Review Report/Permit No.: 18-0072-TV-01
Application number: 022428
Page 1 of 13
OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY
OREGON TITLE V OPERATING PERMIT
REVIEW REPORT
Eastern Region
300 SE Reed Market Road
Bend, OR 97702
Source Information:
SIC
4922
NAICS
486210
No
No
No
12/31/09,
12/31/11
COMS
CEMS
Ambient monitoring
No
No
No
2/15
2/15
2/15 and 7/30
No
Monthly report (due dates)
Excess emissions report
Other reports
No
15 days
No
GG
No
No
No
No
No
No
No
No
Title V
ACDP (SIP)
Major HAP source
Federal major source
NSR
PSD
Acid Rain
Clean Air Mercury Rule (CAMR)
Yes
No
No
Yes
No
No
No
No
Compliance and Emissions Monitoring Requirements:
Unassigned emissions
Emission credits
Compliance schedule
Source test [date(s)]
Reporting Requirements
Annual report (due date)
Emission fee report (due date)
SACC (due date)
Quarterly report (due dates)
Air Programs
NSPS (list subparts)
NESHAP (list subparts)
CAM
Regional Haze (RH)
Synthetic Minor (SM)
Part 68 Risk Management
CFC
RACT
TACT
Review Report/Permit No.: 18-0072-TV-01
Application Number: 22428
Page 2 of 13
TABLE OF CONTENTS
LIST OF ABBREVIATIONS USED IN THIS REVIEW REPORT ............................................................................. 3
INTRODUCTION ......................................................................................................................................................... 4
PERMITTEE IDENTIFICATION ................................................................................................................................ 6
FACILITY DESCRIPTION .......................................................................................................................................... 6
EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION ................................................... 7
EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING ......................... 8
PLANT SITE EMISSION LIMITS ............................................................................................................................. 10
HAZARDOUS AIR POLLUTANTS .......................................................................................................................... 11
GENERAL BACKGROUND INFORMATION ......................................................................................................... 11
COMPLIANCE HISTORY ......................................................................................................................................... 11
SOURCE TEST RESULTS ......................................................................................................................................... 12
PUBLIC NOTICE ....................................................................................................................................................... 12
APPENDIX A: EMISSIONS DETAIL SHEETS ........................................................................................................ 13
Review Report/Permit No.: 18-0072-TV-01
Application Number: 22428
Page 3 of 13
LIST OF ABBREVIATIONS USED IN THIS REVIEW REPORT
AQMA
ASTM
CEMS
CFR
CMS
CO
DEQ
dscf
EF
EPA
EU
FCAA
gr/dscf
HAP
ID
I&M
MB
MM
Air Quality Management Area
American Society of Testing and
Materials
continuous emissions monitoring
system
Code of Federal Regulations
continuous monitoring system
carbon monoxide
Oregon Department of
Environmental Quality
dry standard cubic feet
emission factor
United State Environmental
Protection Agency
emissions unit
Federal Clean Air Act
grains per dry standard cubic feet
hazardous air pollutant
identification code
inspection and maintenance
material balance
million
NA
NESHAP
NOx
NSPS
NSR
O2
OAR
ORS
O&M
PCD
PM
PM10
PSD
PSEL
SO2
ST
VE
VOC
not applicable
National Emission Standard for
Hazardous Air Pollutants
oxides of nitrogen
New Source Performance Standard
New Source Review
oxygen
Oregon Administrative Rules
Oregon Revised Statutes
operation and maintenance
pollution control device
particulate matter
particulate matter less than 10
microns in size
Prevention of Significant
Deterioration
Plant Site Emission Limit
sulfur dioxide
source test
visible emissions
volatile organic compound
Review Report/Permit No.: 18-0072-TV-01
Application Number: 22428
Page 4 of 13
INTRODUCTION
1.
This is a renewal of the Oregon Title V Operating Permit issued to Gas Transmission Northwest
Corporation (GTN) on June 7, 2004 and scheduled to expire on January 1, 2009. A timely and complete
application was submitted to the Department on October 23, 2007, so the current permit will remain in
effect until the permit renewal is issued.
