Arrow Station #7 Synthetic Minor NSR Permit Supporting Documents

444 Pages·2015·10.83 MB·English

Public Notice: Request For Comments

Proposed Air Quality Permit to Construct

Notice issued: March 20, 2014 What are the special conditions of this
permit?  US EPA Region 8 Office
Written comments due: The Permittee is required to limit the Air Program Office
5 p.m., April 20, 2014 NO , CO, VOC, and HAP emissions from 1595 Wynkoop Street
X
the engines using low emission engines or Denver, CO
Permit Writer: Kathy Paser a catalytic control system on each engine. Attn: Claudia Smith, 303-312-6520
VOC and HAP emissions from all tanks
Who is the applicant? storing crude oil and natural gas must be Electronic copies of the draft permit and
Arrow Pipeline, LLC controlled using hydrocarbon combustion Statement of Basis may also be viewed at:
Arrow Pipeline Station #7 with a 95% emission destruction http://www2.epa.gov/region8/air-permit-
efficiency. To minimize VOC and HAP public-comment-opportunities
Where will the facility be located? emissions from truck loading, the
In Dunn County at Permittee is required to use submerged What happens next?
Lat 47.672167, Long -102.401833 loading. EPA will review and consider all
comments received during the comment
What is being proposed? What are the effects on air quality? period. Following this review, the EPA
The EPA proposes to approve a new Based on the available data, discussed in may issue the permit addendum as
crude oil and natural gas gathering and the application, there do not appear to be proposed or modified, or deny the permit
transmission station on the Fort Berthold any significant air quality concerns within addendum.
Indian Reservation. The operation will the exterior boundaries of the Fort
consist of crude oil and natural gas Berthold Indian Reservation. What are the EPA’s responsibilities?
gathering from several customers in the Additionally, emissions from the The EPA Region 8 Air Program is the
region and transmission to a central proposed operation will be controlled at regulatory agency that helps protect and
delivery point located outside the exterior all times. These controlled emissions do preserve the Mandan, Hidatsa, and
boundaries of the Fort Berthold Indian not appear to have a significant impact to Arikara Nation’s air quality. One way
Reservation. The gathering and the the air quality of the surrounding area. EPA does this is by requiring permits for
transport will be conducted via pipeline certain activities. The purpose of this
using large engines, storage tanks and a Where can I send comments? notice is to invite you to submit written
truck load-out operation. EPA accepts comments by mail, fax and comments on this proposed permit.
e-mail.
Permit number:
Federal Minor New Source
SMNSR-TAT-000661-2013.001 US EPA
Review in Indian Country
Region 8 Air Program, 8P-AR

Plant Site Emissions: 1595 Wynkoop Street

The applicant has requested emission Denver, CO 80202

limitations that will limit the facility-wide [email protected]

emissions of volatile organic compounds Fax: [phone], Attn: Claudia Smith

(VOCs), nitrogen oxide (NO ), carbon
X

monoxide (CO), and hazardous air How can I review documents?

pollutants (HAPs). You can review the proposed permit and

administrative record at the:

Potential uncontrolled emissions from the
United States Environmental
proposed construction are estimated to be  Mandan, Hidatsa and Arikara Nation
Protection Agency
as follows: NO : 805 tons per year (tpy); Environmental Programs Office
X

CO: 545 tpy; VOCs: 408 tpy; 404 Frontage Road, New Town, ND
Region 8
HAPs: 45 tpy. Attn: Edmund Baker
Air Program

Considering the EPA proposed  Fort Berthold Community College
1595 Wynkoop Street
requirements in the permit, potential Library: 220 8th Avenue East
Denver, CO 80202
controlled emissions will be as follows: New Town, ND

NOX: 59 tpy; CO: 66; tpy;
Phone [phone]
VOCs: 52 tpy; HAPs: 9 tpy  Mandaree West Segment Tribal Office

