dep west virginia department of environmental protection Earl Ray Tomblin, Governor Randy C. Huffman, Cabinet Secretary www.dep.wv.gov Division of Air Quality 60 I 57 th Street SE Charleston, WV 25304 Phone: 304-926-0475 • FAX: 304-926-0479 February 4,2016 Jackie D. Shultz West Virginia Air Quality Board 601 57th Street, SE Charleston, WV 25304 ENVtRONME~;AL QUALITY 60AHO AIR QUALITY BOAno Re: Certified File for Appeal Number 15-04-AQB Dear Ms. Shultz: In accordance with W.Va. Code §22B-I-7(e), and with 52CSR §1-3, I hereby certify that the attached documents constitute the complete record of the issuance by the West Virginia Division of Air Quality of General Permit G35-C, which is the subject of Appeal Number 15-04AQB. Please note that by the filing of this certified file, the Director does not make any admission or waive any right to file a motion to dismiss the instant appeal. Sincerely, William F. Durham Director Promoting a healthy environment. West Virginia Department of Environmental Protection Division ofAir Quality Randy C. Huffman Cabinet Secretary Earl Ray Tomblin Governor Class II General Permit G35-C for the Prevention and Control of Air Pollution in regard to the Construction, Modification, Relocation, Administrative Update and Operation of Natural Gas Compressor and/or Dehydration Facilities This permit is issued in accordance with the West Virginia Air Pollution Control Act (West Virginia Code §§ 22-5-1 et seq.) and 45CSR13 - Permits for Construction. Modification. Relocation and Operation ofStationary Sources ofAir Pollutants. Notification Requirements. Temporary Permits. General Permits and Proceduresfor Evaluation. -~~William F. Durham Director Issued: December 18, 2015 -1- 20f38 G35-C Natural Gas Compressor and/or Dehydration Facility Any person whose interest may be affected, including, but not necessarily limited to, the applicant and any person who participated in the public comment process, by a permit issued, modified or denied by the Secretary may appeal such action of the Secretary to the Air Quality Board pursuant to article one [§§22B-l-l et seq.], Chapter 22B of the Code of West Virginia. West Virginia Code §§22-5-14. The source is not subject to 45CSR30. General Permit G35-C authorizes the construction, modification, administrative update and/or operation of natural gas compressor and/or dehydration facilities. The applicability of General Permit G35-C may include any of the following: natural gas-fired spark ignition internal combustion engines, diesel-fired compression ignition internal combustion engines, storage vessels/tanks, glycol dehydration units and associated equipment, equipment leaks, truck loading/unloading operations, and pneumatic controllers. West Virginia Department of Environmental Protection· Division of Air Quality -2- 30f38 G35-C Natural Gas Compressor and/or Dehydration Facility Table of Contents 1.0. Emission Units ................................................................. ;............................................. 5 2.0. General Conditions ....................................................................................................... 5 1.1. 2.1. 2.2. 2.3. 2.4. 2.5. 2.6. 2.7. 2.8. 2.9. 2.10. 2. 11. 2. 12. 2. 13. 2.14. 2.15. 2.16. 2.17. 2.18. 2.19. 2.20. 2.21. 3.0. Purpose ................................................................................................................... 5 Authority ................................................................................................................ 5 Applicability ........................................................................................................... 6 Definitions ............................................................................................................... 7 Acronyms ............................................................................................................... 7 Permit Expiration and Renewal .............................................................................. 8 Administrative Update to General Permit Registration .......................................... 8 Modification to General Permit Registration.................................................. ,....... 8 Duty to Comply ...................................................................................................... 8 Inspection and Entry ................................................................................................ 8 Need to Halt or Reduce Activity not a Defense ...................................................... 9 Emergency .............................................................................................................. 9 Federally-Enforceable Requirements ..................................................................... 9 Duty to Provide Information ................................................................................... 9 Duty to Supplement and Correct Inforrnation ........................................................ l0 Credible Evidence .................................................................................................. 10 Severability ..................................................... ............................................. ........... 10 Property Rights ........................................................................................................ 10 Notification Requirements .................... ;................................................................. 10 Suspension of Activities ............................. ..................................................... ....... 10 Transferability ........................................................................................................ 10 Facility-Wide Requirements ........................................................................................ 11 3.1. 3.2. 3.3. 3.4. 3.5. 3.6. 4.0. General Permit Registration .................................................................................. 5 Siting Criteria ......................................................................................................... 11 Limitations and Standards ...................................................................................... 11 Monitoring Requirements ................................................................................ ....... 12 Testing Requirements ............................................................................................. 12 Recordkeeping Requirements·.......................................................................... ....... 13 Reporting Requirements ......................................................................................... 13 Source-Specific Requirements ..................................................................................... 15 4.1. 4.2. Limitations and Standards ...................................................................................... 15 Recordkeeping Requirements ................................................................................. 16 5.0. Source-Specific Requirements [Storage Vessels Containing Condensate and/or Produced WaterJ ........................................................................................................................ 17 5.1. 5.2. 5.3. 5.4. Limitations and Standards ...................................................................................... 17 Monitoring Requirements ........................................................................................ 18 Recordkeeping Requirements ................................................................................. 19 Notification and Reporting Requirements .............................................................. 19 6.0. Source-Specific Requirements [Standards of Performance for Storage Vessel Affected Facilities (NSPS, Subpart 0000)] ........................................................................... 20 6.1. Limitations and Standards ...................................................................................... 20 7.0. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH) ......................................... 20 7.1. 7.2. 7.3. 7.4. 7.5. Limitations and Standards ...................................................................................... 20 Monitoring Requirements ............................................................................. .......... 25 Testing Requirements .................. .. .............................................................. ........... 26 Recordkeeping Requirements ...................................................................... ........... 27 Reporting Requirements ................................................................................ .......... 28 West Virginia Department of Environmental Protection· Division of Air Quality -3- G35-C Natural Gas Compressor andlor Dehydration Facility 40f38 8.0. Source-Specific Requirements [Small Heaters and Reboilers not subject to 40CFR60 Subpart Dc] .................................................................................................................................. 29 8.1. 8.2. 8.3 8.4. Limitations and Standards ...................................................................................... 29 Monitoring Requirements .................. ..... .............. : ................................................. 29 Testing Requirements ............................................................................................. 29 Recordkeeping Requirements., ............. ...... ... ... ........... ........................... ... ... .......... 29 9.0. Source-Specific Requirements [Pneumatic Controllers Affected Facility (NSPS, Subpart 0000») ........................................................................................................................30 9.1. Limitations and Standards ........................ .. ............. ... ............. ........ .............. ......... 30 10.0. Source-Specific Requirements [Centrifugal Compressor Affected Facility (NSPS, Subpart 0000») ....................................................................................................................... 30 10.1. Limitations and Standards .......................... ........................... ......................... ........ 30· 11.0. Source-Specific Requirements [Reciprocating Compressor Affected Facility (NSPS, Subpart 0000)] ....................................................................................................................... 30 11.1. Limitations and Standards ...................................................................................... 30 12.0. Source-Specific Requirements [Reciprocating Internal Combustion Engine(s) (RICE), Generators, Microturbine Generators) ................................................................................... 31 12.1. 12.2. 12.3. 12.4. 12.5. 13.0. Source-Specific Requirements [Tanker Truck Loading) .......................................... 34 13.1. 13.2. 14.0 Limitations and Standards ... ................................................................................... 31 Monitoring Requirements ....................................................................................... 32 Recordkeeping Requirements ................ ,..... ....... ............. ...... .... ....... ...................... 32 Testing Requirements .............. .. ..................... .............. .................. ..... ........ ........... 32 Reporting Requirements ................................. ............... ......... ..................... ........... 33 Limitations and Standards .............................. ................... .......... .... ............. ........... 34 Recordkeeping Requirements .. ....................... ................. ........ ..... ...... .. ....... ........... 34 Source-Specific Requirements [Glycol Dehydration Units) ...................................... 35 14.1. 14.2. 14.3. 14.4. 14.5. Limitations and Standards ... .. ...... ............. .... .... ....... ... ....... ...................... .... ........... 35 Monitoring Requirements ................................................ ......... ...................... ........ 35 Testing Requirements ....;.......................... ......... .. ... ....... ....... .... ..... :.... ......... ........... 37 Recordkeeping Requirements ................................................................................. 37 Reporting Requirements ..... ......................................................... ... ..... .................... 37 CERTIFICATION OF DATA ACCURACY .......................................................................... 38 West Virginia Department of Environmental Protection· Division of Air Quality -4- 50f38 G35-C Natural Gas Compressor and/or Dehydration Facility 1.0. Emission Units 1.1. 2.0. 2.1. General Permit Registration 1.1.1. Only those emission units/sources as identified in the G35-C General Permit Registration, with the exception of any de minimis sources as identified under Table 45-13B of 45CSR13, are authorized at the registered facility. 1.1.2. In accordance with the information filed in the G35-C General Permit Registration Application, the equipment/processes identified in the Emissions Unit Table of the G35-C General Permit Registration shall be installed, maintained, and operated so as to minimize any fugitive escape of pollutants, shall not exceed the listed maximum design capacities, shall use the specified control devices, and shall not exceed the emission limits listed in the General Permit Registration. 1.1.3. Minor Source ofHazardous Air Pollutants (HAP). The facility shall not exceed 10 tons per year of any single hazardous air pollutant which has been listed pursuant to 112(b) of the Clean Air Act or 25 tons per year of any combination of hazardous air pollutants. Compliance with this section shall ensure that the facility is a minor source of HAPs. 1.1.4. Minor Source ofRegulated Pollutants. The.facility shall not exceed 100 tons per year of any regulated air pollutant. The fugitive emissions of a stationary source shall not be considered in determining whethedt is a major stationary source for the purposes of 45CSR30-2.26.b. Compliance with this Section shall ensure that the facility is a minor source of regulated air pollutants. 1.1.5. Minor Source Compliance. The registrant shall maintain records of annual HAP and all other regulated air pollutant emissions using AP-42 emission factors, GRI-GLYCalc model inputs and outputs, flashing simulation model inputs and outputs, manufacturer guaranteed values, sample and/or test data, calculation methods used in preparation of the registration application or other methods approved by DAQ demonstrating that facility-wide emissions are less than those specified in Sections 1.1.3 and 1.1.4. * General Conditions Purpose The purpose of this Class II General Permit is to authorize the construction, modification, administrative update, relocation, and operation of eligible natural gas compressor and/or dehydration facilities through a Class II General Permit Registration process. The requirements, provisions, standards and conditions of this Class II General Permit address the prevention and control of regulated pollutants from the operation of a natural gas compressor and/or dehydration facility. 2.2. Authority This permit is issued in accordance with West Virginia air pollution control law W.Va. Code seq. and the following Legislative Rules promulgated thereunder: 2.2. 1. ** 22-5-1. et 45CSR 13 - Permitsfor Construction, Mod!fication, Relocation and Operation of Stationwy Sources ofAir Pollutants, Notification Requirements, Administrative Updates, Temporwy Permits, General Permits, Permission to Commence Construction, and Procedures for Emlualion. West Virginia Department of Environmental Protection· Division of Air Quality -5- G35-C Natural Gas Compressor and/or Dehydration Facility 2.3. 60f38 Applicability 2.3.1. All natural gas compressor and/or dehydration facilities designed and operated for the purpose of compressing and/or dehydrating natural gas and included in the following NAICS and/or SIC codes are eligible for General Permit registration except for those instances listed in (a) through (h) below: NAICSCode 211111 213112 221210 486210 a. b. c. d. e. f. g. h. SIC Code 1311 1382, 1389 4923 4922 Description Crude Petroleum and Natural Gas Extraction Support Activities for Oil and Gas Operations Natural Gas Distribution Pipeline Transportation of Natural Gas Any natural gas compressor and/or dehydration facility which is a major source of pollutants as defined in 45CSR14, 45CSR19 or 45CSR30. Any natural gas compressor and/or dehydration facility that is located in Putnam County, Kanawha County, Cabell County, Wayne County, or Wood County and is required by 45CSR21 to conduct a Reasonably Available Control Technology (RACT) Analysis and/or subject to 45CSR21 Section 29 (Leaks from Natural Gas/Gasoline Processing Equipment). Any natural gas processing plant (e.g. production of ethane, propane, butane, and pentane) as defined in 40 CFR §60.5430. Any natural gas sweetening plant. Any natural gas compressor and/or dehydration facility with a storage tank subject to NSPS, SubpartKb. . Any steam generating unit (as defined in §60.41c) subject to NSPS, Subpart Dc (> 10 MMBTU/hr). Any turbine subject to NSPS, Subpart KKKK. Any natural gas compressor and/or dehydration facility which will require an individual air quality permit review process (45CSR13 construction/modification permit) to incorporate regulatory requirement(s) other than those established by General Permit G35-C. This would include "synthetic minor" permitting actions, as they are required to undergo Notice Level C under 45CSR13 Section 8.5. "Synthetic minor" permitting actions would include limitations on physical or operational capacity to remain below major stationary source thresholds (including 45CSR14, 45CSR19, 45CSR30 and 45CSR34). 2.3.2. For the purposes of General Permit G35-C,natural gas compressor station means reciprocating internal combustion engine driven compressor(s) or combination of equipment (including but not limited to compressor engines, emergency standby generators, engine driven air compressors, boilers, line heaters, tanks, glycol dehydration units, air pollution control devices, etc.) that supplies energy to move natural gas at increased pressure from gathering systems, in transmission pipelines or into storage. Engine means any compressor engine, emergency standby engine, auxiliary engine or air compressor engine located at a natural gas compressor station. 2.3.3. The West Virginia Division of Air Quality reserves the right to reopen this permit or any authorization issued under this pemlit if the area in which the facility is located is federally designated as non-attainment for specified pollutants. If subsequently any proposed construction. modification and/or operation does not demonstrate eligibility and/or compliance with the requirements, provisions, standards and conditions of this General Permit, tilis General Permit registration shall be denied and an individual permit for the proposed actiyity shall be required. West Virginia Departmen~ of Environmental Protection· Division of Air Quality -6- 70f38 G35-C Natural Gas Compressor and/or Dehydration Facility 2.4. 2.5. Definitions 2.4.1. All references to the "West Virginia Air Pollution Centrol Act" orthe"Air Pollution Control Act" mean those provisions contained in W.Va. Code ~~ 22-5. 2.4.2. The "Clean Air Act" means those provisions contained in 42 U.S.c. §§ 7401 to 7671q, and regulations promulgated thereunder. 2.4.3. "Secretary" means the Secretary of the Department of Environmental Protection or such other person to whom the Secretary has delegated authority or duties pursuant to W.Va. Code ~~ 22-1-6 or 22-1-8 (45CSR~30-2.12.). The Director of the Division of Air Quality is the Secretary's designated representative for the purposes of this permit. 2.4.4. The terms established in applicable definitions codified in the Code of Federal Regulations including 40 CFR Part 60 NSPS Subparts A, 1111, JJJJ, and 0000 or 40 CFR Part 63 MACT Subparts A, HH and ZZZZ shall also apply to those sections of General Permit G35-C where these subparts are incorporated or otherwise addressed. Acronyms BBL orbbl Barrel Clean Air Act Amendments CAAA Confidential Business CBI Information CEM Continuous Emission Monitor Certified Emission Statement CES Code of Federal Regulations C.F.R. Carbon Monoxide CO Code of State Rilles C.S.R. Division of Air Quality DAQ Department of Environmental DEP Protection Freedom of Information Act FOIA Hazardous Air Pollutant HAP Horsepower HP lb/hr Pounds per hour Leak Detection and Repair LDAR Morm Thousand Maximum Achievable MACT Control Technology Maximum Design Heat Input MDHI MMormm Million MMBTU/hr Million British Thermal Units Per Hour MMCflhr Million Cubic Feet per Hour Not Applicable N/A National Ambient Air Quality NAAQS Standards NESHAPS National Emissions Standards for Hazardous Air Pollutants Latitude LAT Longitude LON NO x NSCR NSPS PM PM2.5 PM IO ppm ppmv PSD psi RICE SCR SIC SIP S02 TAP TPY TSP USEPA UTM VEE VOC VRU Nitrogen Oxides Non Selective Catalytic Reduction New Source Performance Standards Particulate Matter Particulate Matter less than 2.5 ~m in diameter Particulate Matter less than 10 ~m In diameter Parts per million Parts per million by Volume Prevention of Significant Deterioration Pounds per square inch Reciprocating Internal Combustion Engine Selective Catalytic Reduction Standard Industrial Classification State Implementation Plan Sulfur Dioxide Toxic Air Pollutant Tons per year Total Suspended Particulate United States Environmental Protection Agency Universal Transverse Mercator Visual Emissions Evaluation Volatile Organic Compounds Vapor Recovery Unit West Virginia Department of Environmental Protection· Division of Air Quality -7- G35-C Natural Gas Compressor and/or Dehydration Facility 2.6. 80f38 Permit Expiration and Renewal 2.7. 2.6.1. This Class II General Permit shall remain valid, continuous and in effect unless it is revised, suspended, revoked or otherwise changed under an applicable provision of 45CSR13 or any other applicable legislative rule. 2.6.2. General Permit registrations granted by the Secretary shall remain valid, continuous and in effect unless suspended or revoked by the Secretary. If the Class II General Permit registration is subject to action or change, existing registrations will continue to be authorized and subject to the previously established permit conditions. [45CSR§13-10.2, 45CSR§13-10.31 Administrative Update to General Permit Registration 2.7.1. 2.8. The registrant may request an administrative update to their General Permit registration as defined in and according to the procedures specified in 45CSR§ 13-4. [45CSR§13-4.] Modification to General Permit Registration 2.8.1. 2.9. The registrant may request a minor permit modification to their General Permit registration as defmed in and according to the procedures specified in 45CSR§13-5. [45CSR§13-5.] Duty to Comply 2.9.1. The registered facility shall be constructed and operated in accordance with the information filed in the General Permit Registration Application and any amendments thereto. The Secretary may suspend or revoke a General Permit Registration if the plans and specifications upon which the approval was based are not adhered to. 2.9.2. The registrant must comply with all applicable conditions of this Class II General Permit. Any General Permit noncompliance constitutes a violation of the West Virginia Code,and/or the Clean Air Act, and is grounds for enforcement action by the Secretary or USEP A. 2.9.3. Violation of any of the applicable requirements, provisions, standards or conditions contained in this Class II General'Permit, or incorporated herein by reference. may subject the registrant to civil and/or criminal penalties for each violation and further action or remedies as provided by West Virginia Code 22-5-6 and 22-5-7. 2.9.4. Registration under this Class II General Permit does not relieve the registrant herein of the responsibility to apply for and obtain all other permits, licenses, and/or approvals from other agencies; i.e. local, state and federal. which may have jurisdiction over the construction and/or operation of the source(s) and/or facility herein permitted. 2.10. Inspection and Entry 2. 10.1. The registrant shall allow any authorized representative of the Secretary. upon the presentation of credentials and other documents as may be required by law, to perform the following: a. At all reasonable times enter upon the registrant's premises where a source is located or emissions related activity is conducted, or where records must be kept under the conditions of this permit; West Virginia Department of Environmental Protection· Division of Air Quality -8- G35-C Natural Gas Compressor and'or Dehydration Facility 2.11. 90f38 b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this Class II .General Permit; c. Inspect at reasonable times (including all times in which the facility is in operation) any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this Class II General Permit; d. Sample or monitor at reasonable times, substances or parameters to determine compliance with the permit or applicable requirements or ascertain the amounts and types of air pollutants discharged. Need to Halt or Reduce Activity not a Defense 2. 11.1. It shall not be a defense for a registrant in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this Class II General Permit. Howe\'er, nothing in this paragraph shall be construed as precluding consideration of a need to halt or reduce activity as a mitigating factor in determining penalties for noncompliance if the health, safety, or environmental impacts of halting or reducing operations would be more serious than the impacts of continued operations. 2.12. Emergency 2.12.1. An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technologybased emission limitation under this Class II General Permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. 2.12.2. In any enforcement proceeding, the registrant seeking to establish the occurrence of an emergency has the burden of proof. 2. 12.3. This provision is in addition to any emergency or upset provision contained in any applicable requirement. 2.13. Federally-Enforceable Requirements 2.13 .1. All terms and conditions in this permit are enforceable by the Secretary, USEP A. and citizens under the Clean Air Act. 2.13.2. Those provisions specitically designated in the permit as "State-enforceable only" shall become "Federally-Enforceable" requirements upon SIP approval by the USEPA. 2.14. Duty to Provide Information 2.14. 1. The registrant shall furnish to the Secretary within a reasonable time any information the Secretary may request in writing to determine whether cause exists for modifying, revoking and reissuing. or terminating this Class II General Permit Registration or to determine compliance with this General Permit. Upon request, the registrant shall also furnish to the Secretary copies of records required West Virginia Depm1ment of Environmental Protection ' Division of Air Quality -9- G35-C Natural Gas Compressor and/or Dehydration Facility 10 of38 to be kept by the registrant. For information claimed to be confidential, the registrant shall furnish such records to the Secretary along with a claim of confidentiality in accordance with 45CSR31. If confidential information is to be sent to USEPA, the registrant shall directly provide such information to USEPA along with a claim of confidentiality in accordance with 40 C.F.R. Part 2. 2.15. Duty to Supplement and Correct Information 2. 15.1. Upon becoming aware of a failure to submit any relevant facts or a submittal of incorrect information in any registration application, the registrant shall promptly submit to the Secretary such supplemental facts or corrected information. 2.16. Credible Evidence 2. 16.1. Nothing in this Class II General Permit shall alter or affect the ability of any person to establish compliance with, or a yiolation of, any applicable requirement through the use of credible evidence to the extent authorized by law. Nothing in this permit shall be construed to waive any defenses otherwise available to the registrant including but not limited to any challenge to the credible evidence rule in the context of any future proceeding. 2.17. Severability 2. 17.1. The provisions of this Class II General Permit are severable. If any provision of this Class II General Permit, or the application of any provision of this Class II General Permit to any circumstance is held invalid by a court of competent jurisdiction, the remaining Class II General Permit terms and conditions or their application to other circumstances shall remain in full force and effect. 2.1S. Property Rights 2.18.1. Registration under this Class II General Permit does not convey any property rights of any sort or any exclusive privilege. 2.19. Notification Requirements 2.19.1. The registrant shall notify the Secretary, in writing, no later than thirty (30) calendar days after the actual startup of the operations authorized under this permit. 2.20. Suspension of Activities 2.20.1. In the event the registrant should deem it necessary to suspend, for a period in excess of one (1) year, all operations authorized by this permit, the registrant shall notify the Secretary, in writing, within two (2) calendar weeks of the passing of the one (l) year of the suspension period. 2.21. Transferability 2.2 1.1. This permit is transferable in accordance with the requirements outlined in Section 10.1 of 45CSRI3. [45CSR§13-10.1.] West Virginia Department of Environmental Protection· Division of Air Quality -10- G35-C Natural Gas Compressor and/or Dehydration Facility 3.0. 11 of 38 Facility-Wide Requirements 3.1. Siting Criteria 3. 1.1. 3.2. All persons submitting a Class II General Permit Registration Application to construct, modify or relocate a natural gas compressor and/or dehydration facility shall be subject to the following siting criteria: a. No emission unit shall be constructed, located or relocated within 300 feet of any occupied dwelling, business, public building, school, church, community building, institutional building or public park. An owner of an occupied dwelling or business may elect to waive the 300 foot siting criteria. b. Any person proposing to construct, modify or relocate any emission unites) within 300 feet of any occupied dwelling, business, public building, school, church, community, institutional building or public park may elect to obtain an individual permit pursuant to 45CSR13. Limitations and Standards 3.2.1. Open burning. The open burning of refuse by any person is prohibited except as noted in 45CSR*6-3.1. [45CSR§6-3.1.] 3.2.2. Open burning exemptions. The exemptions listed in 45CSR*6-3.l are subject to the following stipulation: Upon notification by the Secretary, no person shall cause or allow any form of open burning during existing or predicted periods of atmospheric stagnation. Notification shall be made by such means as the Secretary may deem necessary and feasible. [45CSR§6-3.2.J 3.2.3. Asbestos. The registrant is responsible for thoroughly inspecting the facility, or part of the facility, prior to commencement of demolition or renovation for the presence of asbestos and complying with 40 C.F.R. * 61.145,40 C.F.R. * 61.148, and 40 C.F.R. 61.150. The registrant, owner, or operator must notify the Secretary at least ten (10) working days prior to the commencement of any asbestos removal on the forms prescribed by the Secretary if the registrant is subject to the notification requirements of 40 C.F.R. § 61.145(b)(3)(i). US EPA, the Division of Water and Waste Management (DWWM), and the Department of Health and Human Resources (DHHR) - Office of Environmental Health Services (OEHS) require a copy of this notice to be sent to them. [40CFR§61.145(b) and 45CSR§34] * 3.2.4. Odor. No person shall cause, suffer, allow or permit the discharge of air pollutants which cause or contribute to an objectionable odor at any location occupied by the public. [45CSR§4-3.1] [State Enforcellble Only/ 3.2.5. Permanent shutdown. A source which has not operated at least 500 hours in one, twelve (12) month period within the previous five (5) year time period may be considered permanently shutdown, unless such source can provide to the Secretary, with reasonable specificity, information to the contrary. All permits may be modified or revoked and/or reapplication or application for new permits may be required for any source determined to be permanently shutdown. This requirement does not apply to emergency generator(s) permitted to operate on~y 500 hours per year. [45CSR§13-10.5.] West Virginia Department of Environmental Protection· Division of Air Quality -11- G35-C Natural Gas Compressor and/or Dehydration Facility 3.3. 12of38 3.2 .6. Standby plan for reducing emissions. When requested by the Secretary, the registrant shall prepare standby plans for reducing the emissions of air pollutants in accordance with the objectives set forth in Tables I, II, and III of 45CSRII. [4SCSR§ 11-S.2.] 3.2.7. Minimization of Fugitive Emissions. The registrant shall operate consistent with infonnation provided in registrant's G35-C General Pennit Registration Application for fugitive emission sources. [4SCSR§ 13-5. 11. J 3.2.8. The registrant shall not create a nuisance to the surrounding community by way of unreasonable noise and light during operation. Monitoring Requir.e ments . See Section 4.2. 3.4. Testing Requirements 304. 1. Stack testing. As per provisions set forth in this permit or as otherwise required by the Secretary, in accordance with the West Virginia Code, underlying regulations, permits and orders, the registrant shall conduct testes) to determine compliance with the emission limitations set forth in this Class II General Pennit and/or established or set forth in underlying documents. The Secretary, or their duly authorized representative, may at hislher option witness or conduct such testes). Should the Secretary exercise hislher option to conduct such testes), the operator shall provide all necessary sampling connections and sampling ports to be located in such manner as the Secretary may require, power for test equipment and the required safety equipment, such as scaffolding, railings and ladders, to comply with generally accepted good safety practices. Such tests shall be conducted in accordance with the methods and procedures set forth in this pennit or as otherwise approved or specified by the Secretary in accordance with the following: a. The Secretary may on a source-specific basis approve or specify additional testing or alternative testing to the test methods specified in the permit for demonstrating compliance with 40 C.F.R. Parts 60, 61, and 63 in accordance with the Secretary's delegated authority and any established equivalency determination methods which are applicable. If a testing method is specified or approved which effectively replaces a test method specified in the Class II General Permit, the permit may be revised in accordance with 45CSR§ 13-4. or 45CSR§ 13-504 as applicable. b. The Secretary may on a source-specific basis require, approve or specify additional testing or alternative testing to the test methods specified in the Class II General Permit for demonstrating compliance with applicable requirements which do not involve federal delegation. In specifying or approving such alternative testing to the test methods, the Secretary, to the extent possible, shall utilize the same equivalency criteria as would be used in approving such changes under Section 3.4.l.a. of this general pemlit. Iia testing method is specified or approved which effectively replaces a test method specified in the permit, the permit may be revised in accordance with 45CSR§ 13-4. or 45CSR§ 13-5.4 as applicable. c. All periodic tests to detennine mass emission limits from or air pollutant concentrations in discharge stacks and such other tests as specified in this Class II General Permit shall be conducted in accordance with an approved test protocol. Such protocols shall be submitted to the Secretary in writing at least thirty (30) days prior to any testing and shall contain the information set forth by the Secretary. In addition, the registrant shall notify the Secretary at least fifteen (15) days prior to any testing so the Secretary may have the opportunity to observe such tests. This notification shall include the actual date and time during which the West Virginia Department of Environmental Protection· Division of Air Quality -12- G35-C Natural Gas Compressor and/or Dehydration Facility 13 of38 test will be conducted and, if appropriate, verification that the tests will fully conform to a referenced protocol previously approved by the Secretary. d. The registrant shall submit a report of the results of the stack test within sixty (60) days of completion of the test. The test report shall provide the information necessary to document the objectives of the test and to determine whether proper procedures were used to accomplish these objectives and any operating parameters r~quired to be monitored. The report shall include the following: the certification described in paragraph 3.6.1; a statement of compliance status, also signed by a responsible official; and,· a summary of conditions which form the basis for the compliance status evaluation. The summary of conditions shall include the following: 1. The permit or rule evaluated, with the citation number and language; 2. The result of the test for each permit or rule condition; and, 3. A statement of compliance or noncompliance with each permit or rule condition. [WV Code § 22-5-4(a)(14-15) and 45CSR13) 3.5. 3.6. Ilecordkeeping Requirements 3.5 .1. Retention of records. The registrant shall maintain records of all information (including monitoring data, support information, reports, and notifications) required by this permit recorded in a form suitable and readily available for expeditious inspection and review. Support information includes all calibration and maintenance records. The files shall be maintained for at least five (5) years following the date of each occurrence, measurement; maintenance, corrective action, report, or record. Said records shall be maintaiIied on site or in a readily access~ble off-site location maintained by the registrant for a period of five (5) years. Said records shall be readily available to the Secretary of the Division of Air Quality or hislher duly authorized representative for expeditious inspection and review. Any records submitted to the agency pursuantto a requirement of this permit or upon request by the Secretary shall be certified by a responsible official. Where appropriate, the registrant may maintain records electronicailY. 3.5.2. Odors. For the purposes of 45CSR4, the registrant shall maintain a record of all odor complaints received, any investigation performed in response to such a complaint, and any responsive action(s) taken. [45CSR§4. State Enforceable Only.) Reporting Requirements 3.6.1 . Responsible official. Any application form, report, or compliance certification required by this permit to be submitted to the DAQ and/or USEP A shall contain a certification by the responsible official that states that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. . 3.6.2. Confidential information. A registrant may request confidential treatment for the submission of reporting required by this permit pursuant to the limitations and procedures of W.Va. Code 225-10 and 45CSR31. 3.6.3. Correspondence. All notices, requests, demands, submissions and other communications required or permitted to be made to the Secretary of DEP and/or USEPA shall be made in writing and shall be deemed to have been duly given when delivered by hand, e-mailed or mailed first class with postage prepaid to the addressees) set forth below or to such other person or address as the Secretary of the Department of Environmental Protection may designate: * . West Virginia Department of Environmental Protection· Division of Air Quality -13- G35-C NatUral Gas Compressor and/or Dehydration Facility 140f38 If to the DAQ: Director WVDEP Division of Air Quality 601 57th Street SE Charleston, WV 25304-2345 3.6.4. If to the US EPA: Associate Director Office of Air Enforcement and Compliance Assistance (3AP20) U.S. Environmental Protection Agency Region III 1650 Arch Street Philadelphia, PA 19103-2029 Emission inventory. At such time(s) as the Secretary may designate, the registrant herein shall prepare and submit an emission inventory for the previous year, addressing the emissions from the facility and/or process(es) authorized herein, in accordance with the emission inventory submittal requIrements of the DAQ. After the initial submittal, the Secretary may, based upon the type and quantity of the pollutants emitted, establish a frequency other than on an annual basis. 3.6.5. Operating Fee 3.6.5.1. In accordance with 45CSR22 - Air Quality Management Fee Program, the registrant shall not operate nor cause to operate the permitted facility or other associated facilities on the same or contiguous sites comprising the plant without first obtaining and having in current effect a Certificate to Operate (era). Such Certificate to Operate (CTO) shall be renewed annually, shall be maintained on the premises for which the certificate has been issued, and shall be made immediately available for inspection by the Secretary or hislher duly authorized representative. West Virginia Depal1ment of Environmental Protection· Division of Air Quality -14- 150f38 G35-C Natural Gas Compressor andlor Dehydration Facility 4.0. Source-Specific Requirements 4.1. Limitations and Standards 4.1.1. Operation and Maintenance ofAir Pollution Control Equipment and Emission Reduction Devices. The registrant shall, to the extent practicable, install, maintain, and operate all pollution control equipment and emission reduction devices listed in the issued General Permit Registration and associated monitoring equipment to comply with limits set forth in this General Permit or as set forth by any State rule, Federal regulation, or alternative control plan approved by the Secretary. [45CSR§13-5.11.1 4.1. 2. Applicability ofState and Federal Regulations. The registrant is subject to the provisions of the following State Rules and Federal Regulations, to the extent applicable based on its registration: a. b. c. d. e. f. g. h. i. j. k. 45CSR2 - Particulate Air Pollution from Combustion of Fuel in Indirect Heat Exchangers 45CSR6 - To Prevent and Control Air Pollution from the Combustion of Refuse 45CSRlO - To Prevent and Control Air Pollution from the Emissions of Sulfur Oxides 45CSR13 - Permits for Construction, Modification, Relocation and Operation of Stationary Sources of Air Pollutants, Notification Requirements, Administrative Updates, Temporary Permits, General Permits, and Procedures for Evaluation 45CSR16· Standards of Performance for New Stationary Sources Pursuant to 40 CFR Part 60 45CSR22 • Air Quality Management Fee Program 40CFR60 Subpart IIIl • Standards of Performance for Stationary Compression Ignition Internal Combustion Engines 40CFR60 Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines 40CFR60 Subpart 0000 - Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution 40CFR63 Subpart HH - National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities 40CFR63 Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for . Reciprocating Internal Combustion Engines 4.1.3. The registrant shall install, maintain, and operate all above-ground piping, vah'es, pumps, etc. that service lines in the transport of potential sources of regulated air pollutants to minimize any fugitive escape of regulated air pollutants (le*). Any above-ground piping, valves, pumps, etc. that shows signs of excess wear and that have a reasonable potential for fugitive emissions of regulated air pollutants shall be repaired or replaced as needed. 4.1.4. The registrant shall monitor and maintain quarterly records (calendar year) for each facility component that was inspected for fugitive escape of regulated air pollutants. Each component shall operate with no detectable emissions, as determined using audio-visual-olfactory (AVO) inspections, USEP A 40CFR60 Method 21, USEPA alternative work practice to detect leaks from equipment using optical gas imaging (OGI) camera (ex. FUR camera), or some combination thereof. A va inspections shall include, but not limited to, defects as visible cracks, holes, or gaps in piping; loose connections; liquid leaks; or broken or missing caps or other closure devices. If registrant uses USEPA Method 21, then no detectable emissions is defined as less than 500 ppm in emiSSIOns is accordance with Method 21 . If registrant uses an OGI camera, then no detectable defined as no visible leaks detected in accordance with USEPA alternative OGI work practices. If any leak is detected, the registrant shall repair the leak as soon as possible. The first attempt at repair must be made within five (5) calendar days of discovering the leak, and the final repair must be made within fifteen (15) calendar days of discovering the leak. The registrant shall record each leak detected and the associated repair. The leak will not be considered repaired until the same monitoring method or a more detailed instrument determines the leak is repaired. West Virginia Department of Environmental Protection· Division of Air Quality -15- G35-C Natural Gas Compressor and/or Dehydration Facility 160f38 Delay of repair of a closed vent system for which leaks or defects have been detected is allowed if the repair is technically infeasible without a shutdown, or if you determine that emissions resulting from immediate repair would be greater than the fugitive emissions likely to result from delay of repair. You must complete repair of such equipment by the end of the next shutdown. [45CSR§13-5.11.) 4.2. Recordkeeping Requirements 4.2.1 .. Monitoring information. The registrant shall keep records of monitoring information that include the following: a. b. c. d. e. f. The date, place as defined in this permit and time of sampling or measurements; The date(s) analyses were performed; The company or entity that performed the analyses; The analytical techniques or methods used; The results of the analyses; and The operating conditions existing at the time of sampling or measurement. 4.2.2. Record ofMaintenance ofAir Pollution Control Equipment and Emission Reduction Devices. For all pollution control equipment and emission reduction devices listed in the General Permit Registration, the registrant shall maintain accurate records of all required pollution control equipment and emission reduction devices inspection and/or preventative maintenance procedures specifically required in this General fermit. 4.2.3. Record ofMalfunctions ofAir Pollution Control Equipment and Emission Reduction Devices. For all air pollution control equipment and emission reduction devices listed in the Genera:l Permit Registration, the registrant shall maintain records of the occurrence and duration of any malfunction or operational shutdown of the air pollution control equipment and emission reduction devices during which excess emissions above the applicable permit limit occur. For each such case, the following information shall be recorded: a. b. c. d. The equipment involved. Steps taken to minimize emissions during the event. The duration of the event. The estimated increase in emissions during the event. For each such case associated with an equipment malfunction, the additional information shall also be recorded: e. f. g. The cause of the malfunction. Steps taken to correct the malfunction. Any changes or modifications to equipment or procedures that would help prevent future recurrences of the malfunction. West Virginia Department of Environmental Protection· Division of Air Quality -16- 170f38 G35-C Natural Gas Compressor and/or Dehydration Facility 5.0. Source-Specific Requirements [Storage Vessels Containing Condensate and/or Produced Water] Limitations and Standards 5.1. 5.1.1. Emission Units. The maximum design capacity for any registered storage "essel (condensate and/or produced water) listed in the G35-C General Permit Registration shall not exceed the maximum design capacity recorded with the registrant's General Pennit Registration. 5.1 .2. Maximum Storage Vessel Throughput Limitation. The registrant shall not exceed the throughput recorded with the registrant's G35-C General Permit Registration without first obtaining a modification or administrative update. Compliance with the annual throughput limitation shall be determined using a twelve (12) month rolling total. A twelve (12) month rolling total shall mean the sum of the storage vessel throughput at any given time during the previous twelve (12) consecutive calendar months. 5.1.3. Regulated Pollutant Limitation. The registrant shall not cause, suffer, allow or permit emissions of any regulated pollutant from any storage vessel (condensate and/or produced water) listed in the G35-C General Permit Registration to exceed the emission limit in pounds per hour and tons per year recorded within the registrant's General Permit Registration without obtaining an administrative update or modification. 5.1.4. Emissions determination. The registrant shall determine the VOC emissions for each storage vessel (as defined in § 60.5430) to determine affected facility status (commenced construction, modification or reconstruction after August 23, 2011) in accordance with the emissions determination required in 40CFR60 Subpart 0000. 5.1.5. Control Devices. The registrant shall install, operate, and maintaiti all control devices listed in the G35-C General Permit Registration for the purpose of controlling emissions from the storage vessels in accordance with what was recorded with the registrant's General Permit Registration Application. 1. 2. Control Devices that are not subject to the control device requirements ojNSPS, Subpart 0000. If the registrant has determined per section 5.1.4 of this general permit that the storage vessel(s) are not subject to control requirements of 40CFR60 Subpart 0000, the registrant shall choose 'whether they want to be subject to the control device and closed vent system requirements of section 6.0 or section 7.0 of this general permit. Control Devices that are subject to the control device requirements ojNSPS. Subpart 0000. If the registrant has determined per section 5.1.4 of this general permit that the storage vessel(s) are subject to control requirements of 40CFR60 Subpart 0000, the registrant shall be subject to the control device and closed vent system requirements of section 6.0 of this general permit. 1. ii. 5.1.6. The registered enclosed combustion device, flare or incinerator is subject to 45CSR6. The registrant is subject to the applicable requirements specified in 45CSR6. Site spec(fic sample. 1. (On~vjor storage vessels with no air pollution control devices or VRUs) Applicabili~y. The requirements of this section apply to storage vessels that meet the requirements of paragraphs (a) and (b). a. Any storage vessel that contains condensate and/or produced water. West Virginia Department of Environmental Protection· Division of Air Quality -17- G35-C Natural Gas Compressor andlor Dehydration Facility 2. 180f38 b. Any storage vessel that is not subject to the control device requirements of section 5.1.5 of this general permit. c. Any storage vessel that has an upstream low pressure tower that meets the requirements of section 5.104 of this general permit is exempt from the requirements of this section. For registrants that meet the applicability requirements of paragraph (1) of this section, the registrant shall use a site specific sample to determine potential emissions. The registrant shall comply with the following: 1. The site specific sample shall be taken· within thirty (30) days of startup. 11. The type and location of the sample shall be appropriate for the calculation methodology or model (e.g. ProMax, E&P Tanks, HYSYS) being used to calculate the emissions. The sample location shall be equipped with appropriate sampling access. iii. If the VOC potential emissions are higher than the emission limits in the registration, DAQ shall be notified in accordance with section 504.1. a. 5.2. The registrant shall re-evaluate the VOC potential emissions based on the site specific sample within 90 days of receiving the analysis of the site specific sample determined per section 5.104 of this general permit. Monitoring Requirements 5.2. 1. Flash emissions. 1. The requirements of this section apply to .storage vessels that meet the requirements of paragraphs (a) and (b) of this section; a.Any storage vessel that contains condensate andlor produced water. 2. 5.2.2. b. Any storage vessel that is not subject to the control device requirements of 5.J.5. c. Any storage vessel that has a VRU system thilt is designed and operated in accordance with section 7.1. 7 of this general permit is exempt from the requirements of this section. The registrant shall monitor and maintain quarterly records of the temperature ·and pressure upstream of any storage vessel containing condensate and/or produced water at the appropriate separation unit based on the calculation methodology or model being used by the registrant to calculate their VOC flash emiSSions. Pressure monitoring shall not be required if the pressure setting is greater than the pressure safety valve for the storage vessel(s). Uncontrolled production storage vessels that are fed by a gas to liquid separator shall perfonn the following: 1. Inspect and maintain records of the separator liquid level that opens the dump valve on an as needed basis and annually (at a miuimum). 2. Inspect and maintain records of the separator dump valves operation per manufacturer recommendations or annually (at a minimum). West Virginia Department of Environmental Protection· Division of Air Quality -18- G35-C Natural Gas Compressor and/or Dehydration Facility 5.3. 5.4. 190f38 Recordkeeping Requirements 5.3.1. To demonstrate compliance with section 5.1.1 - 5.1.3 of this general permit, the registrant shall maintain a record of the aggregate throughput for the storage vessel(s) that contain condensate and/or produced water on a monthly and rolling twelve (12) month total. Alternatively, recording the monthly and rolling twelve (12) month total of condensate and/or produced water loaded into tanker trucks from the storage vessels according to section 14.2.1 can be used to demonstrate compliance. Said records shall be maintained in accordance with section 3.5.1 of this general permit. 5.3.2. To demonstrate compliance with section 5.1.4 of this general permit, .the registrant shall maintain records of the determination of the VOC emission rate per storage vessel, including identification of the model or calculation methodology used to calculate the VOC emission rate. 5.3.3. To demonstrate compliance with section 5.1.6 of this general permit, the registrant shall maintain · records of the type of sample taken, the location of the sample within the process, the temperature at the location and time where the sample was taken, the pressure at the location and time that the sample was taken, the analysis of the sample, and the resulting emissions calculations using the site specific sample. Notification and Reporting Requirements 5.4.1. The registrant shall notify the Director of the DAQ in writing for any instance when the potential emissions determined with a site specific sample in accordance with section 5.1.6 of this general permit were greater than the potential emissions provided in the G35-C general permit application. The notification shall include whether or not this change in emissions affects applicability determination to NSPS, Subpart 0000 for any storage vessel. The notification to the Director shall be provided no later than 30 days from the date of discovery of the increased emissions. West Virginia Department of Environmental Protection· Division of Air Quality -19- G35-C Natural Gas Compressor and/or Dehydration Facility 6.0. 200f38 Source-Specific Requirements [Standards of Performance for Storage Vessel Affected Facilities (NSPS, Subpart 0000)] 6.1. Limitations and Standards 6.1.1. 7.0. The registrant of each storage \'essel affected facility (commenced construction, modification or reconstruction after August 23, 2011) shall comply with the applicable requirements specified in 40 CFR Part 60, SubpartOOOO, unless they have installed a VRU or have Federally Enforceable Controls to limit each storage vessel(s) potential to emit below 6 tons per year of Volatile Organic Compounds. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH] 7.1. Limitations and Standards Scope: The scope of this section is to address requirements for control devices and emission reduction devices that will be installed and operated to control air emissions at a natural gas compressor andlor dehydration facility and that are not subject to NSPS, Subpart 0000 or NESHAP, Subpart HH requirements. If the control device is subjectto NSPS, Subpart 0000 control device and closed system requirements, they are subject to Section 6. O. Possible control and emission reduction devices meeting the scope ofthis section include: (1) control devices used to control VOC and HAP emissionsfrom the tanker truck loading operations; (2) control devices used to controlVOC and HAP emissionsfrom the storage vessel(s) below the NSPS, Subpart 0000 threshold of 6 tpy Voc. Control devices that are permitted under a legally and practically enforceable state permit achieve a "federally enforceable PTE" for VOC emissions at the storage vessels; and (3) control devices used to control VOC and HAP emissions from dehydration units. 7.1. 1. Operation and Maintenance ofAir Pollution Control Equipment and Emission Reduction Devices. The registrant shall, to the extent practicable, install, maintain, and operate all air pollution control equipment and emission reduction devices listed in the General Permit Registration and associated monitoring equipment in a manner consistent with safety and good air pollution control practices for minimizing emissions, or comply with any more stringent limits set forth in this permit or as set forth by any State rule, Federal regulation, or alternative control plan approved by the Secretary. [45CSR§13-5.11.] 7.1.2. Enclosed Combustion Devices and Flares. The registrant shall comply with the requirements in this section for any registered enclosed combustion device or flare that is listed as a control device in the General Permit Registration: 1. The registrant may use the same control device to control emissions from multiple emission sources (ex. storage vessels, loading racks, etc.) where the control deyice is both subject to and not subject to NSPS, Subpart 0000 requirements depending on the emission source being controlled and if the control device was designed accordingly. If the registrant uses the control device for multiple source types, they shall comply with the more stringent NSPS, Subpart 0000 closed vent system and control device requirements for the entire system and shall comply with the applicable NSPS, Subpart 0000 closed vent system and control requirements for storage vessels provided in section 6.0 of this general permit. West Virginia Department of Environmental Protection· Division of Air Quality -20- 210f38 G35-C Natural Gas Compressor and/or Dehydration Facility 2. Flares. If the registrant utilizes a flare control device, the registrant shall comply with the design and operating-requirements below: i. Vapors that are being controlled by the flare shaH be routed to the flare at all times. 11. Flares shall be operated with a flame present at all times, as determined by the methods specified in section 7.2.1 of this general permit; 1Il. Flares shall be designed according to the requirements specified in § 60.18; tv. Flares shall be operated at all times when emissions are vented to them; v. To ensure compliance with 7.1.2.2 (iv) of this general permit, the registrant shall monitor in accordance with section 7.2.1 of this general permit. VI. Flares shall be designed for and operated with no visible emissions as determined by the methods specified in permit section 7.3.1 of this general permit except for periods not to exceed a total of 5 minutes during any 2 consecutive hours; and, V11. The registrant shall monitor the flare(s) to ensure that they are operated and maintained in conformance with their designs. The registrant may claim a capture and control efficiency of 98% for those units meeting the requirements of2.i-vii. 3. Enclosed Combustion Devices. If the registrant utilizes an enclosed combustion control device; the registrant shall comply with the design and operating requirements below: i. Vapors that are being controlled by the enclosed combustion device shall be routed to the enclosed combustion device at all times. ii. The enclosed combustion device shall be operated with a flame present at all times, as determined by the methods specified in sections 7.2.1 and 7.2.3 of this general permit: 111. Enclosed combustion devices shall be designed for and operated with no visible emissions as determined by the methods specified in section 7.3.1 of this general permit except for either (a) or (b); a. periods not to exceed a total of one minute during any 15 minute period, determined on a monthly basis; or b. periods not to exceed a total of two (2) minutes during any hour, determined on a quarterly basis if the enclosed combustion device installed was a model tested under § 60.5413(d) which meets the criteria in § 60.54 13 (d)(l I). lV. Enclosed combustion devices shall be operated at all times when emissions are vented to them. \. To ensure compliance with 7.1.2.3(iv) above, the registrant shall monitor in accordance with section 7.2.3 of this general pennit. VI. The registrant shall operate and maintain the enclosed combustion device according to the manufacturer's specitications for operating and maintenance requirements to maintain the guaranteed control efficiency listed in the General Permit Registration. West Virginia Department of Environmental Protection· Division of Air Quality -21- G35-C Natural Gas Compressor and/or Dehydration Facility 22 0f38 The registrant may claim a capture and control efficiency of98% for those units meeting the requirements of 3.i-vi. 4. Closed Vent System. The registrant shall comply with the closed vent system requirements in section 7.1.4. 5. Maximum Design Heat Input. The maximum design heat input for any registered flare or enclosed combustion deyice listed in the General Permit Registration shall not exceed the Maximum Design Heat Input (MMBtulhr) recorded with the registrant's General Permit Registration. 6. 7.1.3. The registered enclosed combustion device or flare is subject to the applicable requirements specified in 45CSR6. Cover Requirements. The registrant shall comply with the cover requirements in this section if the potential emissions that were calculated to determine affected facility status did include recovered vapors from the storage vessel as allowed and in accordance with 5.1.4 of this general permit. I. The co\'er and all openings on the cover (e.g., access hatches, sampling ports, pressure relief valves and gauge wells) shall form a continuous impermeable barrier over the entire surface area of the liquid in the storage vessel. 2. Each cover opening shall be secured in a closed, sealed position (e.g., covered by a gasketed lid or cap) whenever material is in the unit on which the cover is installed except during those times when it is necessary to use an opening as follows: (i) To add material to, or remove material from the unit (this includes openings necessary to equalize or balance the internal pressure of the unit following changes in the level of the material in the unit); (ii) To inspect or sample the material in the unit; (iii) To inspect, maintain, ,repair, or replace equipment located inside the unit; or (iv) To vent liquids, gases, or fumes from the unit through a closed-vent system designed and operated in accordance with the requirements of this general permit to a control device or to a process. 3. 7.1.4. Each storage vessel thief hatch shall be weighted and properly seated. You must select gasket material for the hatch based on composition of the fluid in the storage vessel and weather conditions. [45CSR§ 13-5.11. J Closed Vent Systems (applies to all non 40CFR60 Subpart 0000 controls). The registrant shall comply with the closed vent system requirements in this section if the potential emissions that were calculated to determine affected facil\ty status did include recovered vapors from the storage vessel as allowed and in accordance with 5.1.4 of this general permit. 1. You must design the closed vent system to route all gases, vapors. and fumes emitted from the material in the storage vessel to a control device that meets the requirements of 5.1.5 of this general permit or to a process. The registrant shall perform an initial LDAR evaluation within thirty (30) days of start-up and follow the procedures in section 4.1.4 for ongoing compliance. 2. You must design and operate a closed vent system with no detectable emissions, as determined using audio-visual-olfactory (AVO) inspections, USEPA 40CFR60 Method 21, West Virginia Department of Environmental Protection· Division of Air Quality -22- G35-C Natural Gas Compressor andior Dehydration Facility 230f38 USEP A alternative work practice to detect leaks from equipment using optical gas imaging (OGI) camera (e.g. FUR camera), or some combination thereof. AVO inspections shall include, but not limited to, defects as visible cracks, holes, or gaps in piping; loose connections; liquid leaks; or broken or missing caps or other closUre devices. If registrant uses USEP A Method 21, then no detectable emissions is defined as less than 500 ppm in accordance with Method 21. If registrant uses an OGI camera, then no detectable emissions is defined as no visible leaks detected in accordance with US EPA alternative OGI work practices. 3. You must meet the requirements specified in (1) and (2) of this section if the closed vent system contains one or more bypass devices that could be used to divert alI or a portion of the gases, vapors, or fumes from entering the control device or to a process. i. Except as provided in paragraph (2) of this section, you must comply with either paragraph (A) or (B) of this section for each bypass device. A. You must properly ins talI, calibrate, maintain, and operate a flow indicator at the inlet to the bypass device that could divert the stream away from the control device or process to the atmosphere that sounds an alarm, or initiates notification via remote alarm to the nearest field office, when the bypass device is open such that the stream is being, or could be, diverted away from the control device or process to the atmosphere. B . You must secure the bypass device vah-e installed at the inlet to the bypass device in the non-diverting position using a car-seal or a lock-and-key type configuration. ii. Low leg drains, high point bleeds, analyzer vents, open-ended valves or lines, and safety devices are not subjectto the requirements of paragraph (i) of this section. [4SCSR§13-S.11.] 7.1.5. Carbon Adsorption Systems. The registrant shall comply with the requirements below for any registered carbon adsorption system that is listed as a control device in the General Permit Registration: 1. The carbon adsorption system shall be designed to achieve the minimum guaranteed control efficiency that is listed in the General Permit Registration for volatile organic compound (VOC) emissions; 11. The carbon adsorption system must be operated at all times when gases, Yapors, and fumes are vented to it. Carbon canisters shall be operated in series as dual carbon canisters, in case of emission breakthrough in one carbon canister. iii. The carbon adsorption system must have a commercially manufactured saturation indicator installed. iv. Prior to the loading of each truck, the saturation indicator on the carbon adsorption system shaII be checked to ensure that the carbon is not spent. These records must be kept in accordance with section 3.5.1 of this general permit. If the saturation indicator demonstrates that the carbon is saturated, truck loading is prohibited and/or emissions are to cease. Y. All carbon in the carbon canister shall be replaced with fresh carbon or the carbon canister replaced with a new canister when the saturation indicator changes in color and indicates saturation. vi. Fresh replacements for all carbon being used in the carbon adsorption system shall be kept on site. West Virginia Department of Environmental Protection· Division of Air Quality -23- G35-C Natural Gas Compressor and/or Dehydration Facility 240f38 The registrant may claim a control efficiency of95% for those units meeting the requirements of 7.1.5.i-vi. 7.1.6. CondenserslBTEX Eliminators. The registrant shall comply with the requirements below for any registered condenser/BTEX Eliminator that is listed as a control device/emission reduction device for a glycol dehydration unit in the General Permit Registration: 1. Vapors that are being controlled by the condenser/BTEX Eliminator shall be routed through a closed vent system to the condenser/BTEX Eliminator at all times when there is a potential that vapors (emissions) can be generated from the glycol dehydration still column. ii. The condenser/BTEX Eliminator shall be designed, operated, and maintained according to good engineering practices and manufacturer's specifications so as to achieve, at a minimum, a capture and control efficiency of 50%. a. 7.1.7. The registrant may claim a capture and control efficiency greater than 50% if the General Permit Registration was approved based on manufacturer's specifications and the unit was operated as such. Vapor Recovery Units (VRUs) i. The registrant shall comply with the closed vent system requirements in Section 7.1.4 of this general permit. ii. The registrant may claim a capture and control efficiency of95% (which accounts/or 5% expected downtime). iii. The registrant may claim a capture and control efficiency of 98% if the VRU has a backup flare (enclosed combustion device) that meet the requirements of section 7.1.2 of this general permit. iv. The registrant may claim a capture and control efficiency of 98% if the VRU has a backup VRU. 7.l.8. Glycol Dehydration Units Recycling Back to Flame Zone of the Reboiler. If the registrant is reducing emissions by recycling the glycol dehydration unit back to the flame zone of the reboiler, it shall be designed and operated in accordance with the following: a. The vapors/overheads from the still column shall be routed through a condenser at all times when there is a potential that vapors (emissions) can be generated from the still column. b. The reboiler shall only be fired with vapors from the still column and flash tank, and natural gas may be used as a supplemental fuel. c. The yapors/overheads from the still column shall be introduced into the flame zone of the reboiler as the primary fuel or with the primary fuel before the combustion chamber. The registrant may 'claim a capture and control efficiency of 50% for those units meeting the requirements of either a or b. The registrant may claim a capture and control efticiency greater than 50% if the General Permit Registration was approved based on manufacturer's specifications and the unit was operated as such. West Virginia Department of Environmental Protection· Division of Air Quality -24- 250f38 G35-C Natural Gas Compressor and/or Dehydration Facility 7.2. Monitoring Requirements 7.2. I. To demonstrate compliance with the pilot flame requirements of sections 7.1.2.2 and 7.1.2.3 of this general permit, the presence of a pilot flame shall be continuously monitored using a thermocouple or any other equivalent device to detect the presence of a flame when emissions are vented to it. The pilot shall be equipped such that it sounds an alarm, or initiates notification via remote alarm to the nearest field office, when the pilot light is out. 7.2.2. To demonstrate compliance with the closed vent system requirements of section 7. 1.4 of this general permit, the registrant shall: a. Initial requirements. Conduct an initial AVO inspection or those methods listed in section 4.1.4 of this general permit for defects that could result in air emissions within thirty (30) days of start-up. Defects include, but are not limited to, visible cracks, holes, or gaps in piping; loose connections; liquid leaks; or broken or missing caps or other closure devices. 1. The initial inspection shall include the bypass inspection, conducted according to paragraph (c) of this section. 11. In the event that a leak or defect is detected, you must repair the leak or defect as soon as practicable. Grease or another applicable substance must be applied to deteriorating or cracked gaskets to improve the seal while awaiting repair. iii. Delay of repair of a closed vent system for which leaks or defects have been detected is allowed if the repair is technically infeasible without a shutdown, or if you determine that emissions resulting from immediate repair would be greater than the fugitive emissions likely to result from delay of repair. You must complete repair of such equipment by the end of the next shutdown. b. Continuous requirements. The registrant shall monitor and maintain quarterly records for each component that was inspected for fugitive escape of regulated air pollutants. Each component shall operate with no detectable emissions, as determined using AVO inspections, USEPA 40CFR60 Method 21, USEPA alternative work practice to detect leaks from equipment using optical gas imaging (OGI) camera (ex. FLIR camera), or some combination thereof. AVO inspections shall include, but not limited to, defects as visible cracks, holes, or gaps in piping; loose connections; liquid leaks; or broken or missing caps or other closure devices. If registrant uses USEPA Method 21, then no detectable emissions is defined as less than 500 ppm in accordance with Method 2 I. If registrant uses an 001 camera, then no detectable emissions is defined as no visible leaks detected in accordance with USEP A alternatiye 001 work practices. If any leak is detected, the registrant shall repair the leak as soon as possible. The first attempt at repair must be made within five (5) days of discovering the leak, and the final repair must be made within fifteen (15) days of discovering the leak. The registrant shall record each leak detected and the associated repair. The leak will not be considered repaired until the same monitoring method that detected the leak determines the leak is repaired. The registrant shall maintain records of all quarterly monitoring for fugitive escape of regulated air pollutants. c. Bypass inspection. Visually inspect the bypass valve during the initial inspection for the presence of the car seal or lock-and-key type configuration to verify that the valve is maintained in the non-diverting position to ensure that the vent stream is not diverted through the bypass device. If an alternative method is used, conduct the inspection of the bypass as described in the operating procedures. West Virginia Department of Environmental Protection· Division of Air Quality -25- G35-C Natural Gas Compressor andlor Dehydration Facility d. 26 0f38 Unsafe to inspect requirements. You may designate any parts of the closed vent system as unsafe to inspect if the requirements in paragraphs (0 and (ii) of this section are met. Unsafe to inspect parts are exempt from the inspection requirements of paragraphs (a) and (b) of this section. i. You determine that the equipment is unsafe to inspect because inspecting personnel would be exposed to an imminent or potential danger as a consequence of complying with the requirements. ii. You have a written plan that requires inspection of the equipment as frequently as practicable during safe-to-inspect times. . [45CSR§13-5.11.1 7.2.3. To demonstrate compliance with the pilot flame requirements of sections 7.1.2.3 of this general permit, the registrant shall follow (i). i. For any absence of pilot flame, or other indication of smoking or improper equipment operation, you must ensure the equipment is returned to proper operation as soon as practicable after the event occurs. At a minimum, you must: (1) Check the air vent for obstruction. Ifan obstruction is observed, you must clear the obstruction as soon as practicable. (2) Check for liquid reaching the combustor. 11. The registrant is exempt from the pilot flame requirements of permit condition 7.2.3.i of this section if the registrant installed an enclosed combustion device model that was tested under ~ 60.5413(d) which meets the criteria in 60.54 13 (d)(l 1). * 7.3. Testing Requirements 7.3.1. To demonstrate compliance with the visible emissions requirements of section 7.1.2.2, 7.1.2.3, and 7.1.2.6 of this general permit, the registrant shall conduct visible emission checks and/or 0}Jacity monitoring and recordkeeping for all emission sources subject to an opacity limit. i. The visible emission check shall determine the presence or absence ofyisible emissions. The observations shall be conducted according to Section 11 of EPA Method 22. At a minimum, the observer must be trained and knowledgeable regarding the effects of background contrast, ambient lighting, observer position relative to lighting, wind, and the presence of uncombined water (condensing water vapor) on the visibility of emissions. This training may be obtained from written materials found in the References I and 2 from 40CFR Part 60, Appendix A, Method 22 or from the lecture portion of the 40CFR Part 60, Appendix A, Method 9 certification course. The observation period shall be: a. b. c. 7.3.2. a minimum of 2 hours if demonstrating compliance with 7.1.2.2; a minimum of 15 minutes if demonstrating compliance with 7.1.2.3(iii)(a); or a minimum of 1 hour if demonstrating compliance with 7.1.2.3 (iii)(b) ll. The visible emission check shall be conducted initially within 180 days of start-up to demonstrate compliance while vapors are being sent to the control device. Ill. If during this visible emission check or at any other time visible emissions are observed, compliance with section 7.1.2.6 of this general pemlit shall be detennined by conducting opacity tests in accordance with Method 9 or 40 CFR 60, Appendix A. A flare that is designed and operated in accordance with §60.18(b) shall not require performance testing, unless at the request of the Secretary, but must conduct visible emission check. West Virginia Department of Environmental Protection· Division of Air Quality -26- G35-C Natural Gas Compressor and/or Dehydration Facility 7.3.3. 7.4. 270f38 Enclosed combustion devices or flares. At such reasonable times as the Secretary may designate, the operator of any incinerator shall be required to conduct or have conducted stack tests to determine the particulate matter loading, by using 40 CFR Part 60, Appendix A, Method 5, and volatile organic compound loading, by using Methods 18 and 25A of 40 CFR Part 60, Appendix A, Method 320 of 40 CFR Part 63, Appendix A, or ASTM D 6348-03 or other equivalent U.S. EP A approved method approved by the Secretary, in exhaust gases. Such tests shall be conducted in such manner as the Secretary may specify and be filed on forms and in a manner acceptable to the Secretary. The Secretary may, at the Secretary's option, witness or conduct such stack tests. Should the Secretary exercise his or her option to conduct such tests, the operator will provide all the necessary sampling connections and sampling ports to be located in such manner as the Secretary may require, power for test equipment and the required safety equipment such as scafIolding, railings and ladders to comply with generally accepted good safety practices. The Secretary may conduct such other tests as the Secretary may deem necessary to evaluate air pollution emissions other than those noted above. [45CSR6 §§7.1 and 7.2) Recordkeeping Requirements 7.4.1. For the purpose of demonstrating compliance with the design requirements in section 7.1.2.2 of this permit, the registrant shall maintain a record of the flare design evaluation. The flare design evaluation shall include, net heat value calculations, exit (tip) velocity calculations, and all supporting concentration calculations. 7.4.2. For the purpose of demonstrating compliance with the continuous pilot flame require'ments in sections 7.1.2.2 and 7.1.2.3 of this general permit, the registrant shall maintain records of the times and duration of all periods when the pilot flame was not present and vapors were vented to the device. 