DRAFT
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM
June 17, 2005
TO:
Dawson Lasseter, P.E., Chief Engineer, Air Quality Division
THROUGH:
David Schutz, P.E., New Source Permits Section
Grover Campbell, P.E., Existing Source Permits Section
THROUGH:
Peer Review
FROM:
Ing Yang, P.E., New Source Permits Section
SUBJECT:
Evaluation of Permit Application No. 2001-150-TV
ONEOK Field Services Company
Smallwood Compressor Station (SIC 1311)
Sec. 22, T14N, R20W, Custer County
Driving Directions: Six miles west of Butler on Highway 33, then 3 miles
north on county road.
SECTION I. INTRODUCTION
The applicant has requested a Title V Operating Permit for the above referenced facility (SIC
1311). A Title V Operating Permit application was submitted to ODEQ on March 11, 2002. A
construction permit No. 2001-150-C(M-1) was issued in August 26, 2004 to address the
installation of one 1,340-hp Caterpillar G-3516 TALE compressor engine (C-5) and one oxidation
catalyst to one 1,265-hp Caterpillar G-3516 TALE compressor engine (C-4). The permit went
through a Tier II major source review. On March 18, 2005, the applicant submitted a letter to notify
the agency of the removal of one of the existing 1,265-hp Caterpillar G-3516 TALE engines, C-3,
from the site.
The facility emits more than 100 TPY of a regulated pollutant and is subject to Title V permitting
requirements. Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) in
the following outline. Field-grade natural gas is the primary fuel with the emission units
operating continuously.
SECTION II. EQUIPMENT
EUG 1. Compressor Engines
EU
Point
Make/Model
ID#
ID#
C-1.2
S-1.2
Waukesha L-7042 GSI w/C.C.
C-2
S-2
Caterpillar G-3516 TALE, Lean Burn
C-4
S-4
Caterpillar G-3516 TALE, Lean Burn w/O.C.
C-5
S-5
Caterpillar G-3516 TALE, Lean Burn
hp
1,232
1,265
1,265
1,340
Construction
Date
2003
2001
2001
2002
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PERMIT MEMORANDUM 2001-150-TV
2
EUG 2. Condensate Storage Tanks
EU ID#
Point ID#
Capacity (gallon)
TK-1
T-1
12,600
TK-2
T-2
12,600
TK-3
T-3
12,600
Material Stored
Condensate
Condensate
Condensate
EUG 3. Methanol Storage Tanks
EU ID#
Point ID#
TK-4
T-4
TK-5
T-5
TK-6
T-6
Material Stored
Methanol
Methanol
Methanol
Capacity (gallon)
8,820
504
504
EU ID#
Point ID#
Contents
EU-4
LOAD
Condensate/Slop Oil
Vapor Presure
(psia)
6.0
EUG 5. Fugitive VOC Emission Sources
EU ID#
Point ID#
Equipment
FUG
FUG
Valves
Flanges
Pressure Relief Valves
Open-ended Lines
Compressor Seals
Const. Date
02/03/93
Number
563
506
25
6
20
SECTION III. EMISSIONS
Estimates of emissions and emissions changes are based on the following factors and references:
EUG-1
Emissions estimates for all engines are based on continuous operation and the following
manufacturers’ emission data.
Engine Model
C-1.2, 1,232-hp Waukesha L-7042 GSI w/C.C.
C-2, 1,265-hp Caterpillar G-3516 TALE, Lean Burn
C-4, 1,265-hp Caterpillar G-3516 TALE, Lean Burn
w/O.C.
C-5, 1,340-hp Caterpillar G-3516 TALE, Lean Burn
NOx
g/hp-hr
2.0
3.0
3.0
CO
g/hp-hr
3.0
3.0
1.5
VOC
g/hp-hr
0.44
0.46
0.23
3.0
3.0
0.46
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PERMIT MEMORANDUM 2001-150-TV
3
EUG-2
Estimated emissions for the condensate tanks are calculated using Tanks 4.0. Flash emissions
are estimated using the BR&E PROMAX simulation program.
Calculated Emissions
Sources
C-1.2, 1,232-hp Waukesha L-7042 GSI w/C.C.
C-2, 1,265-hp Caterpillar G-3516 TALE, Lean
Burn
C-4, 1,265-hp Caterpillar G-3516 TALE, Lean
Burn w/O.C.