440 th Ave NE, Mandaree, ND
http://www2.epa.gov/aboutepa/e
Attn: Cory Sanders
pa-region-8-mountains-and-

plains
Air Pollution Control .
40 CFR 49.151 Tribal Minor New Source Review In Indian Country ;p "()
Technical Support Document (TSD) t~~}
Proposed Permit No.: SMNSR-TAT-000661-2013.001
~-ry."l( PR01~c;<'
Arrow Pipeline, LLC
Arrow Pipeline Station #7
on the Fort Berthold Indian Reservation
Dunn County, North Dakota
In accordance with the requirements of the Tribal Minor New Source Review Permit Program at 40 CFR Part
49 (MNSR), the Region 8 office of the U.S. Environmental Protection Agency (EPA) has prepared this
technical support document (TSD) describing the conditions of this synthetic minor MNSR permit for a
proposed new crude oil and natural gas gathering and transmission station and presents information that is
germane to this permit action.
Table of Contents
I. Project Description ................................................................................................................................... 3
II. Uncontrolled Potential Emissions ............................................................................................................ 5
III. Potential Regulatory Requirements .......................................................................................................... 6
IV. Synthetic Minor Permitting ...................................................................................................................... 8
V. Control Technology Review .................................................................................................................. 10
VI. Proposed Permit Requirements .............................................................................................................. 11
VII. Air Quality Review ................................................................................................................................ 19
VIII. Tribal Consultations and Communications ............................................................................................ 21
IX. Environmental Justice ............................................................................................................................ 21
X. Public Notice and Comment, Hearing, and Appeals .............................................................................. 22
2
I. Project Description
On May 6, 2013, the EPA received an application from Arrow Pipeline, LLC (Arrow) requesting
approval to construct a new crude oil and natural gas gathering and transmission station on the Fort
Berthold Indian Reservation. The operation will consist of crude oil and natural gas gathering from
several customers in the region and transmission to a central delivery point (CDP) located outside the
exterior boundaries of the Fort Berthold Indian Reservation. Arrow plans to construct the facility at the
following location:
Quarter
County Township Range Section Latitude Longitude
Section
w w
Dunn 148 N 92 4 47.672167 N -102.401833
------------- ------.-------- ---------
The legal locations given are for the 2011 U.S. Geological Survey San ish SW quadrangle, North Dakota, 7.5-minute series.
The crude oil and natural gas gathering will be conducted via pipelines from production wells in the
area. Upon delivery to the station, the hydrocarbons will be separated into natural gas, crude oil and
produced water. The crude oil, natural gas condensate, and produced water will be transported off-site
via trucks. The natural gas will be compressed using engine driven compressors and transmitted via
pipeline to the central delivery point.
After first entering the station through a crude oil and natural gas system receiver, the crude oil and
natural gas will be put through a slug catcher to "knock out" excess liquids consisting of produced
water and crude oil and natural gas condensate. Further removal of the crude oil and natural gas
condensate will be carried out by a filter separator, after which the natural gas will be routed to the
individual compressor units for compression.
The compressor units will each consist of an inlet filter separator, a compressor, a fin fan heat
exchanger, and a natural gas-fired engine to power the compressor. Natural gas entering each individual
compressor unit will first be passed through the filter separator to further remove the crude oil and
natural gas condensate from the natural gas stream before compression, after which the natural gas will
be compressed by a compressor.
Compressed natural gas will then be routed to a splitter, with most of the natural gas routed to the
natural gas pipeline exiting the station and the remainder routed to a fuel gas coalescer. Natural gas from
the fuel gas coalescer will be routed to and combusted by individual compressor engines and/or natural
gas-fired electrical generator engines designed to provide power to the station.
The crude oil, natural gas condensate, and produced water removed from the natural gas via the slug
