### Authors: Pennsylvania Department of Environmental Protection (PADEP)



## Timothy Kuntz: Environmental Group Manager (Air Quality SWRO)

Thomas Norris: Air Quality Specialist (SWRO)

May 2014

SWRO: South West Regional Office This Power Point presentation is intended to discuss Air Quality GP5 field inspections of natural gas compressor stations in the State of Pennsylvania.

 The scope of this Power Point is to highlight a typical inspection by an Air Quality Field Inspector to ensure the station is in compliance.

 The GP5 issuance/renewal process is not discussed in this Power Point.

 GP5 issuance/renewal is handled by PADEP Engineers. As such, Air Quality Inspectors rely on documentation created by the Engineers during the permit review process to assist them in determining applicable State and Federal regulations.

 This Power Point will focus on the PA State regulations listed within the GP5. Federal regulations will not be thoroughly discussed.

 T he following sources (Sections) within the 2013 GP5 will not be discussed:

• Section C. Requirements For Natural Gas

- Fired Simple Cycle Gas Turbines

• Section D. Requirements For Centrifugal Compressors

• Section G. Requirements For Onshore Natural Gas Processing Plants

• Section I. Requirements For Pneumatic Controllers

• Section J. Requirements For Sweetening UnitsThe following process should be conducted by the Air Quality Inspector.



## Before:

 

### Review station file for station familiarization.

 

### Determine which GP5 version is applicable.

 

### Coordinate field inspection date/time with station owner. 

## During:

 

### Conduct GP5 permit review with station personnel and request
pertinent documents.

 

### Verify station inventory matches permitted inventory.

 

### Conduct visual observations and take notes.



## After:

 

### Pursue follow

- up requests as needed.

 

### Write up inspection report. 

### In the state of Pennsylvania, natural gas production (compressor) stations (conventional & unconventional) are regulated under a

GP5.

 

### Applicable GP5 versions:

- 8/2006

– GP5 issued/re

- issued prior to 3/17/2011

- 3/17/2011

– GP5 issued/re

- issued between 3/17/2011 and 2/2/2013

- 2/2/2013

– GP5 issued/re

- issued on or after 2/2/2013

 

### GP5 permits are applicable for a timeframe of five (5) years before

re

- issuance is required.

 

### GP5 permit renewal applications need to be submitted to the Department thirty (30) days prior to permit expiration.

- (2006 & 2011 GP5 Condition 9)

- (2013 GP5 Section A Condition 21) 

### Differences between the 2006 and 2011 GP5 are minimal in regards to Air Quality Inspector inspections.

 

### The 2011 GP5 is a ‘cleaned

- up’ version in regards to language revisions throughout the document.

 

### The main difference is that the 2011 GP5 contains a paragraph

under Condition 2 Titled: Potential to Emit Limitations. This condition allows the applicant to propose lower emission limits based on manufacturer’s specifications and other operational
limits. This condition is not found within the 2006 GP5 version, nor

has it been carried over into the 2013 GP5 version.

 

### Additionally, the revised 2011 GP5 clarified that federal new source performance standards and NESHAPs are applicable requirements. 

### For the most part, the contents of the 8/2006 and 3/17/2011
GP5 versions have been carried over into the 2/2/2013 GP5
version. Differences between the versions are :

- More sources are covered within the 2013 GP5.

- Stricter emission limits in the 2013 GP5.

- Emission limits are listed in the 2013 GP5 for sources

that were not included within the 2006/2011 GP5.

- More stringent conditions are in the 2013 GP5 for Glycol Dehydrators

.

- Additional conditions have been added to the 2013

GP5 that are not listed within the 2006/2011 GP5.

- Applicable Federal Regulations are addressed within

the 2013 GP5

.Ensure the following written notifications have been submitted to the Department by the station owner/operator no later than five (5) business days prior to:

- Initial commencement date of construction of the source(s) authorized under the GP5. (2013 GP5 Section A Condition 11c(i).

