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OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM
June 29, 2007
TO:
Phillip Fielder, P.E., Permits and Engineering Group Manager
Air Quality Division
THROUGH:
Matt Paque, Supervising Attorney, Air Quality Division
THROUGH:
Kendal Stegmann, Senior Environmental Manager
Compliance and Enforcement
THROUGH:
Eric Milligan, P.E., Engineering Section
THROUGH:
Dale Becker, P.E., New Source Permits Section
THROUGH:
Peer Review
FROM:
Mark Chen, P.E., New Source Permits Section
SUBJECT:
Evaluation of Operating Permit Application No. 2007-102-O
Canaan Resources, L.L.C.
Ulan Compressor Station
Latitude N 35.1010o, Longitude W 95.8514o
Sections 8, Township 7N, Range 14E
Indianola, Pittsburg County, Oklahoma.
Directions: From the Exit of the Indian Nation Turnpike at Ulan Exit (Exit
82), go east 1/4 mile, turn south on Ulan Road and go 1 mile, turn east and
go 2.0 miles, then, turn south into site entrance.
SECTION I. INTRODUCTION
Canaan Resources, L.L.C. (Canaan) has submitted a Part 70 Title V Operating Permit application
for their Ulan Compressor Station (SIC code 1311) as agreed in a Voluntary Disclosure of
Noncompliance, submitted to AQD on December 29, 2006. Canaan purchased the Ulan
Compressor Station from XAE Corporation on November 15, 2006. Then, Canaan discovered
that the Ulan Station has potential emissions of NOx and CO exceeding the major source
threshold, 100 TPY. An analysis of actual and potential emission was submitted to AQD on
January 29, 2007. Canaan files this Part 70 Title V Operating permit application to bring the
Ulan Station into compliance with DEQ regulations. The facility is subject to Tier II of Title V
permitting requirements. A “synthetic minor” permit will be issued at the conclusion of the Title
V review process.
SECTION II. FACILITY DESCRIPTION
A pipeline gathering system transports field natural gas from wells through inlet separators,
where free liquids are removed. Most liquids collected from the inlet separator and then stored
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in three 40-bbl storage tanks are essentially water, and the organic material in the condensate
water is not recoverable. Then, the natural gas stream enters the compressors at approximate 1020 psig, and leaves the compressors at an approximate gas pressure of 450-550 psig. After
passing through the compressors, the natural gas streams are combined into one stream and then
split into two streams. One natural gas stream is sold to CenterPoint without being dried. The
other stream enters the dehydration unit, which is then sold to Enogex. In the dehydration unit,
the lean glycol stream contacts wet gas, where water/moisture is absorbed from the gas. The rich
glycol stream with the absorbed water is transferred to a glycol regenerator, where heat is used to
boil off the water/moisture. Heat is supplied by an 85 MBTUH glycol reboiler. Dry gas exits
the dehydration unit contactor and enters Enogex pipeline. Produced water is stored in the
storage tanks and periodically transported off site via truck for disposal. The facility is designed
to operate at the maximum capacity of 8 MMSCF/day.
SECTION III. EQUIPMENT
Table 1 Internal Combustion Engines
Source
Name/Model
Serial No.
Installation Date
1,232-hp
Waukesha
7042
GSI
C-1
143300
August 2006
4-stroke rich-burn with a catalytic converter
550-hp Caterpillar G398 TA
C-2
73B534
2000
4-stroke rich-burn with a catalytic converter
550-hp Caterpillar G398 TA
C-3
73B1538
September 2003
4-stroke rich-burn with a catalytic converter
515-hp Waukesha 3711 GU
C-4*
48756
1996
4-stroke rich-burn without controls
145-hp Caterpillar 3306 NA
C-5*
7Y212
1997
4-stroke rich-burn without controls
* Standby units only operate when one of the primary units is not operating.
Source
D-1
H-1
Source
T-1
T-2
T-3
T-4
Table 2 Glycol Dehydrator Heater/Still Vent
Make/Model
MMBTUH
Installation Date
Dehydrator Still Vent
----1996
Glycol Regeneration Heater
85 MBTUH
1996
Table 3 Storage Tanks
Capacity
Contents
Barrels
Gallons
Produced Water
40
1,680
Produced Water
40
1,680
Produced Water
35.7
1,500
Produced Water
35.7
1,500
Installation
Date
1996
1996
1996
1996
SECTION IV. AIR EMISSIONS
Based on manufacturer’s data (including a safety factor for operational flexibility), the emission
factors for compressor engines are presented in Table 4. The criteria pollutant emissions are
estimated from the primary compressor engines (C-1, C-2, and C-3) and the glycol regeneration
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heater (reboiler) based on 8,760 hours per year operation and 1,000 BTU/SCF average heating
value. The emissions from standby compressors (C-4 and C-5) are estimated based on 1,000
hours per year operation.
Table 4 Engine Emission Factors
NOx
Emissions Source
g/hp-hr
C-1, 1,232-hp Waukesha 7042 GSI with C.C.
3.00
C-2 & C-3, 550-hp Caterpillar G398 TA with C.C.
3.00
C-4, 515-hp Waukesha 3711 GU without C.C.
18.00
C-5, 145-hp Caterpillar 3306 NA without C.C.
20.30
CO
g/hp-hr
3.00
3.00
28.00
1.50
VOC
g/hp-hr
1.00
1.00
0.35
0.24
Table 5A lists the engine specifications and stack parameters for primary compressor engines.
Table 5B lists the engine specifications and stack parameters for standby compressor engines.
