NO2 of 100 μg/m3 (y s/no)? Yes

Unless otherwise documented by actual test data, the following nitrogen dioxide (NO 2 )/NOx ratios shall be used for modeling NO2;

Device NOx Emission Rate (g/hp-hr) NO2/NOx 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 PM10 AP-42 0.000588lb/MMbtu 0.12 0.51

Vendor Data Sheet Included?

(required if ≥ 500-hp )

No* SO2 AP-42 0.01940 lb/MMbtu <0.01 0.02

Date of Manufacture or

Reconstruction:

MFG

1968

CH2O 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.
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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 PM10 PM 2.5 SO2 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 REVIEWER
file:///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

Footers

Published by GroupWise
file:///C|/Brad/Oil%20&%20Gas/Docket/Final%20Rule/alta%20mesa%20services2.htm[4/17/2012 12:52:06 PM]

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.html
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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

NOx 13.17 tpy

CO 19.38 tpy

PM10 0.52 tpy

PM2.5 0.52 tpy

SO2 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 

Footers
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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 transmission 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 (NOX) 60.66 52.49 

Particulate Matter (PM10) 1.45 0.5781 

Total Particulate Matter (TSP) 1.45 0.5781 

Sulfur Dioxide (SO2) 0.09 0.0264 

Volatile Organic Compounds (VOC) 32.95 25.66 

PM10 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 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 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) The Secretary can request 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 fugitive 

 
Title 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 upon which it is based. Any condition of the draft Title V 

permit that is enforceable by the State but is not Federally-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 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 Justifications

According to the following calculation, compliance with FERC (Federal Energy Regulatory Commission) 

limit for total sulfur of 20 grains/100 cu.ft will assure compliance with 45CSR10 limit of 2000 ppm SO2: 

(20grains of S/100 cu.ft of gas) x (1lb/7000 grains) x (1lbmol S/32 lb S) x (1lbmol SO2 /1lbmol S) x (385.1 

cu.ft of gas/1lbmol gas) x 106 = 343 ppm of SO2. 

Compliance with FERC limit for H2S 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 H2S content and total sulfur includes H2S. 

Hence H2S 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 Reboiler’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. Hence, 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 requirements for tanks because there are no tanks with a volume equal to or greater 

than 75 m3

. 

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 according 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 57th 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 

U.K.Bachhawat

West Virginia Department of Environmental Protection 

 Division of Air Quality 

 601 57th Street SE 

 Charleston, WV 25304 

 Phone: 304/926-0499 ext. 1256 • Fax: 304/926-0478 
Title 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 the 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 Virginia

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 covered by Standard Industrial 

Classification (SIC) Code 1311. The station has the potential 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 

natural gas compressor engine, two (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 (NOX) 233.58 231.58

Particulate Matter (PM10) 3.62 3.59

Total Particulate Matter (TSP) 3.62 Not reported

Sulfur Dioxide (SO2) 0.08 0.07

Volatile Organic Compounds (VOC) 16.14 15.86

PM10 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 233.58 tons per year of Nitrogen Oxide. Due to this facility's 

potential to emit over 100 tons per year of criteria 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 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 Indirect Heat Exchangers

45CSR6 Open burning prohibited.

45CSR10 Emission 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 pertinent 

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 Asbestos 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

MACT
Title 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 objectionable 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 Amendments 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 with 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 define “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 changed 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.

Changes 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 facilities 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, “Facilities 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, natural 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 applicability 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 miles 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 permit 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 standards 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 requirements 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 applicable 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 

verify 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 permit 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 in order to demonstrate compliance with the area source status, as well as the 1 ton per 

year benzene exemption provided 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-GLYCalc 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 added for the permittee to submit by March 31st 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 successful 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 compliance 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 permittee sampled and performed a new wet gas analysis on August 1, 2011. The new gas analysis and 

subsequent GLYCalc emissions report showed a violation of R13-2585B limits for Hexane, Toluene and 

Xylene as shown in the following table:

Pollutant 45CSR13 permit limit GlYCalc 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 25 tons/yr aggregate HAPs. 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 HAPs; 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 commenced in 2010. Per 40 C.F.R. §63.6590(c) (Section 8.1.3

of the permit), the engine shall meet the requirements 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) nonemergency SI 2SLB < 500 HP located at an Area 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 – These are existing stationary SI RICE (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 

permittee must meet the applicable notification requirements in 40 C.F.R. §63.6645 and in 40 CFR part 63, 

subpart A.

Sections 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 11 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 RICE (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 

permittee must meet the applicable notification requirements in 40 C.F.R. §63.6645 and in 40 C.F.R. Part 

63, subpart A.

Sections 11.1.2 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 eliminate 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 requirements 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 of 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 155.2 hp Kohler generator was added in 2010. The catalytic converter for this 

generator is inherent process equipment according to the definition in 40 C.F.R §64.1 and is not a control 

device; hence according to 40 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 

applicable to the flare. 

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: November 23, 2011

Ending Date: December 23, 2011

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 57th 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

U.K.Bachhawat

West Virginia Department of Environmental Protection

Division of Air Quality

601 57th Street SE

Charleston, WV 25304

Phone: 304/926-0499 ext. 1256 • 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 the 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 25086

Physical Location: Cedar Grove, Kanawha County, 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 Hollow. 

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-four (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 Pipeline 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 (NOX) 202.71 32.31

Particulate Matter (PM10) 2.16 0.14

Total Particulate Matter (TSP) 2.16 0.14

Sulfur Dioxide (SO2) 0.04 < 0.01

Volatile Organic Compounds (VOC) 18.84 2.06

PM10 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 Federal 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 matter from indirect 

heat exchangers

45CSR6 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 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 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 matter
Title V Fact Sheet R30-03900075-2012 Page 3 of 5

Cranberry Pipeline 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 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 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 Justifications

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 Requirements 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 engines (#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 concentration 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 maintenance 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 CO2 or oxygen at the inlet and outlet 

of the 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 specifies 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 Pipeline Corporation  Horsemill Compressor Station

West Virginia Department of Environmental Protection  Division of Air Quality

Condition 7.3.3 has been added and requires subsequent performance tests be completed every 8,760 hours, 

or 3 years, whichever comes first.

Condition 7.4.1 has been added and requires recordkeeping for notification, reporting, performance tests, 

and the continuous monitoring data.

Condition 7.5.1 has been added and requires reports for things such as deviations, malfunctions, 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 Writer

West Virginia Department of Environmental Protection

Division of Air Quality

601 57th 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 Virginia Department of Environmental Protection

Division of Air Quality

601 57th Street SE

Charleston, WV 25304

Phone: 304/926-0499 ext. 1208 • Fax: 304/926-0478

Response to Comments (Statement of Basis)

(Choose) Not applicable.
Title V Fact Sheet R30-03900075-2012 Page 5 of 5

Cranberry Pipeline 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.