C-5, 1,340-hp Caterpillar G-3516 TALE, Lean
Burn
Tanks in Condensate Service*
Tanks in Methanol Service
Loading Losses
Fugitive
Total
NOx
CO
lb/hr
5.43
8.37
TPY
23.79
36.64
lb/hr
8.15
8.37
TPY
35.69
36.64
VOC
lb/hr
TPY
1.20
5.23
1.28
5.62
8.37
36.64
4.18
18.32
0.64
2.81
8.86
38.82
8.86
38.82
1.36
5.95
----31.03
----135.90
----29.56
----129.47
----4.48
86.00
0.29
2.63
3.85
117.99
*
Combined emissions from working, breathing losses and flash emissions
Brake-specific fuel consumption for the 1,232-hp Waukesha L-7042 GSI compressor engine with
a catalytic converter has been listed at 7,550 Btu/hp-hr for a fuel consumption of 9,302 SCFH
(based on 1,000 BTU/CF). Air emissions from the engine will be discharged through a 12-inch
diameter stack, 22 feet above grade, at a rate of 6,739 ACFM at 880F. Moisture content of
stack gases has been estimated at 12% from fuel usage and the stoichiometric ratio of two SCF of
water per SCF of natural gas fuel.
Brake-specific fuel consumption for each of the 1,265-hp Caterpillar G-3516 TALE compressor
engines has been listed at 7,552 Btu/hp-hr for a fuel consumption of 9,551 SCFH (based on
1,000 BTU/CF). Air emissions from each engine will be discharged through a 10-inch diameter
stack, 33 feet above grade, at a rate of 7,179 ACFM at 869F. Moisture content of stack gases
has been estimated at 11% from fuel usage and the stoichiometric ratio of two SCF of water per
SCF of natural gas fuel.
Brake-specific fuel consumption for the 1,340-hp Caterpillar G-3516 TALE compressor engine
has been listed at 7,546 Btu/hp-hr for a fuel consumption of 10,112 SCFH (based on 1,000
BTU/CF). Air emissions from the engine will be discharged through a 12-inch diameter stack,
33 feet above grade, at a rate of 7,685 ACFM at 855F. Moisture content of stack gases has been
estimated at 11% from fuel usage and the stoichiometric ratio of two SCF of water per SCF of
natural gas fuel.
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PERMIT MEMORANDUM 2001-150-TV
4
The internal combustion engines have emissions of toxic air contaminants, the most significant
being formaldehyde, a Category A air toxic with de minimis levels of 0.57 lbs/hr and 0.60 TPY,
and a MAAC of 12 µg/m3 (24-hr average). ONEOK estimated formaldehyde emissions using the
manufacturer data for the C-1.2 engine and using the stack test data for the other three engines
(C2, C4, and C5). Total formaldehyde emissions are above the de minimis levels. Air dispersion
modeling study is required.
Formaldehyde Emissions from IC Engines
EU
ID #
C-1.2
C-2
C-4
C-5
Total
Source
1,232-hp Waukesha L-7042 GSI w/C.C.
1,265-hp Caterpillar G-3516 TALE, Lean Burn
1,265-hp Caterpillar G-3516 TALE, Lean Burn
w/O.C. Caterpillar G-3516 TALE, Lean Burn
1,340-hp
Emission Factor
(g/hp-hr)
0.020
0.265
0.1325
0.265
Formaldehyde
lb/hr
0.05
0.74
0.37
0.78
1.95
TPY
0.238
3.237
1.618
3.429
8.52
A series of modeling analyses were performed for formaldehyde emissions from the compressor
engines (C-1.2, C-2, C-3, C-4, C-5) at the referenced site. The purpose of the air modeling was to
determine its impact on the air quality of the surrounding area and community, and to compare
the modeled impacts for formaldehyde with the Maximum Acceptable Concentration (MAAC)
limit per OAC 252:100-41.
AERMOD version 02222 (American Meteorological Society/Environmental Protection Agency
Regulatory Model Improvement Committee Dispersion Model) was performed to estimate
ground level concentration (GLC) of formaldehyde emitted from these compressor engines at the
site. The meteorological data used in modeling include five years (1986, 1987, 1988, 1990, and
1991) of surface data from Tulsa and upper air data from Oklahoma City and Norman. A total of
five model runs were performed for formaldehyde to the maximum ground-level concentration
for each of the five years of meteorological data discussed above. The maximum predicted
ambient concentration is shown to be below the MAAC of 12 g/m3 for formaldehyde and thus,
compliance with the formaldehyde MAAC is demonstrated.