2.
In accordance with OAR 340-218-0120(1)(f), this review report is intended to provide the legal and factual
basis for the draft permit conditions. In most cases, the legal basis for a permit condition is included in the
permit by citing the applicable regulation. In addition, the factual basis for the requirement may be the
same as the legal basis. However, when the regulation is not specific and only provides general
requirements, this review report is used to provide a more thorough explanation of the factual basis for the
draft permit conditions.
3.
The following administrative amendments were issued during the previous permit term:
Date
04/27/2005
4.
Permit revision or notification
Administrative Amendment
Brief explanation
Incorporate emission factors from source testing
A history of turbine replacements is shown in the table below. The turbine replacements in 2004 (unit B)
and 2005 (Unit A) were not “like-for-like” replacements. The permit was modified, as discussed above, for
the Unit B replacement. The Unit A replacement is addressed in this permit action by revising the emission
limit in condition 12.
Unit
Unit A
Unit B
5.
Date
Manufacturer/Model
Existing Unit
Serial #
Replacement Unit
Serial #
Horsepower
6/24/05
Solar/Mars
0378m
0177M
14,100
3/18/99
Solar/Mars
0279m
0486m
13,000
10/24/04
Solar/Titan
003L
0115L
19,500
12/11/00
Solar/Titan
002L
003L
17,800
11/99
Solar/Titan
S02
002L
17,800
02/16/99
Rolls Royce/Spey
020
S02
14,300
02/10/99
Rolls Royce/Spey
021
020
14,200
08/25/98
Rolls Royce/Spey
020
S/D2
14,200
12/09/97
Rolls Royce/Spey
020
021
14,200
Provided below is a discussion of the permit changes on a condition-by-condition basis.
New Permit
Condition
Number
Old Permit
Condition
Number
Description of Change
1
1
No changes
2
2
Added state only enforceable
conditions.
3 - 10
3 - 10
No changes
Reason for Change
These should have been identified in
the previous permit.
Review Report/Permit No.: 18-0072-TV-01
Application Number: 22428
Page 5 of 13
New Permit
Condition
Number
Old Permit
Condition
Number
11
Description of Change
Reason for Change
---
Added a provision for complying with
the accidental release regulations in
the event that there are changes that
would trigger a risk management plan.
Title V program review and model
permit.
12
11
No changes
13 – 14
12-13
Updated emission limits based on
turbine heat rate.
15 - 17
14 - 16
No changes
18
17
Changed the procedure for revising
emissions factors from an
Administrative Amendment to a minor
modification.
19
18
No change
20
19
Reduced the unassigned emissions to
the significant emission rate.
21 - 23
20 - 22
No changes
24
23
Included dates for completing testing
and added alternative test methods for
NOx testing.
25 – 30
24 - 29
No changes
31
30
Added 40 CFR Part 60, subpart GG
provisions for monitoring fuel sulfur.
Revised rules
32
31
The PSEL monitoring condition is
revised to incorporate the emission
basis used for emission inventory
purposes. This is just a change in
presentation and not a substantive
change.
Title V program revisions
33
---
Added a condition identifying permit
emissions for purposes of the emission
fee rules.
As stated in the permit these are not
enforceable limits. This information
is used to identify permitted emissions
for individual emission
sources/processes in the event that
GTN chooses to pay fees on actual
emissions for a specific emission
source/process.
34 - 38
32 - 36
No changes
39
37
An excess emission report must be
submitted within 15 days of an excess
emissions event.
Revised rules – OAR 340-214-0340
40
38
The department must be notified of
permit deviations within 15 days
rather than 7 days.
Revised rules – OAR 340-2180050(3)(c)
NSPS requirement
Title V program revisions
OAR 340-222-0045
Adding the dates allows time for
reviewing the results before renewing
the permit.