1. If the registrant is demonstrating compliance to 7.2.3 of this general permit with visual inspections, the registrant shall maintain records of the inspections. ii. If the registrant is demonstrating compliance to 7.2.3 of this general permit with an enclosed combustion device model that was tested under the conditions of 60.5413(d), a record shall be maintained of the performance test results. * 7.4.3. For the purpose of demonstrating compliance with the visible emissions and opacity requirements, the registrant shall maintain records of the visible emission opacity tests and checks. The registrant shall maintain records of all monitoring data required by section 7.3.1 of this general permit documenting the date and time of each visible emission check, the emission point or equipment/ source identification number, the name or means of identification of the observer, the results of the check(s), whether the visible emissions are normal for the process, and, ifapplicable, all corrective measures taken or planned. The registrant shall also record the general weather conditions (i.e. sunny. approximately 80°F. 6-10 mph NE wind) during the visual emission check(s). Should a visible emission observation be'required to be performed per the requirements specified in Method 9. the data records of each observation shall be maintained per the requirements of Method 9. For an emission unit out of service during the evaluation, the record of observation may note" out of service" (O/S) or equivalent. 7.4.4. To demonstrate compliance with section 7.1.2.3.vi of this general permit. the registrant shall maintain records of the manufacturer's specifications for operating and maintenance requirements to maintain the control efficiency. 7.4.5 . To demonstrate compliance with the closed vent monitoring requirements in section 7.2.2 of this general permit, records shall be maintained of: 1. The initial compliance requirements; West Virginia Department of Environmental Protection· Division of Air Quality -27- 280f38 G3S-C Natural Gas Compressor andlor Dehydration facility 11. Each AVO inspection, Method 21, infrared camera or some combination thereof conducted to demonstrate continuous compliance, including records of any repairs that were made as a result of the inspection; . iii. If you are subj ect to the bypass requirements, the following records shall also be maintained: (a) Each inspection or each time the key is checked out or a record of each time the alarm is sounded; (b) Each occurrence that the control device was bypassed. lfthe device was bypassed, the records shall include the date, time, and duration of the event and shall provide the reason that the event occurred. The record shall also include the estimate of emissions that were released to the environment as a result of the bypass. iv. Any part of the system that has been designated as "unsafe to inspect" in accordance with 7.2.2(d). [45CSR§13-5.11.] 7.5. 7.4.6. To demonstrate compliance with section 7.1.S of this general permit, records shall be kept on each carbon canister to indicate the date when the activated carbon was replaced and the date of all indicator checks. 7.4.7. The registrant shall maintain records of any testing that is conducted according to section 7.3 of this general permit. 7.4.8. All records required under Section 7.4 shall be maintained on site or in a readily accessible off-site location maintained by the registrant for a period offive (S) years. Said records shall be readily available to the Director of the DAQ or his/her duly authorized representative for expeditious inspection and review. Any records submitted to the agency pursuant to a requirement of this permit or upon request by the Director shall be certified by a responsible official. 7.4.9. To demonstrate compliance with section 7 .1.2.S of this general permit, the registrant shall record the volume of gas flared on a monthly basis. Reporting Requirements 7.S.1. Any deviation of the allowable visible emission requirement for any emission source discovered during observation using 40CFR Part 60, Appendix A, Method 9 per section 7.3.ICiii) of this general permit must be reported in writing to the Director of the DAQ as soon as practicable, but within ten (10) calendar days, of the occurrence and shall include, at a minimum, the following information: the results of the visible determination of opacity of emissions, the cause or suspected cause of the violation(s), and any corrective measures taken or planned. 7.S.2. Any bypass event of the registered control device must be reported in writing to the Director of the DAQ as soon as practicable, but within ten C10) calendar days, of the occurrence and shall include, at a minimum, the following information: the date of the bypass, the estimate of VOC emissions released to the atmosphere as a result of the bypass, the cause or suspected cause of the bypass, and any corrective measures taken or planned. 7.S.3. Any time the air pollution control device is not·operating when emissions are vented to it, shall be reported in writing to the Director of the DAQ as soon as practicable, but within ten (10) calendar days of the disco\·ery. West Virginia Depal1ment of E~vironmental Protection· Division of Air Quality -28- G35-C Natural Gas Compressor and/or Dehydration Facility 290f38 8.0. Source-Specific Requirements [Small Heaters and Reboilers not subject to 40CFR60 Subpart Dc] 8.1. 8.2. Limitations and Standards 8.1 .1. Maximum Design Heat Input. The maximum design heat input for any small heater and/or reboiler shall be less than 10 MMBTUlhr. 8.1.2. No person shall cause, suffer, allow or permit emission of smoke and/or particulate matter into the open air from any fuel burning unit which is greater than ten (10) percent opacity based on a six minute block average. [45CSR§2-3.1.) Monitoring Requirements 8.2.1. 8.3 Testing Requirements 8.3.1. 8.4. At such reasonable times as the Secretary may designate, the registrant shall conduct Method 9 emission observations for the purpose of demonstrating compliance with section 8.1.2 of this general permit. Method 9 shall be conducted in accordance with 40 CFR 60 Appendix A. Upon request by the Secretary, compliance with the visible emission requirements of section 8.1.2 of this general permit shall be determined in accordance with 40 CFR Part 60, Appendix A, Method 9 or by using measurements from continuous opacity monitoring systems approved by the Secretary. The Secretary may require the installation, calibration, maintenance and operation of continuous opacity monitoring systems and may establish policies for the evaluation of continuous opacity monitoring results and the determination of compliance with the visible emission requirements of section 8.1.2 of this general permit. Continuous opacity monitors shall· not be required on fuel burning units which employ wet scrubbing systems for emission control. [45CSR§2-3.2.) Recordkeeping Requirements 8.4. 1. The registrant shall maintain records of all monitoring data required by section 8.2.1 of this general permit documenting the date and time of each visible emission check, the emission point or equipment/source identification number, the name or means of identification of the observer, the results of the check(s), whether the visible emissions are normal for the process, and, if applicable, all correctiYe measures taken or planned. The registrant shall also record the general weather conditions (i.e. sunny, approximately 80°F, 6 - 10 mph NE wind) duri~g the visual emission check(s). Should a visible emission observation be required to be performed per the requirements specified in Method 9, the data records of each observation shall be maintained per the requirements of Method 9. West Virginia Department of Environmental Protection· Division of Air Quality -29- 300f38 G35-C . Natural Gas Compressor and/or Dehydration Facility Source-Specific Requirements [Pneumatic Controllers Affected Facility (NSPS, Subpart 0000)] 9.0.. 9.1. Limitations and Standards 9.1 .1. 10.0. The registrant of each pneumatic controller affected facility shall comply with the applicable requirements specified in 40 CFR Part 60, Subpart 0000. Source-Specific Requirements [Centrifugal Compressor Affected Facility (NSPS, Subpart 0000)] 10.1. Limitations and Standards 10.1.1. The registrant of each centrifugal compressor affected facility shall comply with the applicable . requirements specified in 40 CFR Part 60, Subpart 0000. 11.0. Source-Specific Requirements [Reciprocating Compressor Affected Facility (NSPS, Subpart 0000)] 11.1. Limitations and.Standards 11.1.1. Theregistrant of each reciprocating compressor affected facility shall comply with the applicable requirements specified in 40 CFR Part 60, Subpart 0000. West Virginia Department of Environmental Protection' Division of Air Quality -30- G35-C Natural Gas Compressor andlor Dehydration Facility 310f38 12.0. Source-Specific Requirements [Reciprocating Internal Combustion Engine(s) (RICE), Generators, Microturbine Generators] 12.1. Limitations and Standards 12.1.1. Regulated Pollutant Limitation. The registrant shall not cause, suffer, allow or permit emissions of of any regulated pollutant listed in the General Permit Registration to exceed the emission limit (pounds per hour and tons per year) recorded with the registrant's General Permit Registration without effecting a modification or administrative update. 12.1.2. The applicable RICE(s) andlor generator(s) shall be operated and maintained as follows: a. b. In accordance with the manufacturer's recommendations and specifications or in accordance with a site specific maintenance plan; and, In a manner consistent with good operating practices. 12.l.3. Requirements for Use of Catalytic Reduction Devices a. Rich-bum natural gas-fired compressor engine(s) equipped with non-selective catalytic reduction (NSCR) air pollution control devices shall be fitted with a closed-loop, automatic air/fuel ratio controller to enslire emissions of regulated pollutants do not exceed the emission limit listed in the General Permit Registration, for any enginelNSCR combination under varying load. The closed-loop, automatic air/fuel ratio co.ntroller shall control a fuel metering valve to ensure a fuel-rich mixture and a resultant exhaust oxygen content of less than or equal to 2%. b. Lean-bum natural gas compressor engine(s) equipped with selective catalytic reduction (SCR) air pollution control devices shall be fitted with a closed-loop automatic feedback controller to ensure emissions of regulated pollutants do not exceed the emission limit listed in the General Permit Registration for any engine/SCR combination under varying load. The closed-loop ~utomatic feedback controller shall provide proper and efficient operatipn of the engine, ammonia injection and SCR device, monitor emission levels downstream of the catalyst element and limit ammonia slip to less than 10 ppmv. c. Lean-bum natural gas compressor engine(s) equipped with oxidation catalyst air pollution control devices shall be fitted with a closed-loop automatic air/fuel ratio feedback controller to ensure emissions of regulated pollutants do not exceed the emission limit listed in the General Permit Registration for any engine/oxidation catalyst combination under varying load. The closed-loop, automatic air/fuel ratio controller shall control a fuel metering valve to ensure a lean-rich mixture. d. For natural gas compressor engine(s), the registrant shall monitor the temperature to the inlet of the catalyst and in accordance with manufacturer's specifications; a high temperature alarm shall shut off the engine before thermal deactivation of the catalyst occurs. If the engine shuts off due to high temperature, the registrant shall also check for thermal deactivation of the catalyst before normal operations are resumed. e. The registrant shall follow a written operation and maintenance plan that provides the periodic and annual maintenance requirements. 12.1.4. The registrant shall comply with all applicable NSPS for Stationary Compression Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart lIIl, Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart JJJJ, andlor the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 63, Subpart ZZZZ. West Virginia Department of Environmental Protection· Division of Air Quality -31- G35-C Natural Gas Compressor and/or Dehydration Facility 320f38 12.1.5. The emission limitations specified in section 12.1.1 shall apply at all times except during periods of start-up and shut-down provided that the duration of these periods does not exceed 30 minutes per occurrence. The registrant shall operate the engine in a manner consistent with good air pollution control practices for minimizing emissions at all times, including periods of start-up and shut-down. The emissions from start-up and shut-down shall be included in the twelve (12) month rolling total of emissions. The registrant shall comply with all applicable start-up and shut-down requirements in accordance with 40 CFR Part 60, Subparts lIII, JJJJ and 40 CFR Part 63, Subpart ZZZZ. 12.1.6. For the purposes of General Permit G35-C, emergency generator means a generator whose purpose is to allow key systems to continue to operate without interruption during times of utility power outages. 12.2. Monitoring Requirements 12.2.1. Catalytic Reduction Devices a. The registrant shall regularly inspect, properly maintain and/or replace catalytic reduction devices and auxiliary air pollution control devices to ensure functional and effective operation of the engine's physical and operational design. The registrant shall ensure proper operation, maintenance and performance of catalytic reduction devices and auxiliary air pollution control devices by: 12.3. 1. Maintaining proper operation of the automatic air/fuel ratio controller or automatic fe~dback controller. 2. Following the catalyst manufacturer emissions related operating and maintenance recommendations, or develop, implement, or follow a site-specific maintenance plan. Recordkeeping Requirements 12.3.1. To demonstrate compliance with general permit section 12.1.3, the registrant shall maintain records of the maintenance performed on each RICE and/or generator. 12.3.2. To demonstrate compliance with general permit sections 12.2.1, the registrant shall maintain a copy of the site specific maintenance plan or manufacturer maintenance plan. 12.3.3. The registrant shall comply with all applicable recordkeeping requirements under NSPS for Stationary Compression Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart IIII, Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart JJJJ, and/or the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 63, Subpart ZZZZ. 12.3.4. All records required by this section shall be maintained in accordance with section 3.5.1 of this general pennit. 12.4. Testing Requirements 12.4. \'. The registrant shall comply with all applicable testing requirements under NSPS for Stationary Compression Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart IIII, Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart JJJJ, and/or the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 63, Subpart ZZZZ. West Virginia Department of Environmental Protection· Division of Air Quality -32- G35-C . Natural Gas Compressor and/or Dehydration Facility 33 0f38 12.4.2. To demonstrate compliance with general permit section 12.1.3(a), the registrant shall verify that the closed-loop, automatic air/fuel ratio controller shall control a fuel metering valve to ensure a fuel-rich mixture and a resultant exhaust oxygen content ofless than or equal to 2% during any perfonnance testing. 12.5. Reporting Requirements 12.5.1. The registrant shall comply with all applicable notification requirements under NSPS for Stationary Compression Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart IIII, Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart JJJJ, and/or the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary"Spark Ignition Internal Combustion Engines specified in 40 CFR Part 63, Subpart ZZZZ. West Virginia Department of Environmental Protection· Division of Air Quality -33- G35-C Natural Gas Compressor and/or Dehydration Facility 13.0. 340f38 Source-Specific Requirements [Tanker Truck Loading] 13.1. Limitations and Standards 13.1.1. Regulated Pol/utant Limitation. The registrant shall not cause, suffer, allow or permit emissions from any registered Tanker Truck Loading Facility of any regulated pollutant listed in the General Permit Registration to exceed the emission limit (pounds per hour and tons per year) recorded with the registrant's General Permit Registration without effecting a modification or administrative update. . 13.1.2. Maximum Truck Loading Throughput Limitation. To demonstrate compliance with the tanker truck loading emissions in section 13.1.1. the registrant shall not exceed the maximum throughput limit that was recorded with registrant's General Permit Registration without obtaining a modification or administrative update. Compliance with the Maximum Annual Throughput Limitation shall be determined using a twelve (12) month rolling total. A twelve (12) month rolling total shall mean the sum of the tanker truck product throughput at any given time during the previous twelve (12) consecutive calendar months. 13.1.3. Control Devices and VRUs. The registrant shall install, operate, and maintain all control devices and/or VRU(s) in accordance with the applicable requirements of section 7.0 of this general permit. 13.1.4. The following applicable capture efficiencies are required: a. b. c. For tanker trucks and/or rail cars not passing one of the annual leak tests in 13.1.4(b) or (c) and has vapor return - 70% For tanker trucks and/or rail cars passing the NSPS level annual leak test - 98.7%. For tanker trucks andlor rail cars passing the MACT level annual leak test - 99.2% Compliance with this requirement shall be demonstrated by keeping records of the applicable MACT or NSPS Annual Leak Test certification for every truck and railcar loaded/unloaded. This requirement can be satisfied if the trucking/rail car company provided certification that all tanker trucks/rail cars servicing the location are compliant. 13.2. Recordkeeping Requirements 13.2.1. To demonstrate compliance with the emission limitations in section 13.1.1 and with the throughput limitation in section 13.1.2. the registrant shall maintain monthly and annual records that include the total quantity of material loaded into tanker trucks. The annual records shall be calculated on a twelve (12) month rolling total. 13.2.2. For the purpose of demonstrating compliance with section 13.1.2, the registrant shall maintain records of the MACT and/or NSPS Annual Leak Tests of all tanker trucks/rail cars loaded at the facility. This requirement can be satisfied if the trucking/rail car company pro':ided certification that all tanker trucks/rail cars servicing the location are compliant. This certification must be submitted in writing to the Director of the DAQ. West Virginia Department of Environmental Protection· Division of Air Quality -34- G35-C Natural Gas Compressor and/or Dehydration Facility 14.0 350f38 Source-Specific Requirements [Glycol Dehydration Units] 14.1. Limitations and Standards 14.1.1. The registrant of each glycol dehydration unit subject to 40 CFR Part 63, Subpart HH shall comply with the applicable requirements specified in 40 CFR Part 63, Subpart HH. 14. 1.2. Maximum Throughput Limitation. The maximum dry natural gas throughput to the glycol dehydration units,' still columns shall not exceed the throughput limit listed in the registrant's G35C General Permit Registration. Compliance with the" Maximum Throughput Limitation shall be determined using a twelve (12) month rolling total. A twelve (12) month rolling total shall mean the sum of the quarterly throughput at any given time during the previous twelve (12) consecutive calendar months. 14.1.3. Emission Limits. The registrant shall not cause, suffer, allow or permit emissions of HAPs and VOCs to exceed the emission limits listed in the registrant's G35-C General Permit Registration. 14.1.4. Emission Calculations. a. For purposes of determining potential HAP emissions, the methods specified in 40 CFR 63, Subpart HH shall be used. b. Any source that has actual emissions of 5 tons per year or more of a single HAP, or 12.5 tons per year or more of a combination of HAP (i.e., 50 percent of the major source thresholds), shall update its major source determination within 1 year of the prior determination or October 15,2012, whichever is later, and each year thereafter, using gas composition data measured during the preceding 12 months. [40CFR§63.760(c)] c. For the purposes of determining actual annual average natural gas throughput or actual average benzene emissions, the methods specified in § 63.772(b) of 40 CFR 63, Subpart HH shall be used if the registrant is exempt from § 63.764(d). 14.1.5. Control Devices and Emission Reduction Devices. The registrant shall comply with all applicable control device and emission reduction device requirements provided in section 7.0 of this general permit for any control device and emission reduction de\'ice used to control emissions from the dehydration unit and that is listed in the G35-C General Permit Registration. Compliance will be demonstrated according to the requirements listed in Section 7.0 of this general permit. 14.1.6. Maximum Glycol Recirculation Rate. The maximum glycol recirculation rate shall not exceed the gallons per minute limit listed in the registrant's G35-C general permit application. Compliance with the Maximum Glycol Recirculation Limitation shall be determined using an average of a minimum of quarterly readings of the actual glycol pump(s) rate. If more than one pump is operating simultaneously then the rate of each operating pump shall be recorded and totaled for compliance purposes. 14.2. Monitoring Requirements 14.2.1. To demonstrate compliance with section 14.1.2 of this general pennit, the registrant shall monitor the throughput of dry natural gas from the dehydration system on a quarterly basis for each glycol dehydration unit listed in the G35-C General Permit Registration. 14.2.2. Representative gas sample collection and analysis frequency for dehydration units shall be determined as set forth in the schedule provided in Table 14.2.2 of this section. West Virginia Department of Environmental Protection· Division of Air Quality -35- G35-C Natural Gas Compressor and/or Dehydration Facility 360f38 Table 14.2.2 Wet Gas Sampling and Analysis Frequency for Dehydration Units Based on Potential HAP Emission Rates Each dehydration unit exempt from 63.764(d) requirements and with federally enforceable controls * Each dehydration unit exempt from- *63.764(d) requirements and without federally enforceable controls Upon request by the Secretary. An initial compliance evaluation within 180 days of registration issuance or within 180 days of start-up of the dehydration unit, whiche,-er is later. 14.2.3. To demonstrate compliance with area source status and the benzene exemption in 14.1.4.c, the following parameters shall be measured at a minimum frequency of once per quarter, with the exception of natural gas flowrate annual daily average, natural gas flowrate maximum design capacity and wet gas composition, in order to define annual average values or, if monitoring is not practical, some parameters may be assigned default values as listed below. a. b. c. d. e. f. g. h. i. Natural Gas Flowrate 1. Operating hours per quarter 11. Quarterly throughput (MMscf/quarter) iii. Annual daily average (MMscf/day), and iv. Maximum design capacity (MMscf/day) Absorber temperature and pressure Lean glycol circulation rate Glycol pump type and maximum design capacity (gpm) Flash tank temperature and pressure, if applicable Stripping Gas flow rate, if applicable Wet gas composition (upstream of the absorber - dehydration column) sampled in accordance with GPA method 2166 and analyzed consistent with GPA extended method 2286 as well as the procedures presented in the GRI-GLYCaIc™ Technical Reference User Manual and Handbook V4 Wet gas water content (lbs H20/MMsct) Dry gas water content (lbs H 20IMMsct) at a point directly after exiting the dehydration column and before any additional separation points The following operating parameter(s) may be assigned default values when using GRI-GLYCalc: a. b. c. d. Dry gas water content can be assumed to be equivalent to pipeline quality at 7 lb H 20 I MMscf Wet gas water content can be assumed to be saturated Lean glycol water content if not directly measured may use the default value of 1.5 % water as established by GRI Lean glycol circulation rate may be estimated using the TEG recirculation ratio of3 gal TEG I lb H 20 removed. . Note: If you are measuring and using actual wet or dry gas water content, then you should also measure the glycol circulation rate rather than using the default TEG recirculation ratio. l45CSR§ 13-5.11, §63. 772(b)(2)(i) I West Virginia Department of Environmental Protection· Division of Air Quality -36- G35-C Natural Gas Compressor and/or Dehydration Facility 14.3. 370f38 Testing Requirements 14.3. I. The registrant shall sample wet natural gas in accordance with the Gas Processor Association (GP A) Method 2166 and analyze the samples in accordance with GP A Method 2286. The registrant may utilize other equivalent methods provided they are approved in advance by DAQ as part of a testing protocol. If alternative methods are proposed, a test protocol shall be submitted for approval no later than 60 days before the scheduled test date. Note: The DAQ defines a representative wet gas sample to be one that is characteristic of the average gas composition dehydrated throughout a calendar year. If an isolated sample is not indicative of the, annual average composition, then a company may opt to produce a weighted average based on throughput bet\Veen multiple sampling events, which can be used to define a more representative average annual gas composition profile. 14.4. Recordkeeping Requirements 14.4.1. The registrant shall maintain records of the quarterly dry natural gas throughput through the glycol dehydrationunit(s), all monitoring data, wet gas sampling, and GRI-GLYCalc™ emission estimates. Said records shall be maintained in accordance with section 3.5.1 of this general permit. 14.5. Reporting Requirements 14.5.1. The registrant shall submit the wet gas analysis report required by section 14.2 of this general permit within 60 days of conducting the sampling of the wet gas stream as required. This report .shall include a potential to emit (PTE) estimate using GRI-GlyCalc Version 3.0 or higher, incorporating the specific parameters measured, as well as a copy of the laboratory analYS.is. 14.5.2. If the results of the compliance determination conducted as required in Section 14.2 of this general permit predict the emissions to be at or above 95% of HAPs major source levels or 0.95 tons per year of benzene, the registrant shall submit such determination and all supporting documentation to the Secretary within 15 days after making such determination. West Virginia Depaliment of Environmental Protection' Division of Air Quality -37- G35-C Natural Gas Compressor and/or Dehydration Facility 380f38 CERTIFICATION OF DATA ACCURACY I, the undersigned, hereby certify that, based on information and belief formed after reasonable inquiry, all information contained in the attached _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , representing the period beginning ____________ and ending _ _ _ _ _ _ _ _ _ _ _ , and any supporting documents appended hereto, is true, accurate, and complete. Signature I (plense lise blue ink) Responsible OlliciaJ or. \ulhorized Rcprescntnti\,e Dale Name & Title (please print or type) Title Name F~No. Telephone No. This form shall be signed by a a. "R~sponsible __________________________ Official." "Responsible Official" means one of the following: For a corporation: The president, secretary, treasurer,' or vice-president of the corporation in charge of a principal business function, or any other person who perfonns similar policy or decision-making functions for the corporation, or a duly authorized representative of such person if the representative is responsible for the overall operation of one or more manufacturing, production, or operating facilities applying for or subject to a permit and either: (i) the facilities employ more than 250 persons or have a gross annual sales or expenditures exceeding $25 million (in second quarter 1980 dollars), or (ii) the delegation of authority to such representative is approved in advance by the Director; b. For a partnership or sole proprietorship: a general partner or the proprietor, respectively; c. For a municipality, State, Federal, or other public entity: either a principal executive officer or ranking elected official. For the purposes of this part, a principal executive officer of a Federal agency includes the chief executive officer having responsibility for the overall operations of a principal geographic unit of the agency (e.g., a Regional Administrator of U.S. EPA); or d. The designated representative delegated with such authority and approved in advance by the Director. West Virginia Department of Environmental Protection· Division of Air Quality -38- west virginia department of environmental protection Division of Air Quality 601 57th Street SE Charleston, WV 25304 Phone (304) 926-0475· FAX: (304) 926-0479 Earl Ray Tomblin, GovemQr Randy C. Huftinan, Cabinet Secretary www.dep.wv.gov GENERAL PERMIT G35-C ENGINEERING EVALUATION I FACT SHEET BACKGROUND INFORMATION General Pennit No.: Class II General Permit G35-C (Prevention and Control of Air Pollution in regard to the Construction, Modification, Relocation, Administrative Update and Operation of Natural Gas Compressor andlor Dehydration Facilities) The Secretary may develop and issue Class I and Class II general pennits under 45CSR13 authorizing the construction, modification or relocation of a category of sources by the same owner or operator or involving the same or similar processes or pollutants upon the tenns and conditions specified in the general pennit. Eligible SIC and NAICS Codes: NAICSCode SIC Code 211111 213112 221210 486210 1311 1382,1389 4923 4922 Engineer Assigned: . G35-C Registration Fee Amount: Description Crude Petroleum and Natural Gas Extraction Support Activities for Oil and Gas Operations Natural Gas Distribution . Pipeline Transportation of Natural Gas Jerry Williams, P .E. $500 (Construction, Modification, and Relocation) $300 (Class II Administrative Update) $1,000 NSPS fee for 40 CFR60, Subpart 1111 1 $1,000 NSPS fee for 40 CFR60, Subpart JJJJ 1 $1,000 NSPS fee for 40 CFR60, Subpart 0000 I $2,500 NESHAP fee for 40 CFR63, Subpart ZZZZ 2 $2,500 NESHAP fee for 40 CFR63, Subpart HH 2 I Only one NSPS fee will apply. 2 Only one NESHAP fee will apply. The Subpart ZZZZ NESHAP fee will be waived for new engines that satisfy requirements by complying with NSPS, Subparts nn and/or JJJ1. NSPS and NESHAP fees apply to new construction and modified. Promoting a healfhy environment. -39- if the source is being Description: General Permit G35-C replaces previously noticed General Permit G35-8 with the inclusion of language to address potential noise and light issues. This language can be found in Section 3.2.8. General Permit G35-C is for natural gas compressor and/or dehydration facilities. Currently, General Permit G30-D and G35-A cover natural gas compressor and/or dehydration facilities. These General Permits will continue to exist, however, there will be no future registrations, modifications, or administrative updates allowed to registrations issued under these permits. If a registrant wishes to modify an existing registration under General Permits G30-D or G35-A, it must be done so under General Permit G35-C. General Permit G35-C activities may include: Natural gas compressor station activiiies are reciprocating internal combustion engine driven compressor(s) or combination of equipment (including but not limited to compressor engines, emergency standby generators, engine driven air compressors, boilers, line heaters, tanks, glycol dehydration units, air pollution control devices, etc.) that supplies energy to move natural gas at increased pressure from gathering systems, in transmission pipelines or into storage. The permission/approval for Gas Well Drilling is .not part of this general permit and is handled by the WV DEP, Office of Oil and Gas. General Permit G35-C terms and conditions are the same for all facilities that receive a registration to General Permit G35-C. General Permit G35-C allows registrants to install and operate specified equipment, air pollution control devices and/or emission reduction devices to control emissions of regulated pollutants into the air. Each General Permit G35-C registration will list all emission units, air pollution control devices and/or emission reduction devices and will specify which sections of the general permit are applicable to the particular facility based on equipment that will be operated at that facility. General Permit G35-C registration will also include the emission limits and throughputs for the emission units. General Permit G35-C will undergo public notice prior to being issued. The public notice will appear in the Charleston Gazette, Dominion Post (Morgantown), Herald Dispatch (Huntington), IntelligenceI' (Wheeling), Parkersburg News, Exponent/Telegram (Clarksburg), Journal (Martinsburg), Herald Record (Doddridge County), Wetzel Chronicle (Wetz~l County), Moundsville Daily Echo (Marshall County), and The State Register consistent with other General Permit public notices. Page 2 of 19 -40- EMISSION SOURCES AND G35-C GENERAL PERMIT ELIGIBILTY Emission units at eligible oil and natural gas production, compressor and/or dehydration facilities may include any of the following pieces of equipment: • Storage vessel affected facility(ies) • Natural gas driven pneumatic controller affected facility(ies) • Natural gas in-line heater(s) • Natural gas production unites) (GPU) • Natural gas heater treater(s) • Low pressure tower(s) • Tanker truck loading facility(ies) • Reciprocating internal combustion engine(s) (RICE) (including emergency) • Glycol dehydration unites) and associated reboiler(s) • Reciprocating compressor(s) • Centrifugal compressor(s) . • Generator engine(s) There may be other small storage tanks located at the site for the storage of freeze protection materials and lubricants. These units shall be listed in the registration application and will be included in the issued registration document. Air pollution control and emission reduction devices may include: • Completion combustion devices • Enclosed combustimi devices including thermal vapor incinerators, catalytic vapor incinerators, boilers, and process heaters • Flares • Vapor recovery devices including carbon adsorption systems and condensers • Post-combustion catalytic control technologies for reciprocating internal combustion engines: Rich-bum engine with Nonselective Catalytic Reduction (NSCR); Lean-burn engine with Selective Catalytic Reduction (SCR); Lean-bum engine with Catalytic Oxidation For the purposes of General Permit G35-C, a natural gas compressor station means any reciprocating internal combustion engine driven compressor(s) or combination of equipment (including but not limited to compressor engines, emergency standby generators, engine driven air compressors, boilers, line heaters, tanks, etc.) that supplies energy to move natural gas at increased pressure from gathering systems, in transmission pipelines or into storage. Engine me,ans any natural gas compressor engine, emergency standby engine or air compressor engine located at a natural gas compressor station. This does not include permitting for or approyal of the natural gas well drilling that is handled by the Office of Oil and Gas. Page 3 of 19 -41- All natural gas compressor andlor dehydration facilities designed and operated for the purpose of gathering, transmitting, or compressing natural gas and are included in the following NArcs andlor SIC Codes are eligible for General Permit Registration except for those instances listed in items 1-7 below: NAICS Code SIC Code 211111 1311 213112 1382, 1389 221210 486210 4923 4922 Description Crude Petroleum and Natural Gas Extraction Support Activities for Oil and Gas Operations Natural Gas Distribution Pipeline Transportation of Natural Gas 1. Any natural gas compressor andlor dehydration facility which is a major source of pollutants as defined in 45CSR14, 45CSR19, or 45CSR30. 2. Any natural gas compressor andlor dehydration facility that is located in Putnam County, Kanawha County, Cabell County, Wayne County, or Wood County and is required by 45CSR21 to conduct a Reasonably Available Control Technology (RACT) Analysis andlor subject to 45CSR21 Section 29 (Leaks from Natural Gas/Gasoline Processing Equipment). 3. Any natural gas processing plant (e.g. production of ethane, propane, butane, and pentane) as defined in 40 CFR §60.5430. 4. Any natural gas sweetening plant. 5. Any natural gas compressor andlor dehydration facility with a storage tank subject to NSPS, Subpart Kb. 6. Any steam generating unit (as defined in §60.41c) subject to NSPS, Subpart Dc. (>10 MMBTU/hr). 7. Any turbine subject to NSPS, Subpart KKKK. 8. Any natural gas compressor andlor dehydration facility which will require an individual air quality permit review process andlor individual permit provisions to address the emission of a regulated pollutant or to incorporate regulatory requirement(s) other than those established by General Permit G35-C. This would include "synthetic minor" permitting actions, as they are required to undergo Notice Level C under 45CSR13 Section 8.5. Page 4 of 19 -42- SITE INSPECTION All persons submitting a G35-C General Permit Registration Application to construct, modify or relocate a natural gas compressor and/or dehydration facility shall be subject to the following siting criteria: • No emission unit shall constructed, located or relocated within three hundred (300) feet of any occupied dwelling, business, public building, school, church, community building, institutional building or public park. An owner of an occupied dwelling or business may elect to waive the three hundred (300) foot siting criteria. • Any person proposing to construct, modify or relocate any emission unites) within three (300) feet of any occupied dwelling, business, public building, school, church, community, institutional building or public park may elect to obtain an individual permit pursuant to 45CSR13. The registrant shall allow any authorized representative ofthe Secretary, upon the presentation of credentials and other documents as may be required by law, to perform the following: • At all reasonable times, enter upon the registrant's premises where a source is located or emissions related activity is conducted, or where records must be kept under the conditions of this permit. • Have access to and copy, at reasonable times, any records that must be kept under the conditions of this General Permit. • Inspect, at reasonable times, any facilities, equipment (including monitoring, air pollution control devices and emission reduction devices), practices, or operations regulated or required under this General Permit. • Sample or monitor, at reasonable times, substances or parameters to determine compliance with the permit or applicable requirements, or ascertain the amounts and types of air pollutants discharged. ESTIMATE OF EMISSIONS BY REVIEWING ENGINEER Sources of emissions at eligible natural gas compressor and/or dehydration facilities may include pneumatic controllers, GPUs, heater treaters, RICEs, generators (including emergency), glycol dehydration units, storage tanks, truck loading facilities, vapor recovery units, vapor combustors, and other specified control or emission reduction devices. Sources of fugitive emissions may include loading operations, haul road emissions, equipment leaks, and blowdown emissions. An estimate ofthe maximum potential emissions of regl;llated air pollutants must be submitted with each General Permit G35-C registration application. Applicants are required to submit emission estimates and supporting calculations for each emission point and for the fugitive emissions at the facility. These emissions will be reviewed by the assigned DAQ permit engineer to determine if the registrant meets the requirements of Page 5 of 19 -43- General Pennit G35-C prior to recommending whether or not the general permit registration should be issued. Each General Permit G35-C registration application must include the basis of the emission calculations used to determine the potential emissions (i.e. manufacturer's data, GlyCalc, AP-42, ProMax, E&P Tanks, HYSYS, USEP A Tanks, etc.). The maximum potential emissions after controls shall not equal or exceed 100 tons per year of any regulated air pollutant, 10 tons per year of any hazardous air pollutant (HAP), or 25 tons per year of any combination of hazardous air pollutants (HAPs). CONTROL DEVICES AND EMISSION COLLECTION EFFICIENCIES Applicants are required to submit all technical data for control devices and emission reduction devices that are used for the supporting calculations for each emissions point and for each type of fugitive emissions at the facility. The following control device and emission collection efficiencies will be allowed under General Permit G35-C and all requirements are detailed in Section 7.0 of General Permit G35-C, including requirements for closed vent systems: Flares All flares that meet the control device requirements under 40CFR Subpart 60.18 may claim a destruction efficiency of98% for VOCs and HAPs. Vapor Combustors and flares that do not meet the requirements under 40CFR Subpart 60.18 must be non-smoking and may claim a destruction efficiency of 98% for VOCs and HAPs. Enclosed Combustion Devices All enclosed combustion control devices meeting the requirements outlined in Section 7.0 of General Permit G35-C may claim a capture and control efficiency of98% for VOCs and HAPS. Vapor Recovery Units • The registrant may claim a capture and control efficiency of95% (which accounts for 5% expected downtime). • The registrant may claim a capture and control efficiency of98% if the VRU has a backup flare that meet the requirements of section 7.1.2 of this general permit. • The registrant may claim a capture and control efficiency of98% if the VRU has a backup VRU. Carbon Adsorption Systems All carbon adsorption systems meeting the requirements outlined in Section 7.0 of General Permit G35-C may claim a control efficiency of98% for VOCs and HAPS. Condensers Any condenser that is utilized under Section 7.0 of General Permit G35-C must have supporting data submitted with the registration application to support the claimed control device efficiency above 50%. Page 6 of 19 -44- Truck Loadout Collection Efficiencies The following applicable capture efficiencies of a truck loadout are allowed: • • • For tanker trucks not passing one of the annual leak tests in G35-C - 70% For tanker trucks passing the NSPS level annual leak test - 98.7% For tanker trucks passing the MACT level annual leak test - 99.2% Compliance with this requirement shall be demonstrated by keeping records of the applicable MACT or NSPS Annual Leak Test certification for every truck loaded/unloaded. This requirement can be satisfied if the trucking company provided certification that its entire fleet was compliant. This certification must be submitted in writing to the Director of the DAQ. SOURCE AGGREGATION DETERMINATION Applicants for the General Permit G35-C registration will be required to complete the Single Source Determination form which is part ofthe General Permit G35-C application. This completed form allow the DAQ to make a determination as to whether or not the facility is a single source. will "Building, structure, facility, or installation" is defined as all the pollutant emitting activities which belong to the same industrial grouping, are located on one or more contiguous and adjacent properties, and are under the control ofthe same person. REGULATORY APPLICABILITY The following state and federal regulations may apply to sources requesting registration under General Permit G35-C: State Regulations: 45CSR2 (To Prevent and Control Particulate Air Pollution From Combustion of Fuel in Indirect Heat Exchangers) 45CSR2 establishes emission limitations for smoke and particulate matter that are discharged from fuel burning units. Sources subject to 45CSR2 include GPUs, in-line heaters, heater treaters, and glycol dehydration reboilers. Registered fuel burning units may be subject to the weight emission standard for particulate matter set forth in 45CSR2-4.1. The particulate matter emission standard set forth in 45CSR2 is generally less stringent than the potential emissions from the fuel burning unit utilizing natural gas; therefore, only the potential emissions from the fuel burning unit will be included in the general permit registration. Each registrant is subject to the opacity requirements set forth in 45CSR2, Section 3.1. The G80A general permit includes the opacity limit along with the monitoring, recordkeeping, and reporting requirements in Section 8.0. Page 7 of 19 -45- 45CSR4 (To Prevent and Control the Discharge of Air Pollutants into the Open Air which Causes or Contributes to an Objectionable Odor or Odors) 45CSR4 states that an objectionable odor is an odor that is deemed objectionable when in the opinion of a duly authorized representative of the Air Pollution Control Commission (Division of Air Quality), based upon their investigations and complaints, such odor is objectionable. All facilities are inspected by the DAQ Enforcement Section. The facility-wide requirements of the . general permit include the odor standards of 45CSR §4-3.1. 45CSR6 (To Prevent and ControlAir Pollution from the Combustion of Refuse) 45CSR6 prohibits open burning, establishes emission limitations for particulate matter, and establishes opacity requirements. Sources subject to 45CSR6 include completion combustion devices, enclosed combustion devices, and flares. The facility-wide requirements of the general permit iriclude the open burning limitations §§456-3.1 and 3.2. All completion combustion devices, enclosed combustion devices, and flares are subject to the particulate matter weight emission standard set forth in §45-6-4.1; the opacity requirements in §§45-6-4-3 and 4-4; the visible emission standard in §45-6-4.5; the odor standard in §45-64.6; and, the testing standard in §§45-6-7.l and 7.2. Enclosed combustion control devices and flares that are used to comply with emission standards ofNSPS, Subpart 0000 are subject to design, operational, performance, recordkeeping and reporting requirements of the NSPS regulation that meet or exceed the requirements of 45CSR6. 45CSRIO (To Prevent and Control Air Pollution from the Emission of Sulfur Oxides) 45CSRlO establishes emission limitations for S02 emissions which are discharged from stacks of fuel burning units. A "fuel burning unit" means and includes any furnace, boiler apparatus, device, mechanism, stack or structure used in the process of burning fuel or other combustible material for the primary purpose of producing heat or power by indirect heat transfer. Sources that meet the definition of "Fuel Burning Units" per 45CSRlO-2.8 include GPUs, in-line heaters, heater treaters, and glycol dehydration unit reboilers. Fuel burning units. less than 10 MMBtu/hr are exempt. The sulfur dioxide emission standard set fOlth in 45CSR lOis generally less stringent than the potential emissions from a fuel burning unit for natural gas. The S02 emissions from fuel burning units will be listed in the G35-C permit registration at the discretion of the permit engineer on a case-by-case· basis. Issues such as nonattainment designation, fuel use~ and amount of sulfur dioxide emissions will be factors used in this determination. Fuel 'burning units burning natural gas are exempt from Section 8 (Monitoring, Recording and Reporting) as well as interpretive rule lOA. The G35-C eligibility requirements exclude from eligibility any fuel burning unit that does not use natural gas as the fuel; therefore, there are no permit conditions for 45CSRI O. Page 8 of 19 -46- 45CSR13 (Permits for Construction, Modification, Relocation and Operation of Stationary Sources of Air Pollutants, Notification Requirements, Administrative Updates, Temporary Permits, General Permits, and Procedures for Evaluation) As provided in 45CSR13 §5.12, the Secretary may develop and issue Class I and Class II general permits under this rule authorizing the construction, modification, relocation, and operation of a category of sources by the same owner or operator or involving the same or similar processes or pollutants upon the terms and conditions specified in the general permit. The designation of Class I or Class II for a general permit is made at the time the permit goes through public comment and adoption for the source category governed by the general permit. The designation for General Permit G35-C is Class II. The scope of General Permit G35-C is for minor stationary sources that are not subject to 45CSR14, 45CSR19, or 45CSR30. The general conditions of Section 2.0 and the facility-wide requirements of Section 3.0 of General Permit G35-C include the authority and other general provisions of 45CSR13. The G35-C Class II General Permit will undergo public notice in accordance with the Notice Level B provisions of subsection 8.4 and in accordance with 45CSR13 §8.9. At the time that an application for a Class II general permit registration is submitted by the applicant, the applicant shall place a Class I legal advertisement in a newspaper of general circulation in the area where the source is or will be located. No such general permit registration shall be issued to any applicant until at least thirty (30) days notice has been provided to the public in accordance with the requirements of 45CSR13 §8.3 for Notice Level A. Class II general pennit registrations are subject to a $500 application fee and any applicable additional fees under the provisions of subdivision 3.4.b of 45CSR22 in accordance with 45CSR13 § 12.1. The possible additional fees are a $1,000 NSPS fee for applicants subject to NSPS requirements and a $2,500 NESHAP fee for applicants subject to NESHAP requirements. For eligible registrants, General Permit G35-C Registration satisfies the construction, modification, relocation and operating permit requirements of 45CSR13. General Permit G35-C sets forth reasonable conditions that enable eligible registrants to establish enforceable permit limits. Section 5 of 45CSR 13 provides the permit application and reporting requirements for construction of and modifications to stationary sources. No person sha!l cause, suffer, allow or permit the construction, modification, relocation and operation of any stationary source to be commenced without notifying the Secretary of such intent and obtaining a permit to construct, modify, relocate and operate the stationary source as required in the rule or any other applicable rule promulgated by the Secretary. Stationary source means, for the purpose of this rule, any building, structure, facility, installation, or emission unit or combination thereof, excluding any emission unit which meets or falls below the criteria delineated in Table 45-13B which: (a) is subject to any substantive requirement of an emission control rule promulgated by the Secretary; (b) discharges or has the potential to discharge more than six .C6) pounds per hour and ten (10) tons per year, or has the Page 9 of 19 -47- potential to discharge more than 144 pounds per calendar day of any regulated air pollutant; (c) discharges or has the potential to discharge more than two (2) pounds pt;:r hour or five (5) tons per year of hazardous air pollutants considered on an aggregated basis; (d) discharges or has the potential to discharge any air pollutant(s) listed in Table 45-13A in the amounts shown in Table 45-13A or greater; or, (e) an owner or operator voluntarily chooses to be subject to a construction or modification permit pursuant to this rule, even though not otherwise required to do so. 45CSR16 (Standards of Performance for New Stationary Sources Pursuant to 40 CFR Part 60) 45CSR16 applies to all registrants that are subject to any of the NSPS requirements described in more detail in the Federal Regulations section. Applicable requirements ofNSPS, Subparts nn, JJJJ and 0000 are included in General Permit G35-C. Excluded from General Permit G35-C eligibility are any sources that are subject to NSPS, Subparts Dc, Kb, KKK, LLL, or KKKK. 45CSR22 (Air Quality Management Fee Program) 45CSR22 is the program to collect fees for certificates to operate and for permits to construct or modify sources of air pollution. 45CSR22 applies to all registrants. The general permit application fee of $500 is required in 45CSR13 Section 12.1. In addition to the application fee, all applicants subject to NSPS requirements or NESHAP requirements shall pay additional fees of$l,OOOand $2,500, respectively. Registrants are also required to obtain and have in effect a valid certificate to operate in accordance with 45CSR22 §4.1. The fee group for General Permit G35-C is Group 8D (natural gas compressor stations greater than 1,000 HP) with an annual operating fee of $500 or 9M (all other sources) with an annual,operating fee of$200. 45CSR34 (Emission Standards for Hazardous Air Pollutants) 45CSR34 applies to any registrant that is subject to the area source requirements of 40 CFR 63, Subpart ZZZZ or Subpart HH, described in more detail in the Federal Regulations section. WVDAQ does have delegation of the area source requirements of these SUbparts. 45CSR34 applies to all registrants that are subject to any of the NESHAP requirements. Applicable area source requirements ofNESHAP, Subpart HH and ZZZZ are ineluded in General, Permit G35-C. Excluded from General Permit G35-C eligibility are any sources that are subject to NESHAP Subpart HHH. Page 10 of 19 -48- Federal Regulations: 40CFR60 Subpart 1111 (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines) Subpart nn sets forth non-methane hydrocarbon (NMHC), hydrocarbon (HC), nitrogen oxides (NOx), carbon monoxide (CO), and particulate matter (PM) emission limits, fuel requirements, . installation requirements, and monitoring requirements based on the year of installation ofthe subject internal combustion engine. The provisions for stationary compression ignition (CI) internal combustion engines for owners or operators of this Subpart have been included in General Permit G35-C, Section 12.0. 40CFR60 Subpart JJJJ (Standards of Performance for Stationary Spark Ignition Internal Combustion Engines) Subpart JJJJ sets forth nitrogen oxides (NOx), carbon monoxide (CO), and volatile organic compound (VOC) emission limits, fuel requirements, installation requirements, and monitoring requirements based on the year of installation of the subject internal combustion engine. The provisions for stationary spark ignition (Sr) internal combustion engines for owners or operators ofthis subpart have been included in General Permit G35-C, Section 12.0. 40CFR60, Subpart 0000 (Standards of Performance for Crude oil and Natural Gas Production, Transmission and Distribution) EPA published its new source performance standards (NSPS) and air toxics rules for the oil and gas sector on August 16, 2012. EPA published final amendments to the subpart on September 23,2013. 40CFR60 Subpart 0000 establishes emission standards and compliance schedules for the control of volatile organic compounds (VOC) and sulfur dioxide (S02) emissions from affected facilities that commence construction, modification or reconstruction after August 23,2011. The affected sources which commence construction, modification or reconstruction after August 23, 2011 are subject to the applicable provisions of this Subpart as described below: a. Each gas well affected facility. Gas well affected facilities are not covered in General Permit G35-C and all applicable requirements are listed in General Permit G70-B. h. Each centrifugal compressor affected facility, which is a single centrifugal compressor using wet seals that is located between the wellhead and the point of custody transfer to the natural gas transmission and storage segment. A centrifugal compressor located at a well site, or an adjacent well site and servicing more than one well site, is not an affected facility under this subpart. Centrifugal compressor affected facilities are included in General Permit G35-C, Section 10.0. Page 11 of 19 -49- c. Each reciprocating compressor affected facility, which is a single reciprocating compressor located between the wellhead and the point of custody transfer to the natural gas transmission and storage segment. A reciprocating compressor located at a well site, or an adjacent well site and servicing more than one well site, is not an affected facility under this subpart. Reciprocating compressor affected facilities are included in General Permit G35-C, Section 11.0. d. For the natural gas production segment (between the wellhead and the point of custody transfer to the natural gas transmission and storage segment and not including natural gas processing plants), each pneumatic controller affected facility, which is a single continuous bleed natural gas-drivc:;n pneumatic controller operating at a natural gas bleed rate greater than 6 scth. Pneumatic controllers affected facilities are included in General Permit G35-C, Section 9.0. e. Each storage vessel affected facility, which is a single storage vessel located in the oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment, and has the potential for VOC emissions equal to or greater than 6 tpy as determined according to this section by October 15,2013 for Group 1 storage vessels and by April 15, 2014, or 30 days after startup (whichever is later) for Group 2 storage vessels. A storage vessel affected facility that subsequently has its potential for VOC emissions decrease to less than 6 tpy shall remain an affected facility under this subpart. Requirements for storage vessel affected facilities are included in General Permit G35-C, Section 6 ..0. Determination of storage vessel affected facility status is included in Section 5.0 of General Permit G35-C. f. Processing units and sweetening units are outside the scope of General Permit G35-C and are excluded from applicability for the general permit. 40CFR63 Subpart HR (National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities) This Subpart applies to owners and operators of each triethylene glycol (TEG) dehydration unit that is located at oil and natural gas production facilities. Only area source requirements are included in General Permit G35-C, as defined in §63.761. For area source applicability, the affected source includes each trietheylene glycol (TEG) dehydration unit located at a facility that meets the criteria specified in §63.760(a). Glycol dehydration unit affected facilities are included in General Permit G35-C, Section 14.0. Page 12 of19 -50- 40CFR63 Subpart ZZZZ (National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) Subpart ZZZZ establishes national emission limitations and operating limitations for hazardous air pollutants (HAPs) emitted from stationary reciprocating internal combustion engines (RICE) located at major and area sources of HAP emissions. This Subpart also establishes requirements to demonstrate initial and continuous compliance with the emission limitations and operating limitations. This section reflects EPA's final amendments to 40 CFR Part 63, Subpart ZZZZ that were issued on January 15,2013 and published in the Federal Register on January 30,2013. WVDEP DAQ has delegation of the area source air to·xics provisions of this Subpart requiring Generally Achievable Control Technology (GACT). The provisions of this Subpart have been included in this general pennit under Section 12.0. REGULATORY NON-APPLICABILITY The following state and federal regulations were reviewed but do not apply to General Permit G35-C: 45CSR14 (Permits for Construction and Major Modification of Major Stationary Sources for the Prevention of Significant Deterioration of Air Quality) The G35-C applicability criterion excludes facilities that meet the definition of a major source as defined in 45CSR14 from being eligible for the general permit. 45CSR19 (Permits for Construction and Major Modification of Major Stationary Sources of Air Pollution which Cause or Contribute to Nonattainment) TheG35-C applicability criterion excludes facilities that meet the definition of a major source as defined in 45CSR19 from being eligible for the general permit. 45CSR21 (Regulation to Prevent and Control Air Pollution from the Emissions of Volatile Organic Compounds) It is the intent Qf the Director that all persons engaged in the manufacture, mixing, storage, use, or application of volatile organic compounds control the emissions of volatile organic compounds through the application of reasonable available control technology (RACT). This regulation applies to sources located in Putnam County, Kanawha County, Cabell County, Wayne County, and Wood County. Section 40 (Other Facilities that Emit Volatile Organic Compound (VOC) applies to any facility that has aggregate maximum theoretical emissions of 100 tons or more of VOCs per calendar year in the absence of control devices. Any source at a facility subject to Section 40 that has maximum theoretical emissions of 6 pounds per hour or more must comply with a control plan developed on a case-by-case basis that meets the definition of RACT. Page 13 of 19 -51- Any natural gas production, compressor and/or dehydration facility that is located in Putnam County, Kanawha County, Cabell County, Wayne County, or Wood County and is required by 45CSR21, Sectiori 40 to conduct a RACT Analysis and/or subject to 45CSR21 Section 29 (Leaks from Natural Gas/Gasoline Processing Equipment) is excluded from General Permit G35-C applicability; therefore, this rule does not apply. 45CSR30 (Requirements for Operating Permits) The G35-C applicability criterion excludes facilities that meet the definition of a major source from being eligible for the general permit. Certain spark ignition internal combustion engines may be subject to NSPS Subpart IIII or JJJJ; however, NSPS Subparts IIII or JJJJ are exempt from Title V permitting for minor sources. Affected facilities that commence construction, modification or reconstruction after August 23, 2011 are subject to NSPS, Subpart 0000; however, NSPS, Subpart 0000 is exempt from Title V permitting for minor sources. Certain spark ignitionintemal combustion engines may be subject to 40 CFR 63, Subpart ZZZZ as area sources; however, area sources subject to 40 CFR 63, Subpart ZZZZ are exempt from Title V permitting. Certain area source TEO dehydration units may be subject to 40 CFR 63, Subpart HH; however, area sources subject to 40 CFR 63, Subpart HH are exempt from Title V permitting. 40CFR60.18 (General control device and work practice requirements) The requirements apply only to flares that are required for compliance to an NSPS Standard. Completion combustion devices and enclosed combustion devices used for compliance to NSPS, Subpart 0000 do not meet the definition of a flare, as it is defined in that subpart. Therefore, this rule does not apply to General Permit G35-C unless the applicant states in their general permit application that they are meeting the requirements of §60.18 for flares. 40CFR60, Subpart Dc (Standards of Performance for Small Industrial-CommercialInstitutional Steam Generating Units) Subpart Dc applies to each steam generating unit for which construction, modification, or reconstruction is commenced after June 9, 1989 and that has a maximum design heat input capacity of 100 MMBtulhr or less, but greater than or equal to 10 MMBtu/hr. Any steam generating unit facility (as defined in §60.41c) is excluded from eligibility to General Permit G35-C Steam generating unit means a device that combusts any fuel and produces steam or heats water or heats any heat transfer medium. This term includes any duct burner that com busts fuel and is part of a combined cycle system. This tt~1m does not include process heaters, as defined in this subpart. Process heater means a device that is primarily used to heat a material to initiate or promote a chemical reaction in which the material participates as a reactant or catalyst. . Page 14 of 19 -52- 40CFR60, Subpart Kb (Standards of Performance for VOC Liquid Storage Vessels for which construction, reconstruction,or modification commenced after July 23,1984) Subpart Kb establishes control requirements, testing requirements, monitoring requirements, and recordkeeping and reporting requirements. Subpart Kb applies to any storage vessel with a capacity greater than 19,313 gallons that is used to store volatile organic liquids except that it does not apply to storage vessels with a capacity greater than 39,890 gallons storing a liquid with a maximum true vapor pressure less than 3.5 kPa or with a capacity greater than 19,813 gallons but less than 39,890 gallons storing a liquid with a maximum true vapor pressure less than 15.0 kPa. This Subpart does not apply to vessels with a design capacity less than or equal to 419,204 gallons used for petroleum or condensate stored, processed, or treated prior to custody transfer. Condensate means hydrocarbon liquid separated from natural gas that condenses due to changes in the temperature or pressure, or both, and remains liquid at standard conditions. Any natural gas production, compressor and/or dehydration facility that is subject to NSPS, Subpart Kb is excluded from eligibility to General Permit G35-C. 40CFR60 Subpart KKK (Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants for which construction, reconstruction, or modification commenced after January 20,1984 and on or before August 23,2011) Natural Gas Processing Plants are excluded from General Permit G35-C applicability. Natural gas processing plants were excluded to focus the scope of General Permit G35-C on activities typically conducted at natural gas production, compressor andlor dehydration facilities. Based on the Rule 13 pennit applications for new natural gas production, compressor and/or dehydration facilities that WV DAQ has received thus far, this exclusion should not be a concern. Furthermore, any new natural gas processing plant would be constructed, reconstructed,. or modified after August 23, 2011 and would no longer be subject to NSPS, Subpart KKK. Requirements for natural gas processing plants constructed, reconstructed, or modified after August 23, 2011 are covered by NSPS, Subpart 0000. This rule, therefore, does not apply to General Pennit G35-C. 40CFR60, Subpart LLL (Standards of Performance for S02 Emissions From Onshore Natural Gas Processing for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011) Natural Gas Sweetening Units are excluded from General Permit G35-C applicability. Natural gas processing plants and sweetening units were excluded from General Pennit G35-C. Based on the Rule 13 permit applications for new natural gas production, compressor and/or dehydration facilities that WV DAQ has received thus far, this exclusion should not be a concern. Furthermore, any new natural gas processing plant or sweetening unit would be constructed, reconstructed, or modified after August 23, 2011 and would no longer be subject to NSPS, Subpart LLL. Requirements for natural gas processing plants and sweetening units constructed, reconstructed, or modified after August 23, 2011 are covered by NSPS, Subpart 0000. This rule, therefore, does not apply to General Pennit G35-C. Page 15 of 19 -53- 40CFR60, Subpart KKKK (Standards of Performance for Stationary Combustion Turbines) 40CFR60 Subpart KKKK does not apply because stationary combustion turbines with a heat input at peak load equal to or greater than 10 MMBTUlhr, based on the higher heating value of the fuel (§60.4305) are not covered by this General Permit. This rule, therefore, does not apply to General Permit G35-C. 40CFR63 Subpart HHH (National Emission Standards for Hazardous Air Pollutants: Natural Gas Transmission and Storage) This subpart applies to owners and operators of natural gas transmission and storage facilities that transport or store natural gas prior to entering the pipeline to a local distribution company or to a final end user (if there is no local distribution company), and that are major sources of hazardous air pollutants (HAP) emissions as defined in §63.1271. General Permit G35-C excludes major sources from registration. Therefore, this rule does not apply to General Permit G35-C. TOXICITY OF NON-CRITERIA REGULATED POLLUTANTS Small amounts of non-criteria regulated hazardous air pollutants such as benzene, toluene, and formaldehyde may be emitted when natural gas is combusted in reciprocating engines, combusted in the fuel burning units, or combusted in one of the combustion type air pollution control devices. All natural gas production, compressor and/or dehydration facilities that are issued a General Pennit G35-C registration by the Director will be limited to those that are classified as minor sources of hazardous air pollutants; Minor sources of hazardous air pollutants are defined as those that have a potential to emit of less than 10 tons per year of any hazardous air pollutant or less than 25 tons per year of any combination of hazardous air pollutants. Listed below is information regarding each of the possible hazardous air pollutants. BTEX BTEX is the term used for benzene, toluene, ethylbenzene, and xylene. Each of these possible hazardous air pollutants are identified in this section. Benzene Benzene is found in the air from emissions from burning coal and oil, gasoline service stations, and motor vehicle exhaust. Acute (sh0l1-term) inhalation exposure of humans to benzene may cause drowsiness, dizziness, headaches, as well as eye, skin, and respiratory tract ilTitation, and, at high levels, unconsciousness. Chronic (long-term) inhalation exposure has caused various disorders in the blood, including reduced numbers of red blood cells and aplastic anemia, in occupational settings. Reproductive effects have been reported for women exposed by inhalation to high levels, and adverse effects on the developing fetus have been observed in animal tests. Increased incidence of leukemia (cancer of the tissues that form white blood cells) have been Page 16 of 19 -54- observed in humans occupationally exposed to benzene. EPA has classified benzene as a Group A, human carcinogen. Toluene The acute toxicity of toluene is low. Toluene may cause eye, skin, and respiratory tract irritation. Short-term exposure to high concentrations of toluene (e.g., 600 ppm) may produce fatigue, dizziness, headaches, loss of coordination, nausea, and stupor; 10,000 ppm may cause death from respiratory failure. Ingestion of toluene may cause nausea and vomiting and central nervous system depression. 'Contact of liquid toluene with the eyes causes temporary irritation. Toluene is a skin irritant and may cause redness and pain when trapped beneath clothing or shoes; prolonged or repeated contact with toluene may result in dry and cracked skin. Because of its odor ~nd irritant effects, toluene is regarded as having good warning properties. The chronic effects of exposure to toluene are much less severe than those of benzene. No carcinogenic effects were reported in animal studies. Equivocal results were obtained in studies to determine developmental effects in animals. Toluene was not observed to be mutagenic in standard studies. Ethylbenzene Ethyl benzene is mainly used in the manufacturing of styrene. Acute (short-term) exposure to ethyl benzene in humans results in respiratory effects, such as throat irritation and chest constriction, irritation of the eyes, and neurological effects, such as dizziness. Chronic (longterm) exposure to ethyl benzene by inhalation in humans has shown conflicting results regarding its effects on the blood. Animal studies have reported effects on the blood, liver, and kidneys from chronic inhalation exposure to ethyl benzene. Limited information is available on the carcinogenic effects of ethyl benzene in humans. In a study by the National Toxicology Program (NTP), exposure to ethyl benzene by inhalation resulted in an increased incidence of kidney and testicular tumors in rats, and lung and liver tumors in mice. EPA has classified ethyl benzene as a Group D, not classifiable as to human carcinogenicity. Xylenes Commercial or mixed xylene usually contains about 40-65% m-xylene and up to 20% each of 0xylene and p-xylene and ethyl benzene. Xylenes are released into the atmosphere as fugitive emissions from industrial sources, from auto exhaust, and through volatilization from their use as solvents. Acute (short-term) inhalation exposure to mixed xylenes in humans results in irritation ofthe eyes, nose, and throat, gastrointestinal effects, eye irritation, and neurological effects. Chronic (long-term) inhalation exposure of humans to mixed xylenes results primarily in central nervous system (CNS) effects, such as headache, dizziness, fatigue, tremors, and incoordination; respiratory, cardiovascular, and kidney effects have also been reported. EPA has classified mixed xylenes as.a Group D, not classifiable as to human carcinogenicity. Mixed xylenes are used in the production of ethylbenzene, as solvents in products such as paints and coatings, and are blended into gasoline. Formaldehyde Formaldehyde is used mainly to produce resins used in particle board products and as an intermediate in the synthesis of other chemicals. Exposure to formaldehyde may occur by breathing contaminated indoor air, tobacco smoke, or ambient urban air. Acute (short-term) and chronic (long-term) inhalation exposure to formaldehyde in humans can result in respiratory symptoms, and eye, nose, and throat irritation. Limited human studies have reported an association between formaldehyde exposure and lung and nasopharyngeal cancer. Animal Page 170f19 -55- inhalation studies have reported an increased incidence of nasal squamous cell cancer. EPA considers formaldehyde a probable human carcinogen (Group Bl). n-Hexane n-Hexane is a solvent that has many uses in the chemical and food industries, either in pure form or as acomponent of commercial hexane. The latter is a mixture that contains approximately 52% n-hexane; the balance is made up of structural analogs and related chemicals such as methylpentane and methylcyclopentane. Highly purified n-hexane is used as a reagent for chemical or chromatographic separations. Other grades ofn-hexane are used as solvents for extracting edible fats and oils in the food industry and as a cleaning agent in the textile, furniture, and printing manufacturing industries. Hexane is the solvent base for many commercial products, such as glues, cements, paint thinners, and degreasers. n.,.Hexane is a minor constituent of crude oil and natural gas and occurs in different petroleum distillates. No data are available regarding the potential toxicity of n-hexane in humans orally exposed to n-hexane. However, as might be expected for a chemical with such wide application, the potential exists for persons to be environmentally and/or occupationally exposed to n-hexane via other routes of exposure. 2,2,4-Trimethylpentane 2,2,4-Trimethylpentane is released to the environment through the manufacture, use, and disposal of products associated with the petroleum and gasoline industry. During an accident, 2,2,4-trimethylpentane penetrated the skin of a human which caused necrosis of the skin and tissue in the hand and required surgery. No other information is available on the acute (shortterm) effects in humans. Irritation ofthe lungs, edema, and hemorrhage have been reported in rodents acutely exposed by inhalation and injection. No information is available on the chronic (long-term); reproductive, developmental, or carcinogenic effects of2,2,4-trimethylpentane in humans. Kidney and liver ,effects have been observed in rats chronically exposed via gavagt? (experimentally placing the chemical in the stomach) and inhalation. EPA has not classified 2,2,4-trimethylpentane with respect to potential carcinogenicity. AIR QUALITY IMP ACT ANALYSIS Air dispersion modeling may be performed when the Director finds existing circumstances and/or submitted data provide cause for an assessment to be made concerning whether a specific natural gas well production, compressor and/or dehydration facility may interfere with attainment or maintenance of an applicable ambient air quality standard or cause or contribute to a violation of an applicable air quality increment from any proposed General Permit Registration action. Factors to be considered when determining whether an ambient air assessment would be made include: a. b. c. d. Page 18 of 19 Existingair quality of the area Topographic or meteorological factors Maximum emissions Siting criteria -56- DEVELOPMENT OF GENERAL PERMIT G35-C General Permit G35-C was developed with the intention of being comprehensive to address the emission sources that are located at a stationary source oil and natural gas compressor and/or dehydration facility and to provide consistent requirements for facilities within this industry group. General Permit G35-C was developed to address the increasing volume of construction permits for natural gas compressor andlordehydration facilities. For affected facilities subject to federal air regulations, those sections of General Permit G35-C were developed based on the language from the federal regulations. For emission sources that are not subject to federal requirements, those sections of the general permit were developed based on language that is currently being used in 45CSR13 construction and modification permits to control air pollution at other natural gas production, compressor andlor dehydration facilities with the intention of providing consistent requirements across the industry group. All facilities registered under General Permit G35-C will be subject to Sections 1.0,2.0, 3.0, and 4.0 ofthe general permit. Each applicant will select the sections that they are seeking registration for under General Permit G35-C and will do so when they submit the -General Permit G35-C registration application: Section 5.0 Section 6.0 Section 7.0 Storage Vessels Containing Condensate andlor Produced Water Storage Vessel Affected Facility (NSPS, Subpart 0000) Control Devices and Emission Reduction Devices not subject to NSPS, Subpart 0000 Section 8.0 Section 9.0 Section 10.0 Section 11.0 Section 12.0 Section 13.0 -Section 14.0 Small Heaters and Reboilers not subject to 40CFR60 Subpart Dc Pneumatic Controllers Affected Facility (NSPS, Subpart 0000) Centrifugal Compressor Affected Facility (NSPS, Subpart 0000) Reciprocating Compressor Affected Facility (NSPS, Subpart 0000) Reciprocating Internal Combustion Engine(s) (RICE), Generators, Microturbine Generators Tanker Truck Loading Facility Glycol Dehydration Units RECOMMENDATION TO DIRECTOR General Permit G35-C meets all requirements of applicable state and federal regulations. Therefore, it is recommended that General Permit G35-C should be issued. ~~ ngmeer Date Page 19 of 19 -57- -, r---------j::------------------r-----------------------------------------------------------------------------------------------------------------T------~-i~i;~~:~~~i~t~~f~t~ . -.' "'p" . e' d ! west virginia department of environmental protection , r-~·-~~--------------·-·--·----------------·---------~--- ! Charleston, WV ·25304 Phone, (304) 926-0475 Fax (304) 926-0479 www_dep_wv.goV! I: ..---.------..----------------------_.--... -.--------.---~--.---.---------------------."! G35-C GENERAL PERMIT REGISTRATION APPLICATION PREVENTION AND CONTROL OF AIR POLLUTION IN REGARD TO THE CONSTRUCTION, MODIFICATION, RELOCATION, ADMINISTRATIVE UPDATE AND OPERATION OF NATURAL GAS COMPRESSOR AND/OR DEHYDRATION FACILITIES .. _ - ------------_._-----------------------------------------------------.-------------------------------------: DCONSTRUCTION OCLASS I ADMINISTRATIVE UPDATE ' DMODIFICATION DCLASS II ADMINISTRATIVE UPDATE ORELOCATION .:r--------------------------------··-------------- _.-...---..--._-.---_.-.--.-----.-----.-..-."---.--.--"..--------..-.-. ---_..--..---.--..----..-------._-----.------ - ,! SECTION 1. GENERAL INFORMATION ,----- ------------------- -----------------. ---- -- --- ----.. - - .-------..----- .-..-----------------------------.-----------------------'1 ! Name of Applicant (as registered with the WV Secretary of State's Office): ' f----------------------------------------------- -----------------------------------------------------------------------------------------------------------------1 i Federal Employer ID No. (FEIN): ; ,---_.._----------------------------------------------------------------------------------------------------------------------------------------------------------- - - - - -. i: Applicant's Mailing Address: --C-;t;~----------------------------------------------Ts~;:t;;-----------------------------------------------Tzip~C~d;;-----------------------j ----L..-----------------------------------1 ; _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -1..-______________ ---________________________________ . i Facility N a m e : i r-Op~;;t;g-Sit-;Phy~i~-;iAdd-~;~;~---------------------------------------------------------------------------------------1 ! ; If none available, list road, city or town and zip of facility_ ,-----------------------------------------------------,------------------------------------------------------------r--------------------------I City: i Zip Code: County: 1I_____________________________________ -1-________________________________________ ..:.!______________ , _____________ i Latitude & Longitude Coordinates (NAD83, Decimal Degrees to 5 digits): ! ~ i i Latitude: : Longitude: ___________.