Formaldehyde MAAC AERMOD Modeling Results
Meterological Year
Max. GLC (g/m3) 24-hr period
1986
10.44
1987
9.67
1988
11.49
1990
9.33
1991
10.49
Formaldehyde MAAC
12
Predicted Formaldehyde Concentration
11.49
Below MAAC
YES
* With the removal of C-3, the ambient concentration of formaldehyde for four engines is
expected to be lower than the predicted ambient concentration shown above for five engines.
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PERMIT MEMORANDUM 2001-150-TV
5
SECTION IV. INSIGNIFICANT ACTIVITIES
The insignificant activities identified and justified in the application are duplicated below.
Records are available to confirm the insignificance of the activities. Appropriate recordkeeping
of activities indicated below with “*” is specified in the Specific Conditions.
1. * Emissions from storage tanks constructed with a capacity less than 39,894 gallons which
store a VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. The lube
oil and waste oil tanks have capacities less than 39,894 gallons and store materials having a
vapor pressure less than 1.5 psia.
2. * Activities that have the potential to emit no more than 5 TPY (actual) of any criteria
pollutant. The methanol tank has the potential to emit less than 5 TPY of any criteria pollutant
and other activities may be used in the future.
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 July 1, 2002,
except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B, Subpart
C, Subpart Ca, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, and Appendix
G. These requirements are addressed in the “Federal Regulations” section.
OAC 252:100-5 (Registration, Emission 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. Emission inventories have been submitted and fees paid for the past years.
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PERMIT MEMORANDUM 2001-150-TV
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OAC 252:100-8 (Permits for Part 70 Sources)
[Applicable]
Part 5 includes the general administrative requirements for part 70 permits. Any planned
changes in the operation of the facility which result in emissions not authorized in the permit and
which exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior
notification to AQD and may require a permit modification. Insignificant activities mean
individual emission units that either are on the list in Appendix I (OAC 252:100) or whose actual
calendar year emissions do not exceed the following limits:
 5 TPY of any one criteria pollutant
 2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20%
of any threshold less than 10 TPY for single HAP that the EPA may establish by rule
 0.6 TPY of any one Category A toxic substance
 1.2 TPY of any one Category B toxic substance
 6.0 TPY of any one Category C toxic substance
Emission limitations for all the sources are taken from the operating permit application.
OAC 252:100-9 (Excess Emissions 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. Part
70/Title V sources must report any exceedance that poses an imminent and substantial danger to
public health, safety, or the environment as soon as is practicable. Under no circumstances shall
notification be more than 24 hours after the exceedance.
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, and 0.56 and 0.55
lb/MMBTU for equipment with a rated heat input of 13.6 and 14.5 MMBTUH, respectively. For
2-cycle lean-burn engines burning natural gas, AP-42 (7/00), Section 3.2 lists the total PM
emissions as approximately 0.01 lbs/MMBTU. AP-42 (7/98), Section 1.4 lists natural gas TPM
emissions to be 7.6 lbs/million SCF or about 0.0076 lbs/MMBTU which is in compliance with
this subchapter. The permit requires the use of natural gas for all fuel-burning equipment to
ensure compliance with Subchapter 19.
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 very little possibility of exceeding these standards.
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PERMIT MEMORANDUM 2001-150-TV
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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 originated 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 to interfere with the
maintenance of air quality standards. Under normal operating conditions, this facility has negligible
potential to violate this requirement; therefore it is not necessary to require specific precautions to
be taken.
OAC 252:100-31 (Sulfur Compounds)
[Applicable]
Part 3 lists a maximum ambient air concentration limit of 1,200 g/m3 (1-hour average) for
existing equipment. A typical engine burning field gas with a sulfur concentration of 159 ppm
will produce a maximum ambient concentration of less than 10 g/m3, which is in compliance.
Compliance with the other averaging period standards (5-minute, 3-hour, 24-hour, and annual) is
assured by the wide margin of compliance with the 1-hour standard.
OAC 252:100-33 (Nitrogen Oxides)
[Not Applicable]
This subchapter limits new gas-fired 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)
[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 to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system. This applies to the three
300-bbl condensate tanks and the three (one 8,820-gallon and two 500-gallon) methanol tanks.
Part 3 requires 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. Therefore, this requirement is not applicable.