Review Report/Permit No.: 18-0072-TV-01
Application Number: 22428
Page 6 of 13
New Permit
Condition
Number
Old Permit
Condition
Number
Description of Change
41 - 42
39 - 40
No changes
43
41
The number of reports has been
changed from 4 to 3.
Title V program review and revised
rules.
44
42
The semi-annual compliance
certification requirements have been
revised by requiring the permittee to
identify the compliance status as
continuous or intermittent for each
permit condition.
Title V program review and revised
rules.
45
42.e
Condition renumbered
Title V program review and revised
rules.
46
43
Narrowed the scope of the nonapplicable requirements section to
only those rules that could possibly
apply to the facility.
Title V program review and revisions.
G1 – G28
G1 – G28
Condition G12 is revised to reflect the
current emission fee rules.
OAR 340, Division 220.
Reason for Change
PERMITTEE IDENTIFICATION
6.
GTN is a natural gas transmission company operating a pipeline from the Canadian border through the
states of Idaho, Washington, and Oregon to California. GTN’s dual mainline is 612.5 miles in length and
includes 638.9 miles of 36-inch and 589.4 miles of 42-inch pipeline. Energy to move the gas is provided by
12 compressor stations located along the pipeline all of which are designed for remote, unattended
operation from GTN’s Gas Control Center in Portland.
FACILITY DESCRIPTION
7.
Compressor Station 14 is located in Klamath County, Oregon, on Harpold Valley Road, 3 miles south of
Bonanza. Compressor Station 14 contains two gas turbine-driven compressor units. Unit A is a Solar Mars
90S gas turbine, rated at 14,100 HP (ISO). Unit B is a Solar Titan 130S gas turbine rated at 19,500 HP
(ISO). Station 14 structures include a control building, a compressor building which houses Units A and B,
a lubricating oil storage building, a storage building, a motor control center building, a fuel gas building,
gas scrubbers, a scrubber-separator, instrument buildings, and valve shelters. The facility was originally
built in 1970.
8.
During normal operation, turbines will occasionally suffer a mechanical breakdown or a turbine will be
replaced for scheduled maintenance. In the event of a turbine breakdown or scheduled maintenance GTN
will replace the disabled turbine with a “like” turbine or a turbine of similar function. A like for like
replacement is defined as same manufacturer, same horsepower and same combustion system. The disabled
turbine will then be sent back to the manufacturer to be refurbished. After the turbine is refurbished it is
held as a replacement for other turbines in the system that may breakdown. This permit allows the
replacement of a turbine without modifying this permit or going through public notice if all applicable
permit limits are met including NSPS and PSD limits in accordance with OAR 340-218-0190(2)(b).
Review Report/Permit No.: 18-0072-TV-01
Application Number: 22428
Page 7 of 13
EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION
9.
The emissions units, devices, activities, and pollution control devices at the facility include the following:
Emission Unit Description
EU ID
Device Description
Device ID
Gas turbine-driven
compressor units
A
Solar Mars 90S - 14,100 hp
B
Solar Titan 130S - 19,500 hp
14-A
14-B
Aggregate Insignificant
AI
Aggregate Insignificant
AI
9.a.
9.b.
9.c.
10.
Pollution Control Devices
Description
PCD ID
None
None
Emissions Unit 14-A – The current unit is a low NOx Solar Mars 90S gas turbine rated at 14,100
hp (ISO).
Emissions Unit 14-B - This current unit is a low NOx Solar Titan 130S gas turbine rated at 19,500
hp (ISO).
Aggregate Insignificant - Emission sources which are insignificant in aggregate include;
auxiliary generator, fugitive particulate emissions from parking areas and driveways and fugitive
VOC emissions from seals, valves, flanges, and blowdowns.