___1 ! f--sIE-cod~~-----------------------------------------------------T~~-;:~-~~_;;~;;-:~~~or e:isting facilities) NAICS Code: i --.-.. -------- -.---.-------...-- -----...-- ..- -.. ----_ ..------ - ----.------ - _L_ .. -------,--- --- .- ---- '. - ..-----.. ---- ----- --------------- - - - -- ! l--'- - - . - .. - - ! ----1 CERTIFICATION OF NFORMATION ------- ~-------------,,----------- .. - - . - R . - ...- - - - -------- - - ----- - - - - - _ _ • _ __ ______ _ ~ _____ i This G35-C General Permit Registration Application shall be signed below by a Responsible Official. A Responsible I Official is a President, Vice President, Secretary, Treasurer, General Partner, General Manager, a member of the Board of ! Directors, or Owner, depending on business structure_ A business may certify an Authorized Representative who shall have i authority to bind the Corporation, Partnership, Limited Liability Company, Association, Joint Venture or Sole I Proprietorship_ Required records of daily throughput, hours of operation and maintenance, general correspondence, compliance 'certifications and all required notifications must be signed by a Responsible Official or an Authorized ! Representative. If a business wishes to certify an Authorized Representative, the official agreement below shall be checked I off and the appropriate names and signatures entered_ Any administratively incomplete or improperly signed or unsigned G3S-C Registration Application will be returned to the applicant. Furthermore, if the G3S-C forms are not . utilized, the application will be returned to the applicant. No substitution of forms is allowed. ! 1. . I i--·-----·-----·-·-----------------------------------~-----------------------------------------~-----.------~-.----------------------------__l i I hereby certify that is an Authorized Representative and in that capacity shall represent the interest of the business I (e.g., Corporation, Partnership, Limited Liability Company, Association Joint Venture or Sole Proprietorship) and may ! obligate and legally bind the business. If the business changes its Authorized Representative, a Responsible Official shall . I notify the Director of the Division of Air Quality immediately_ i, I hereby certify that all information contained in this G35-C General Permit Registration Application and any supporting , documents appended hereto is, to the best of my knowledge, true, accurate and complete, and that all reasonable efforts i1---------------------------------------------------------------------------------------------------------------------------------------------------------------------1 have been made to provide the most comprehensive' information possible_ i i Responsible Official Signature: ! . Ie: :, Name an d Tit Phone: Fax: :I i Email: Date: ! >---_._---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------j i If applicable: i ! Authorized Representative Signature: ! Name and Title: Phone: Fax: j : Email: Date: ! r---·--------------------------------------------·-~---.--------------------------------------------------------------------------------------------------------i I If applicable: Environmental Contact Name and Title: Phone: Fax: i L.!?_~~~_~ __________________________________________________ !?at~_: ___________________________________________________________ i J 1 -58- OPERATING SITE INFORMATION Briefly describe the proposed new operation and/or any changers) to the facility: Directions to the facility: ATTACHMENTS AND SUPPORTING DOCUMENTS .. . -.... . I have enclosed the following required documents: Check payable to WVDEP - Division of Air Quality with the appropriate application fee (per 45CSRI3 and 45CSR22). o CJleck attached to ti·ont of application. o [ wish to pay by electronic transfer. Contact for payment (incl. name and email address): o [ wish to pay by credit card. Contact for payment (incl. name and email address): 0$300 (Class II Administrative Update) 0$500 (Construction, Modification, and Relocation) 0$1,000 NSPS fee for 40 CFR60, Subpart 1111, JJJJ and:or 0000 I 0$2,500 N ESHAP fee for 40 CFR63, Subpart ZZZZ and:or HH 2 Only one NSPS fee will apply. Only one NESHAP fee will apply. The Subpart ZZZZ NESHAP fee will be waived for new engines that satisfy requirements by complying w·ith NSPS, Subparts [III and/or JJJJ. NSPS and NESHAP fees apply to new construction or if the source is being modified. I 2 0 Responsible.Official or Authorized Representative Signature (if applicable) 0 Single Source Determination Form (must be completed in its entirety) - Attachment A o o o o 0 Siting Criteria Waiver (if applicable) - Attachment B 0 Process Flow Diagram - Attachment D o Plot Plan - Attachment F 0 G35-C Section Applicability Form - Attachment H Current Business Certificate - Attachment C Process Description - Attachment E Area Map - Attachment G Emission Units/ERD Table - Attachment I 0 Fugitive Emissions Summary Sheet - Attachment J 0 Storage Vessel(s) Data Sheet (include gas sample data, USEPA Tanks, simulation software (e.g. ProMax, E&P Tanks, HYSYS, etc.), etc. where applicable) - Attachment K o Natural Gas Fired Fuel Burning Unites) Data Sheet (GPUs, Heater Treaters, In-Line Heaters if app[icable)Attachment L o ..- [nternal Combustion Engine Data Sheet(s) (include manufacturer performance data sheet(s) if applicable) Attachment M o o Tanker Truck Loading Data Sheet (if applicable) - Attachment N o Pneumatic Controllers Data Sheet - Attachment P Glycol Dehydration Unit Data Sheet(s) (include wet gas analysis, GRI- GLYCalc™ input and output reports and information on ·reboiler if applicable)- Attachment 0 C Air Pollution Control Device/Emission Reduction Device(s) Sheet(s) (include manufacturer performance data sheet(s) if applicable) - Attachment Q 0 Emission Calculations (please be specific and include all calculation methodologies used) - Attachment R 0 Facility-wide Emission Summary Sheet(s) - Attachment S o Class I Legal Advcrtisement - Attachment T DOne (I) paper copy and two (2) copics of CD or DVD with pdf copy of application and attachments All attachments must be identified by name, divided into sections, and submitted in order. 2 -59- ATTACHMENT A - SINGLE SOURCE DETERMINATION FORM Classifying multiple facilities as one "stationary source" under 45CSR13, 45CSR14, and 45CSR19 is based on the definition of Building, structure, facility, or installation as given in §45-14-2.13 and §45-19-2.12. The definition states: "Building, Structure, Facility, or Installation" means all o/the pollutant-emitting activities which belong to the same industrial grouping, are located on one or more contiguous or adjacent properties, and are under the control o/the same person (or persons LInder common control). Pollutant-emitting activities are a part of the same industrial grouping if they belong to the same "Major Group" (i.e., which have the same two (2)-digit code) as described in the Standard Industrial Classification Manual, 1987 (United States Government Printing Office stock number GPO 1987 O-185-718:QL 3). Is there a facility owned by or associated with the natural gas industry located within one (l) mile of the proposed facility? Yes 0 No 0 If Yes, please complete the questionnaire on the following page (Attachment A). Please provide a source aggregation analysis for the proposed facility below: 3 -60- ATTACHMENT A - SINGLE SOURCE DETERl\UNATION FORM Answer each question with a detailed explanation to determine contiguous or adjacent properties which are under a common control and any support facilities. This section must be completed in its entirety. Provide a map.of contiguous or adjacent facilities (production facilities, compressor stations, dehydration facilities, etc.) which are under common control and those facilities that are not under common control but are support facilities. Please indicate the SIC code, permit number (if applicable), and the distance between facilities in question on the map. Are the facilities owned by the same parent company or a subsidiary of the parent company? Provide the owners identity and the percentage of ownership of each facility. Yes 0 No 0 Does an entity such as a corporation have decision making authority over the operation of a second entity through a contractual agreement or voting interest? Please explain. Yes 0 No 0 Is there a contract for service relationship between the two (2) companies or, a support.·dependency relationship that exists between the two (2) companies? Please explain. Yes 0 No 0 Yes 0 No 0 Do the facilities share common workforces, plant managers, security forces, corporate executive officers or board executives? Will managers or other workers frequently shuttle back and forth to be involved actively at both facilities? Do the facilities share common payroll activities, employee benefits, health plans, retirement funds, insurance coverage, or other administrative functions? Please explain. Yes 0 No 0 Yes 0 No 0 Does one (I) facility operation support the operation of the other facility? Yes 0 No 0 Is one (I) facility dependent on the other? If one (I) facility shuts down, what are the limitations on the other to pursue outside business? Please explain. Yes 0 No 0 Are there any financial arrangements between the two (2) entities? Yes 0 No 0 Aloe there any legal or lease agreements between the two (2) facilities? Yes 0 No 0 Do the facilities share products, byproducts, equipment, or other manufacturing or air pollution control device equipment? Please explain. Yes 0 No 0 Do all the pollutant-emitting activities at the facilities belong to the same SIC Code? Please provide the S Ie Codes. Yes 0 No 0 Was the location of the new facility chosen primarily because of its proximity to the existing facility to integrate the operation of the t":o (2) facilities? Please explain. Yes 0 No 0 Will materials be routinely transferred between the two (2) facilities? Please explain the amount of transfer and how often the transfers take place and what percentages go to the various entities. Yes 0 No 0 Yes 0 No 0 Does the facility influence production levels or compliance with environmental regulations at other facilities? Who accepts the responsibility for compliance with air quality requirements? Please explain. 4 -61- I·. · · A TT ACHMENT B - SITING CRITERIA WAIVER If applicable, please complete this form and it must be notarized. G35-C General Permit Siting Criteria Waiver WV Division of Air Quality 300' Waiver I --------------------~p=rm~tN=a=lIIe~---------------- hereby acknow ledge and agree that ---------...=:-r=====~--------will General PermIt Applicant's Name construct an emission unites) at a natural gas compressor and/or dehydration facility that will be located within 300' of my dwelling and/or business. I hereby offer this waiver of siting criteria to the West Virginia Department of Environmental Protection Division of Air Quality as permission to construct, install and operate in such location. Signed: Signature Date Signature Date Taken, subscribed and sworn before me this _ _ day of ____________,20____ My commission expires: SEAL__________________~~---------------Notary Public 5 -62- ATT ACHMENT C - CURRENT BUSINESS CERTIFICATE If the applicant is a resident of West Virginia, the applicant should provide a copy of the current Business Registration Certificate issued to them from the West Virginia Secretary of State's Office. If the applicant is not a resident of the State of West Virginia, the registrant s·hould provide a copy of the Certificate of Authority! Authority of LLC!Registration. This information is required for all sources to operate a business in West Virginia regardless of whether it is a construction, modification, or administrative update. If you are a new business to West Virginia and have applied to the West Virginia Secretary of State's Office for a business license, please include a copy of your application. Please note: Under the West Virginia Bureau of Employment Programs, 96CSR 1, the DAQ may not grant, issue, or renew approval of any permit, general permit registration, or Certificate to Operate to any employing unit whose account is in default with the Bureau of Employment Programs Unemployment Compensation Division. 6 -63- ATTACHMENT D - PROCESS FLOW DIAGRAM Provide a diagram or schematic that supplements the process description of the operation. The process flow diagram must show all sources, components or facets of the operation in an understandable line sequence of operation. The process flow diagram should include the emission unit ID numbers, the pollution control device ID numbers, and the emission point ID numbers consistent with references in other attachments of the application. For a proposed modification, clearly identify the process areas, emission units, emission points, andlor control devices that will be modified, and specify the nature and extent of the modification. Use the following guidelines to ensure a complete process flow diagram: • • • • The process flow diagram shall logically follow the entire process from beginning to end. Identify each emission source and air pollution control device with proper and consistent emission unit identification numbers, emission point identification numbers, and control device identification numbers. The process flow lines may appear different for clarity. For example, dotted lines may be used for vapor flow and solid lines used for liquid flow and arrows for direction of flow. The process flow lines may be color coded. For example: new or modified equipment may be red; old or existing equipment may be blue; different stages of preparation such as raw material may be green; and, finished product or refuse, another color. 7 -64- ATTACHMENT E - PROCESS DESCRIPTION Provide a detailed written description of the operation for which the applicant" is seeking a permit. The process description is used in conjunction with the process flow diagram to provide the reviewing engineer a complete understanding of the activity at the operation. Describe in detail and order the complete process operation. Use the following guidelines to ensure a complete Process Description: • • • • • The process flow diagram should be prepared first and used as. a guide when preparing the process description. The written description shall follow the logical orde·r of the process flow diagram. All emission sources, emission points, and air pollution control devices must be included in the process description. When modifications are proposed, describe the' modifications and the effect the changes will have on the emission sources, emission points, control devices and the potential emissions. Proper emission source ID numbers must be used consistently in the process description, the process flow diagram, the emissions calculations, and the emissions summary information provided. Include any additional information that may facilitate the reviewers understanding of the process operation. The process description is required for all sources regardless of whether it is a construction, modification, or administrative update. 8 -65- ATTACHMENTF - PLOTPLAN Provide an accurately scaled and detailed Plot Plan showing the locations of all emission units, emission points, and air pollution control devices. Show all emission units, affected facilities, enclosures, buildings and plant entrances and exits from the nearest public road(s) as appropriate. Note height, width and length of proposed or existing buildings and structures. A scale between 1 "=10" and 1 "=~OO' should be used with the determining factor being the level of detail necessary to show operation or plant areas, affected facilities, emission unit sources, transfer points, etc. An overall small scale' plot plan (e.g., I "=300') should be submitted in addition to larger scale plot plans for process or activity areas (e.g., 1 "=50') if the plant is too large to allo.w adequate detail ona single plot plan. Process or activity areas may be grouped for the enlargements as long as sufficient detail is shown. Use the following guidelines to ensure a complete Plot Plan: • • • • • • • • Facility name Company name Compan'y facility ID number (for existing facilities) Plot scale, north arrow, date drawn, and submittal date. Facility boundary lines Base elevation Lat/Long reference coordinates from the area map and corresponding reference point elevation Location of all point sources labeled with proper and consistent source identification numbers This information is required for all sources regardless of whether it is a construction, modification, or administrative update. 9 -66- A TT ACHMENT G - AREA MAP Provide an Area Map showing the current or proposed location of the operation. On this map, identify plant or operation property lines, access roads and any adjacent dwelling, business, public building, school, church, cemetery, community or institutional building or public park within a 300' boundary circle of the collective emission units. Please provide a 300' boundary circle on the map surrounding the proposed emission units collectively. This information is required for all sources regardless of whether it is a construction, modification, or administrative update. 10 -67 - ATTACHMENT H - G35-C SECTION APPLICABILITY FORM General Permit G35-C Registration Section Applicability Form General Pennit G35-C was developed to allow qualified applicants to seek registration for a variety of sources. These sources include storage vessels, gas production units, in-line heaters, heater treaters, glycol dehydration units and associated reboilers, pneumatic controllers, centrifugal compressors, reciprocating compressors, reciprocating internal combustion engines (RICEs), tank truck loading, fugitive emissions, completion combustion devices, flares, enclosed combustion devices, and vapor recovery systems. All registered facilities will be subject to Sections 1.0,2.0,3.0, and 4.0. General Pennit G35-C allows the registrant to choose which sections of the pennit they are seeking registration under. Therefore, please mark-which additional sections that you are applying for registration under. If the applicant is seeking registration under multiple sections, please select all that apply. Please keep in mind, that if this registration is approved, the issued registration will state which sections will apply to your affected facility. ......... ... o Section 5.0 o Section 6.0 GENERAL PERMIT G35-C APPLICABLE SECTIONS ........... .... ... ..... . Storage Vessels Containing Condensate and/or Produced Water l ... Storage Vessel Affected Facility (NSPS, Subpart 0000) D Section 7.0 Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH o Section 8.0 Small Heaters and Reboilers not subject to 40CFR60 Subpart Dc DSection 9.0 Pneumatic Controllers Affected Facility (NSPS, Subpart 0000) DSection 10.0 Centrifugal Compressor Affected Facility (NSPS, Subpart 0000)2 o Section 11.0 Reciprocating Compressor Affected Facility (NSPS, Subpart 0000)2 DSection 12.0 Reciprocating Internal Combustion Engines, Generator Engines. Microturbine Generators o Section 13.0 Tanker Truck Loading 3 DSection 14.0 Glycol Dehydration Units 4 1 Applicants that are su~ject to section 5 may also be subject to Section 6 if the applicant is subject to the NSPS, Subpart 0000 control requirements or the applicable control device requirements a/Section 7. 2 Applicants that are subject to Section 10 and 11 may also be subject to the applicable RICE requirements a/Section 12. 3 Applicants that are subject to Section 13 may also be subject to control device and emission reduction device requirements 0/ Section 7. 4 Applicants thatare subject to Section 14 may also be subject to the requirements a/Section 8 (reboilen). Applicants that are subject to Section 14 may also be subject to control device and emission reduction device requirements a/Section 7. 11 -68- ATTACHMENT I - EMISSION UNITS / EMISSION REDUCTION DEVICES (ERD) TABLE . ............... ............................................... .. ... .. . .... . .........'. .. ...... ..... . ... ...................... ...... . ..•....... ... ...- ..... .. ................. .. ' ' Include ALL emission units and air pollution control devices/ERDs that will be part of this permit application review. Do not include fugitive emission sources in this table. Deminimis storage tanks shall be listed in the Attachment K table . This information is required for all sources regardless of whether it is a construction, modification, or administrative update. Emission Unit 10 1 Emission Point 101 Emission Unit Description Year Installed Manufac. DateJ Type J and Date of Change Design Capacity Control Device(s)5 ERO(s)6 I I I 0'\ I.C I For Emission Units (or Sources) use the following numbering system: I S. 2S. 3S .... or other appropriate designation. For Emission Points use the following numbering system : I E. 2E. 3 E.... or other appropriate designation . ) When required by rule • New. modification. removal. existing 5 For Control Devices use the following numbering system : I C. 2C. 3C .... or other appropriate designation. c. For EROs use tht: following numbering system : 10.20.30 .... or other appropriate designation . I 1 _. 12 . c - , - ATTACHMENT J - FUGITIVE SUMMARY SHEET_................... .. .... ........ ... - ................-...... .......... ............... _..... _................ .......- ............. .... _...EMISSIONS .. _............ .... ... .... .............. -........................ .Sources of fugitive emissions may include loading operations, equipment leaks, blowdown emissions, etc. Use extra pages for each associated source or equipment if necessary. ......... . . ..... ... Source/Equipment: Leak Detection Method Used Component Type I o Valves DYes o No Q Open Ended Lines , - " Audible, visual, and olfactory (AVO) inspections Count .- I0 Infrared (FUR) cameras DYes No DYes . 0 No DYes o No DYes No o Compressors DYes o No o Flanges Yes DNa Other' o '" DYes No VOC HAP Please provide an explanation of the sources of fugitive emissions (e.g. pigging operations, equipment blowdowns, pneumatic controllers, etc.): .- 13 -.- - , - . .. .... ....... None required Estimated Emissions (tpy) , Other equipment types may include compressor seals, relief valves, diaphragms, drains, meters, etc . - - .- o Other (please describe) o Gas o Liquid o Both o Gas o Liquid o Both o Gas o Liquid o Both o Gas o Liquid o Both o Gas o Liquid o Both o Gas o Liquid o Both o Gas o Liquid o Both o Gas o Liquid o Both o Gas o Liquid o Both o Connections (Not sampling) o . ........ ....... " Stream type (gas, liquid, etc .) Source of Leak Factors (EPA, other (specify)) I Sampling Connections . " DYes No Pumps Safety Relief Valves ~ Closed Vent System I0 _..... . GHG (CO~e) Please indicate if there are any closed vent bypasses (include component): Specify all equipment used in the closed vent system (e.g. VRU, ERD, thief hatches, tanker truck loading, etc.) I -...I ~ I 14 ATTACHMENT K- STORAGE VESSEL DATA SHEET Complete this data sheet if you are the owner or operator of a storage vessel that contains condensate and/or produced water. This form must be completed for each new or modified bulk liquid storage vessel(s) that contains condensate and/or produced water. (If you have more than one (l) identical tank (i.e. 4-400 bbl condensate tanks), then you can list all on one (l) data sheet). Include gas sample analysis, flashing emissions, working and breathing losses, USEPA Tanks, simulation software (ProMax, E&P Tanks, HYSYS, etc.), and any other supporting documents where applicable. The following information is REQUIRED: o Composition of the representative sample used for the simulation o For each stream that contributes to flashing emissions: o Temperature and pressure (inlet and outlet from separator(s)) o Simulation-predicted composition o Molecular weight o Flow rate o Resulting flash emission factor or flashing emissions from simulation o Working/breathing loss emissions from tanks and/or loading emissions if simulation is used to quantify those emissions Additional information may be requested ifnecessary . GENERAL INFORMATION I. Bulk Storage Area Name 2. Tank Name 3. Emission Unit ID number 4. Emission Point 1D number 5. Date Installed, Modified or Relocated ({or existing tanks) 6. Type of change: Was the tank manufactured after August 23, 20 II? 0 New construction 0 Relocation DYes o New stored material o 0 No 7A. Description of Tank Moditication ((f applicable) 7B. Will more than one material be stored in this tank? ({so. {( separate/arm must be completed/or eac/r material. DYes 0 No 7C. Was USEPA Tanks simulation software uti lized? DYes 0 No If Yes, please pm vide tile appropriate documelltatioll and items 8-42 below are II0t required. 15 -72- Other TANK INFORMATION 8. Design Capacity (specifY barrels or gallons). Use the internal cross-sectional area multiplied by internal height. 9B. Tank Internal Height (ft.) 9A. Tank Internal Diameter (ft.) I DB. Average Liquid Height (tl.) IDA, Maximum Liquid Height (ft.) liB . A\'erage Vapor Space Height (ft.) I I A. Maximum Vapor Space Height (ft.) 12. Nominal Capacity (specify barrels or gallons). This is also known ,as "working volume"". 13A. Maximum annual throughput (gal/yr) 13B: Maximum daily throughput(gal/day) 15. Maximum tank till rate (gal/min) 14. Number of tank turnovers per year 16. Tank fill method D Submerged o Bottom Loading o No D Splash 17. Is the tank system a variable vapor space system? DYes If yes, (A) What is the volume expansion capacity of the system (gal)? (B) What are the number of transfers into the system per year? 18. Type of tank (check all that apply): 0 Fixed Roof o vertical o horizontal o tlat roof o cone roof D dome roof D other (describe) o pontoon roof o double deck roof 0 External Floating Roof 0 Domed External (or Covered) Floating Roof o vertical column support o self-supporting o lifter roof o diaphragm o spherical o cylindrical 0 Internal Floating Roof 0 Variable Vapor Space 0 Pressurized 0 Other (describe) PRESSURENACUUM CONTROL DATA o 19. Check as many as apply: Does Not Apply o D Inert Gas Blanket of D Carbon Adsorption I Rupture Disc (psig) l 0 Vent to Vapor Combustion Device (vapor combustors, flares, thermal oxidizers, enclosed combustors) 0 Conservation Vent (psig) Pressure Setting Vacuum Setting 0 Emergency Relief Valve (psig) Pressure Setting Vacuum Setting o Condenser l 0 Thief Hatch Weighted 0 Yes 0 No I Complete appropriate Air Pollution Control Device Sheet 20. Expected Emission Rate (submit Test Data or Calculations here or elsewhere in the application). Material Name' Flashing Loss Breathing Loss Working Loss Ib/hr Ib/hr Ib/hr tpy tpy 16 -73- tpy Total Emissions Loss Ib/hr tpy Estimation Method l I I EPA = EPA Emission Factor, MB = Material Balance, SS = Similar Source, ST = Similar Source Test, Throughput Data, 0 = Other (specify) Remember to attach emissiollS calculations. including TANKS Summwy Sheets and other modeling slImmary sheets if applicable. TANK CONSTRUCTION AND OPERATION INFORMATION 21. Tank Shell Construction: 0 o Riveted 0 Gunite lined Epoxy-coated rivets I 21B. 2 I A. Shell Color: 22. Shell Condition (if metal and unlined): 0 No Rust 0 Light Rust 22A. Isthetankheateq? 0 Yes o 0 Dense Rust I 22B. 0 No o Other (describe) I 21C. Roof Color: Year Last Painted: Not applicable If yes, operating temperature: 122C. If yes, how isheat provided to tank? 23. Operating Pressure Range (psig): Must be listed for tanks usIng VRUs with closed vent system. 24. Is the tank a Vertical Fixed Roof Tank? /24A. If yes. tor dome roof provide radius (tt): /24B. If yes, tor cone root: provide slop (tlln): 0 DYes No 0 25. Complete item 25 for Floating Roof Tanks Does not apply 0 25A. Year Internal Floaters Installed: 25B. Primary Seal Type (check one): 0 0 Metallic (mechanical) shoe seal o Vapor mounted resilient seal o Other (describe): o No 25C. Is the Floating Roof equipped with a secondary seal? DYes 25D. If yes, how is the secondary seal mounted? (check one) 25E. Is the floating roof equipped with a weather shield? 0 Liquid mounted resilient seal 0 Shoe 0 DYes Rim 0 Other (describe): No 25F. Describe deck fittings: o 26. Complete the following section fur Internal Floating Roof Tanks 26A. Deck Type: 0 0 Bolted Does not apply 268. For bolted decks, provide deck construction: Welded 26C. Deck seam. Continuous sheet construction: o 5 ft. wide 0 6 ft. wide 0 26D. Deck seam length (n.): 27. Closed Vent System with VRU? 7 ft. wide 0 5 x 7.5 ft. wide 26E. Area of deck (tt-): 0 Yes 0 o 5 x 12 ft. wide 0 other (describe) 26F. For column SUPPOlted tanks. # of columns: 26G. For column sUPPOlted tanks, diameter of column: No 28. Closed Vent System with Enclosed Combustor? 0 Yes o No SITE INFORMATION 29. Provide the city and state on which the data in this section are based: 31. Annual Avg. Maximum Temperature (OF): 30. D-dily Avg. Ambient Templ!rature (OF): 33. Avg. Wind Speed (mph): 32. Annual Avg. Minimum Temperature (OF): 34. Annual Avg. Solar Insulation Factor (BTU:n--day): 35. Atmosphcric Pressure (psia): LIQUID INFORMATION 36. Avg. daily tcmpel11ture I1lnge of bulk liquid (OF): 37. Avg. operating pressure range of tank (psig): 36A. Minimulll (OF): 368. Maximum (OF): 37A. Minimum (psig): 37B. Maximum (psig): 38B. Com:sponding vapor pressure (psia): 38A. Minimum liquid surtilct: temperature (OF): 39B. Con'esponding vapor pressure (psia): 39A. Avg. liquid surface temperature (OF): 40B ..Con·esponding vapor pressure (psia): 40A. Maximum liquid surface temperature (OF): 41 . Provide the tollowing tor each liquid or gas to be stored in the tank. Add additional pages if necessary. 41 A. Material name and composition : 41B. CAS iUlIllber: 41 C. Liquid density (lb/gal): 41 D. Liquid molecular weight (Ib/lb-molt:): 41 E. Vapor molecular weight (lb/lb-mole): 17 -74- 41 F. Maximum tme vapor pressure (psia): 41 G. Maximum Reid vapor pressure (psia): 41 H. Months Storage pel' year. To: From: 42. Final maximum gauge pressure and temperature prior to transfer into tank used as inputs into tlashing emission calculations. STORAGE TANK DATA TABLE List all deminimis storage tanks (i.e. lube oil, glycol, diesel etc.) Source 10#1 I. 2. 3. 4. Status! Contene Volume4 Enter the appropriate Source Identification Numbers (Source 10 #) for each storage tank located at the compressor station. Tanks should be designated TO I, T02, T03, etc. Enter storage tank Status using the following: EXIST Existing Equipment NEW Installation of New Equipment REM Equipment Removed . Enter storage tank content such as condensate, pipeline liquids, glycol (OEG or TEG), lube oil, diesel, mercaptan etc. Enter the maximum design storage tank volume in gallons. 18 -75- ATTACHMENT L - SMALL HEATERS AND REBOILERS NOT SUBJECT TO 40CFR60 SUBPART DC DATA SHEET ......... . Complete this data sheet for each small heater and reboiler not subject to 40CFR60 Subpart Dc at the facility . The Maximum Design Heat Input (MDHI) must be less than 10 M"~BTU/hr. ......................... .............. " . . ... Emission Unit 10#' 2 4 Emission Point ID#1 Emission Unit Description (manufacturer, model #) Year Installed! Modified Type J and Date of Change Maximum Design Heat Input (MMBTU!hr)4 .... . ..- Fuel Heating Value (BTU!scf)' Enter the appropriate Emission Unit (or Source) identification number for each fuel burning unit located at the production pad. Gas Producing Unit Burners should be designated GPU-I, GPU-2, etc. Heater Treaters should be designated HT-I, HT-2, etc. Heaters or Line Heaters should be designated LH-I, LH-2, etc. For sources, use IS, 2S, 3S ... or other appropriate designation. Enter glycol dehydration unit Reboiler Vent data on the Glycol Dehydration Unit Data Sheet. Enter the appropriate Emission Point identification numbers for each ·fuel burning unit located at the production pad. Gas Producing Unit Burners should be designated GPU-l, GPU-2, etc. Heater Treaters should be designated HT-1, HT-2, etc. Heaters or Line Heaters should be designated LH-l, LH-2, etc. For emission points, use IE, 2E, 3E ... or other appropriate designation. New, modification, removal Enter design heat input capacity in MMBtulhr. Enter the fuel heating value in BTU/standard cubic foot. 19 -76- A TT ACHMENT M - INTERNAL COMBUSTION ENGINE DATA SHEET Complete this data sheet for each internal combustion engine at the facility. Include manufacturer performance data sheet(s) or any other supporting document if applicable. Use extra pages if necessary. Generator(s) and microturbine generator(s) shall also use this form. ..... Emissio n Unit 10#1 Engine Manufacturer/Model Manufacturers Rated bhp/rpm Source Status 2 Date Installed/ Modified/Removcd,Relocated) Engine Manufacturcd :Reconstruction Date 4 Check all applicable Federal Rules for the engine (include EPA Certificate of Conformity if applicable); D40CFR60 Subpart JJJJ DJJJJ Certified? D40CFR60 Subpart IIII o II II Certified? D40CFR63 Subpart ZZZZ o NESHAP ZZZZ/ NSPS J11J Window o NESHAP ZZZZ Remote Sources D40CFR60 SLLbpart JJJJ DJJJJ Cert'ified? D40CFR60 Subpart II II 01111 Certified? D40CFR63 Subpart ZZZZ o NESHAP ZZZZ/ NSPS 1111 Window o NESHAP ZZZZ Remote Sources D40CFR60 Subpart JJJJ DJJJJ Certified? D40CFR60 Subpart 1111 o II II Certified? D40CFR63 Subpart ZZZZ o NESHAP ZZZZI NSPS JJ11 Window o NESHAP ZZZZ Remote Sources fellu gal/hr ftJ;hr gal/hr ftl'hr gal/hr MMfe'yr gal/yr MMfe/yr gal/yr MMfe/yr gal.yr Engine Type 6 APCD Type 1 Fuel Type X H2 S (gr/I 00 scf) Operating bhp,rpm BSFC (BTU,bhp-hr) Hourly Fuel Throughput Annual Fuel Throughput (Must use 8.760 hrs.'yr unless e:nergency generator) Fuel Usage or Hours of Operation Metered Calculation Methodology9 PolJutant lll Yes 0 Hourly PTE (Ib/hr)" No 0 Yes 0 Hourly PTE (Ib/hr) II Annual PTE (tons/year) No 0 Annual PTE (tons/year) II II Yes 0 Hourly PTE (Ib/hr) II No 0 Annual PTE (tons/year) II NO, CO VOC SOl PM III Formaldehyde Total HAPs GI-!G (CO,e) Enter the appropriate Source Identitication Number tor each natural gas-fueled reciprocating intemal combustion compressor/generator engine located at the compressor station. Multiple compressor engines should be designated CE-l. CE-l. CE-3 etc. Generator engines should be designated GE-l. GE-2. GE-3 etc. Microturbine generator engines should be designated MT-l. MT-2. MT-3 etc. If more than three (3) engines exist. please use additional sheets. 2 Enter the Source Status using the tollowing codes: NS MS REM ConstlUction of New Source (installation) Moditication of Existing Source Removal of Source Existing Source Relocated Source ES RS 20 -77- 3 Enter the date (or anticipated date) of the engine's installation (construction of source), moditication, relocation or removal. 4 Enter the date that the engine was manufuetured, modified or reconstructed. 5 Is the engine a certified stationary spark ignition intemal combustion engine according to 40CFR60 Subpalt III IIJJJJ? If so, the engine and control device must be operated and maintained in accordance with the manufacturer's emission-related written instlllctions. You must keep records of conducted maintenance to demonstrate compliance, but no perfonnance testing is required. If the cCltified engine is not operated and maintained in accordance with the manufacturer's emission-related written instlllctions, the engine will be considered a non-celtitit.'li engine and you must demonstrate compliance as appropriate. Provide a manufacturer's data sheet for all engines being registered. 6 Enter the Engine Type designation(s) using the following codes: 2SLB 4SLB 7 Air/Fuel Ratio High Energy Ignition System Prestratitied Charge Rich Bum & Non-Selective Catalytic Reduction Lean Bum & Selective Catalytic Reduction IR S·IPC LEC OxCat Ignition Retard Screw-in Precombustion Chambers Low Emission Combustion Oxidation Catalyst Enter the Fuel Type using the tollowing codes: PQ 9 Four Stroke Rich Bum 4SRB Enter the Air Pollution Control Device (APCD) type designation(s) using the tollowing codes: A/F HEIS PSC NSCR SCR 8 Two Stroke Lean Bum Four Stroke Lean BUill Pipeline Quality Natural Gas RG Raw Natural Gas (Production Gas o Diesel Enter the Potential Emissions Data Reference designation using the followi.ng codes. Attach all reference data used. MD GR Manufacturer's Data GRI-HAPCa\c™ AP OT AP-42 Other (please list) 10 Enter each engine's Potential to Emit (PTE) for the listed regulated pollutants in pounds per hour and tons per year. PTE shall be calculated at manufacturer's rated brake horsepower and may reflect reduction efficiencies oflisted Air Pollution Control Devices. Emergency generator engines may use 500 hours of operation when calculating PTE. PTE data ti'om this data sheet shall be incorporated in the Emissions Summary Sheet. 11 PTE for engines shall be calculated from manufacturer's data unless unavailable. 21 -78- Engine Air Pollution Control Device (Emission Unit ID# , use extra pages as necessary) Air Pollution Control Device Manufacturer ' s Data Sheet included? Yes D No D D NSCR D SCR D Oxidation Catalyst Provide details of process control used for proper mixing/control of reducing agent with gas stream: Manufacturer: Model #: "F Design Operating Temperature: Service life of catalyst: Volume of gas handled: scfm Design gas volume: Provide manufacturer data? DYes acfm at OF Reducing agent used, if any: Pressure drop against catalyst bed (delta P): D No Operating temperature range for NSCR/Ox Cat: OF to "F From Ammonia slip (ppm): inches of H2O Provide description of warning/alarm system that protects unit when operation is not meeting design conditions: . Is temperature and pressure drop of catalyst required to be monitored per 40CFR63 DYes 0 No S~lbpart ZZZZ? How often is catalyst recommended or required to be replaced (hours of operation)? How often is performance test required? o Initial o Annual o Every 8,760 hours of operation o Field Testing Required o No performance test required . If so, why (please list any maintenance required and the applicable sections in NSPS/GACT, 22 -79- ATTACHMENT N - TANKER TRUCK LOADING DATA SHEET Complete this data sheet for each new or modified bulk liquid transfer area or loading rack at the facility. This is to be used for bulk liquid transfer operations to tanker trucks. Use extra pages if necessary. Truck Loadout Collection Efficiencies The following applicable capture efficiencies of a truck loadout are allowed: • For tanker trucks passing the MACT level annual leak test - 99.2% • For tanker trucks passing the NSPS level annual leak test - 98.7% • For tanker trucks not passing one of the annualleak tests listed above - 70% Compliance with this requirement shall be demonstrated by keeping records of the applicable MACT or NSPS Annual Leak Test certification for every truck and railcar loaded/unloaded. This requirement can be satisfied if the trucking company provided certification that its entire fleet was compliant. This certification must be submitted in writing to the Director of the DAQ. These additional requirements must be noted in the Registration Application and will be noted on the issued G35-C Registration. I Emission Point 10#: Emission Unit 10#: I Year Installed/Modified: Emission Unit Description: Loading Area Data I Max number of trucks loading at one I Number of Liquids Loaded: Number of Pumps: Are tanker trucks pressure tested for leaks at this or any other location? If Yes, Please describe: (I) time : DYes o No o Not Required Provide description of closed yent system and any bypasses. Are any of the following truck loadout systems utilized? D Closed System to tanker truck passing a MACT level annual leak test? D Closed System to tanker truck passing a NSPS level annual leak test? D Closed System to tanker truck not passing an annual leak test and has vapor return? Projected Maximum Operating Schedule (for rack or transfer point as a whole) Time Ja n - Mar Apr - Jun Jul - Sept Hours/day Days/ wee k Bulk Liquid Data (use extra pages as necessary) Liquid Name Max . Daily Throughput (1000 gal.'day) "'lax. Annual Throughput ( 1000 gaJ.'yr) Loading Method l Max, Fill Rate (gal/min) Average Fill Time (min: loading) Max . Bulk Liquid Temperature (OF) Tmc Vapor Pressure 2 Cargo Vessel Condition' Control Equipment or Method~ 23 -80- Oct - Dec Max. Collection Efficiency (%) Max. Control Efficiency (%) Max.VOC Emission Rate Max.HAP Emission Rate Loading (Ib:hr) Annual (ton/yr) Loading (Ib/hr) Annual (ton/yr) Estimation MethodS I 2 3 4 5 Splash Fill SUB Submerged Fill BF Bottom Fill SP At maximum bulk liquid temperature B Ballasted Vessel C Cleaned U Uncleaned (dedicated service) o Other (describe) List as many as apply (complete and submit appropriate Air Pollution Control Device Slieets) CA Carbon Adsorption VB Dedicated Vapor Balance (closed system) ECD Enclosed Combustion Device F Flare TO Thermal Oxidization or Incineration EP A EPA Emission Factor in AP-42 MB Materiai Balance TM Test Measurement based upon test data submittal o Other (describe) 24 -81- ATTACHMENT 0 - GLYCOL DEHYDRATION UNIT DATA SHEET Complete this data sheet for each Glycol Dehydration Unit, Reboiler, Flash Tank and/or Regenerator at the facility. Include gas sample arialysis and GRI- GLYCalc™ input and aggregate report. Use extra pages if necessary. Model: Manufacturer: Max. Dry Gas Flow Rate: Design Type: 0 TEG Reboiler Design Heat Input: mmscti'day 0 DEG 0 MMBTU:hr Source Status': EG Date Installed:Modified/Removed l : Regenerator Still Vent APCD/ERD>: Control Device;ERD ID#>: Fuel HV (BTU/scf): HzS Content (grll 00 sct): Operation (hours/year): Pump Rate (scfm): Water Content (wt %) in: Wet Gas: Dry Gas: Is the glycol dehydration unit exempt from 40CFR63 Section 764(d)? DYes o No: If Yes, answer the following: The actual annual average f10wrate of natural gas to the glycol dehydration unit is less than 85 thousand standard cubic meters per day, as determined by the procedures specified in *63.772(b)(l) of this subpart. DYes o No The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0.90 megagram per year (I ton per year), as determinedby the procedures specified in §63.772(b)(2) of this subpart. 0 Yes No o Is the glycol dehydration unit located within an Urbanized Area (UA) or Urban Cluster (UC)? DYes [s a lean glycol pump optimization plan being utilized? 0 Yes o o No No Recyclin g the glycol dehydration unit back to the flame zone of the reboiler. o No DYes Recyclin g the glycol dehydration unit back to the flame zone of the reboiler and mixed with fuel. o No DYes What happens when temperature controller shuts off fuel to the reboiler? D Still vent emissions to the atmosphere. D Still vent emissions stopped with valve. D Still vent emissions to glow plug. Please indicate if the following equipment is present. Flash Tank Burner management system .that continuously burns condenser or flash tank vapors D D Control Device Technical Data I\ianufacturer's Guaranteed Control Efficiency (%) Pollutants Controlled Emissions Data Emission Unit 10 I Emission Point ID4 Description Calculation Methodology5 PTE 6 NO, CO VOC Reboiler Vent S02 PM IfI 25 -82- Controlled Maximum Hourly Emissions (Ib/hr) Controlled Maximum Annual Emissions (tpy) GHG (C0 2 e) GR[_G[yCa[c™ Glyco[ Regenerator Still Vent Glycol Flash Tank 2 3 4 5 6 VOC GR[-GlyCalc T :1 Benzene GR[-GlyCalc EI Toluene GR[-GlyCalc™ Ethylbenzene GRI-Glj·Calc™ Xy[enes GRI-GlyCalc T:I n-Hexane GR[-GlyCalc™ VOC GRI-GlyCalc™ Benzene G RI-G lyCalc ™ Toluene GRI-GlyCalc ™ Ethylbenzene GR[-GlyCalc ™ Xylenes GR[-G[yCalc T;1 n-Hexane Enter the Source Status using the following codes: NS. Construction of New SouTce ES Existing Source MS Modification of Existing Source Enter the date (or anticipated date) of the glycol dehydration unit ' s installation (construction of source), modification or removal. Enter the Air Pollution Control Device (APCD)/Emission Reduction Device (ERD) type designation using the following codes and the· device [D number: CD Condenser FL Flare NA None CC Condenser/Combustion Combination TO Therma[ Oxidizer 0 Other (please list) Enter the appropriate Emission Unit [D Numbers and Emission Point ID Numbers for the glycol dehydration unit reboiler vent and glyco[ regenerator still vent. The glycol dehydration unit reboiler vent and glycol regenerator still vent should be designated RBV - [ and RSV -I, respectively. [f the compressor station incorporates multiple g[ycol dehydration units, a Glycol Dehydration Emission Unit Data Sheet shall be completed for each, using Source Identification RBV-2 and Rsv-i, RBV-3 and RSV-3, etc . Enter the Potential Emissions Data Reference designation using the following codes : Manufacturer' s Data AP AP-42 MD GR GR[_GLYCalc™ OT Other (please list) Enter the Reboiler Vent and Glycol Regenerator Still Vent Potential to Emit (PTE) for the listed regulated pollutants in Ibs per hour and tons per year. The Glycol Regenerator Still Vent potential emissions may be determined using the most recent version of the thermodynamic software model GRI-dLYCalc TH (Radian International LLC & Gas Research Institute). Attach all referenced Potential Emissions Data (or ca[culatlons) and the GRI-GLYCalc™ Aggregate Calculations Report (shall include emissions reports, equipment reports, and stream reports) to this Glycol Dehydration Emission Unit Data Sheet(s). Backup pumps do not have to be considered as operating for purposes of PTE. This PTE data shall be incorporated in the Emissions Summary Sheet. 26 -83- ATTACHMENT P - PNEUMATIC CONTROLLERS DATA SHEET Are there any continuous bleed natural gas driven pneumatic controllers at this facility that commenced construction, modification or reconstruction after August 23, 2011? DYes ONo Please list approximate number. Are there any continuous bleed natural gas driven pneumatic controllers at this facility with a bleed rate greater than 6 standard cubic feet per hour that are required based on functional needs, including but not limited to response time, safety and positive actuation that commenced construction, modification or reconstruction after August 23, 2011? DYes ONo Please list approximate number. 27 -84- i ATTACHMENT Q - AIR POLLUTION CONTROL DEVICE I EMISSION REDUCTION DEVICE SHEETS .............. Complete the applicable air pollution control device sheets for each flare, vapor combustor, thermal oxidizer, condenser, adsorption system, vapor recovery unit, BTEX Eliminator, Reboiler with and without Glow Plug, etc. at the facility. Use extra pages if necessary. Emissions calculations must be performed using the most conservative control device efficiency. Tile jollo~ving jil'e (5) rows are OIl~V to be completed if registering an alternatil'e air poI/lilian cOlltrol device. Emission Un it 10: Make/Model: Primary Control Device 10: Make/Model: Control Efficiency (%) : APCD/ ERD Data Sheet Completed: 0 Yes Secondary Control Device 10: Make /Model: Control Efficiency (%): APCD/ERD Data Sheet Completed: 0 Yes 28 -85- o No o No VAPOR COMBUSTION (Including Enclosed Combustors) General Information Installation Date: New D Modified Control Device 10#: 0 Maximum Design Heat Input (from mfg. spec sheet) Maximum Rated Total Flow Capacity SCtll scfd o Relocated Design Heat Content BTU/scf MMBTUfhr Control Device Information D o Type of Vapor Combustion Control? D Elevated Flare Enclosed Combustion Device Thermal Oxidizer Manufacturer: Model: o Ground Flare Hours of operation per year? List the emission units whose emissions are controlled by this vapor control device (Emission Point 10# Emission Unit 10# Emission Unit 10# Emission Source Description ) Emission Source Description If this vapor combustor controls emissions from more than six (6) emission units. please attach additional pages. Assist Type (Flares only) o0 Steam Pressure 0 0 Tip Diameter Flare Height Air Non Was the design per §60.I8? DYes o No Provide determination. feet feet Waste Gas Information Maximum Waste Gas Flow Rate (scfm) Pro~' ide all I Heat Value of Waste Gas Stream BTUfft) I Exit Velocity of the Emissions Stream (ft:s) attachment with the characteristics of the wa.rte gas stream to be burned. Pilot Gas Information Number of Pilot Lights Heat Input per Pilot BTUfhr Fuel Flow Rate to Pilot Flame per Pilot SCtll Will automatic re-ignition be used? DYes o No If automatic re-ignition is used, please describe the method. If Yes, what type? 0 Thermocouple o Infrared o Ultraviolet o Camera o Other: Is pilot flame equipped with a monitor to detect the presence of the flame? DYes o No Describe all operating ranges and maintenance procedures required by the manufacturer to maintain the warranty. (If unavailable. please indicate) . o Additional information attached? DYes No Please attach copies of manufacturer's data sheets, drawings, -flame demonstration per *60 .18 or *63.11 (b) and performance testing. 29 -86- CONDENSER General Information Installation Date: Control Device 10#: o New Manufacturer: Model: o Modified o Relocated I Control ~e'!ice Name: Control Efficiency (%) : Manufacturer's required temperature range for control efficiency, of Describe the warning and/or alarm system that protects against operation when unit is not meeting the design requirements : Describe all operating ranges and maintenance procedures required by the manufacturer to maintain the warranty, o Additional information attached? DYes No Please attach copies of manufacturer"s data sheets , Is condenser rOLlted to a secondary APCD or ERD? DYes No o 30 -87- ADSORPTION SYSTEM General Information Installation Date: D Modified New Control Device 10#: D Man ufacturer: Model: pesign Inlet Volume: o Relocated I Control Device Name: Adsorbent charge per adsorber vessel and number of adsorber vessels: scfm Length of Mass Transfer Zone supplied by the man u facturer: Adsorber diameter: Adsorb,er area: Adsorbent type and physical properties: Overall Control Efficiency (%): ft2 ft Working Capacity of Adsorbent .(%): Operating Parameters In let volume: scfm @ Monday, September 14, 2015 4:35 PM DEP GSO-A; Williams, Jerry 'demarco@wvonga.com'; 'Rebekah Hogue'; 'David L Yaussy'; McKeone, Beverly D; Durham, William F Comments of the West Virginia Oil & Natural Gas Association on the G35-C permit 2015-09-14 - G35C WVONGA comments.pdf JerryAttached is a scanned copy of the comments of the West Virginia Oil and Natural Gas Association with regard to the proposed G35-C general permit. Please contact Corky DeMarco or me if you have any questions regarding these comments. Thank you! Melissa Melissa Hatfield Atkinson, P.E. Co-Chair, WVONGA Environmental Committee Superoisor - Air Permitting, Northern Division Chesapeahe Energy Corporation Office: 304-353-5118 Mobile: 304-380-3074 This email (and attachments If any) is intended only for the use of the individual or entity to which it is addressed, and may contain information that is confidential or privileged and exempt from disclosure under applicable law. If the reader of this email is not the intended recipient, or the employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately by return email and destroy all copies of the email (and attachments if any). 1 -222- WeST VIRGINIA OIL AND NATURAL GAS AssocIATION September 14, 2015 By I-mail to DEPG80A@wv.gov Mr. Jerry Williams, P.E. Division of Air Quality West Virginia Department of Environmental Protection 601 57th Street, SE Charleston, WV 25304 Re: Comments on praft Class II General Permit G35-C Mr. Williams: The West Virginia Oil and Natural Gas Association CWVONGA',) appreciates the opportunity to provide the following ~omments on the West · Virginia Department of Environmental Protection Division of Air Quality's ("WVDAQ") proposed Class II General Permit G3S-C for the Prevention and Control of Air Pollution in regard to the Construction, Modification, Administrative Update and Operation of Natural Gas Compressor and/or Dehydration Facilities (the "Draft General Permit"). Chartered in 1915, WVONGA is one of the oldest trade organizations in the State, and is the only association that serves the entire oil and gas industry. The activities of our members include construction, environmental services, drilling, completion, gathering, transporting, distribution and proceSSing. WVONGA members operate in almost every county in West Virginia and employ thousands of people across the State, with payrolls totaling hundreds of millions of dollars annually. Our members have cumulative investment of nearly ten billion dollars in West Virginia, account for 80% of the production and 90% of the permits, operate more than 20,000 miles of pipeline across the state and provide oil and natural gas to more than 300,000 West Virginia homes and businesses. As such, WVONGA's members have a keen interest in all aspects of environmental regulation associated with oil and gas activities, including the Draft General Permit. A. General Comments on Draft General Permit 1. Potential to Commence Construction (45 C.S.R. 16) WVONGA requests that WVDAQ modify the Draft General Permit to incorporate the requirements of 45 C.S.R. 13 ("Permission to Commence Construction in Advance of Permit -223- Mr. Jerry Williams, P.E. September 14, 2015 Page 2 Issuance") for existing facilities. This approach would allow companies the option to include elements of the "Permission to Commence Construction" application in the application for the Draft General Permit 2. Like-Kind Replacement WVONGA requests that WVDAQ consider incorporating into the Draft General Permit the express authorization of like-kind replacements for all equipment and control devices permitted under the G35-C, and require companies to keep records of such replacements that demonstrate that the emissions are less than or equal to those claimed for the original equipment This is authorized under 45 C.S.R. 13-5.13 and -5.14, and could be incorporated into Section 3.0 or 4.0 of the Draft General Permit 3. Incorporation of 40 CFR 60, Subpart OOOOa WVONGA proposes doing away with all LDAR requirements in this permit. However, to the extent they remain in the permit, WVONGA suggests that permittees be allowed to implement the LDAR requirements of 40 CFR 60, Subpart OOOOa, which was proposed August 18, 2015. the DAQ should consider allowing permittees the option of applying the proposed LDAR program for facilities that are constructed and equipment installed after that date, in lieu.ofthe LDAR and closed vent requirements of this proposed permit. The LDAR requirements in final Subpart OOOOa will likely change little, and many permittees may decide that it makes sense to prepare now for changes that are likely to be effective in the future. Any changes in the final federal rule can be implemented through an amendment to the permit at some later time. For those facilities and equipment that are not subject to Subpart OOOOa, we urge the DAQ to remove all references to LDAR or closed vents, as there is no support for regulating fugitives in the manner the DAQ has proposed. B. Specific Comments 1. General Permit Registration (Section 1.0) Section 1.1.1. WVONGA requests the explicit inclusion of sources that are less than the modification levels as defined in 45 C.S.R 13 and are not subject to an applicable substantive standard or regulation. This would allow flexibility in the Draft General Permit for minor changes that do not meet the definition of "modification" and are consistent with 45 C.S.R 13. Section 1.1.5. WVONGA requests that calculation methods used in the permit application be listed as an additional approved calculation method, without requiring WVDAQ approval. Calculation methods that were sufficient for purposes of permitting should be sufficient for purposes of recordkeeping, and allowing use of the same methods would result in consistency in calculating emissions and easy comparison of permitted to actual emissions. We suggest the section be amended by adding the following phrase: "... -224- Mr. Jerry Williams, P.E. September 14, 2015 Page 3 sample and/or test data, calculation methods used in preparation of the permit application, or other methods approved by the DAQ..." 2. Applicability (Section 2.3) Section 2.3.1.g. WVONGA notes that some operators are increasing the use of turbines in their operations, but that turbines subject to NSPS, Subpart KKKK are not permittable under the Draft General Permit Accordingly, WVONGA requests that WVDAQ eliminate the prohibition in Section 2.3.1.g and incorporate the requirements of NSPS 40 C.F.R. 60 Subpart GG and 40 C.F.R. 60 Subpart KKKK, in order to make these turbines eligible for permit coverage. Section 2.3.1.h. This section excludes from coverage under the Draft General Permit "[a]ny natural gas production, compressor, and/or dehydration facility which will require an individual air quality permit review process and/or individual permit provisions to address the emission of a regulated pollutant or to incorporate regulatory requirement(s) other than those established by General Permit G35-C. This would include "synthetic minor" permitting actions, as they are required to undergo Notice Level C under 45 CSR 13 Section 8.5." While WVONGA understands that the intent of this section is to exclude from coverage those facilities requiring or otherwise seeking site-specific conditions or review not otherwise accounted for in the Draft General Permit, some of the language of this section is confusing. First, WVONGArequests clarification as to what constitutes an "individual air quality permit review process" -presumably this is intended to include only the individual permitting process under 45 C.S.R 13 and not a permit determination or aggregation analysis. Further, the express prohibition of "synthetic minor" permitting through the Draft General Permit may raise some logical inconsistencies with some of the limitations that are authorized in the Permit (e.g., having a backup pump on a glycol dehydrator, but only running one pump at a time). 3. Duty to Comply (Section 2.9) Section 2.9.1. WVONGA requests the inclusion of an explicit authorization in this section to construct and/or operate changes that do not meet the definition of modification as defined in 45 C.S.R 13. Further, WVONGA requests that this language be expanded to include other operating scenarios authorized under the Draft General Permit to maximize the flexibility and utility of the permit. 4. Inspection and Entry (Section 2.10) Section 2.10.1.c. For safety reasons, WVONGA requests that this section be revised to include language requiring any authorized representative of the Director wishing to access the permitted facility to contact company personnel prior to entering the facility to ensure that all necessary safety precautions are taken. -225- Mr. Jerry Williams, P.E. September 14,2015 Page 4 5. Facility-Wide Requirements (Section 3.0) Section 3.2.8. The WVDAQ has no authority to regulate noise and light, and it cannot impose limitations in the Draft Permit that purport to regulate noise and light. Even if it could, the prohibition of a "nuisance" and "unreasonable light and noise" is too vague to enforce, as it gives the permittee no guidance as to what constitutes permitted behavior. This section should be eliminated from the Draft General Permit. 6. Units Listed in General Permit Registration (Section 4.0) Section 4.1.1. To reduce ambiguity regarding applicable requirements, WVONGA requests that the phrase "or as set forth by any State rule, Federal regulation, or alternative control plan approved by the Secretary" be eliminated. Otherwise, this language introduces uncertainty as to when an alternative rule would apply in lieu of the Draft General Permit requirements. Sections 4.1.3 and 4.1.4. The Draft General Permit would impose significant requirements relating to fugitive emissions and leak detection compliance requirements. WVDAQ has derived its authority for these requirements from 45 C.S.R. 13-5.11, which allows the DAQ to impose "reasonable conditions" in a permit. However, these leak detection requirements are not specified elsewhere in 45 CSR 13 or in another rule adopted by the DAQ, and we are not aware of any federal rule that imposes this type of leak detection on units covered by the Draft General Permit. The West Virginia Air Pollution Control Act expressly provides that "[n]o legislative rule or program of the director hereafter adopted shall be any more stringent than any federal rule or program except to the limited extent that the director first makes a specific written finding for any such departure that there exists scientifically supportable evidence for such rule" or program reflecting factors unique to West Virginia or some area thereof." W Va. Code § 22-54 (a) (4). Absent some applicable federal requirem~nt or an express finding that conditions unique to oil and gas development in West Virginia merit imposing these additional, more stringent requirements on sources to be governed by the Draft General Permit, thes"e new and far-reaching leak detection requirements are inappropriate and should be deleted. Indeed, these requirements are more stringent than many other more complex permitted facilities in the state. Another reason to leave out the LDAR requirements for existing facilities and equipment is EPA's proposed leak detection and repair requirements in 40 CFR 60 Subpart OOOOa. Whatever the final details of that rule, it will become the de facto standard for LDAR. Rather than having two standards, one that applies pre-August 18, 2015 and postAugust 18, 2015, it would make more sense to leave off the permit's proposed LDAR obligations, and wait for a final federal rule. (As more fully explained in Section A.3 of these comments, if LDAR requiremtns remain in the permit, we suggest that the WVDAQ allow permittees to use the LDAR requirements of 40 CFR 60, Subpart OOOOa for facilities and -226- Mr. Jerry Williams, P.E. September 14, 2015 . Page 5 equipment that are installed after August 18, 2015, in lieu of any other LDAR requirements.) In the event these requirements are not eliminated, Section 4.1.4 requires the maintenance of quarterly records of fugitive emissions for "each facility component that was inspected for fugitive escape of regulated air pollutants." WvONGA requests that this section be revised to authorize the documentation of leaks by equipment type rather than by component, given the very high number of individual components likely to be present at any given permitted facility. WVONGA also suggests that the Draft Permit authorize a reduction in the frequency of LDAR monitoring based on the number of leaks detected. For example, Ohio's protocol is as follows: (1) An initial monitoring shall be completed within 90 days of startup and quarterly thereafter for a period of four consecutive quarters (1 year); (2) If, following the initial four consecutive quarters, less than or equal to 2.0% of the facility components are determined to be leaking during the most recent quarterly monitoring event, then the frequency of monitoring can be reduced to semiannual; (3) If, following two consecutive semi-annual periods, less than 2.0% of the ancillary equipment are determined to be leaking during the most recent semi-annual monitoring event, then the frequency of the monitoring can be reduced to annual; (4) If more than or equal to 2.0% of the ancillary equipment are determined to be leaking during anyone of the semi-annual or annual monitoring events, then the frequency of monitoring shall be returned to quarterly. WVONGA suggests adopting a similar protocol in the Draft General Permit. Finally, WVONGA requests a change to the last paragraph of Section 4.1.4 to include any facility component satisfying the outlined conditions for delay of repair. This could be done by amending the sentence in the following manner: "Delay of repair of a €lased veRt system any facility component for which leaks or defects have been detected is allowed if the repair is technically infeasible without a shutdown..." 7. Storage Vessels Containing Condensate and/or Produced Water (Section 5.0) This section should be modified to exclude produced water tanks with greater that 90% produced water, as these tanks have minimal emissions. That could be done by changing the title to ("Storage Vessels Containing Less Than 90% Produced Water")" Section 5.1.2. WVONGA requests revision of this section to authorize changes that do not exceed the definition of "modification" as allowed by 45 CSR 13. -227- Mr. Jerry Williams, P.E. September 14, 2015 Page 6 Section 5.1.3. Most produced water tanks do not have an emission limit, consistent with the WVDAQ's own guidance. WVONGA requests confirmation that a tank that is not otherwise required to have a limit is not required by this section to obtain one. Section 5.1.5.2. This section specifies the applicable General Permit sections for control devices that are subject to control device requirements of NSPS Subpart 0000. The condition states the registrant shall be subject to the control device and closed vent system requirements of section 7.0 of this general permit. However, this is a relic from the proposed General Permit GSO-A. Control devices subject to the requirements of NSPS Subpart 0000 should be subject to section 6.0 of the draft General Permit G35Section 5.1.6.2.i. Flowback is a wellsite-specific event that would be more appropriate in a producer permit. WVONGA requests a more logical requirement such as "within thirty (30) days of startup" or allowing samples to be taken in the same time frames as gas samples for dehydrators. Section 5.2.2.1. This section requires the registrant, for uncontrolled production storage vessels that are fed by a gas to liquid separator, to inspect and maintain records of the separator liquid level that opens the dump valve for uncontrolled production storage vessels on an as-needed basis and annually (at a minimum). Liquid level inspection in separators is not practical, and this requirement should be deleted. Section 5.3.2. This section requires the registrant to maintain records of the determination of the VOC emission rate per storage vessel, including identification of the model or calculation methodology used to calculate the VOC emission rate. WVONGA notes that not all companies calculate tank emissions on a per-tank basis, but rather as a aggregate emissions point, and we urge the WVDAQ to allow aggregate emission reporting. 8. Control Devices and Emission Reduction Devices Not Subject to NSPS Subpart 0000 (Section 7.0) Section 7.1. WVONGA requests confirmation that this section is limited in scope to non-engine control devices. To the extent that this is the case, WVONGA recommends adding an express statement to this effect in the introductory "scope" narrative under Section 7.1. Further, all references "Emission Reduction Devices" should be changed to "Process Modifications," as this is more accurate terminology for the equipment being addressed here. 1 Additionally, the Scope narrative explains that if a control device is subject to NSPS Subpart 0000 requirements, then it is subject to Section 7.0 of the General Permit G35-C. Corresponding changes should be made throughout the Draft General Permit and application forms wherever this term is used. For purposes of clarity in providing these comments, however, WVONGA will use the terminology currently contained in the Draft General Permit. -228- Mr. Jerry Williams, P.E. September 14, 2015 Page 7 However, this is a relic of the proposed General Permit G80-A. The required applicable section should now be Section 6.0 for control devices subject to NSPS Subpart 0000. This comment also applies to Section 7.1.2.1, which again refers to Section 7.0 for control devices subject to NSPS Subpart 0000, when it should refer to Section 6.0. Section 7.1.2.2. WVONGA offers the following comments on this section: • • • • • • • • Section 7.1.2.2.ii. This language does not account for pilotless flares. Section 7.1.2.2.iii. This language appears to assume that all flares will be subject to 40 C.F.R. § 60.18, which is not the case (e.g., pressure-assisted flares). Ifa flare is not otherwise subject to a NSPS, the Draft General Permit should not require compliance with this provision. Sections 7.1.2.2.ii and iv. These sections appear to conflict with one another. Does the flare have to operate with a flame present at all times (per ii) or only when emissions are vented to it (per iv)? Section 7.1.2.3. WVONGA offers the following comments on this section: Section 7.1.2.3.ii.. WVONGA requests the inclusion of language authorizing autoignite enclosed flares. Section 7.1.2.3 .iii. This section requires enclosed combustion devices to be designed for and operated with "no visible emissions." This requirement directly conflicts with the 20 percent opacity limitation contained in 45 C.S.R. 6-4.3. As currently drafted, it appears that any visible emissions would automatically constitute a violation of the Draft General Permit, which is unreasonable. At a minimum, th~ Draft General Permit should be revised to be consistent with 45 C.S.R. 6. Further, the references in Section 7.1.2.3.iiLb to NSPS Subpart 0000 subsections are inappropriate because this section of the Draft General Permit expressly applies to those control devices not subject to NSPS Subpart 0000. . Section 7.1.2.3.iv. WVONGA requests the removal of the closed vent system requirement set forth here. This is another requirement that will likely conflict with the final OOOOa fugitive control provisions. Sections 7.1.2.3.ii and iv. These sections appear to conflict with one another. Does the enclosed combustion device have to operate with a flame present at all times (per ii) or only when emissions are vented to it (per iv)? Section 7.1.3. WVONGA offers the following comments on this section: • • Section 7.1.3. This section should refer to Section 5.1.4, not 5.1.2, regarding emissions determination from storage vessels. Section 7.1.3.2.iv. WVONGA requests the removal of the closed vent system requirement set forth here. Section 7.1.4. For the reasons discussed above in relation to Sections 4.1.3 and 4.1.4 of the Draft General Permit, WVONGA objects to the imposition of new LDAR requirements -229- Mr. Jerry Williams, P.E. September 14, 2015 Page 8 in this section. See Sections 7.1.4.1. and 7.1:4.2. Additionally, this section should refer to Section 5.14, not 6.1.4, regarding emissions determinations from storage vessels. Section 7.1.5.yi. The Draft General Permit requires the registrant to keep on-site fresh replacement for all carbon used in a carbon adsorption system. The regulatory authority for this requirement is unclear, as the Draft General Permit does not include a citation for this provision. This is expected to create logistical problems, particularly at unmanned facilities where the materials may be subject to theft. Accordingly, WVONGA requests the deletion of this requirement. Section 7.1.6. WVONGA offers the following comments on this section: • Section 7.1.6.ii. This section requires the condenser/BTEX Eliminator to be designed, operated and maintained according to good engineering practices and manufacturer's specifications so as to achieve, at a minimum, a capture and control efficiency of 50%." WVONGA is unclear on the basis for this limitation in the absence of an NSPS requirement. Is WVDAQ's intent to allow the registrant to claim a maximum capture and control efficiency of 50% unless it can provide documentation of greater reductions? Additionally, does this section conflict with Section 7.1.6.i, which requires routing vapors through a closed vent system to the condenser/BTEX Eliminator "at all times"? WVONGA believes that Section 7.1.6.ii and 7.1.6.ii.a are overly prescriptive and suggests that they be deleted. Section 7.1.7. Section 7.1.7.i requires the registrant to comply with the closed vent system requirements of Section 7.1.4 of the Draft General Permit. It is not appropriate to impose closed vent requirements on a non-NSPS Subpart 0000 source regulated under this section. This is also not applicable to sources not subject to an NSPS or NESHAP controls. Section 7.1.8. This section appears to mix two possible systems for the control or recycling of possible emissions from a dehydrator-a condenser and a flash tank. WVONGA believes that this section is unusable as currently drafted because it is possible to have one or both of these systems on a dehy. Section 7.1.8.a is redundant for a condenser, as this is addressed in Section 7.1.6.i. Section 7.1.8.b is problematic because if a dehydrator does not have a condenser it is impossible to burn vapors in the reboiler from the still column as the water content is too great. Additionally, if a dehydrator has only a condenser, it is possible for natural gas to be the primary fuel for the reboiler. With regard to Section 7.1.8.c, again, if a dehydrator does not have a condenser then it is impossible to burn vapors from the still column as the water content is too great. Often, a dehydrator equipped with a condenser does not use the non-condensables as a primary fuel because this has the chance of putting out the reb oiler flame. It is introduced to the flame zone in addition to the primary burner fuel and has a back-up system that will control the vapors if the reboiler turns off. There is a great variety of ways that this is done, including but not -230- Mr. }erryWilliams, P.E. September 14, 2015 Page 9 limited to glow plugs, extra burners, and some burn management systems. Additionally, Section 7.1.8.c would not apply to a dehydrator that has a flash tank only. Section 7.1.8 goes on to limit the control and capture efficiency to 50% unless a company is approved based on manufacturer's specifications. This again appears to mix a condenser and a flash tank. . First, a condenser and flash tank will have two different percentage rates by which they will limit emissions that are unrelated to each other. This can even be seen in the emission calculations for a dehydrator. The calculations treat these systems as separate limiting factors. The condenser will be more likely to be based on manufacturer's design. A flash tank will be more related to the BTU/scf of the gas, glycol pump type, and the size of the reboiler that is attached to the dehydrator. For that reason, it is highly unlikely that a company will be able to provide manufacturer's specifications for a flash tank. Additionally, in dry gas areas 85% has been a standard capture efficiency for a flash tank and has in the past and currently been accepted by many states. Due to this conflation of the condenser and flash tank systems, WVONGA believes that this section will be unusable for dehydrators that have a condenser only, flash tank only or both, and require companies with such dehydrators to obtain an individual permit under 45 C.S.R. 13. Because dehydrators are one of the most common pieces of equipment in oil and gas operations and flash tanks are common, this would mean that a sizable number of sites would not be able to use this general permit. Accordingly, in order to avoid redundancy with Section 7.1.6, WVONGA suggests that this section be rewritten for requirements for a flash tank only, as follows: 7.1.8. Glycol Dehydration Units Equipped with a Flash Tank. If the registrant reduces waste gas by recycling it as fuel via process design, such as the use of a dehydration flash tank back to the flame zone of the reboiler, it may be designed and operated in accordance with the following: a. The reboiler shall only be fired with vapors from a flash tank or noncondensables from a condenser, and natural gas may be used as a supplemental fuel. Please note that WVONGA has the same concerns about the control efficiency of 50% referenced in the last paragraph that we noted with regard to Section 7.1.6. However, if an efficiency requirement is to be retained, WVONGA suggests rewording the last paragraph of Section 7.1.8. to the following: The registrant may claim a recycling factor of 50% for wet gas and 85% for dry gas systems for those units meeting the requirement of 7.1.8.a. The registrant may claim a recycling factor greater than 50% or 85% if the General Permit Registration was approved based on manufacturer's specifications or calculations based on gas analysis, glycol pump type and -231- Mr. Jerry Williams, P.E. September 14,2015 Page 10 burner size. An additional capture and control efficiency can be applied to flash tanks that are routed to another type of control listed in section 7 as either a secondary or primary control of the vapor. Section 7.2.1. The Draft General Permit requires the pilot flame for flares and enclosed combustion devices to be "equipped such that it sounds an alarm, or initiates notification via remote alarm to the nearest field office, when the pilot light is out." Again, the regulatory basis for this requirement is unclear. Many remote locations may not be equipped with such an alarm. Further, this does not account for multiple pilots (if one pilot goes down but others remain lit, would an alarm have to be sent?), and this section should not apply if the unit is equipped with an automatic re-igniter. Section 7.2.2. The requirements of this section relating to the initial leak inspection and subsequent leak monitoring requirements are overbroad and unduly burdensome. These are not appropriate for controls not subject to NSPS Subpart 0000. Section 7.2.3. Please see the comment to Section 7.2.1, above, regarding the requirement to equip a pilot flame with an alarm. Section 7.3.1. This section prescribes testing requirements relating to the visible emissions requirements in Sections 7.1.2.2, 7.1.2.3 and 7.1.2.6 of the Draft General Permit. As stated above, WVONGA objects to these requirements on the ground that they would render any visible emissions an automatic violation of the Draft General Permit, and contradict the 20 percent opacity limitation contained in 45 C.S.R. 6. Furthermore, the testing protocols required in this section are much more stringent than other sources currently permitted in West Virginia, and without any regulatory basis; WVONGA suggests that the opacity limitations from 45 C.S.R. 6 be incorporated into the Draft General Permit as the governing standard-which may already be the case, pursuant to Section 7.1.2.6, although it is unclear how this provision relates to other sections relating to visible emissions-and then, if visible emissions are detected using Section 11 of EPA Method 22, the registrant should be given a certain timeframe in which to correct the issue. If a followup test using Method 22 indicates that the leak persists, then a Method 9 test may be appropriate within 10 days thereafter (due to difficulties in getting someone who is certified to perform Method 9 tests out to the individual sites immediately). Section 7.3.3. WVONGA notes that several of the methods referenced in this section are not included in 45 C.S.R. 6-7.1 and may not be appropriate for use here. Specifically, Method 5 is unnecessary and would prove very difficult, if not impossible, to perform with any accuracy due to the high temperatures and the lack of sampling access on flare exhaust stacks. Special equipment such as glass filter frits and quartz probe liners would be needed just to handle the heat. The preferred nozzle (glass) would not be possible since the union used to connect glass probe nozzles to probe liners must be made of Teflon (max sampling temperature of Teflon is 500°F) to prevent nozzle damage. Furthermore, filter and probe temperatures are almost impossible to maintain at the required 248± 25°F due to the -232- Mr. Jerry Williams, P.E. September 14,2015 Page 11 extremely high temperature gas samples being drawn into the sampling system. Since the flare is used to burn natural gas that has a very low particulate loading, a full blown Method 5 partic.ulate test will most likely not tell you anything you could not surmise from a visual observation of the exhaust. When you consider the applicable Method 22 opacity testing requirement this seems, at the very least, duplicative. Method 18, for many of the same reasons stated above, will not be possible on these types of sources. The Tedlar bags used in this method can only handle about 225°F and any Teflon components in the sample train will start to deform above 500°F. Again, when a flare is operating it is controlling emissions sufficiently and performing a stack test is duplicative in nature and simply not necessary. Section 7.4.1. It appears that this section presumes that a flare-specific on-site design evaluation will be done in accordance with 40 C.F.R § 60.18. Again, WVONGA notes that some flares are not subject to 40 C.F.R. § 60.18, and therefore requests confirmation that such flares would not have to comply with this requirement. If that is the case, WVONGA suggests adding express language to this section limiting its applicabIlity to any flares subject to 40 C.F.R § 60.18. Section 7.4.5. For the reasons discussed above in conjunction with Section 7.2.2, the closed vent monitoring requirements should not be applicable to non-NSPS Subpart 0000 sources and therefore should be deleted from the Draft General Permit. Section 7.4.8. This section requires that any records submitted to the agency pursuant to a requirement of the permit or upon request by the Director be certified by a responsible official. WVON GA suggests adding "upon request by WVDAQ" to the end of this sentence, as records that are provided to agency officials during inspections and otherwise frequently are not individually certified. Section 7.4.9. This section would require the registrant to record the volume of gas flared and the heating value of the gas flare on a monthly basis to demonstrate compliance with the maximum heat design input for a flare or enclosed combustion device. This requirement is unnecessary and overly burdensome for ensuring compliance with the maximum heat design input, and not all operators have a means of readily collecting this information. Section 7.4.10. For the glycol dehydrators that have condenser overheads that are routed to a combustion device or to the reboiler to be combusted, WVONGA believes this requirement is unnecessary, and accordingly, WVONGA requests the deletion of this requirement. Additionally, for the glycol dehydrators that have the condenser overheads vented to the atmosphere rather than combusted, WVONGA suggests that monitoring be quarterly, as in Section 14.2.3. -233- Mr. Jerry Williams, P.E. September 14, 2015 Page 12 Section 7.5. WVONGA submits that this entire section is without a regulatory basis (and the Draft General Permit cites to no authority for any of the requirements in this section), and as such constitutes an unreasonable overreach by the agency in the context of the relatively minor sources to be permitted subject to the Draft General Permit. Further, with regard to Section 7.5.3 specifically, WVONGA questions why any reporting is necessary in the absence of any exceedance of emissions, regardless of the operational status of the air pollution control device. 