- ...completion of construction and the intent to commence operation. (2006/2011 GP5 Condition 6).

- Final completion date of construction. (2013 GP5 Section A Condition 11c(ii).

- Any lapse in construction activity of eighteen (18) months or more that may take place in

between the initial and start

- up dates... (2013 GP5 Section A Condition 11c(iii)

...written notification...of the intent to commence operation of the....facility. When multiple sources...are subject to different commencement of operation schedules, written notice shall be submitted...prior to the commencement of operation of each source. (2013 GP5 Section A Condition 11d).

###  

# Have any malfunctions been reported?

 

# Were they reported as per the GP5 condition?

 

# Review any reported malfunctions.

- 2006/2011 GP5 Condition 6

- 2013 GP5 Section A Condition 11e

Malfunction as defined within 2013 GP5 Section A Condition 11e: ...any malfunction of pollution control equipment associated with the facility, which results in, or may possibly be resulting in, the emission of air contaminants in excess of any applicable limitation specified

herein. 

### Fugitive Emissions and Malodors cannot leave facilities property.

- 2006/2011 GP5 (odors only) Conditions 13a(ii) and 13c(v)

- 2013 GP5 (fugitives & odors) Section A Conditions 9(iii) and 9(iv )

 

### Opacity limits apply to both engines and dehydrators.

- 2006/2011 GP5 Conditions 13a(i) or 13b(v) and 13c(iv)

- 2013 GP5 Section B Condition 1c and Section F Condition 2d

 

### There are no permit requirements that mandate the owner/operator conduct observations for fugitive emissions, odors or opacity or maintain a log of any observations

.

 

### Inspector: Inquire about fugitive emission, odor and opacity compliance and conduct observations for each to determine compliance. Section A Condition 9c

- ...emissions from all sources and associated air pollution control equipment... shall not equal or exceed the following on a 12

- month rolling sum...

- 100 tons for NOx, CO, SOx, PM10, PM2.5

- 50 tons for VOCs

- 10 tons for any individual HAP

- 25 tons for total HAPs

- 100,000 tons for greenhouse gases, expressed as carbon dioxide

equivalent (CO2e)

* Note: Stricter NOx (25 tons) and VOC (25 tons) emission limits are listed for Bucks, Chester, Delaware, Montgomery and

Philadelphia counties.

 Section A Condition 14

– The owner/operator... shall maintain records that clearly demonstrate... that the facility is not a Title V facility.... and shall keep records to verify compliance with the facility

- wide emission limitations (as listed within Section A Condition 9c).

 Inspector: Request records to show compliance with these conditions. Ensure
records are maintained as a 12

- month rolling sum.

 Note: There are no facility

- wide emission limits listed within the 2006/2011 GP5. 

### Section A Condition 15

- ...the owner/operator... shall submit to the Department by March 1 st 

### each year a source report for the preceding calendar year for all sources regulated under this General Permit. Emissions data including, but not limited to the following, shall be reported:

CO , NOx, PM10, PM2.5, SOx , VOCs, Total HAPs, Speciated

Individual HAPs and Greenhouse Gases expressed as CO2e

.

 

### Inspector: Confirm that the appropriate Emissions Inventory Report has been submitted in a timely manner.

 Note: This condition is not listed within the 2006/2011 GP5, however, PADEP has sent out a letter to all GP5 permitted facilities to submit this report regardless of the

GP5 version they are currently permitted under. 

### This condition pertains to unconventional gas facilities only. 

## Upon review of the station file and DEP Engineer
review documents, the inspector needs to determine
the specific applicable GP5 conditions for each engine.
Determine if Federal Part 63 Subparts JJJJ and/or ZZZZ
regulations apply.

 

## Verify that the on

- site station inventory matches the
GP5 permitted sources.

 

## Verify if each engine is existing, new or reconstructed.

If reconstructed, determine date of reconstruction.