Categorically insignificant activities include the following:
Constituents of a chemical mixture present at less than 1% by weight of any chemical or compound
regulated under Divisions 20 through 32 of OAR Chapter 340, or less than 0.1% by weight of any
carcinogen listed in the US Department of Health and Human Service's Annual Report on Carcinogens
when usage of the chemical mixture is less than 100,000 pounds/year
Evaporative and tail pipe emissions from on-site motor vehicle operation
Distillate oil, kerosene, and gasoline fuel burning equipment rated at less than or equal to 2.0 million
Btu/hr
Natural gas and propane burning equipment rated at less than or equal to 2.0 million Btu/hr each
Office activities
Janitorial activities
Personal care activities
Groundskeeping activities including, but not limited to building painting and road and parking lot
maintenance
Instrument calibration
Maintenance and repair shops
Automotive repair shops or storage garages
Air cooling or ventilating equipment not designed to remove air contaminants generated by or released
from associated equipment
Refrigeration systems with less than 50 pounds of charge of ozone depleting substances regulated under
Title VI, including pressure tanks used in refrigeration systems but excluding any combustion
equipment associated with such systems
Bench scale laboratory equipment and laboratory equipment used exclusively for chemical and physical
analysis, including associated vacuum producing devices but research and development facilities
Temporary construction activities
Warehouse activities
Arson fires
Air vents from air compressors
Air purification systems
Continuous emission monitoring vent lines
Demineralized water tanks
Pre-treatment of municipal water, including use of deionized water purification systems
Electrical charging stations
Fire brigade training
Review Report/Permit No.: 18-0072-TV-01
Application Number: 22428
Page 8 of 13
Instrument air dryers and distribution
Process raw water filtration systems
Routine maintenance, repair, and replacement such as anticipated activities most often associated with
and performed during regularly scheduled equipment outages to maintain a plant and its equipment in
good operating condition, including but not limited to steam cleaning, abrasive use, and woodworking
Electric motors
Storage tanks, reservoirs, transfer and lubricating equipment used for ASTM grade distillate or residual
fuels, lubricants, and hydraulic fluids
On-site storage tanks not subject to any New Source Performance Standards (NSPS), including
underground storage tanks (UST), storing gasoline or diesel used exclusively for fueling of the facilities
fleet of vehicles
Natural gas, propane, and liquefied petroleum gas (LPG) storage tanks and transfer equipment
Storm water settling basins
Pressurized tanks containing gaseous compounds
Fire suppression and training
Hazardous air pollutant emissions of fugitive dust from paved and unpaved roads except or those
sources that have processes or activities that contribute to the deposition and entrainment of hazardous
air pollutants from surface soils
Health, safety, and emergency response activities
Emergency generators and pumps used only during loss of primary equipment or utility service
Non-contact steam vents and leaks and safety and relief valves for boiler steam distribution systems
Non-contact steam condensate flash tanks
Non-contact steam vents on condensate receivers, deaerators and similar equipment
Oil/water separators in effluent treatment systems
Combustion source flame safety purging on startup
EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING
11.
There have not been any new applicable requirements promulgated for this source during the last permit
term, so the emission limits and standards are the same as those contained in the previous permit. A
summary of the emission limits and standards along with the testing, monitoring, and recordkeeping
requirements is provided below.
12.
Facility wide requirements: Since the turbines were installed after 1970 the applicable requirements are
OAR 340-208-0110(2) (20% opacity) and 340-226-0210(1)(b) (0.1 gr/dscf).
12.a.
12.b.
13.
Testing Requirements: Particulate emissions are expected to be negligible when the turbines are
operated on natural gas and therefore, no testing will be required.
Monitoring Requirements: Because particulate emissions are expected to be negligible when these
units combust natural gas the permittee is not required to conduct monitoring for opacity or grain
loading when the permittee burns only natural gas. The permittee shall maintain monthly and
annual records of natural gas usage.
Facility wide requirements: The following general standards for preventing nuisances apply:
13.a.
OAR 340-208-0210(2) is a requirement to take reasonable precautions to minimize fugitive
particulate emissions. OAR 340-208-0300 prohibits nuisances. OAR 340-208-00450 prohibits
the deposition of particulate matter larger than 250 microns in size upon another person’s property.
13.a.i. Testing Requirements: By definition, it is not possible to perform source emission tests
on fugitive emission sources. Therefore, the permit does not include any testing
requirements or compliance test methods.