9. Reciprocating Internal Combustion Engine(s) (RICE), Generators (Section 12.0) Section 12.1.3.d. WVONGA requests confirmation that the r~quirement to "monitor" the temperature to the inlet of the catalyst does not require that this information be recorded, as this is typically not the case-rather, it is monitored and the unit will alarm and shut down in the event of high temperature. WVONGA also questions whether thermal deactivation is such a common issue that it needs to be addressed in such a specific, prescriptive manner in this section of the permit, rather than as a part of the registrant's normal operation and maintenance procedures Section 12.1.3.e WVONGA requests that this requirement be removed since this is addressed in NESHAP ZZZZ and NSPS IIJJ and can have different requirements. Section 12.1.5. This section would require emissions from startup and shutdown to be included in calculating the 12-monthroIling emissions total. WVONGA requests clarification regarding from the agency regarding what emissions, are considered to be "startup and shutdown" emissions. 10. Tanker Truck Loading (Section 13.0) Section 13.1.2. WVONGA requests revision of this section to authorize changes that do not exceed the definition of "modification" as allowed by 45 C.S.R. 13. Section 13.1.4. Not all registrants will use capture efficiencies in their emissions calculations. We suggest the first sentence of this section be amended to read "To the extent a registrant intends to claim a capture efficiency in calculating emissions. the following applicable capture efficiencies are required:" In addition, Section 13.1.4 requires submission of certification with the G35-C Annual Certification. We do not see any requirement for an annual certification in the Draft Permit. Section 13.2.2. Certification of truck fleet compliance with Section 13.1.2 is to be submitted to the Director in writing, but there is no deadline for this certification. This could be addressed in a reporting section. -234- Mr. Jerry Williams, P.E. September 14,2015 Page 13 11. Glycol Dehydration Units (Section 14.0) Section 14.1.2. For purposes of consistency with the monitoring frequency required in Section 14.2.3 of the Draft General Permit, WVONGA requests that the 12-month rolling total be based on the sum of the quarterly throughput (versus monthly throughput). Section 14.1.6. WVONGA requests that language be added to this section to clarify that backup pumps do not have to be considered as operating for purposes of calculating potential to emit here. Section 14.2.1. For purposes of clarity and consistency with what we believe is the agency's intent, WVONGA recommends that this section be revised as follows: "To demonstrate compliance with Section 14.1.2 of this general permit, the registrant shall monitor the throughput of dry natural gas fea to from the dehydration system on a moRthly quarterly basis ...." The proposed change to quarterly monitoring is consistent with Section 14.2.3. Section 14.2.3. For purposes of assigning a "default value" for maximum design capacity as contemplated in Section 14.2.3.a.iv, WVONGA notes that this is a documented value that is a part of the registrant's application. Section 14.3.1. WVONGA requests confirmation that advance notification of the sampling to be conducted pursuant to this section is not required. Section 14.4.1. Consistent with its previous comments, WVONGA requests that the reference to monthly dry natural gas throughput records be changed to quarterly. Section 14.5.2. WVONGA submits that this should not be required if the source was permitted as such and has not exceeded any permitted limits. C. Comments on Application Forms WVONGA appreciates the Significant improvements made to the application forms following the close of the comment period on the Draft General Permit GaO-A. However, WVONGA notes that in certain places the forms continue to prompt the entry of data multiple times and in multiple places, which increases the likelihood of errors that may result in permit delays. Accordingly, WVONGA ·urges WVDAQ to review the proposed forms once more in an effort to eliminate all duplicative data entry requirements. WVONGA also offers the following specific comments on the application forms and attachments: 1. General Permit Registration Application (pp. 1-2) -235- Mr. Jerry Williams, P.E. September 14,2015 Page 14 For purposes of clarity and ease in completing the application forms, WVONGA suggests that the individual check boxes for construction, modification and relocation at the top of page 1 of the application be replaced with a single box for "New Registration" (as modifications and relocations are not expected to be applicable here). Corresponding changes (from "Construction, Modification and Relocation" to "New Registration," deleting unnecessary references to "modifications" and "relocations," etc.) should be implemented throughout the forms. The Class I and Class II Administrative Update boxes should remain as-is in the Draft General Permit. In the last row on page 2, the application requires the registrant to provide "One (1) paper copy and two (2) copies of CD or DVD· of pdf copy of Application and Excel Spreadsheets (plot plans, all attachments and supporting documents)." WVONGA notes that plot plans are not easily convertible to PDF and as such requests that one paper copy of these plans is sufficient to provide with the application (particularly as any PDF of a plot plan is likely to be too small to read anyway). Finally, WVONGA believes that this form needs to be clearer regarding what documentation and forms are required for the different types of applications. For example, is a plot plan required when filing for an administrative update? 2. Attachment A - Single Source Determination Form It appears that the current proposed version of this form-as revised from the version included with the draft General Permit G80-A earlier this year-would require all applicants to provide a narrative source aggregation analysis, those facilities located within one mile of another facility owned by or associated with the natural gas industry would also have to complete the extensive "Single Source Determination Form" checklist. While WVONGA appreciates the agency's limitation of the requirement to fill out the detailed checklist, WVONGA continues to believe that this checklist will create far more confusion for both the regulated community and the agency than the current narrative-only approach. Despite this attempt to systematize and simplify the aggregation analysis, the fact remains that whether aggregation is appropriate is a highly site-specific inquiry that is best evaluated on the basis of a narrative justification. Furthermore, it is unclear from the checklist what additional "explanations" regarding the specific questions would be required beyond what the applicant presumably already would have included in its narrative discussion on page 3. Finally, WVONGA notes that the current checklist ultimately may end up conflicting with any revisions to the aggregation analysis ultimately finalized by the United States Environmental Protection Agency. Accordingly, WVONGA suggests thaf WVDAQ delete the proposed checklist in favor of requiring a narrative aggregation analysis/justification only, consistent with current practice. 3. Attachment F - Plot Plan -236- Mr. Jerry Williams, P.E. September 14,2015 Page 15 WVONGA notes that a plot plan should not be required for an administrative update that does not affect the location of an emission point or the location of the facility. 4. Attachment G - Area Map Like the plot plan discussed above, an area map should not be required for an administrative update that does not affect the location of an emission point or the location of the facility. 5. Attachment ( . .; Emission Units/Emission Reduction Devices (ERD) Table WVONGA offers the following comments on this attachment: • • • • 6. The reference in the header of the Table to "Emission Reduction Devices" should be changed to "Process Modifications."z WVONGA notes further that control devices and ERDs are not interchangeable like Section 8.0 of the Draft General Permit treats them-many of the "emissions reductions devices" are treated separately by the Draft General Permit as quaSi-controls, despite being legitimate process configurations. These terms are not defined in the permit to provide the needed clarity. The introductory language at the top of the table should clarify that this attachment does not apply to sources of fugitive emissions. WVONGA approves of the agency's deletion of language requiring the applicant to list all storage vessels associated with the permitted facility's operation, including those that have "negligible emissions," in this table. WVONGA seeks confirmation that these de minimis tanks are no longer required to be included in Attachment I (i.e., and they are to be enter~d into Attachment L only). The fourth column on the chart would require the registrant to provide the "Year Installed/Modified:" WVONGA requests that the agency delete the reference to modification as confusing and potentially duplicative, as any change will be captured in the seventh column ("Type and Date of Change"). Attachment J- Fugitive Emissions WVONGA offers the following comments on this attachment: • WVONGA incorporates its comments relating to the monitoring frequency for fugitive emissions in the Draft General Permit, above, and requests the deletion of the "Monitor Frequency" column in ~e table on page 12. 2 Corresponding changes should be made throughout the Draft General Permit and application forms wherever this term is used. For purposes of clarity in providing these comments, however, WVONGA will use the terminology currently contained in the Draft General Permit. -237 - Mr. Jerry Williams, P.E. September 14, 2015 Page 16 • WVONGA notes that the form on page 12 could cause confusion by requiring the applicant to denote "Closed Vent System" and "Stream Type" for each type and count of component. It becomes unclear how to complete this form if there are valves in both gas and liquid service, for example. Additionally, these two fields provide no benefit to WVDAQ, as they will not provide any additional information for regulatory applicability or for inspections. • At the bottom of the table on page 12, WVDAQ requests the applicant to provide an explanation of the sources of fugitive emissions, including pneumatic controllers. Historically, WVDAQ has not required any information on pneumatic controllers to be included in the permit application. The reference to pneumatic controllers in this question should be removed. • The question at the bottom of the table on page 12 relating to closed vent bypasses is unnecessary. Such systems are either not regulated or are regulated by NSPS Subpart 0000. If they are subject to NSPS Subpart 0000, the general references to the regulation in the Draft General Permit itself would cover all regulatory requirements. This question provides no additional value to the forms. 7. Attachment K - Storage Vessel Data Sheet The Storage Tank Data Table on page 18 of the application prompts the applicant to identify all de minimis storage timks. WVONGA requests clarification as to how companies should address the installation or removal of de minimis tanks, as emissions from these tanks do not have to be quantified and the tanks are not subject to emissions limits. Will a notification to WVDEP be required of any change in the number of de minimis tanks on site? 8. Attachment M - Internal Combustion Engine Data Sheet WVONGA offers the following comments on this attachment: • In the seventh row of the table on page 20, WVONGA requests clarification regarding what the agency means by "NESHAP ZZZZjNSPS JIIJ Window." • WVONGA requests clarification of whether, by checking "yes" in response to the question of whether the Air Pollution Control Device Manufacturer's Data Sheet is included on the "Engine Air Pollution Control Device" form on page 22, the remainder of the form can be left blank • The "Engine Air Pollution Control Device" form on page 22 requires the registrant to specify the "Service life of the catalyst." This is unnecessary and will vary. The "Pressure drop against the catalyst bed" also changes. • WVONGA objects to the requirement in the "Engine Air Pollution Control Device" form on page 22 to specify the recommended frequency of replacement of the catalyst as unnecessary and irrelevant. The purpose of this requirement is unclear. • As a global comment on the "Engine Air Pollution Control Device" form on page 22, WVONGA notes that much of this information should not be necessary to -238- Mr. Jerry Williams, P.E. September 14,2015 Page 17 provide if the manufacturer's data sheet is included with the application. The agency should take all efforts to minimize unnecessary duplication. 9. Attachment 0 - Glycol Dehydration Unit Data Sheet WVONGA offers the following comments on this attachment: • In the "Date Installed/Modified/Removed" field, the reference to "removal" should be deleted. Why would a form be completed for the removal of a dehy? Corresponding changes should be made to footnotes 1 and 2 on page 25. • The purpose of the series of questions relating to NESHAP Subpart HH is not clear. If this subpart is referenced generally in the Draft General Permit and an applicant has the option to have a dehy that is either above or below the control thresholds in NESHAP Subpart HH, there is no purpose for including these questions in the application. 10. Attachment Q - Air Pollution Control Device / Emission Reduction Device Sheets WVONGA offers the following comments on this attachment: • Consistent with its comments elsewhere, all references to "Emission Reduction Device" should be changed to "Process Modification." • Comments on the "Vapor Combustion" form on page 28: o The form prompts the registrant to "Describe all operating ranges and maintenance procedures required by the manufacturer to maintain the warranty. (If un available, please indicate)." The purpose and relevance of this information is unclear. Further, in many cases specific units will not have been purchased yet at the time that the registration is filled out; by requiring this type of extremely specific information, the agency is encouraging last-minute permitting and precluding permitting ahead, which thereby creates a need for permits to be processed in a more expedited fashion than they otherwise would have been. WVONGA requests clarification/confirmation that a permit application may be submitted without this specific information (i.e., such that · the information would be indicated as "unavailable" here on the form) and the application would still be considered "complete" for purposes of its processing by the agency in accordance with applicable statutory timeframes. • Comments on the "Adsorption System" form on page 30: o It is unclear what certification WVDAQ is referring to by the question "Has the control device been tested by the manufacturer and certified?" If the purpose of the question is to determine whether the control efficiency is guaranteed, that information is on the form elsewhere. WVONGA requests the removal of this question. -239- Mr. Jerry Williams, P.E. September 14,2015 Page 18 11. Attachment R' - Emissions Calculations WVONGA offers the following comments on this attachment: • WVONGA requests that WVDAQ make its emissions summary sheets available in Excel format. This will make the provision of the requested information much simpler and foster consistency. • WVONGA notes that it is unnecessarily duplicative to provide emissions on separate forms AND here. This increases the likelihood of unintentional errors and confusion without any corresponding benefit. Information should only have to be provided once. • WVONGA requests clarification regarding what the agency intends by requiring "speciated emissions calculations." • For purposes of clarity, WVONGArecommends the following revision to this language: "If calculations are based on a compositional analysis of the gas, attach the laboratory analysis. Include the following information: the location that the sample was taken (and whether the sample was taken from the actual site or a representative site); the date the sample was taken; and, if the sample is considered representative . , ," 12. Attachment T Facility Wide Controlled Emissions Summary Sheet (p. 33) For clarity,WVONGA suggests retitling the form on page 36 "Requested Permitted Potential to Emit for Facility." Note: The same comment applies to the "Facility Wide HAP Controlled Emissions Summary Sheet" on page 34. 13. Attachment T - Class I Legal Advertisement With regard to the "Air Quality Permit Notice" on page 36 of the forms, WVONGA recommends adding a header to this page reflecting that this constitutes a "Recommended Template." If the agency intends to reject permit applications for not following the exact wording of thisnotice..:-despite the lack of any regulatory authority for being so prescriptive-then that should be very clearly stated to minimize unnecessary delays. B. Conclusion WVONGA appreciates the opportunity to provide these comments on the Draft General Permit, and would be happy to discuss any of the issues raised above with the agency. Again, WVONGA comments WVDAQ on its efforts to ensure that the Draft General Permit promotes operational flexibility for the regulated community while minimizing the administrative burden for both industry and the agency. WVONGA believes that the Draft -240- Mr. Jerry Williams, P.E . . September 14, 2015 Page 19 General Permit represents a significant step forward in this regard. Please do not hesitate to contact me at (304) 343-1609 should you have any questions. Respectfully submitted, ~;-c_~ Nicholas DeMarco, Executive Director -241 - Williams. Jerry From: Sent: To: Cc: Subject: Attachments: Zawaski, Danell Monday, September 14, 2015 4:23 PM Williams, Jerry Zawaski, Danell; Fernald, Don; Tarde, Jeff; Thompson, Bill; Pichardo, Robert; McKeone, Beverly D WVDEP G-35C General Permit Comments Williams Companies - WVDEP G-35C Formal Comment Letter.docx; G35-C General Permit Redline - finaI2015-09-14Williams Companies.docx Hi Jerry, Please see the attached comments and redline of the WVDEP G-35C General Permit. Please contact me if you have any questions. Regards, Dane" !R. !i)aneI£ Zmoa6IU, 9fEnvironmental Specialist NEGP Environmental Services 304-843-3133 Moundsville 412/787-4259 Pittsburgh 505/787-7926 cell 412/787-6002 fax Danell.zawaski@williams.com ·~~:-l.r -· " "'.~-~ . \- . 6t/.~l"'ilo.l: '~' ~:-l~~~M " ' ·~.:a~~~~ 1 -242- Williit3s. ~ September 14,2015 West Virginia Department of Environmental Protection Division of Air Quality 601 57th Street, SE Charleston, WV 25304 Submitted Electronically RE: Comments on the West Vltglnla Department of Environmental Protection, Division of Air Quality's Proposed Class II General Permit G35-C for Natural Gas Compressor and/or Dehydration Facilities To Whom It May Concern, Williams Companies, Inc. (Williams) respectfully submits the following comments on the West Virginia Department of Environmental Protection's Division of Air Quality's (WVDEP) Proposed Class" General Permit G35-C for Natural Gas Compressor and/or Dehydration Facilities (General Permit). Williams has also provided, as an attachment, a redline of the proposed General Permit. This document contains detailed comments on numerous proposed amendments. However, there are several issues that warrant initial discussion. Williams respectfully requests that WVDEP consider incorporating, into the General Permit, the express authorization of like-kind replacements for all equipment and control devices permitted under the G35-C, and require companies to keep records of such replacements that demonstrate that emissions are less than or equal to those claimed for the original equipment. This proposal is already authorized under 45 C.S.R. 13-5.13 and 5.14, and could be incorporated into Section 3.0 or 4.0 of the General Permit. Williams suggests that all language within the General Permit that refers to NSPS "OOOO"be amended to refer to NSPS 0000 or NSPS OOOOa. With the pending proposal of NSPS OOOOa, NSPS 0000 is no longer applicable to new or modified sources. Williams asks that WVDEP review NSPS OOOOa as proposed and remove any potential conflicts that may result in conflicting permit requirements between this General Permit and NSPS OOOOa. This would force companies to maintain two different "books" and also create double monitoring; thus, making this General Permit an unfavorable option for the industry. This conflict currently exists in the storage vessels, fugitive components and closed vent sections but have the potential to also affect further sections once NSPS OOOOa is final. Since NSPS OOOOa has not been finalized, Williams asks that NSPS OOOOa be referenced only to avoid conflicts if the final rule is different than proposed. Individual Comments Comment 1: § 1.1.1. Emission Units: General Pennit Registration Onlv those emission units/sources as identified In the G35-C General Permit Reflstration. with the exceptlon any de minimis sOyrces as 'dentlfied ynder Table 45-138 qf45CSR13. ace autbqdzed at the registered facilItY. qf Williams respectfully suggests the language allow for flexibility in the permit for minor changes that do not meet the definition of modification and are consistent with 45CSR13. The suggested amendatory language would state that "[o]nly those emission units/sources as identified in the G35-C General Permit Registration, with the exception of any de minimis sources as identified under Table 45-138 of 45CS~13 and sources that are less than modification levels as defined In 45CS813 and are not sumect to an substantive appljcable standard or rule. are authorized atthe registered facility." Williams Companies 2000 Commerce Drive· Pittsburgh, PA 15275 Office: (412) 787-4259· Danell.Zawaski@williams.com -243- Comment 2: § 1.1.5. Emission Units: General Permit Registration Minor Source Compliance. The ,"Isrrant shall maintain reconts of annual HAP and all other regulated ajr pollutant emjss/oos using AP:42 emission factors. GRI-GLYCalc model Inputs and outputs. flashiaf slmulatjon model Inputs and outputs. manufacturer guaranteed values. sample aadlor test data. or other methods aoomved by DAD demonstcaUag that (aCilitv-wlde emissloos are less than those specified in Sections 1.1.3 and 1.1.4. Williams respectfully requests that this subsection be removed since most emission sources currently show compliance through monitoring operational parameters and run times. It is vital that the language within the General Permit does not create a conflict between how emissions are calculated in terms of permitting versus compliance standards. If the General Permit requires one calculation method for permitting, yet another standard is used for compliance, then it not only creates inconsistency but also a massive burden on the industry to ensure proper regulatory compliance is maintained. For example, if a company permits using a manufacturer numbers engine and uses AP-42 numbers to show compliance, the engine ·will always be out of compliance unless the engine rarely operated. This is because the AP-42 factors show more emissions for the same engine. Additionally, removal is warranted because it does not reference or allows companies to reach compliance through other commonly used methods such as material balance and API fugitive factors. Williams recommends that calculation methods used for said General Permit be allowed for consistency, thus being a more beneficial permitting option. In lieu of deleting said subsection, Williams recommends that the language be substituted for the following language: "The registrant shall maintain records of annual HAP and all other regulated air pollutant emissions using methods of calculation used in the permit application or other methods approved by DAQ demonstrating that facility-wide emiss/oos are less than those specified in Sections 1.1.3 and 1.1.4." Comment 3: § 2.9.1. General Conditions: Duty to Comply The ,"Istered facility shall be constructed and ooerated fn accordance with the Informatjon filed In the General Permit Registration Apollcatjon and anv amendments thereto· The Secretary may suspend or revoke a Geneml permIt Registration if the plans and soec/tlcatlons upon which the apwqval Was based are not adhered to. Williams respectfully requests that the subsection be modified to allow for changes that do not meet the definition of modification as defined in 45CSR13. HistOrically, by not allowing such changes, it has forced companies to constantly modify current permits. If not changed, it will create the same issue with the G35-C permit. The suggested amendatory language would state: "[t]he registered facility shall be constructed and operated in accordance with the information filed in the General Permit Registration Application and any amendments thereto or changes that do not meet the definition of modification as defined in 45CSR13.· Comment 4: § 2.10.1.c. General Conditions: Inspection and Entry Inspect at reasonable tjroes (inc/udin, all t;roes in which the facllltv js In operatIon) any facilities. equipment (including monltqrlag and aI, pqftuUon control equipment), practices. or operatjons regulated or required under thiS Class U General peanit Safety is the highest priority at Williams and to keep all parties safe, we believe that the inspector should contact company personnel to confirm that it is safe to enter the premises before conducting an inspection. The suggested amendatory language would add that: "[i]f entering the facility, the inspector must give notice to company personnel and take into account safety conditions before entering;" Williams Companies 2000 Commerce Drive· Pittsburgh, PA 15275 Office: (412) 787-4259 • DanelI.Zawaski@williams.com -244- Comment 5: § 3.2.8. Facility-Wide Requirements: Limitations and Standards The refistrant shall not create a nuisance to the surroundin, community by way of unreasonable noise and light during operatjon. Williams respectfully requests that this subsection be removed because the subsection is: (1) too broad; (2) does not define what is consiqered "unreasonable" noise and light; and (3) fails to provide operation standards for compliance. Based on the current draft language as written, companies will be unable to determine if they meet the requirements per said rule because there are no compliance standards to follow. Comment 6: § 4.1.3. Source Specific Requirements: Umitations and Standards The &4istrant shall Install. maintain. and operate all aboyCHtround piolfll, yatyes. pumps. etc. that servjce lines In the transPM of potentjal sources of regylated aIr DOIIutants to minImize any fYStjye escape qf ,"ulated atr pollutants aeald Any above-f'Ound DiDiag. yalves. pumps. etc. that shoWS slgns of excess wear and that have a reasonable POtent;a1 for flllitive emjsslqas of refulated aIr pollutants shall be replaced. Williams respectfully requests that this subsection be removed because the requirement to prevent Many" fugitive escape is exceedingly stringent pursuant to W. Va. Code § 22-5-4(a}(4} and unreasonable. The terms "excess wear" and "reasonable potential" are too vague and open to interpretation as written. Additionally, the section should be removed to avoid any conflict with NSPS OOOOa. Comment 7: § 4.1.4. Source Specific Requirements: Umitations and Standards The ,",steant shall monitor and maintaIn quarterly records (calendar mrl for each faci/ltv component that Was Inspected for futlUve escape of retulated air pollutants. Each component shall operate with no detectable emissIons. as detean1ned uslrul audlo-yisual-olfactoCY fAVO) inspections. USEPA 4QCER60 Method 21. USEPA alternatjye work practice to detect leaks from equIpment usi", OPtjcal gas fmUing (OG/I cameli (ex. ELIR cameral. pr sqme cqmblnaUon thereof. AVO lnsoections shall Inelude. but not Umlted to. defects as vjslble Clicks. holes. or gaps fn olDlnf: loose connecUons: liqUid leaks: or broken or missl'" caps or other clOSure deylces. If ref/steant USes USfPA Method 21. then no detectable emlsslons Is defined as less than 500 ppm In accordance Wlth Method 21. If tef/steant Uses an 001 'ameli. then no detectable emIssIons Is defined as no yislble leaks detected in BCCOCCIance with alternatjye OGI work practices. If any leak is detected. the registrant shall repair the leak soon possible. The first attempt at repair must be made withIn five (5) calendar days of discovering the leak. and the final reMie myst be made within flfteen (151 calendar days qf d;scoveriot the leak. The regIst@nt shall recoa1 each leak detected and the associated repair. The 'eak WW not be considered reoaired unUl the same monltqr;ot method or a more detaUed Instrument detecmjoes the leak Is repaired. Delay of repaIr of a clqsed vent system for Which leaks or detects bave been detected Is allowed if the repair Is technicBllV infeasible wIthout a shutdown. or If you determine that emissIons resUlting from Immediate repajr would be greater than the fqgitive emissiOns llkelv to result from delay qf repair. you must complete realr of such equipment by the end of the next shUtdown. C45CSR§13-5.11.1 as as usEfA Due to the likelihood of contradicting NSPS OooOa once finalized, this subsection should simply require that sources subject to NSPS OOOOa, shall follow NSPS ooooa requirements. By not removing this subsection, it risks making the General Permit unusable by the industry. Many requirements within this subsection directly contradict the proposed NSPS OOOOa language. Merely referencing NSPS OOOOa would be the most beneficial towards a usable General Permit since NSPS OOOOa is still in the drafting stage and additional edits are possible. Comment 8: § 5.0. Source Specific Requirements: [Storage Vessels Containing Condensate and/or .Produced Water] Tanks with littleto no emissions, such as tanks with greater than 90% produced water, should not be subject to this subsection because emissions will be limited. Williams Companies 2000 Commerce Drive· Pittsburgh, PA 15275 Office: (412) 787-4259· Danell.Zawaski@williams.com -245- Comment 9: § 5.1.3. Source Specific Requirements: [Storage Vessels Containing Condensate and/or Produced Water] Regulated pgnutant LimitaUoa. The regIstrant shan not cayse. suffer, anow or permit emlssigas of any regulated goUmant from any storage vessel (condensate and/or produced wafer) listed In the G35-C Gene@1 Permit Refistratlon to exceed the emission /lmit jn pounds Der hour aad tons Der year recorded within the registrant's Geneml Permit RefJstraUon without obtaining an admjnlstcat/ye update or modtflcatloo' Williams respectfully requests that WVDEP be consistent with existing guidance and not require limits on produced water tanks to maintain regulatory consistency throughout this General Permit Comment 10: § 5.1.5.1. Source Specific Requirements: [Storage Vessels Containing Condensate and/or Produced Water] COntrol Devices that are not syb/ect to the contml device requirements of NSPS. Subpart QQQQ, «the regIstrant has determined per secUqn 5,1.4 of thjs ,eneml permit that the storage yesse"s) are not syb/ect to contrpl requIrements of 4OCFR6Q SubPart 0000. the tUist@nt may choose whether they want to be sublect to the contrpl device and cIgsed yent system requirements ofsectlon 6.0 or secUon 7,0 of thIs ,eneral Dermit Williams recommends removing the option of being subject to the closed vent system requirements of section 6.0 or section 7.0 of this general permit because the final version of NSPS OOOOa will likely address a similar requirement and may create a conflict with NSPS if not removed. Comment 11: § 5.1.6. Source SpeCifiC Requirements: [Storage Vessels Containing Condensate and/or Produced Water] Site specific sample. (Only tor storage Vessels wjtb no air ooUytjon contmI deYlces or YRUs) 1. ADDlicabllity. The requIrements of this section apDlY to storage vessels that meet the requirements of pa@graDhs (a) and fbI. a.Any stQlUe vessel that contains condensate. b. Any storue vessel that Is not sUb/ect to the contrql deYlce requirements of secUon 5.1,5 of this ,eneral permit c. Any stora,e vessel that has an upstream loW Dressure tower that meets the requirements ofsection 5.1.4 of this general permit Is exemot from the requirements of this secUon ApDllcability, The regylr'ements of this section aQDlv to stora,e vessels that meet the requirements of paragraPhs (a) and (bl. a.Any stqmge vessel that contains condensate aod/or produced water. Williams seeks confirmation from WVDEP that a gas analysis would be allowed in lieu of liquid sampling. since the liquid sampling method used for most condensate tanks does not work due to a lack of produced condensate needed to run the test Please remove this requirement for produced water tanks above 90% water. Comment 12: § 5.1.6.2.1. Source SpeCific Requirements: [Storage Vessels Containing Condensate and/or Produced Water] The site speciflc sample shall be taken withjn thirty (30) days offlqwback. Williams recommends that this subsection be removed from the General Permit because the term "flowback" is a wellsite specific event and is more appropriate language for a producer focused permit It would be more fitting to require samples be taken at the same timeframe as dehydrators since this is a midstream focused General Permit This modification would also create conSistency in multiple monitoring requirements. Williams Companies 2000 Commerce Drive· Pittsburgh, PA 15275 Office: (412) 787-4259· Danell.Zawaski@williams.com -246- Comment 13: § 5.3.2. Source Specific Requirements: [Storage Vessels Containing Condensate and/or Produced Water]: Record Keeping Requirements To demonstrate compUance with section 5.1.4 of this general permit. the registrant shaH maintain records qfthe determjoatlon of the yOC emission rate per storage Vessel. Including ldentiOcatjon of the model or calculatIon methodoloet Used Calculate the yOC emIssion rate. to This subsection possibly creates duplicative requirements that are already within the permit application since emission rates and PTEs are both part of the application process. The above sampling is a check and does not reflect the on-going emissions of the tank. Additionally, our tanks are normally permitted as a group since they are historically tracked as a group. Please make changes accordingly to minimize any duplicative requirements. This section may also create conflict with NSPS 0000 and NSPS OOOOa standards since some tank maybe required to determine emissions as a group and other as a single tank. Comment 14: § 7.1. Source-Specific Requirements [Control Devices and Emission Reduct/on Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: limitations and Standards If the contCP/ device Is subject to Nsps. SUbpart OQQQ control device 'and closed system requIrements. they are subJect to Section 7,0. Williams respectfully requests that WVDEP confirm that Section 7.0 is the correct section to be referenced in said title. Referencing Section 7.0 appears to create a contradiction since the section is subject to devices not subject the NSPS 0000 or NESHAP HH. Comment,15: § 7.1. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Umitatlons and Standards Possible control and emissIon reduction devjces meeting the scope qf this sectjon Include; (1) cqatml devices used to control YOC and HAP emissIons from the tanker truck loading operatIons: (2) control devices used to cOntrol yoc and HAP emissions fmm the storage vesseL(s} below the NSPS. Subpart QQQO threshold of 6 toy yoc. Control devices that are permitted under a tegaUy and praqtlcally enfocpeabJe state permit achieve a jederallv enfqrceable PTE" tor yoc emlsslQOS at the stwage vesselS; and (3) control deWes used to control yee and HAP emissions frpm dehydration Units. Williams respectfully requests that the language should be modified to state: "Possible control and emission reduction devices meeting the scope of this section include but are not limited to ... • Said modification would allow for unforeseen sources and situations, at the time of permitting, to still be eligible for this permit if they can meet the requirements of this section. If the permit writer determines said sources are beyond the scope of this general permit, they can request a company to apply for R13. For example, a flare controlling blowdowns, pigging, SSM emissions or etc. These examples are not included but should be able to be handled in this permit. Comment 16: § 7,1.2. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH): Umitatlons and Standards Enclosed Combustion Devices and Bares. The registrant shaff complY with the regutrements in thIs section for anv _smd ene/osed cQUlbystjon' device or flare that is asteet as a control device In the Gene@1 fermit Beg/stration: Williams respectfully requests that WVDEP add a section specifically for thermal oxidizer coverage. While some may consider thermal oxidizers as an enclosed combustor, this is not clear in the general permit and needs clarified by WVDEP. Williams Companies 2000 Commerce Drive' Pittsburgh, PA 15275 Office: (412) 787-4259' DaneII.Zawaski@williams.com -247- Comment 17: § 7.1.2.2.i. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Limitations and Standards Vapors that are being controlled by the flare shall be routed to the flare at all times. Please allow flexibility for a site to permit a minimum down time of the flare for such things as manufacturer required flare maintenance. The language also needs to be modified because it does not allow for a flare to be used as a back-up control device. Williams respectfully requests the following modification to the language: "[v]apors that are being controlled by the flare shall be routed to the flare at all times unless applicatIon reflects a minimum amount of downtime or use as a back-uo control device." Comment 18: § 7.1.2.2.ii. Source-Specific Requirements [Control Devices and Emission .Reductlon Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Limitations and Stimdards flares shall be operated with 7.2.1 of thjs leneral permit: a flame present at all times. as determined by the methods speclffed In sectign Williams recommends the following language to be added to the subsection: "[f]lares shall be operated with a flame present at all times when flow to the flare is Present. as determined by the methods specified in section 7.2.1 of this general permit or is equipped with automatic ignitor,w This modification allows for flare emissions to be reduced during times when said flare is not needed during practices such as site maintenance shutdowns or controlled equipment shutdowns. Comment 19: § 7.1.2.2.iiI. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Limitations and Standards flares shall be cleslIDed according to the requirements specltled In § 60.18; Williams respectfully requests said language be removed from the General Permit because flares are not subject to a NSPS or NESHAP. As a reSUlt, there is no requirement for a flare to be subject to 60.18. This change would allow for use pressure assisted flares. Comment 20: § 7.1.2.2.iv. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Limitations and Standards flares shall be operated at all tjmes when emissions are vented to them: Williams respectfully requests said language be removed from the General Permit since the change to § 7.1.2.2.11. now makes this subsection duplicative. Comment 21: § 7.1.2.3.i. Source-Speclfic Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH): Limitations and Standards vapors that are bel", controlled by the enclosed combustion deylce shall be routed to the enclosed combustion device at all tiroes. Williams respectfully requests that WVDEP allow flexibility for a site to permit a minimum down time of flaring activities for specific practices such as manufacturer required device maintenance. Williams requests the language be modified to state, "[v]apors that are being controlled by the enclosed combustion device shall be routed to the enclosed combustion device at all times unless appUcation reflects a minimum amount of downtime or use as a back-up device." Williams Companies 2000 Commerce Drive· Pittsburgh, PA 15275 Office: (412) 787-4259· Danell.Zawaski@williams.com -248- Comment 22: § 7.1.2.2.ii. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Limitations and Standards The enclosed combystion device shall be ope@ted with a flame DCeSent at all tImes. methods specified in sectjons 7,2.1 and 7,2.3 of this gene@/permit, as determined by the Williams requests the language be modified to state: "[t]he enclosed combustion device shall be operated with a flame present at all times when flow to the flare is present., as determined by the methods specified in sections 7.2.1 and 7.2.3 of this general permit or is equipped with automatic i~nitor." This modification allows for device emissions to be reduced when not needed during certain events that include site maintenance shutdowns or controlled equipment shutdowns. This modification also prohibits a flare to be used as a back'up control device which results in reductions in emissions from the pilot gas. Comment 23: § 7.1.2.2.iv. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Limitations and Standards Enclosed combustIon deVIces shall be operated at all times when emIssions are vented to them, Williams respectfully requests that said subsection be deleted due to a potential duplicative requirement as a --result ofthe modification of § 7.1.2.2.ii. Comment 24: § 7.1.4. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH): Limitations and Standards Closed Vent System, The _istrant shall comply with the closed vent system requjrements In seption 7.1.4, Williams respectfully requests that said subsection be deleted due to a likely conflict with NSPS OOOOa. Comment 25: § 7.1.3.2.iv. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH): Limitations and Standards To vent Uqujds. gases. or fumes from the ynit through a closed-yent system designed and ooerated in accordance with the reqylrements of thIs general permIt to a control devjce o( to a process. Most liquids are loaded out of the tanks and into tank trucks which are often not a closed vent system nor are proposed to be in the permit application. This subsection may also create a potential conflict with the proposed NSPS OOOOa. Williams respectfully requests that the subsection's language be modified to state: [t]o vent gases, or fumes from the unit through a designed and operated in accordance with the requirements of this general .permit to a control device. ~ Comment 26: § 7.1.4 Source-5pecific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Limitations and Standards Closed Vent Systems (applfes to all non 4QCER6Q Subpart 0000 controls I. The reg/st@nt shall comDlv with the clqsed vent system reqY/rements in this section If the potenUaI emiSSiOns that were ca/cY/ated to determine affected facjlity Status did include recovered vaDQIS from the storage vessel as allowed and in accordance with 6,1.4 of this general permit .. Williams respectfully requests that this entire section be removed from the General Permit as it will likely conflict with the proposed OOOOa. Williams Companies 2000 Commerce Drive· Pittsburgh, PA 15275 Office: (412) 787-4259· Danell.Zawaski@williams.com -249- Williifls~ ~ Comment 27: § 7.1.5.vi. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Limitations and Standards Fresh replacements for all carbon be;agUSed In the carbon adsorptjqn system shall be kept on site. . Williams respectfully requests that this requirement be removed due to a lack of on-site storage within facility locations. Comment 28: § 7.1.6.i. Source-Speclfic Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Limitations and Standards Vaoors that are belng contrplled bv the condenser/BIEX Eliminator shall be routed throwth a closed vent system to the condenset1BTEX Eliminator at all times when there is a pptential that wPQOj (emissiqnsl can be generated from the glycDl dehydration still co/ymn. Williams respectfully requests that this subsection be removed as the closed vent portion will likely conflict with the proposed NSPS OOOOa. Additionally. the low control percentage reflects that WVDEP does not expect the vapors to be controlled by the condenser at all time and thus companies should not be held to that standard. Comment 29: § 7.1.7.1. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Limitations and Standards The .strant shall cornDlv with the c/osed vent system requIrements In Sectlqn Zl.4 qt this general oermit. Williams respectfully requests that this subsection be removed from the General Permit as it will likely conflict with the proposed NSPS OOOOa. Comment 30: § 7.1.8. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH): Limitations and Standards G!vcol DehYdration Units Recycling Back to Rame Zone qt the Rebollee Williams requests that this be clarified that this is for flash tanks. Comment 31 § 7.1.8.a. Source-Speclfic Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH): Limitations and Standards The vaDOlSloverlJeads from the still column shall be routed throUfh a condenser at all times when there is a DOteoUal that yapQOj (emIssIons I can be generated from the stfll column. Williams respectfully requests that this entire section be removed from the General Permit because still column emissions are unable to be directly recycled back due to high water content. Removal is warranted because still column emissions going through a condenser is already covered under 7.1.6. Additionally. the low control efficiency reflects that these vapors may not be able to be routed to the reboiler at all times. Comment 32: § 7.1.8.b. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH): Limitations and Standards The rebpi1er shall only be flred with yapors fmm the still columo and flash tank. suDDlemental fuel. and Datural gas may be used as a Williams respectfully requests that the subsection be modified to state: ~[t]he reboiler shall only be fired with the non-condensables from a condenser.anct/or vapors from the flash tank. and natural gas may be used as a supplemental fuel. Williams requests said change because still column vapors are unable to be directly routed to the reboiler. Williams Companies 2000 Commerce Drive • Pittsburgh. PA 15275 Office: (412) 787-4259· DanelI.Zawaski@williams.com -250- Comment 33: § 7.1.8.c. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH): limitations and Standards The vaponVqverbeads from the sU" column shall be lntcpdyced {nto the flame zone of the reboller as the fuel or with the primacy fuel befom the combusVon chamber. Primacv Williams respectfully requests that the subsection's language be modified to state: ~[t]he vapors/overheads from the f/ash tank shall be introduced into the flame zone of the reboiler or with the prImary fuel before the comblJStlon chamber." We recommend the change because the vapors/overheads cannot be the primary fuel if it is introduced in said flame zone and the flash tank should be focus of this section since condensers (still column vapors) are handled in a previous section. Comment 34: § 7.1.8. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: limitations and Standards The ret'strant may claim a capture and· control etflclency of 5096 for those unjts meeting the requirements of a The rei/srrant may claim a capture and control efflclency ""ter than 50% If the General PermIt Reg1straVon Was approved based on mancdacture(s speclficaVons and the unit was operated as such. throUlh .c. The capture and control efficiency should be based on stream heat content modeled using a gas analysis. The manufacturer never provides a reduction percentage because of changes from site to site gas analysis. Williams recommends the language be changed to state: ~[t]he registrant may claim a capture and control efficiency greater than 50% if the General Permit Registration was approved based on gas analysis and boiler rating or back-up burner/control system and the unit was operated as such." Comment 35: § 7.2.1. Sourc&Specific Requirements [Control Devices and Emission Reduction DevIces not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Monitoring Requirements To deroonsttiJte compliance with the DIIpt flame regulrements of sections ~1 22 and 7,1.2,3 at this general pennjt the presence ofa pilot flame shall be contjnuous/v mqnltqred yslng a theanOCQuq/e pr any other eauiyafent deylce to detect the pmsence of a flame when emissjons ace vented to It The pilot shall be eautoped SUch that It sounds an alarm. or IniUates notification via remote alann to the newest field otrlce, when the pilot light is out Williams believes an alarm requirement is unnecessary since most flares are equipped with multiple pilots making the possibility of all pilots out to be unlikely. Also, if a Site is in a remote location, having alarms to the nearest field office is often unreliable or impossible since electricity is sometimes not available in remote areas. In areas that do have electric power access, alarms will still not properly function if the site experiences a power outage. This is the reason that multiple pilots are normally the standard for the industry. Williams recommends that the following language be changed to read: ~To demonstrate compliance with the pilot flame requirements of sections 7.1.2.2 and 7.1.2.3 of this general permit, the presence of a pilot flame shall be continuously monitored using a thermocouple or any other equivalent device to detect the presence of a flame when emissIons are vented to It unless an automatjc ignitor Is installed. The pilot shall be equipped such that It sounds an alarm, or Initiates notification via remote alarm to the nearest field office, when the al/ pUot lights are out unless equioped with multiple pilots." Comment 36: § 7.2.2. SourceSpecific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Monitoring Requirements Williams respectfully requests that this entire subsection be removed from the General Permit as it will likely conflict with the proposed NSPS oooOa. Williams Companies 2000 Commerce Drive· Pittsburgh, PA 15275 Office: (412) 787-4259· Danell.Zawaski@williams.com -251- Comment 37: § 7.2.3.1. Souroe-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Monitoring Requirements The presence pta pilot flame shall be contjouously rnqnjtoretl using a thermgcoUP/e or any other equivalent devlce to detect the presence ofa flame wben emissIons ate vented to It The Pilot shall be equipped s!JCh that It sounds an alarm. or Injtja1es notlffcaUon vta remote alarm to the nearest fleld oftlce. when the pilot 'iiht Is out Williams respectfully requests that this entire subsection be removed from the General Permit as it is duplicative of § 7.2.1. Please also see Comment 34 on § 7.2.1. Comment 38: § 7.3.2. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP SUbpart HH1: Monitoring Requirements accoatance A tfate that is d9slfned and agecated In with 6BO.l8fbl shall not regulre performance testiCWthe request ptthe Secretary, but must conduct ylsible emIssion check. unless at This does not allow for pressure assisted flares which often can be more reliable than candle stick flares and there are no performance test listed in the general permit. So this requirement has no affect. Additionally, since said flares are not subject to a N5PS or NEHAP, the flares in this section are not subject to 60.18. Williams respectfully requests that this section be removed from the General Permit Comment 39: § 7.3.3. Souroe-Speciflc Requirements [Control Devices and Emission Reduction DevIces not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Monitoring Requirements Enctosed COIDbustjgn deylces or flares. At such reasonable times as the Seqetacv may ctesifnate. the opemtpr ptany Inclneratpr shall be regulred to CQDctuct or have -conducted stack tests to determine the particulate matter loadl",. bv !ISlrJI40 CER Pact 60, APpendix A Method 5, and yplatile dnle comooynd loadintl. by using Methods 18 and 2M pt 40 CfR Pact 60. Appendix A Method 32Q pt 40 CFR Pact 63. AQpendix A. or ASTM D 63§D3 or other equivalent U,s. EPA appcpyed method appcpyed by the Secretary. in exhaust 41a:ie& SUch tests shall be conducted In such manner as the Secretary may speclfv and be flied on fpans and In a manner accepfBble to the SecceCary. The Sectetacv may. at the Sectetacv's qptlon. witness or COnduct such stack tests. Should the Secmtary exemlse his or her , option to conduct such tests. the opemW will prpylde all the DtWerWIry sampling cqnnecUgos and samPlIng POrts to be located In SUCh manner as the Secretary may require. POwer fpc test equipment and the requlred safety equipment such as sqaffgldl",. rallln. and ladders to comply with generally'accepted good safety QRict/ces. The Secretary may conduct such other tests as the Seccetary may deem '¥'f"5'fUV to evalyate alc pollution emlssigns ottzer than those noted aboys. C45CSR6 i 67.,1 and ~21 Williams respectfully requests that this entire subsection be removed from the General Permit because many of these test methods would either be impossible or do not result in the desired data for flares thus making it impossible for companies to comply. Comment 40: § 7.4.5. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH1: Monitoring Requirements TQ demonsttate comollance with the closed yent monltgring requirements In section ~2 2 of this general peanit reco$ shall be maintaIned qf: I. The Initial comoliance requirements; II. Each annyal AVO Inspectjon Metbgd 21· Infrared camera Ql some comb/naUon thereotconclucted to demonstrate made as a of the InsoectJqn: iU. 1f)(QU are continuous comollance. IncludIng cecqats W any repallS that SUb/ect to the IMw;s ceqyjmments. the fpIIowlnl records shall also be maintained: (a) Each InspectIqn or each Urne the key Is checked out or a recant Wesch time the alarm js sounded: (bl Each qccurreace that the contcql devtqe bypassed. If the device was bypassed· the recqrds shall include the date. Ume. and durat/qn W the event and shall provide the that the event occurred· The cecqnt shall also Include the W emissIons that were were result was reason _mate Williams Companies 2000 Commerce Drive· Pittsburgh, PA 15275 Office: (412) 787-4259· Danell.Zawaski@williams.com -252- to the enylronment as a result of the bypass. ·UOBate to Insnec;t= In accqcdance with 7.2.2(dl. releaSed Any pact of ly. the slrStem that has been desjfnated as Williams respectfully requests that this entire subsection be removed from the General Permit because it will likely conflict with NSPS OOOOa. Comment 41: § 7.4.8. SourceSpecific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Monitoring Requirements off. or All recqrds required under Sectjon 7.4 shall be maintained on site in a readily accessible lpeatlon majatalnecl by the refistcant for a period of five (5) yeatS. Said cecon1s shall be readily available to the Director of the DAD his/her duly authorized repcesentatlye for expedlUo Inspeqtlon and review. Any reooats submitted to the agency pursuant to a requirement of this permit Upon request by the Djrector shall be certjf1ed by a responsible or or us QftIs;JaJ" Williams respectfully requests that the ~certification" language be removed from this subsection because most inspectors would prefer the data during the inspection. The current language would create a conflict with the "readily available" requirement because it requires certification by a responsible party, thus causing a delay in the submittal of information. Comment 42: § 7.4.10. SourceSpecific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Monitoring Requirements To demoostcate compliance with section 7.1.6 of this general permit the reglstamt shall record the ouUet tempemture of the condenser on a monthly basis. Williams respectfully requests the subsection be removed because this requirement does not clearly determine if a condenser is in compliance. If the requirement is to be kept, Williams requests that the language is modified to state that: "[t]o demonstrate compliance with section 7.1.6 of this general permit, the registrant shall record the outlet temperature of the condenser on a quarterly basis." Said modification matches the dehydrator requirement for record keeping and will provide conSistency in monitoring requirements. Comment 43: § 7.5.2. SourceSpecific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Reporting Requirements event Any bypass of the registered control device must be reported in writjrvt to the Director of the DAD as soon as wactjcable. but within ten (10l calendar days. of the occurrence and shall include. at a minimum. the following Wgrmation: the date of the bypass. the esUmate of yoc emissions released to the atmosphem as a result of the bypass. the or SUSpected caUse of the bypass. and any coaectjve measures taken oIanned. cause or Williams respectfully requests that the subsection's language be modified to state that: "[a]ny bypass event that results in emissions above the permit limit of the registered control device must be reported in writing to the Director of the DAQ as soon as practicable, but within ten (10) calendar days, of the occurrence and shall include, at a minimum, the following information: the date of the bypass, the estimate of voe emissions released to the atmosphere as a result of the bypass, the cause or suspected cause of the bypass, and any corrective measures taken or planned." This recommended modification allows for back-up devices and planned bypasses that were included in the application, such as manufacturer required maintenance. Comment 44: § 7.5.3. SourceSpecific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Reporting Requirements Any Urne the air DOl/uUon control deylce Is not operating when emissions are vented to It. shall be reported in writj06 to the DIrector of the DAD soon wactjcab1e. but within ten (1.0) calendar dalrS of the d/scoyery. as as Williams requests the following modification: ~[a]ny time the air pollution control device is not operating when emissions are vented to it that results in emissions above permit limit shall be reported in writing to the Director Williams Companies 2000 Commerce Drive· Pittsburgh, PA 15275 Office: (412) 787-4259· Danel1.Zawaski@williams.com --253- of the DAQ as soon as practicable, but within ten (10) calendar days of the discovery. Said modification is recommended because it will allow for back-up devices and planned bypasses that were included in the application. An example this would be applicable is during manufacturer required maintenance. H Comment 45: § 12.1.3;a. SourceSpecific Requirements] [Reciprocating Internal Combustion Engine{s) (RICE), Generators, Microturbine Generators]: Umitations and Standards The registrant shall follow a written ODelation and maintenance plan that proyides the periodic and annual maintenance reqylrements. Williams respectfully requests that this subsection be removed due to being duplicative of NSPS 1111, NSPS JJJJ and NEHAP llIl requirements. Comment 46: § 12.1.5. SourceSpecific Requirements [Reciprocating Internal Generators, Microturbine Generators]: Umitations and Standards Combustion Engine{s) . (RICE), The emission limitatIons specified in sectjon 13.1.1 shaH apply at all times except during periods ofstart-up and shutThe .tomt shall down proyided that the ducatlon of these periods does apt exceed 30 minutes per ODelate the englne in a manner consistent with good air oollutjon oontrol cuactjces for minimizing emlsslons at all times. IncludIng perlods of start-up and shut-11own. The emissIons frpm start-UP and shut-down shall be included In the tweIye (12) month roiling total of emissions. The _/st@nt shall comply w1tIJ all applicable start-UP and shut-down regulrements in accordance with 40 CFR fart 60. Subparts II"' JJO and 40 CFR part 63. Subpart zm occuuence. The subsection's language is ambiguous in regards to what 12-month roiling total emissions and which type of start-up or shutdown emissions WVDEP is referring too. Williams permits pipeline blowdowns separate from engines since they are a different type of emissions. The only other emission that WVDEP may be referring to are emissions caused by engine cold starts. Please keep in mind that engines take seconds to warm up and there are no manufacturer emissions factors for this period. As a result, Williams respectfully recommends that the following sentence be deleted from the subsection: "[t]he emissions from start-up and shut·down shall be included in the twelve (12) month rolling total of emissions.~ Additionally, 13.1.1 appear to be a typo. Williams believes that the reference should be 12.1.1. Comment 47:§ 12.1.6. SourceSpecific Requirements [Reciprocating Internal Combustion Engine(s) (RICE), Generators, Microturbine Generators]: Umitations and Standards For the pycposes of Genem' Permit G35-C. emergency generator means a gene@tor whose purpqse Is to alloW key systems to contjnue to qpenlte wlthqut Inteauptlon dutinl Umes of yWIty oower qytagA Williams requests that WVDEP please confirm that this definition does not create a direct conflict with NEHAP zzzz. and NSPS JJjJ language. Comment 48: § 13.1.4. Souro&Specific Requirements [Tanker Truck Loading): Umitations and Standards The tolwng applicable capture eff1cIencles ace requjred: a. Foe tanker tcycks not D8ss/ng one of the annyal leak 7026 b. Fqc tanker trucIcs passing the NaPS level annual teak test 98. V6. c. Fqc tanker trucIcs passing the MAeT Ievef annual leak test - 99,226 tests In 13.1.4(b) or (e) and has vaoor return - Please note that not all companies claim loading controls. The subsection's language suggests a requirement for all loading. Williams suggests the language be modified to state: "The following applicable capture efficiencies are allowed If represented in the application: a. For tanker trucks not passing one of the annual leak tests in 13.1.4(b) or (c) and has vapor return - 70% b. For tanker trucks passing the NSPS level annual leak test - 98.7%. c. For tanker trucks passing the MACT level annual leak test - 99.2%... " Williams Companies 2000 Commerce Drive· Pittsburgh, PA 15275 Office: (412) 787-4259· Danell.Zawaski@williams.com -254- . Williitls~ ~ Comment 49: § 13.1A. Source-Specific Requirements [Tanker Truck Loading]: Limitations and Standards Compliance with this requirement shall be demonstrated by keeoiog records of the applicable MACT or NSPS Annual Leak Test certification for eveN truck and callesr lqaded/unloadecl. thiS requirement can be satisfied if the trucking company provided certification that all tanker trucks serylem, sybmitted wlUr the G35-CAnnual CectJflcatjon. me locaUon are complIant This cectiOcaUon must be This permit does not require an annual certification. This requirement appears to be written in error and is a requirement of the G70 general permit and not the G-35C General Permit. Williams requests the following language be deleted from the subsection: "[t]his certification must be submitted with the G35-C Annual Certification." . Comment 50: § 13.2.2. Source-Specific Requirements [Tanker Truck LoadingJ: Recordkeeping Requirements Fqr the purpose of demonstrating compliance with secuQa 13.1.2. the mg/stnmt shalf maIntaIn records of the MACT and/or NSPS Annual Leak Tests of aU trucks 'oaded at the facility. This requIrement can be satjsfied If the truck/at company DfQylded certmcatlon that Us entire fleet was compliant This certwcaUon must be submitted In wrttlnt to tl1§ Director of the DAQ. The G-35C permit does not require an annual certification or report as does the G-70B permit. Williams recommends the following language be deleted from the subsection: "[t]his certification must be submitted in writing to the director of the DAQ." Comment 51: § 14.5.1. Source-Specific Requirements [Glycol Dehydration Units]: Reporting Requirements ,as wet required by sectlon 14.2 of thiS general oermft withIn SO dm wet 1M analysis sacnpljDl of the wet stream The refistmnt shall submit the of conductinl the as requlred. ThiS IBDOCt shall Inclyde a potential to emit rere estjroate using GRt-G1vCa1c Version 3.0 or higher. Incorpocatjog the soecItjc parameters measured. as well as a COPY of the laboratory analysis. Williams respectfully recommends that this entire subsection be deleted from the General Permit because it potentially requires over-reporting. § 14.5.1 should merely be a matter of recordkeeping as required by § 14.4.1 and not reporting. The main reporting focus is already included within § 14.5.2. Comment 52: § 7 and 14. Sourc&Specific Requirements [Control Devices and EmiSSion Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH]: Monitoring Requirements and SourceSpeclfic Requirements [GI)Q>I Dehydration Units]: Reporting Requirements WVDEP sho"uld define a bypass to not include safety pressure release devices as stated in NESHAP HH and the Applicability Determination Index (ADI) so not to cause conflict between this general permit and NESHAP HH. Please refer to 40 CFR 60.771(c). Williams appreciates the open dialog with the WVDEP during this process and the opportunity to comment on the West Virginia Department of Environmental Protection's Division of Air Quality's (WVDEP) Proposed Class /I General Permit G35-C for Natural Gas Compressor and/or Dehydration Facilities. Williams maintains a commitment to environmental excellence by protecting the environment and all natural resources as required by regulation. Please feel free to contact me at (412) 787-4259, if you should have any questions or need to address the submitted comments in more detail. Regards, Williams Companies 2000 Commerce Drive· Pittsburgh, PA 15275 Office: (412) 787'-4259· Danell.Zawaski@williams.com -255- Danell Zawaski Environmental Specialist NEGP Environmental Services 304/843-3133 Moundsville 412/787-4259 Pittsburgh 505/787-7926 cell 412/787-6002 fax Danell,zawaski@williams,com Attachment: Redline edits on WVDEP DAQ Class II Williams Companies 2000 Commerce Drive· Pittsburgh, PA 15275 Office: (412) 787-4259· DaneII.Zawaski@williams,com -256- General Permit G35-C West Vuginia Department ofEnvironmental Protection Division ofAir Quality Earl Ray Tomblin Governor Randy C. Huffman Cabinet Secretary Class II General Pennit G35-C for the Prevention and Control of Air Pollution in regard to tlte Cons~ction,Modification, Relocation, Administrative U\ildate and Operation of Natural Gas Compressor and/or Dehydration/Faciliti~ --- ---- --..... _---~ This permit Is issued In DCcol'dance with the West Virginia Air Pol/ulion Contraf Act (West Virginia Code §§ 22-5-1 etseq) and 45CSRI3 - PermltsJor Construction, Modification, Relocation and Ope1'OtionoJ Stationary Sources ojAir Pollutants, Notificalion Requirelilenls, Temporary Permits, Genel'f1i Permlls and Procedures Jor Evaluation. William F. Durham Director Issued: Draft -257- Comment 1ZD1J: WUllams requests that WVDAQ consider incorporating Into the Draft General Permit the express authorization ollike-kind replacemenb for all eqUipment and control devices permitted under the G3S-C, and require companies to keep records of such replacemeDbi that demonstrate that the emissions are less than or equal to those claimed for the original equipment This Is authorized under 45 c.s.R. 13-5.13 and 5.14, and could be incorporated into Section 3.0 or 4.0 of the Draft General Permit 20f39 G35-C Natural Gas Compressor and/or Dehydration Facility Any person whose interest may be affected, including, but fWt necessarily limited to, the applicant and any person who participated in the public comment process, by a permit issued, modified or denied by the Secretary may appeal such action of the Secretary to the Air Quality Boardpursuant to article one [§§22B-I-I et seq.], Chapter 22B of the Code of West Virginia. West Virginia Code §§22-5-14. The source is fWt subject to 45CSR30. General Permit G35-C authorizes the construction, modification. administrative update and/or operation of natural gas compressor and/or dehydrationfacilities. The applicability of General Permit G35-C may include any ofthe following: natural gas-fired spark ignition internal combustion engines,.diesel-fired compression ignition internal combustion engines, storage vessels/tanks, glycol dehydration tDlil.J and associated equipment, equipment leaks, truck loading/unloading operatio1l!l, fUld pneumatic controllers. West Virginia Department of Environmental Protection· Division of Air Quality -258- 30f39 G35-C Natural Gas Compressor andlor Dehydration Facility Table of Contents 1.0. Emission Units .............................................................................................................. 5 2.0. General Conditions._.................. _._.. _................................... _ ...... _ ...................... 5 1.1. 2.1 . 2.2. 2.3. 2.4. 2.5. 2.6. 2.7. 2.8. 2.9. 2.10. 2. 11. 2.12. 2.13. 2. 14. 2.15. 2.16. 2.17. 2. 18. 2.19. 2.20. 2.21. 3.0. 4.0. General Permit Registration .................. ... ................. .......... .. ................................. 5 Purpose ...... .... ... ............ ... ..... .......... ... ... ........ ....... ...... .............................. ...... .... ..... 5 Authority .......... .... .. ................ ... ...... .... .................... .. ...................... .... ................ ... .5 Applicability ........ .. ...... ............. ............................ ...... ...... ..... ................... ............. .6 Definitions .. ........................ ........................................................ ........ ... .......... ... ....7 Acronyms .. .... ......... .......... ................ .... ..... ... .... ...... ... .... .. .... ............. ... ... ................. 7 Permit Expiration and Renewal .......... .... ............... ........ ......... :................. .......... ... 8 Administrative Update to General Permit Registration .......................................... 8 Modification to General Permit Registration ...... .... ...............................................8 Duty to Comply .. ....... .............................................. ............................................. 8 Inspection and Entry .... ......................... ....................... ...... .................................. 8 Need to Halt or Reduce Activity not a Defense.... ............ ............ ................... .. 9 Emergency ...... ............. .... ...... ........... .......... .......................... ....................... .........9 Federally-Enforceable Requirements ................................... ..... .... ................... ....... 9 Duty to Provide Information .... ... ". _. ...... ...... ..... ....... ...... ..................................... 9 Duty to Supplement and Correct Information. .. .. .. .................................. ....... .... 10 Credible Evidence.. ........ .... .............. .... ... . . .. .................................... .................. ... 10 Severability ........... ..... ... ... ...... ....... ........................................................................ 10 Property Rights ............ ; .. .. .................................................................................... 10 Notification Requirements ..... .. ..... ............ ............ .. . ........................................ .10 Suspension of Activities .... ... ....... ......... ............. .. ............................... ....... ....... IO Transferability... ................... ............. ............ .. . ....... .................................. ........... 10 Facility-Wide RequiremeDts...... _...... _ ................... ~_ .............................................. 11 ~:~: ~:~~~~~~·S~d~d~·:::::::::::··::::::: :::::::::::::::::::: :::::: ::::::::::::::::::::::::::::: ::::::::: ::!~ 3.3. 3.4. 3.5. 3 6: MonltOlmgReqwrements ....... :.. .... ....... ..... :.......................................................... 12 Testing Requirements ... ................ ... ............................ ... .......... ..................... ........ 12 RecQrdkeeping Requirement:; ..................................................... ....... ...... ....... .... ... 13 Reporting Requirements .... .......... ................... ............................ ,... .... ... ................. 13 Source-Specific Requirements.......... _........................... _ ......._ ............... _............... 15 4.1. 4.2. ' Limitations and Standards ............ .. .. ........... ........ , .... ............. .......... .. .... ............. ;... 15 Recordkeeping Requirements ........................................... ............ ... .... .... .... ........... 16 5.0. Source-Specific Requirements (Storage Vessels Containing Condensate and/or Produced Water) ...:............................................................... ___ .......... _................_............... 17 5. 1. 5.2. 5.3. 5.4. LImitations and Standards .............. ......................................... ... .............. .............. 17 Momtoring Requirements .............................................................. ......................... 18 Recordkeeping Requirements .............. ..... ....... ...... .... ..... ;....... ..... ............... ............ 19 Notification and Reporting Requirements ..... ,............ ... ... ,............ ...... ................... 19 !~ecte:;:~~;~~~~S.~'::~~~~~t;,J~:::!:.:::._.::!,.:~.::~:.:,::,:::,~,~::.!'.~~:,::!:~~~~~~~ ____ ----- reo-m-m-ent-[-m-2]-:-pr-ea-s-e-not-e-t-h-at-a-n-pr-aces-'" 6.1. Limitations and Standards ....... ...................... .......................... .......... ..................... 20 7.0. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH) ........................................ 20 7.1. 7.2. 7.3. Limitations and Standards .... ............ ...... ........... ......... .... ,........................... ............ 20 Monitoring Requirements ... ............ .. .... ....... .......... ... .... ..... .... ,................. ...... .... ..... 25 Testing Requirements ..... ,... ,....... ... ... .......................................... .......... ....... ........... 26 ~:~: ~~~:~e::u~!~~~~~~.::::::::::::::::::::::: :::::::::::::::::: ::::::::::::::::::::::::::~:::::::::::::i~ West Virginia Department ofEnvironmcntaI Protection· Division of Air Quality -259- that say 0000 should be change to 0000 or OOOOa. G35-C 4of39 Natural Gas Compressor anellor Dehydration Facility 8.0. Source-Specific Requirements [Small Heaters and Reboilers not subject to 40CFR60 Subpart Dc] ................................................................................................................................ 30 8.1. 8.2. 8.3 8.4. LimitationS and Standards ......................................................................................30 Monitoring Requirements ....................................................................................... 30 Testing Requirements ................................... ........ ...... ........................................... .30 Recordkeeping Requirements ................................... ................ .............................. 30 9.0. Source-Specific Requirements [Pneumatic Controllers Affected Facility (NSPs, Subpart 0000)] .. _...._ ... _._ ••.•..... _ ........._.• __....._.. _......._......_........................... _ ....._...... 31 9. I. Limitations and Standards ............ ..... ..................................................................... 31 10.0. Source-Specific Requirements [Centrifugal Compressor Affected Facility (NSPS, Subpart 0000)] .......................................................................................................................31 10.1 . Limitations and Standards .. ..... ...... .............................. .... ,.................................... 31 11.0. Source-Specific Requirements [Reciprocating Compte8sor Affected Facility (NSPS, Subpart 0000)] ..............................................................................._...................................... 31 11.1. Limitations and Standards .... .......... ...... ........ ........... . .. • .................................... 31 12.0. Source-Specific Requirements [Reciprocating Internal Combustion Engine(s) (RICE), Generators, Microturbine Generators] ............... _ ...•:......... _....................... _ ...................... 32 12.1. 12.2. 12.3. 12.4. 12.5. 13.0. Source-Specific Requirements [Tanker Truck Loading) ........................ _................ 34 13.1. 13.2. 14.0 Limitations arid Standards ... ... ...... .. ..... ......... ............... .. .......... .... ..................... 32 Monitoring Requirements ............. ..................... _................................. ........... ....... 33 Recordkeeping Requirements ................_ .... . _ .................................................... 33 Testing Requirements ........... ......................................................................... ......... 33 Reporting Requirement, .... ................ ........... ...... ........................................... ........ 34 Limitations and Standards ....... ... " .................... ................................................ 34 Recordkeeping Requirement'l. ............. ... ........... .. .............................................. 35 Source-Specific Requirements [Glycol Dehydration Units] ...._.......... __ ................. 36 14.1. 14.2. 14.3. 14.4. 14.5. LimitatiOJJ.~ and Standards ..... .. ........................................................................... 36 Monitonng ReqUirements ....................................................................................... 36 Testmg Requirements .................... .. .......................................................: ............. .38 Recordkeeping Requirements ....... ._........................................................ .............. 38 Reporting Requirements ... .. . ........................................................ ..................... 38 CERTIFICATION OF DATA ACCURACY.......................................................................... 39 West Virginia Department of Environmental Protection· Division of Air Quality -260- G35-C Natural Gas Compressor and/or Dehydration Facility 50f39 1.0. ' Emission Units 1.1. General Permit Registration 1.1.1. Only those emission units/sources as identified in the G35-C General Permit Registration, with the exception of any de minimis sources as identified under Table 45-I3B of45CSR13..1!1ll Sources that are less than modification levels as defined in 45CSR13 and are not subject to a substantive applicable standard or rule, are authorized at the registered facility. 1.1.2. In accordance with the information filed in the G35-C General Permit Registration Application, the equipment/processes identified in the Emissions Unit Table of the G35-C General Permit . Registration shall be installed, maintained, and operated so as to minimize any fugitive escape of pollutants, shall not exceed the listed maximum design capacities, shall use the specified control devices, and shall not exceed the emission limits listed in the General Permit Registration. 1.1.3. Minor Source ofHazardous Air Pollutants (HAP). The facility shall not exceed 10 tons per year of any single hazardous air pollutant which has been listed punuant to § 112(b) of the Clean Air Act or 25 tons per year of any combination of hazardous air pollutants. Compliance with this section shall ensure that the facility is a minor source of HAPs. 1.1.4. Minor Source 0/ RegUlated Pollutants. The 1:itcility shall not exceed 100 tons per year of any regulated air pollutant. The fugitive emiSSIOns of a stationary source shall pot be considered in determining whether it is a major stationary source for the purposes of 45CSRJO-2.26.b. Compliance with this Section shall ensure that the facility is a minor source of regulated air pollutants. . l.1.S. ~Sew..1e C~ __~_~M!.@t~~j!l_ftI!II_~_"'f.~~_IY-..,.~_~_!'!L~~~__________ ----- Comment [ZD3): This should bl' remoYed . _ d air pelllllaRt emissiBll8l15it1g t\P 43 8111iaeiell faetiaf!l, GRI Gb¥Cale lI\eEIel illplltS and 1IIlII'uts; tJlIIIhiIIg simliialiell Riedel inpItts aM eutpllt9; IIIIHIIifeetwer gueRlftteed -lilkies. 5IIIIIple aadleF test data, eFedlerRled!eds-. ift tile DfIl'RIit !!Jtli!lljj8R er~fl!~~_~_~_~& _________ ________ ~ demell9lf8tiag that fileila, v. ide BRlissi81111 life le55 tfteII tfie5e speeified ill Be_ens 1.1.3 IIftd "" ~ 2.0. 