catcher and filter separator(s) will be pumped to individual storage tanks. Truck load out racks will be
used to truck the crude oil, natural gas condensate, and produced water from the proposed station.
The operation will not be processing natural gas or refining crude oil or natural gas condensate into end
products. In addition, no glycol dehydration units will be used in the operation.
Figure 1 illustrates the operations at the proposed station.
3
Natural Gas Gas System Filter J Compressor Unit ---?j Natural Gas
Pipeline ~ Receiver Separator '- ' Filter Separator Compressors I Pipeline
1
Natural Gas
/ ( ombustion
Water Condensate
Emissions
1 1
I
VOC& 400 bbl Produced 2-400 bbl Natural Gas VOC&
Thermal
HAP /" Water Storage Tank Condensate Storage ~ HAP Oxidizer
Emissions Tanks Emissions
Natural Gas
VOC&HAP l
Emissions
I
I I Fuel Gas Combustion
Coalescer emissions
7-i Truck Loadout I< I l If\
Compressor/Pump/Electric / Combustion ~ Catalytic
Generator Engines ~Emissions Converter
Figure 1 - Simplified Process Flow Diagram
4
When completed, the station will consist of the following primary emission units:
Two Crude Oil and Natural Gas Condensate Storage Tanks;
One Produced Water Storage Tank;
Two Truck Loading Racks;
Eight Natural Gas-Fired Reciprocating Internal Combustion Engines; and
Hydrocarbon Emission Controls.
II. Uncontrolled Potential Emissions
Pursuant to 40 CFR 52.21, "potential to emit" (PTE) is defined as the maximum capacity of a stationary
source to emit a pollutant under its physical and operational design. Any physical or operational
limitation on the capacity of the source to emit a pollutant, including air pollution control equipment and
restrictions on hours of operation or on the type or amount of material com busted, stored, or processed,
shall be treated as part of its design if the limitation, or the effect it would have on emissions, is federally
enforceable. Therefore, to calculate potential uncontrolled emissions in this proposal, the worst possible
case for emissions was considered, such as, 8,760 hours of operation per year, a maximum condensate
throughput of2201 barrels per day, and operating each engine at its maximum horse power.
Table 2 provides the uncontrolled PTE for the proposed operation.
Table 2-Uncontrolled Potential Emissions
Uncontrolled Potential
Criteria Pollutants Emissions PM-Particulate Matter
(tons per year) PM 10- Particulate Matter less than I 0 microns in size
PM 2.4 PM25- Particulate Matter less than 2.5 microns in size
SO,-Sulfur Oxides
PM 2.4
10 NOx-Nitrogen Oxides
PM2.s 2.4
CO-Carbon Monoxide
so. 16.3 VOC-Volatile Organic Compounds
NOx 804.5 Pb-Lead and lead compounds
co 544.9 H2S04- Sulfuric Acid Mist
voc 408.1 H2S-Hydrogen Sulfide
TRS -Total Reduced Sulfur
Pb 0
RSC-Reduced Sulfur Compounds
Fluorides 0
C0 Carbon dioxide
2-
H2S04 0 CH Methane
4-
H2S 0 N0-Nitrous oxide
2
TRS 0 HFCs-Hydrofluorocarbons
RSC 0 PFCs- Pertluorocarbons
SF Sulfur hexafluoride
Greenhouse Gases 6-
GHG The sum of C0 CH N0, HFCs, PFCs, SF on a
C02 (mass basis) 33,339 1otal- 2, 4, 2 6
mass basis
CH4 (mass basis) 22 C0 e-Equivalent C0 A measure used to compare the
2 2.
N20 (mass basis) 0 emissions from various greenhouse gases based upon their
HFCs (mass basis) 0 global warming potential (GWP)
PFCs (mass basis) 0
SF6 (mass basis) 0 HFCs, PFCs, and SF6 emissions are not created by oil and
natural gas production operations.
GHG (mass basis) 33,361
1otal
C0 e (Total) 33,822
2
1 In the application, all calculations were based on a maximum throughput of 110 barrels per day for water and condensate,
combined. However, the 110 bbls/day throughput resulted in controlled emissions that are only 40% of the facility-wide
VOC limit and 30% of the facility-widen-hexane and total HAP emission limits request by the company. The controlled
emission estimates support the approval of a higher maximum throughput while still maintaining the synthetic minor status.
The 220 bbl/day limit will provide a great deal more flexibility in operations and increased assurance of compliance with the
throughput limit.
5
Uncontrolled Potential
Hazardous Air Pollutants
Emissions PM-Particulate Matter
(HAPs) PM Particulate Matter less than I 0 microns in size
(tons per year) 10-
PM Particulate Matter less than 2.5 microns in size
I, I ,2,2-Tetrachloroethane 0.01 25-
SO,-Sulfur Oxides
I, I ,2-Trichloroethane 0.00
NOx-Nitrogen Oxides
I ,3-Butadiene 0.18 CO - Carbon Monoxide
I ,3-Dichloropropene 0.00 VOC-Volatile Organic Compounds
2-Methylnapthalene 0.00 Pb - Lead and lead compounds
2,2,4-Tirmethylpentane 0.01 H2S04- Sulfuric Acid Mist
HS-Hydrogen Sulfide
Acenaphthene 0.00 2
TRS-Total Reduced Sulfur
Acenaphthylene 0.00
RSC-Reduced Sulfur Compounds
Acetaldehyde 0.98 C0 Carbon dioxide
2-
Acrolein 0.84 CH Methane
4-
Benzene 0.41 N0-Nitrous oxide
2
Benzo(b )flouranthene 0.00 HFCs- Hydrotluorocarbons
PFCs-Pertluorocarbons
Benzo( e )pyrene 0.00
SF Sulfur hexafluoride
Benzo(g,h,i)perylene 0.00 6-
C0 e-Equivalent C0 A measure used to compare the
2 2•
Biphenyl 0.01