13.a.ii. Monitoring requirements: Monitoring for this standard consists of maintaining a
complaint log and resolving complaints.
Review Report/Permit No.: 18-0072-TV-01
Application Number: 22428
Page 9 of 13
14.
Turbine Units A and B: Since these units were installed after October 3, 1977 and the heat input at peak
load is equal to or greater than 10.7 gigajoules per hour, the applicable requirements are under Subpart GG Standards of Performance for Stationary Gas Turbines - 40 CFR Part 60.333(b) (0.8 % Sulfur by weight in
fuel), 40 CFR Part 60.332(a)(2) (228 ppmv NOx at 15% O2 dry for Unit A and 213 ppmv NOx at 15% O2
dry for Unit B).
14.a.
Testing Requirements: These units have already undergone the initial performance test as required
by 40 CFR Part 60.8 of the NSPS. Two additional tests for NOx and CO will be required during
the permit term to verify emission factors. If a unit is replaced, an initial compliance test is
required to verify compliance with the NSPS NOx limit. Compliance tests must be conducted
using EPA Method 20 and they may be used as one of the emission factor verification tests. Tests
conducted solely for the purpose of verifying emission factors may be performed using EPA
Method 7e or CTM-034.
14.b.
Monitoring Requirements: The permittee had been required to monitor fuel sulfur content in
accordance with the May 8, 1996 custom fuel compliance monitoring schedule and the January 29,
1999 revision to the custom fuel compliance monitoring schedule approved by EPA Region X.
This monitoring was contingent upon the use of pipeline quality natural gas. However, in 2006, 40
CFR Part 60, subpart GG was revised as follows:
60.334(3) Notwithstanding the provisions of paragraph (h)(1) of this section, the owner
or operator may elect not to monitor the total sulfur content of the gaseous fuel
combusted in the turbine, if the gaseous fuel is demonstrated to meet the definition of
natural gas in 60.331(u), regardless of whether an existing custom schedule approved by
the administrator for subpart GG requires such monitoring. The owner or operator shall
use one of the following sources of information to make the required demonstration: (i)
The gas quality characteristics in a current, valid purchase contract, tariff sheet or
transportation contract for the gaseous fuel, specifying that the maximum total sulfur
content of the fuel is 20.0 grains/100 scf or less; or (ii) Representative fuel sampling data
which show that the sulfur content of the gaseous fuel does not exceed 20 grains/100 scf.
At a minimum, the amount of fuel sampling data specified in section 2.3.1.4 or 2.3.2.4 of
appendix D to part 75 of this chapter is required.
15.
Turbine Units A & B: Under alternative operating scenario 2, any of these units may be replaced with new
units of the same or different heat input rates as long as the emission levels are maintained below the PSEL,
other limits and the applicable requirements under Subpart GG - Standards of Performance for Stationary Gas
Turbines - 40 CFR Part 60.333(b) (0.8 % Sulfur by weight in fuel) and 40 CFR Part 60.332(a)(2) (STD
ppmv NOx at 15% O2 dry) are met.
15.a.
15.b.
Testing Requirements: An initial test as required by 40 CFR Part 60.8 on a replacement unit under
alternate operating scenario 2 must be conducted within 60 days after achieving the maximum
production rate at which the affected facility will be operated, but not later than 180 days after
initial startup of such facility. Subsequent tests shall be performed one time per calendar year
unless the results from the first source test or two subsequent source tests are less than 90% of the
NOx emission limit for each individual unit, in which case no further testing will be required on
that turbine during the permit term. In addition to the compliance tests, two tests for NOx and CO
will be required during the permit term to verify emission factors. Results from the initial
compliance tests may be used to meet the requirement for emission factor verification testing.
Emission factor verification tests may be conducted using a non-reference method such as CTM034.
Monitoring Requirements: See 14.b.
Review Report/Permit No.: 18-0072-TV-01
Application Number: 22428
Page 10 of 13
16.