Table 5A Engine Specifications and Stack Parameters (Primary Engines)
Parameter
C-1
C-2 & C-3
Manufacturer
Waukesha
Caterpillar
Model
7042 GSI
G398 TA
Control
Cat. Conv. & AFR Controller Cat. Conv. & AFR Controller
Input Parameter
Horsepower (max)
1,232
550
Fuel Consumption (BTU/hp-hr)
7,284
8,011
Fuel Usage (SCFH)
8,798
4,406
Stack Diameter (Inches)
12
8
Height above Grade (Feet)
15.0
15.0
Exhaust Flow (ACFM)
4,166
2,558
Exhaust Temperature (oF)
1,033
1,004
Calculated Parameter
Moisture Content (%)
20.3
15.9
Table 4B Engine Specifications and Stack Parameters (Standby Engines)
Parameter
C-4
C-5
Manufacturer
Waukesha
Caterpillar
Model
3711 GU
G3306 NA
Control
None
None
Input Parameter
Horsepower (max)
515
145
Fuel Consumption (BTU/hp-hr)
8,004
7,543
Fuel Usage (SCFH)
4,122
1,094
Stack Diameter (Inches)
6
6
Height above Grade (Feet)
12.0
8.0
Exhaust Flow (ACFM)
2,530
711
o
Exhaust Temperature ( F)
1,100
1,035
Calculated Parameter
Moisture Content (%)
16.0
14.5
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The Glycol Dehydrator has air emissions from the regenerator vent, and the reboiler combustion
exhaust stack. Emissions from the glycol dehydration unit’s still vent are based upon GRIGLYCALC™ Version 4.0 along with an extended gas analysis, 2.5 MMSCFD gas throughput,
and maximum 0.50 gallon per minute lean glycol recirculation rate for the dehydration unit.
Emission estimates are based on continuous operation, 8,760 hr/yr. The dehydration unit is
equipped with an 85 MBTUH gas-fired burner to provide heat to distill water and volatile
organic compounds out of rich glycol stream. Criteria pollutants emissions from the natural gasfired equipment, heater H-1, are estimated based on the emission factors in AP-42 (7/98), Tables
1.4-1 and 1.4-2, Section 1.4, “Natural Gas Combustion.” Dehydration units using glycol
desiccants emit benzene, toluene, ethyl benzene, xylene (BTEX), and n-hexane from the
dehydrator still vent stack. These compounds are regulated as hazardous air pollutant (HAP).
Vapors from the still vent and the off-gas from the flash tank are directly vented to the air. The
emission summary from the Glycol Dehydrator is shown below in Table 6.
Table 6 VOC and HAP Emissions from Glycol Dehydrator
Uncontrolled Emissions
Pollutant
lb/hr
TPY
n-Hexane
ND
ND
Benzene
0.0631
0.2765
Toluene
0.1946
0.8522
Ethyl Benzene
ND
ND
Xylene
0.0327
0.1434
Total HAP
0.2904
1.2721
Total VOC
1.2692
5.5591
ND = Not Detectable
Table 7 lists total facility-wide controlled emissions.
ID #
C-1
C-2
C-3
C-4
C-5
D-1
H-1
FUG
Total
Table 7 Total Facility-Wide Controlled Emissions
NOx
CO
Source
lb/hr
TPY
lb/hr TPY
1,232-hp Waukesha 7042 GSI with
8.15
35.69
8.15 35.69
Catalytic Converter
550-hp Caterpillar G398 TA with
3.64
15.93
3.64 15.93
Catalytic Converter
550-hp Caterpillar G398 TA with
3.64
15.93
3.64 15.93
Catalytic Converter
515-hp Waukesha 3711 GU without
20.44
10.22 31.79 15.90
Catalytic Converter
145-hp Caterpillar 3306 NA without
6.49
3.24
0.48
0.24
Catalytic Converter
Dehydrator Still Vent
----Dehydrator Glycol Heater
0.01
0.04
<0.01
0.03
Fugitive Emissions
----Emissions
42.37
81.05 47.71 83.72
lb/hr
VOC
TPY
2.72
11.90
1.21
5.31
1.21
5.31
0.40
0.20
0.08
0.04
1.27
<0.01
0.09
6.99
5.56
0.01
0.38
28.71
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Fugitive emissions are based on Table 2-4 of “1995 Protocol for Equipment Leak Emission
Estimates (EPA 453/R-95-017),” Oil and Gas Production Operations Average Emission Factors.
VOC content in the vapor lines is averaged at 6.00% by weight. VOC emissions from the water
storage tanks, methanol tanks, and lube oil tanks are considered negligible. Most liquids
collected from the inlet separator and stored in all four produced water tanks (T-1, T-2, T-3, & T4) are essentially water, and the organic material in the condensate water is not recoverable.
Based on Table 7, the facility is considered a synthetic minor source since controlled emissions
are below major source thresholds, 100 TPY. The primary hazardous air pollutant (HAP)
emission from the engines is formaldehyde (HCHO). Formaldehyde emissions from the engines
are estimated based on formaldehyde emission factor derived from AP-42 (7/00), Section 3.2,
Table 3.2-3, for uncontrolled 4-stroke rich burn natural gas-fired stationary engines, 0.0205
lb/MMBtu. The installation of a catalytic converter reduces the formaldehyde emissions by 75%
to 0.00513 lb/MMBtu. Table 8 lists formaldehyde emissions based on 8,760 hours per year
operation except for standby compressor engines, which is based on 1,000 hr/yr. The facilitywide formaldehyde emissions do not exceed the major source threshold, 10 TPY. Including
HAP emissions from glycol dehydrator (D-1), the facility-wide HAP emissions, 1.724 TPY, do
not exceed the major source threshold, 10 TPY.