emissions from various greenhouse gases based upon their
Carbon Tetrachloride 0.01 global warming potential (GWP)
Chlorobenzene 0.00
Chloroform 0.00 HFCs, PFCs, and SF emissions are not created by oil and
6
Chrysene 0.00 natural gas production operations.
Ethyl benzene 0.01
Ethylene Dibromide 0.01
Flourathene 0.00
Flourene 0.00
Formaldehyde 6.95
Methanol 0.86
Methylene Chloride 0.01
N-Hexane 34.00
Napthalene 0.03
PAH 0.04
Phenanthrene 0.00
Phenol 0.00
Pyrene 0.00
Styrene 0.00
Tetrachloroethane 0.00
Toluene 0.15
Vinyl Chloride 0.00
Xylene 0.06
Total HAPs 44.57
III. Potential Regulatory Requirements
Based on the PTE, the proposed operation would be subject to the following regulatory requirements:
A. Prevention of Significant Deterioration (PSD) for criteria pollutants:
PSD applies on a pollutant specific basis to any proposed new source with a potential to emit for
any one pollutant regulated by PSD greater than or equal tolOO tons per year (tpy) or more for
sources included in 28 specified source categories as defined in 40 CFR 52, or 250 tpy or more
for any other type of source. For a new source which is major for at least one regulated
pollutant, all pollutants which are emitted in amounts greater than or equal to the significance
levels identified in the PSD regulations at §52.21(b)(23) are also subject to PSD review.
6
PSD applies on a pollutant specific basis to any proposed modification to an existing minor
source with a potential to emit for any one pollutant regulated by PSD that is greater than or
equal to 100 tpy or more for sources included in 28 specified source categories as defined in 40
CFR 52, or 250 tpy or more for any other type of source. For a modification which is major for
at least one regulated pollutant, all pollutants which are emitted in amounts greater than or equal
to the significance levels identified in the PSD regulations at §52.21 (b )(23) are also subject to
PSD review.
PSD also applies to a proposed modification to an existing major PSD source with a potential to
emit of any one pollutant regulated by PSD is greater than or equal to the significance levels
identified in the PSD regulations at §52.21 (b )(23).
Arrow's proposed new source has triggered PSD review for NOx, CO, and VOCs based on the
major source threshold of250 tpy. As such, any requested limits to avoid PSD must include
limits on NOx, CO, and VOCs.
B. Requirements for Hazardous Air Pollutants (HAPs):
New construction projects that have the potential to emit 25 tpy or more of total HAPs or 10 tpy
or more of any individual HAP are subject to major source requirements for HAPs, such as 40
CFR 63 - National Emissions Standards for Hazardous Air Pollutants for Source Categories
(also known as Maximum Achievable Control Technology (MACT)).
Arrow's proposed new source is major for total uncontrolled HAPs and n-hexane. The foremost
contributors to the total HAPs are formaldehyde from the engines, and n-hexane from the
handling of crude oil and natural gas condensate at the produced water and crude oil and natural
gas condensate tanks. ·
The Permittee requested voluntary emissions limits on each ofthe 37 individual HAPs and total
HAPs to reduce the PTE to below the major source thresholds.
C. Title V (Part 71) Operating Permit Requirements: NOx, CO, VOCs, n-hexane, and total HAPs
Part 71 permitting applies to any stationary which meets any one of the following emissions
levels:
1. 100 tpy or more of any criteria pollutant;
2. 100,000 tpy or more of C02e and 100 tpy or more of GHGs on a mass basis;
3. 10 tpy or more of any individual HAP; or
4. 25 tpy or more of all HAPs in aggregate.
For purposes of Part 71 permitting, the proposed facility is major for NOx, CO, VOCs, n-hexane,
and total HAPs. As such, any requested emission limits to become a synthetically minor source
for purposes of Part 71 permitting must include limits on these pollutants that are below the
major source thresholds for Part 71.
7
Note: Regardless of emission levels, Part 71 also applies to the following:
1. Any source, including an area source, subject to a standard, limitation, or other
requirement under section 111 of the Act;
2. Any source, including an area source, subject to a standard or other requirement under
section 112 of the Act, except that a source is not required to obtain a permit solely
because it is subject to regulations or requirements under section 112(r) of the Act;
3. Any source subject to the Acid Rain Program; and
4. Any source in a source category designated by the Administrator pursuant to this section.
5. Sources that are exempted until such time as the EPA completes a rulemaking to
determine how the program should be structured for non major sources and the
appropriateness of any permanent exemptions:
(a) Non major sources that have not received a major new source review permit;
(b) Non major sources that are not acid rain sources;
(c) Non major sources that are not solid waste incineration units required to obtain a
permit pursuant to section 129(e) of the Act; and