2.1. many other common used methods such as APi fugitive factors so calculations used for permit should be allowed for consistency. Purpose Authority This permit is issued in accordance with West Virginia air pollution control law W.Va. Code §§ 22-5-1. et seq. and the following Legislative Rules promul~ed thereunder: 2.2.1. \ " ,>pe--.r_3._6._4_ . _ _ _ _ _ _ _ _ _ _-< Comment [ZD4J; This does not mdude General Conditions The purpose of this Class II General Permit is to authorize the construction, modification, administrative update, relocation, and operation of eligible natural gas compressor and/or dehydration facilities through a Class II General Permit RegIstration process. The requirements, provisions, standards and conditions of this Class II General Permit address the prevention and control of regulated pollutants from the operation of a natural gas compressorandlor dehydration facility. 2.2. since most sources show compliance by monitoring such things as run time and gas use. Additionally, WVDEP has the optiol'l of requesting 8n emissions inventory at any time 45CSR13 - Permits/or Construction, Modification, Relocation and Operation o/Stationary Sources 0/Air Pol/utants, Notification Requirements. Administrative Updates. Temporary Permits. General Permits, Permission to Commence Construction. and Procedures/or Evaluation. West Virginia Department of Environmental Protection· Division of Air Quality -261- G35-C Natural Gas Compressor andlor Dehydration Facility 2.3. 60f39 Applicability 2.3.1. All natural gas compressor andlor dehydration facilities designed and operated for the purpose of compressing.andlor dehydrating natural gas and included in the following NAICS andlor SIC codes are eligtble for General Permit registration except for those instances listed in (a) through (h) below: NAICSCode 211111 213112 221210 486210 a. b. c. d. e. f. g. h. SIC Code 1311 1382,1389 4923 4922 Description Crude Petroleum and Natural Gas Extraction Support Activities for Oil and Gas Operations Natural Gas Distribution Pipeline Transportation of Natural Gas Any natural gas compressor andlor dehydration facility which is a major source of pollutants as defined in 45CSR14, 45CSR19 or 45CSR30. Any natural gas compressor andlor dehydration facility that is located in Putnam County, Kanawha County, cabi:n County, Wayne C0Wlty, or Wood County and is required by 45CSR2l to conduct a Reasonably Available Control Technology (RACT) Analysis andIor subject to 45CSR21 Section 29 (Leaks from Natural Gas/Gasoline Processing Equipment). Any natural gas processing plant (e.g. production of ethane, propane, butane, and pentane) as defined in 40 CFR §60.5430. Any natural gas sweetening plant. Any natural gas compressor andlor dehydration facility with a storage tank subject to NSPS, SubpartKb. Any steam generating unit (as defined in ~60. 41c) subject to NSPS, Subpart Dc (> 10 MMBTIJ/hr). Any turbine subject to NSPS, Subpart KKKK. Any natural gas compressor andlor dehydration facility which will require an individual air quality peImtt review process (45.CSR13 <:onstructionlrilodification permit) to incorporate regulatory requirement(s) other than those established by General Permit G35-C. This would inclvdt "!!Yllthetlc. minor" permitting actions, as they are required to undergo Notice Level C under 45CSR13 Section 8.5. "Synthetic minor" permitting actions would include limitations on physical or operational capacity to remain below major stationary source thresholds (including 45CSR14, 45CSR19, 45CSR30 and 45CSR34). 2.3.2. For the purposes ofGeneraI Permit G35-C, natural gas compressor station means reciprocating internal combustion engine driven compressor(s) or combination of equipment (including but not limited to compressor engines, emergency standby generators, engine driven air compressors, boilers, line h\'8ters, tanks, glycol dehydration units, air pollution control devices, etc.) that .supplies energy to move natural gas at increased pressure from gathering systems, to gas plants. in transmission pipelines or into storage. Engine means any compressor engine, emergency standby engine, auxiliary engine or air compressor engine located at a natural gas compressor station. 2.3.3. The West Virginia Division of Air Quality reserves the right to reopen this permit pr any authorization issued under this permit if the area in which the facility is located is federally designated as non-attainment for specified pollutants. If subsequently any proposed construction, modification andlor operation does not demonstrate eligibility andlor compliance with the requirements, provisions, standards and conditions of this General Permit, this General Permit registration shall be denied and an individual permit for the proposed activity shall be required. West Virginia Department of Environmental Protection· Division of Air Quality -262- G35-C Natural Gas Compressor and/or De.h ydration Facility 2.4. 2.5. 70f39 Definitions 2.4.1. All references to the "West Virginia Air Pollution Control Act" or the "Air Pollution Control Act" mean those provisions contained in W.Va. Code §§ 22-5. 2.4.2. The "Clean Air Act" means those provisions contained in 42 U.S .C . §§ 7401 to 7671q, and regulations promulgated thereunder. 2.4.3. "Secretary" means the Secretary of the Department of Environmental Protection or such other person to whom the Secretary has delegated authority or duties pursuant to W.Va. Code §§ 22-1-6 or 22-1-8 (45CSR§30-2.12.). The Director of the Division of Air Quality is the Secretary's designated representati ve for the purposes of this permit 2.4.4. The terms established in applicable defmitions codified in the Code of Federal Regulations including 40 CFR Part 60 NSPS Subparts A, IIII, mJ, and 0000 or 40 CFR Part 63 MACT Subparts A, HH and ZZZZ shall also apply to those sectjons Of General Permit G35-C where these subparts are incorporated or otherwise addreSsed. Acronyms BBLorbbl Barrel Clean Air Act Amendments CAAA CBI Confidential Business Information CEM Continuous Emission MOJUior Certified Emission Statement CES C.F.R. Code of Federal Regulations CO Carbon Monoxide C.S.R. Code of StlIte Rules DAQ Division of Au Quality DEP Dep.u'l:ment of Environmental Protection FOIA Freedom oflnformatton Act HAP Huardous Air Pollutani HP HOIsepower Pounds per hour Ih/hr LDAR Leak Detection and Repair Morm Thousand Maximum Achievable MACT Control Technology MDID Maximum Design Heat Input MM or mm Million MMBTUIhr Million British Thermal Units Per Hour MMCFlhr Million Cubic Feet per Hour N/A Not Applicable NAAQS National Ambient Air Quality Standards NESHAPS National Emissions Standards for Hazardous Air Pollutants LAT Latitude LON Longitude NO, NSCR NSPS PM PMu PM IO ppm ppm. PSD psi RICE SCR SIC SIP S~ TAP TPY TSP USEPA UIM VEE VOC VRU Nitrogen Oxides Non Selective Catalytic Reduction New Source Performance Standards Particulate Matter Particulate Matter less than 2.5 IIJYI in diameter Particulate Matter less than 10 IIJYI in diameter Parts per million Parts per million by Voiume Prevention ·of Significant Deterioration Pounds per square inch Reciprocating Internal Combustion Engine Selective Catalytic Reduction Standard Industrial Classification State Implementation Plan Sulfur Dioxide Toxic Air Pollutant Tons per year Total Suspended Particulate United States Environmental Protection Agency Universal Transverse Mercator Visual Emissions Evaluation Volatile Organic Compounds Vapor Recovery Unit West Virginia Department of Environmental Protection· Division of Air Quality -263- G35-C Natural Gas Compressor and/or Dehydration Facility 2.6. 2.7. 80f39 Permit Expiration and Renewal · 2.6.1. This Class II General Permit shall remain valid, continuous and in effect unless it is revised, suspended, revoked or otherwise changed under an applicable provision of 45CSR13 or any other applicable legishrtive rule. 2.6.2. General Permit registrations granted by the Secretary shall remain valid, continuous and in effect unless suspended or revoked by the Secretary. If the Class II General Permit registration is subject to action or change, existing registrations will continue to be authorized and subject to the previously established permit conditions.(45CSR§13-10.1, 45CSR§13-10.3J Administrative Update to General Permit Registration . 2.7.1. 2.S. The registrant may request an administrative update to their General Permit registration as defined in and according to the procedures specified in 45CSR§I3-4 (45CSR§lJ-4.] Modification to General Permit Registration 2.8.1. 2.9. The registrant may request a minor permit modification to their General Permit registration as defined in and according to the procedures speciMd in 45CSR§13-5. (45CSR§13-5.J Duty to Comply 2.9.1. The registered facility shall be constructed aDd operated In accordance with the information filed in the General Permit Registration ApplicatIon and any amendments thereto or changes that not meet the definitjog of modification as define in 4SCSRll The Secretary may suspend or revoke a General PermrtRegistration if the plans and specifications upon which the approval was based are not Bdhered to. lmtL------ 2.9.2. The registrant must comply with all applicable conditions of this Class II General Permit. Any General Permit noncompliance constitutes a violation of the West Virginia Code, and/or the Clean Air Act, and is grounds for enforcement action by the Secretary or USEPA. 2.9.3. Violation of any ofthe applicable requirements, provisions, standards or conditions contained in this Class II General Permit, or incorporated herein by reference, may subject the registrant to civil and/or climinal penalttes for each violation and further action or remedies as provided by West Virginia Code 22-5.{j and 22-5-7. 2.9.4. Registration under this Class II General Permit does not relieve the registrant herein of the responsibility to apply for and obtain all other permits, licenses, and/or approvals from other agencies; i.e. local, state and federal, which may have jurisdiction over the construction and/or operation of the source(s) and/or facility herein permitted. 2.10. Inspection and Entry 2.10.1. The registrant shall allow any authorized representative of the Secretary, upon the presentation of credentials and other documents as may be required by law, to perform the following: a. At all reasonable times enter upon the registrant's premises where a source is located or emissions related activity is conducted, or where records must be kept under the conditions of this permit; West Virginia Department of Environmental Protection· Division of Air Qu8.Iity -264- Comment [ZDS]: This section does not allow for changes that are less than ~ modification as deftned by R13. This has resulted in the need fol constant changes 10 the current permits and Will do the sal1l4! With the G8O-A. pennlt. Please allow for changes that do not meet the definition of modification as defined in 45CSR13. 90f39 G35-C Natural Gas Compressor and/or Dehydration Facility b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this Class II General Permit; c. Inspect at reasonable times (including all times in which the facility is in operation) any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this Class II General Permit Ifentcrins the facility :=r~~_~i_~~_~~"~_~~_~_~~~~_~_~~~_~~~~:_~~~_~~~i~~~ d. 2.11. _ ___ _ - --- Sample or monitor at reasonable times, substances or parameters to determine compliance with the permit or applicable requirements or ascertain the amounts and types of air pollutants discharged. Need to Halt or Reduce Activity not a Defense 2.11.1. It shall not be a defense for a registrant in an enforcement acnon that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions ofthis Class II General Permit. However, nothing in this paragraph shall be construed as precluding consideration of a need to halt or reduce activity as a mitigating filctor in determining penalties for noncompliance if the health, safety, or environmental impacts ofhaltmg or reducing operations would be more serious than the impacts of continued operations. 2.12. Emergency 2.12.1. An "emergency· means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, includint!: acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technologybased emission limitation under this Class JI Geneid! Permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by Improperly designed equipment, lack ofpreventative maintenance, careless or improper operation, or oper-.uor error. 2.12.2. In any ellforcement proceeding; the registrant seeking to establish the occurrence of an emergency has the burden of proof. 2.12.3. This provision is in addition to any emergency or upset provision contained in any applicable requirement. . 2.13. Federally':'Enforeeable Requirements 2.13.1 . All terms and conditions in this permit ~e enforceable by the Secretary, USEPA, and citizens under the Clean Air Act. 2.13.2. Those provisions specifically designated in the permit as "Statc-enforceabJe only" shall become "Federally-Enforceable" requirements upon SIP approval by the USEPA. 2.14. Duty to Provide Information 2.14.1. The registrant shall furnish to the Secretary within a reasonable time any information the Secretary may request in writing to determine whether cause exists for modifYing, revoking and reissuing, or terminating this Class II General Permit Registration or to determine compliance with this General Permit. Upon request, the registrant shall also furnish to the Secretary copies of records required west Virginia Department of Environmental Protection· Division of Air Quality -265- rC-o-m-m-en-t-[Z-D-6]-:-s-afety--ls-a-h-j-gh-p-r-iO-rit-y-t-0--,. Williams and we feel that the inspector coming on to our sites should be required to have the same priority. G35-C Natural Gas Compressor andlor Dehydration Facility 100£39 to be kept by the registrant. For information claimed to be confidential, the registrant shall fwnish such records to the Secretal)' along with a claim of confidentiality in accordance with 45CSR3l . If confidential information is to be sent to USEPA, the registrant shall directly provide such .information to USEPA along with a claim of confidentiality in accordance with 40 C.F.R. Part 2. 2.1S. Duty to Supplement and Correct Information 2.15.1 . Upon becoming aware of a failure to submit any relevant facts or a submittal of incorrect information in any registration application, the registrant shall promptly submit to the Secretal)' such supplemental facts or corrected information. 2.16. Credible Evidence 2.16.1. Nothing in this Class n General Permit shall alter or affect the ability of any person to establish compli&nce with, or a violation of, any applicable requirement through the use of credible evidence to the extent authorized by law. Nothing in this permit Wall be construed to waive any defenses otherwise available to the regilMmt including but not limIted to any challenge to the credible evidence rule in the context of any future proceeding. 2.17. Severability 2.17.1. The provisions of this Class II General Permit are se~able. If any provision of this Class n General Permit. or the applicatioo ohny provision ofttns Class II General Permit to any circumstance is held invalid by a court of competent jurisdiction, the remaining Class II General Permit terms and conditions or theu application to other circumstances shall remain in full force and effect. 2.18. Property Rights 2.18.1. Registration under this Class II General Pel mit does not convey any property rights of any sort or any exclusive privilege. 2.19. Notification Requirements 2.19.1. The registrant shall notify the Secretary, in writing, no later than thirty (30) calendar days after the acttW startup of the operations authorized under this permit. 2.20. Suspension of Activities 2.20.1. In the event the registrant should deem it necessary to suspend, for a period in excess of one (I) year, all operations authorized by this permit, the registrant shall notify the Secretary, in writing, within two (2) calendar weeks of the passing ofthe one (I) year of the suspension period. 2.21. Transferability 2.21.1. This permit is transferable in accordance with the requirements outlined in Section 10.1 of 45CSR13. (45CSR§13-10.1.J West Virginia Department of Environmental Protection· Division of Air Quality -266- Ilof39 G3S-C Natural Gas Compressor and/or Dehydration Facility 3.0. Facility-Wide Requirements 3.1. Siting Criteria 3.1.1. All persons submitting a Class II General Permit Registration Application to construct, modify or relocate a natural gas compressor and/or dehydration facility shall be subject to the following siting criteria: a. No emission unit shall be constructed, located or relocated within 300 feet of any occupied dwelling, business, public building, school, church, community building, institutional building or public park. An owner of an occupied dwelling or business may elect to waive the 300 foot siting criteria. b. Any person proposing to construct, modify or relocate.my emission unites) within 300 feet of any occupied dwelling, business, public building, school, church, community, institutional building or public park may elect to obtain an individual permit pursuant to 4SCSR13. 3.2. Limitations and Standards 3.2.1. Open burning. The open burning of refuse by any person is prohibited except as noted in 4SCSR§6-3.1. [45CSR§6-3.1. J 3.2.2. Open burning exemptions. The exemptions listed in 4SCSR~6-3.1 are subject to the following stipulation: Upon notification by the Secretary, no person shall cause or allow any form of open . burning during existing or predicted period'!. of atmospheric stagnation. Notification shall be made by such means as tht Secretary may deem necessary and feasible. [45CSR§6-3.2.) 3.2.3. A~bestos. The registrant ir. responsible for thoroughly inspecting the facility, or part of the facility, prior to commencement of demolition or renovation fur the presence of asbestos and compl)ing with 40 C:F.R. §61.14S,",0 C.F.R § 61.148, and 40 C.F.R § 61.1S0. The registrant, owner, operator must notify the Secretary at least ten (10) working days prior to the commencemerit of lilly asoor.tos fetnoval on the forms prescribed by the Secretary if the registrant is subject to the notification requirements of 40 C.F.R. § 61.14S(b)(3)(i). USEPA, the Division of Water and Waste Management (DWWM), and the Department of Health and Human Resource.'! (DHHR) - Office of Environmental Health Services (OEHS) require a copy of this notice to be sent to them. [40CFR§6U45(b) and 45CSR§34] or 3.2.4. Odor. No person shall cause, suffer, allow or permit the discharge of air pollutants which cause or contribute to an objectionable odor at any location occupied by the pUblic. [45CSR§4-3.1] (State Enfol'COJbIe Only! 3.2.S. Permanent shutdown. A source which has not operated at least SOO hours in one, twelve (12) month period within the previous five (S) year time period may be considered permanently shutdown, unless such source can provide to the Secretary, with reasonable specificity, information to the contrary. All permits may be modified or revoked and/or reapplication or application for new permits may be required for any source determined to be permanently shutdown. This requirement does not apply to emergency generator(s) permitted to operate only 500 hours per year. (45CSR§I3-10.5.] West Virginia Department of Environmental Protection· Division of Air Quality -267- G35-C Natural Gas Compressor and/or Dehydration Facility 120f39 3.2.6. Standby plan for reducing emissioDl. When requested by the Secretary, the registrant shall prepare standby plans for reducing the emissions of air pollutants in accordance with the objectives set forth in Tables I, II, and III of 45CSRII . [45CSR§11-5.2.] 3.2.7. Minimization.of Fugitive Emissions. The registrant shall operate consistent with information provided in registrant's G35-C General Permit Registration Application for fugitive emission sources. [45CSR§13-5.11.] 3.2.8. The regi9lflBt shell Rat ereate 8 lHIisliftee ta the sllftaWldiRg eeIRIRHRHy tty way e41111fe1111enahle lIeise _light IkHillg elleratiell. 3;3. L_________ - Comment [ZD7]: Williams believes that the Monitoring Requirements See Section 4_2. 3.4. Testing Requirements 3.4.1. Stack testing. As per provisions set forth in this permit or as otherwise required by the Secretary, in accordance with the West Virginia Code, underlying regulations, permits .md orders, the registrant shall conduct test(s) to determine compbdnce with the emission limitations set forth in this Class II General Permit and/or established or set forth in underlying documents. The Secretary, or their duly authorized lepresentative, may at hi'llher option witness or conduct such test(s). Should the Secretary exer(;,Jse In-not_a_C_lo...se_d_ve_nt_s..;,vs_te_m_._ _ _ _ _ _-< 3. Each storage vessel thief hatch shall be weighted and properly seated. You must select gasket material for the hatch based on composition of the fluid in the storage vessel and weather conditions. Comment (ZD30]: This may conflict with proposed OOOOa. [4SCSR§13-S.1l.] 7.1.4. I. 6.1.~ 1. ImaIL ____ ..--. GI88/NJ JlM' ~ (llpplieB 18 all_ #JCFR69 SIIhfNI'" (){)OO 86/t11'61s). The Fegi9lHDt eeHlpi)' vlith die elesed , ..lit ~teM FeljllirelReRts iR thi9 geetieR ifdie plReRtiai eMi99iell9 diIR y.'eFe aalelllatei ta aetefRtiae dated fsaility MaMi did iRalHde Feea ..lf18 ,apsfS Hem: the HeFege '_sel as allewed IIIIIi ill aeellFdaRee widi 6.1.4 efthis gt!IlI!fBi Pl!flllit. ¥ell MllSt de9igH the elased '/ellt systeM te Fe. all gBSas, 'JIIIleFS; IIIIIi fumes eMilted frem the mateHal ill die sterage 'Iessel te II eeRtrel deviee thai meets the FeljllirelR811t9 ef efdii9 geRefIII pl!flllit BF te II preeas9. The Fegilltrllftt shall peFfeFIR 8ft illitillll.DAR e'lilktaliell \'Iithill IhiFt) fig) dll)'9 ef9l:Btt HjlIIIIIi felle'.... the pfesedlH'l!II ill seelisll 4.1.4 fef eRgeiog sSHlpliBftse. ¥ell RltI9t desigR IIIIIi epeFllle II elesed vellt sy9l:_ ,'lith lie dstee189le eMissiens, as deteFIRilled lISiRg Bllllie viSll8l elfaeteFy (AllG) illSpeetiell9,lISBPA 4QG:R(jg Methed 2) , West Virginia Department of Environmental Protection· Division of Air Quality -278- Comment· [ZD31]: Please remove as this will likely conflict with the proposed OOOOa. Formatted: Indent: Left: 0.6", Hanging: 0.5", Right 0.11", Space Before: 0 pt. Line spacing: single, Tab stops: 1.1", Left 230f39 G35-C Natural Gas Compressor and/or Dehydration Facility USBPA altemlli'le '","erk pfHliee te delest leaks item ellilipmellt l19iag apaeal gas imegif!g (OGij _ _ (a FLIR eemeR), aF saRle eamhiR8lialltRe.eef. ,'W{) iRspe&tiElRS shall iREllllde, hlK Ret limited te, defeets fill '/isihle eReks, IIales, a'lIl1ps iB pipillg; laase eaMeetieRs; lilillid leale; af hreiEellaF miIIIIiag eaps af ether ela911Ftl de¥ie.s. If regiskllRt l1ges USBPA MetRed 21, tbeB R8 dete_le eRli99iaRs is defiRed fill less tfl8ft SIlIl ",,1ft iR aeeerdllftee )lith Methed 21. If rellistftllllll9e5 8ft OBI elllReRt, ti!eR Ba deleetehle elftissiaRs is defined lIS R8 visihle lelliEs deleeled ill lIeeerdellee with USBPA aIlerneti.e om walk p_aees. l. ¥ell mll9lllle&t the FelllliF8IfteHts spesifiell iR (I) 8ftd (2) aHhis s.&tiaR if the elesell ,'ellt systelft eerHIIiDs ene 8F mere ilypflllS ae liees lhet seHla lie lI9Ia te iii. eft allaf II pertiaD afdle gases, '/1Ip9f9; If tUmes &11ft entering tI!e I181ftfII de'/ise IF tEl II praeess. i. & eept fill pre lided in pBfllgfllllh (2) afthis S_8ft; )'8l1lf1Hst eelftpiy with eilller PIIfIII!J'III''' f....) af (8) IftRis se&tiElII fer ell811 ilypfllls aeviee. .... Yell R11181 preperly iRstall, ealihFllle, IftIIiRtlliIl; IIRII ape_ a flaw inlliedteF lit the iRlet te the hytlll9s de,,'ie. tRllt seilia ai'/eR the strelllR II .1&)' iteFR the eeatrel de,.'iee aF preeess tEl the Btlllaspll.re diet selilHls BR ai&rIII; er iftiti&tes RlltifielltiaR 'Iill NIII8te allIFIII te the nellRl81 HeW amee, tRo h)'!lfllls de. iee is apIIRl,"," thet tI!e slFelllR is heinl!t; er eaHld he, iii. ertea ·WlI8Y item the 8aBlfel de'l'ise er pFase99 te the _ISphere. ,,"'en H. YIHRIII81sellllAl tI!e II)'!I1I95 de"iee 'J8i"le inslaIl;.a lit tI!e ittIet te the ilypll9S ae"lise iR the RaR iii, eRilll pasHiall l19ing II ear 98IIIer IIlaeIE IIRII key twe e~8R: w-. ii, Lewlell dfllill8; IHgh paill. hlee89, IIIII)'II!IIf apeB enilea "IIIlws eF lilies; 8fta safety dei"iees lIFe lIet SIIiljeet te tI!e reCjllirelfteets efPlIRIIJRIPft (ij ef4hiB ~eeaaR. (4&e8R§13 SalI.1 . 7.1.5. Carbon Adsorption Systems The registrant shall comply with the requirements below fur any registered carlxm adsorption system that is listed as a control device in the General Permit Registration: i.The carbon adsorption system shall be designed to achieve the minimum guaranteed 'control efficiency that is listed mthe General Permit Registration for volatile organic compound (VOC) emissIOns; ii. The carbon adsorption system must be operated at all times when gases, vapors, and fumes are vented to it. Carbon canisters shall be operated in series as dual carbon canisters, in case of emission breakthrough in one carbon canister. iii. The carbon adsorption system must have a commercially manufactured saturation indicator installed. iv. Prior to the loading of each truck, the saturation indicator on the carbon adsorption system shall be checked to ensure that the carbon is not spent. These records must be kept in accordance with section 3.5.1 of this general permit. If the saturation indicator demonstrates that the carbon is saturated, truck loading is prohibited and/or emissions are to cease. v. All carbon in the carbon canister shall be replaced with fresh carbon or the carbon canister replaced with a new canister when the saturation indicator changes in color and indicates saturation. vi. Fresh feplll8l!lfteRts fef all l!IIfhalllleiRg 119" iii tRe earhllll e&sarpalB syslelft shall he kapt~l ___ , __, -' Comment [ZD32]: Many sites appropriate site, do not have storage on site. Please remove, West Virginia Department of Environmental Protection· Division of Air Quality -279- G35-C Natural Gas Compressor andlor Dehydration Facility 240f39 The registrant may claim a control efficiency of95% for those units meeting the requirements of 7.1.5.i-vi. 7.1.6. Condensers/BTEX Eliminators. The registrant shall comply with the requirements below for any registered condenserlBTEX Eliminator that is listed as a control devicefemission reduction device for a glycol dehydration unit in the General Permit Registration: i. V~ors that are being controlled. by the condenserlBTEX Eliminator shall be routed to ~ a ~I!~~_.'~~~. ___ ~~!'!!'_ ;~. !\)~..~Q!l_4~!l.s.!;.~IJ!r.I?!L~!t,!!iJ!~!9~.!!t__I!.IJ.. _!i!!l'!;'~.~~n.~~r~. it.l!.. __ . ----potential that vapors (emissions) can be generated from the glycol dehydration still column. ii. 0000a. Please remove. The condenserlBTEX Eliminator shall be designed, operated, and maintained according to good engineering practices and manufacturer's specifications so as to achieve, at a minimum, a capture and control efficiency of 50%. a 7.1.7. Comment (ZD33): Will likely conflict with The registrant may claim a capture and control efficiency greater than 50% if the General Permit Registration was approved based on manufacturer'~ specifications and the W1it was operated as such. Vapor Recovery Units (VRUs) i. The regislHRt skall a_ply with tfie alese' \l emissi_liIteIy te rellllh &em daley Bfrepair. ¥au IftII9t eamplete repair Bf8lleh eollYiJII!IeBt by the ertd efthe shutd_. 11_ h. CIJIIIiIfll8_ NfIII~. . 'fJIe registrant shall mBllilar and IIl8iftteiB IIl111fterly reeards fer eaell eelllp8ll.8lli" WBII _peated fef fIIslwltl eseape efregtllatea air pelilitellts. Baeh: eBllljl8!leRl shall eperate ;rIitIl ft8 date."'e emi95iBns, l1li detefmilled usirtg AVO il!speea-; YSBPA 4QC¥R69 M.-d 11, Y88Y. alteR1aa'lI werk praRiee te dReR lelllEs hIR eEjuipalelllllsillg aptieai giIs i_SiRS (Q{fij eamera (elf: fbIR a8RlBf8), Bf 8eIM eamllillattell thefeBf. twO _1I_iBns shall i!lellllile, hut !let limited te, defests l1li visihle 8Rleks, hales, er gape ill pipifl8'; Jeese a_.RieN; lilluid leaks; er hreMII af ftlissillS eape er ether .Ies_ de'li_. If resislRmt l1ges YSePA Mathed aI, thelllle detaetallie emis9ieRs is IIefiIIed l1li 18ss than SQO PP'" ill a.eerdallee ...Iith Methad a1. If registraRt 11989 M 091 elllB8flt; IheIIIIB date8liallie IIIIis8iens is dIMes IIIIM ,..iaihle IlallII dateetea ill aseeAlMee with YSBPA altemetiVe 091 '\.wrk pRieaeas. IEB!\)' lealE is detested; the regi9trBl\t shall repair tile Ilak l1li98811 l1li pe9sillle. 'Ate first attempt at repair HHI9t he !Baee ',tithill w.'e (S) days efdis.s iIlrills tile leak; B!Id the filial repair IRIISt lie lIlIHIe ...Jit.'1iII fifteell (1 S) days af disae'leRIIS the leall. The regislRmt shall _aN eaeh leak SeleRea 11111 Ole _eeiated repair. "Ale leak will. he sell9idered repaired lIIItii the 98111e malliterillg I118tked that deteated the leak determi_ tile leak is repaired. The registftlllt shelllll8intaill reaerds BfallqllllAerly m8lliterillg feF fllgiti,'8 88ll11J1e aEregulated aiF palllltMts. i. The IIRIHIIII inspeetiaR shall lie eeMliRe8..,AthiR 36S eallllldar days freIII the date aEthe . pre 1ie119 inspaeti8ft er ellFlier. ii. The 8f".1111&1 illSJlaeti811 shall iIIalllde the "YPIIIIS iNpeet.i8ll, e8llduRed aseerdiBg te JIIIf8I!f8IIh (8) Bfthis seRiell. West Virginia Department ofEnvironmenta\ Protection· Division of Air Quality -281- l, \ " \~ \ Comment [ZD40): Please remove as this will likely conflict with the proposed ooooa and will make the permit unusable, Formatted: Indent left 0.6", Hanging: . OS', Right 0.41", Space Before: 0 pt, Line spacing: single, Tab stops: LOS", left G35-C Natural Gas Compressor andlor Dehydration Facility 260f.39 s. BJ'11'1M6 iIM]1f1s,is". 'Ii_II)' iflllJleet the IIypass valve dllfiHg the initial ed IW.lftlai inspeetisn . fer the preaeMe sftha ear seal ef lesk ed lEe)' type esllfigllratian ta '/srify that the valve is I118iRtaiMd in the RSR di'JeFtmg p8SitiSR te ell9llRl that the 'IIRt streaM is Ret dh eFted thrSugft the IIyp89S de'Iies. If 8R aiteflHYi'1'8 metltad i!llII.IN, saMliet the iMpeetiSR sf the 11)'11899 89 deserilled ift the 8peraftHg prseedtlfl!ll. d. Yrut(e Ie ilfBpefll1WtllJl'elfteIfU. ¥ell may desigRate BfI)' pH sf the sl_1I '/aRt 9) stam 89 _life te iflspeet iftha relilliremeRts iR PIIfII@fIIIIIls (i) aad (ii) afthi!l seetisn are met. "GRsm te iRspeet pH are elEeRlpt hm the iRspeetisR relilliremeRts sfplIRI8RlJ1RS (D} BRd (II) sf this seetieR, ¥eli deteFlftiRe that the I!Ijllipmelit is tIIIaafe te iMpeet IIeeBlllls inspeetiHg ptIRIsMIII '11111111 lie eJIfI89ed te e imminelit Sf "stslltial 118RgSF 89 a eSRalljllBRSe sf esmpl)'ing 'fflth the flljllifemeRts. i. ii. ¥ell 8••'8 II written pie that relillires iflspsetien sf the llIuipRleRt 89 freEjll8I1tI)' 89 pfllStieallte dllfifts safe te iflllJleet times. 7.2.3. To demonstrate compliance with the pilot flame requirements of sectIons 7.1.2.3 of this generel permit, the registrant shall follow (i) and (ii) i. I.... __ " _'- ' '}:he preseMe efa pilM fllIIRa shall IIa eslltKNelisly lIIenitered lII.IiRg It theFlftsellllple Sf ~ ether alilliveieRt de'lies te detest the presenee era fllIIRe wheII eRli99iaflS _ -II_II ts it. The "ilM shall I" aquipJlllld aliM that it SElUllliallft altum, Sf itHtillte9 netifieatisn via remete alBfRl ia the Rearest fieldaftiee, MleR the pilat I~ it Sill ii. For any absence of pilot flame, or other indication of smoking or Improper equipment operation, you must ensure the equipment ls-retumedto proper operation as soon as practicable I!fti:r the event occurs. Ai a minimum, you must: (1) Check the air vent for obstruction. If an oostruction is observed, you must clear the obstruction as soon as practicdble, (2) Check for liquid reaching the combustor. iii. The registrant 'l~ exempt from the pilot flame requirements of paragraphs (i) and (ii) of this section if the reglfltrlOt installed an enclosed combustion device model that was tested under § 60.5413(d) which meets the criteria in § 60.54I3(d)(JJ). 7.3. Testing Requirements 7.3.1. To demonstrate compliance with the visible emissions requirements of section 7.1.2.2, 7.1.2.3, and 7. I .2.6 of this general permit, the registrant shall conduct visible emission checks andlor opacity monitoring and recordkceping for all emission sources subject to an opacity limit i. The visible emission check shall determine the presence or absence of visible emissions. The observations shall be conducted according to Section 11 of EPA Method 22. Ata minimum, the observer must be trained and knowledgeable regarding the effects of background contrast, ambient lighting, observer position relative to lighting, wind, and the presence of uncombined water (condensing water vapor) on the visibility of emissions. This training may be obtained from written materials found in the References I and 2 from 40CFR Part 60, Appendix A, Method 22 or from the lecture portion of the 40CFR Part 60, Appendix A, Method 9 certification course. The observation period shall be: a. a minimum of2 hours if demonstrating compliance with 7.1.2.2; b. a minimum of 15 minutes if demonstrating compliance with 7.1.23(iii)(a); or c. a minimum of 1 hour if demonstrating compliance with 7.1 .2.3 (iii)(b) West Virginia Department of Environmental Protection· Division of Air Quality -282- Comment [ZD41]ols a duplicate of 7.2.1. Please remove. G35-C Natural Gas Compressor and/or Dehydration Facility ii. 270£39 The visible emission check shall be conducted initially within 180 days of start-up to demonstrate compliance while vapors are being sent to the control device. iii. If during this ~sible emission check or at any other time visible emissions are observed, compliance with section 7.1.2.6 of this general permit shall be determined by conducting opacity tests in accordance with Method 9 or 40 CFR 60, Appendix A. 7.3.2. 7.3.3. 7.4. A flare that is designed and operated in accordance with ~60.18(b) ~~t !\.qtr~Q.l!!~~ J1C?!fQ~"C: _______ ••••• COmment [ZD42]: This does not allow for testing, unless at the request of the Secretary, but must conduct visible emission check. pressure assisted flares which often can be more reliable than candle stick flares. &teI6HfI «1mb_BIt thWeH 8'jlslW. At slI8h _allaele times 119 the SIeFetllf)' may ~sigllllte; :.;.;..;..;...;,;;;,;....;..;;;.;,;;;.;.;;;;.;,;;;.;;.;,;;.;;;;~;.;;;;;;...---< the epe_af efany iBeill8f8ter llhallile required te I!8IWiIlBl.8f he','e aaMlletell staek teMS te CQmment [ZD43): WIlliams believes that dMSffllills the pllftiBlilats matter la_illg, hy IIBillg 49 CFR PaR /ig, AppelWiiJ[ A, MetRed S, aM many of these test methods would either be '.-elatile ef88Hie lI_pallflll leading; by l19ing MMllads 18 Bllil U .... af 49 CFR Part /ig, AppelldiJ[ impossible or not result in the desired data for A, Methed ]ag af4g CFR PeR /i], AppelldiK A, 81' .6JlTM S 6148 g] 81' ether IIqtliveieRt H.S. flares thus making it Impossible for companies ~ apple led Hl8thed BPJ!le'led hy the Seeretary, illl!lillBust psIS. SlieR telll!l sItaIl hs e8llHeted to comply. ill sII8h _Sf 119 the 8 eefetafy IIIIIY iipecit; and lie filed all &l'III8l1ftd ill a _ e r seee_le te the Seeretary. Tile 8eerMllf)' may, at the Secretary'. apa8ft; ·.TJilfttll!l8 8£ ealldttet sII8h Meek tests. SRllllld the SeerMllf)' 8J(ereise his er hef eptiaft te 8allhM Slieft tests; the aperater "";11 pra, ide all the lIeee998fy sampling eallfteetians IIftEI SllPlfllillg paFts te Be laeated ift BIIeIt IB8IIft8r 119 the Seeretary Ift8:J feqllire, perm. fer test ~_lIftEIlh8'AlEl:llired aafe~ ellUiJMllellt s!I8k 119 se&ft"eldiHg, railiftga BIId I_dee ta I!OHIJIly will generally aeeepted gead 9IfetY praetiees. 'fhe 8ecretafy may saullel sll8h ether tests 89 the 8ee.ey may deem fl8eessllfY .a .,,\,aIIIate air pelltttieR Blllissi8lls ether dt8R tiles., fl8tell aee'l8. 14se8R{j 117.1 ••• 7.1) L. __ .__ .. Recordkeeping Requirements 7.4.1. For the purpose of demonstrating compliimce with.the design requirements in section 7.1 .2.2 of this permit, the registrdllt shall maintain a record of the flare design evaluation. The flare design evaluation shall mclude, net heat value calculations, exit (tip) velocity calculations, and all supporting concentration calculations. 7.4.2. For the purpose of demonstrating compliance with the continuous pilot flame requirements in sectiOIll. 7.1.2.2 and 7.1.2.3 of this general permit, the registrant shall maintain records of the times and duration of aU period!! '¥hen the pilot flame was not present and vapors were vented to the device. 7.4.3. i. lfthe registrant is demonstrating compliance to 7.2.3 of this general permit with visual inspections, the registrant shall maintain records of the inspections. ii. lfthe registrant is demonstrating compliance to 7.2.3 of this general permit with an enclosed combustion device model that was tested under the conditions of § 60.5413(d), a record shall be maintained of the performance test results. For the purpose of demonstrating compliance with the visible emissions and opacity requirements, the registrant shall maintain records of the visible emission opacity tests and checks. The registrant shall maintain records of all monitoring data required by section 7.3.1 of this general permit documenting the date and time of each visible emission check, the emission point or equipment! source identification number, the name or means ofidentification of the observer, the results of the check(s), whether the visible emissions are normal for the process, and, if applicablc:, all corrective measures taken or planned. The registrant shall also record the general weather conditions (i.e. sunny, approximately 80°F, 6·10 mph NE wind) during the visual emission check(s). Should a visible emission observation be required to be performed per the requirements specified in Method 9, the data records of each observation shall be maintained per the requirements of Method 9. For an emission unit out of service during the evaluation, the record of observation may note "out of service" (OIS) or equivalent West Virginia Department of Environmental Protection· Division of Air Quality -283- G35-C Natural Gas Compressor and/or Dehydration Facility 280f39 7.4.4. To demonstrate compliance with section 7.1.2.3. vi of this general permit, the registrant shall maintain records of the manufacturer's specifications for operating and maintenance requirements to maintain the control efficiency. . 7.4.~. 1s dsmenstRlle eSlllplianee with tke elesell ,,!lilt mSlliteRHg reqlliremsfts ift seeaisII7.i!.i! sf~ ... __ ---_.. Comment [ZD44J: Please remove as this gt!IIBRII p-it, ressRis shall he I118iftteifted sf: ' will likely conflict with NSPS oooOa. i. The iBKiel e_pliuee reqllifelllllllts; ii. Beeh BI".ft1lal AVQ iftSpeee8ft, Mel:hsd i! 1, iftlfered e_efe er seme eelllhilllle8ft thereef esntltieteli te demeRRre'e esHii_1IS esmplieHser iIIelllliiHg f88sRls sfu)' re!laifS iltIt were lIIee es a reslll' sftke iftspeelieft; iii. Ifysli are sllhjeel te the hypess re'lllirelllds, the felle\...mg reseRIs shall a1ss he lIIaiftteillBli: (it) Beeh iMpeetiell er eaeh ellle the key is shee.eII ell' Sf a _sRi sf saeh S1118 the allIHII is 9BIIftded;- Ell) Baeh eeslllftl_ that tke eBRifel: llMiee _ hypassed. Iflile dIMes \'lllIIil hyplllilsed, tke III!ld dllfa98ft sf the eveRt aIId skellp!'B"ide the feesRis shall iRellide the date, _ rees8ft diet the e'JeHi seewHli. The I'I!IleRI shell alse ifteilide the elifimete sf elllissisftS that ,~re releesed te tke 8ft-life_Hi es a Rll!l1I1t eHhe hypess. i.... My !111ft sftke systelll that hM IJeen desigftateli IIfII '!Jmda te ifl9p8el" ill eeeeRIliftee ",lith ~ 7.4.6. To demonstrate compliance with section 7.1.5 of&, general permit, records shall be kept on each carbon canister to indicate the date wh~ the activated carbon was replaced and the date of all indicator checks. 7.4.7. The registrant shall maintain records of any testing that is conducted according to section 7.3.of this general permit 7.4.8. All records required under Section 7.4 shall be maintained on site or in a readily accessible off-site location maintainetl by the registrant for a period of five (5) years. Said records shall be readily available to the DireCtor of the DAQ or his/her duly authorized representative for expeditious ' Inspection and review. ,\By f88eR1s 9.IIhRlitkld te 'he agallS) I'lIf9II&Ift te fl relj;llifellleHi sf this I'eFII'Ift Sf III'Sft reqlle&t by the Dire.sf shall he eefSfieli hy fl _pslIsmle lameialLuuumumu ____ ------ Comment [ZD4S): Williams requests that this be removed due to the fact that most 7.4.9. To demonstrate compliance with section 7.1.2.5 of this general permit, the registrant shall record inspectors would like the data durllll: the the volume of ga' flared and the heating value of the gas flared on a monthly basis. inspection and for a company to follow this to the letter would not allow a company to give 7.4.10. To demonstrate compliance with section 7.1.6 of this general permit, the registrant shall record the records to an inspector during the Inspection ~ut1ettemperatureh(!tI_Il.~_ Saturday, September OS, 2015 12:10 PM Williams, Jerry Noise Mr. Williams, Why are people who are near drilling and gas pipe lines not protected from noise, failing wells, bad roads, etc. The general permit should include noise a,b atement. If gas wells are in the public interest, why should not the ones near be protected from bad water, noise, and other problems? John Bird Masontown, WV 26542 1 296 Williams. Jerry From: Williams, Jerry Sent Friday, September 11, 2015 8:51 AM 'Tina Del Prete' To: Subject: RE: G35-C Ms. Del Prete, Thank you for your comments. I will incorporate your comments with others received during the G35-C public comment period and a formal response to comment document will be created at the end of the public comment period (9/14/2015). The proposed noise and light language is not a new rule being promulgated by the DAQ. Instead it is proposed permit language under General Permit G35-C. In regards to this language, it will cover any source that is registered under General Permit G35-C. This includes new sources or any existing G35-A registrant who modifies their permit after General Permit G35-C is issued. This means that if a company is registered under General Permit G35-A and makes a change to their facility which requires a General Permit update, it will be done under General Permit G35-C, which is proposed to contain noise and light language. We will review all comments received in regards to the noise and light issues and make a determination on the finallangliage. You will receive a copy of the Response to Comment document created for this permitting action. If you have further comments and/or questions, please let me know. Thanks, Jerry Jerry Williams, P.E. Engineer WVDEP - Division of Air Quality 601 57th Street, SE Charleston, WV 25304 (304) 926-0499 ext. 1223 jeny.williams@wv.gov dep ~ Please consider the envirorunent before printing this email. From: Tina Del Prete [mailto:tna4mail@yahoo.com] Sent: Friday, September 11, 2015 7:45 AM To: Williams, Jerry Subject: G35-C Dear Mr. Williams, I am writing in reference to the new rules your office is planning on instituting for compressor stations. 1 -297- I would like to start by thanking you and your office for realizing that more needs to be done to limit noise, light and emission pollution from these stations. "3.2.8 states-The registrant shall not create a nuisance to the surrounding community by way of unreasonable noise arid light during operations." I appreciate that noise and light are considered a nuisance, because they really are to folks living around them. In Doddridge County,where llive,there are so many compressor stations already built that are constantly emitting way to much noise and light, not to mention the polluting em.issions spewing from these stations. The one thing I regret about these new rules is that they would only cover new stations.Something really needs to be done about the ones that already exist. The noise from these stations are unbearable to folks living close to them and can travel to homes rather far away. Especially in fall and winter when the leaves are off the trees So I feel that a decimal limit must be imposed as it would be more predictable and clear. .1can hear the Victoria Station that is about 3 or 4 miles,as the crow flies,from my house in fall and winter. I also have the Canton North Compressor station about 11/4 miles from my house that I expect to be able to hear when the leaves come off the trees.And behind me about a mile,the Pandora(doesn't that name give you warm and fuzzy feelings? NOT) being built.So I am surrounded by these stations and I do not like it one bit. I do not have the ways' and means to move so I am stuck here,as are a lot of folks and it is way past time that someone started caring about us and our environment. I am hoping that new rules and regulations will be imposed on the emissions from these stations also. I've asked this before and was not given an answer so here it is again.When will enough be enough for my community?When will there be enough well pads, compressor stations,metering stations,gathering lines and pipelines be enough for your agency to say enough? It's already way to much for the folks living in Doddridge. Sorry to vent to you all my frustrations but I am at the end of my rope.l gU,ess I can be thankful that my days are numbered and won't have to watch the total destruction and toxic wasteland that Doddridge will soon become. Please let me know you got my comments and keep me informed as to what ends up happening with these new rules and whether they will be implemented or if the industry gets to win again by you not implementing these new rules. Thank you for your time. Much Respect-Tina Del Prete 4805 Riggins Run West Union,WV 6456 2 -298- Williams, Jerry From: Sent: To: Subject: Tina Del Prete Friday, September 11, 2015 7:45 AM Williams, Jerry G35-C Dear Mr.Williams" I am writing in reference to the new rules your office is planning on instituting for compressor stations. I would like to start by thanking you and your office for realizing that more needs to be done to limit noise, light and emission pollution from these stations. "3.2.8 states-The registrant shall not create a nuisance to the surrounding community byway of unreasonable noise and light during operations." I appreciate that noise and light are considered a nuisance, because they really are to folks living around ,them.ln Doddridge County,where Ilive,there are so many compressor stations already built that are constantly emitting way to much noise and light,not to mention the polluting emissions spewing 'from these stations.The one thing I regret about these new rules is that they would only cover new stations. Something really needs to be done about the ones that already exist. The noise from these stations are unbearable to folks living close to them and can travel to homes rather far away. Especially in fall and winter when the leaves are off the trees So I feel that a decimal limit must be imposed as it would be more predictable and clear. .1can hear the Victoria Station that is about 3 or 4 miles,as the crow flies,from my house in fall and winter. I also have the Canton North Compressor station about 11/4 miles from my house that I expect to be able to hear when the leaves come off the trees.And behind me about a mile,the Pandora(doesn't that name give you warm and fuzzy feelings? NOT) being built.So I am surrounded by these stations and I do not like it one bit. I do not have the ways and means to move so I am stuck here,as are a lot of folks and it is way past time that someone started caring about us and our environment. I am hoping that new rules and regulations will be imposed on the emissions from these stations also.I've asked this before and was not given an answer so here it is again.When will enough be enough for my community?When will there be enough well pads,compressor stations,metering stations,gathering lines and pipelines be enough for your agency to say enough? It's already way to much for the folks living in Doddridge. Sorry to vent to you all my frustrations but I am at the end of my rope. I guess I can be thankful that my days are numbered and won't have to watch the total destruction and toxic wasteland that Doddridge will soon become. Please let me know you got my comments and keep me informed as to what ends up happening with these new rules and whether they will be implemented or if the industry gets to win again by you not implementing these new rules. Thank you for your time. Much Respect-Tina Del Prete 4805 Riggins Run West Union,WV 6456 1 -299- · Williams, Jerry From: Sent: To: Subject: Lyn Bordo Saturday, September 12, 2015 5:30 PM Williams, Jerry Compressor Stations Greeting Jerry, As a citizen ofWV and resident living right on the Doddridge-Ritchie county line, I am contacting you with my concerns surrounding the drilling activity in our are~ specifically compressor stations and even more specifically, the noise from the compressor station closest to our home. Most days, especially mornings, that I feel like I am living on an airport runway. During my 30+ year working career my husband and I poured all of our resources into educating our children and developing our home & land. I retired just last fall. Now I find I cannot even sit outside and enjoy the fruits of our labors. The compressor is unbearably loud. Set aside all the other aspects of drilling in our area- this whole fiasco as it were- I find my life and lifestyle being destroyed. And, no, that is not hyperbole. The noise is that bad! I implore you to please :;tdvocate for stricter noise and light standards for these facilities, both future and existing. I appreciate your considerations and action!! Thank yOll'" Lyn S Bordo 1777 Yearger Run Greenwood WV 2641 5 304-677-2606 />0~.)~:~~~~;.:r2~ ··> ~.r-~~ ~.~. ~ : d_\:;"~ 1 -300- r; ;'~'~~:'-~~J - ~;: LC.: ~ ji;;-::'.~ Williams, Jerry From: Sent: To: Subject: George Monk Monday, September 14, 2015 1:31 PM Williams, Jerry comments G35-C Dear Mr Williams, We would like to support the DAQ in their language for noise restriction in the G35-C general permit. We believe that the loud noise that is generated at compressor stations could be lessened dramatically, but is not. Our experience is based on 039-00530, the Cranberry Pipeline station near us. For our neighbors who live closest the constant noise is a nuisance. For us who live further away the din is annoying. We believe the language in the general permit at 3.2.8 should be retained without change. Sincerely, George Monk and Molly Schaffnit 199 Bronco lane Poca, WV 25159 304-533-8622 1 -301- Williams, Jerry From: Sent: To: Cc: Subject: Attachments: Julie Archer Sunday, September 13, 2015 3:02 PM Williams, Jerry Wvdavid@wvdavid.net; joe@gasp-pgh.org; nsteinzor@earthworksaction.org; Radcliff, Wendy E Comments Re: Draft Class IT General Permit G35-C G80-A_comments_GASP_ecal.pdf; OrdinanceNoiseControl.pdf Dear Mr. Williams, Please accept the following comments on the draft Class II G35-C general permit for natural gas compressor stations and/or dehydration facilities on behalf of the WV Surface Owners' Rights Organization (WV-SORO). Supporting documents are attached. Having reviewed the draft G35-C, which replaces portions of the previously proposed G80-A general permit, we remain concerned that the permit fails to satisfy several requirements of the Clean Air Act and federal and state regulations implementing the Act. Because the G35-C incorporates many provisions of the proposed G80-A, which had several shortcomings including a lack of uniform terms and conditions; failure to provide specific technically accurate limits on potential to emit, etc., we respectfully ask that you reconsider our prior comments on the proposed G80-A where relevant. A copy of the comments on the draft G80-A previously submitted by the Group Against Smog & Pollution, WV-SORO, et. a/. are attached . . While our broader concerns regarding the permit's deficiencies have not been addressed, it does appear that DAQ made some improvements to many of the sections regarding, monitoring, inspections and related recordkeeping that are appreciated. In addition to these improvements, WV-SORO supports the inclusion the provision in section 3.2.8. to limit community impacts and the use of a nuisance standard to limit unreasonable noise and light during operation. The most frequent complaint that WV-SORO gets with regard to compressor stations is noise. The number of stations is growing and the noise is more and more a problem. Individual surface owners may have dodged the bullet and did not have a well pad on or near them, but their lives can still be affected by the noise a compressor station makes from great distances. Noise can reduce a citizen's to the point that the citizen wants to leave, but often the noise reduces the value of the home to the extent that they cannot sell the home and land for what they owe, let alone for their investment in the payments already made. The value of the gas going through these compressor stations is beyond the experience of most West Virginians living near them, and it is even beyond the experience of those working in the industry prior to horizontal shale drilling. The cost of a sound insulating building (not just any bUilding·, but a sound insulating building), and the cost of other noise reduction technologies and measures (such as turning the cooling fans upward and the use of electric motors is not significant when compared to the total cost of constructing the facility and certainly nothing compared not to the value of the gas passing through it to the private enterprise to whom the compressor station will belong. So the industry should put the most and the best noise reduction technologies in place, and it is not an unreasonable imposition to require them to do so. Having done that, it is unlikely that there will be a nuisance noise level at any residence or other sensitive facility. It is therefore not unreasonable to put the nuisance standard that is proposed in this general permit. The industry will do its own noise management plan/study of a particular site and either put in the most and the best,n,oise reductiQlJ.,., r 1 -302- Co ':-,__ ; available from the start, or risk that in putting in something less that results in a citizen complaining the noise, and the State Insisting on improvements to reduce it. ~\bout Further argument for the nuisance standard for noise is the difficulty of developing a standard based on enumerated decibelleve!s. One frequently used limit is 55 dB(A). (See 18 C.F.R. 380.12(k) carrying out the National Environmental Policy Act.) This level is recognized by the EPA and the World Health Organization of causing health concerns. (See footnote 12 at page 128 of the May 28, 2013, study that was ordered by the Horizontal Well Act and commissioned to Dr. Michael McCawley of the WVU School of Public Health by the DEP.) There are several problems with such a standard. First it is often used as an average, and intermittent sounds can occur that are much louder, loud enough to disturb sleep or even awaken a perso'n (clangs, bangs, horns, etc.), but are well above the average. And there can be different sensitivities. Young children, the chronically ill and the elderly are more susceptible to adverse health affects for example. There is also the general enjoyment and quality of life of one's property. A nearby store that is playing music to its customers has a different sensitivity than a residence that can have the sounds of approaching strangers obscured. Rural residences are of often chosen for the peace and quiet, and as noted above, their value will be diminished without it. Any such enumeration setting decibel limits on noise would have difficulty taking into account all of the factors that might affect the noise level at a particular site, such as the elevation or height of the facility relative to homes and other sensitive facilities and dwellings, whether the noise is unusual or incongruous, the frequency of the noise, and the level and frequency the ambient noise, prevailing winds, etc. Some other nuisance standards start with the ambient noise level at the impacted residence and limit additions (see the attached Noise Control Ordinance for the Town of Windsor, NY). But if it is already noisy, that can get above even something like 55 dBA. Some governmental limits on highway noise levels address peaks, but even with that, who should be made to live next to a highway -- a highway out of which they get no use. Also, many of these standards are measured at existing facilities, such as residences, and do not take into account that future home sites between the existing home and the compressor station may be compromised. Therefore, WV-SORO supports the general permit with regard to noise as written because it knows of no more objective standard that is or can be made workable for all citizens affected. The incluSion of such a standard In the general permit Is need to require operators to limit noise from compressor stations and give DEP DAQ some basic authority to regulate noise, suspend operations if they are too loud and order operators to deploy noise reducing measures and technologies to reduce it. The downside of the noise provisions included in this general permit will be there limited applicability. While WV-SORO supports their incluSion, what is really needed are comprehensive rules regulating and monitoring air, noise and light emissions from all permitted oil and gas facilities including 011 and gas production facilities and well sites, to reduce potential exposures, prevent negative health impacts, protect property values and preserve the quality of life of residents living near these operations. For air compressor stations in particular such rules should include resident notification of blowdowns and maintenance, shutdown and startup (MSS), which can release large volumes of emisSions in a short time; and a prohibition on the use of diesel engines and open flares that emit high levels of VOCs. Additionally, regular and ongoing monitoring at and near compressor stations should be conducted to allow the DAQ to assess the cumulative impacts to air quality as more facilities corrie online. Thank you for your consideration and the opportunity to comment. If you have any questions or require additional information, please feel free to contact us. Sincerely, 2 -303- Julie Archer, Project Manager & David McMahon, Co-Founder wv Surface Owners' Rights Organization 1500 Dixie Street Charleston, WV 25311 Phone: (304) 346-5891 (Julie) or (304) 343-6101 (David) E-mail: julie@wvsoro.orgorwvdavid@wvdavid.net 3 -304- -305- Via Email March 30,2013 Jerry Williams, P.E. West Virginia Department of Environmental Protection Division of Air Quality 601 57th Street, SE Charleston, WV 25304 DEPG80A@wv.gov Re: Comments Regarding Draft Class IT General Permit G80-A for Natural Gas Production, Compressor and/or Dehydration Facilities Dear Mr. Williams, Please accept the enclosed comments regarding Draft Class II General Permit G80-A for Natural Gas Production, Compressor and/or Dehydration Facilities on behalf of the Group Against Smog and Pollution, the West Virginia Surface Owner's Rights Organization, the West Virginia Highlands Conservancy, the West Virginia Chapter of the Sierra Club, the West Virginia Environmental Council, the Mon Valley Clean Air Coalition, the Wetzel County Action Group, and the Ohio Valley Environmental Coalition. We thank the Department for providing this opportunity to comment. If you have any questions or require any additional information, please feel free to contact us. Sincerely, Joe Osborne Legal Director Group Against Smog & Pollution 5135 I,>enn Ave. Pittsburgh, P A 15224 412-924-0604 joe@gasp-pgh.org Cindy Rank WVHC Extractive Industries Committee WV Highlands Conservancy 4401 Eden Road Rock Cave, WV 26234 304-924-5802 clrank2@gmail.com Connie Gratop Lewis West Virginia Environmental Council 2207 Washington St E Charleston, WV 25311 (304) 344-3141 Julie Archer West Virginia Surface Owner's Rights Organization 1500 Dixie Street Charleston, WV 25311 304-346-5891 julie@wvsoro.org Janet Keating Executive Director Ohio Valley Environmental Coalition P.O. Box 6753 Huntington, WV 25773-6753 ·304.522.0246 janet.ovec@gmail.com Jim Kotcon Energy Committee Chair West Virginia Chapter of the Sierra Club PO Box 4142 Morgantown, WV 26504-4142 -306- Mon Valley Clean Air Coalition clo Duane G. Nichols 330 Dream Catcher Circle Morgantown, WV 26508 304-216-5535. Nichols330@gmail.com MVCAC@osenergy.org Bill Hughes Wetzel County Action Group 862 Scheidler Run Road New Martinsville, WV 26155 304-386-4692 hughes@orvis.net General pennits establish standardized permit tenns and conditions for categories of sources that are numerous and similar in nature. 1 General penn its can reduce burdens on airpermitting-programs by eliminating the need to develop separate air permits tailored to each individual facility application the agency receives. Further, air-pennitting-authorities generally need not provide opportunity for public comment prior to authorizing construction or modification of an individual source pursuant to a general pennit. However, in its present fonn, G80-A fails to satisfy several requirements of the Clean Air Act and federal and state regulations implementing the act. These shortcomings are described in more detail in the following sections. 1. WVDAQ must either alter G80-A to provide uniform terms and conditions, or provide a 30-day public comment period prior to authorizing construction or modification of individual sources under G80-A. 1.1 Typically, public participation is not required prior to issuing a general permit registration to an individual source based on the presumption that all facilities authorized under the same general permit will be subject to uniform terms and conditions. While EPA requires state and local air permitting authorities to provide a 30-day opportunity for public comment prior to issuing a standard pennit,2 EPA does not require a similar public comment period prior to issuing a general permit registration to an individual source. EPA's logic is that (1) the public has an opportunity to comment on the general pennit when the air permitting authority initially developed the general permit, and (2) no additional public comment period is necessary because general pennits are standardized documents that will not be tailored on a case-by-case basis to individual sources: In cases where standardized permits have been adopted, EPA and the public need not be involved in their application to individual sources as long as the standard permits themselves have been subject to notice and opportunity to comment. ... A general permit is a single permit that establishes terms and conditions that must 1 See e.g. W. Va. Code §22-5-11(g)(2), 45 CSR 13·5.l2. 240 C.F.R. § 51.161(a). 1 -307- be complied with by all sources subject to that permit. The establishment of a general permit provides for conditions limiting potential to emit in a one-time permitting process, and thus avoids the need to issue separate permits for each source within the covered source type or category. 3 1.2 By incorporating facility-specific emission limits and operating par~meter requirements by reference, G80-A defies the presumption that all facilities authorized under the same general permit will be subject to uniform terms and conditions. G80-A contains virtually no specific numeric limits on emissions from G80-A-eligible emission units, nor does it specify pollution control device efficiencies, limits on equipment capacities, operational or production limitations, or operating parameters necessary to ensure sources achieve and maintain any required control efficiencies or emission limits. Instead, G80A would incorporate by reference emission limits and other operating parameters contained in facility-specific G80-A registration forms. It appears that the information in the registration forms would copied directly from applicants' G80-A registration applications. Thus, while G80-A nominally provides uniform, standardized permit terms and conditions, the G80-A terms and conditions themselves contain very few substantive requirements; instead, the G80-A language largely incorporates by reference whatever facilityspecific numeric emission limits and operating parameters the applicant provided in its initial G80-A registration application. As a result, the actual applicable numeric emission limits and operating parameters may vary as wildly from one G80-A facility to the next as they would between G80-A-eligible sources permitted under the standard individualized minor NSR permitting process. Yet, unlike individual minor NSR permits, neither individual G80-A authorizations, nor the facility-specific G80-A registration forms are subject to public comment prior to issuance. 371 FR 5979,5981; Memo from Kathie Stein, USEPA, Guidance on Enforceability Requirements for Limiting Potential to Emit (Jan. 25, 1995), available at: http://www.epa.gov/region7/air/nsr/nsrmemos/potoem.pdf. 2 -308- As proposed, G80-A would afford applicants virtually the same freedom to customize their proposed facilities the standard minor NSR permitting process would provide while eliminating the'opportunity for public participation afforded under the standard minor NSR permitting process. As discussed above, the rationale for not requiring a 30-day public comment period prior to issuing a general permit registration to an individual source is premised on the assumption that applicable terms and conditions will not vary from one general permit facility to the next. In its present form, G80-A defies that assumption. Thus WVDAQ must either alter G80-A to provide uniform terms and conditions, or provide a 30-day public comment period prior to issuing a general permit registration to an individual source. 2. G80-A fails to provide specific, technically accurate limits on potential to emit and fails to establish specific operating parameters to ensure those limits are achieved and maintained in practice. ' As discussed in the previous section, G80-A itself contains virtually no specific limits on emissions or operating parameter requirements to ensure sources achieve and maintain limits on potential to emit. In a memo titled "Guidance on Enforceability Requirements for Limiting Potential to Emit" USEPA states: fA permit-by-Jrule or general permit . . , must specify technically accurate limits on the potential to emit. . . must clearly specify the limits that apply, and include the specific associated compliance monitoring. . . . The standards or limits must be technically specific and accurate to limit potential to emit, identifYing any allowed deviations. ... Further, for potential to emit limitations, the standards set must be technically sufficient to provide assurance to EPA and the public that they actually represent a limitation on the potential to emit for the category of sources identified. Any presumption for control efficiency must be technically accurate and the rule must provide the specific parameters as enforceable limits to assure that the control efficiency will be met. For example, rules setting presumptive efficiencies for incineration controls applied to a specific or broad category must state the operating temperature limits or range, the air flow, or any 3 -309- other parameters that may affect the efficiency on which the presumptive efficiency is based. 4 EPA goes on to directly address problems with proposals, like G80-A, which would allow general permit applicants to establish source-specific operating parameters and emission limits: A rule that allows sources to submit the specific parameters and associated limits to be monitored may not be enforceable because the rule itself does not set specific technical limits. The submission of these voluntarily accepted limits on parameters or monitoring requirements would need to be federally enforceable. Absent a source-specific permit and appropriate review and public participation of the limits, such a rule is not consistent with the EPA's enforceability principles. 5 3. G80-A fails to establish federally enforceable limits on potential to emit because underlying emission limits and operating parameter requirements are not subject to public participation requirements. M~jor sources are not eligible for G80-A.6 Major source status is based on a facility's "potentialto-emit" applicable pollutants. 7 Limitations must be "enforceable by the [WVDEP] Secretary and U. S. EPA" in order to constitute limits on potential to emit.s In order to be federally enforceable, limits must be subject to an opportunity for public review. 9 As stated in the sections above, individual facility authorizations under G80-A are not subject to public review, and the standard terms and conditions of G80-A fail to provide specific limits on emissions or establish operating parameter requirements to ensure sources achieve and maintain limits on potential to emit. 4 Memo from Kathie Stein, USEPA, Guidance on Enforceability Requirements for Limiting Potential to Emit (Jan. 25,1995) at 8, available at: http://www.epa.gov/region7/air/nsr/nsnnemos/potoem.pdf. sId. - WVDEP, Draft General Pennit G80-A, conditions 2.3.1 .a at 5. Definition of "major stationary source" 45 CSR 13-2.16,45 CSR 14-2.43, 45 CSR 19-2.35, and 45 CSR 30-2.26. 8 Definition of "potentiaI to emit" 45 CSR 13-2.19. 940 CFR 51.161; 71 FR 5979,5981; USEPA, Guidance an Enforceability Requirements for Limiting Potential to Emit through SIP and §112 Rules and General Permits (Jan. 25, 1995) at 8, available at: http://www.epa.gov/region7/air/nsr/nsrmemos/potoem.pdf 6 7 4 -310- The public notice required at the time ofG80-A application submission 1o is not sufficient to satisfy the public participation requirement. The application itself would not provide any indication to the public of which limits and operating parameters listed in the application WVDAQ would ultimately include in the G80-A registration form and incorporate by reference as facility-specific G80-A emission unit level terms and conditions. Further, if the initial G80-A application was later revised to include new or modified limits on emissions or operating parameter requirements, a new 45 CSR 13-8.3 notice, and new 30-day comment window would be necessary to satisfy the public participation requirements of 40 CFR 51.161. 4. 45 CSR 13-5.11 prohibits incorporation of emission limits and operating parameters by reference. 45 CSR 13-5.11 states that, "any portions of the permit application, other than plans and specifications, that are to be made permit conditions must be specifically identified in the permit itself." WVDAQ's proposal to incorporate emission limits and operating parameter requirements by reference, rather than stating them directly in G80-A itself is clearly and expressly prohibited by 45 CSR 13-5.11. S. G80-A should be revised to include specific emission limits and operating parameter requirements in the general permit itself, rather than incorporating such requirements by reference from facility-specific registration forms. The problems described in sections 1-4 above are due in large part to the fact that proposed General Permit G80-A incorporates emission limits and operating parameter requirements by reference to facility-specific information and could be addressed by instead providing specific, uniform emission limits and operating parameter requirements directly in the G80-A terms and conditions themselves. For example, Pennsylvania Air Quality General Permit 5 for natural gas compression and/or processing facilities includes specific numeric emission 10 45 CSR 13-8.3. 5 -311- limits for stationary engines II and turbines,I2 a numeric control efficiency for the dehydrator still vent, 13 a~d provides specific parametric requirements to ensure dehydrator control device efficiency. 14 6. G80-A should be revised to include conditions establishing reciprocating engine control device efficiencies and engine emission limits. Reciprocating engine emissions are generally among the largest permanent sources of NOx, CO, VOC, and formaldehyde emissions from natural gas facilities. Consistent with the policy and purpose ofW. Va. Code Chapter 22, Article 5,15 and pursuant to its authority under W. Va. Code §22-5-4(a)(I) and 45 CSR 13-5.11 , DAQ should include specific numeric limits on emissions from reciprocating engines in G80-A. 7. Absent a permit condition requiring trucks to meet a specific collection efficiency, PTE from truck loadout must be based on maximum uncontrolled emissions from truck load out. The G80-A fact sheet directs applicants to estimate facility potential to emit l6 and goes on to provide presumptive control efficiencies and emission limits for various G80-A emission sources. For truck loadout emissions, DAQ lists 3 separate presumptive capture efficiencies, ranging from 70% to 99.2% depending on the leak certification status of individual trucks and states that "compliance with this requirement shall be demonstrated by keeping records of the applicable MACT or NSPS Annual Leak Test certification for every truck loadedlunloaded.,,17 Jl PADEP, Air Quality General Pennit 5, conditions B.l & 2 at 10, available at: http://www.elibrary.dep.state.pa.usldsweb/GetlDocument-l0588112700-PM-BAQ0205%20GP5%20PennitoAl20SAMPLE.pdf. 12Id. condition C.l at 12. 13 Id, conditions F.2(a) & F.3 at 14-15. 14Id conditionsF.2(b)-(j) at 14-15. IS W. Va. Code §22-5-1. 16 WVDEP, G80-A Fact sheet at 6. 17 WVDEP, G80-A Fact sheet at 7. 6 -312- However, DAQ does not indicate how applicants should estimate potential to emit from truck loadout. Potential to emit is defined as: the maximum capacity ofa 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 offuel combusted, 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. 18 Numerical limits on potential to emit are not enforceable per se. In order to be federally enforceable, a PTE limit must either: reflect maximum emissions of the source operating at full capacity, or be based on production limits or operational limits (e.g., hours of operation, fuel restrictions, pollution control requirements) sufficient to ensure the source will not exceed the numerical emission limit.I9 Thus, absent a permit condition requiring trucks to meet a specific collection efficiency, PTE from truck loadout must be based on maximum uncontrolled emissions from truck loadout. S. Several GSO-A terms and conditions are not enforceable as a practical matter and must be revised. Several G80-A terms and conditions including the qualifying language "as soon as practicable.,,20 In some instances, the "as soon as practicable" language is rendered enforceable because it is followed by language establishing a specific deadline (e.g., "but within ten (10) 18 40 C.F.R. §§ 52.21(b)(4), 51.165(a)(1)(iii), 51.166(b)(4) (emphasis added), see also, substantially similar definition of potential to emit at 45 CSR 13-2.19. 19 U.S. EPA, Limiting Potential to Emit (PTE) in New Source Review (NSR) Permitting available at http://www.epa.gov/reg3artd/permitting/limitPTEmmo.htm; see also us. v. Louisiana-Pacific Corp., 682 F. Supp. 1122 (D. Colo. Oct. 30, 1987) & 682 F. Supp. 1141 (D. Colo. Mar. 22,1988). 20 WVDEP, Draft G80-A, Conditions 3.2.7 at 12, 4.1.1 at 15, 5.1.3 at 17,6.5.1 & 4at 22,8.1.1 at 23, 8.2.2.ii at 27, 8.2.3.ii at 28, 8.5.1-4 at 31-32,9.5.1 at 33; for additional discussion of enforceable permit requirements, see e.g., USEPA, Guidelines: Practical Enforceability available at: http://www.epa.gov/region9/air/permitltitlevguidelines/practical-enforceability.pdf 7 -313- calendar days,,).21 However, several conditions using the "as soon as practicable" language are not accompanied by language setting an absolute deadline.22 In the latter cases, an absolute deadline should be added or the permit condition should otherwise be altered to render it enforceable. 9. DEP should implement the additional measures recommended by Dr. McCawley of the WVU School of Public Health. DEP has statutory authority to undertake additional rulemaking with regard to Marcellus Shale and other horizontal oil and gas well drilling, pursuant to the J-Iorizontal Well Act, particular with regard to air quality. W.Va. Code §22-6A-22. '~Air quality study and rule making" provides that, The secretary shall, by July 1, 2013, report to the Legislature on the need, if any, for further regulation of air pollution occurring from well sites, including the possible health impacts, the need for air quality inspections during drilling, the need for inspections of compressors, pits and impoundments, and any other potential air quality impacts that could be generated from this type of drilling activity that could harm human health or the environment. If he or she finds that specialized permit conditions are necessary, the secretary shall promulgate legislative rules establishing these new requirements. That report was done. The West Virginia Surface Owner's Rights Organization appeared at the public hearing on this general permit and spoke in more detail on this matter and submitted a copy of the report by Dr. McCawley of the WVU School of Public Health. His recommendation to the Legislature was that monitoring of parameters should be required at the boundary of natural gas operations or at a nearby residence chosen based on distance, topography and prevailing wind. If monitoring results exceeded acceptable levels, additional actions by the driller should be required. More particularly: The operator shall set up continuous real-time monitoring of air (and noise), and dust and particulates at the residence or 21 22 See e.g.,ld. conditions 5.1.3 at 17,6.5.1 & 4 at 22 8.5.1-4 at 31-32, 9.5.1 at 33. See e.g., ld. conditions 3.2,7 at 12,4.1.1 at 15, 8.1.1 at 23, 8.2.2.ii at 27 (leaks), 8.2.3.ii at 28. 8 -314- other point of impact that is closest or most likely to be impacted by the well work, including traffic associated with the site. The operator shall continuously monitor those parameters in real time. If there is a 5% chance or greater that the monitored levels could exceed any of the required parameters as determined by continuous process control analysis during any running twenty four hour averaging period, the operator shall implement the best available control technology available to limit the levels. The monitored levels need to be continuously available by wireless or other transmission to those persons or entities within fifteen hundred feet of the limit of disturbance who request it. When levels exceed parameters, alerts shall be sent to those persons or entities. The data shall be available to the public for study. Unless altered by legislative rule, the parameters shall be: (1) for noise during site construction, 70 elBA average an hour. (2) for noise at all other times, 55 dBA at any time. (3) for dust,the national ambient air quality standard level for a twenty-four hour period and no visible dust on residences or crops. (4) for air, the Minimal Risk Levels for chronic (365 days or more) exposure to organic compounds set by the Agency for Toxic Substances and Disease Registry of the Centers for Disease Control and Prevention of the United States Department of Health and Human Services. If, after completion of well work, production or production facilities cause a violation of the standards set out in subsection (b) at a residence, then the operator shall implement the best available control technology available to limit the levels that violate the standards. The DEP, either as part of this general permit or as rule making, should carry out those recommendations. 9 -315- § 68 NOISE CONTROL CHAPTER 68 NOISE CONTROL § 68-1. Short Title. § 68-2. Policy. § 68-3. Purposes. § 68-4. Authority. § 68-5. Performance Standards. § 68-6. Definitions. § 68-7. Unreasonable Noise Prohibited. § 68-8. Maximum permissible continuous sound levels. § 68-9. Exceptions. §68-10. Enforcement and administration. § 68-11. Temporary License. § 68-12. Special Permit. § 68-13. Severability. § 68-14. Effective Date. [History: Adopted on 6-2-2010 as LL #4-2010J 6801 -316- § 68 § 68-1 NOISE CONTROL §68-5 § 68-1. Short Title. This chapter shall be known and may be cited as the itTown of Windsor Noise Control Local Law.It § 68-2. Policy. This chapter shall be liberally construed so as to effectuate the purposes described in this chapter. Nothing herein shall abridge the powers and responsibilities of any Police Department or law enforcement agency or code enforcement department to enforce the provisions of this chapter. Nothing herein shall be construed to abridge the emergency powers of any Health Department or code enforcement department or any such departments or agencies to engage in any necessary or proper activities. § 68-3. Purposes. The purpose of this chapter is to protect the public health, welfare, safety, peace and tranquility of the residents of the Town of Windsor by regulating noise levels. § 684. Authority. In accordance with Article 10 of the Municipal Home Rule Law of the State of New York, the Town Board of the Town of Windsor has the authority to enact local laws and amend local laws and for the purpose of promoting the health, safety or general welfare of the Town of Windsor and for the protection and enhancement of its environment. The Town Board of the Town of Windsor may include in any such local law provisions for the appointment of any municipal officer, employees, or independent contractor to effectuate, administer and enforce such local law. § 68-5. Performance Standards. Property within the geographical boundaries of the Town of Windsor shall be utilized within the limits specified as follows as safeguards and conditions for the protection of the community welfare. Standard methods of collection, measurement and chemical analysis or any method approved by the Town of Windsor, United States Bureau of Standatds and Broome County Health Department shall be used in the application of these standards. 