Table 8 Formaldehyde Emissions
Emissions Source
C-1, 1,232-hp Waukesha 7042 GSI with C.C.
C-2, 550-hp Caterpillar G398 TA with C.C.
C-3, 550-hp Caterpillar G398 TA with C.C.
C-4, 515-hp Waukesha 3711 GU without C.C.
C-5, 145-hp Caterpillar 3306 NA without C.C.
Total
C.C. = Catalytic Converter
Formaldehyde
lb/hr
TPY
0.046
0.202
0.023
0.099
0.023
0.099
0.085
0.042
0.022
0.011
0.199
0.453
SECTION V. OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252:100-1 (General Provisions)
Subchapter 1 includes definitions but there are no regulatory requirements.
[Applicable]
OAC 252:100-3 (Air Quality Standards and Increments)
[Applicable]
Primary Standards are in Appendix E and Secondary Standards are in Appendix F of the Air
Pollution Control Rules. At this time, all of Oklahoma is in attainment of these standards.
OAC 252:100-4 (New Source Performance Standards)
[Not Applicable]
Federal regulations in 40 CFR Part 60 are incorporated by reference as they exist on September
1, 2005, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B,
Subpart C, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, Subpart BBBB,
Subpart DDDD, Subpart HHHH, and Appendix G. NSPS standards are addressed in the
“Federal Regulations” section.
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OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Applicable]
Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission
inventories annually, and pay annual operating fees based upon total annual emissions of
regulated pollutants. This facility is required to submit an emission inventory and pay annual
fees after this operating permit is issued to this facility.
OAC 252:100-7 (Permits for Minor Facilities)
[Applicable]
This facility (with controls listed in this permit) qualifies as a “synthetic minor” source after
issuance of this permit because total controlled emissions of each criteria pollutant do not exceed
100 TPY and Hazardous Air Pollutants (HAP) emissions do not exceed the 10 TPY for any one
HAP or 25 TPY for any aggregate of HAP.
OAC 252:100-9 (Excess Emission Reporting Requirements)
[Applicable]
In the event of any release which results in excess emissions, the owner or operator of such
facility shall notify the Air Quality Division as soon as the owner or operator of the facility has
knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10)
working days after the immediate notice is given, the owner operator shall submit a written
report describing the extent of the excess emissions and response actions taken by the facility.
OAC 252:100-13 (Open Burning)
[Applicable]
Open burning of refuse and other combustible material is prohibited except as authorized in the
specific examples and under the conditions listed in this subchapter.
OAC 252:100-19 (Particulate Matter)
[Applicable]
This subchapter specifies a particulate matter (PM) emissions limitation of 0.6 lb/MMBTU from
fuel-burning equipment with a rated heat input of 10 MMBTUH or less. For 4-cycle rich-burn
engines, AP-42 (7/00), Table 3.2-3 lists the total PM emissions for natural gas to be 0.02
lbs/MMBTU. AP-42 (7/98), Table 1.4-2 lists total PM emissions for natural gas combustion
from heaters, boilers, etc., to be 0.01 lbs/MMBTU. The permit requires the use of natural gas for
all fuel-burning units to ensure compliance with Subchapter 19.
This subchapter also limits emissions of PM from industrial processes. Per AP-42 factors, there
are no significant PM emissions from any other industrial activities at this facility.
OAC 252:100-25 (Visible Emissions and Particulates)
[Applicable]
No discharge of greater than 20% opacity is allowed except for short-term occurrences that
consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed
three such periods in any consecutive 24 hours. In no case shall the average of any six-minute
period exceed 60% opacity. When burning natural gas there is little possibility of exceeding the
opacity standards.
OAC 252:100-29 (Fugitive Dust)
[Applicable]
No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the
property line on which the emissions originate in such a manner as to damage or to interfere with
the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the
maintenance of air quality standards. Under normal operating conditions, this facility will not
cause a problem in this area, therefore it is not necessary to require specific precautions to be
taken.
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OAC 252:100-31 (Sulfur Compounds)
[Applicable]
Part 5 limits sulfur dioxide emissions from new petroleum or natural gas process equipment
(constructed after July 1, 1972). For gaseous fuels the limit is 0.2 lb/MMBTU heat input
averaged over 3 hours. For fuel gas having a gross calorific value of 1,000 Btu/SCF, this limit
corresponds to fuel sulfur content of 1,203 ppmv. Gas produced from oil and gas wells having
343 ppmv or less total sulfur will ensure compliance with Subchapter 31. The permit requires
the use of pipeline-grade natural gas or field gas with a maximum sulfur content of 343 ppmv for
all fuel-burning equipment to ensure compliance with Subchapter 31.
OAC 252:100-33 (Nitrogen Oxides)
[Not Applicable]
This subchapter limits NOx emissions from new fuel-burning equipment with rated heat input
greater than or equal to 50 MMBTUH to emissions of 0.2 lb of NOx per MMBTU. There are no
equipment items that exceed the 50 MMBTUH threshold.
OAC 252:100-35 (Carbon Monoxide)
[Not Applicable]
None of the following affected processes are located at this facility: gray iron cupola, blast
furnace, basic oxygen furnace, petroleum catalytic cracking unit, or petroleum catalytic
reforming unit.
OAC 252:100-37 (Volatile Organic Compounds)
[Part 7 Applicable]
Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons
or more and storing a VOC with a vapor pressure greater than 1.5 psia at maximum storage
temperature to be equipped with a permanent submerged fill pipe or with an organic vapor
recovery system. There are no condensate storage tanks at this facility. No tanks are subject to
this requirement.