Part 5 limits the VOC content of coatings used in coating lines and operations of parts and
products. This facility does not normally conduct coating or painting operations except for
routine maintenance of the facility and equipment which is exempt and considered a Trivial
Activity.
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.
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PERMIT MEMORANDUM 2001-150-TV
8
Part 7 also requires all reciprocating pumps and compressors handling VOCs to be equipped with
packing glands and rotating pumps and compressors handling VOCs to be equipped with
mechanical seals. All of the pumps and compressors at this facility are subject to these
requirements.
Part 7 also requires fuel-burning equipment to be operated and maintained so as to minimize
emissions. Temperature and available air must be sufficient to provide essentially complete
combustion.
OAC 252:100-41 (Hazardous Air Pollutants and Toxic Air Contaminants)
[Applicable]
Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted
by reference as they exist on July 1, 2003, 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, J, 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, GGGG, HHHH, JJJJ, NNNN, OOOO,
QQQQ, RRRR, SSSS, TTTT, UUUU, VVVV, WWWW, XXXX, BBBBB, CCCCC, FFFFF,
JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP, QQQQQ, and SSSSS are hereby adopted
by reference as they exist on July 1, 2003. These standards apply to both existing and new
sources of HAPs. These requirements are covered in the “Federal Regulations” section.
Part 5 is a state-only requirement governing toxic air contaminants. New sources (constructed
after March 9, 1987) emitting any category “A” pollutant above de minimis levels must perform
a BACT analysis, and at a minimum, install BACT. All sources are required to demonstrate that
emissions of any toxic air contaminant which exceeds the de minimis level do not cause or
contribute to a violation of the MAAC. BACT is acceptable as catalytic converter on the engine.
Emissions of formaldehyde at this site exceeded the de minimis levels. Using AERMOD version
02222, a total of five model runs were performed for formaldehyde to the maximum ground-level
concentration for five years of meteorological data. The maximum predicted ambient
concentration is shown to be below the MAAC of 12 g/m3 for formaldehyde and thus,
compliance with the formaldehyde MAAC is demonstrated.
MAAC Compliance For Formaldehyde
Pollutant
CAS
Toxic
Emission Rate
Modeled MAAC,
In
3
No.
Category
Impact,
Compliance
g/m
lb/hr
TPY
?
g/m3
Formaldehyde 50-00-0
A
2.68
11.76
11.49
12.5
yes
* With the removal of C-3, the ambient concentration of formaldehyde for four engines is
expected to be lower than the predicted ambient concentration shown above for five engines.
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PERMIT MEMORANDUM 2001-150-TV
9
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.
The following Oklahoma Air Pollution Control Rules are not applicable to this facility:
OAC 252:100-11
OAC 252:100-15
OAC 252:100-17
OAC 252:100-23
OAC 252:100-24
OAC 252:100-39
OAC 252:100-47
Alternative Emissions Reduction
Mobile Sources
Incinerators
Cotton Gins
Grain Elevators
Nonattainment Areas
Municipal Solid Waste Landfills
not requested
not in source category
not type of emission unit
not type of emission unit
not in source category
not in area category
not in area category
SECTION VI. FEDERAL REGULATIONS
PSD, 40 CFR Part 52
[Not Applicable]
Final total emissions are less than the 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]
Subpart Kb, VOL Storage Vessels. This subpart regulates hydrocarbon storage tanks larger than
19,812-gal capacity and built after July 23, 1984. The three condensate storage tanks are below
this threshold, thus they are exempt.
Subpart GG, Stationary Gas Turbines. The compressors on-site are powered by reciprocating
engines.
Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. The
facility does not engage in natural gas processing.
Subpart LLL, Onshore Natural Gas Processing: SO2 Emissions. There is no natural gas
sweetening operation at this site.
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PERMIT MEMORANDUM 2001-150-TV
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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
benzene. Subpart J (Equipment Leaks of Benzene), concerns only 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 B, Requirements for Control Technology Determinations for Major Source in
Accordance with CAA Sections 112(g) and 112(j). ONEOK tested two engines (C-4 & C-5) at
this facility on October 8, 2002 and estimated formaldehyde emissions to be 3.18 and 3.24 TPY,
respectively. With this modification, no single project is estimated to emit 10 tons or more of
formaldehyde. Therefore, this facility is not subject to a case-by-case MACT determination.