6802 -317- § 68-6 NOISE CONTROL §68-6 § 68-6. Definitions. A. All terminology defmed herein which relates to the nature of sound and the mechanical detection and recording of sound is in conformance with the terminology of the American National Standards Institute (ANSI) or its successor body. !L As used in this chapter, the following terms shall have the meanings indicated: AMBIENT NOISE- The all-encompassing noise associated with a given environment, being usually a composite of sounds from many sources. The calculation or measurement of ambient noise shall subtract any or all noise or sound generated by properties or uses that have been issued a special permit, as prescribed herein. A-WEIGHTED SOUND LEVEL- The sound-pressure level in decibels as measured on a sound level meter using the A-weighted network. The level so read is designated "dBA." CONTINUOUS SOUND- Any sound that is not impulse sound dBA, the abbreviation designating the unit of sound as measured by a decibel level meter using A-weighting, also known as "dB(A)." dBA- The abbreviation designating the unit of sound level as measured by a sound level meter using the A-weighting, also known as "dBA." All references to "decibel" or "dB" shall be presumed to mean "dBA" unless otherwise specified. DECIBEL- The practical unit of measurement for sound pressure level. The number of decibels of a measured sound is equal to 20 times the logarithm: to the base 10 of the ratio of the sound pressure of the measured sound to the sound pressure ofa standard sound (20 micropascals), abbreviated "dB." EMERGENCY-Any occurrence or circumstances involving actual or imminent physical or property damage which demands immediate action. FREQUENCY- The number of sound pressure oscillations per second, expressed in hertz, abbreviated "Hz." IMPULSE SOUND- Sound characterized by either a single pressure peak or a single burst (multiple pressure peaks) having duration of less than one second. NOISE- Any sounds of such level and duration as to be or tend to be injurious to human health or welfare, or which would un:reasonably interfere with the enjoyment oflife or property within the Town. PEAK SOUND PRESSURE LEVEL- Maximum absolute value of instantaneous sound pressure level during a specific time interval. PERsON- Any individual, association, partnership, corporation or other entity and includes any officer, employee, department or agency of the person. REAL PROPERTY LINE- Either: Ql The imaginary line, inCluding its vertical extension, that separates one parcel of real property from another; or The vertical and horizontal boundaries of a dwelling unit that is one in a multi-dwelling-unit building. SOUND- An oscillation in pres.sure, particle displacement, particle velocity or other physical parameter, in a mediUm with internal forces that causes compression and rarefaction of that medium. The 6803 m -318- §68-6 NOISE CONTROL § 68-8 description of sound may include any characteristic of such sound, including duration, intensity and frequency. SOUND LEVEL- The weighted sound pressure level obtained by the"use of a sound level meter and frequency weighting network, such as A, B, or C as specified in American National Standards Institute specifications for sound level meters (ANSI). If the frequency weighting employed is not indicated, the A-weighting shall apply. SOUND LEVEL METER- Any instrument, including a microphone, amplifier, an output ineter, and frequency weighting networks for the measurement of noise and sound levels in a specific manner and which complies with standards established by the American National Standards Institute (ANSI) specifications for sound level meters. SOUND PRESSURE LEVEL- The level of a sound measured in dB units with a sound level meter, which has a uniform (tlflat") response over the band of frequencies measured. SOUND SOURCE- Any person, animal, device, operation, process, activity, or phenomenon, which emits or causes sound. VIBRATION- An oscillatory motion of solid bodies of deterministic or random natures described by qisplacement, velocity or acceleration with respect to a given reference point. § 68-7. Unreasonable Noise Prohibited. No person shall make, cause, allow or permit to be made any unreasonable noise upon property, within the geographical boundaries of the Town of Windsor, except as otherwise provided herein. § 68-8. Maximum Permissible Continuous Sound Levels. The following general prohibitions regarding continuous sound levels shall apply in determining unreasonable noise. Noise shall be measured as follows: A. The measurement of sound or noise shall be made with a sound level meter meeting the standards" prescribed by the American National Standards Institute. B. The slow meter response of the sound level meter shall be used in order to best determine that the average amplitude has not exceeded the limiting noise level. C. Measurement of noise levels shall be made at or beyond the property line of the property on which such noise is generated or perceived, as appropriate, and shall be taken at least four feet from ground level. D. Compliance with the noise limits shall be maintained at all elevations at the boundary ofthe property. E. Daytime hours shall be between 7:00 a.m. and 10:00 p.m. Nighttime hours shall be between 10:00 p.m. and 7:00 a.m. 6804 -319- §68-8 NOISE CONTROL § 68-9 F. The maximum permitted noise or sound levels on property, within the geographical boundaries of the Town of Windsor are: During daytime hours: ambient noise levels plus five (5) dBA. During nighttime hours: ambient noise levels plus three (3) dBA. Additionally, until demonstrated by the applicant or by the Town, ambient noise or sound levels within the Town of Windsor shall be assumed to be 35 dBA. However, in no event shall the allowed noise or sound levels on the property exceed 55 dBA, unless as allowed via a Special Permit. Moreover, noise levels shall be measured as described in this section. § 68-9. Exceptions. The provisions of this law shall not apply to: ill.. Sounds and vibrations emitted for the purpose of alerting people in emergencies. m Sounds created by bells or chimes of religious institutions. m Sounds created by any governmental entity, their agents, employees or contractors in the course of its duties (fire districts" towns, villages, counties, schools, police agencies, etc.). ffi Noise from burglar alarms of any building or motor vehicle. (2l. Noise from lawn mowers and related lawn equipment, snowblowers, and snowplows, if working within the parameters as set forth by the Manufacturer. !§l. Noise typically associated with residential uses (e.g., air conditioners in good working order, swimming pool filter motors, etc.). ffi Noise created by the normal operation of public and private schools, typically consisting of classes and other school-sponsored activities. (8) Noise generated by municipally sponsored concerts and special events. 00.. ~oise generated by charitable organizations under the New York State Not-for-Profit Corporation Law. (10) Noise generated by volunteer fire companies in the performance oftheir duties, drills, and public demonstrations. LUl. Noise allowed, pursu~t to this chapter by Special Permit issued by the Town Board of the Town of Windsor or by temporary license issue by the Town Clerk of the Town of Windsor; @Noise due to emergency repairs, where the repairs are necessary due to actual or imminent physical or property damage which demands immediate action. (13) Sound from a farm, as defined in Section 93-4 or within an Agricultural District Designation that result from construction, repair, day to day activities, and/or emergency work that is done in the 6805 -320- § 68-9 NOISE CONTROL § 68-10 pursuit of farming. (14) Noise from emergency generators used during power outages. (15) Construction or modification of a single or two family house or its accessory structure(s) where one of the following has been granted: a Building Permit, Site Plait approval, Broome County Health Department approval, a Driveway Permit from the Town of Windsor Highway Department and/or where the construction or modification of a single or two family house or its accessory structure(s) will be completed within seven (7) calendar days. § 68-10. Enforcement and Administration. The noise control requirements established herein shall be administered and jointly enforced by the Town enforcement officers and the police agencies of Broome County or officials authorized by the Town Board of the Town of Windsor. Violations maybe established upon verbal or written complaint by at least one person, including the enforcement officer. A. Compliance orders. The Code Enforcement Officer is authorized to order in writing the remedying of any condition or activity found to exist in this chapter. Upon finding that any such condition or activity exists, the Code Enforcement Officer shall issue a compliance order. If the condition or activity is not remedied after the issuance of the compliance order, then an appearance ticket may be issued as provided hereinafter. . B. Appearance tickets. The Code Enforcement Officer and each inspector are authorized to issue appearance tickets for any violation ofthe chapter; C. Penalties for offenses. Any person who violates any provision of this chapter shall be deemed guilty ofa violation and, upon conviction thereof, shall be subject to penalties in a fine of not less than $50 and not more than $250. D. In addition to those penalties prescribed herein, any person who violates any provision of this chapter shall be liable for a civil penalty of not more than $3,000 for each day or part therefore during which such violation continues. The civil penalties provide by this subsection shall be recoverable in an action instituted in the name of the Town. E. If the violation is of a continuing nature, each eight-hour period during which it occurs shall constitute an additional, separate and distinct offense. F. Injunctive relief. An action or proceeding may be instituted in the name of the Town, in a court of competent jurisdiction, to prevent, restrain, enjoin, correct, or abate any violation of, or to enforce any provision of this chapter. In particular, but not by way of limitation, where there is an violation of this chapter, an action or proceeding may be commenced in the name of the Town, in the Supreme Court or 6806 -321- § 68-10 NOISE CONTROL § 68-11 in any other court.having the requisite jurisdiction, to obtain an order directing abatement of the condition in violation of such provisions. No action or proceeding described in this subsection shall be commenced without the appropriate authorization from the Town Board of the Town. G. Remedies not exclusive. No remedy or penalty specified in this section shall be the exclusive remedy or penalty available to address any violation described in this chapter. Any remedy or penalty specified in this section may be pursued at any time, whether prior to, simultaneously with, or after the pursuit of any other remedy or penalty specified in this section. H. In addition to the above-provided remedies, the Town Board may also seek reimbursement to the Town for costs incurred by the Town in identifying and remedying each violation, including but not limited to reasonable attorney's fees. § 68-11. Temporary License. A. Application for a temporary license. The Town Clerk shall have the authority to grant temporary licenses for limited times and purposes ofthis chapter. Any person seeking a temporary license pursuant to this section shall file an application with the Town Clerk. The application shall consist of a letter signed by the applicant and shall contain a legal form of verification. Such letter shall contain information, which demonstrates that bringing the source of sound or activity for which the permit is sought into compliance with this chapter would constitute an unreasonable hardship on the applicant, on the community or on other persons. In addition, the following information shall be provided: (1) The plans, specifications and any other information pertinent to the source of sound and vibration. (2) The characteristics of the sound and vibration entitled by the source, including but not limited to the sound levels, the presence of impulse sounds or discrete (pure) tones, the day(s) and hours during which such vibration and sound is generated. (3) The noise abatement and control methods used to restrict the emissions of the sound and vibration. (4) A time schedule for the installation of noise abatement and control devices, technology and procedures or process modifications that will be followed to restrict the emissions of sounds and vibrations. (5) The name and address of the applicant and the applicant's agent, if any, and whether the applicant is the owner, lessee, licensee, etc., of the premises. If the applicant is not the owner, the application must contain the written consent of the owner. (6) A filing fee as set by the Town Board, from time to time, via a Resolution. (7) The requested duration of the permit. (8) The hours and days of operation and maintenance. B. Decision. 6807 -322- § 68-11 NOISE CONTROL § 68-12 (1) Upon receipt by the Town Clerk of all information required for the granting of the temporary license, and upon receipt of the appropriate filing fee, the Town Clerk shall issue or deny the temporary license. (2) The Town Clerk shall not issue the temporary license if the requested duration of the permit is in excess of three days. . (3) If the Town Clerk denies the application for a temporary license for any reason, the applicant may apply to the Town Board for a Special Permit, following the procedure established below. (4) If the Town Clerk issues a temporary license pursuant to this provision, the temporary license shall be valid for the time requested, but shall be rendered invalid if the actual source of sound authorized under the issued permit, as measured by an enforcement officer, causes a continuous noise level in excess of 80 dB(A) across any real property boundary. § 68-12. Special Permit A. Any person seeking a Special Permit from the Town Board pursuant to this section shall file an application with the Town Clerk. The Special Permit, if granted~ shall be valid for a term of 5 years. B. The application shall consist of a letter signed by the applicant and shall contain a legal form of verification. Such letter shall contain information, which demonstrates that bringing the source of soUnd or activity for which the Special Permit is sought into compliance with this chapter would constitute an unreasonable hardship of the applicant, on the community or on other persons. In addition, the following information shall be provided: (1) The plans, specifications and any other information pertinent to the source of sound and vibration. (2) The characteristics of the sound and vibration emitted by the source, including but not limited to the sound levels, the presence of impulse sounds or discrete (pure) tones, the day(s) and hours during which such vibration and sound is generated. (3) The name and address of the applicant and the applicant's agent, if any, and whether the applicant is the owner, lessee, licensee, etc., of the premises. If the applicant is not the owner, the application must contain the written consent of the owner. (4) The names and addresses of all owners of contiguous land within 500 feet of the premises. A filing fee as set by the Town Board, from time to time, via a Resolution. (5) (6) The requested duration of the Special Permit. (7) Certification that there are no zoning or uniform code violations on the property. (8) The hours and days of operation and maintenance for the activity causing the noise or 6808 -323- § 68-12 NOISE CONTROL §6842 sound. (9) A Noise Management Plan, the goal o.fwhich is to mitigate noise levels and keep the noise levels as low as possible. Such NMP shall include: a) Identification of noise sources; b) Assessment of current and available noise mitigation programs; c) Method of noise measurement; d) Best practices programs; and e) Continuous improvement programs. C. Public hearing. Upon prior reasonable public notice published in the official newspaper of the Town,and upon a public notice board designated for that purpose by the Clerk for a minimum of 14 days, the Town Board shall hold a public hearing on the Special Permit application. The applicant in like manner shall give notice of the public hearing and application by certified mail, return receipt requested, to all property owners surrounding the sound source site within a radius 500 feet from the borders of said site. The notice to the neighbors shall be deposited in a mailbox at least 21 days prior to the public hearing date. The applicant shall provide an affidavit of mailing, showing proof of mailing to the neighbors as required herein. The applicant's affidavit of mailing shall become part of the application. Failure to provide notice to the neighbors shall result is automatic denial of the application. D. Applicant to obtain other necessary permits or variances. This chapter does not preclude the necessity of the applicant to obtain any other approval, permit or variances as required by any other agency or local law before proceeding with an application for a Special Permit. The application for a Special Permit may not be initiated by the applicant until such time that other permits or variances, as may be required, are issued. E. Decision (l)In determining whether to grant or deny the application, the Town Board shall apply the following balancing test: a)The use possesses characteristics of unique and special form to warrant its consideration as an individual case. b) The location, size of the use and structure, nature and intensity of the operations involved, size of the site in relation to it and the location of the site with respect to the streets giving access to it are such that it will be in harmony with the orderly development of the district. c) The proposed Special Permit will not have an adverse effect or impact on the physical or environmental conditions in the neighborhood or district; including but not limited to odor, light, traffic, etc. d) The use shall not conflict with any Master Plan or part thereof. e) The relief granted must be the minimum required to achieve the use. Best practices as to noise management and operating procedures shall be taken into account when determining what 6809 -324- § 68-12 NOISE CONTROL § 68-12 constitutes the minimum required to achieve the use. Noise management considerations should include but is not limited to, mufflers, enclosed buildings, burms, noise barriers, noise insulation, alignment, etc. (2) The Town Board may consider other factors including, butnot limited to the following: a) The sound level of the noise; b) The frequency of the noise; c) Whether the noise is unusual and incongruous with the surrounding environment; d) The sound level and frequency of the ambient noise, if any; e) The use, nature and character of the zoning district of the immediate area where the noise source exists;_ f) The time of day or night the noise occurs; g) The duration of the noise; h)The intensity of the noise; i) Whether the origin of the noise is associated with nature or with human-made activity, j) The existence of complaints concerning the noise from persons living or working in different places or premises who are affected by the noise and k) Seasonal and prevailing weather; including wind, precipitation and tree cover. (3) In connection with this section, the Town Board may cause the taking of sound level readings in the event that there shall be any dispute as to the sound levels. (4) The Town Board shall have the power to impose restrictions, conditions and the recording of covenants upon any sound source site, including time limits on permitted activity in the event that it shall grant any Special Permit hereunder. (5) The Town Board shall comply with the State Environmental Quality Review Act. If such a SEQRA review is necessary, the Town Board shall be lead agency in that SEQRA review. (6) The Board, upon reviewing all input from the public hearing and obtaining any additional data or information as deemed necessary, shall then pass or deny the application by resolution. The decision shall be transmitted to the Clerk, who will advise the applicant of such decision by transmitting a copy of the Special Permit application to the applicant, with the decision and conditions, if any, imposed by the Town Board attached. F. Transferability and expiration of Special Permit A Special Permit is not transferable except upon approval by resolution by the Town Board. A Special Permit shall authorize only one use and shall expire if the use ceases for more than three months for any reason. Changes or modifications to the use, including but not limited to changes in noise levels, shall void the 6810 -325- § 68-12 NOISE CONTROL § 68-12 Special Permit. Changes or modifications to the use requires a new application pursuant to this Chapter. The Town Board may revoke the Special Permit at any time if the permit holder fails to comply with any section of this chapter or condition of the Special Permit. G. The applicant or his agent shall have readily available the approved Special Permit at the location or site for which the Special Permit has been issued and shall show same to any agent of the Town whenever requested. H. Activity open to inspection. Activity conducted under the Special Permit shall be open to inspection at anytime by any agent of the Town. I. Request for Recertification of the Special Permit (1) The Special Permit, if granted, shall need to be recertified prior to the five-year anniversary date of the original grant and every five years thereafter. The holder of the Special Permit shall submit a signed written request to the Town Board for recertification between 12 months and 6 months prior to each five-year anniversary date. The application shall include all the information required for the original submission requesting the Special Permit with the additional information: a) The date ofthe original granting of the Special Permit; b) A statement that use is in compliance with the Special Permit and is in compliance with all applicable statutes, laws, local laws, ordinances, codes, rules and regulations. c) Whether the use has been moved, relocated, rebuilt, repaired or otherwise modified since the issuance of the Special Permit. 2) A filing fee as set by the Town Board, from time to time, via a Resolution. 3) The review shall be an administrative review, not requiring a public hearing or notice to the neighbors. 4) If, after such review, the Town Board determines that the use is in compliance with the Special Permit and all applicable statutes, laws, local laws, ordinances, codes, rules and regulations, then the Town Board shall issue a recertification of the Special Permit, which may include any new provisions or conditions that are mutually agreed upon, or required by applicable statutes, laws, local laws, ordinances, codes, rules and regulations. If, after such review, the Town Board determines that the use is not in compliance with the Special Permit and all applicable statutes, local laws, ordinances, codes, rules and regulations, then the Town Board may refuse to issue a recertification of the Special Permit, and in such event, such use shall not be used after the date that the applicant receives written notice of such decision by the Town 6811 -326- § 68-12 NOISE CONTROL § 68-13 Board. Any such decision shall be in writing and supported by substantial evidence contained in a written record. . 1. The Board may hire any consultant and/or expert necessary to assist the Town Board in reviewing and evaluating the application and any recertification. (1) The Town requires an applicant to deposit with the Town funds sufficient to reimburse the Town for all reasonable costs of consultant and expert evaluation and consultation to the Town Board in connection with the review of any application. The initial deposit shall be the sum of $5,000. However, the Town Board may, in its discretion reduce said fee upon good cause shown. These funds shall accompany the filing of an application and the Town shall maintain a separate escrow account for all such funds. The Town's consultants/experts shall, in accordance with an agreement between the Town and its.consultants or experts, bill or invoice the Town not less frequently than monthly for its services in reviewing the application and performing its duties. If at any time during the review process this escrow account has a balance that shall not reasonably cover the cost of the remaining work of the Town's consultants/experts, the Town will require applicant to immediately replenish said escrow account in an amount set by the Town, but not to exceed $2,500. Such additional escrow funds must be deposited with the Tqwn before any further action or consideration is taken on the application. If, at the conclusion of the review process, the cost of such conSUltant/expert services is more than the amount escrowed pursuant hereto, the applicant shall pay the difference to the Town prior to the issuance of any Special Pennit. In the event that the amount held in escrow by the Town is more than the amount of the actual billing or invoicing by the Town's consultants or experts, the difference shall be promptly refunded to the applicant. (2) . A request may be made by the applicant to reduce or eliminate the funds needed for the consultant/expert escrow. After a recommendation by the Attorney for the Town, Engineer for the Town and/or any other consultant/expert engaged by the Town pursuant to this chapter, the Town Board shall review the request and make a determination based upon the scope and complexity of the project, the completeness of the application and other information as may be needed by the Town Board or its consultant/expert to complete the necessary review and analysis. Additional escrow funds, as required and requested by the Town, shall be paid by the applicant. The initial amount of the escrow deposit may be established by Town Board upon receipt of information sufficient to make such a determination. K. Other costs. The applicant seeking the Special Pennit and/or Recertification must reimburse the Town all costs associated with the Special Permit, including the cost of the public hearing publication. Such reimbursement may be a condition of granting such Special Permit. § 68-13. Severability. If any clause, sentence, paragraph, section, or part of this locallaw shall be adjUdged by any 6812 -327- ,. § 68-13 NOISE CONTROL § 68-14 court of competent jurisdiction to be invalid, such judgment shall not affect, impair or invalidate the remainder thereof but shall be confined in its operation to the clause, sentence, paragraph, section, or part thereof directly involved in the controversy in which such judgment shall have been rendered. § 68-14. Effective Date. This local law shall take effect immediately upon filing with the Secretary of State of the State of New York. 6813 -328- ~' cJ9(J Sign-In Class II General Permit G35-C west virginia department of environmental protection Division of Air Quality DEP Headquarters, Charleston, West Virginia Page_ ! _or~ Tuesday, September 1, 2015 • 6-8 p.m. The Departrrient of Environmental Protection asks for the information below so that agency staff may provide responses and information about decisions to you. The information you voluntarily provide on this sheet becomes part of the public record related to this topic and may be released if requested under the Freedom of Information Act. '-frll. -1". ; ~ 1'1.l Organization Address Name Email Comment? (Yes/No) ~ Jv..lu... ~ %t~4~~ _ - ---- - - - - __'" 1 ~ ..: ~. ~~~~~~~~~~~~----~~--1--~--~~~------r-~~~~~~~~~~--~~~~~~ \C I 1\11"" 1. IfJ' ;\ ." 'T./,~,"'o .. ft @ '/ : ~ i",~ '::~~ tJ."~ ~ hoi. ~ ile:.JbW Uty,1r~r. ~:.fclt:;~ j ~ ~.;.~..:J ~'. dep Sign-In Class II General Permit G35-C west virginia department of environmental protection Division of Air Quality DEP Headquarters, Charleston, West Virginia Page-Lof~ Tuesday, September 1, 2015 • 6-8 p.m. The Department of Environmental Protection asks for the information below so that agency staff may provide responses and information about decisions to you. The information you voluntarily provide on this sheet becomes part of the public record related to this topic and may be released if requested under .the Freedom of Information Act. Name -\"). I ~ ~ = I Address Organization Email Comment? (Yes/No) General Permit G35-C Natural Gas Compressor and/or Dehydration Facilities west Virginia Division of Air Quality Jerry Williams, P.E. . dep What Is an Air Quality General Permit? General Permits under 45CSR13 authorize the construction, modification or relocation of a category of sources by the same owner or operator or involving the same or similar processes or pollutants upon the terms and conditions specified In the general permit. General Permit Benefits • Consistent reqUirements for all facilities covered by the General Permit • Facility specific information contained in the Registration • Class II General Permits • Applicants provide public notice wilen /he application Is submiHed (one comment period) • Timeframe is 45 days rrom the date a COMPLETE permit application is received vs. 90 days for 45CSR13 construction permits 1 -331- G35-C Development o o After review of the comments received on General Permit G80-A the decision was made to not issue General Permit G80-A in its current form. Instead, two (2) separate general permits will be utilized. • General Permit G70-8 will cover natural gas production facilities. Public comment period ended on August 26,2015. • General Permit G35-C will cover natural gas compressor and dehydration facilities. Public comment period will end on September t4, 2015. o . What is the purpose of General Permit G35-C? o o General Permit G35-C has been developed for natural gas compressor and/or dehydration facilities to contain the current requirements for this industry. After General Permit G35-C is issued, General Permits G30-0 and G35-A will continue to exist, however, there will be no future registrations, modifications, or administrative updates allowed to registrations issued under these permits. What is the purpose of General Permit G35·C? (cont'dJ o If a registrant wishes to change an existing registration under existing General Permits G30~O and G35-A it must be done so under General Permit ·G35-C or a 45CSR13 permit. • General Permit G33-C is not affected by this permitting action. 2 -332- General Permit G35-C Overview • Addresses the increased volume of permit applications • Permit term consistency • Incorporation by reference (NSPS, NESHAP) • Inclusion of language to address potential noise and light issues • No major sources • Establishes control device and capture efficiencies • Standardized forms to expedite application review General Permit G35-C Coverage • • • • • • • • • • Storage Vessels Small Heaters and Reboilers Pneumatic Controllers Centrifugal Compressors Reciprocating Compressors . Reciprocating Internal Combustion Engines (RICEs) (NG, Diesel, Propane) Generator Engines Truck Loading Glycol Dehydration Units Control Devices and Emission Reduction Devices General Permit G35-C Coverage (conl'dJ Control Devices and Emission Reduction Devices Included: • Completion Combustion Devices • Enclosed Combustion Devices and Flares • Closed Vent ·System Requirements • Carbon Adsorption Systems • CondenserslBTEX Eliminators • Vapor Recovery Units • NSCR, SCR, Catalytic Oxidation 3 -333- Public Notice Procedures • General Permit G35-C and all associated documents were posted to the DAQ website on August 14, 2015 and wfll remain throughout the public notice period • The public notices were published the week of August 10th • The public comment period ends on September 14, 2015 at 5:00 PM • Comments can be submitted via mail, fax or email • Emailed comments shall be sent to jerry.williams@wv.gov • Response to public comments Contact Information Jerry Williams, P.E. 304 926 0499, ext. 1223 jerry.williams@wv.gov WVOEP-DAQ 601 57th Street, SE Charleston, WV 25304 4 -334- napS:/ll 11..j l.lJj,j: lS44j/neWzware/nwcOIUlector.Jsp'tuserid=LURE .. Notice of Intent to Approve Class II General Pennlt G35-C ' Natural . for Gas Compressor PUBLISHER'S CERTIFICATE and/or Dehydration Facilities T~ West Virginia Departm~nt ~( " -, ,thO<.>o- E:o. .<. :. .:-J~tfa'"-'-±h. . . . . ,: of Environmental Protection · Division of PJr Quality (DAQ) is providing notice to the .general public of its Intent to ISsue a Class II General Permit lor the construction, modijication. relo-. cation DI and to prevent and control air pDllution IrDm the operatiDn of natural gas com~ pressor andlor dehydratio~ facilities pursuant to WV legiSlative.• Rule !'I5CSRI3. Gene~ Permit G35 C replaces pTe~­ ously noticed . General' Permit G35-B with the in!;lusion · .of. language to. addr~ss pDtentl!!1 noise Bnd .hght Issues. Th!S language .can be. found In . . Section 3.2.8. I, JJtt",-,. l. .Jl1......." . . . . VU =·:-- - - > Advertising Manager of 1HE EXPONENT TELEGRAM, a newspaper of general circulation published in the city of Clarksburg, County and state aforesaid, do hereby certify that the annexed: Notice oflntent to Approve Class II General Permit G35-C for was published in THE EXPONENT-TELEGRAM 1 time(s) commencing on 08/14/2015 and ending on 08/14/2015 at the request of General ,Permit G35-C is for natural gas cDmpressor andlor dehydration.fac!lities. Currently, General' ~ermKS G30-D and GaS-A cover natural gas compressor andlor dehydratipn' ~­ cillties, These General Permits will continue to exist. howevet•. there will be no future registratiDriS. modifications. Dr administrative updates allowed . to registrations . Issued. under these permits. If a regi~tr!!nt Wishes to lJl9(IiIy an eXIstiJ;!g ,regist[atiDn Under General Permits G30-D or G35-A, \I must be done so under General Permit G35-C. Provided that theappli<:ant can demonstrate compliance with the requirements. provisions, 'standards and conditions of this Class' II General Permit. the DAQ has determined that all state air qualitY requir&' ments will be met by any eligible natural gas cDmpressor and/or dehydratiDn' facilitieS. Any natural gas compressor and/or dehydratlpn facility granted Class II Genllr.il Permit registration by lIle Director shall ·nDt . have a ' potential to emit any criteria pollutant in an amount equal to or greater than . 100 tons per year or 10 tons per yea, Df any single· hazardousItoxic PDWutant or 2S. tons per year of any combinatiOn of hazardousltoxic pollutants ... The public may provide written CDmments regarding the DRAFT Class II General Permit G35-C to the Division of Air QUality via l1)ail. fait or email to the address below. A public meeting to provide inlormatlon on this permitting action wiN be held on September 1. 2.015. 2015 from ~:OO p.m. 8:00 p.m, at the West Virginia Department of EnVironmental Protee. tion office in Charieston. WV. Ail written coniments . must be receive.d by the DAQ before 5:00 p.O). on September 14. 20~ 5. Pnor.to talclng any final action on thiS permitting issue the DAQ will cDnsider Dnly those Written comments relev~t tD. ~i~ quality issues which thiS Divl~lOn has jUrisdiction. Such written comments must ~e received withln the spl!cified time frame and at the address ' . . below. lofl DEPT OF ENVIRONMENTAL PROTECT. Given under my hand this 08/18/15. The publisherls fee for said publication is: $100.24. '1··P(\;~.. ft @~~WI~U·'r.t·N.ro ·I·'ftRrvertising Manager of The Exponent-telegram '\Itq,,~ a~~~"W'J ~ in " bdOfruui~~ ati n:. · Subscribed to and sworn to before me this 08/18/15 My commission expires on The This n~tice prOvides an ~_ tUnlty for the public to review the 9RAFT Class " (3eneral Permit ~35-C and Engineering E~aluatlon. In the event you Wish to su!>lnit written comments. include your name a return address. and a dayti~e telephone number and indicate an~ organization DII behalf Df whlc~ your commentl! are submitted, .11\11 public comments ·are a part of the public record and are available fDr inspection by any interested party. : . Copies of this DRAFT Class Ii General . Permit.. Engillel!ring ~~aluation and this Notice nf . QQth day of f\1.x.L\jt)1G. 20 II 8/18/20159:54 AM -335- NoticeollntBntto ApproveClaasll General PermitG35-C for Natural Gas COrnpraasor anCVOr DehydrallonFaclli\leS, The West Virginia Department of Environmei'ltal Protection DIvIsion 01 AIr Quality (OAQ) IS providing notice to the general public of Its Intent to Issue a Class II General Permit for the con·, struction, modification, relocation 0/ and to pi9vent and,control air pollution from the operation of naturat gas coropresllOr and/or dehydration facilHles pursuant to WV· legislative RIlle 4SCSR13 Genaral Permit G35-C replaces ptevlously noticed Genaral Per.mit G3S-B with the Inclusion 0/ language to address potential noise and light Issues. This Iangu8gecan be found in Section 32.8. General Pel'll1it G35-C is for natural gas compressor and/or dehydration facilities. Currently, General PermItS G30' 0 lind G35-A cover naturaLgas compressOr andior dehydrati!li1 faCllli1es ,These General Permits will continue to e1Clst. hoWlMlr, there will be no future registrations, modifications, or,adminlslr!ltive updates al/OWed to registrations issued under these permits. If areglSlrant wishes to modity an existing registration under General Permtts G30-0 or G35-,(, 'i1 must be done so under General Perini\ G35-C. ' ProvIded thaI ~ app/i\:ant can demon8lrata compliance with ,the requirements, provisions, standards and conoitions ,of this Class II General Permit, theOAQ has' determined that alll!lale all' quality requirementS will,b.lt met by any elfgibl& ,natural gas co'n ipressor andlor dehydraMn 'acllitles Any mUural gas C9mpresSol' andlor dehydration iacdily granted Class" General PermH registration by the OiractC1r shall not have a potential to emit any·crneria pollutant Iii an amount equal to or greater than 100 tOns per yeao' Q( 10 IDnS per yearo!,any'single 1IazardouIII1oxic. polluiant or 2S tons per year of any COmbination 0/ hai8rd~'sItoxIc pollutants The public may provide ,wriltan comments regarc.llng the DRAFT Class II General Permit (;;'35-C to the Ollllsior, of Air 'Quarily via mail, fax or em&;11o the address below. Apublic meet- . ing to provide inftllniation on thj~ P'lnmlting Id party. Copies of this DRAFT Class II General Permit, Englneerllig Evaluation and this Notice of Intent to Approve are available for public review on the DAQ website at: http://www.dep.wv.gov/daqlPages/delault_dspx and at the followln~ location between the hours of 8'00 a m and 5:00 p.m. Mcmnay through Friday, holidays excluded, unless otherwise noted below: West Virginia Department of EnYlronmenta/ Protection Division of Air Qualitv 601 57th Street, SE Charleston, WV 25304 Contact: Jerry Williams, P E Phone: (304) 926-0499, ext. 1223 Fax: (304) 926-0478 Email: jerry.williams@wv.gov WC-8-12 12608 -338- WETZEL CHRONICLE New Martinsville, WV ... ~9d:. (i?:. . . . . . ,2015 State of West Virginia, County of Wetzel: Personally appeared before the undersigned, a Notary Public, _ _ _ _ _ _-"Bo!J.r.!..!iia!!..nwCo!Jll.!.!ulltte2Jrl---- who, being duly sworn, states that he is the manager of the Wetzel Chronicle, a weekly newspaper of general circulation, published at New Martinsville, County of Wetzel, State of West Virginia, and that a copy of the notice attached hereto was published for ....... .!.......... !2:.. . successive weeks in the Wetzel Chronicle, beginning on the .... daY ~~ ..., 2015 and ending on the .. ..!..?.~ ....day ~f ... ~,. 2fJ15. . of ... Manager, Wetzel Chronicle Subscribed and sworn to before me, a Notary Public of said County, on this ...... / ; ) , ........ day of .. ~ 2015. o.0.3./1))iJc. Nofa~ My commission expires on the 4th day of Janua . ~ Public 2016 . ~ OFfllCIAL SlW. NOTARY PUBUC STATE OF WEST VIRGINIA DIANNS.WRIGHT Printers Fee....................... ... ~ ..' was~ paper for ... ... . successive weeks beginning with the issue Of ...... / t:Iu 20lS and ~. If ..... ending with the issue of .> 2015 and CRS'I . .......... . t h at 511'd no t'Ice contains .115 WORD SPACE at .cenls a word 7 amounts to the sum of S . . . "' '" .7:." 1/ f)(;. .. . . FOR FIRST PUBLICATION, SECOND PUBLI{:ATION IS 75% OF TH E FIRST PUBLltATION aetion on Ihi. permitli., iiilue, Ihe DAQ will consid.r on1, Ibose wrillen commenl relevant 10 air qu.lity iSlu .. which tbis. DivisioD ·has jurisdiction. Suth wrilted mmments DlUII be RUWed WilhiD Ihe .pedfiat lime fame and iii Ihe .ddres. below. This notice pro.id.... opportunity for Ibe pablic to review Ihe DRAFf CI... II Gener.1 Permil G3!~ and Enain.ering EVllualion. In lb...eal you ~"h to lubm.1 wrilten comDl~ntll indude. Y0l:lr name, B',relum addrul t and • da,ylirae telephone nu ....~er .n~ indicate la7 oQlllnizlitioD on .behalf of which your cammenll ... lubmitle6. AlI.pablic comnient> .re • part or lb. public ..cord aad a ...ya.lable for inljlection by any i.terated pal1)'. . . .. .-() s and each publication thereafter 7.. 'l.f, R.7. .......... . S ... . Copi•• of Ihi. DRAFT 0 ... Ii Gcneral Permll. EnlineerlDl Evalualion Rnd tbis Notice or I_tent 10 Approve an IVRIIabie ror public re,view on the DAQ . webliteal' .llp:/"""..... d.p.wv.gOv!daqlP.gwd.....ult.asl!! and al the following localion betw..a Ibe hours or ':00 a.m. and 5:00 p.m. MODday Ihrough Friday. holidays excluded, unltl...therwise noled tiela",! Wcsl Virtlinia D.partmenl of [nvifODme.lol Protec:tion Division of Air Qual.ty &ns7'" Streel, SE CharicstOD, WV l!l304 Coalacl: J.rry Wllliaml, P.E. Phon., (304) 926·0499, "I. 1113 F.. , (304) 926-047. Em.il: ierry.williams@wv.lov 4-1I-"b . . . . .. . . TOTAL EDITOR ~r-'; , .. ~l ~.i..J.A" .:U~~ .. rWf":r.~.~. SWORN TO AND SUBSCRIBED ·ru BEFORE ME THIS THE OF ...... NOTARY ., I. ..- "I PU~~WrtG - - -WE * f , +0..;, * --/".,.(' . ~"'I 'r.."~" t. ....- -........'&11'...... OFFICIAL SEAL NOTARY PUBLIC STATEOI'~E~:rVlRaINIA ROBERT I::. BURNSIDE J 100 SCHOOL ST. WESrUNION. 2~456 My cDmmis~iofl expires May 16. 2019 ) ~---... -340- 2015 ....................... ~ . . 1. i AAy..z{. . . . . . ... . .. .... DAr wv - - . -...$1 , STATE OF WEST VIRGINIA, COUNTY OF OHIO. I ~ for the publisher oft ntelligencer newspaper published in the CITY OF WHEEliNG. STATE OF WEST VIRGINIA. hereby certify that the annexed publication was inserted in said newspaper o~n the foll~wing dates: _~ _. /4I 8t11$ Given under ~ this. ~1Jc do.yo/ 19#J of, in and for OHIO COUNTY, WEST VIRGINIA. My Commission expires ~ 0; c?()Ii ... -.- ,.----. --I ,,',. , -, ·Z~;"'-' L 2R 8 . .; • J ~. U • OFFICIALSEAl NOTMV PUBlIC STATE OF WEST VIRGINIA CRYSTAL COFFIELD 488 BenWOod Hill Roacr Benwood. Wesl Virginia 280 - My CommisSIon Ellpires May 5, :18 ~. -341- ,".!' , STATE OF WEST VIRGINIA, COUNTY OF OHIO. I oft for the publisher nteUigencer newspaper published in the CITY OF WHEELING, STATE OF WEST VIRGINIA, hereby certify that the annexed publication was inserted in said newspaper 0 G the foll~win8 n ~es: _~ 14·( atJ/~ Given under ~is ~ day of d subscribed before me this /CJ.iAJ ~~~o<:.L.L..:=:...:.-_cfl()rr-;;WHEELING, a~ · ~~NO"'"uld Public of, in and for OHIO COUNTY, WEST VIRGINIA. . "'Yl1l/1d 4 5; c?() Ii .. My Comrmsslon explres-JY!!Aif-L-....!.....~+f----'---"-----,. ,- --- -/ ' 1" 2 6~2;'i;--- 1 . -' ,'- i OFFICIAL SI:AL ", , '" • ~ ' , J •" ~". ... . NOTARY PUBLIC STATE OF WEST VIRGINIA CRYSTAL COFFIeLD 488 BanWOOd Hill Road 1Ienwood. Wasl Virginia 2eo31 My CommissIon Expires May 5,2018 -342- ~ teria pollutant In an amount equal to or greater.than 100 tons per year or 10 tons per y., . of any single . NotIce of Intent to ApproveC/asa II General Permit G35-C for Natural Gas I 'I, 11~f'; The pub/Ie may p~vIda , writt8n comments ra: garding the DRAFT Cia.. " General Pennit G35-C to the Dliliaion of AIr 1 I I This is to certify the annexed advertisement WV DEP/DIV AIR QUALITY NOTICE Quality via mai~. fax or 8lll!l1I to the address · belOW. , A public meeting toprovlda IliforniatJon on thIs Pennlttlng acticm , wUl be heJdon Sep- appeared for ~ber1,2015,2015 from 6:00 p.m. - 8:00 p.m. ilJthe West Virginia nant to WV Legisl8tJve consecutive days/weeks in The Journal Publishing Company, a news- Dapal1mentof EilVironmental Protection office , In Chaiteston, WV. Ail written comments must be receIved by the DAQ , Rule 45CSR13. General Permit G~ replaces , previously noticed General Permit G:J5,B with, 1 paper in the City of Martinsburg, WV in it's issue beginning: befQre5:OO p.1IL CIItSep- the. : JnCJWlion of language to _ber1" 2015. Prior anv final don on this pennjtJing issue, the DAQ win consider only written CQmriIenta relevant to.aIr qualItY Issues whIch this Division hB8junsdlCtJon. , SUch Writtencomnients must be received wtthln the specified time frame and at the acldrass addreas potiIntiai noise. , and .1f9ht Issues. 111ls language can be found In . , SectIon 3.2JI. , I to taking 8-147"15 and ending those Gen8raI Pennit G35-C Is for natural gas camp,,", -sor andIor dehydration faeilitles. CUrrently, Genera/Pennits G30-D and G35-A Qover natural gas eomPressor andlor . dehydration facilities. These General Perrnttil will continue to eXIst, how_, there wiD be no futureregiatrations, .. modHlCliUons, or ad.mlnl81rativeupdates allowed to tegistrations is- · lUed under these permits. If a registrant wishes to modify an exIatlng registration under ' . General Pennits G3O-D or G35-~ It must be ,done so under General Permit G35-C. 8-14-15 The Journal 207W. King Street below. 111/8 notlceprovldeailn opportunity lor the public to review the DRAFT Class J1Ge/:1eraJ Permit ~ and ErigJnesnng Evaltllltion. In the event you wish to submit written Conimente, Incillde your name, • relUm addraaa, and a daytime telephone number and indic:ate sny organi28tion on behaJf of which your comments are submitted. All publIc comments are a,pjIIt of the pubUc 'n!COrd and are available for Inspection by any In- .fIrovided that tl!e IIppllcantean demon. . . . COInpilanee wtth the requIrements, provi- Martinsburg, WV 25401 Fee ($) THE STATE OF WEST VIRGINIA COUNTY OF BERKELEY The foregoing instrument was acknowledged . tIIrested party. sions, standards and condItIOns of 1h/s Class II General Pennlt, the DAQ has determined that , • all state &ir qll8ljty re'i qulraments will be met by Sny , eligible natural gas compressorandlor dehydration faellities. Any natural gas comprtI8or andlor dehydration facility grantad Class II General Pennlt regIstration by the Dirac- I before me thls · Copies of thisDRAFr Class /I General Pennlt, EngI..-rlng EvalusUon and this Notlee of Intent to Approve are available for public . review on the DAQ· , website at: hIfp;IAnrw dep:wv,govI ~.1J6PK [f"'~-+dasby QCNV\OA IYhl..UD My commission expires ~..21' C?o /I:> ~ and st the fOllowing loc:atJo.n between the hOllrll of 8:00 a.m. and - 5.:00 p.m. Monday , through Friday, holidays excl"ded, unless 0therwise noted below: =of west Virginia , Environmental , , Division of Air Ouaity 601 57111 SIreet. SE Charfestpn, 'NY 25304 ConJact Jeny WIMiiIs, P.E. Phone: 13041 !I2&Oc99, axt. 1223 fix: 13041 926-4478 Email: jeny,wi!iams@wv.gov 8:14 '109.43 (1t) -343- . ./ " :/ , pollutants. Department of Environmental Protec:tion Division' of . Air Quality (DAQ) Is pro- i v1ding notiee to the gen- , era! publle of its 'j Intent to issile a Class II , General Pennlt for the i eonstruc:tion, mocfifiea- I tlon, reJoc:atlon of and to pravent and contrOl air ' pollution from the operation of natural, gas compiessor IInd1ordehyi:JraUon 'faeilities pur- : '·,'W' '{ 1<.. .iI'~ ". )" I .) _ or 25 tons per yurof , any combination of . , hazardous/toxic The West Virginia :.~ ' ~EP/OIVOFAJijQ hazardo~xlc pollutant Compressor a!1dlor Dehydration Faellities . 0 re©~nt\nlll@ .~ \'!f -- ' I • I.E. '.. ,,. , tor shall not have a p0tential to emit sny cri- !j I The public may provide written comments regard. 1119 the DRAFT CI.oss Ii General Permit G350-C to the DiviSion of Air Quality via mail, fax or email ta the addresS below. ApubI lic meeting to provide information on this permitting action will be held on September 1,'lO15, 2015 from 6:00 p.m. - 8:00 p.m. '1t the West Virginia Department of Environmental Protection office In Charleston, WV. All written comments must be received by the DAQ before 5:00 p.m. on September 14, 2015. Prior to . taking any final action on this permitting Issue, the DAQ will consider only those written comments relevant to air qualItY Issues which this Division has jurISdiction. Such written comments must be received within the specIfied time frame and at the address below. NatIce of Intent ta ApPl'Dve t lass II GeneI'D;' Permit G35-CfDr Nalural Gas ComPr'tSSOI' ancl/af Dehydration Facilities : The West Virginia De,.,artment of Environmen- tal Protection Division of Air G1uality (DAQ) Isprovldlng notice to the general public of .ifs intent fo Issue a Class Ii General Permit for the construction, modification, relocation of and to prevent and control air pollution from the aperatlan of natural gas compressOr and/Or dehydratloh facilities pursuant to WV Legislative Rule 45CSR13. General Permit G3S-C · · replaces previously noticlRl Gener" 01 Permit G3S-B with the Inclusion of language to address pOtential noise and light IssUes. This Ianliyage can be found in Sec- ,. .," I tion 3.2,8. . . . .. .... . This notice provides an OPPBrfunltY for the public to revieW the DRAFT Class II General Permit G35-C and Engineering Evaluation. In ·the event YOU Wish to submit written comments, Include your nalfie, a return address, and a daytlm.e telephone number and Indicate.. any organization on behalf of which your comments are submitted. All pUblic comments are a part of the public record and are available for inspection by any Interested party. .. . General Permit G35-C is for natural gaS compressor dnd/or dehydration facilities. Currently, General Permits G3G-D andG350A cover natural .gaS compressor and/or dehydration facilities. These Gen' eral Permits will continue to exist, however, there will be no future registrations, modifications, or administrative updates allowed to registrations Issued under these permits. If a registrant wishes to modlty an existlllll registration under General Permits G30-D or G3S-A, it must be done so under General Permit G3S-C. Provided that the applicant can demonstrate compliance with the re'qul,-en,ents, pravisions, standards and conditions of this .Class I I General Permit, the DAQ has determined that all state air quality requirements will be met by any eligible natural gas compressor and/Or dehydration facilities. Any natural gas compressor and/or dehydration facility granted Class II General Permit registration by the Dlractor shall not have a potential to emit any criteria pollutant In an amount equal to or greater than 100 tons per year or 10 tons per year of any single hazardou!/lOxlc pollutant ·or 25 tons per year of any of combinatlan hazardous/toxic pollutants. Copies of this DRAFT Class II General Permit, Engineering Evaluation and this Notice of I ntent to Approve are available for public review on the DAQ website at: http ://www .dep.wv.gOv/ da.i~ 08/14 . AD 'r:&~ LEG PUB :O'lll~tC,inF1IQN '.' :~i!'E$$1ll't'JE' Nim P~CHA$E ORDll:~ # An NllIMImR f--~ ~n>l:~ 1X1400 14.00 0606700 GZ 8/14 NEW G35-C NOTIC 962650001 RATE TOTAL Rtml· GRGSS 17.01 ~MOi:MJ.' 238.14 NET AMOUNT' 238.14 '.\ TOTAL INVOICE AMOUNT 23 8.14 FIDAVIT OF PUBLICATION 1 .--f!-:. 11 I'~L-~__________________~~~~~~~L- I OFFICIAL SEAL NOTARY PUBLIC of STATE OF WEST VIRGINIA MARY C. SMITH CHARLESTON GAZETTE 871 SOUTH WASHINGTON ST. ST. ALBANS, WV 25171 My C<0mmisslon expires June 16, 2019 do solemnly swear that the legal notice of: 8/14 NEW G35-C NOTICE was duly published in said newspaper(s) at, the'1l::"co for. Subscribed and sworn to before me IhiS~day of i respectiv~ newspaper(s, an~ithe~. listed below: . ( J . en, Notary Public -345- C~aWha ~08/14/15 - 08/14/15 OLt~,C Counly. West Virginia C M K 50ildl + + cominG soon to a closing ·near you! FOR §ALE OWI\IER 1h.(ab.It-H.... l .. g_~hO........."' ~.1IIl~ ......_HIII\~ Rea'dy to !iell your Home? Wa~ch i~ VNlSJtI.~I'O"'W.!I"""" Inf~odi ... ",..01 M~~o:N w.o.1I I'rag,,,m Iofalld a, lSI CapIMISIrK4".m JIJ.ClNllttton.YN 2UO,·1113.kI,. pM"," IODp",,.i"l9I,.rwr.l.. ,tlnlKliousWolJII. ..am._\'t'MI 1Moodie:... WI •• .. uc_ " ~FMihI)-. Th.""uI\·.-..ctwll M 1'_PIiIII'_ Irt tralllpO"_ alllhemft 'I 1fa.'0f"11 .... "'~r-w ..... AIff.u.-lIIh,u,_ ...... _ . c~_ 7 Day Reill Estilte Milrketplilce $ ..., CII!~ .....IIIIU11b"'".u-...IIiInui.hIIf blDIDgKI' 1I/...... .nlllIbJdp'... tICII, ' .......IaIWul ... Happen! Packilge ,,' _ ', ,I _ th. . .U.tWftlVorIl' ....· ,n.·fdl!nrlill'"NI ..almallln oIthIIllOlibal • • • ,lnII'iIllId_ f>e'-:iIicy. ..... tot~"'~ \........ ..; bio....ICil 1IID1tII.lUiblDodprodlKu .....,.y...IW• .,u Shalf" 1tnr ............,_....,s,. lI _ _lIr fu:1Iw,lIIfoll'lllllOnO" ..... P'OpDMdIll'8!.a unbeotll.'"'-tIby(OlltlctlflDIhtc...... Hun\ingI...,I :..... I'.P.'T"-.. 7tl!S"""",h Mil'" HlInoI ... ~-: =.'~ =:.=:~~~~~ 1ocM0Id1t ::.OQpit.1l'.,...." ••.,.llJ. ON,,".I.n,Wtl15101-l7lJ. nw 111*'....... -.lid. riI .. ~ C!II14/a11IS ... iIInlllrolS. \· II"'" _!rIM" . . . I"'dudtl._ OIl! ~4J1_ftll Dlr... ""'u,...rI"'"_.I~.I ••b_.lldslwlU ... I",,"'''''''' I...... CAboll+(~II-.a",I ... Huhh o.p.~""a: ~-"'71)~" ......... IIoaMIftIONI,W2lll1 .. tolM s.u"'.".lh.D.pa~eJ.".Hoo.llh ~nd Hu ..... n AaDUla:I. WItCIIOYI MIodlc~ WaA. '"'01'11\ ]SO c...,uI !111M II""",, In. """""..... WV UIGt·UU "'"lIhioo )0 .j'lrldobpllYctti<:r ~-.~ •.......,tft.r.,......... ~I ..........1' 1hl·. . . lfIolIwS_·IJ ..... Io·~ ....... iI~l-n .f"-laua"'~lllh .. lddl ... abo.!wiI ..,.. 1t1d1J'.'lht~per,"" -346- aOOU[;01!lIlK AFFIDAVIT OF PUBLICATION b-€ ~ ~ JIrvl' ( I, being duly sworn, depose and say that I am Legal Clerk for The Herald-Dispat h, HD Media Co., LLC, who publIshes at Huntington, Cabell County, West Virginia, the newspaper The Herald-Dispatch, an Independent newspaper, the morning seven days each week, Monday through Sunday including New Year's Day, Memorial Day, the Fourth of July, Labor Day, Thanksgiving and Christmas; that I have been duly authorized by the Board of Directors of such corporation and the newspaper mentioned herein; that the legal advertisement attached in the left margin of this affidavit and made a part herof and bearing number 34748 was duly published in the The Herald-Dispatch once a week for 1 successive weeks, commencing with its issue of 08114/2015 and ending with the issue of 08/14/2015, that said legal advertisement was published.oI1, the folloWing dates: 08/14/2015 that the cost of publishing said annexed advertisement as aforesaid was $ 134.40; that such newspaper in which such legal advertisement was published has been and is now published regularly, at least as frequently as once a week for at least fifty weeks during the calendar year as prescribed by its mailing pennit and has been so published in the municipality of Huntington, Cabell County, West Virginia, for at least one year immediately preceding the date on which the legal advertisement set forth herin was delivered to such newspaper for publication; that such newspaper is a newspaper of "general circulation" as defined in article 3 ,chapter 59, ofthe West Virginia Code within the publication area or areas of the municipality of Huntington, Cabell, Putnam and Wayne Counties, West Virginia, and that such newspaper is circulated to the general public at a definite price or consideration; that such newspaper on each date published consists of not less than four pages without a cover; and that it is a newspaper to which the general public resorts for passing events of a political, religious, commercial and social nature, and for current happenings, announcements, miscellaneous reading matter, advertisements and other notices. Taken, subscribed and sworn to before me in my said county this day: 08114/2015 My commission expire~ 41i 0 'J{) ~ Notary Public Cabell County, West Virginia 1 of 1 10/22/20152:15 PM -347- West Virginia Department ofEnvironmental Protection Division ofAir Quality Randy C. Huffman Cabinet Secretary Earl Ray Tomblin Governor Class II General Permit G35-C for the Prevention and Control of Air Pollution in regard to the Construction, Modification, Relocation, Administrative Update and Operation of Natural Gas Compressor and/or Dehydration Facilities ThM permit is issuedi n accordance with the West Virginia Air Pollution Control Act (West Virginia Code. §§ 22-5-1 et seq.) and 45CSRI 3 - Permits for Construction, Modification, Relocation and Operation ofStationary Sources ofAir Pollutants, Notification Requirements, Temporary Permits, General Permits and Procedures for Evalltation. William F. Durham Director Issued: Draft -348- 2of39 G35-C Natural Gas Compressor and/or Dehydration Facility Any person whose interest may be affected, including, but not necessarily limited to, the applicant and any person who participated in the public comment process, by a permit issued, modified or denied by the Secretary may appeal such action of the Secretary to the Air Quality Board pursuant to article one [§§22B-l-l et seq.], Chapter 22B of the Code of West Virginia. West Virginia Code §§22-5-14. The source is not subject to 45CSR30. General Permit G35-C authorizes the construction, modification, administrative update and/or operation ofnatural gas compressor and/or dehydrationfacilities. The applicability ofGeneral Permit G35-C may include any ofthe folloWing: natural gas-flred spark ignition internal combustion engines, diesel-fired compression ignition internal combustion engines, storage vessels/tanks, glycol dehydration Utlits and associatedequVlment, equipment leaks, truck loading/unloading operations. and pneumatic controllers. West Virginia Department of Environmental Protection· Division of Air Quality -349- G35-C . Natural Gas Compressor and/or Dehydration Facility 30f39 Table of Contents 1.0. Emission Units ................................................................................................................ 5 1.1. 2.0. General Conditions ....................................................................................................... 5 2.1. 2.2. 2.3. 2.4. 2.5. 2.6. 2.7. 2.8. 2.9. 2.10. 2.11. 2.12. 2.13 . 2.14. 2.15. 2.16. 2.17. 2.18. 2.19. 2.20. 2.21. 3.0. Purpose ............................ ................................................................. ...... .. .............. 5 Authority ... ............. :................... .... .................... .. ................. .. ....................... ........ 5 Applicability ................................... ................. .................... .................................... 6 Definitions ................................ .................................................. ... .... ..................... 7 Acronyms ............................................................................................................... 7 Permit Expiration and Renewal .................................. " ........... ... ............................ 8 Administrative Update to General Permit Registration ...... .. ................................. 8 Modification to General Permit Registration ...... ...... :............................................ 8 Duty to Comply ............................................... ....... " .. ............... ............................... 8 Inspection and Entry ..................................... ............... .............. ....... ........................ 8 Need to Halt or Reduce Activity nota Defense ............... ....................................... 9 Emergency ..................................... .. .. ,·........................ .................., .......................... 9 Federally-Enforceable Requirements .......................................... ,.. ........................ 9 Duty to Provide Inform.ation ......; ................................~ ............... .. ...... ,..................... 9 Duty to Supplement and Correet Infonnation .............................. .... .... .. ................ 10 Credible Evidence ............. ............ ........... ................................. .............................. 10 Severability .................................................. ..... ,..................................................... 10 Property Rights ............. ..... ,'. ...........................'.................. .... .... ............................. 10 Notification RequirementS .. .:...... :.......................... .... ,; ............................................ 10 Suspension of Activities ... ........ :.. :... ;.......... ............ .... ............................................. 10 Transferability ............................. .,........ ..,:...... ,....................................................... 10 Facility-Wide Requ~~meDts ....................................~•.....•.....•.••.••.•.......••....••........•...... 11 3.1. 3·.2. 3.3. 3.4. 3.5 . 3.6. 4.0. General Permit Registration ............................................. ..... ................................ 5 SitingCriteria ·... _.................................................... ................................................ 11 Limitations and'S tandards ...........:,.,.............................. .......................................... 11 Monitoring Requiri:ments ....... .. ... :.... ;......................... ,............ .. .............. ............... 12 Testing Requ.ireJ11ellts·.. ;;.; ....... :. ,.............................................................................. 12 :RecordkeepingReq~irements •....·............................................................................ 13 ReportiDg Requirements ........................................................... .............................. 13 Source-Specific Requirements ..... ~ ............................................................................... 15 4 .1. 4.2. Limitation." and Standards ......... ............................................................................. 15 Recordkeeping Reqtiirements ..................................... :.................. ......................... 16 5.0. Source-Specific Requirements [Storage Vessels Containing Condensate and/or Produced Water] .............................................................................................................................. 17 5.1. 5.2. 5.3. 5.4. LimitatioD!S and Standards ...... .................... ............................................................ 17 Monltoring Requirements ....... ... ................ .............. ........ ........................... ....... .. .. . 18 Recordkeeping Requirements ................................ ...... ........ ................................... 19 Notification and Reporting Requirements ................... ,...... .................................... 19 6.0. Source-Specific Requirements [Standards of Performance for Storage Vessel Affected Facilities (NSPS, Subpart 0000)] ...........................................................................20 6.1. Limitations and Standards ...................................................... ................................ 20 7.0. Source-Specific Requirements [Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP Subpart HH] ......................................... 20 7.1. 7.2. 7.3. 7.4. 7.5. Limitations and Standards ............................................................ ....... .... ............... 20 Monitoring Requirements ... .................................................................................... 25 Testing Requirements .. .................................................................... ....................... 26 Recordkeeping Requirements ................................................................................ :27 Reporting Requirements ............ ...... .. ...... .. ............................................................: 29 West Virginia Department of Environmental Protection· Division of Air Quality -350- G35-C Natural Gas Compressor and/or Dehydration Facility 8.0. 40f39 Source-Specific Requirements [Small Heaters and Reboilers not subject to 40CFR60 Subpart Dc] ................................................................................................................................ 30 8.1. Limitations and Standards ...................................................................................... 30 8.2. Monitoring Requirements ....................................................................................... 30 8.3 Testing Requirements ............... ...................... ;....................................................... 30 8.4. Recordkeeping Requirements ................................................................................. 30 9.0. Source-Specific Requirements (Pneumatic Controllers Affected Facility (NSPS, Subpart 0000)] ........................................................................................................": .............. ~1 9.1. Limitations and Standards ...................................................................................... 31 10.0. Source-Specific Requirements [Centrifugal Compressor Affected Facility (NSPS, Subpart 0000)] .......................................................................................................................31 10.1. Limitations and Standards ...................................................................................... 31 11.0. Source-Specific Requirements [Reciprocating Compressor Affected Facility (NSPS, Subpart 0000)] .....................................................................•.........•..........................!' •••••••••••• 31 11.1. Limitations and Standards .......................................... .~ .......................................... 31 12.0. Source-Specific Requirements [Reciprocating Internal Combustion Engine(s) (RICE), Generators, Microturbine Generators] ................................................................................... 32 12.1. 12.2. 12.3. 12.4. 12.5. 13.0. Source-Specific Requirements [Tanker Truck Loading) .......... ~............................... 34 13.1. 13.2. 14.0 Limitations and Standards ........... ................... ......................... , .. .......... ., ................ 32 Monitoring Requirements ........ " ..·.. .................... .................................. ~................... 33 Recordkeeping Requirements .................... ,................. .............................................. 33 Testing Requirements ............................. ., .............................................................. 33 Reporting Requirements .. ..............................: .......................................................... 34 Limitations and Standardr. ~ .... :.........,................. ~ .. ................................................... 34 Re.cordkeeping Requirements .... ..·.. ....:....:............... :...·.............................................. 35 Source-Specific Requirements [GlyC()1 Debydration Units] ...................................... 36 14.1. 14.2. 14.3. 14.4. 14.5. Limitati(lns ·arid.Standards ...... ........................ ........................................................ 36 Monitoring ReEJ,uitements ......... .............................................................................. 36 Testing Requirements ................. ..... ......................................................................... 38 RecordkCeping Requirements ........... ...................................................................... 38 Reporting Requirement.'1 .............. ............. , ............................................................. 38 CERTIFICATION"OF DATA ACCURACY~ .......................................................................... 39 West Virginia Department of Environmental Protection • Division of Air Quality -351- 50f39 G35-C , Natural Gas Compressor and/or Dehydration Facility 1.0. Emission Units 1.1. 2.0. 2.1. General Permit Registration 1.1 .1. Only those emission units/sources as identified in the G35-C General Permit Registration, with the exception of any de minimis sources as identified under Table 45-13B of 45CSR13, are authorized at the registered facility. 1.1 .2. In accordance with the infonnation filed in the G35-C General Permit Registration Application, the equipment/processes identified in the Emissions Unit Table of the G35-C General Permit Registration shall be installed, maintained, and operated so as to minimize any fugitive escape of pollutants, shall not exceed the listed maximum design capacities, shall use the specified control devices, and shall not exceed the emission limits listed in the General Permit Registration. 1.1.3. Minor Source ofHazardous Air Pollutants (HAP). The facllity shall not exceed 10 tons per year of any single hazardous air pollutant which has been listed pursuant to § 112(b) of the Clean Air Act or 25 tons per year of any combination of hazardous air pollutants. Compliance with this section shall ensure that the facility is a minor SOUf\if of HAPs. 1.1.4. Minor Source ofRegulated Pollutants. The&cility shall not exceed 100 t.ons per year of any regulated air pollutant. The fugitive emisslODsof a stationary source shaH not be considered in detennining whether it is a major stationary source for the purposes of 45CSR30-2.26.b. Compliance with this Section shall ensure that the facility is a minor source of regulated air pollutants. 1.1.5 . Minor Source Compliance. The registrant ~hall maintain records of annual HAP and all other regulated air pollutant emissions using AP-42 emission factOrs, GRI~GLYCalc model inputs and outputs, flashing simulation model inputs at,ldoutpllbl, manufacturer guaranteed values, sample andlor test data, or othetmethods approved by DAQdemonstrating that facility-wide emissions are less than tlwse specified in Sections l .t.3 and 1.1.4. General Conditions Purpose The purpose of this Class II General Pennit is to authorize the construction, modification, administrative update, relocation, and operation of eligible natural gas compressor andlor dehydration facilities through a Class II General Permit Regi8tration process. The requirements, provisions, standards and conditions of this Class II General Pennit address the prevention and control of regulated pollutants from the operation of a natural gas compressor and/or dehydration facility. 2.2. Authority This pennit is issued in accordance with West Virginia air pollution control law W.Va. Code §§ 22-5-1. et seq. and the following Legislative Rules promulgated thereunder: 2.2.1 . 45CSRI3 - Permits for Construction, Modification, Relocation and Operation ofStationary Sources ofAir Pollutants, Notification Requirements, Administrative Updates, Temporary Permits, General Permits, Permission to Commence Construction, and Procedures for Evaluation. West Virginia Department of Environmental Protection· Division of Air Quality -352- 60f39 G35-C Natural Gas Compressor and/or Dehydration Facility 2.3. Applicability 2.3.1. All natural gas compressor and/or dehydration facilities designed and operated for the purpose of compressing and/or dehydrating natural gas and included in the following NAICS and/or SIC codes are eligible for General Permit registration except for those instances listed in (a) through (h) below: NAICSCode 211111 213112 221210 486210 SIC Code 1311 1382,1389 4923 4922 Description Crude Petroleum and Natural Gas Extraction Support Activities for Oil and Gas Operations Natural Gas Distribution Pipeline Transportation of Natural Gas a. Any natural gas compressor and/or dehydration facihty which is a major source of pollutants as defined in 45CSR14, 45CSR19 or 4SCSR30. b. Any natural gas compressor and/or dehydration fa(;ility that is located in Putnam County, Kanawha County, Cabell County, Wayne County, or Wood County and is required by 45CSR21 to conduct a Reasonably Available Control Technology (RACT) Analysis and/or subject to 45CSR21 Section 29 (~ frOm Natural Gas/Gasoline Processing Equipment). c. Any natural gas processing plant (e.g. production of ethWle, propane, butane, and pentane) as defmed in 40 CFR §60.5430. . ... d. Any natural gas sweetening plant. e. Any natural gas compressor andior dehydration facility with a storage tank subject to NSPS, SubpartKb. f. Any steam generating unit (as defined in§60Alc) subject to NSPS, Subpart Dc (> 10 MMBTU/hr). g. Any turbine wbject to NSPS, Subpart KKKK. . ' h. Any natural gas compressor and/or dehydration facility which will require an individual air quality pennit review process (45CSR13constructionimodification perinit) to incorporate regulatory requirement(s) other.than 1;hose established by General Permit G35-C. This would include "synthetic minor'; permitting actions, as they are required to undergo Notice Level C under 45CSR13 Se<.tion 8.5. "Synthetic minor" permitting actions would include limitations on physical or operational capacity to remain below major stationary source thresholds (including 45CSR14, 45CSR19, 45CSR30 and 45CSR34). 2.3.2. For the purposes of General Permit G35-C, natural gas compressor station means reciprocating internal combustion engine driven compressor(s) or combination of equipment (including but not limited to cOlllJlressor engines, emergency standby generators, engine driven air compressors, boilers, line heaters, tanks, glycol dehydration units, air pollution control devices, etc.) that supplies energy to move natural gas at increased pressure from gathering systems, in transmission pipelines or into storage. Engine means any compressor engine, emergency standby engine, auxiliary engine or air compressor engine located at a natural gas compressor station. 2.3.3. The West Virginia Division of Air Quality reserves the right to reopen this permit or any authorization issued under this permit if the area in which the facility is located is federally designated as non-attainment for specified pollutants. If subsequently any proposed construction, modification and/or operation does not demonstrate eligibility and/or compliance with the requirements, provisions, standards and conditions of this General Permit, this General Permit registration shall be denied and an individual permit for the proposed activity shall be required. West Virginia Department of Environmental Protection · Division of Air Quality -353- 70f39 G35-C - Natural Gas Compressor andlor Dehydration Facility 2.4. 2.5. .. Definitions 2.4.1. All references to the "West Virginia Air Pollution Control Act" or the "Air Pollution Control Act" mean those provisions contained in W.Va. Code §§ 22-5. 2.4.2. The "Clean Air Act" means those provisions contained in 42 U.S.C. §§ 7401 to 7671q, and regulations promulgated thereunder. 2.4.3. "Secretary" means the Secretary of the Department of Environmental Protection or such other person to whom the Secretary has delegated authority or duties pursuant to W.Va. Code §§ 22-1-6 or 22-1-8 (45CSR§30-2.12.). The Director of the Division of Air Quality is the Secretary's designated representative for the purposes of this permit. 2.4.4. The terms established in applicable definitions codified in the Code of Federal Regulations including 40 CFR Part 60 NSPS Subparts A, IIII, JJJJ, and 0000 or 40 CFR Part 63 MACT Subparts A, HH and ZZZZ shall also. apply to those sections of General Permit G35-C where these subparts are incorporated or otherwise addressed. Acronyms BBLorbbl Barrel CAAA Clean Air Act Amendments Confidential Business CBi Information Continuous Emission Monitor CEM CES Certified Emission Statement · C.F.R. Code of Federal Regulations CO Carbon Monoxide C.S.R. Code of State Rules Division of Air Quality DAQ DEP Depa.rtm.ent of Environmental Protection FOIA Freedom of Information Act HAP lIazar40us Air Pollutant HP Horsepower lhihl: Pounds per hour LDAR Leak Detection and RqJair Morm Thousand' MACT Maximum Achievable Control Teehnology MDHI Maximum Design Heat Input MMormm Million MMBTUIhr Million British Thermal Units Per Hour MMCF/hr Million Cubic Feet per Hour Not Applicable N/A NAAQS National Ambient Air Quality Standards NESHAPS National Emissions Standards for Hazardous Air Pollutants LAT Latitude Longitude LON NO .. NSCR NSPS PM PMi-s PM 10 ppm ppmv PSD psi RICE SCR SIC SIP S02 TAP TPY TSP USEPA UTM VEE vac. VRU Nitrogen Oxides Non Selective Catalytic Reduction New Source Performance Standards Particulate Matter Particulate Matter less than 2.5 11m in diameter Particulate Matter less than 10 IJ.ffi in diameter Parts per million Parts per million by Volume Prevention of Significant Deterioration Pounds per square inch Reciprocating Internal Combustion Engine Selective Catalytic Reduction Standard Industrial Classification State Implementation Plan Sulfur Dioxide . Toxic Air Pollutant Tons per year Total Suspended Particulate United States Environmental Protection Agency Universal Transverse Mercator Visual Emissions Evaluation Volatile Organic Compounds Vapor Recovery Unit West Virginia Department of Environmental Protection' Division of Air Quality -354- 80f39 G35-C Natural Gas Compressor and/or Dehydration Facility 2.6. Permit Expiration and Renewal 2.6.1 . This Class II General Permit shall remain valid, continuous and in effect unless it is revised, suspended, revoked or otherwise changed under an applicable provision of 45CSRI3 or any other applicable legislative rule. 2.6.2. General Permit registrations granted by the Secretary shall remain valid, continuous and in effect unless suspended or revoked by the Secretary. If the Class II General Permit registration is subject to action or change, existing registrations will continue to be authorized and subject to the previously established permit conditions. [45CSR§13-10.2, 45CSR§13-10.3] 2.7. Administrative Update to General Permit Registration 2.7.1 . 2.S. The registrant may request an administrative update to their GeneralPermit registration as defined in and according to the procedures specified in 45CSR§ 13-4. [45CSR§13-4.] Modification to General Permit Registration 2.8.1. 2.9. The registrant may request a minor peront modification t(\ their General Permit registration as defmed in and according to the procedures speoifi~d in 45CSR§ 13-5. [45CSR§13-5.] Duty to Comply 2.9.1. The registered facility shall be constructed and operated in accordance with the information filed in the General Permit Registration A,pplicatlCm and allY amendments thereto. The Secretary may suspend or revoke a General Permit Registration if the plans and specifications upon which the approval was based are not adhered to. \ 2.9.2. The registrant must comply with all applicable conditions of this Class II General Permit. Any General Permit noncomphance constitutes a violation of the West Virginia Code, and/or the Clean Air Act, and is grounds fqr enforcemenJ action by the Secretary or USEP A. 2.9.3 . Violation of any of the applicable requirements, provisions, standards or conditions contained in this Class II General Permit, or incorporated herein by reference, may subject the registrant to civil and/or criminal penalties for each violation and further action or remedies as provided by West Virginia Code 22-5-6 and 22-5-7. 2.9.4. Registration uttdelLhis Class II General Permit does not relieve the registrant herein of the responsibility to apply for and obtain all other permits, licenses, and/or approvals from other agencies; i.e. local, state and federal, which may have jurisdiction over the construction and/or operation of the source(s) and/or facility herein permitted. 2.10. Inspection and Entry 2.10.1. The registrant shall allow any authorized representative of the Secretary, upon the presentation of credentials and other documents as may be required by law, to perform the following: a. At all reasonable times enter upon the registrant's premises where a source is located or emissions related activity is conducted, or where records must be kept under the conditions of this permit; West Virginia Department of Environmental Protection· Division of Air Quality -355- 90f39 G35-C - Natural Gas Compressor and/or Dehydration Facility 2.11. b. Have access to arid copy, at reasonable times, any records that must be kept under the conditions of this Class II General Permit; c. Inspect at reasonable times (including all times in which the facility is in operation) any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this Class II General Permit; d. Sample or monitor at reasonable times, substances or parameters to determine compliance with the permit or applicable requirements or ascertain the amounts and types of air pollutants discharged. Need to Halt or Reduce Activity not a Defense 2.11.1. It shall not be a defense for a registrant in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this Class II General Permit. However, nothing in this paragraph shall be construed as precluding consideration of a need to halt or reduce activity as a mItigating fac.t or in determining penalties for noncompliance if the health, safety, or envirorunental impacts ofhaltin,g or reducing operations would be more serious than the impacts of continued operations. 2.12. Emergency 2.12. 