 

## Verify air pollution control equipment.

 

## Observe operating parameters of each engine and
take notes as applicable.

###  

## Request annual hours of operation and fuel used

for each engine (2006/2011 GP5 Condition 17a).

 

## Request monthly hours of operation and fuel used for

each engine (2013 GP5 Section B Condition 5b).

 

# Note if there are any differences between
the station and what was reported within the
permit application.

 

# Ask to review engine maintenance records.

 

# Verify compliance with applicable Federal
Part 63 Subpart JJJJ and/or ZZZZ regulations

. 

### Upon review of the station file and DEP Engineer review documents, the inspector needs to determine which specific GP5 performance testing conditions apply (if any) for each engine

.

 

### Within all GP5 versions, engines equal to or less than 500 bhp do not need initial or subsequent emission tests.

 

### Within all GP5 versions, engines greater than 500 bhp must have an initial emissions test conducted and conduct subsequent portable analyzer tests thereafter.

 

### Inspector: Ensure station has submitted the proper initial testing notifications in a timely manner and review for compliance.

 

### Inspector: Request and review all applicable portable analyzer test reports for compliance. 

### The 2006/2011 GP5 versions do not have any conditions that apply to storage tanks listed.

 2013 GP5

– Section E

– Requirements For Storage Vessels/Storage Tanks

- Must comply with 40 CFR Subparts Kb, OOOO and HH.

- Tank capacity greater than 40,000 gallons shall comply with

25 PA Codes 129.56.

- Tank capacity less than or equal to 40,000 gallons shall comply

with 25 PA Code129.57.

 Inspector: Compliance with these conditions is typically conducted during the engineer permit review process. Inspector should conduct a visual observation of tanks to confirm inventory, confirm tank labelling is

correct , determine that the condition of the tank is sound and ensure covers, lids or seals are in the closed position except during required tank operations.

 Annual tank emissions should be submitted within the facilities annual emission inventory reports. Determine if 40 CFR Part 63 Subpart HH applies (engineer review) and
ensure compliance if applicable. Request proof of HH exemption if
applicable.

 Determine units uncontrolled VOC Tons Per Year emissions to determine
applicable GP5 conditions (engineer review).

- >10 Tons Per Year then Condition 13c and Condition 17c applies.

- ≤10 TPY then the unit is exempt from Condition 13c & 17c and Condition
17d applies. If >10 TPY VOC and not exempt, Condition 13c and 17c apply

 Condition 13c:

• (i) Ensure unit is outfitted with a VOC control device with at least 85% efficiency.

• (ii) If condenser is used, ensure an average final exhaust temperature of less than 110 degrees Fahrenheit is achieved daily.

• (iii) If flare is used, ensure that VOC emissions destruction is achieved by maintaining the heat content of the flare gas above 300 BTU/scf and document daily visual observations of the continuous presence of a flame. Inspector requests proof of compliance.

• (iv) Unit opacity limitations: 10% for a period or periods aggregating more than 3 minutes in any one hour and 30% at any time.

• (v) Malodors from the unit are not detectable off the facility property.

 Condition 17c:

• (i) Request any test reports if applicable.

• (ii) If unit uses a condenser, a record of final exhaust temperature and time observed shall be recorded twice per week on different days during daylight hours. Inspector requests log.

• (iii) If unit uses a flare, a record of daily visual observations of the continuous presence of a flame shall be recorded. Inspector requests log.

• (iv) Inspector requests to review records of maintenance and repairs and records of the duration of uncontrolled emissions during such activities. If ≤10 TPY VOC and exempt from Conditions 13c and 17c, then Condition
17d applies :

- ( i) Inspector request records of VOC emissions using GRI

- GLYCalc

computer software or an alternative method approved by the Department

.

- ( ii) Inspector requests records of actual throughput per day and the glycol

circulation rate.