Part 3 requires VOC loading facilities with a throughput equal to or less than 40,000 gallons per
day to be equipped with a system for submerged filling of tank trucks or trailers if the capacity of
the vehicle is greater than 200 gallons. This facility does not have the physical equipment
(loading arm and pump) to conduct this type of loading and is not subject to this requirement.
Part 5 limits the VOC content of coatings from any coating line or other coating operation. This
facility does not normally conduct coating or painting operations except for routine maintenance
of the facility and equipment. No coating operation is located at this facility.
Part 7 requires fuel-burning and refuse-burning equipment to be operated to minimize emissions
of VOC. The equipment at this location is subject to this requirement.
Part 7 requires all effluent water separator openings which receive water containing more than
200 gallons per day of any VOC, to be sealed or the separator to be equipped with an external
floating roof or a fixed roof with an internal floating roof or a vapor recovery system. No
effluent water separators are located at this facility.
Part 7 also requires all rotating pumps or compressors handling VOC to be equipped with
mechanical seals or other equipment of equal efficiency. All reciprocating pumps or compressors
handling VOC are to be equipped with packing glands that are properly installed and in good
working order such that emissions from the drain recovery system are limited to two cubic inches
of VOC in any 15 minute period at standard conditions per pump or compressor. The equipment at
this location will be subject to this requirement.
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OAC 252:100-41 (Hazardous Air Pollutants)
[Not Applicable]
Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted
by reference as they exist on September 1, 2005, with the exception of Subparts B, H, I, K, Q, R,
T, W and Appendices D and E, all of which address radionuclides. In addition, General
Provisions as found in 40 CFR Part 63, Subpart A, and the Maximum Achievable Control
Technology (MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, L, M, N, O, Q,
R, S, T, U, W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR, SS,
TT, UU, VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN, OOO,
PPP, QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC, DDDD, EEEE, FFFF, GGGG,
HHHH, IIII, JJJJ, KKKK, MMMM, NNNN, OOOO, PPPP, QQQQ, RRRR, SSSS, TTTT,
UUUU, VVVV, WWWW, XXXX, YYYY, ZZZZ, AAAAA, BBBBB, CCCCC, EEEEE,
FFFFF, GGGGG, HHHHH, IIIII, JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP,
QQQQQ, RRRRR, SSSSS and TTTTT are hereby adopted by reference as they exist on
September 1, 2005. These standards apply to both existing and new sources of HAPs. These
requirements are covered in the “Federal Regulations” section.
Part 5 was a state-only requirement governing sources of toxic air contaminants that have
emissions exceeding a de minimis level. However, Part 5 of Subchapter 41 has been superseded
by OAC 252:100-42, effective June 15, 2006.
OAC 252:100-42 (Toxic Air Contaminants (TAC))
[Applicable]
Part 5 of OAC 252:100-41 was superceded by this subchapter. Any work practice, material
substitution, or control equipment required by the Department prior to June 11, 2004, to control a
TAC, shall be retained unless a modification is approved by the Director. Since no Area of
Concern (AOC) has been designated anywhere in the state, there are no specific requirements for
this facility at this time.
OAC 252:100-43 (Testing, Monitoring, and Recordkeeping)
[Applicable]
This subchapter provides general requirements for testing, monitoring and recordkeeping and
applies to any testing, monitoring or recordkeeping activity conducted at any stationary source.
To determine compliance with emissions limitations or standards, the Air Quality Director may
require the owner or operator of any source in the state of Oklahoma to install, maintain and
operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant
source. All required testing must be conducted by methods approved by the Air Quality Director
and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol
shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests.
Emissions and other data required to demonstrate compliance with any federal or state emission
limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained,
and submitted as required by this subchapter, an applicable rule, or permit requirement. Data
from any required testing or monitoring not conducted in accordance with the provisions of this
subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive
use, of any credible evidence or information relevant to whether a source would have been in
compliance with applicable requirements if the appropriate performance or compliance test or
procedure had been performed.
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The following Oklahoma Air Pollution Control Rules are not applicable to this facility:
OAC 252:100-11 Alternative Emissions Reduction
not requested
OAC 252:100-15 Mobile Sources
not in source category
OAC 252:100-17 Incinerators
not type of emission unit
OAC 252:100-23 Cotton Gins
not type of emission unit
OAC 252:100-24 Grain Elevators
not in source category
OAC 252:100-39 Nonattainment Areas
not in area category
OAC 252:100-47 Municipal Solid Waste Landfills
not in source category
SECTION VI. FEDERAL REGULATIONS
PSD, 40 CFR Part 52
[Not Applicable]
Final total emissions are less than the major source threshold of 250 TPY of any single regulated
pollutant and the facility is not one of the 26 specific industries with a threshold of 100 TPY.
NSPS, 40 CFR Part 60
[Not Applicable]
Subparts Kb, VOL Storage Vessels. Subpart Kb regulates hydrocarbon storage tanks larger than
19,813 gallons capacity and built after July 23, 1984. There are no condensate storage tanks at
this facility. This subpart is not applicable.
Subpart GG, Stationary Gas Turbines. There are no turbines at this facility. The compressors
here are powered by reciprocating engines.
Subpart VV, Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing
Industry. This facility is not a SOCMI plant.
Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. This
subpart applies to natural gas processing plants that commence construction, reconstruction, or
modification after January 20, 1984, and include the following facilities located at on-shore
natural gas processing plants: a compressor station, dehydration unit, underground storage tank,
field gas gathering system, or liquefied natural gas unit located at an on-shore natural gas
processing plant. "Natural gas processing plant" is defined as any site engaged in the extraction
of natural gas liquids from field gas, fractionation of natural gas liquids, or both; "Natural gas
liquids" are further defined as hydrocarbons such as ethane, propane, butane, and pentane. This
site does not engage in this type of activity at this time. Therefore, this facility is not subject to
Subpart KKK.