1. An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which !;ituation requires immediate · corrective action to restore normal operation, and that causes the source to exceed a technologybased emission limitation under this Class II GeneralPermit, due to unavoidable increases in emissions attributable to the emergency: An emerg~ney shall not include noncompliance to the extent caused by improperly designed eqUipment, lack of preventative maintenance, careless or improper operatipu. or opmtor error. 2.12.2. In any enforcement proceeding, the registrant seeking to establish the occurrence of an emergency has the burden of proof. 2.12.3. This provision is in addition to any emergency or upset provision contained in any applicable requirement. 2.13. Federally-Eliforceable Requirements 2.13.1. All terms and conditions in this permit are enforceable by the Secretary, USEPA, and citizens under the Clean Air Act. 2.13.2. Those provisions specifically designated in the permit as "State-enforceable only" shall become "Federally-Enforceable" requirements upon SIP approval by the USEPA. 2.14. Duty to Provide Information 2.14.1. The registrant shall furnish to the Secretary within a reasonable time any information the Secretary may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this Class II General Permit Registration or to determine compliance with this General Permit. Upon request, the registrant shall also furnish to the Secretary copies of records required West Virginia Department of Environmental Protection· Division of Air Quality -356- 100f39 G35-C Natural Gas Compressor and/or Dehydration Facility to be kept by the registrant. For information claimed to be confidential, the registrant shall furnish such records to the Secretary along with a claim of confidentiality in accordance with 45CSR3I. If confidential information is to be sent to USEP A, the registrant shall directly provide such information to USEPA along with a claim of confidentialityiti accordance with 40 C.F.R. Part 2. 2.1S. Duty to Supplement and Correct Information 2.15.1. Upon becoming aware of a failure to submit any relevant facts or a: submittal of incorrect information in any registration application, the registrant shall promptly submit to the Secretary such supplemental facts or corrected information. 2.16. Credible Evidence 2. 16.1. Nothing in this Class II General Permit shall alter or affect th(; ability of any person to establish compliance with, or a violation of, any applicable requirement through the use of credible evidence to the extent authorized by law. Nothing in this permit shall be construed to waive any defenses otherwise available to the" registrant including but not limited to any challenge to the credible evidence rule in the context of any future proceeding. 2.17. Severability 2.17.1. The provisions of this Class II General Permit are severable. If any provision of this Class II General Permit, or the application of any provision of this Glass II General Permit to any circumstance is held invalid by a cOurl;of competent jurisl'l.iction, the nimaining Class II General Permit terms and conditions or their apphcation to other cir~mstances shall remain in full force and effect. 2.1S. Property Rights 2.18.1. Registration under this Class II General Permit does not convey any property rights of any sort or any exclusive privilege. 2.19. Notification Requiremenu" . 2.19.1. The registrant shall notify the Secretary, in writing, no later than thirty (30) calendar days after the actual startup of the operations authorized under this permit. 2.20. Suspension of Activities 2.20.1. In the event the registrant should deem it necessary to suspend, for a period in excess of one (1) year, all operations authorized by this permit, the registrant shall notify the Secretary, in writing, within two (2) calendar weeks of the passing of the one (1) year of the suspension period. 2.21. Transferability 2.21.1 . This permit is transferable in accordance with the requirements outlined in Section 10.1 of 45CSR13. [45CSR§13-10.1.] West Virginia Department of Environmental Protection· Division of Air Quality -357- 11 0f39 G35-C - Natural Gas Compressor and/or Dehydration Facility 3.0. Facility-Wide Requirements 3.1. Siting Criteria 3.1.1. 3.2. All persons submitting a Class II General Permit Registration Application to construct, modify or relocate a natural gas compressor and/or dehydration facility shall be subject. to the following siting criteria: a. No emission unit shall be constructed, located or relocated within 300 feet of any occupied dwelling, business, public building, school, church, community building, institutional building or public park. An owner of an occupied dwelling or business may elect to waive the 300 foot siting criteria. b. Any person proposing to construct, modify or relocate dtly emission unit(s) within 300 feet of any occupied dwelling, business, public building, s(;hool., church, community, institutional building or public park may elect to obtain an indhidual permit pursuant to 45CSRI3 . Limitations and Standards 3.2.1. Open burning. The open burning of refuse by any person is prohibited except as noted in 45CSR§6-3.1. [45CSR§6-3.1. ] 3.2.2. Open burning exemptions. The exemptions listed in 4SCSR§6-3.1 are subject to the following stipulation: Upon notification by the Secl'~tary, no person shall cause or allow any form of open burning during existing or predicted periods ofa1mospheric" stagnation. Notification shall be made by such means as the Secretary may d~~ necessary and feasible. [45CSR§6-3.2,J 3.2.3. Asbestos. The registrant is responsible for thoroughly inspecting the facility, or part of the facility, prior to commencem¢nt of demolition or renovation for the presence of asbestos and complying with40 C.PR § 6(14S, 40 C.F.R § 61 .148, and 40 C.F.R. § 61.150. The registrant, owner, or op~rator mustootUy the Secretary at least ten (10) working days prior to the commencement of any asbestos removal on the forms prescribed by the Secretary if the registrant IS subject to the noti.fk:ation requirements of 40 C.F.R § 61.l45(b)(3)(i). USEPA, the Division of Water and Waste Management (DWWM), and the Department of Health and Human Resources (DHHR) - Office of Environmental Health Services (OEHS) require a copy of this notice to be sent to them. [40CFR§61.145(b) and 45CSR§34] 3.2.4. Odor. No person shall cause, suffer, allow or permit the discharge of air pollutants which cause or contribute to"an objectionable odor at any location occupied by the public. [45CSR§4-3.1] [Stat/! Enforceable Only] 3.2.S. Permanent shutdown. A source which has not operated at least SOD hours in one, twelve (12) month period within the previous five (5) year time period may be considered permanently shutdown, unless such source can provide to the Secretary, with reasonable specificity, information to the contrary. All permits may be modified or revoked and/or reapplication or application for new permits may be required for any source determineq to be permanently shutdown. This requirement does not apply to emergency generator(s) permitted to opf!rate only 500 hours per year. [45CSR§13-10.5.] West Virginia Department of Environmental Protection' Division of Air Quality -358- 120f39 G35-C Natural Gas Compressor andlor Dehydration Facility 3.3. 3.2.6. Standby plan for reducing emissions. When requested by the Secretary, the registrant shall prepare standby plans for reducing the emissions of air pollutants in accordance with the objectives set forth in Tables I, II, and III of 45CSRII. [4SCSR§11-S.2.) 3.2.7. Minimization of Fugitive Emissions. The registrant shall operate consistent with information provided in registrant's G35-C General Permit Registration Application for fugitive emission sources. [4SCSR§13-S.11.) 3.2.8 . The registrant shall not create a nuisance to the surrounding community by way of unreasonable noise and light during operation. Monitoring Requirements See Section 4.2. 3.4. Testing Requirements 3.4.1. Stack testing. As per provisions set forth in this permit or as otherwise required by the Secretary, in accordance with the West Virginia Code, underlying regulations, permits- and orders, the registrant shall conduct test(s) to determine compliati¢e with the emission limitations set forth in this Class II General Permit andlor established or set forth in underlying documents. The Secretary, or their duly authorized l:epresentative, may at hislher option witness or conduct such test(s). Should the Secretary exercise his/her option to conduct such test(s), the operator shall provide all necessary sampling contiections sampling ports to be located in such manner as the Secretary may require, power for test equipment and the required safety equipment, such as scaffolding, railings' and ladders, to comply with generally accepted good safety practices. Such tests shall be conducted in accordance with the methods and procedures set forth in this permit or as otherwise-approved or specified by the Secretary in accordance with the following: and a. The Secretary may oil a so\lrce-specific basis approve or specify additional testing or alternative testing to the test methods specified in the permit for demonstrating compliance with 40 C .P .R. Parts60, 61, and 63 in accordance with the Secretary's delegated authority and any establishtd equivalency determination methods which are applicable. If a testing method is specified or approved which effectively replaces a test method specified in the Class II General Permit, the permit may be revised in accordance with 45CSR§ 13-4. or 45CSR§ 13-5.4 as applicable. b. The Secretary may on a source-specific basis require, approve or specify additional testing or alternative testing to the test methods specified in the Class II General Permit for demonstrating compliance with applicable requirements which do not involve federal delegation. In specifying or approving such alternative testing to the test methods, the Secretary, to the extent possible, shall utilize the same equivalency criteria as would be used in approving such changes under Section 3.4.l.ii. of this general permit. Ifa testing method is specified or approved which effectively replaces a test method specified in the permit, the permit may be revised in accordance with 45CSR§ 13-4. or 45CSR§ 13-5.4 as applicable. c. All periodic tests to determine mass emission limits from or air pollutant concentrations in discharge stacks and such other tests as specified in this Class II General Permit shall be conducted in accordance with an approved test protocol. Such protocols shall be submitted to the Secretary in writing at least thirty (30) days prior to any testing and shall contain the information set forth by the Secretary. In addition, the registrant shall notify the Secretary at least fifteen (15) days prior to any testing so the Secretary may have the opportunity to observe such tests. This notification shall include the actual date and time during which the West Virginia Department of Environmental Protection • Division of Air Quality -359- 130f39 G35-C . Natural Gas Compressor and/or Dehydration Facility test will be conducted and, if appropriate, verification that the tests will fully conform to a referenced protocol previously approved by the Secretary. d. The registrant shall submit a report of the results of the stack test within sixty (60) days of completion of the test. The test report shall provide the information necessary to document the objectives of the test and to determine whether proper procedures were used to accomplish these objectives and any operating parameters required to be monitored. The report shall " include the following: the certification described in paragraph 3.6.1; a statement of compliance status, also signed by a responsible official; and, a summary of conditions which form the basis for the compliance status evaluation. The summary of conditions shall include the following: 1. The permit or rule evaluated, with the citation number and language; 2. The result of the test for each permit or rule condition; and, 3. A statement of compliance or noncompliance with each permit or rule condition. [WV Code § 22-5-4(a)(14-15) and 45CSR13] " 3.5. 3.6. Recordkeeping Requirements 3.5.1. Retention of records. The registrant shall maintain records of all infoi'mation (including monitoring data, support information, reports, and notifications) required by this permit recorded in a fonn suitable and readily available for expeditious inspection and review. Support information includes all calibration and maintenance ~ecords. The files shall be maintained for at least five (5) years following the date of each occurrence. measurement, maintenance, corrective action, report, or record. "Said records shall be maintaIned on site or in a readily accessible off-site location maintained by the registni1,lt roI' a pe,riod of five (5) years. Said records shall be readily available to the Secretary of the DiV1$ion of Air Quality or ms/her duly authorized representative for expeditious inspection and review. "Any lecord$ sllbmitted to the agency pursuant to a requirement of this pemnt or upon requ~st by the Secretary shall be certified by a responsible official. Whereappropriaw, the registrant may maintain records electronically. 3.5.2. Odors. For the purposes of 45CSR4, the registrant shall maintain a record of all odor complaints received. any inver;tigatlon petformed in response to such a complaint, and any responsive action(s) taken. [45CSR§4. State Enforceable Only.] Reporting ReqUirements 3.6.1. Re~ponsible 3.6.2, Confidential information. A registrant may request confidential treatment for the submission of reporting required by this permit pursuant to the limitations and procedures of W.Va, Code § 225-10 and 45CSR31. 3.6.3. Correspondence. All notices, requests, demands, submissions and other communications required or permitted to be made to the Secretary of DEP and/or USEP A shall be"made in writing and shall be deemed to have been duly given when delivered by hand, e-mailed or mailed first class with postage prepaid to the address( es) set forth below or to such other person or address as the Secretary of the Department of Environmental Protection may designate: officiaL Any application form, report, or compliance certification required by this permit to be submitted "to the DAQ and/or USEP A shall contain a certification by the responsible officialtbat states that, based on information and belief formed after reasonable inquiry, the statements and i.nformation in the document are true, accurate, and complete. West Virginia Department of Environmental Protection· Division of Air Quality -360- G35~C 140f39 Natural Gas Compressor and/or Dehydration Facility Uto theDAQ: Director WVDEP Division of Air Quality 601 57th Street SE Charleston, WV 25304-2345 3.6.4. Uto the US EPA: Associate Director Office of Air Enforcement and Compliance Assistance (3AP20) U.S. Environmental Protection Agency Region III 1650 Arch Street Philadelphia, PA 19103-2029 Emission inventory. At such time(s) as the Secretary may designate, the registrant herein shall prepare and submit an emission inventory for the previous year, addressing the emissions from the facility and/or process(es) authorized herein, in accordance with the emission inventory submittal requirements of the DAQ. After the initial submittal, the-Secretary may, based upon the type and quantity of the pollutants emitted, establish a frequency other than on an annual basis. 3.6.5. Operating Fee 3.6.5.1. In accordance with 45CSR22 - Air Quality Managt>ment Fee Program, the registrant shall not operate nor cause to operate the permitted facility or other associated facilities on the same or contiguous sites comprising the plant withoutfu~tobtaining and having in current effect a Certificate to Operate (CTO). Such Certificate to Operate (CTO) shall be renewed annually, shall be maintained on the premises fur- which the certificate has been issued, and shall be made immediately available for inspe<'ti~n by the Secretary or his/her duly authorized representative. West Virginia Department of Environmental Protection' Division of Air Quality -361- 150f39 G35-C . Natural Gas Compressor and/or Dehydration Facility 4.0. Source-Specific Requirements 4.1. Limitations and Standards 4.1.1. Operation and Maintenance ofAir Pollution Control Equipment and Emission Reduction Devices. The registrant shall, to the extent practicable, install, maintain, and operate all pollution control equipment and emission reduction devices listed in the issued General Permit Registration and associated monitoring equipment to comply with limits set forth in this General Permit or as set forth by any State rule, Federal regulation, or alternative control plan approved by the Secretary. [45CSR§ 13-5.11.] 4.1.2. Applicability olState and Federal Regulations. The registrant is subject to the provisions of the following State Rules and Federal Regulations, to the extent applicable based on its registration: a. b. c. d. e. f. g. h. i. j. k. 45CSR2 - Particulate Air Pollution from Combustion of Fuel in Indirect Heat Exchangers 45CSR6 - To Prevent and Control Air Pollution from the Combustion of Refuse 45CSRI0 - To Prevent and Control Air Pollution from the fimissions of Sulfur Oxides 45CSRl3 - Permits for Construction, Modification, Relocation and Operation of Stationary Sources of Air Pollutants, Notification ReqUirements, Administrative Updates, Tempofary Permits, General Permits, and ProcedureS for Evaluation 45CSR16 - Standards of Performance for New StatioMry Sources Pw~uant to 40 CFR Part 60 45CSR22 - Air Quality Management Fee P-r:ogram . 40CFR60 Subpart IllI - Standards ofPerforiruuw.e for Stationary Compression Ignition Internal Combustion Engines 40CFR60 Subpart JJJJ - Standal'ci<; of Performance fur Stationary Spark Ignition Internal Combustion Engines 40CFR60 Subpart 0000 - StaQdards ofPerfo'rmance·for Crude Oil and Natural Gas Production, Transmission, and Oistril)l~t'1On 40CFR63 Subpart HH - National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Produc:tion Facilities 40CFR63 Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines 4.1.3. TheregistnuJ.t shall install,maintain, and operate all above-ground piping, valves, pumps, etc. that selvice lines in the transport of potential sources of regulated air pollutants to minimize any fugitive escape of r~ulated air poUutants (leak). Any above-ground piping, valves, pumps, etc. that shows signs of exeess wear and that have a reasonable potential for fugitive emissions of regulated air pollutant<; shall be replaced. 4.1.4. The registtant shall monitor and maintain quarterly records (calendar year) for each facility component that was inspected for fugitive escape of regulated air pollutants. Each component shall operate with no detectable emissions, as determined using audio-visual-olfactory (AVO) inspections, lJSEP A 40CFR60 Method 21, USEPA alternative work practice to detect leaks from equipment using optical gas imaging (OGI) camera (ex. FUR camera), or some combination thereof. AVO inspections shall include, but not limited to, defects as visible cracks, holes, or gaps in piping; loose connections; liquid leaks; or broken or missing caps or other closure devices. If registrant uses USEP A Method 21, then no detectable emissions is defined as less than 500 ppm in accordance with Method 21. If registrant uses an OGI camera, then no detectable emtSSlons is defined as no visible leaks detected in accordance with USEP A alternative OGI work practices. If any leak is detected, the registrant shall repair the leak as soon as possible. The first attempt at repair must be made within five (5) calendar days of discovering the leak, and the final repair must be made within fifteen (15) calendar days of discovering the leak. The registrant shall record each leak detected and the associated repair. The leak will not be considered repaired until the same monitoring method or a more detailed instrument determines the leak is repaired. West Virginia Department of Environmental Protection· Division of Air Quality -362- G35-C Natural Gas Compressor and/or Dehydration Facility 160f39 Delay of repair of a closed vent system for which leaks or defects have been detected is allowed if the repair is technically infeasible without a shutdown, or if you determine that emissions resulting from immediate repair would be greater than the fugitive emissions likely to result from delay of repair. You must complete repair of such equipment by the end of the next shutdown. [45CSR§13-5.11.] 4.2. Recordkeeping Requirements 4.2.1. Monitoring information. The registrant shall keep records of monitoring information that include the following: a. b. c. d. e. f. The date, place as defined in this permit and time of sampling Or measurements; The date(s) analyses were performed; The company or entity that performed the analyse'); The analytical techniques or methods used; The results of the analyses; and The operating conditions existing at the time of sampling or mea~urement. 4.2.2 . Record ofMaintenance ofAir Pollution Cont1"FJIEquipment and Emission Rt'ductwn Devices. For all pollution control equipment and emission reduction devices listed in the General Permit Registration, the registrant shall maintain accurate reoords of all required pollution control equipment and emission reducti determined by the methods specified in section 7.3.1 of this general permit except fordther (a)or (b): a. periods not to exceed a total of one minute during any 15 minute period, determined on a monthly basis; or b. periods not to exceed a total of two (2) minutes during any hour, determined on a quarterly basis if the enclosed combustion device installed was a model tested under § 60.5413(d) which meets the criteria in § 60.5413(d)(1I), IV. Enclosed combustion devices shall be operated at all times when emissions are vented to them. v. To ensure compliance with 7.1.2 .3(iv) above, the registrant shall monitor in accordance with section 7.2.3 of this general permit. VI. The registrant shall operate and maintain the enclosed combustion device according to the manufacturer's specifications for operating and maintenance requirements to maintain the guaranteed control efficiency listed in the General Permit Registration. West Virginia Department of Environmental Protection • Division of Air Quality -368- G35-C Natural Gas Compressor and/or Dehydration Facility 22 0f39 The registrant may claim a capture and control efficiency of 98% for those units meeting the requirements of3.i-vi. 4. Closed Vent System. The registrant shall comply with the closed vent system requirements in section 7.1.4. 5. Maximum Design Heat Input. The maximum design heat input for any registered flare or enclosed combustion device listed in the General Permit Registration shall not exceed the Maximum Design Heat Input (MMBtu/hr) recorded with the registrant's General Permit Registratiori. 6. 7.1.3. The registered enclosed combustion device or flare is subject to the applicable requirements specified in 45CSR6. Cover Requirements. The registrant shall comply with the cover requirements in this section if the potential emissions that were calculated to determine affected facility status did include recovered vapors from the storage vessel as allowed and in accordance with 5.1.2 of this general permit. 1. The cover and all openings on the cover (e g., access hatches, ~ampling ports, pressure relief valves and gauge wells) shall form a continuous impermeable banle.r over the entire surface area of the liquid in the storage vess.eL . .: , 2. Each cover opening shall be secured in a closed. sealed position (e.g., covered by a gasketed lid or cap) whenever material is in the unit em Vlthich the cover is installed except during those times when it is necessary to.1.ISeanopening as foHows : ..... (i) To add material to, or remove matcrialfrom the unit (this includes openings necessary to equalize or balance the internal pre~sure(lf the unit following changes in the level of the . . material in the unit); (ii) To inspect or sample the material in the unit; (iii) To inspect, mainiaUi; iepair, or replace equipment located inside the unit; or (iv) To ven.t liquids, gases, or fumes from the unit through a closed-vent system designed and operated in accordance with the requirements of this general permit to a control device or to a proce.ss: 3. F..a~h storage vessel thief hatch shall be weighted and properly seated. You must select gasket material for the hatch based on composition of the fluid in the storage vessel and weather conditions. [45CSR§13-5.1l.] 7.1.4 . Closed Vent Systems (applies to all non 40CFR60 Subpart 0000 controls). The registrant shall comply with the closed vent system requirements in this section if the potential emissions that were calculated to determine affected facility status did include recovered vapors from the storage vessel as allowed and in accordance with 6.1.4 of this general permit. . 1. You must design the closed vent system to route all gases, vapors, and fumes emitted from the material in the storage vessel to a control device that meets the requirements of 6.1.5 of this general permit or to a process. The registrant shall perform an initial LDAR evaluation within thirty (30) days of start-up and follow the procedures in section 4.1.4 for . ongoing compliance. 2. You must design and operate a closed vent system with no detectable emissions, as determined using audio-visual-olfactory (AVO) inspections, USEP A 40CFR60 Method 21, West Virginia Department of Environmental Protection· Division of Air Quality -369- 230f39 G35-C . Natural Gas Compressor and/or Dehydration Facility USEPA alternative work practice to detect leaks from equipment using optical gas imaging (OG!) camera (ex. FUR camera), or somecombinatio~ thereof. AVO inspections shall include, but not limited to, defects as visible cracks, holes, or gaps in piping; loose connections; liquid leaks; or broken or missing caps or other closure devices. If registrant uses USEP A Method 21, then no detectable emissions is defined as less than 500 ppm in accordance with Method 21. If registrant uses an OGI camera, then no detectable emissions is defined as no visible leaks detected in accordance with USEPA alternative. OGI work practices. 3. You must meet the requirements specified in (1) and (2) of this section if the closed vent system contains one or more bypass devices that could be used to divert all or a portion of the gases, vapors, or fumes from entering the control device or to a process. I. Except as provided in paragraph (2) of this section, you must comply with either paragraph (A) or (B) of this section for each bypass device. A. You must properly install, calibrate, maintain, and Ilperate a flow indicator at the inlet to the bypass device that could divert the stream away from the control device or process to the atmosphere that Sllunds an alarm, or injtiates notification via remote alarm to the nearest field office, when the bypass device is open such that the stream is being, or could be, diverted away from the control device or-process to the atmosphere. B . You must secure the bypass device valve installed at the inlet to the bypass device in the non-diverting position using a car-sealol a lock-and-key type configuration. Low leg drains, high point bleeds, analyzer vents, open-ended valves or lines,· and safety devices are not subject to ·the requirements of paragraph (i) of this section. [45CSR§13-5.11.1 " '. 11. 7 .1.5. Carbon Adsorption Systems. The registrant shall comply with the requirements below for any registered carbon adsorption system that is listed as a control device in the General Petmit Registration: i. The carbon adsorption system shall be designed to achieve the minimum guaranteed control efficiency that is listed in the General Permit Registration for volatile organic compound (VOC) emissions~ ii. The carbon adsorption system must be operated at all times when gases, vapors, and fumes are vented to it. Carbon canisters shall be operated in series as dual carbon canisters, in case of emis.'1ion breakthrough in one carbon canister. iii. The carbon adsorption system must have a commercially manufactured saturation indicator installed. IV. Prior to the loading of each truck, the saturation indicator on the carbon adsorption system shall be checked to ensure that the carbon is not spent. These records must be kept in accordance with section 3.5.1 of this general pe~it. If the saturation indicator demonstrates that the carbon is saturated, truck loading is prohibited and/or emissions are to cease. v. All carbon in the carbon canister shall be replaced with fresh carbon or the carbon canister replaced with a new canister when the saturation ind:icator changes in color and indicates saturation. vi. Fresh replacements for all carbon being used in the carbon adsorption system shall be kept on site. West Virginia Department of Environmental Protection· Division of Air Quality -370- 240f39 G35-C Natural Gas Compressor andlor Dehydration Facility 7.1.6. The registrant may claim a control efficiency of95% for those units meeting the requirements of 7.1.5.i-vi. CondenserslBTEX Eliminators. The registrant shall comply with the requirements below for any registered condenserlBTEX Eliminator that is listed as a control device/emission reduction device for a glycol dehydration unit in the General Permit Registration: i. Vapors that are being controlled by the condenserlBTEX Eliminator shall be routed through a closed vent system to the condenserlBTEX Eliminator at all times when there is a potential that vapors (emissions) can be generated from the glycol dehydration still column. ii. ThecondenserlBTEX Eliminator shall be designed, operated, and maintained accordi,ng to good engineering practices and manufacturer's specifications so as to achieve, at a minimum, a capture and control efficiency of 50%. a. 7.1.7 . The registrant may claim a capture and control efficiency greater than 50% if the General Permit Registration was approved based on manufacturer',> specifications and the unit was operated as such. Vapor Recovery Units (VRUs) i. The registrant shall comply with the closed vellt system requirements in Section 7.1.4 of this . general permit. 11. The registrant may claim a captwe and control efficlency of95% (which accounts for 5% expected downtime). iii. The registrant may claim a captute and control "fficiency of 98% if the VRU has a backup flare (enclosed (-Ombustion device)tl\at meet the requirements of section 7.1.2 of this general permit. iv. The registrant may clalro a capture and control efficiency of98% if the VRU has a backUp VRU. 7.1.8. Glycol Dehydration Unit~; Recycling Back to Flame Zone ofthe Reboiler. If the registrant is reducing emission.; by rec~ling the glycol dehydration unit back to the flame zone of the reboiler, it. shall be designed and operated in accordance with the following: a. The vapors/overheadsfrom the still column shall be routed through a condenser at all times when tnere is a potential that vapors (emissions) can be generated from the still column. b. The rltboiler shall only be fired with vapors from the still column and flash tank, and natural gas may be used as a supplemental fuel. c. The vapors/overheads from the still column shall be introduced into the flame zone of the reboiler as the primary fuel or with the primary fuel before the combustion chamber. The registrant may claim a capture and control efficiency of 50% for those units meeting the requirements of a through c. The registrant may claim a capture and control efficiency greater than 50% if the General Permit Registration was approved based on manufacturer's specifications and the unit was operated as such. West Virginia Department of Environmental Protection· Division of Air Quality -371- 250f39 G35-C . Natural Gas Compressor and/or Dehydration Facility 7.2. Monitoring Requirements 7.2.1. To demonstrate compliance with the pilot flame requirement~ of sections 7.1.2.2 and 7.1.2.3 of this general permit, the presence of a pilot flame shall be continuously monitored using a thermocouple or any other equivalent device to detect the presence of a flame when emissions are vented to it. The pilot shall be equipped such that it sounds an alarm, or initiates notification via remote alarm to the nearest field office, when the pilot light is out. 7.2.2. To demonstrate compliance with the closed vent system requirements of section 7.1.4 of this general pennit, the registrant shall: a. Initial requirements. Conduct an initial AVO inspection or those methods listed in section 4.1.4 of this general pennit for defects that could result in air emissions within thirty (30) days of start-up. Defects include, but are not limited to, visible cracks, holes, or gaps in piping; loose connections; liquid leaks; or broken or missing caps or other closure devices. 1. The initial inspection shall include the bypass inspection. conducted according to paragraph (c) of this section. ii. In the event that a leak or defect is detected, you must repair the leak or defect as soon as practicable. Grease or another applicable substance mIDit be applied to deteriorating or cracked gaskets to improve the seal while awaiting repair. iii. Delay of repair of a closed vent system for which leaks or defects have been detected is allowed if the repair IS technically infeasible without a shutdown, or if you determine that emissions'rersulting. from immediate repair would be greater than the 'fugitive emissions likely to~ result frow, de)ay of repair. You must complete repair of such equipment by the end ofthe next shutdOwn. b. Continuolls req~i,.emt1nts. The registrant shall monitor and maintain quarterly records for each component that was inspected fbi' fugitive escape of regulated air pollutants. Each component shall opexate with no detectabie emissions, as determined using AVO inspections, USEP A 40CFR6Q Method 21, USEP ~altemative work practice to detect leaks from eqUipment using optical ga!i imaging (OG!) camera (ex. FUR camera), or some combination thereof: AVO inspections shall include, but not limited to, defects as visible cracks, holes, or gaps in piping; loose connections; liquid leaks; or broken or missing caps or other closure devices. If registrant uses USEPA Method 21, then no detectable emissions.is defined as less than 500 ppm in accordance with Method 21. If registrant uses an OGI camera, then no detectable emissions is defined as no visible leaks detected in accordance with USEP A alternative OGI 'Work practices. If any leak is detected, the registrant shall repair the leak as soon as possible. The first attempt at repair must be made within five (5) days of discovering the leak, and the final repair must be made within fifteen (15) days of discovering the leak. The registrant shall record each leak detected and the associated repair. The leak will not be considered repaired until the same monitoring method that detected the leak determines the leak is repaired. The registrant shall maintain records of all quarterly monitoring for fugitive escape of regulated air pollutants. 1. The annual inspection shall be conducted within 365 calendar days from the 'date of the previous inspection or earlier. ii. The annual inspection shall include the bypass inspection, conducted according to paragraph (c) of this section. West Virginia Department of Environmental Protection· Division of Air Quality -372- 260f39 G35-C Natural Gas Compressor andlor Dehydration Facility 7.2.3. c. Bypass inspection. Visually inspect the bypass valve during the initial and annual inspection for the presence of the car seal or lock-and-key type configuration to verify that the valve is maintained in the non-diverting position to ensure that the vent stream is not diverted through the bypass device. If an alternative method is used, conduct the inspection of the bypass as described in the operating procedures. d. Unsafe to inspect requirements. You may designate any parts of the closed vent system as unsafe to inspect if the requirements in paragraphs (i) and (ii) of this section are met. Unsafe to inspect parts are exempt from the inspection requirements of paragraphs (a) and (b) of this section. 1. You determine that the equipment is unsafe to inspect because inspecting personnel would be exposed to an imminent or potential danger a.~ a consequence of complying with the requirements. ii. You have a written plan that requires inspection of the equipment as frequently as practicable during safe-to-inspect times. To demonstrate compliance with the pilot flame requirements of sections 7.1.2.3 of this general permit, the registrant shall follow (i) and (ii)' i. The presence of a pilot flame shall be continuously;monitored using a thermocouple or any vented to it. other equivalent device 'to detect the presence ofa flame when emissions are The pilot shall be equipped such that it sounds an !\larm, or initiates notification via remote alarm to the nearest field office, when the pilot light is out. 11. For any absence of pilot flame, -(\r other 'mdication of smoking or improper equipment operation, you must ensure the equipment is returned to proper operation as sOQn as practicable after the event occurs. At Ii minimum. you must: (1) Check the air vent for obstruction~ If an obstruction is observed, you must clear the obstruction as soon as practicable. (2) Check for liquid rea~hing the combustor. iii. The registrant is e;xempt from the pilot flame requirements of paragraphs (i) and (ii) of this 8ection if the registrant installed an enclosed combustion device model that was tested under § 60.5413(d) which mi::ets the criteria in § 60.5413(d)(11). 7.3. Testing Requirements 7.3.1. To demonstrate compliance with the visible emissions requirements of section 7.1.2.2,7.1.2.3, and 7.1.2.6 of this general pennit, the registrant shall conduct visible emission checks andlor opacity monitoring and recordkeeping for all emission sources subject to an opacity limit. i. The visible emission check shall determine the presence or absence of visible emissions. The observations shall be conducted according to Section 11 of EPA Method 22. At a minimum, the observer must be trained and knowledgeable regarding the effects of background contrast, ambient lighting, observer position relative to lighting, wind, and the presence of uncombined water (condensing water vapor) on the visibility of emissions. This training may be obtained from written materials found in the References 1 and 2 from 40CFR Part 60, Appendix A, Method 22 or from the lecture portion of the 40CFR Part 60, Appendix A, Method 9 certification course. The observation period shall be: a. b. c. a minimum of2 hours if demonstrating compliance with 7.1.2.2; a minimum of 15 minutes if demonstrating compliance with 7.1.2.3(iii)(a); or a minimum of 1 hour if demonstrating compliance with 7.1.2.3 (iii)(b) West Virginia Department of Environmental Protection· Division of Air Quality -373- 270f39 G35-C . Natural Gas Compressor and/or Dehydration Facility 11. The visible emission check shall be conducted initially within 180 days of start-up to demonstrate compliance while vapors are being sent to the control device. 111. If during this visible emission check or at any other time visible emissions are observed, compliance with section 7.1.2.6 of this general permit shall be determined by conducting opacity tests in accordance with Method 9 or 40 CFR 60, Appendix A. 7.3.2. A flare that is designed and operated in accordance with §60.l8(b) shall not require performance testing, unless at the request of the Secretary, but must conduct visible emission check. 7.3.3 . Enclosed combustion devices or flares. At such reasonable times as the Secretary may designate, the operator of any incinerator shall be required to conduct or have conducted stack tests to determine the particulate matter loading, by using 40 CFR Part 60, Appendix A, Method 5, and volatile organic compound loading, by using Methods 18 and 25A of 40 CFR Part 60, Appendix A, Method 320 of 40 CFR Part 63, Appendix A, or ASTM D 6348-03 or other equivalent U.S. EPA approved method approved by the Secretary, in exhaust gases. Such tests shall be' conducted in such manner as the Secretary may specify and be filed on forms and in a manner acceptable to the Secretary. The Secretary may,. at the Secretary'S option, witness or conduct such stack tests. Should the Secretary exercise his or her option to conduct such tests, the operator will provide all the necessary sampling connecti0ns and sampling ports to be located In such manner as the Secretary may require, power for test equipmerit and the required safety eqUipment such as scaffolding, railings and ladders to comply with generally accepted good safety practices. The Secretary may conduct such other tests as the Secretary may deem necessary to evaluate air pollution emissions other than those noted above. [45CSR6 §§7.1 and 7.2] 7.4. Recordkeeping Requirements 7.4.1. For the purpose of demonstrating compliance with the design requirements in section 7.1 .2.2 of this permit, the registl'aut shall maintain It record of the flare design evaluation. The flare design evaluation shall include, net. heat value calculations, exit (tip) velocity calculations, and all supporting concentration ca1~ulations. 7.4.2. For the purpose demonstrating compliance with the continuous pilot flame requirements in section8 7.1..2 .2 and 7.1.23 of this general permit, the registrant shall maintain records of the times and duration of all perio when the pilot flame was not present and vapors were vented to the device. . 7.4.3. of i. If the registrant 18 demonstrating compliance to 7.2.3 of this general permit with visual inspections, the registrant shall maintain recor.ds of the inspections. ii. If the registrant is demonstrating compliance to 7.2.3 of this general permit with an enclosed combustion device model that was tested under the conditions of § 60.5413(d), a record shall b~ maintained of the performance test results. For the purpose of demonstrating compliance with the visible emissions and opacity requirements, the registrant shall maintain records of the visible emission opacity tests and checks. The registrant shall maintain records of all monitoring data required by section 7.3.1 of this general permit documenting the date and time of each visible emission check, the emission point or equipment! source identification number, the name or means of identification of the observer, the results of the check(s), whether the visible emissions are normal for the process, and, if applicable, all corrective measures taken or planned. The registrant shall also record the general weather conditions (i.e. sunny, approximately 80°F, 6-10 mph NE wind) during the visual emission check(s). Should a visible emission observation be required to be performed per the requirements specified in Method 9, the data records of each observation shall be maintained per the requirements of Method 9. For an emission unit out of service during the evaluation, the record of observation may note "out of service" (O/S) or equivalent. West Virginia Department of Environmental Protection· Division of Air Quality -374- G35-C Natural Gas Compressor andlor Dehydration Facility 280f39 7.4.4. To demonstrate compliance with section 7.1.2.3.vi of this general permit, the registrant shall maintain records of the manufacturer's specifications for operating and maintenance requirements to maintain the control efficiency. 7.4.5. To demonstrate compliance with the closed vent monitoring requirements in section 7.2.2 of this general permit, records shall be maintained of: 1. The initial compliance requirements; ii. Each annual AVO inspection, Method 21, infrared camera or some combination thereof conducted to demonstrate continuous compliance, including records of any repairs that were made as a result of the inspection; iii. If you are subject to the bypass requirements, the folloVl'ing records shall also be maintained: (a) Each inspection or each time the key is chec~oo out or Ii record of each time the alarm is sounded; (b) Each occurrence that the control device was bypassed. If thede"ice was bypassed, the records shall include the date, time, arid duration of the event and !$hall provide the reason that the event occurred. The record shall also include the estimate of emissions that were released to the environment as a ~lt of the bypass. iv. Any part of the system that has been designated as " un~afe to inspect" in accordance with 7.2.2(d). 7.4.6. To demonstrate compliance with section 7.1 .5 oftbls general permit, records shall be kept on each carbon canister to indicate the date when the activated carbon was replaced mid the date of all indicator checki.>. . 7.4.7. The registrant shall maint~ records of any testing that is conducted according to section 7.3 of this general permit. 7.4.8. All recordsreqwred under Section 7.4 shall be maintained on site or in a readily accessible off-site location maintained by the regi~trant for a period of five (5) years. Said records shall be readily avrulable to the Director of the DAQ or his/her duly authorized representative for expeditious im;pection and revieVl' . Any records submitted to the agency pursuant to a requirement of this permit or upon requerst by the Director shall be certified by a responsible official. 7.4.9. To demonstrate compliance with section 7.1.2.5 of this general permit, the registrant shall record the volume of gM flared and the heating value of the gas flared on a monthly basis. . .' 7.4.10. To demonstrate compliance with section 7.1.6 of this general permit, the registrant shall record the outlet temperature of the condenser on a monthly basis. West Virginia Department of Environmental Protection· Division of Air Quality -375- 290f39 G35-C . Natural Gas Compressor and/or Dehydration Facility 7.S. Reporting Requirements 7.5 .1. Any deviation of the allowable visible emission requirement for any emission source discovered during observation using 40CFR Part 60, Appendix A, Method 9 per section 7.3. 1(iii) of this general permit must be reported in writing to the Director of the DAQ as soon as practicable, but within ten (10) calendar days, of the occurrence and shall include, at a minimum, the following information: the results of the visible determination of opacity of emissions, the cause or suspected cause of the violation(s), and any corrective measures taken or planned. 7.5.2. Any bypass event of the registered control device must be reported in writing to the Director of the DAQ as soon as practicable, but within ten (10) calendar days, of the occurrence and shall include, at a minimum, the following information: the date of the bypass, the estimate of VOC emissions released to the atmosphere as a result of the bypass, the cause 01 suspected cause of the bypass, and any corrective measures taken or planned. 7.5.3. Any time the air pollution control device is not operating when emissions are vented to it, shall be reported in writing to the Director of the DAQ as soon as practicable, but within ten (10) calendar days of the discovery. West Virginia Department of Envifonmental Protection· Division of Air Quality -376- G35-C Natural Gas Compressor and/or Dehydration Facility 300f39 8.0. Source-Specific Requirements [Small Heaters and ~eboilers not subject to 40CFR60 Subpart Dc] 8.1. 8.2. Limitations and Standards 8.1.1 . Maximum Design Heat Input. The maximum design heat input for any small heater and/or reboiler shall be less than 10 MMBTUIhr. 8.1.2. No person shall cause, suffer, allow or pennit emission of smoke and/or particulate matter into the open air from any fuel burning unit which is greater than ten (10) percent opacity based on a six minute block average. [45CSR§2-3.1.] Monitoring Requirements 8.2.1 . 8.3 Testing Requirements 8.3.1. 8.4. At such reasonable times as the Secretary may designate•.the registrant shall conduct Method 9 emission observations for the purpose of demonstrating compliarv;e with section 8.1.2 of this general permit. Method 9 shall be conducted in accordance with 40 CFR 60 Appendix A. Upon request by the Secretary, compliance witb the visible emission requir~ments of section 8.1.2 of this general pennit shall be detennined in aCC(lldance with 40 CFR Part 60, Appendix A, Method 9 or by using measurements from continuou~ op~city monitoring systems approved by the Secretary. The Secretary inay require the installation; calibration, maintenance and operation of continuous opacity monitoring syS~ms and may establish po1i.cies for the evaluation of continuous opacity monitoring results and the determination of compliance with the visible emission requirements of section 8.1.2 of this general permit. Continuous opacity monitors shall not be required on fuel burning units which employ wet scrubbing systems for emission control. [45CSR§2-3.2.} Recordkeepirtg Requirements 8.4.1. The registrant shall maintain records of all monitoring data required by section 8.2.1 of this permit documenting the date and time of each visible emission check, the emission point or-equipment/source identification number, the name or means of identification of the observer, the results of the check(s), whether the visible emissions are nonnal for the process, and, if applicable, all corrective mea!;ures taken or planned. The registrant shall also record the general weather conditions (Le. sunny, approximately 80°F, 6 - 10 mph NE wind) during the visual emission cbeck(s). Should a visible emission observation be required to be perfonned per the requirement!; specified in Method 9, the data records of each observation shall be· maintained per the requirements of Method 9. g~neral West Virginia Department of Environmental Protection· Division of Air Quality -377- 310f39 G35-C . Natural Gas Compressor and/or Dehydration Facility 9~0. Source-Specific Requirements [Pneumatic Controllers Affected Facility (NSPS, Subpart 0000») 9.1. Limitations and Standards 9.1.1. 10.0. The registrant of each pneumatic controller affected facility shall comply with the applicable requirements specified in 40 CFR Part 60, Subpart 0000. Source-Specific Requirements [Centrifugal Compressor Affected Facility (NSPS, Subpart 0000)] 10.1. Limitations and Standards 10.1.1. The registrant of each centrifugal compressor affectedfitcility shall comply with the applicable requirements specified in 40 CFR Part 60, Subpart 0000. 11.0. Source-Specific Requirements [Reciprocating Compressor Affected Facility (NSPS, Subpart 0000)) 11.1. Limitations and Standards 11.1.1 . The registrant of each reciprocating compressor affected facility shall comply with the applicable requirements specified in 40 CFR Part 60, Subpart qooo. West Virginia Department of Environmental Protection· Division of Air Quality -378- 320f39 G35-C Natural Gas Compressor and/or Dehydration Facility 12.0. Source-Specific Requirements [Reciprocating Internal Combustion Engine(s) (RICE), Generators, Microturbine Generators) 12.1. Limitations and Standards 12.1.1 . Regulated Pollutant Limitation. The registrant shall not cause, suffer, allow or pennit emissions of of any regulated pollutant listed in the General Permit Registration to exceed the emission limit (pounds per hour and tons per year) recorded with the registrant's General Permit Registration without effecting a modification or administrative update. 12.1.2. The applicable RICE(s) and/or generator(s) shall be operated and maintained as follows: a. b. In accordance with the manufacturer's recommendations and specifications or in accordance with a site specific maintenance plan; and, In a manner consistent with good operating practices. 12.1.3. Requirements for Use of Catalytic Reduction Devices', a. Rich-burn natural gas-fired compressor cngine(s) equipped with non-selective catalytic reduction (NSCR) air pollution contr(lldevices shall be fitted with a c}os(ld-Ioop, automatic air/fuel ratio controller to ensure emissions of regulated pollutants do not exceed the emission limit listed in the General Pennlt Registration for any enginelNSCR combination under varying load. The closed-loop, automatic air/fuel ratio controller shall control a fuel metering valve to ensure a fuel-rich mixture and a rt:'>ultant exhaust oxygen content of less than or equal to 2%. b. Lean-burn natural gas compressor engine('i) equipped with selective catalytic reduction (SCR) air pollution control devices ~ll be fitted with a closed-loop automatic feedback controller to en!;UTe emissions of regulated pollutants do not exceed the emission limit listed in the General PermIt Registration £Jr any engine/SCRcombination under varying load. The closed~loop automatic feedback controller shall provide proper and efficient operation of the engine, ammonia injection and SCR de\'lce, monitor emission levels downstream of the catalyst element and limit ammonia slip to less than 10 ppmv. c. Lean-buni natural gas compressor engine(s) equipped with oxidation catalyst air pollution control deviees shall be fitted with a closed-loop automatic air/fuel ratio feedback controller to ensure emissions of regulated pollutants do not exceed the emission limit listed in the General Permit Registration for any engine/oxidation catalyst combination under varying load. The closed-loop, automatic air/fuel ratio controller shall control a fuel metering valve to ensure a lean~richmixture. d. For natural gas compressor engine(s), the registrant shall monitor the temperature to the inlet of the catalyst and in accordance with manufacturer's specifications; a high temperature alann shall shut off the engine before thermal deactivation of the catalyst occurs. If the engine shuts off due to high temperature, the registrant shall also check for thermal deactivation of the catalyst before normal operations are resumed. e. The registrant shall follow a written operation and maintenance plan that provides.the periodic and annual maintenance requirements. 12.1.4. The registrant shall comply with all applicable NSPS for Stationary Compression Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart IIII, Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart IJJI, and/or the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 63, Subpart ZZZZ. West Virginia Department of Environmental Protection' Division of Air Quality -379- G35-C Natural Gas Cbmpressor andlor Dehydration Facility 330f39 12.1.5. The emission limitations specified in section 13.1.1 shall apply at all times except during periods of start-up and shut-down provided that the duration of these periods does not exceed 30 minutes per occurrence. The registrant shall operate the engine in a manner consistent with good air pollution control practices for minimizing emissions at all times, including periods of start-up and shut-down. The emissions from start-up and shut-down shall be included in the twelve (12) month rolling total of emissions. The registrant shall comply with all applicable start-up and shut-down requirements in accordance with 40 CFRPart 60, Subparts IIll, JJJJ and 40 CFR Part 63, SubpartZZZZ. 12.1.6. For the purposes of General Permit G35-C, emergency generator means a generator whose purpose is to allow key systems to continue to operate without interruption during times of utility power outages. 12.2. Monitoring Requirements 12.2.1. Catalytic Reduction Devices a. The registrant shall regularly inspect, property maintain andlor rtplace catalytic reduction devices and auxiliary air pollution control devices to ensure functional and effective operation of the engine's physical and operational design. The registrant shall en'JUfe proper operation, maintenance and performance of catalytic reduction devices and auxiliary air pollution control . devices by: 12.3. 1. Maintaining proper operation of the automatiC air/fuel ratio controller or automatic feedback controller. 2. Following the catalyst manufacturei' emissioos related operating and maintenance recommendations, or develop, implement, or follow a site-specific maintenance plan. RecordkeepingRequirements 12.3.1. To demonstrate compliance WIth general perinit section 12.1.4, the registrant shall maintain reconh of the mainterumce performed on each RICE andlor generator. 12.3.2. To demonstrate compliancewii.bgeneralpermit sections 12.2.1, the registrant shall maintain a copy of the site specific maint~nance plan or manufacturer maintenance plan. 12.3.3. The registrant shall comply with all applicable recordkeeping requirements under NSPS for Stationary Compresston Ignition Internal CombUstion Engines specified in 40 CFR Part 60, Subpart nn, Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart JJJJ, andior the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 63, Subpart ZZZZ. 12.3.4. All records required by this section shall be maintained in accordance with section 3.5.1 of this . general permit. 12.4. Testing Requirements 12.4.1. The registrant shall comply with all applicable testing requirements under NSPS for Stationary Compression IgnitionInternal Combustion Engines specified in 40 CFR Part 60, Subpart IIII, Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart JJJJ, andlor the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 63, Subpart ZZZZ. West Virginia Department of Environmental Protection· Division of Air Quality -380- G35-C Natural Gas Compressor andlor Dehydration Facility 340f39 12.4.2. To demonstrate compliance with general permit section 12.1.3(a), the registrant shall verify that the closed-loop, automatic air/fuel ratio controller shall control a fuel metering valve to ensure a fuel-rich mixture and a resultant exhaust oxygen content of less than or equal to 2% during any perfonnance testing. 12.5. Reporting Requirements 12.5.1. The registrant shall comply with all applicable notification requirements under NSPS for Stationary Compression Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart nn, Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 60, Subpart JJJJ, andlor the National Emission Standards for Hazardous Air Pollutants (NESHAP)for Stationary Spark Ignition Internal Combustion Engines specified in 40 CFR Part 63, Subpart ZZZZ. 13.0. Source-Specific Requirements [Tanker Truck Loading] 13.1. Limitations and Standards 13.1.1. Regulated Pollutant Limitation. The registrant shall nofcause, suffer, allow or permit emissions from any registered Tanker Truck Loading Facility of any regulated pollutant listed in the General Pennit Registration to exceed the emission limit (pounds per hour and tons per year) recorded with the l'egistrant's Genenil P~it Registration without effecting a . modification or administrative update. 13.1.2. Maximum TruckLoading ThroughputLimitation. 10 demonstrate compliance with the tanker truck loading emissfonli in section 13.1.1, the registrant shall not exceed the maximum throughput limit that wag recordedwtth registrant's General Pennit Registration without obtaining a modification or administrative update. Codlpliance with the Maximum Annual Throughput Limitation shall be determined using a twelve (12) month rolling total. A twelve (12) month rolling total,shall mean the sUtrl .ofthetanker truck product throughput at any given time during the previous twelve (I:!) cOI1secutlve calendar months. 13.1.3. Control Devices and VRUs.The registrant shall install, operate, and maintain all control devices andlor VRU(s) in accordance with the applicable requirements of section 7.0 of this general permit. 13.1.4. The following applicable capture efficiencies are required: a. b. c. For tanker trucks not passing one of the annual leak tests in 13 .1.4(b) or (c) and has vapor return-1O% For tanker trucks passing the NSPS level annual leak test - 98.7%. For tanker trucks passing the MACT level annual leak test - 99.2% Compliance with this requirement shall be demonstrated by keeping records of the applicable MACT or NSPS Annual Leak Test certification for every truck and railcar loaded/unloaded. This requirement can be satisfied if the trucking company provided certification that all tanker trucks servicing the location are compliant. This certification must be submitted with the G35-C Annual Certification. West Virginia Department of Environmental Protection· Division of Air Quality -381- 350f39 G35-C . Natural Gas Compressor and/or Dehydration Facility 13.2. Recordkeeping Requirements 13.2.1. To demonstrate compliance with the emission limitations in section 13.1.1 and with the throughput limitation in section 13.1.2, the registrant shall maintain monthly and annual records that include the total quantity of material loaded into tanker trucks. The annual records shall be calculated on a twelve (12) month rolling total. 13.2.2. For the purpose of demonstratlngcompliance with section 13.1.2, the registrant shall maintain records of the MACT and/or NSPS Annual Leak Tests of all trucks loaded at the facility. This requirement can be satisfied if the trucking company provided certification that its entire fleet was compliant. This certification must be submitted in writing to the Director of the DAQ. West Virginia Department of Environmental Protection · Division of Air Quality -382- 360f39 G35-C Natural Gas Compressor and/or Dehydration Facility 14.0 Source-Specific Requirements [Glycol Dehydration Units] 14.1. Limitations and Standards 14.1.1. The registrant of each glycol dehydration unit subject to 40 CFR Part 63, Subpart HH shall comply with the applicable requirements specified in 40 CFR Part 63, Subpart HH. 14.1.2. Maximum Throughput Limitation. The maximum dry natural gas throughput to the glycol dehydration units! still columns shall not exceed the throughput limit listed in the registrant's G35C General Permit Registration. Compliance with the Maximum Throughput Limitation shall be determined using a twelve (12) month rolling total. A twelve (12) month rolling total shall mean the sum of the monthly throughput at any given time during the previous twelve (12) consecutive calendar months. 14.1.3. Emission Limits. The registrant shall not cause, suffer. allow or permit emissions of HAPs and VOCs to exceed the emission limits listed in the registrant's G35-C General Permit Registration. 14.1.4. Emission Calculations. a. For purposes of determining potential HAP emissions, the methods sp~ified in 40 CFR 63, Subpart HH shall be used. b. Any source that has actual emissions of 5 tons rer year or more of a single HAP, or 12.5 tons per year or more of a combination of HAP (i.e., 50 Percent of the major source thresholds), shall update its maj or source detL,'rmination within I year of the prior determination or October 15, 2012, whichever is Iarer, and each year then~after, using gas composition data measured during the preceding 12 months: (40CFR§.63.760(c)] c. For the purposes of determining actual annual average natural gas throughput or actual average benzene emi~sions, the methods specified in § 63.772(b) of 40 CPR 63, Subpart HH shall be used if the registrant is exempt from § 63.764(d). .... '. ' 14.1 .5. Control Devices and Emission .Redkt.-tion Devices. The registrant shall comply with all applicable control device and enussion reduction device requirements provided in section 7.0 of this general permit for any control devic~ and emission reduction device used to control emissions from the dehydration unit and that is listed in the G35-C General Permit Registration. Compliance will be demonstrated according to the requirements listed in Section 7.0 of this general permit. 14.1.6. Maximum Glycol Recirculation Rate. The maximum glycol recirculation rate shall not exceed the gallons pet minute limit listed in the registrant's G35-C general permit registration. Compli~ncewith the Maximum Glycol Recirculation Limitation shall be determined using an average of a minimum of quarterly readings of the actual glycol pump(s) rate. If more than one pump is operating simultaneously then the rate of each operating pump shall be recorded and totaled for compliance purposes. 14.2. Monitoring Requirements 14.2.1. To demonstrate compliance with section 14.1.2 of this general permit, the registrant shall monitor the throughput of dry natural gas fed to the dehydration system on a monthly basis for each glycol dehydration unit listed in the G35-C General Permit Registration. 14.2.2. Representative gas sample collection and analysis frequency for dehydration units shall be determined as set forth in the schedule provided in Table 14.2.2 of this section. West Virginia Department of Environmental Protection· Division of Air Quality -383- 370f39 G35-C . Natural Gas Compressor andlor Dehydration Facility Table 14.2.2 Wet Gas Sampling and Analysis Frequency for Dehydration Units Based on Potential HAP Emission Rates Each dehydration unit exempt from § 63.764(d) requirements and with federally enforceable controls Each dehydration unit exempt from § 63.764(d) requirements and without federally enforceable controls Upon request by the Secretary. An initial compliance evaluation within 180 days of registration issuance or within 180 days of start-up of the dehydration unit, whichever is later. 14.2.3. To demonstrate compliance with area source status and the benzene exemption in 14.1.4.c, the following parameters shall be measured at a minimum frequency of once per quarter, with the exception of natural gas flowrate annual daily average, natural g~ flowrate maximum design capacity and wet gas composition, in order to define annual average values or, if monitoring is not practical, some parameters may be assigned default values as listed below. a. b. c. d. e. f. g. h. i. Natural Gas Flowrate i. Operating hours per quarter ii. Quarterly throughput (MMscfJquarter) iii. Annual daily average (MMscf/day), and iv. Maximum design capacit)' (MMscfJday) Absorber temperature and pressure Lean glycol circulation rate . Glycol pump type and maximum design CIlPW;;lty (gpm) Flash tank temperature and pr~iJre, if applicable StrippiPg Gas flO'Wrate, if applicable Wet gas composition (upstream of the absorber - dehydration column) sampled in accordruwe with GPA method 2166 and analyzed consistent with GP A extended method 2286 as well as the procedures presented in the GRI-GLYCaIcTM Technical Reference User Manual and Handbook V4 Wet gas water content (lbs H 20lMMscf) Dry gas water content (lbs H 2 0IMMscf) at a point directly after exiting the dehydration column and before any additional separation points The following operating parameter(s) may be assigned default values when using GRI-GLYCalc: a. b. c. d. Dry gas water content can be assumed to be equivalent to pipeline quality at 7 lb H 20 / MMscf Wet gas water content can be assumed to be saturated Lean glycol water content if not directly measured may use the default value of 1.5 % water as established by GRI Lean glycol circulation rate may be estimated using the TEG recirculation ratio of 3 gal TEG lib H 20 removed. Note: If you are measuring and using actual wet or dry gas water content, then you should also measure the glycol circulation rate rather than using the default TEG recirculation ratio. [45CSR§13-5.11, §63.772(b)(2)(i)] West Virginia Dep~ent of Environmental Protection· Division of Air Quality -384- 380f39 G35-C Natural Gas Compressor and/or Dehydration Facility 14.3. Testing Requirements 14.3.1 . The registrant shall sample wet natural gas in accordance with the Gas Processor Association (GPA) Method 2166 and analyze the samples in accordance with GPA Method 2286. The registrant may utilize other equivalent methods provided they are approved in advance by DAQ as part of a testing protocol. If alternative methods are proposed, a test protocol shall be submitted for approval no later than 60 days before the scheduled test date. Note: The DAQ defines a representative wet gas· sample to be one that is characteristic of the average gas composition dehydrated throughout a calendar year. If an isolated sample is not indicative of the annual average composition, then a company may opt to produce a weighted average based on throughput between multiple sampling events, which can be used to define a more representative average annual gas composition profile. 14.4. Recordkeeping Requirements 14.4.1. The registrant shall maintain records of the monthly dry natural ga" throughput through the glycol dehydration unites), all monitoring data, wet gas 8ampling, and GRI-GLYCalc™ emission estimates. Said records shall be maintained in accordance with section 3.5.1 of this general permit. 14.5. Reporting Requirements . :.:,, " 14.5.1. The registrant shall submit the ""'et gas analysis report required by section 14.2 of this general permit within 60 days of conducting the sampling of the \\'Ot gas stream as required. This report shall include a potential to emit (PTE) estimate using GRI-GlyCalc Version 3.0 or higher, incorporating the specific parameters meaS~as well as a copy of the laboratory analysis. 14.5.2. If the results of the cODlJlliance determuiation conducted as required in Section 14.2 of this general permit predict the emissions to b¢ at or above 95% of HAPs major source levels or 0.95 tons per year of benzene, the registrant shall submit such determination and all supporting documentation to the Secretary within 15 days after making such determination. West Virginia Department of Environmental Protection· Division of Air Quality -385- G35-C Natural Gas Compressor and/or Dehydration Facility 390f39 CERTIFICATION OF DATA ACCURACY I, the undersigned, hereby certify that, based on information and belief formed after reasonable inquiry, all information contained in the attached _ __ _ _ __ _ _ _ _ _ _ _ _ _" representing the period beginning _ _ _ _ _ _ _ __ _ _ and ending _ _ __ _ _ _ _ _ _ _,' and any supporting documents appended hereto, is true, accurate, and complete. Signature! (please use blue ink) Responsible OffICial or Authorized Repres~tative Oit. Name & Title (plea•• print or type) ,itl. Name FuNo . _______________________ Telephone No. This form shall be signed by a "Responsible Official:' "Responsible Offk.ial" means one of the following: a. For a corporation: The president, secretary, treasurer, or vi<»-pre8ident of the corporation in charge of a principal business function.. (lr any other perSOll; who perform€> similar policy or decision-making functions for the corporation, or a duly authorized representative of such person if the representative is responsible for the overall operation of one or more manufacturing, production, or operating facilities applying for or subject to a permit and either: (i) the facilities employ more than 250 persons or have a gross annual sales or expenditures exceeding $25 million (in second quarter 1980 dollars), or (ii) the delegation of authonty to such representative is approved in advance by the Director; b. For a partnership or sole proprititorsbip: a general partner or the proprietor, respectively; c. For a municipality, State. Federal, or other public entity: either a principal executive officer or ranking elected official. For the purposes of this part, a principal executive officer of a Federal agency includes the chief executive officer having responsibility for the overaIl operations of a principal geographic unit of the agency (e.g., a Regional Administrator of U.S. EPA); or d. The designated representative delegated with such authority and approved in advance by the Director. West Virginia Department of Environmental Protection' Division of Air Quality -386- cJep west virginia department of environmental protection Division of Air Quality 60 I 57dl Street SE Charleston, WV 25304 Phone (304) 926-0475· FAX: (304) 926-0479 Earl Ray Tomblin. Governor Randy C. Huffman, Cabinet Secretary www.dep.wv.gov GENERAL PERMIT G35-C ENGINEERING EVALUATION / FACT SHEET BACKGROUND INFORMATION General Permit No.: Class II General Permit G35-C (Prevention and Control of Air Pollution in regard to the Construction, Modification, Relocation, Administrative Update and Operation of Natural Gas Compressor and/or Dehydration Facilities) The Secretary may develop and issue Class I and Class II general permits under 45CSR13 authorizing the construction, modification or relocation of a category of sources by the same owner or operator or involving the same or similar processes or pollutants upon the terms and conditions specified in the general permit. Eligible SIC and NAICSCodes: NAICSCode 211111 213112 221210 486210 SIC Code 1311 1382,1389 4923 4922 Description Crude Petroleum and Natural Gas Extraction Support Activities for Oil and Gas Operations Natural Gas Distribution Pipeline Transportation of Natural Gas Engineer Assigned: Jerry Williams, P.E. G35-C Registration Fee Amount: $500 (Construction, Modification, and Relocation) $300 (Class II Administrative Update) $1,000 NSPS fee for 40 CFR60, Subpart IIII I $1,000 NSPS fee for 40 CFR60, Subpart J J J J 1 $1,000 NSPS fee for 40 CFR60, Subpart 0000 1 $2,500 NESHAP fee for 40 CFR63, Subpart ZZZZ 2 $2,500 NESHAP fee for 40 CFR63, Subpart HH 2 I Only oneNSPS fee will apply. NESHAP fee will be w~ived for 2 Only one NESHAP fee will apply. The Subpart new engines that satisty requirements by complying with NSPS, Subparts IIlI and/or JJ11. zzz:z -387- Description: General Permit G35-C replaces previously noticed General Permit G35-B with the inclusion oflanguage to address potential noise and light issues. This language can be found in Section 3.2.8. General Permit G35-C is for natural gas compressor and/or dehydration facilities. Currently, General Permit G30-D and G35-A cover natural gas compressor and/or dehydration facilities. These General Permits will continue to exist, however, there· will be no future registrations, modifications, or administrative updates allowed to registrations issued under these permits. If a registrant wishes to modify an existing registration under General Permits G30-D ot G35-A, it must be done so under General Permit G35-C. General Permit G35-C activities may include: Natural gas compressor station activities are reciprocating internal combustion engine driven compressor(s) or combination of equipment (including but not limited to compressor engines, emergency standby generators, engine driven air compressors, boilers, line heaters, tanks, glycol dehydration units, air pollution control devices, etc.) that supplies energy to move natural gas at increased pressure from gathering systems, in transmission pipelines or into storage. The permission/approval for Gas Well Drilling is not part of this.general permit and is handled by the WV DEP, Office of Oil and Gas. General Permit G35-C terms and conditions are the same for all facilities that receive a registration to General Permit G35-C. General Permit G35-C allows registrants to install and operate specified equipment, air pollution control devices and/or emission reduction devices to control emissions of regulated pollutants into the air. Each General Permit G35-C registration will list all emISSIOn units, air pollution control devices and/or emission reduction devices and will specify which sections of the general permit are applicable to the particular facility based on equipment that will be operated at that facility. General Permit G35-C registration will .also include the emission limits and throughputs for the emission units. General Permit G35-C will undergo public notice prior to being issued. The public notice will appear in the Charleston Gazette, Dominion Post (Morgantown), Herald Dispatch (Huntington), Intelligencer (Wheeling), Parkersburg News, Exponent/Telegram (Clarksburg), Journal (Martinsburg), Herald Record (Doddridge County), Wetzel Chronicle Moundsville Daily Echo (Marshall County), and (Wetzel County), The State Register consistent with other General Permit public notices. Page 2 of19 -388- EMISSION SOURCES AND G35-C GENERAL PERMIT ELIGIBILTY Emission units at eligible oil and natural gas production, compressor and/or dehydration facilities may include any of the following pieces of equipment: • Storage vessel affected facility(ies) • Natural gas driven pn~umatic controller affected facility(ies) • Natural gas in-line heater(s) • Natural gas production unites) (GPU) • Natural gas heater treater(s) • Low pressure tower(s) • Tanker truck loading facility(ies) • Reciprocating internal combustion engine(s) (RICE) (including emergency) • Glycol dehydration unites) and associated reboiler(s) • Reciprocating compressor(s) • Centrifugal compressor(s) • Generator engine(s) There may be other small storage tanks located at the site for the storage of freeze protection materials and lubricants. These units shall be listed in the registration application and will be included in the issued registration document. Air pollution control and emission reduction devices may include: • Completion combustion devices • Enclosed combustion devices including thermal vapor incinerators, catalytic vapor incinerators, boilers, and process heaters • Flares • Vapor recovery devices including carbon adsorption systems and condensers • Post-combustion catalytic control technologies for reciprocating internal combustion engines: Rich-burn engine with Nonselective Catalytic Reduction (NSCR); Leanburn engine with Selective Catalytic Reduction (SCR); Lean-burn engine with Catalytic Oxidation For the purposes of General Permit G35-C, a natural gas compressor station means any reciprocating internal combustion engine driven compressor(s) or combination of equipment (including but not limited to compressor engines, emergency standby generators, engine driven air compressors, boilers, line heaters, tanks, etc.) that supplies energy to move natural gas at increased pressure from gathering systems, in transmission pipelines or into storage. Engine means any natural gas compressor engine, emergency standby engine or air compressor engine located at a natural gas compressor station. This does not include permitting for or approval of the natural gas well drilling that is handled by the Office of Oil and Gas. Page 3 of19 -389- All natural gas compressor and/or dehydration facilities designed and operated for the purpose of gathering, transmitting, or compressing natural gas and are included in the following NAICS and/or SIC Codes are eligible for General Permit Registration except for those instances listed in items 1-7 below: NAICS Code SIC Code 211111 1311 213112 1382, 1389 221210 486210 4923 4922 Description Crude Petroleum and Natural Gas Extraction Support Activities for Oil and Gas Operations Natural Gas Distribution Pipeline Transportation of Natural 1. Any natural gas compressor and/or dehydration facility which is a major source of pollutants as defined in 45CSR14, 45CSR19, or 45CSR30. 2. Any natural gas compressor and/or dehydration facility that is located in Putnam County, Kanawha County, Cabell County, Wayne County, or Wood County and is required by 45CSR21 to conduct a Reasonably Available Control Technology (RACT) Analysis and/or subject to 45CSR21 Section 29 (Leaks from Natural Gas/Gasoline Processing Equipment). 3. Any natural gas processing plant (e.g. production of ethane, propane, butane, and pentane) as defined in 40 CFR §60.5430. 4. Any natural gas sweetening plant. 5. Any natural gas compressor and/or dehydration facility with a storage tank subject to NSPS, Subpart Kb. 6. Any steam generating unit (as defined in §60.41c) subject to NSPS, Subpart Dc (>10 MMBTU/hr). 