Insignificant emissions units: As identified earlier in this Review Report, this facility has insignificant
emissions units (IEUs) that include categorically insignificant activities and aggregate insignificant
emissions, as defined in OAR 340-200-0020. For the most part, the standards that apply to IEUs are for
opacity (20% limit) and particulate matter (0.1 gr/dscf limit). The Department does not consider it likely
that IEUs could exceed an applicable emissions limit or standard because IEUs are generally equipment or
activities that do not have any emission controls (e.g., small natural gas fired space heaters) and do not
typically have visible emissions. Since there are no controls, no visible emissions, and the emissions are
less than one ton per year, the Department does not believe that monitoring, recordkeeping, or reporting is
necessary for assuring compliance with the standards. In addition, the insignificant emissions units at this
facility are not subject to any NESHAP standards.
PLANT SITE EMISSION LIMITS
17.
Provided below is a summary of the baseline emissions rate, netting basis, and plant site emission limits.
Pollutant
PM
PM10
SO2
NOx
CO
VOC
a. tons/year
17.a.
17.b.
18.
Baseline Emission
Ratea
2.7
2.7
3.1
359
329
6.2
Netting Basisa
Previous
Proposed
2.7
2.7
2.7
2.7
3.1
3.1
359
201
329
217
6.2
6.2
Plant Site Emission Limit (PSEL)a
Previous
Proposed
Increase
24
24
0
14
14
0
39
39
0
161
161
0
117
117
0
39
39
0
The baseline emission rate is the actual emissions during 1977.
The netting basis is equal to the baseline emission rate plus or minus any adjustments made
pursuant to Department rule. Because of a 265 ton increase in NO x emissions the permittee was
required to go through New Source Review in 1994. A NOx netting basis was established in the
New Source Review process. NOx emissions increased because of increased hours of operation
and the 1984 Unit B turbine replacement. An air quality analysis was conducted by the permittee
which demonstrated that, once the stack height was raised to 19.5 meters, the emission increases
would not cause air quality levels in excess of any Ambient Air Quality Standards (AAQS) or
Prevention of Significant Deterioration (PSD) increment, and will not have a significant impact
(including visibility impairment and vegetation impact) within any Class I area. Stack height was
raised to 19.5 meters in 1995. In 1999 when Unit B was replaced the stack was also replaced with
a stack of lower height. Since the new stack would not disperse the NOx as demonstrated in the
1994 modeling the netting basis was lowered so that it is now equal to the baseline emission rate of
359 tons.
Unassigned emissions were established in the last permit action. The unassigned emissions were not used,
so they are being reduced to the significant emission rate in accordance with OAR 340-222-0045(3)(a):
Unassigned Emissions (tons/yr)
Pollutant
PM/PM10
SO2
NOx
CO
VOC
Previous
0
0
198
212
0
Proposed
0
0
40
100
0
Review Report/Permit No.: 18-0072-TV-01
Application Number: 22428
Page 11 of 13
SIGNIFICANT EMISSION RATE
19.
The proposed Plant Site Emission Limits are equal to the previous Plant Site Emission Limits, thus there is
no increase above the significant emission rates and no further air quality analysis is required.
HAZARDOUS AIR POLLUTANTS
20.
A major source is a facility that has the potential to emit more than 10 tons/year of any single HAP or 25
tons/year of combined HAPs. This source is not a major source of hazardous air pollutants. Using AP-42
emission factors (table 3.1-3), the maximum potential estimated emissions are:
Hazardous Air Pollutant (HAP)
Annual HAP Emissions - tons
Acetaldehyde
Acrolein
Benzene
Ethylbenzene
Formaldehyde
Naphthalene
PAH
Toluene
Xylenes
Total
21.
0.0418
0.0067
0.0125
0.0334
0.7422
0.0014
0.0023
0.1359
0.0669
1.0739
The NESHAP/MACT standard for combustion turbines (40 CFR Part 63, Subpart YYYY) could apply to
this source. However, since this source is not a major source of HAPs Subpart YYYY does not apply.
GENERAL BACKGROUND INFORMATION
22.