Subpart LLL, Onshore Natural Gas Processing: SO2 Emissions. There is no natural gas
sweetening operation at this site. Therefore, this facility is not subject to Subpart LLL.
Subpart JJJJ, Stationary Spark Ignition (SI) Internal Combustion Engines (ICE). This subpart
was proposed on June 12, 2006. For the purposes of this subpart, the date of construction is the
date the engine is ordered by the owner or operator. All owners or operators of SI ICE will be
required to keep records of all maintenance conducted on an engine per § 60.4245(a)(2).
As proposed, this subpart will affect engines, with a maximum engine power greater than 500hp, ordered after June 12, 2006 which are manufactured after July 1, 2007. The engines in this
permit are manufactured prior to July 1, 2007 and are not subject to this subpart.
NESHAP, 40 CFR Part 61
[Not Applicable]
There are no emissions of any of the regulated pollutants: arsenic, asbestos, beryllium, benzene,
coke oven emissions, mercury, radionuclides or vinyl chloride except for trace amounts of
PERMIT MEMORANDUM 2007-102-O
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benzene. Subpart J, Equipment Leaks of Benzene, only applies to process streams which contain
more than 10% benzene by weight. Analysis of Oklahoma natural gas indicates a maximum
benzene content of less than 1%.
NESHAP, 40 CFR Part 63
[Not Applicable]
Subpart HH, Oil and Natural Gas Production Facilities. This subpart applies to affected emission
points that are located at facilities which are major and area sources of HAPs and either process,
upgrade, or store hydrocarbons prior to the point of custody transfer or prior to which the natural
gas enters the natural gas transmission and storage source category. For purposes of this subpart
natural gas enters the natural gas transmission and storage source category after the natural gas
processing plant. If no natural gas plant is present, natural gas enters the natural gas transmission
and storage source category after the point of custody transfer.
The EPA promulgated the final rule for Subpart HH at area oil and gas production facilities,
effective January 3, 2007. The only affected source at an area source is triethylene glycol (TEG)
dehydration unit. Since the TEG dehydration unit was constructed/reconstructed before July 8,
2005, and the facility is not located within an Urban-1 County or in an Urban Area plus offset or
Urban Cluster, it is considered an existing source. As an existing source it is not subject to the
glycol optimization requirements of §§ 63.764(d)(2)(i) through (iii) until January 5, 2009. Even
though the existing TEG dehydration unit at this facility is considered an affected area source it
is exempt from the requirements of [§ 63.764(d)] since the actual average emissions of benzene
from the glycol dehydration unit process vents to the atmosphere are less than 1 TPY, as
determined by the procedures specified in § 63.772(b)(2). However, the facility must maintain
records of the de minimis determination as required in § 63.774(d)(1). All applicable
requirements have been incorporated into the permit.
Subpart HHH, affects Natural Gas Transmission and Storage Facilities. Since this facility is a
production facility, this subpart does not apply.
Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart was published
in the Federal Register on June 15, 2004 and affects existing, new, and reconstructed spark
ignition 4-stroke rich-burn (4SRB) RICE, new or reconstructed spark ignition 2-stroke lean-burn
(2SLB) RICE, new or reconstructed 4-stroke lean-burn (4SLB) RICE, and new or reconstructed
compression ignition (CI) RICE, with a site-rating greater than 500 brake horsepower, that are
located at a major source of HAP emissions. This facility is not a major source of HAPs.
Changes to this subpart which will affect area sources of HAP were proposed on June 12, 2006.
All owners or operators of RICE will be required to keep records documenting proper engine
maintenance per § 63.6655(f). As proposed, this subpart will affect new or reconstructed RICE,
located at area sources, with a maximum engine power greater than 500-hp, constructed or
reconstructed after June 12, 2006, and which are manufactured after July 1, 2007.
It is expected that replacement engines authorized in this permit will be manufactured prior to
July 1, 2007 and are not subject to this subpart. If however an engine is used that is
manufactured after July 1, 2007, this subpart will be applicable. The engine would need to
comply with the applicable emission standard in NESHAP Subpart ZZZZ Table 3 (NMHC - 1.0
g/hp-hr) and all applicable testing, monitoring, recordkeeping, and reporting requirements.
Chemical Accident Prevention Provisions, 40 CFR Part 68
[Not Applicable]
The definition of a stationary source does not apply to transportation, including storage incident
to transportation, of any regulated substance or any other extremely hazardous substance under
the provisions of this part. The definition of a stationary source also does not include naturally
PERMIT MEMORANDUM 2007-102-O
DRAFT
11
occurring hydrocarbon reservoirs. Naturally occurring hydrocarbon mixtures, prior to entry into
a natural gas processing plant or a petroleum refining process unit, including: condensate, crude
oil, field gas, and produced water, are exempt for the purpose of determining whether more than
a threshold quantity of a regulated substance is present at the stationary source. This facility
does not process or store more than the threshold quantity of any regulated substance (Section
112r of the Clean Air Act 1990 Amendments). More information on this federal program is
available on the web page: www.epa.gov/ceppo.
Stratospheric Ozone Protection, 40 CFR Part 82
[Subpart A and F Applicable]
These standards require phase out of Class I & II substances, reductions of emissions of Class I
& II substances to the lowest achievable level in all use sectors, and banning use of nonessential
products containing ozone-depleting substances (Subparts A & C); control servicing of motor
vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D); require warning labels on products made with or
containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon
disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons
(Subpart H).
Subpart A identifies ozone-depleting substances and divides them into two classes. Class I
controlled substances are divided into seven groups; the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform
(Class I, Group V). A complete phase-out of production of Class I substances is required by
January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are
hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs.
Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances,
scheduled in phases starting by 2002, is required by January 1, 2030.
This facility does not utilize any Class I & II substances.
SECTION VII. COMPLIANCE
Tier Classification and Public Review
This application has been determined to be a Tier II based on the fact that it is a request for a
significant modification of a major source, which is described in Voluntary Disclosure of
Noncompliance, submitted to AQD by Canaan on December 29, 2006. After modification, the
facility becomes a “synthetic minor” source. Information on all permit actions is available for
review by the public in the Air Quality Section of the DEQ web page: www.deq.state.ok.us.
The permittee has submitted an affidavit that they are not seeking a permit for land use or for any
operation upon land owned by others without their knowledge. The affidavit certifies that the
applicant owns the land, which will be used to accomplish the permitted purpose.
The applicant published the “Notice of Filing a Tier II Application” in The McAlester NewsCapital, a daily newspaper printed and published in the City of McAlester, Pittsburg County,
Oklahoma, on May 20, 2007. The notice stated that the permit application was available for
12
DRAFT
PERMIT MEMORANDUM 2007-102-O
public review at the McAlester Public Library, 401 N. Second Street, McAlester, Oklahoma
74501, or at the Air Quality Division’s Main Office in Oklahoma City, Oklahoma. A draft of
this permit will also be made available for public review for a period of 30 days as stated in
another newspaper announcement and will be available on the AQD Section of the DEQ Web
site. This facility is not located within 50 miles of the Oklahoma border. Information on all
permits is available for review by the public in the Air Quality Section of DEQ Web Page:
http://www.deq.state.ok.us.
Inspection
An initial compliance inspection was conducted on May 30, 2007. Present for the inspection
were Mr. Randall Richmond, Field Superintendent of Canaan, and Mark Chen of Air Quality
Division. The facility was constructed and is operating as described in the permit application.
The total natural gas throughput was at 5.48 MMSCFD around 1:40 PM when the facility was
inspected. The natural gas stream to the CenterPoint line was at 3.59 MMSCFD and the natural
gas stream to the Enogex line was at 1.89 MMSCFD. Identification plates with the make, model,
and serial number were attached to the engine. Periodic engine testing records and other
required records are maintained at the Wetumka District office.
Testing
The engine emission testing was conducted in March, May, and June 2007. All results are
presented below and show compliance with the applicable permit conditions.
ID
Source
C-1 1,232-hp Waukesha 7042 GSI with C.C.
C-2 550-hp Caterpillar G398 TA with C. C.
C-3 550-hp Caterpillar G398 TA with C. C.
C-4 515-hp Waukesha 3711 GU w/o C. C.
C-5 145-hp Caterpillar 3306 NA w/o C. C.
*CC = Catalytic Converter
Testing
Date
03/07/07
03/07/07
03/07/07
06/23/07
05/29/07
Permit Limitations
NOx
lb/hr
8.15
3.64
3.64
20.44
6.49
CO
lb/hr
8.15
3.64
3.64
31.79
0.48
Test Results
NOx
lb/hr
0.58
0.04
0.51
2.08
1.49
CO
lb/hr
0.20
0.14
0.63
3.39
0.36
Fees Paid
Title V Operating Permit fee of $2,000.
SECTION VIII. SUMMARY
The facility was constructed and is operating as described in the permit application. Ambient air
quality standards are not threatened at this site. This Tier II permit satisfies the requirements in
accordance with OAC 252:4-9-5 and in the Voluntary Disclosure of Noncompliance, dated
December 29, 2006. There are no other active Air Quality compliance or enforcement issues
concerning this facility. Issuance of the operating permit is recommended, contingent on EPA and
public review.
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
Canaan Resources, L.L.C.
Ulan Compressor Station
Permit No. 2007-102-O
The permittee is authorized to operate in conformity with the specifications submitted to Air
Quality on May 11, 2007, and supplemental information received on May 18, May 29, May 30,
June 1, and June 25, 2007. The Evaluation Memorandum dated June 29, 2007, explains the
derivation of applicable permit requirements and estimates of emissions; however, it does not
contain operating limitations or permit requirements. Continuing operations under this permit
constitutes acceptance of, and consent to, the conditions contained herein:
1. Points of emissions and emissions limitations for each point:
ID #
Source
lb/hr
NOx
TPY
lb/hr
CO
TPY
1,232-hp Waukesha 7042 GSI with
8.15
35.69
8.15 35.69
Catalytic Converter
C-2 550-hp Caterpillar G398 TA with
3.64
15.93
3.64 15.93
Catalytic Converter
C-3 550-hp Caterpillar G398 TA with
3.64
15.93
3.64 15.93
Catalytic Converter
515-hp Waukesha 3711 GU without
C-4*
20.44
10.22 31.79 15.90
Catalytic Converter
C-5* 145-hp Caterpillar 3306 NA without
6.49
3.24
0.48
0.24
Catalytic Converter
D-1 Dehydrator Still Vent
----** Standby units only operate when one of the primary units is not operating.
C-1
lb/hr
VOC
TPY
2.72
11.90
1.21
5.31
1.21
5.31
0.40
0.20
0.08
0.04
1.27
5.56
2. The fuel-burning equipment shall be fired with pipeline grade natural gas or other gaseous
fuel with a sulfur content less than 343 ppmv. Compliance can be shown by the following
methods: for pipeline grade natural gas, a current gas company bill; for other gaseous fuel, a
current lab analysis, stain-tube analysis, gas contract, tariff sheet, or other approved methods.
Compliance shall be demonstrated at least once annually.