Subpart HH, Oil and Natural Gas Production Facilities. Subpart HH affects glycol dehydration
units, storage vessels with the potential for flash emissions, and compressors and ancillary
equipment in VHAP service which are located at gas plants. This facility does not have a glycol
dehydration unit. This facility is not a major source of HAPs, as defined in this subpart.
Subpart EEEE - Organic Liquids Distribution (Non-Gasoline). This subpart was proposed on
April 2, 2002, and would only affect organic liquid distribution (OLD) operations at major
sources of HAPs with an organic liquid throughput greater than 7.29 million gallons per year
(173,571 barrels/year). This facility is not a major source of HAPs. The facility’s potential
throughput is estimated at 1.0 million gallons per year (23,810 barrels/year) and is not expected
to be subject to this regulation.
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. On March 18, 2005, the applicant submitted a letter
to notify the agency of the removal of one of the Caterpillar clean-burn engines, C-3, from the
site. Thus, the site is now minor for HAP with regard to Subpart ZZZZ.
Compliance Assurance Monitoring, 40 CFR Part 64
[Applicable]
Compliance Assurance Monitoring, as published in the Federal Register on October 22, 1997,
applies to any pollutant specific emission unit at a major source, that is required to obtain a Title V
permit, if it meets all of the following criteria:
 It is subject to an emission limit or standard for an applicable regulated air pollutant;
 It uses a control device to achieve compliance with the applicable emission limit or
standard;
 It has potential emissions, prior to the control device, of the applicable regulated air
pollutant greater than major source levels.
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Engines C-2, C-4 and C-5 use clean burn technology to meet low NOx emission rates and do not
individually have potential emissions greater than 100 tpy of NOx or CO. Engine C-1.2 has the
PTE prior to controls greater than 100 TPY of NOx and CO. Therefore, the information required
by §64.4 is not required for C-2, C-4 and C-5 but will be required at renewal for C-1.2.
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
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
store any regulated substance above the applicable threshold limits. 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.
DRAFT
PERMIT MEMORANDUM 2001-150-TV
12
SECTION VII. COMPLIANCE
Inspection
An initial Title V inspection was conducted on April 25, 2005 by Ing Yang of Air Quality. Mr. Roy
Bradford, Maintenance Supervisor of ONEOK Field Services represented the facility during the
visit. The facility was operating as described in the permit application and supplemental materials.
Identification plates with the make, model, and serial number were attached to all engines. Records
of operating hours and periodic testing results of the engines were maintained and kept at the
facility.
Testing
Engine testing results conducted on January 19, 2005, were provided which show compliance
with the expected emissions.
Source
Expected Emissions
NOx
CO
lb/hr
lb/hr
5.43
8.15
8.37
8.37
8.37
8.37
4.18
8.37
Test Results
NOx
CO
lb/hr
lb/hr
0.10
2.06
6.88
5.29
3.60
4.62
4.51
0.19
C-1.2, 1,232-hp Waukesha L-7042 GSI w/C.C.
C-2, 1,265-hp Caterpillar G-3516 TALE, Lean Burn
C-3, 1,265-hp Caterpillar G-3516 TALE, Lean Burn*
C-4, 1,265-hp Caterpillar G-3516 TALE, Lean Burn
w/O.C.
C-5, 1,340-hp Caterpillar G-3516 TALE, Lean Burn
8.86
8.86
6.66
4.35
* On March 18, 2005, the applicant submitted a letter to notify the agency of the removal of one of the
existing 1,265-hp Caterpillar G-3516 TALE engines, C-3, from the site.
Tier Classification and Public Review
This application has been determined to be a Tier II based on the request for an operating permit
for a major source for which a Title V operating permit is required.
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 possesses a current lease or easement given by the landowner for the purpose or
purposes stated in the application.
The applicant published the “Notice of Filling a Tier II Application” in the Clinton Daily News, a
daily newspaper in Custer County, on March 14, 2002. The notice stated that the application was
available for public review at the Clinton Public Library, 721 Frisco Avenue, Clinton, 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. This facility is located within 50 miles of the
Oklahoma-Texas border. Texas has been notified of this draft permit. 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.
Fees Paid
Initial Title V operating permit fee of $2,000.
DRAFT
PERMIT MEMORANDUM 2001-150-TV
13
SECTION VIII. SUMMARY
The applicant has demonstrated compliance with all applicable Air Quality rules and regulations.