(d) In the case of non major sources subject to a standard or other requirement under
either section 111 or 112 of the Act after July 21, 1992 publication, the EPA will
determine whether to exempt any or all such applicable sources from the
requirement to obtain a Part 70 or Part 71 permit at the time that the new standard
is promulgated.
6. The following source categories are exempted from the obligation to obtain a Part 71
permit:
(a) All sources and source categories that would be required to obtain a permit solely
because they are subject to 40 CFR Part 60, Subpart AAA- -Standards of
Performance for New Residential Wood Heaters; and
(b) All sources and source categories that would be required to obtain a permit solely
because they are subject to 40 CFR Part 61, Subpart M- National Emission
Standard for Hazardous Air Pollutants for Asbestos, §61.145, Standard for
Demolition and Renovation.
IV. Synthetic Minor Permitting
In the MNSR regulations, PTE is defined as the maximum capacity of a source to emit a pollutant under
its physical and operational design. Any physical or operational limitation on the capacity of the source
to emit a pollutant, including air pollution control equipment and restrictions on hours of operation or on
the type or amount of material combusted, stored or processed, shall be treated as part of its design if the
limitation or the effect it would have on emissions is enforceable as a practical matter. Secondary
emissions, as defined at Section 52.21 (b )(18), do not count in determining the PTE of a source.
A. "Enforceable as a practical matter"
"Enforceable as a practical matter" means that an emission limitation or other standard is both
legally and practically enforceable as follows:
8
1. An emission limitation or other standard is legally enforceable if the reviewing authority
has the right to enforce it.
2. Practical enforceability for an emission limitation or for other standards (design
standards, equipment standards, work practices, operational standards, and pollution
prevention techniques) in a permit for a source is achieved if the permit's provisions
specify:
(a) A limitation or standard and the emissions units or activities at the source subject
to the limitation or standard;
(b) The time period for the limitation or standard (e.g., hourly, daily, monthly, and/or
annual limits such as rolling annual limits); and
(c) The method to determine compliance, including appropriate monitoring,
recordkeeping, reporting, and testing.
B. National EPA Guidance on PTE
National EPA guidance on PTE states that air pollution control equipment can be credited as
restricting PTE only if enforceable requirements are in place requiring the use of such air
pollution control equipment. EPA approved guidance for establishing PTE limits in a memo
titled Guidance on Limiting Potential to Emit in New Source Permitting, (NSR) dated June 13,
1989, to EPA Regional Offices, from Terrell F. Hunt, Associate Enforcement Counsel, Air
Enforcement Division, Office of Enforcement and Compliance Monitoring (OECA), and from
John Seitz, Director, Stationary Source Compliance Division, Office of Air Quality Planning and
Standards. The 1989 guidance (available.online at:
http://www.epa.gov/ttn/atw/pte/june 13 89.pdf) identifies the following as essential components
of a restriction on PTE:
1. An emission limitation, in terms of mass of emissions allowed per unit of time, and
2. A production or operational limitation (which can include requirements for the use of in
place air pollution control equipment).
The 1989 guidance explains that restrictions on PTE must be enforceable as a practical matter.
This means there must also be adequate monitoring, reporting, and recordkeeping requirements.
The 1989 memo also explains that an emission limitation alone, expressed as a long-term rolling
average (e.g., a rolling 12-month total) should not be relied upon as the basis for a PTE limit,
with the exception of sources that are VOC surface coating operations, and where no add-on
emission control equipment is employed at those sources, and where operating and production
parameters are not readily limited due to the wide variety of coating and products and due to the
unpredictable nature of the operation.
A subsequent memo to the EPA Regional Offices, dated January 25, 1995, from Kathie Stein,
Director, Air Enforcement Division, OECA, titled Guidance on Enforceability Requirements for
Limiting Potential to Emit through SIP and Section 112 Rules and General Permits, (available
online at: http://www.epa.gov/region07 /air/title5/t5memos/potoem) explains that the averaging
time of the emission limitation must readily allow for determination of compliance: "EPA policy
expresses a preference toward short term limits, generally daily but not to exceed 1 month."
Independently enforceable applicable requirements, such as New Source Performance Standards
(NSPS) and National Emissions Standards for Hazardous Air Pollutants (NESHAP) are
9