No other permits are required for this facility by the Department.
23.
This source is located in an area that is in attainment for all pollutants.
COMPLIANCE HISTORY
24.
The facility was inspected on the following dates during the last permit term:
Inspection Date
8/15/06
September 2004
Results of Inspection
In Compliance
Department Actions
No Action Necessary
Review Report/Permit No.: 18-0072-TV-01
Application Number: 22428
Page 12 of 13
SOURCE TEST RESULTS
25.
The results of the most recent source tests are listed below:
Emission
Device
Unit A- Solar
Mars 90S
14,100 Hp,
serial number
0177M
Test Date
8/18/05
Production
Rate
100% load
75% load
50% load
25% load
Unit B-Solar
Titan
SoLoNOx
130S 19,500
Hp, serial
number 0115L
11/18/04
100% load
75% load
50% load
25% load
Pollutant
Measured Value
NOx
82.3 lbs/MMscf; 23 ppm @ 15% O2
CO
6.6 lbs/MMscf; 3 ppm
NOx
59.2 lbs/MMscf; 16 ppm @ 15% O2
CO
33.4 lbs/MMscf; 13 ppm
NOx
51.6 lbs/MMscf; 14 ppm @ 15% O2
CO
57.7 lbs/MMscf; 21 ppm
NOx
43.4 lbs/MMscf; 12 ppm @ 15% O2
CO
81.5 lbs/MMscf; 29 ppm
NOx
70.1 lbs/MMscf; 21 ppm @ 15% O2
CO
18.4 lbs/MMscf; 8 ppm
NOx
57.8 lbs/MMscf; 17 ppm @ 15% O2
CO
58.6 lbs/MMscf; 24 ppm
NOx
57.7 lbs/MMscf; 17 ppm @ 15% O2
CO
56.1 lbs/MMscf; 22 ppm
NOx
58.5 lbs/MMscf; 17 ppm @ 15% O2
CO
63.1 lbs/MMscf; 25 ppm
PUBLIC NOTICE
26.
The permit was placed on public notice from April 17, 2008 to May 21, 2008. No comments were received
in response to the Public Notice. A proposed permit was sent to EPA for a 45 day review period. The
Department requested and EPA agreed to an expedited review of 5 days as there were no substantive or
adverse comments during the comment period. The permit was issued following EPA’s review.
Since EPA did not object in writing, any person may petition the EPA within 60 days after the expiration of
the EPA's 45-day review period to make such objection. Any such petition must be based only on
objections to the permit that were raised with reasonable specificity during the public comment period
provided for in OAR 340-218-0210, unless the petitioner demonstrates that it was impracticable to raise
such objections within such period, or unless the grounds for such objection arose after such period.
Review Report/Permit No.: 18-0072-TV-01
Application Number: 22428
Page 13 of 13
APPENDIX A: EMISSIONS DETAIL SHEETS
Proposed PSEL Calculation
Emissions Unit
A
Emission Factor
(lbs/1,000,000 cf)
Reference
6.73
AP-42 Section 3.1
2.9
SO2
2.9
1.0 gr sulfur/100 scf
1.2
NOx
164.5
Manufacturer’s Data
70.5
CO
119
Pollutant
Natural Gas
(cubic feet/yr)
PM\PM10
859,600,000
VOC
B
PM\PM10
1,092,100,000
Emissions
(tons/yr)
51.1
2.14
AP-42 Section 3.1
0.9
6.73
AP-42 Section 3.1
3.7
SO2
2.9
1.0 gr sulfur/100 scf
1.6
NOx
164.5
Manufacturer’s Data
89.8
CO
119.2
VOC
65.1
2.14
AP-42 Section 3.1
1.2
Annual PSEL
Pollutant
PM/PM10
SO2
NOx
CO
VOC
Unit A
Unit B
Aggregate Insignificant
2.9
3.7
1.0
1.2
1.6
1.0
70.5
89.8
1.0
51.1
65.1
1.0
0.9
1.2
1.0
Total
7.6
3.8
161.3
117.2
3.1