3. The permittee shall be authorized to operate this facility continuously (24 hours per day, every
day of the year) except two standby compressor engines, C-4 and C-5.
4. Each engine at the facility shall have a permanent identification plate attached, which shows the
make, model number, and serial number.
5. At least once per calendar quarter, the permittee shall conduct tests of NOx and CO
emissions in exhaust gases from the engines in Specific Condition No.1 and each replacement
engine when operating under representative conditions for that period. Testing is required
for any engine or replacement engine, which runs for more than 220 hours during that
SPECIFIC CONDITIONS 2007-102-O
DRAFT
2
calendar quarter. Engines shall be tested no sooner than 20 days after the last test. Testing
shall be conducted using a portable engine analyzer in accordance with a protocol meeting
the requirements of the “AQD Portable Analyzer Guidance” document or an equivalent
method approved by Air Quality. When four consecutive quarterly tests show an engine to
be in compliance with the emissions limitations shown in the permit, then the testing
frequency may be reduced to semi-annual testing. A semi-annual test may be conducted no
sooner than 60 calendar days nor later than 180 calendar days after the most recent test.
Likewise, when the following two consecutive semi-annual tests show compliance, the
testing frequency may be reduced to annual testing. An annual test may be conducted no
sooner than 120 calendar days nor later than 365 calendar days after the most recent test.
Upon any showing of non-compliance with emissions limitations or testing that indicate that
emissions are within 10% of the emission limitation, the testing frequency shall revert to
quarterly. Reduced engine testing does not apply to engines with catalytic converters.
6. All three primary compressor engines, C-1, C-2, and C-3, shall each be set to operate with
exhaust gases passing through a properly functioning catalytic converter.
7. The permittee shall be authorized to operate each standby compressor engine, C-4 or C-5, up
to 1,000 hours per engine in any 12-month period.
8. Each standby compressor engine shall be fitted with a non-resettable hour meter. The
permittee shall record the number of hours each standby compressor engine operated each
month and the 12-month rolling total.
9. When periodic compliance testing shows engine exhaust emissions in excess of the lb/hr
limits in Specific Condition Number 1, the permittee shall comply with the provisions of
OAC 252:100-9. Requirements of OAC 252:100-9 include immediate notification and
written notification of Air Quality and demonstrations that the excess emissions meet the
criteria specified in OAC 252:100-9.
10. The permittee shall keep operation and maintenance (O&M) records for those emission units
which do not conduct quarterly testing. Such records shall at a minimum include the dates of
operation, and maintenance, type of work performed, and the increase, if any, in emissions as
a result.
11. Replacement (including temporary periods of up to six months for maintenance, etc.) of
internal combustion engines shown in this permit with engines of lesser or equal emissions of
each pollutant is authorized under the following conditions:
a. The permittee shall notify AQD in writing within 10 days of start-up of the replacement
engine(s)/turbine(s). Said notice shall identify the old engine/turbine and shall include
the new engine/turbine make and model, serial number, horsepower rating, fuel
usage, stack flow (ACFM), stack temperature (F), stack height (feet), stack diameter
(inches), and pollutant emission rates (g/hp-hr, lb/hr, and TPY) at maximum
horsepower for the altitude/location.
SPECIFIC CONDITIONS 2007-102-O
3
b. Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be conducted to
confirm continued compliance with NOx and CO emissions limitations. A copy of the
first quarter testing shall be provided to AQD within 60 days of start-up of each
replacement engine/turbine. The test report shall include the engine/turbine fuel usage,
stack flow (ACFM), stack temperature (oF), stack height (feet), stack diameter (inches),
and pollutant emission rates (g/hp-hr, lbs/hr, and TPY) at maximum rated horsepower
for the altitude/location.
c. Replacement equipment and emissions are limited to equipment and emissions which
are not subject to NSPS, NESHAP, or PSD.
12. Dehydrator still vent emissions are estimated based on existing equipment items with two
specific limitations, which shall be limited as follows:
a. Flow to the dehydrator shall not exceed 2.5 MMSCF per day (monthly average).
b. Glycol pump recirculation rate shall not exceed 0.5 gallon per minute for the dehydrator.
13. The permittee shall comply with all applicable requirements of the National Emission
Standards for Hazardous Air Pollutants (NESHAP) for Oil and Natural Gas Production,
Subpart HH, for each affected dehydration unit including but not limited to the following:
[40 CFR 63.760 through 63.775]
a. An owner or operator of a glycol dehydration unit that meets the exemption criteria in
§ 63.764(e)(1) shall maintain the records specified in § 63.774(d)(1), for that glycol
dehydration unit.
14. The permittee shall maintain records of operations as listed below. These records shall be
retained on-site or at a local field office for a period of at least five years following dates of
recording, and shall be made available to regulatory personnel upon request.
a. Periodic testing for NOx and CO exhaust from each engine and each replacement engine.
b. Operating hours for each engine if less than 220 hours per quarter and not tested.
c. For the fuel(s) burned, the appropriate document(s) as described in Specific Condition
No. 2.
d. O&M log for any engine/turbine not tested in each 3-month period.
e. Natural gas throughput for the dehydration unit (MMSCFD, Annual Average).
f. Records as required by 40 CFR Part 63, NESHAP, Subpart HH.
g. Hours of operation of each standby compressor engine, C-4 and C-5, (monthly, 12-month
rolling total).
15. This permit supersedes all previous Air Quality permits for this facility, which are now null
and void.
Mr. Mark Cain, V.P. Engineering
Canaan Resources, L.L.C.
One Leadership Square
211 North Robinson Avenue, Suite N1000
Oklahoma City, Oklahoma 73102.