Ambient air quality standards are not threatened at this site. There are no active Air Quality
compliance or enforcement issues concerning this facility. Issuance of the permit is recommended,
contingent on public and EPA review.
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
ONEOK Field Services Company
Smallwood Compressor Station
Permit Number 2001-150-TV
The permittee is authorized to operate in conformity with the specifications submitted to Air
Quality on March 11, 2002, with additional information received on April 6, 2005. The Evaluation
Memorandum dated June 17, 2005, 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:
[OAC 252:100-8-6(a)(1)]
EUG 1. Compressor Engines
EU ID# Point ID#
Make/Model
C-1.2
S-1.2
Waukesha L-7042 GSI with C.C.
C-2
S-2
Caterpillar G-3516 TALE, Lean Burn
C-4
S-4
Caterpillar G-3516 TALE, Lean Burn w/O.C.
C-5
S-5
Caterpillar G-3516 TALE, Lean Burn
EU ID#
C-1.2
C-2
C-4
C-5
NOx
lb/hr
5.43
8.37
8.37
8.86
hp
1,232
1,265
1,265
1,340
CO
TPY
23.79
36.64
36.64
38.82
lb/hr
8.15
8.37
4.18
8.86
Serial #
WPI665
4EK03275
4EK03158
4EK03142
VOC
TPY
35.69
36.64
18.32
38.82
lb/hr
1.20
1.28
0.64
1.36
EUG 2. Condensate Storage Tanks
EU ID#
Point ID#
Capacity (gallon)
Material Stored
TK-1
T-1
12,600
Condensate
TK-2
T-2
12,600
Condensate
TK-3
T-3
12,600
Condensate
* VOC emissions from these storage tanks include working, breathing, and flashing losses.
TPY
5.23
5.62
2.81
5.95
VOC tpy
86.01
DRAFT
SPECIFIC CONDITIONS 2001-150-TV
2
EUG 3. Methanol Storage Tanks
The following emission units are “insignificant activities” since emissions are less than 5
TPY.
EU ID#
TK-4
TK-5
TK-6
Point ID#
T-4
T-5
T-6
Capacity (gallon)
8,820
504
504
Material Stored
Methanol
Methanol
Methanol
EUG 4. Condensate Truck Loading
The following emission units are “insignificant activities” since emissions are less than 5
TPY.
EU ID#
EU-4
Point ID#
Contents
LOAD
Condensate/Slop Oil
Vapor Pressure
(psia)
6.0
Throughput
(gallon)
1,000,000
Const. Date
02/03/93
EUG 5. Fugitive VOC Emission Sources
The following emission units are “insignificant activities” since emissions are less than 5
TPY.
EU ID#
FUG
Point ID#
FUG
Equipment
Valves
Flanges
Pressure Relief Valves
Open-ended Lines
Compressor Seals
Number
563
506
25
6
20
2. The fuel-burning equipment shall only use pipeline-grade natural gas or field gas with a
maximum sulfur content of 159 ppm.
[OAC 252:100-31]
3. The permittee shall be authorized to operate this facility continuously, 24 hours per day, every
day of the year.
[OAC 252:100-8-6(a)]
4. The 1,232-hp Waukesha L-7042 GSI engine (C-1.2) shall be set to operate with exhaust gases
passing through a functional catalytic converter.
[OAC 252:100-8-6(a)]
5. The 1,265-hp Caterpillar G-3516 TALE engine (C-4) shall be set to operate with exhaust gases
passing through a functional oxidation catalyst.
[OAC 252:100-41]
6. Each engine/turbine at the facility shall have a permanent identification plate attached, which
shows the make, model number, and serial number.
[OAC 252:100-43]
DRAFT
SPECIFIC CONDITIONS 2001-150-TV
3
7. When engine testing shows emission levels in excess of the lb/hr limits in Specific Condition
No. 1, the owner or operator shall comply with the provisions of OAC 252:100-9 for excess
emissions during start-up, shutdown, and malfunction of air pollution control equipment.
Requirements of OAC 252:100-9 include prompt notification to AQD and prompt
commencement of repairs to correct the condition of excess emissions.