 For all dehydrator units permitted under a 2006/2011 GP5, regardless of
exemption, Condition 17a applies:

- Inspector requests records of number of hours and amount of fuel
used per calendar year for each applicable dehydrator.

*Note: These same conditions have been carried over into the 2013 GP5

version under Section F Conditions 1 & 2. Determine if unit is existing or new. If unit is existing (constructed prior to 2/2/13) Section F Condition 2 is applicable (covered under the 2006/2011 GP5 section). If unit is new (constructed after 2/2/13) then 2013 GP5 Section F

Conditions 3 & 4 apply

.

 Section F Condition 1: Determine if 40 CFR Part 63 Subpart HH applies (engineer review) and ensure compliance if applicable. Request proof of HH exemption if applicable

.

 Section F Condition 3: If unit is not subject to Subpart HH and has a total uncontrolled potential emission rate of VOC >5 TPY it must be outfitted with an air cleaning device capable of at least 95% VOC destruction efficiency. In addition, Section F Condition 2 (b) through (j) also apply (which have been covered under 2006/2011 GP5 section).

 Section F Condition 4: If unit is not subject to Subpart HH and has a total uncontrolled potential emission rate of VOC ≤5 TPY it must comply with the requirements in Section F Condition 2 (d), (e) and (j) (which have been covered under the 2006/2011 GP5 section). 

### Condition 1 : Facility must perform a monthly leak detection and repair program that includes audible, visual and olfactory (AVO) inspections. Inspector requests records of these inspections.

 

### Condition 2 : Facility must conduct quarterly fugitive leak inspections using a forward looking infrared camera (FLIR) or other Department approved leak detection monitoring devices. Compliance is due within 180 days of issuance of the 2013 GP5 or within 180 days of construction/installation of a new source covered under the 2013 GP5. Inspector requests inspection reports.

 

### Condition 3 : If a leak is detected it shall be repaired no later than 15 days after discovery (except provided in 40 CFR 60.482

- 9). Records of each leak detected and the repair activity shall be maintained. Inspector requests records.

###  

# Unauthorized use of an unpermitted source

 

# Operation without Plan Approval/Permit

 

# Emissions Testing (Excess Emissions)

 

# Visual Emission, Fugitive Emission, Odors

 

# Failure to maintain the appropriate records

 

# Failure to submit paperwork in a timely

manner:

- Notifications

- Permit Applications (Initial or Renewal)

- Request For Determinations (RFD)

- Annual Emission Reports (Due by March 1 st 

## )

- Change of Ownership (requires new GP5) PADEP Website: http:// www.depweb.state.pa.us/portal/server.pt/community/dep_home/5968

 PADEP Air Quality General Permits: http:// www.depweb.state.pa.us/portal/server.pt/community/dep_home/5968 Natural Gas Compression and/or Processing Facilities.

• Conditions ( PDF )

• Fact Sheet ( PDF )

• Comment/Response Document ( PDF )

• Changes to Previous Permit ( PDF of PowerPoint )

• Technical Support Document ( PDF )
Amended on 4/9/13

• Internal Implementation Instructions for Exemption Category No. 38 ( PDF )

• FAQ

– Implementation of GP

- 5 and Exemption No. 38 ( PDF )

• Summary of 40CFR60 IIII ( Excel )

• Summary of 40CFR60 JJJJ ( Excel )

• Summary of 40CFR63 HH ( Excel )

• Summary of 40CFR63 ZZZZ ( Excel )

 PADEP Plan Approval/Operating Permit Applications, Exemptions Listing and Request

For Determination: http:// www.dep.state.pa.us/dep/deputate/airwaste/aq/permits/plan.htm

# Inspecting Natural Gas Compressor Stations in Pennsylvania

Authors: Pennsylvania Department of Environmental Protection (PADEP )

Timothy Kuntz: Environmental Group Manager (Air Quality SWRO)

Thomas Norris: Air Quality Specialist (SWRO)

May 2014

SWRO: South West Regional Office