SUBJECT:
Synthetic Minor Operating Permit Application No. 2007-102-O
Canaan Resources, L.L.C.
Ulan Compressor Station
Sections 8, Township 7N, Range 14E
Indianola, Pittsburg County, Oklahoma.
Dear Mr. Cain:
Air Quality Division has completed the initial review of your permit application referenced
above. This application has been determined to be a Tier II. In accordance with 27A O.S. §214-302 and OAC 252:002-31 the enclosed draft permit is now ready for public review. The
requirement for public review include the following steps which you must accomplish:
1. Publish at least one legal notice (one day) in at least one newspaper of general circulation
within the county where the facility is located. (Instruction enclosed)
2. Provide for public review (for a period of 30 days following the date of the newspaper
announcement) a copy of this draft permit and a copy of the application at a convenient
location (preferably a public location) within the county of the facility.
3. Send to AQD a copy of the proof of publication notice from Item #1 above together with any
additional comments or requested changes, which you may have on the draft permit.
Thank you for your cooperation. If you have any questions, please refer to the permit number
above and contact me at (405) 702-4100 or the permit writer at (405) 702-4196.
Sincerely,
Phillip Fielder, P.E.
Permits and Engineering Group Manager
AIR QUALITY DIVISION
Enclosure
PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 NORTH ROBINSON, SUITE 4100
P. O. BOX 1677
OKLAHOMA CITY, OKLAHOMA 73101-1677
Permit No.
2007-102-O
Canaan Resources, L.L.C.,
having complied with the requirements of the law, is hereby granted permission to
operate the Ulan Compressor Station located in Sections 8, Township 7N, Range 14E,
near Indianola, Pittsburg County, Oklahoma, subject to Standard Conditions dated
September 1, 2005, and Specific Conditions, both attached.
___________________________________
Director, Air Quality Division
Date
DEQ Form #100-885
Revised 10/20/2006
MINOR SOURCE PERMIT TO OPERATE / CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(September 1, 2005)
A. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act. The permit does not relieve the holder of the obligation to comply
with other applicable federal, state, or local statutes, regulations, rules, or ordinances. This
specifically includes compliance with the rules of the other Divisions of DEQ: Land Protection
Division and Water Quality Division.
B. A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252:100-7-15(g)) if the construction
is not commenced within 18 months after the date the permit or authorization was issued, or if
work is suspended for more than 18 months after it is commenced.
[OAC 252:100-7-15(f)]
C. The recipient of a construction permit shall apply for a permit to operate (or modified
operating permit) within 60 days following the first day of operation.
[OAC 252:100-7-18(a)]
D. Unless specified otherwise, the term of an operating permit shall be unlimited.
E. Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 10 days after such date.
A new permit is not required.
[OAC 252:100-7-2(f)]
F.
The following limitations apply to the facility unless covered in the Specific Conditions:
1. No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility.
[OAC 252:100-3]
2. All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory. Instructions and forms are available on the
Air Quality section of the DEQ web page. www.deq.state.ok.us
[OAC 252:100-5]
3. All excess emissions shall be reported to the Director of the Air Quality Division as soon as
practical during normal office hours and no later than the next working day following the
malfunction or release. Within ten (10) business days further notice shall be tendered in
writing containing specific details of the incident.
[OAC 252:100-9]
4. Open burning of refuse and other combustible material is prohibited except as authorized in
the specific examples and under the conditions listed in the Open Burning subchapter.
[OAC 252:100-13]
5. No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 0.6 lbs/MMBTU.
[OAC 252:100-19]
6. No discharge of greater than 20% opacity is allowed except for short-term occurrences which
consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed
three such periods in any consecutive 24 hours. In no case shall the average of any sixminute period exceed 60% opacity.
[OAC 252:100-25]
7. No visible fugitive dust emissions shall be discharged beyond the property line on which the
emissions originate in such a manner as to damage or to interfere with the use of adjacent
MINOR SOURCE STANDARD CONDITIONS
September 1, 2005
2
properties, or cause air quality standards to be exceeded, or interfere with the maintenance
of air quality standards.
[OAC 252:100-29]
8. No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2
lbs/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur
dioxide.
[OAC 252:100-31]
9. Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and with a
capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system.
[OAC 252:100-37-15(b)]
10. All fuel-burning equipment shall at all times be properly operated and maintained in a
manner that will minimize emissions of VOCs.
[OAC 252:100-37-36]
G. Any owner or operator subject to provisions of NSPS shall provide written notification as
follows:
[40 CFR 60.7 (a)]
1. A notification of the date construction (or reconstruction as defined under §60.15) of an
affected facility is commenced postmarked no later than 30 days after such date. This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form.
2. A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies, unless that change
is specifically exempted under an applicable subpart or in §60.14(e). This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change, present and proposed
emission control systems, productive capacity of the facility before and after the change, and
the expected completion date of the change. The Administrator may request additional
relevant information subsequent to this notice.
3. A notification of the actual date of initial start-up of an affected facility postmarked within 15
days after such date.
4. If a continuous emission monitoring system is included in the construction, a notification of
the date upon which the test demonstrating the system performance will commence, along
with a pretest plan, postmarked no less than 30 days prior to such a date.
H. Any owner or operator subject to provisions of NSPS shall maintain records of the
occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected
facility or any malfunction of the air pollution control equipment.
[40 CFR 60.7 (b)]
I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file
suitable for inspection. This file shall be retained for at least five years following the date of
such measurements, maintenance, and records.
[40 CFR 60.7 (d)]
J. Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s). Test(s) shall be conducted
within 60 days after achieving the maximum production rate at which the facility will be
operated, but not later than 180 days after initial start-up.
[40 CFR 60.8]