[OAC 252:100-9]
8. At least once per calendar quarter, the permittee shall conduct tests of NOx and CO emissions
in exhaust gases from the turbine and from each replacement engine/turbine when operating
under representative conditions for that period. For the 1,265-hp Caterpillar G-3516 TALE
engine equipped with oxidation catalyst (C-4), compliance with CO emissions limitations in
Specific Condition 1 will demonstrate compliance with VOC and formaldehyde emissions
limitations listed in Specific Condition 1. Testing is required for any engine/turbine that runs
for more than 220 hours during that calendar quarter. Engines/turbines shall be tested no
sooner than 20 calendar days after the last test. Testing shall be conducted using the “AQD
Portable Analyzer Guidance” document or an equivalent method approved by Air Quality.
When four consecutive quarterly tests show the engine/turbine to be in compliance with the
emissions limitations shown in the permit, then the testing frequency may be reduced to
semi-annual testing. Likewise, when the following two consecutive semi-annual tests show
compliance, the testing frequency may be reduced to annual testing. Upon any showing of
non-compliance with emissions limitations or testing that indicates that emissions are within
10% of the emission limitations, the testing frequency shall revert to quarterly. Any
reduction in the testing frequency shall be noted in the next required compliance certification.
Reduced testing frequency does not apply to engines with catalytic converters.
[OAC 252:100-8-6 (a)(3)(A)]
9. Replacement (including temporary periods of 6 months or less for maintenance purposes), of
internal combustion engines/turbines with emissions limitations specified in this permit with
engines of lesser or equal emissions of each pollutant (in lbs/hr and TPY) are authorized under
the following conditions.
a.
The permittee shall notify AQD in writing not later than 7 days in advance of the startup
of the replacement engine(s)/turbine(s). Said notice shall identify the equipment
removed and shall include the new engine/turbine make, model, and horsepower; date
of the change, and any change in emissions.
b.
Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be conducted to
confirm continued compliance with NOX and CO concentration 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.
DRAFT
SPECIFIC CONDITIONS 2001-150-TV
c.
4
Replacement equipment and emissions are limited to equipment and emissions which
are not subject to NSPS, NESHAP, or PSD.
[OAC 252:100-8-6 (f)(2)]
10. Total condensate throughput shall not exceed 1,000,000 gallons per year.
11. The permittee shall maintain records of operations as listed below. These records shall be
maintained on-site or at a local field office for at least five years after the date of recording and
shall be provided to regulatory personnel upon request.
[OAC 252:100-43]
a.
b.
c.
d.
e.
Periodic testing for each engine/turbine and each engine replacement.
Operating hours for each engine/turbine if less than 220 hours/quarter and not tested.
O&M records for any engine not tested in each 6 month period.
Annual H2S concentrations testing results for fuel gas (including date of testing).
Throughput of condensate (monthly).
12. The following records shall be maintained on-site to verify Insignificant Activities. No
recordkeeping is required for those operations that qualify as Trivial Activities.
[OAC 252:100-8-6 (a)(3)(B)]
a. For fluid storage tanks with a capacity of less than 39,894 gallons and a true vapor
pressure less than 1.5 psia: records of capacity of the tanks and contents.
b. For activities that have the potential to emit less than 5 TPY (actual) of any criteria
pollutant: the type of activity and the amount of emissions from that activity (annual).
13. No later than 30 days after each anniversary date of the issuance of this permit, the permittee
shall submit to Air Quality Division of DEQ, with a copy to the US EPA, Region 6, a
certification of compliance with the terms and conditions of this permit. The following specific
information for the past year is required to be included:
[OAC 252:100-8-6 (c)(5)(A), (C) & (D)]
a. Testing results (quarterly or other applicable period) for any engine subject to emission
limitations.
b. Operating hours for each engine (quarterly and annual cumulative).
c. Summary of O&M and inspection reports for the engines not tested.
DRAFT
SPECIFIC CONDITIONS 2001-150-TV
5
14. The Permit Shield (Standard Conditions, Section VI) is extended to the following requirements
that have been determined to be inapplicable to this facility.
[OAC 252:100-8-6(d)(2)]
OAC 252:100-11
OAC 252:100-15
OAC 252:100-17
OAC 252:100-23
OAC 252:100-24
OAC 252:100-39
OAC 252:100-47
Alternative Emissions Reduction
Mobile Sources
Incinerators
Cotton Gins
Grain Elevators
Nonattainment Areas
Municipal Solid Waste Landfills
not requested
not in source category
not type of emission unit
not type of emission unit
not in source category
not in area category
Not in source category
15. This permit supercedes all previous Air Quality permits for this facility, which are now null
and void.