7. Any turbine subject to NSPS, Subpart KKKK. 8. Any natural ga$ compressor and/or dehydration facility which will require an individual air quality permit review process and/or individual permit provisions to address the emission of a regulated pollutant or to incorporate regulatory requirement(s) other than those established by General Permit G35-C. This would include "synthetic minor" permitting actions, as they are required to undergo Notice Level C under 45CSR13 Section 8.5. Page 4 of 19 -390- SITE INSPECTION All persons submitting a G35-C General Permit Registration Application to construct, modify or relocate a natural gas compressor and/or dehydration facility shall be subject to the following siting criteria: • No emission unit shall constructed, located or relocated within three hundred (300) feet of any occupied dwelling, business, public building, school, church, community building, institutional building or public park. An owner of an occupied dwelling or business may elect to waive the three hundred (300) foot siting criteria. • Any person proposing to construct, modify or relocate any emission unit(s) within three (300) feet of any occupied dwelling, business, public building, school, church, community, institutional building or public park may elect to obtain an individual permit pursuant to 45CSR13. The registrant shall allow any authorized representative of the Secretary, upon the presentation of credentials and other documents as may be required by law, to perform the following : • At all reasonable times, enter upon the registrant's premises where a source is located or emissions related activity is conducted, or where records must be kept under the conditions of this permit. • Have access to and copy, at reasonable times, any records that must be kept under the conditions of this General Permit. • Inspect, at reasonable times, any facilities, equipment (including monitoring, air pollution control devices and emission reduction devices), practices, or operations regulated or required under this General Permit. • Sample or monitor, at reasonable times, substances or parameters to determine compliance with the permit or applicable requirements, or ascertain the amounts and types of air pollutants discharged. ESTIMATE OF EMISSIONS BY REVIEWING ENGINEER Sources of emissions at eligible natural gas compressor and/or dehydration facilities may include pneumatic controllers, GPUs, heater treaters, RICEs, generators (including emergency), glycol dehydration units, storage tanks, truck loading facilities, vapor recovery units, vapor combustors, and other specified control or emission reduction devices. Sources of fugitive emissions may include loading operations, haul road emissions, equipment leaks, and blowdown emissions. An estimate of the maximum potential emissions of regulated air pollutants must be submitted with each General Permit G35-C registration application. Applicants are required to submit emission estimates and supporting calculations for each emission point and for the fugitive emissions at the facility. These emissions will be Page 5 of 19 -391- by the assigned DAQ permit engineer to determine if the registrant meets the requirements of General Permit G35-C prior to recommending whether or not the general permit registration should be issued. Each General Permit G35-C registration application must include the basis of the emission calculations used to determine the·potential emissions (i.e. manufacturer's data, GlyCalc, AP-42, ProMax., E&P Tanks, HYSYS, USEPA Tanks, etc.). The maximum potential emissions after controls shall not equal or exceed 100 tons per year of any regulated air pollutant, 10 tons per year of any hazardous air pollutant (HAP), or 25 tons per year of any combination of hazardous air pollutants (HAPs). CONTROL DEVICES AND EMISSION COLLECTION EFFICIENCIES Applicants are required to submit all technical data for control devices and emission reduction devices that are used for the supporting calculations for each emissions point and for each type of fugitive emissions at the facility. The following control device and emission collection efficiencies will be allowed under General Permit G35-C and all requirements are detailed in Section 7.0 of General Permit G35-C, including requirements for closed vent systems: Flares All flares that meet the control device requirements under 40CFR Subpart 60.18 may claim a destruction efficiency of98% for VOCs and HAPs. Vapor Combustors and flares that do not meet the requirements under 40CFR Subpart 60.18 must be non-smoking and may claim a destruction efficiencyof98% for VOCs and HAPs. Enclosed Combustion Devices All enclosed combustion control devices meeting the requirements outlined in Section 7.0 of General Permit G35-C may claim a capture and control efficiency of98% for VOCs and HAPS. Vapor Recovery Units • The registrant may claim a capture and control efficiency of95% (which accounts for 5% expected downtime). • The registrant may claim a capture and control efficiency of98% if the VRU has a backup flare that meet the requirements of section 7.1.2 ofthis general permit. • The registrant may claim a capture and control efficiency of98% if the VRU has a backup VRU. Carbon Adsorption Systems All carbon adsorption systems meeting the requirements outlined in Section 7.0 of General Permit G35-C may claim a control efficiency of98% for VOCs and HAPS. Condensers Any condenser that is utilized under Section 7.0 of General Permit G35-C must have supporting data submitted with the registration application to support the claimed control device efficiency above 50%. Page 6 of19 -392- Truck Loadout Collection Efficiencies The following applicable capture efficiencies ofa truck loadout are allowed: • • • For tanker trucks not passing one ofthe annual leak tests in G35-C - 70% For tanker trucks passing the NSPS level annual leak test - 98.7% For tanker trucks passing the MACT level annual leak test - 99.2% Compliance with this requirement shall be demonstrated by keeping records of the applicable MACT or NSPS Annual Leak Test certification for every truck loaded/unloaded. This requirement can be satisfied if the trucking company provided certification that its entire fleet was compliant .. This certification must be submitted in writing to the Director of the DAQ. SOURCE AGGREGATION DETERMINATION Applicants for the General Permit G35-C registration will be required to complete the Single Source Determination form which is part of the General Permit G35-C application. This completed form will allow the DAQ to make a determination as to whether or not the facility is a single source. "Building, structure, facility, or installation" is defined as all the pollutant emitting activities which belong to the same industrial grouping, are located on one or more contiguous and adjacent properties, and are under the control ofthe same person. REGULATORY APPLICABILITY The following state and federal regulations may apply to sources requesting registration under . General Permit G35-C: State Regulations: 45CSR2 (To Prevent and Control Particulate Air Pollution From Combustion of Fuel in Indirect Heat Exchangers) 45CSR2 establishes emission limitations for smoke and particulate matter that are 4Iri.ec1D.fngl:dburning units. Sources subject to 45CSR2 include GPUs, in-line heaters, heater treaters, and glycol dehydration reboilers. Registered fuel burning units may be subject to the weight emission standard for matter set for1}blainti4tirasR2-4.1. The particulate matter emission standard set forth in generally less ~ti~an the potential emissions from the fuel burning unit utilizing gas; therefore,tW1ilyahe potential emissions from the fuel burning unit will be included in general permitlregistration. Each registrant is subject to the opacity requirements set forth in 45CSR2, Section 3.1. The A general pen6BOncludes the opacity limit along with the monitoring, recordkeeping, and reporting requirements in"Section 8.0. Page 70f19 -393- 4SCSR4 (To Prevent and Control the Discharge of Air Pollutants into the Open Air which Causes or Contributes to an Objectionable Odor or Odors) 45CSR4 states that an objectionable odor is an odor that is deemed objectionable when in opinion of a d~ authorized representative of the Air Pollution Control Commission Air Quality), l(JimdsiIpDnftheir investigations and complaints, such odor is objectionable. facilities are i~jiected by the DAQ Enforcement Section. The facility-wide requirements of general permitlinclude the odor standards of 45CSR §4-3.1. 4SCSR6 (To Prevent and Control Air Pollution from the Combustion of Refuse) 45CSR6 prohibits open burning, establishes emission limitations for particulate matter, establishes oparitly requirements. Sources subject to 45CSR6 include completion devices, enclosmha:bmliwtion devices, and flares. The facility-wide requirements of the general permit include the open burning limitations 6-3.1 and 3.2. §§45All completion combustion devices, enclosed combustion devices, and flares are subject to particulate matter weight emission standard set forth in §45-6-4.1; the opacity in §§45-6-4-3 nqut~1mtllisible emission standard in §45-6-4.5; the odor standard in §456-4.6; and, the testing standard in §§45-6-7.1 and 7.2. Enclosed combustion control devices and flares that are used to comply with emission standards ofNSPS, Subpart 0000 are subject to design, operational, performance, recordkeeping and rep9rting requirements of the NSPS regulation that meet or exceed the requirements of 45CSR6. 4SCSRIO (To Prevent and Control Air Pollution from the Emission of Sulfur Oxides) 45CSR1O establishes emission limitations for S02 emissions which are discharged from stacks of fuel burning units. A "fuel burning unit" means and includes any furnace, boiler apparatus, device, mechanism, stack or structure used in the process of burning fuel or other combustible material for the primary purpose of producing heat or power by indirect heat transfer. Sources that meet the definition of "Fuel Burning Units" per 45CSRIO-2.8 include GPUs, in-line heaters, heater treaters, and glycol dehydration unit reb oilers. Fuel burning units less than 10 MMBtu/hr are exempt. The sulfur dioxide emission standard set forth in 45CSRIO is generally less stringent than the potential emissions from a fuel burning unit for natural gas. The S02 emissions from fuel burning units will be listed in the G35-C.permit registration at the discretion of the permit engineer on a caseby-case basis. Issues such as non-attainment designation, fuel use, and amount of sulfur dioxide emissions will be factors used in this determination. Fuel burning units burning natural gas are exempt from Section 8 (Monitoring, Recording and Reporting) as well as interpretive rule lOA. The G35-C eligibility requirements exclUde from eligibility any fuel burning unit that does not use natural gas as the fuel; therefore, there are no permit conditions for 45CSRI0. Page 8 of 19 -394- 45CSR13 (Permits for Construction, Modification, Relocation and Operation of Stationary Sources of Air Pollutants, Notification Requirements, Administrative Updates, Temporary Permits, General Permits, and Procedures for Evaluation) As provided in 45CSR13 §5.12, the Secretary may develop and issue Class I and Class II general permits under this rule authorizing the construction, modification, relocation, and operation of a category of sources by the same owner or operator or involving the same or similar processes or pollutants upon the terms and conditions specified in the general permit. The designation of Class lor Class II for a general permit is made at the time the permit goes through public comment and adoption for the source category governed by the general permit. The designation for General Permit G35-C is Class II. The scope of General Permit G35-C is for minor stationary sources that are not subject to 45CSR14, 45CSR19, or 45CSR30. The general conditions of Section 2.0 and the facilitywide requirements of Section 3.0 of General Permit G35-C include the authority and other general provisions of 45CSR13. The G35-C Class'n General Permit will undergo public notice in accordance with the Notice Level B provisions of subsection 8.4 and in accordance with 45CSR13 §8.9. At the time that an application for a Class II general permit registration is submitted by the applicant, the applicant shall place a Class I legal advertisement in a newspaper of general circulation in the area where the source is or will be located. No such general permit registration shall be issued to any applicant until at least thirty (30) days notice has been provided to the public in accordance with the requirements of 45CSR13 §8.3 for Notice Level A. Class II general permit registrations are subject to a $500 application fee and any applicable additional fees under the provisions of subdivision 3A.b of 45CSR22 in accordance with 45CSR13 §12.1. The possible additional fees are a $1,000 NSPS fee for applicants subject to NSPS requirements and a $2,500 NESHAP fee for applicants subject to NESHAP requirements. For eligible registrants, General Permit G35-C Registration satisfies the construction, modification, relocation and operating permit requirements of 45CSR13. General Permit G35-C sets forth reasonable conditions that enable eligible registrants to establish enforceable permit limits. Section 5 of 45CSR13 provides the permit application and reporting requirements for construction of and modifications to stationary sources. No person shall cause, suffer, allow or permit the construction, modification, relocation and operation of any stationary source to be commenced without notifying the Secretary of such intent and obtaining a permit to construct, modify, relocate and operate the stationary source as required in the rule or any other applicable rule promulgated by the Secretary. Stationary source means, for the purpose of this rule, any building, structure, facility, installation, or emission unit or combination thereof, excluding any emission unit which falls below the criteria delineated in Table 45-13B which: (a) is subject to any substantive requirement of an emission control rule promulgated by the Secretary; (b) discharges or Page 9 of 19 -395~ potential to discharge more than six (6) pounds per hour and ten (10) tons per year, or has the potential to discharge more than 144 pounds per calendar day of any regulated air pollutant; (c) discharges or has the potential to discharge more than two (2) pounds per hour or five (5) tons per year of hazardous air pollutants considered on an aggregated basis; (d) discharges or has the potential to discharge any air pollutant(s) listed in Table 4513A in the amounts shown in Table 45-13A or greater; or, (e) an owner or operator voluntarily chooses to be subject to a construction or modification permit pursuant to this rule, even though not otherwise required to do so. 45CSR16 (Standards of Performance for New Stationary Sources Pursuant to 40 CFR Part 60) 45CSRl6 applies to all registrants that are subject to any ofthe NSPS requirements described in more detail in the Federal Regulations section. Applicable requirements of NSPS, Subparts IIII, JJJJ and 0000 are included in General Permit G35-C. Excluded from General Permit G35-C eligibility are any sources that are subject to NSPS, Subparts Dc, Kb, KKK, LLL, or KKKK. 45CSR22 (Air Quality Management Fee Program) 45CSR22 is the program to collect fees for certificates to operate and for permits to construct or modify sources of air pollution. 45CSR22 applies to all registrants. The general permit application fee of$500 is required in 45CSR13 Section 12.1. In addition to the application fee, all applicants subject to NSPS requirements or NESHAP requirements shall pay additional fees of$I,OOO and $2,500, respectively. Registrants are also required to obtain and have in effect a valid certificate to operate in accordance with 45CSR22 §4.1. The fee group for General Permit G35;..C is Group 8D (natural gas compressor stations greater than 1,000 HP) with an annual operating fee of $500 or 9M (all other sources) with an annual operating fee of$200. 45CSR34 (Emission Standards for Hazardous Air Pollutants) 45CSR34 applies to any registrant that is subject to the area source requirements of 40 CFR 63, Subpart ZZZZ or Subpart HH, described in more detail in the Federal Regulations section. WVDAQ does have delegation of the area source requirements of these subparts. 45CSR34 applies to all registrants that are subject to any of the NESHAP requirements. Applicable area source requirements ofNESHAP, Subpart HH and ZZZZ are included in General Permit G35-C. Excluded from General Permit G35-C eligibility are any sources that are subject to NESHAP Subpart HHH. Page 10 of 19 -396- Federal Regulations: 40CFR60 Subpart 1111 (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines) Subpart nn sets forth non-methane hydrocarbon (NMHC), hydrocarbon (HC), nitrogen oxides (NOx), carbon monoxide (CO), and particulate matter (PM) emission limits, fuel requirements, installation requirements, and monitoring requirements based on the year of installation of the subject internal combustion engine. The provisions for stationary compression ignition (CI) internal combustion engines for owners or operators of this Subpart have been included in General Permit G35-C, Section 12.0. 40CFR60 Subpart JJJJ (Standards of Performance for Stationary Spark Ignition Internal Combustion Engines) Subpart J J J J sets forth nitrogen oxides (NOx), carbon monoxide (CO), and volatile organic compound (VOC) emission limits, fuel requirements, installation requirements, and monitoring requirements based on the year of installation of the subject internal combustion engine. The provisions for stationary spark ignition (SI) internal combustion engines for owners or operators of this subpart have been included in General Permit G35. C, Section 12.0. 40CFR60, Subpart 0000 (Standards of Performance for .Crude oil and Natural Gas Production, Transmission and Distribution) o EPA published its new source performance standards (NSPS) and air toxics rules for the oil and gas sector on August 16,2012. EPA published final amendments to the subpart on September 23,2013. 40CFR60 Subpart 0000 establishes emission standards and compliance schedules for the control of volatile organiccoinpounds (VOC) and sulfur dioxide (S02) emissions from affected facilities that commence construction, modification or reconstruction after August 23,2011. The affected sources which commence construction, modification or . reconstruction after August 23,2011 are subject to the applicable provisions ofthis Subpart as described below: a. Each gas well affected facility. Gas well affected facilities are not covered in General Permit G35-C and all applicable requirements are listed in General Permit G70-B. b. Each centrifugal compressor affected facility, which is a single centrifugal compressor using wet seals that IS located between the wellhead and the point of custody transfer to the natural gas transmission and storage segment. A centrifugal compressor located at a well site, or an adjacent well site and servicing more than well site, is not an affected facility under this subpart. Centrifugal compressor affected facilities are included in General Permit G35-C, Section 10.0. Page 11 of19 -397- c. Each reciprocating compressor affected facility, which is a single reciprocating compressor located between the wellhead and the point of custody transfer to the gas transmission and storage segment. A reciprocating compressor located at a well or an adjacent well site and servicing more than one well site, is not an affected under this subpart. Reciprocating compressor affected facilities are included in General PermitG35-C, Section 11.0. d. For the natural gas production segment (between the wellhead and the point of custody transfer to the natural gas transmission and storage segment and not including natural gas processing plants), each pneumatic controller affected facility, which is a single continuous bleed natural gas-driven pneumatic controller operating at a natural gas bleed rate greater than 6 scfh . . Pneumatic controllers affected facilities are included in General Permit G35-C, 9.0. Section e. Each storage vessel affected facility, which is a single storage vessel located in the oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment, and has the potential for VOC emissions equal to or greater than 6 tpy as determined according to this section by October 15, 2013 for Group 1 storage vessels and by April 15, 2014, or 30 days after startup (whichever is later) for Group 2 storage vessels. A storage vessel affected facility that subsequently has its potential for VOC emissions decrease to less than 6 tpy shall remain an affected facility under this subpart. Requirements for storage vessel affected facilities are included in General Permit G35-C, Section 6.0. Determination of storage vessel affected facility status is included in Section 5.0 of General Permit G35-C. f C Processing units and sweetening units are outside the scope of General Permit G35and are excluded from applicability for the general permit. 40CFR63 Subpart HH (National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities) This Subpart applies to owners and operators of each triethylene glycol (TEG) dehydration unit that is located at oil and natural gas production facilities. Only area source requirements are included in General Permit G35-C, as defined in §63.761. For area source applicability, the affected source includes each trietheylene glycol (TEG) dehydration unit located at a facility that meets the criteria specified in §63.760(a). Glycol dehydration unit affected facilities are included in General Permit G35-C, Section 14.0. Page 12 of 19 -398- 40CFR63 Subpart ZZZZ (National Emission Standard.s for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) Subpart ZZZZ establishes national emission limitations and operating limitations for hazardous air pollutants (HAPs) emitted from stationary reciprocating internal combustion engines (RICE) located at major and area sources of HAP emissions. This Subpart also establishes requirements to demonstrate initial and continuous compliance with the emission limitations and operating limitations. This section reflects EPA's final amendments to 40 CFR Part 63, Subpart ZZZZ that were issued on January 15,2013 and published in the Federal Register on January 30, 2013 . . WVDEP DAQ has delegation of the area source air toxics provisions of this Subpart requiring Generally Achievable Control Technology (GACT). The provisions of this Subpart have been included in this general permit under Section 12.0. REGULATORY NON-APPLICABILITY The following state and federal regulations were reviewed but do not apply to General Permit G35-C: 45CSR14 (Permits for Construction and Major Modification of Major Stationary Sources for the Prevention of Significant Deterioration of Air Quality) The G35-C applicability critedon excludes facilities that meet the definition of a major source as defined in 45CSR14 from being eligible for the general permit. . 45CSR19 (Permits for Construction and Major Modification of Major Stationary Sources of Air Pollution which Cause or Contribute to Nonattainment) The G35-C applicability criterion excludes facilities that meet the definition of a major source as defined in 45CSR19 from being eligible for the general permit. 45CSR21 (Regulation to Prevent and Control Air Pollution from the Emissions of Volatile Organic Compounds) It is the intent of the Director that all persons engaged in the manufacture, mixing, storage, use, or application of volatile organic compounds control the emissions of volatile organic compounds through the application of reasonable available control technology (RACT). This regulation applies to sources located in Putnam County, Kanawha County, Cabell County, Wayne County, and Wood County. Section 40 (Other Facilities that Emit Volatile Organic Compound (VOC) applies to any facility that has aggregate maximum theoretical emissions of 100 tons or more ofVOCs per calendar year in the absence of control devices. Any source at a facility subject to Section 40 that has maximum theoretical emissions of6 pounds per hour or more must comply with a control plan developed on a case-by-case basis that meets the definition ofRACT. Page 13 of 19 -399- Any natural gas production, compressor and/or dehydration facility that is located in Putnam County, Kanawha County, Cabell County, Wayne County, or Wood County and is required by 45CSR21, Section 40 to conduct a RACT Analysis and/or subject to 45CSR21 Section 29 (Leaks from Natural Gas/Gasoline Processing Equipment) is excluded from General Permit G35-C applicability; therefore, this rule does not apply. 45CSR30 (Requirements for Operating Permits) The G35-C applicability criterion excludes facilities that meet the definition of a major source from being eligible for the general permit. Certain spark ignition internal combustion engines may be subject to NSPS Subpart nn or J J J J; however, NSPS Subparts nn or J J J J are exempt from Title V permitting for minor sources. Affected facilities that commence construction, modification or reconstruction after August 23,2011 are subject to NSPS, Subpart 0000; however, NSPS, Subpart 00.00 is exempt from Title V permitting for minor sou.rces. Certain spark ignition internal Combustion engines may be subject to 40 CFR 63, Subpart ZZZZ as area sources; however, area sources subject to 40 CFR 63, Subpart ZZZZ are exempt from Title V permitting. Certain area source TEG dehydration units may be subje~t to 40 CFR 63, Subpart HH; however, area sources subject to 40 CFR 63, Subpart HH are exempt from Title V permitting. 40CFR60.18 (General control device and work practice requirements) The requirements apply only to flares that are required for compliance to an NSPS Standard. Completion combustion devices and enclosed combustion devices used for compliance to NSPS, Subpart 0000 do not meet the definition of a flare, as it is defined in that subpart. Therefore, this rule does not apply to General Permit G35-C unless the .applicant states in their general permit application that they are meeting the requirements of §60.18 for flares. 40CFR60, Subpart Dc (Standards of Performance for Small Industrial-CommercialInstitutional Steam Generating Units) Subpart Dc applies to each steam generating unit for which construction, modification, or reconstruction is commenced after June 9, 1989 and that has a maximum design heat input capacity of 100 MMBtu/hr or less, but greater than or equal to 10 MMBtu/hr. Any steam generating unit facility (as defined in §60.41c) is excluded from eligibility to General Permit G35-C. Steam generating unit means a device that combusts any fuel and produces steam or heats water or heats any heat transfer medium. This term includes any duct burner that combusts fuel and is part of a combined cycle system. This term does not include process heaters, as defined in this subpart. Process heater means a device that is primarily used to heat a material to initiate or promote a chemical reaction in which the material participates as a reactant or catalyst. Page 14 of 19 -400- 40CFR60, Subpart Kb (Standards of Performance for VOC Liquid Storage Vessels for which construction, reconstruction, or modification commenced after July 23,1984) Subpart Kb establishes control requirements, testing requirements, monitoring requirements, and record keeping and reporting requirements. Subpart Kb applies to any storage vessel with a capacity greater than 19,313 gallons that is used to store volatile organic liquids except that it does not apply to storage vessels with a capacity greater than 39,890 gallons storing a liquid with a maximum true vapor pressure less than 3.5 kPa or with a capacity greater than 19,813 gallons but less than 39,890 gallons storing a liquid with a maximum true vapor pressure less than 15.0 kPa. This Subpart does not apply to vessels with a design capacity less than or equal to 419,204 gallons used for petroleum or condensate stored, processed, or treated prior to custody transfer: Condensate means hydrocarbon liquid separated from natural gas that condenses due to changes in the temperature or pressure, or both, and remains liquid at standard conditions. Any natural gas production, compressor and/or dehydration facility that is subject to NSPS, Subpart Kb is excluded from eligibility to General Permit G35-C. 40CFR60 Subpart KKK (Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants for which construction, reconstruction, or modification commenced after January 20, 1984 and on or before August 23, 2011) Natural Gas Processing Plants are excluded from General Permit G35-C applicability. Natural gas processing plants were excluded to focus the scope of General Permit G35-C on activities typically conducted at natural gas production, compressor and/or dehydration facilities. Based on the Rule 13 permit applications for new natural gas production, compressor and/or dehydration facilities that WV DAQ has received thus far, this exclusion should not be a concern. Furthermore, any new natural gas processing plant would be constructed, reconstructed, or modified after August 23, 2011 and would no longer be subject to NSPS, Subpart KKK. Requirements for natural gas processing plants constructed, reconstructed, or modified after August 23,2011 are covered by NSPS, Subpart 0000. This rule, therefore, does not apply to General Permit G35-C. 40CFR60, Subpart LLL (Standards of Performance for S02 Emissions From Onshore Natural Gas Processing for Which Construction, Reconstruction, or Modification Commenced After January 20,1984, and on or Before August 23, 2011) Natural Gas Sweetening Units are excluded from General Permit G35-C applicability. Natural gas processing plants and sweetening units were excluded from General Permit G35-C. Based on the Rule 13 permit applications for new natural gas production, compressor and/or dehydration facilities that WV DAQ has received thus fa.r, this exclusion should not be a concern. Furthermore, any new natural gas processing plant or sweetening unit would be constructed, reconstructed, or modified after August 23, 2011 and would no longer be subject to NSPS, Subpart LLL. Requirements for natural gas processing plants and sweetening units constructed, reconstructed, or modified after August 23, 2011 are covered by NSPS, Subpart 0000. This rule, therefore, does not apply to General Permit G35-C. Page 15 of 19 -401- 40CFR60, Su~part KKKK (Standards of Performance for Stationary Combustion Turbines) 40CFR60 Subpart KKKK does not apply because stationary combustion turbines with a heat input at peak load equal to or greater than 10 MMBTU/hr, based on the higher heating value of the fuel (§60.4305) are not covered by this General Permit. This rule, therefore, does not apply to General Permit G35-C. 40CFR63 Subpart HHH (National Emission Standards for Hazardous Air Pollutants: Natural Gas Transmission and Storage) This subpart applies to owners and operators of natural gas transmission and storage facilities that transport or store natural gas prior to entering the pipeline to a local distribution company or to a final end user (if there is no local distribution company), and that are major sources of hazardous air pollutants (HAP) emissions as defined in §63.1271. General Permit G35-C excludes major sources from registration. Therefore, this rule does not apply to General Permit G35-C. TOXICITY OF NON-CRITERIA REGULATED POLLUTANTS Small amounts of non-criteria regulated hazardous air pollutants such as benzene, toluene, and formaldehyde may be emitted when natural gas is combusted in reciprocating engines, combusted in the fuel burning units, or combusted in one of the combustion type air control devices. All natural gas production, compressor and/or dehydration facilities that are issued a General Permit G35-C registration by the Director will be limited to those that are classified as minor sources of hazardous air pollutants. Minor sources of hazardous air pollutants are defined as those that have a potential to emit ofless than 10 tons per year of any hazardous air pollutant or less than 25 tons per year of any combination of hazardous air pollutants. Listed below is information regarding each of the possible hazardous air pollutants. BTEX BTEX is the term used for benzene, toluene, ethylbenzene, and xylene. Each of these possible hazardous air pollutants are identified in this section. Benzene Benzene is found in the air from emissions from burning coal and oil, gasoline service and motor vehicle exhaust. Acute (short-term) inhalation exposure of humans to benzene cause drowsiness, dizziness, headaches, as well as eye, skin, and respiratory tract irritation, at high levels, unconsciousness. Chronic (long-term) inhalation exposure has caused disorders in the blood, including reduced numbers of red blood cells and aplastic anemia, occupational settings. Reproductive effects have been reported for women exposed by to high levels, and adverse effects on the developing fetus have been observed in animal Increased incidence ofleukemia (cancer of the tissues that form white blood cells) have Page 16 of 19 -402- observed in humans occupationally exposed to benzene. EP A has classified benzene as a A, human carcinogen. Toluene The acute toxicity of toluene is low. Toluene may cause eye, skin, and respiratory tract irritation. Short-term exposure to high concentrations oftoluene (e.g., 600 ppm) may produce fatigue, dizziness, headaches, loss of coordination, nausea, and stupor; 10,000 ppm may cause death from respiratory failure. Ingestion oftoluene may cause nausea and vomiting and central nervous system depression. 'Contact of liquid toluene with the eyes causes temporary irritation. Toluene is a skin irritant and may cause redness and pain when trapped beneath clothIng or shoes; prolonged or repeated contact with toluene may result in dry and cracked skin. Because of its odor and irritant effects, toluene is regarded as having good warning properties. The chronic effects of exposure to toluene are much less severe than those of benzene. No carcinogenic effects were reported in animal studies. Equivocal results were obtained in studies to determine developmental effects in animals. Toluene was not observed to be mutagenic in standard studies. Ethylbenzene Ethyl benzene is mainly used in the manufacturing of styrene. Acute (short-term) exposure to ethyl benzene in humans results in respiratory effects, such as throat irritation and chest constriction, irritation of the eyes, and neurological effects, such as dizziness. Chronic (long-term) exposure to ethyl benzene by inhalation in humans has shown conflicting results regarding its effects on the blood. Animal studies have reported effects on the blood, liver, and kidneys from chronic inhalation exposure to ethyl benzene. Limited information is available on the carcinogenic effects of ethyl benzene in humans. In a study by the National Toxicology Program (NTP), exposure to ethyl benzene by inhalation resulted in an increased incidence of kidney and testicular tumors in rats, and lung and liver tumors in mice. EPA has classified ethyl benzene as a Group D, not classifiable as to human carcinogenicity. Xylenes Commercial or mixed xylene usually contains about 40-65% m-xylene and up to 20% each of o-xylene and p-xylene and ethyl benzene. Xylenes are released into the atmosphere as fugitive emissions from industrial sources, from auto exhaust, and through volatilization from their use as solvents. Acute (short-term) inhalation exposure to mixed xylenes in hurnans results in irritation of the eyes, riose, and throat, gastrointestinal effects, eye irritation, and neurological effects. Chronic (long-term) inhalation exposure of humans to mixed xylenes results primarily in central neryous system (CNS) effects, such as headache, dizziness, fatigue, tremors, and incoordination; respiratory, cardiovascular, and kidney effects have also been reported. EPA has classified mixed xylenes as a Group D, not classifiable as to human carcinogenicity. Mixed xylenes are used in the production of ethyl benzene, as solvents in products such as paints and coatings, and are blended into gasoline. Formaldehyde Formaldehyde is used mainly to produce resins used in particle board products and as an intermediate in the synthesis of other chemicals. Exposure to formaldehyde may occur by breathing contaminated indoor air, tobacco smoke, or ambient urban air. Acute (shortchronic (long-term) inhalation exposure to formaldehyde in humans can result in symptoms, and eye, nose, and throat irritation. Limited human studies have reported an association between formaldehyde exposure and lung and nasopharyngeal cancer. Animal Page 17 of19 -403- inhalation studies have reported an increased incidence of nasal squamous cell cancer. EPA considers formaldehyde a probable human .carcinogen (Group Bl). n.:.Hexane n-Hexane is a solvent that has many uses in the chemical and food industries, either in pure form or as a component of commercial hexane. The latter is a mixture that contains approximately 52 % n-hexane; the balance is made up of structural analogs and related chemicals such as methylpentane and methylcyc1opentane. Highly purified n-hexaneis used as a reagent for chemical or chromatographic separations. Other grades of n-hexane are used as solvents for extracting edible fats and oils in the food industry and as a cleaning agent in the textile, furnitur:e, and printing manufacturing industries. Hexane is the solvent base for many commercial products, such as glues, cements, paint thinners, and degreasers. n-Hexane is a minor constituent of crude oil and natural gas and occurs in different petroleum distillates. No data are available regarding the potential toxicity of n-hexane in humans .orally exposed to n-hexane. However, as might be expected for a chemical with such wide application, the potential exists for persons to be environmentally and/or occupationally exposed to n-hexane via other routes of exposure. 2,2,4-Trimethylpentane 2,2,4-Trimethylpentane is released to the environment through the manufacture, use, and disposal of products associated with the petroleum and gasoline industry. During an accident, 2,2,4-trimethylpentane penetrated the skin of a human which caused necrosis of the skin and tissue in the hand and required surgery. No other information is available on the acute (short-term) effects in humans. Irritation of the lungs, edema, and hemorrhage have been reported in rodents acutely exposed by inhalation and injection. No information is available on the chronic (long-term), reproductive, developmental, or carcinogenic effects of2,2,4-trimethylpentane in humans. Kidney and liver effects have been observed in rats chronically exposed via gavage (experimentally placing the chemical in the stomach) and inhalation. EPA has not classified 2,2,4-trimethylpentane with respect to potential carcinogenici ty. AIR QUALITY IMPACT ANALYSIS Air dispersion modeling may be performed when the Director finds existing circumstances and/or submitted data provide cause for an assessment to be made concerning whether a natural gas well production, compressor and/or dehydration facility may interfere with attainment or maintenance of an applicable ambient air quality standard or cause or a violation of an applicable air quality increment from any proposed General Permit action. Factors to be considered when determining whether an ambient air assessment made include: a. b. c. d. Existing air quality of the area Topographic or meteorological factors Maximum emissions Siting criteria Page 18 of 19 -404- DEVELOPMENT OF GENERAL PERMIT G35-C General Permit G35-C was developed with the intention of being comprehensive to address the emission sources that are located at a stationary source oil and natural gas compressor and/or dehydration facility and to provide consistent requirements for facilities within this industry group. General Permit G35-C was developed to address the increasing volume of construction permits for natural gas compressor and/or dehydration facilities. For affected facilities subject to federal air regulations, those sections of General Permit G35-C were developed based on the language from the federal regulations. For emission sources that are not subject to federal requirements, those sections of the general permit were developed based on language that is currently being used in 45CSR13 construction and modification permits to control air pollution at other natural gas production, compressor and/or dehydration facilities with the intention of providing consistent :Ai\Uotlitim;tsagiE4Jes:sddJ.ainti:m~reh'.ermit G35-C win be subject to Sections 1.0,2.0,3.0, and 4.0 of the general permit. Each applicant will select the sections that they are seeking registration for under General Permit G35-C and will do so when they submit the General Permit G35-C registration application: . Section 5.0 Storage Vessels Containing Condensate and/or Produced Water Section 6.0 Storage Vessel Affected Facility (NSPS, Subpart 0000) Section 7.0 Control Devices and Emission Reduction Devices not subject to NSPS, Subpart 0000 Section 8.0 Small Heaters and Reboilers not subject to 40CFR60 Subpart Dc Section 9.0 Pneumatic Controllers Affected Facility (NSPS, Subpart 0000) Section 10.0 Centrifugal Compressor Affected Facility (NSPS, Subpart 0000) Section 11.0 Reciprocating Compressor Affected Facility (NSPS, Subpart 0000) Section 12.0 Reciprocating Internal Combustion Engine(s) (RICE), Generators, Microturbine Generators Section 13.0 Tanker Truck Loading Facility Section 14.0 Glycol Dehydration Units RECOMMENDATION TO DIRECTOR General Permit G35-C meets all requirements of applicable state and federal regulations. Therefore, it is recommended that General Permit G35-C should be issued. Jerry Williams, P.E. Engineer Date Page 19 of19 -405- West Virginia Department of Environmental Protection Division ofAir Quality Randy C. Huffman Cabinet Secretary Earl Ray Tomblin Governor Class II General Permit G35~C Registration to (Construct, Modify, etc.) forthe- . Prevelltion and Control of Air Pollution in·regard to the Construction, Modification, Relocation; Administrative Update and Operatioo of Oil and Natural Gas Compressor and/or Dehydration Facilities The permittee Uit'nt~fied at~he facility listed below is authorized to construct the stationary soiirr::es ojuir pqJ{utants identified herein in accordance ... .with all terms and conditions o/General Permit G35-C. G35-C (Registration Number) Issued to: [Company Name] [Facility Name] [Company ID #1 William F. Durham Director Issued: [Date of Issuance] -406- Class II General Pennit G35-C Natural Gas Compressor and/or Dehydration Facilities Page 2 of 12 This Class II General Permit Registration will supercede and replace (Permit registration number, include any applicable permits, consent orders, etc. These may include R13 permits or versions of the G30 or G35 General Permits) Facility Location: Mailing Address: Physical Address: Facility Description: NAI,CS Code: SIC Code: Longitude Coordinates: Latitude Coordinates: Directions to Facility: Registration Type: Description of Change: (City), (County Name) County, West Virginia (Facility Mailing Address) (Facility Physical Address, ifnone available, list road, city or town and zip offacility) (Facility description (Production, Compressor, Dehydration» (NAICS code) (SIC code) (NAD83, Decimal degrees to 5 digits) (NAD83, Decimal degrees to 5 digits) (Directions to the facility from nearest state road) (Administrative update, construction, modification) (Description of change) Any person whose interest may be affected, including, but not necessarily limited to, the applicant and any person who participated in the public comment process, by a permlt 01' registration issued, modified or aelJied by the Secretary may appeal such action of the Secretary to the Air Quality Board pur~uant to article one [§§ 22B-l-l et seq.], Chapter 22B ofthe Code of West Virginia, Witst Virginia Code §22-5-14. The source is not ,<;uqjf'ct to 45CSR30., West Virginia Department of Environmental Protection· Division of Air Quality -407- Page 3 of 12 Class II General Pennit G35-C ,Natural Gas Compressor and/or Dehydration Facilities Permit Section Applicability for the Registrant All registeredfacilitiesunder General Permit G35-C are subject to Sections 1.0, 2.0, 3.0, and 4.0 of General Permit G35-C. The following additional sections of General Pennit G3S:"C apply to the registrant: ..._.... _._...... _.. .. - o Section 5.0 o Section 6.0 o Section 7.0 D - - ' - "-'-"" "-- Section 8.0 Section 9.0 Section 10.0 Section 11.0 o o o o Section 12.0 o Section 13.0 D Section 14.0 GENERAL PERMIT G35-C APPLICABLE SECTIONS .. •• •• ••.• - ••••• _ •• ' ,_, - . •__ ,,_ . ,". .•••• , M• . •, _•• M._ ,_ M., _ _ .,. M___ ._•• _ •• _._ _ •• _ • Storage Vessels Containing Condensate andlor P rod.uced Water l Storage Vessel Affected Facility (NSPS, Subpart 0(00) --------------------~ Control Devices and Emission Reduction Device s not subject to NSPS Subpart 0000 andlor NESHAP Subpart HH .,. Small Heaters and Reboilers not subject to 40CF R60 Subpart Dc Pneumatic Controllers Affected F~c .i1~ty (NSPS, Subpart 0000) . Centrifugal Compressor Affected Facility (NSPS , Subpart 0000)2 - -. Reciprocating Compressor Affected Fagi:flration and add/delete lines as necessary; (2) remove red font notes prior to bmltlnce. West Virginia Department of Environmental Protection· Division of Air Quality -410- Class II General Pennit G35-C Natural Gas Compressor and/or Dehydration Facilities Page 6 of 12 CENTRIFUGAL COMPRESSORS Are there any applicable centrifugal compressors subject to 40CFR60 Subpart 0000 at this facility not located at the well site/pad? DYes DNo See Section 10.0 Description Notes to permit engineer: (1) customize for specific registration fJ.nd add,delete lines as rit!ct:f.sary; (2) remove red font notes prior to issuance. RECIPROCATING COMPRESSORS Are there any applicable reciprocating compresso,r, subject to 40CFR60 Subp3l't 0000 at this facility not located at the, well ~ite/pad? DYes ONo See Section 11.0 \ ------------------------------------~ Description ------------------------------------~ i -, : ---,-1-,--1/ - ._____. ". 7 - - - -----1 Notes to permit engineer: (1) customize for Spl!cijic registration and add/delete lines as necessary; (2) remove red font notes prior to issuance. West Virginia Department of Environmental Protection· Division of Air Quality -411- Class II General Permit G35-C Natural Gas Compressor and/or Dehydration Facilities Page 7 of 12 RECIPROCATING INTERNAL COMBUSTION ENGINES See Section 12.0 Emission Unit 10# Emission Point 10# Make!Model/UP Control Device 10# Vear Installed! Modified Engine Manufacture Date Subject to 13.1.4, 13.1.1 o Yes •.; . . 0 _ _ _ ' Dyes DNo 01:1- Dyes I-l ~ I r"'\ ,+) Dves o D2SLB D4SRB D2sLB D48LB D No Dves D4SRB D2SLB D4sLB D No D D D D DNew D Existing o - D4SLB D No New or Existing? o t I ZZZZ Applicable Rules 40CFR60 Subpart JJJJ Certified? 40CFR60 Subpart 1II1 D4SLB Certified? 40CFR63 Subpart ZZZZ D4SRB NFSHAP ZZZll NSPS JJJJ Wmdow ,-----t-= D 40CFR60 Subpart JJJJ D2SLB _ D Certified? D 40CFR60 Subpart 1111 D4SLB D Certified? 40CFR63 Subpart ZZZZ D NESHAP ZZZll NSPS JJJJ D4'SRB Window D2SLB D No < • 40CFR63 Subpart Engine Type D4SRB D 40CFR60 Subpart JJJJ D Certified? D 40CFR60 Subpart 1111 D Certified? D 40CFR63 Subpart ZZZZ D NESHAP ZZZll NSPS JJJJ Window . D 40CFR60 Subpart JJJJ D Certified? D 40CFR60 Subpart 1111 D Certified? D 40CFR63 Subpart ZZZZ D NESHAP ZZZZJ NSPS JJJJ Window 40CFR60 Subpart JJJJ Certified? . 40CFR60 Subpart 1111 Certified? 40CFR63 Subpart ZZZZ NESHAP ZZZZ' NSPS JJJJ Window D D D D D o New or reconstructed sources in accordance witk 63. 76590(c) must only meet the requirements of 40CFR60 Subparts IlII or JJJJ. Notes to permit engineer: (1) customize for specific registration and add/delete lines as necessary; (2) remove red font notes prior to issuance. West Virginia Department of Environmental Protection· Division of Air Quality DNew D Existing D New D Existing D New o Existing DNew D Existing Class II General Permit G35-C Natural Gas Compressor and/or Dehydration Facilities Page 8 of 12 SPARK IGNITION RECIPROCATING INTERNAL COMBUSTION ENGINES TESTING REQUIREMENTS .. ---- _ ..•.. -. ,-.- -:--. Emission Unit 10# Emission Point 10# ...- - ..- .•._ - - - - - - -- - -. Make/Model/UP ··--·-··--·---~;-S;ct~-;;lio- Control Device 10# Year Installedl Modified ··· -- - - - Engine Manufacture Date 40CFR60 Subpart JJJJ Testing Requirements o Imtil\I 'Pel formanc(; fest .". ~ " Q Eve..2...!!,7 60 hour~ o)f operation or 3 years (whichever comes first) , 0 Imtial Pel formance T~st . I 0 Every 8,7 60 hours of opel'ation or 3 years (whichever comes first) I 0 Initial Pel formance Test ::-. - :.~ ~~ .,~~.. ..... '. - .~ I --~ ~ ',. .~// . . ,.. . ~ ~ I . " '~ J '. . "~" . .'. J • " . 0--; 1.. i- - L • \~l -,,: ' 0/ ''''---• • _ • .,. . .'" o Every 8 .760 hours of operation ... ' o--_ Initial Pel {'o rmanee Test o E\'elY 8,7 60 hours of operation or 3 years (whichever comes first) 01 3 years (whichever comes first) o Initial Performance Test o EVelY 8.7C60 hours of operation or 3 years (whichever comes first) o Initial Pe formance Test o Every 8" 60 hours of operation or 3 years (whichever comes first) o Initial Pe ;fol~ance Test o Every --8 , ~ 60 hours of operation or 3 years (whichever comes first) ---+'-:.,.. 0 0 o o I 0o . Inih~l Per,r formance Test Every 8,7160 hours of operation or 3 years (whichever comes first) Initial PerrfOl'mance Test Every 8,7160 hours of operation or 3 years (whichever comes first) Initial Perrformance Test Every 8,7160 hours of operation or 3 years (whichever comes first) Notes to permit engineer: (1) customize/or specif ic l'egistraiton lmd add/delete lines as necessary; (2) remove red/ant notes prior to issuance. West Virginia Department of Environmental Protection· Division of Air Quality Class II General Permit G35-C Gas Compressor and/or Dehydration Facilities Page 9 of12 ~ Natural TANKER TRUCK LOADOUT Are there any tanker truck loadout operations at this facility? DYes DNo See Section 13.0 Emission Unit ID# Emission Point ID# Description Year Installedl Modified -Annual Throughput Limit (gallyr) -Control Device ID# l Closed System Collection? /' I ~ r I 0 Tanker trucks passing the MACT level annual leak test 0 Tanker trucks passing the NSPS level annual leak test ranker trucks not passing one of the above annual l1'lak tests but has vapor t'etlll'll o ------' Notes to permit engineer: (1) customize for specific registration and ada/delete lines as necessary; (2) remove red font notes prior to issuance. West Virginia Department of Environmental Protection· Division of Air Quality -414- Class II General Permit G35-C Natural Gas Compressor and/or Dehydration Facilities Page 10 of 12 GL YCOL DEHYDRATION UNITS --_.- -- _.. ------- - . ._ .._-. _- _.- .-. - . - - _.- _. -_¥ --- -. -_. - -- - Are there any gly~ol dehydration units at this 1acility? Dyes DNo See Section 14.0 Emission Unit 10# Emission Point 10# Description (Make, Model) I SUb~ect Year Installed/ Modified , ,L ,. \',. ~~, \'LL~ '. \, \\ I ,.. 0l;Io. / til I ---- 1 - / .~ ," .I ./-'--......... 4~ to FR63 Subpart HI ?I -"DYes ,timization D Pump Optimil DNa " Dyes D Pump OphDlUi :mi.ution DNo Dyes 0 Pump Optim zation I DNo ' \ - . Dyes· . , ' I D Pump Optim lzatlon . 40CFR63 Subpart HH Enmption.. Max Dry Gas Flow Rate (mmscf/day) D Benzene E"(emption o flowrate Exemption o Benzene Exemption o Flowrate Exemption o Benzene Exemption D Flowrate Exemption D Benzene Exemption D Flowrate Exemption DNo If Yes, specify if registrant meets benzene or fio\1!rate exemption. Notes to permit engineer: (1) customize for specific registratIOn and add.'delete lines as necessary; (2) remove red font notes prior to issuance. Please list any exemptions « ltpy oj"benzene, 3 mmscflday throughput) and whether or not dehy is located in UA/UC for each unit West Virginia Department of Environmental Protection· Division of Air Quality APCD/ERD ID# Page 11 of 12 Class II General Pennit G35-C ,·Natural Gas Compressor and/or Dehydration Facilities AIR POLLUTION CONTROL DEVICES Are there any air pollution control devices at this facility? DYes ONo See Sec.tions 6.0,7.0 Control Device 10# Control Efficiency Control Device Description (Make/Model) (%) Year Installed/ Modified Max Dnign Capaeity (state anits) ~----------~---+--~~--+-------------------~-------r~ .. ': ------4---------~ Subject to: o Section 7.0 o Section 8.0 o Section 7.0 o Seotion 8.0 o Section 7.0 o Section 8.0 o Section 7.0 0 Section ------,-------1 8.0 ..,..-----...:;'" ..,------:------r-::=_ ... 0 SectlOn 7.0 o Section 8.0 o Section 7.0 o Section 8.0 o Section 7.0 o Section 8.0 I Notes to permit engineer: (1) customize for specific registration and add/delete lines as necessary; (2) remove red font notes prior to issuance. - -- - - .-.. - ..____ _._.REMISSION .... -- .--.-... REDUCTION DEVICES (ERD) . .. ..._. .-- .. - ........- - _ ~ '~-"'- ~-, '" ..... , .-- .. "'R'._ --- - .•.. _.--_. .\re thrre any EROs (VRV, Recycled Reboiler, BTEX Eliminator, etc.) at this facility? DYes ONo See Sections 6.0,7.0 ERD Efficiency (%) ERDID# ERD Description (Make/Model) .. . ' Year Installed/ Modified Max Design Capacity (state units) ----"" Notes to permit engineer: (1) customize for specific registration and add/delete lines as necessary; (2) remove red font notes prior to issuance. West Virginia Department of Environmental Protection • Division of Air Quality -416- Class II General Pennit G35-C Natural Gas Compressor and/or Dehydration Facilities -- ._._,,_._. _ ..._. ''''"' ... ~.-. " ... _-,----.. ........ Page 12 of 12 EMISSION LIMITATIONS _... ...... _.'_.M •....--..-.. _... .,,~ _.w' ._ ' _......_._._...-...._-- ........ ,.. -.- ......-.... .... Maximum Potential Emissions .._._. .._.._.-._..._._._. .... '_,'w' Pollutant Emission Unit ID# Emission Point 10# Emission Unit Description Engine Data ~ Hourly (Ib/hr) -" Annual (tons/year) Nitrogen Oxides Carbon Monoxide Volatile Organic Compounds Formaldehyde Glycol Dehy Still Venti Control Device Data - Volatile Organic Compounds Benzene -- . Toluene Ethylbenzene - Xylenes Storage Vessels I Control Device Data Tanker TIUCk Loading / Control Device Data - Volatile Organic Compounds ., Total HAPs I ---. Volatile Organic Compounti') Total HAPs Control Device Emission Data (Flares, pilots, etc.) '.,~ - ;,,' '. .. ~--'- --.' ........ " .. I . _ .: .............. Note to permit engineer:(l) customize- ,tor .specific regist....ation and add/delete lines as necessary; (2) emission limits are required/or condensate storage ttlnk(s); (3) remove red font notes prior to issuance. West Virginia Department of Environmental Protection· Division of Air Quality -417- ' ~ .... Division of Air Quality 60 I 57 lh Street SE Charleston, WV 25304 Phone (304) 926-0475 Fax (304) 926-0479 www.dep.wv.gov ,l~ :.~'. . west virginia department of environmental protection ""- dep G35-C GENERAL PERMIT REGISTRATION APPLICATION PREVENTION AND CONTROL OF AIR POLLUTION IN REGARD TO THE CONSTRUCTION, MODIFICATION, RELOCATION, ADMINISTRATIVE UPDATE AND OPERATION OF NATURAL GAS COMPRESSOR AND/OR DEHYDRATION FACILITIES OCLASS I ADMINISTRATlVEVPDATE OCLASS II ADMINISTRI\TIVE UPDATE OCONSTRUCTION OMODIFICATION ORELOCATION . _., - ..-. .. ~.- - SECTION 1. GENERAL INFORMATION ~- - - - -_. - Name of Applicant (as registered with the WV Secretary of State's Office): ~F_e_de_r_a_I_E_m~p_lo_y_e_r_I_D_N__o_._(F_E_I_N_)_:~__________~~----------, ~~------------------~ Applicant's Mailing Address: I State: City: ZIP Code: Facility Name: - Operating Site Physical Address:' Ifnone available, list road, city or town and zip of facility. -' .. ' - 'c-- - - - - - - - - - - I City: Zip ('ode: --------------Latitude & Longitude Coordinates (NAD83, Decimal Degrees to 5 digits): Latitude: ., , , Longitude: .. _''_" '" SIC Code: ' DAQ F_BC .'l.'l.i_tY.ID No. (For eXisting facilities) _ . . -_._.- . . . - -_ .. _.-._" . - ... _- - -- - - --- -CERTInCATION OF INF'ORMAHO~ NAICS Code: - ~ _. _ _ . -.--~-.~-. '._ • R" • "'_ ~--- - - -- - " _ '_ _" . ' ._ _ _ • [ . ., . _ •• _ ..... .. .. . _ ._ ____ . _ 0 '''0- _ ' .- ........ r __ _ _ ••• _ • "'_','''.'''' . _• • • • 0.,". _ • • ." .¥. This G35-C General Permit Regi~~t"aijon Application shall be signed below by a Responsible Official. A Responsible Official is a President, Vice President, Secretary, Treasurer, G~neral Partner, General Manager, a member of the Board of Directors, or Owner . depending on buslnCSi!f,structure. A business may certify an Authorized Representative who shall have authority to bind the (orporation,'P,utnership, Limited Lidbility Company, Association, Joint Venture or Sole Proprietorship. Required records of daily throughput, hours ofi)peration and maintenance, general correspondence, compliance certificatio.ns a.~daH requiredUfitifications mustbe'signed by a Responsible Official or an Authorize'd Representative. If a business wishi1$ to'celtif)' an Auth1 Burning Unft(.~J 'Data Sheet (GPUs, H'e ater Treaters, In-Line Heaters if applicable) . Attachment L o Internal Combu~tion Engine Data Sheet(s) (include manufactulet' f'i:l'formance data sheet(s) if applicable) Attachment M -. "~---- D Tanker Truck Loading Data Sheet (if applicable) - Attachment N .. . -... -. ..... .. -------------;::-:--------------------------1 o Glyccl Dehydration Unit Data Sheet(s) (include wet gas ana'lysis, GRI- GLYCalc™ input and output reports and - information on leboil'er ifapplicable) _. Attachment 0 , .. ' . o'Pneumatic Controllers Dot.t a .S heet - - - - - - - - .. . . ' --- - -- -- - - - -- -- - - - -- -- -- - --------j Att..chment p. I] Air Pollution Control DevlI:elEmission Redu(;'tion Device(s) Sheet(s) (include manufacturer performance data sheet(s) if applicable) - Attachment Q I---'-' - .. .... ~ - -- o Emis!sion Calculations (pleue~e specific and include all calculation methodologies used) - Attachment R o Facility.wide Emission Summary Sheet(s) - Attachment S ----------------------------------------------------------j o Class I Legal Advertisement - Attachment T - - ----------------------------------------------------~ DOne (I) paper copy and two i 2) copies of CD or DVD with pdf copy of application and attachments All attachments must be identified by name, dividedinto sections, and submitted in order. 2 -419- ; ATTACHMENT A- SINGLE SOURCE DE.TERMINATION FORM Classifying multiple facilities as one "stationary source" under 45CSR13, 45CSR14, and 4..5CSR19 is based on the definition of Building, structure, facility, or installation as given in §45-14-2.13 and §45-19-2.12. The definition states: "Building, Structure, Facility, or Installation" means all of the pollutant-emitting activities which belong to the same industrial grouping, are located on one or more contiguous or adjacent properties, and are under the control ofthe same person (or persons under common control). Pollutant-emitting activities are a part of the same industrial grouping if they belong to the same "Major Group" (i. e., which have the ·'1ame two (2)-digit code) as dfscribed in the Standard Industrial Classification Manual, 1987 (United States Go-v~rnment Printing Office stock number GPO 1987 O-'i85-718:QL 3). Is there a facility owned by or associated with the natural gas industry located within one (1) mile of the proposed facility? Yes 0 No 0 . IjYes, please complete the questionnaire on the following page (Att~chment Please provide a source aggregation analysis for the proposed facility below: 3 -420- A). ATTACHMENT A -SINGLE SOURCE DETERMINATION FORM . ............... _... - .. __ ..__._...... _-- ._ ...--_.. - .... _ .. ... .. ...... ..._. ,.- ......... .....,- .....-.. .... -...... ...._.. - ._ .._.-_.. _._... ....._....... ..'_. Answer each question with a detailed explanation to determine contiguous or adjacent properties which are under a common control and any support facilities. This section must be completed in its entirety. ...... ........ _.'_....... - , ~ ~ -, , PrO'vide a map O'f cO'ntiguO'us or adjacent facilities (production facilities, compressor statiO'ns, dehydratiO'n facilities, etc.) which are under cO'mmO'n cO'ntrol and those facilities that are nO't under cO'mmon contrO'l but are supPO'rt facilities. Please indicate the SIC code, permit number (if applicable), aqd the distance between facilities in questiO'n on the map. Are the facilities owned by the same parent cO'mpany O'r a subsidiary O'f the parent cO'mpany? ,Provide the O'wners identity and the percentage O'f O'wnership O'f each facility. I Yes 0 NO' 0 Yes 0 NO' 0 Yes 0 NO' 0 Ye, health plans, retirement funds, insurance cO'verage, or O'ther administrative functiO'ns? Please \>,,-plain. , ~, . '- DO'es one (I) facility operation supPO'rt the operation O'f the other facility? Is one (1) facility dependent on the other? If one (I) facility shuts down, what are the limitations on the other to pursue outside business? Please explain 'I.. Are there any financial arrangements between the twO' (2) euttti:<;? " Are there any legal O'r lease agreements between the ty;O'(2) facilities? DO' the facilities share products, byprO'ducts, equipment, cO'ntrol device equipment? Please explain_ Of No 0 - Yes 0 No 0 Yes 0 NO' 0 Yes 0 NO' 0 .._- "'-- .. --~.,. ,- j ~". ..... Yes f] Yes 0 NO' 0 Yes 0 NO' 0 Yes 0 NO' 0 Yes 0 NO' 0 Yes 0' NO' 0 Yes 0 NO' 0 Yes 0 NO' 0 other n;lanufactw'ingor air pollutiO'n . ~- DO' all the PO'llutant-emittjng activit.i~ ilt the facilities belO'ng to' the same SIC CO'de? Please prO'vide the SIC CO'des. "- Was the IO'cation O'f the n~w facility chO'Slln, primarily because O'f lts proximity to' the existing facility to' integrate the O'Pet'a lion O'f the two (:2) facilities? Please explain. ,- ,- .- Will matp.riatll be routinely transferred between the two (2)tacihties? Please explain the amO'unt O'f transfet' and how often ,the transfers take place and what pe'rcentages gO' to' the variO'us entities. ~tiS the facility influence production level~ or cO'mpliance with envirO'nmental regulatiO'ns at othf:r facilities? WhO' accepts the resPO'nsibility fOf cO'mpliance with air quality requirements? I Please e~Plain. --- 4 -421- : ATT ACHMENT B - SITING CRITERIA WAIVER If applicable, please complete this form and it must be notarized. G35-C General Permit Siting Criteria Waiver WV Division of Air Quality 300' Waiver I _ _ _ _ _ _ _ _ _ _-==""""=-_ _~-~------. hereby PrmtName acknowledge and agree that -------,.,,=.-o=="%"==-....-:-..=c::--------'--will General Pennlt "'pplic8ll! , Nanie construct an emission unit(s) at a natural gas productio.p., compressor and/or dehydration facility that will be located within 300' of my dwelling and/or business. . I hereby offer this waiver of siting criteria to the West Virginia Department of Environmental Protection Division of Air Quality as permission construct, install and (lperate in such location. to ". Sign~= Signature Date Signature Date Taken, subscribed and sworn before me this _ _ day of ______________~,20____. My commission expires: _ _ _ _ _ _ _ _ _ __ SEAL_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Notary Public 5 -422- ,.- ATTACHMENT C - CURRENT BUSINESS CERTIFICATE If the applicant is a resident of West Virginia, the applicant should provide a copy of the current Business Registration Certificate issued to them from the West Virginia Secretary of State's Office. If the applicant is not a resident. of the State of West Virginia, the registrant should provide a copy of the Certificate of Authority/Authority of LLC/Registration. This information is required for all sources to operate a business in West Virginia regardless of whether it is a construction, modification, or administrative update. If you are a new business to West Virginia and have applied to the West Virginia Secretary of State's Office for a business license, please include a copy of your application. Please note: Under the West Virginia Bureau of Employment Programs. 96CSRl, the DAQ may not grant, issue, or renew approval of any permit, general pennit . registration, or Certificate to Operate to any employing unit whose account is in default with the Bureau of Employment Programs ·Unemployment Compensation · Division. L..-_ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~._ " ) 6 -423- . .' ATTACHMENT D - PROCESS FLOW DIAGRAM Provide a diagram or schematic that supplements the process description of the operation. The process flow diagram must show all sources, components or facets of the operation in an understandable line sequence of operation. The process flow diagram should inClude the emission unit ID numbers, the pollution control device ID numbers, and the emission point ID numbers consistent with references in other attachments of the application. For a proposed modification, clearly identify the process areas, emission units, emission points, and/or control devices that will be modified, and specify the nature and extent of the modification. Use the following guidelines to ensure a complete process flow diagram: • • • • The process flow diagram shall logically follow the entire process from beginning to end. Identify each emission source and air pollution control device with proper and consistent emission unit identification numbers, emission point identification numbers, and control device identification numbers. The process flow lines may appear different for c1anty For example, dotted lines may be used for vapor flow and solid lines used for liquid flow and arrows for direction of flow. The process flow lines may be color coded. For example: new or modified equipment may be red; old or eXisting equipment may be blue; different stages of preparation such as raw material maybe green; and, finished product or refuse, another color. 7 -424- ATTACHMENT E - PROCESS DESCRIPTION Provide a detailed written description of the operation for which the applicant is seeking a permit. The process description is used in conjunction with the process flow diagram to provide the reviewing engineer a complete understanding of the activity at the operation. Describe in detail and order the complete process operation. Use the following guidelines to ensure a complete Process Description: • • • • • The process flow diagram should be prepared first and used. as a guide when preparing the process description. The written description shall follow the logical order of the process flow d i a g r a m . , All emission sources, emission points, and air pollution control devices must be included in the process description. When modifications are proposed, describe the modifications and the effect the changes will have on the emission sources, emission points, control devices and the potential emissions. Proper emission source ID numbers must be used consistently in the prt'cess description, the process flow diagram, the emissions calculations, and tht:: emissions summary information provided. ., Include any additional information that may facilitate the reviewers understanding of the process operation. The process description is required for all sources regardless of whether it is a construction, modification, or administrative update~ 8 -425- "-"~ - -.. ~ .... ~.. ..-~-- ~-. - _ . . -......... .._ " .- - ' - .• - ..... -~ "- _ .- --1 ATTACHMENT F - PLOT PLAN Provide an accurately scaled and detailed Plot Plan showing the locations of all emission units, emission points, and air pollution control devices. Show all emission units, affected facilities, enclosures, buildings and plant entrances and exits from the nearest public road(s) as appropriate. Note height, width and length of proposed or existing buildings and structures . . A scale between 1 "=10' and 1"=200' should be used with the determining factor being the level of detail necessary to show operation or plant areas, affected facilities, , emission unit sources, transfer points, etc. An oyerall small scale plot plan (e.g., 1"=300') should be submitted in addition to larger scale plot plan~ for process or activity areas (e.g., 1"=50') if the plant is too large to allow adequate detail ona single plot plan. Process or activity areas may be grouped for the enlargements as long as sufficient detail is shown. Use the following guidelin'es to ensure a complete Plot Plan: • • • • • • • • Facility name Company name Company facility ID number (for existing facilities) Plot scale, north arrow, date drawn, and submittal date. Facility boundary lines Base elevation Lat/Long reference coordinates from the area map and correspon'd ing reference point elevation .. . Location of aU point sources labeled with proper and consistent source identification numbcn . This information is required for all sources regardless of whether it is a construction, modification, or administrative upd_at_e_. _ _-: - _ _ _ _ _ _ _ _ _ _ _ __ _ _- l 9 -426- ATTACHMENT G - AREA MAP Provide an Area Map showing the current or proposed location of the operation. On this map, identify plant or operation property lines, access roads and any adjacent dwelling, business, public building, school~ church, cemetery, community or institutional building or public park within a 300' boundary circle of the collective emission units. Please provide a 300' boundary circle on the map surrounding the proposed emission units collectively. This information is required for all sources regardless of whether it is a construction, modification, or administrative update. 10 -427- ATTACHMENT H .,.. G35-C SECTION APPLICABILITY FORM General Permit G35-C·Registration Section Applicability Form General Permit G35-C was developed to allow qualified applicants to seek registration for a variety of sources. These sources include storage vessels, gas production units, in-line heaters, heater treaters, glycol dehydration units and associated reboilers, pneumatic controllers, centrifugal compressors, reciprocating compressors, reciprocating internal combustion engines (RICEs), tank truck loading, fugitive emissions, completion .combustion devices, flares, enclosed combustion devices, and vapor recovCIy systems. All registered facilities will be subject to Sections 1.0, 2.0, 3.0, and 4.0. General Permit G35-C allows the registrant to choose which sections ofth~ permit they are seeking registration under. Therefore, please mark which additional sections that you are applying for registration under. If the applicant is seekirig registration under multiple sections, please select all that apply. Please keep in mind, that if this registration is approved, the issued registration will $tate which sections will apply to your affected facility. G35-C APPLICABLE SECTIONS -- .. _. _..GENERAL - ----- - "-'--'-PERMIT .. _-- - ' . Storage Vessels Contai ning Condensate and/or Produced Water! DSection 5.0 .. .._._- _._--_ .- Storage Vessel Affected Facility (NSPS, Subpar~ . O._O_O_O_)- - - - - - - - 1 .Control Devices and Emission Reduction Devices not subject to NSPS Subpart 0000 and/or NESHAP ~ubpa~HH'~_ _ _ _ _ _ _ _----1 Small Heaters and Reb oilers not subject to 40CFR60 Subpart Dc ,. DSection 6.0 DSection 7.0 o Section 8.0 o Section 9.0 o Section 10.0 o Section 11.0 o Section 12.0 -- ', _ - ~. Pneumatic Controllers Affected Facility (NSPS, Subpart 0000) .- . Centrifugal Coinpresso r Affected Facility (NSPS, Subpart 0000)2 .. . . Rec~procatin:g j CO.mpres sor Affected Facility (NSPS, Subpart 0000)2 Reciproc.ating Internal Combustion Engines, Generator Engines. Microturbine GeneratorS " .. DSection 13.0 .... . 3 Tanker Truck Loading .. C1Section 14.0 Glycol Dehydration Un . " ...... ; .... -----'--- 1 Applicants thut are subject to Section .5 may also be subject to Section 6 if the applicant is subjedtothe NSPS, Subpart 0000 control requirements or the applicable control device requirements of Section 7. 2 Applicants that are subject to Section 10 and 11 may also be subject to the applicable RICE requirements of Section 12. 3 Applicants that are subject to Section 13 may also be subject to control device and emission reduction device requirements of Section 7. 4 Applicants that are subject to Section 14 may also be subject to the requirements ofSection 8 (reboilers). Applicants that are subject to Section 14 may also be subject to control device and emission reduction device requirements ofSection 7. 11 -428- - - - - - - - - - - - -- - -._- -. - -- . - - - ... - --ATTACHMENT I -EMISSION UNITS I EMISSION REDUCTION DEVICES (ERD) TABLE _. M.···.···· .. _ ............ _ •.. ____ ,.... ..• _.. ....... ......... ... _.. _... _ ......... ... _._._............ _"... .... ..... .... ..... ............." .... ,...._ .. ,...... ........... •..... _ ..•.• _.......••..•....•..•............. _. _.................... ._._....... ........ ~- -- ...-.- - ,•..•.... __ .. ............ ............ .... .. Include ALL emission units and air pollution control devices/ERDs that will be part of this permit application review. This information is required for all sources regardless of whether it is a construction, modification, or administrative update. i Emission Unit 10 1 i Emission Point I i Emission Unit Description )D 1 i Manufac. Date l Year Installedl Modified " ' . r Type" And Date of Chaage De&ign Capacity Control Device(s)s ERD(s)6 - + - - - - - - - t - - - - t - - ..., .......- - - - t - - - - - - - - - i I ... / ";-. . I .-. ...~. ~ \..>' - I ~ N \C I . :-'~'"=:::-, :. =±=~=========j~\ b' ===r=-il-. '. . , I '. -> ' J " l---t--+-----~. ·~--:-----t---L """ -===,,:<~ ~\. . ~'.':., "'~n ~ '\ . ~ , ':.0.. f-----+----t-I·" f-----/------' . • .L- +------,. .... - -~~-=-\~7~c~·I:~==t=f~~=t==== ,-, 3==i==E===t== .... - + 1 - - - - - + - - - - + - - - - - - + - - - + - - - - - - - + - - - - - - - - - - 1 ..- \. I I I For Emission Units (or Sources) use the following numbenng system:lS,2S, 3S, .. . or other appropriate designation. 2 For Emission Points use the following 'numbering system: IE, 2E, 3E .... or other appropriate designation. 3 When required by rule 4 New. modification. removal. existing . . S For Control Devices use the following numbenngsyr"tem: I C, 2C, 3C •.. . or other appropriate designation. 6 For EROs use the following numbering system: 10. 20, 3D •... or other appropriate designation. 1 --~~----~~~--~~----------------------------------------------~ 12 _ .............. • . . . . . . . . . . . . . . . 0< ••••••••••••••••••••••••• " . . . . . . . . . . . . . . . . . . ATTACHMENT J - FUGITIVE EMISSIONS SUMMARY SHEET Sources of fugitive emissions may include loading operations, equipment leaks, blowdown emissions, etc. Use extra pages for each associated source or equipment if necessary. ••••• ••••••••••••• Source/Equipment: Leak Detection Me th 0 d Us e d C omponen Type t P umps Valves Closed Vent System • ••••• ____ •• ............................ I0 I: •• _... • •• _ . • ._ ._._._ ••••••••••• ••• • Audible, visual, and t (AVO) . . ory inspectIOns . 0 Ilac M 't . om or Frequency Count •••••• _ . . . . . . ••• ' I0 ••••• .., ••••••• _ . . . . . . . . . . . . " • ..._ ..........~ • ....... ........ ..._........ • ............... _. =£ .. S .£ Stream type ( as Ii uid g ;tc.1' . o ', DYes 0 No "" ~ -..... . .... .. ~ .. Yes 0 No • •• _ . . . . . . ..... ••••• ••••••• • •••••••••_ . . ._ ••••••••••• _,_ I [J ...Other -.. . (please descrtbe) Infrared (FUR) cameras fL kF t ource 0 ea a~ ors (EPA, other (specIfy)) •••••••• J . 'c. .. " ./ .:~ - " VOC ••••••••••• ••••••• •••••••• ••••••••••• ...... • . ...... . ' ........ . , •••••• . 0 None requIred I +--- Estimated Emissions (tpy) HAP aHa (C0 2 e) . '. . -+-----+----------_ ~-------r----------_+--- I 0l:Io- (M = I Safety Relief Valves Open Ended Lines Sampling 00 0 0 0 Connections Connections (Not sampling) 0 No 0 Yes 0 No DYes Compressors 0 No DYes 0 No Flanges Other l I'. . ..'~:~.. \. ___ + - - - - - - + _ - - - - - + - - - - - - - - - - _ I \"' ... >. . .. . \ ' ~ ~ ~ .\ \ - .~ ~"'., Yes No Yes No Yes "-,. . . ..... . , . , . . ---t-------+--- ,. - _ . t - . ~.,' ~ .... - , ---_+-----------j---------+-------------------l .---:-....... -- ,. : ..•. " ' .. '" ~ \ ,/T \" , \. ) ' ;, - - - - - - - - . "\.".:~ ~ ~:s ",:, - - .. -:" .•..• ~. .... . . ,. -----+---------1-- . ~ ..---+------+------+-- . ... ._ _ _ _ _--1._ _ _ _ _L -_ _ _ _---1_ _ _ _---'_ _ _--'-_ _ _ _---J _ IOili~equipment~p~mayincludec~pr~sm~~~mliefv~v~,d~p_h_rn~g~m~~~d_r_a_~_s~,_m_~_e_~~,_e_t_c_._ _ _ _ _ _ _~_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _~ Please provide an explanation of the ! D Other (describe) r PRESSURENACUUM CONTROL DATA - 19. Check as many as apply: D Does Not Apply D RuptUre Disc (psig) " D Carbon Adsorption 1 l D Vent to Vapor Combustion Device (vapor combustors, flares, thermal oAidizers, enclosed combustors) D Inert Gas Blanket of -' " D Conservation Vent (psi g) Vacuum Setting : 0 Condenser.l Pl'eswre Setting D Emergency Relief Valve (psig) Pressure Setting Vacuum Setting 0 Thief Hatch Weighted DYes D No ! .. Complete appropriate Air Pollution Control Device Sheet 20. ExpectCd Emission Rate (submit Test Data or Calculations here or elsewhere in the application). Material Name Flashing I.os5 Breathing Loss Working Loss Total Emissions Loss Ib/hr Iblhr Ib/hr Ib/hr tpy tpy 15 -432- tpy tpy Estimation Method' ./ I EPA = EPA Emission Factor, MB = Material Balance, SS = Similar Source, ST = Similar Source Test, Throughput Data, 0 = Other (specify) Remember to attach emissions calculations. including TANKS Summary Sheets and other modeling summary sheets if applicable. TANK CONSTRUCTION AND OPERATION INFORMATION 21 . Tank Shell Construction: 0 Riveted D Gunite lined D Epoxy-coated rivets 21 A. Shell Color: 22. Shell Condition (ifmetal and unlined): D No Rust 0 Light Rust I 21C. 1228. If yes, operating temperature: .1 22C. Ii·}e8, how is heat provided to tank? 23. Operating Pressure Range (psig): Must be listed for tanks using VRUs with closed vent system. 24. Is the tank a Vertical Fixed Roof Tank? 24A. If yes, for dome roof provide radius I DYes D No (ft):! 24B. If yes, for cone roof, provide slop (ftlft): . . 25. Complete item 25 fo\' Floating Roof Tanks D Year Last Painted: o Not applicable D Dense Rust 22A. Is the tank heated? DYes D No D Other (describe) 1 21B . Roof Color: Does not apply D I ._ .r . / 25A. Year Intemal Floaters Installed: 25B. Primary Seal Type (check one); D Metallic (mechanical) shoe seal D Vapor mounted resilient seal 2sC. Is the Floating Roof equipped with a secondary seal? DYes 250. If yes, how is the secondary seal mounted? (check ont') 25E. Is the floating roof equipped with a weather shield? DNo 0 Shoe 0 DY~s Rim . D ·Othcl'(describe): D No .. 25F. Describe deck fittings: D Doc~ not apply 26. Complete the following section for Internal Floating Roof Tank, 26A. Deck Type: ti Liquid mounted resilient seal o Other (desG1 ibe): .- . D Bolted D Welded .1.26B. For bolteideCkr, ptovide deck construction: ~ I 26C. Deck seam. Continuous sheet COlbt1ucti~n. D 5 ft. wide D 6 ft. wid~ D 7 ft. Wide D 5 x 7.5 ft. wide 05 x 12 ft. wide 26D. Deck seam length (ft.): 26E. Area of deck (ff): .. , o other (describe) 26F .For column supported tank-.;. 0# of columns: 260. For column supported tanks. diameter of column: . ,/ 27. Closed Vent System with VRU? OY~ DNo 28 . Closed Vent S)'IIWm with Enclosed Combustor? DYes D No ---"'- ' SITE INFORMATION 29 .. P1Qvide the city and state on which the data in thili section are based: 3 I. Annual Avg. Maximum Temperature (OF): 30.' Dally Avg. Ambient Temperatut" ("F): 32. Ann1J;tion Chambers LEC Low Elli.isl.ion Combustion OxCat Oxidation Cataly&t Enter the fuel Type using the following codes: PQ 9 4SRB Enter the Air Pollution Control Device (APCD) type designation(s) using the following codes: Nf HEIS PSC NSCR SCR 8 Two Stroke Lean Burn Four Stroke Lean Bum Pipeline Quality Natural Gas RG Raw Natural Gas IPtlluuCtion Ga~ D Diesel Enter the Potential Emissions Data Reference designation using the following codes Attach all reference data used. MD GR Manufacturer's Data GRI-HAPCalc™ AP OT . AP-42 Other (please list) 10 Enter each engine's Potential to Emit (PTE) for the listed regulllted poUutant~ in pounds per hour and tons pel' year. PTE shall be calculated at manufacturer's rated brake horsepower and may reflect reduction etlic"iem;ies oi'listed Air Pollution ContrOl I1evices. Emergency generator engines may use 500 hours of operation when calculating PTE. PTE data from this diitol.;IDeet shall be incorporated i,l the Emissions Summary Sheet. 11 PTE for engines shall be calculated from manufacturer's data unless tl%Javailahle. 20 -437 - Engine Air Pollution Control Device , use extra pages as necessary) (Emission Unit ID# Air Pollution Control Device Manufacturer's Data Sheet included? No 0 Yes 0 o o o SCR NSCR Oxidation Catalyst Provide details of process control used for proper mixing/control of reducing agent with gas stream: Model #: Manufacturer: Design Operating Temperature: " of Design gas volume: Service life of catalyst: Volume of gas handled: sefm o Provide manufacturer dllta? DYes acfm at - of No Operating temperature range fOl'l'IISCR/Ox Cat: of of t.Q From . . '. Ammonia slip (ppm): ' Reducing agent used, if any: . ~,' Pressure drop against catalyst bed (delta P): inches of H2O Provide description ofwaming/alarm system that protects unit when opt;ration is not meeting. design conditions: , " ~.~ . Is temperature and pressure drop of catalyst required to be monitored per40C'FR63 !)ubpart ZZZZ? DYes 0 No How often is catalyst recommended or required to be replaced (hours of operation)? .""~ o Annual o Every 8,760 hours of operation o Field Testing Required o No performance test required. If so, why (please list any maintenance i'(iquirc'd and the applicable sections in How often is performance test required? o Initial NSPS/GACT, - 21 -438- . ATTACHMENT N - TANKER LOADING DATA -_ ..... .- ...SHEET ---_ TRUCK .-.- .. -- --- ....._..._. -_ . ' ....... .' -, - ._-- ._-- _._.... _-- ---, 'Complete this data sheet for each new or modified bulk liquid transfer area or loading rack at the facility. This is to be used for bulk liquid transfer operations to tanker trucks. Use extra pages if necessary. . .. ...... -._. ' ...... ,- -~ Truck Loadout Collection Efficiencies The following applicable capture efficiencies of a truck loadout are allowed: • • • For tanker trucks passing the MACT level annual leak test -99.2% For tanker trucks passing the NSPS level annual leak test - 98.7% For tanker trucks not passing one of the annual leak tests listed above - 70% Compliance with this requirement shall be demonstrated by'keeping records ofthe applicable MACT or NSPS Annual Leak Test certification for every truck and railcar loaded/unloaded. This requirement can be satisfied if the trucking company provided certificationtha.: its entire fleet was compliant. This certification must be submitted in writing to the Director of the DAQ. These additional requirements must be noted in the Registration Application and will be noted on the issued G35-C Registration. I Emission Point 10#: Emission Unit 10#: Emission Unit Description : - " ' ... ", " Loading Area Data ,, ' -,> I Max' ~u~ber of trucks loading at one I Number of L~uidS Lol)d-ed. Number of Pumps: TYear Installed/Modified: (1) time: " Are tanker trucks pressure tested for leaks at this or any :)tber 10catiQn? If Yes. Please describe: n Yes DNo D Not Required -' 0:-::" Provide description of closed Vent "),iitem and any bypasses" Are any of the following '(ruck loadout li.y~t<;ms utilized? o Closed System to tal1lcer truck passing aMACT level annual.feak test? o Closed System to tankcl· truck passing It NSPS level annual leak tefot? 0 Closed System to tankel , tl'u~k not pa!;Jsini\ an a!lnualleak test and has vapor return? ' ~ - . . _ . ., - " .- Projected Muirnum Opera:tiAg Stbedtllt (for rack or transfer point as a whole) " I Time ... I-- Apr - Jun Jan- Mar - .. " Hours/day ,- I Days/week _ .. 1--- . ' . " -' . . , ~ \--- - - Bulk Liquid Data (use extra pages as necessary) ~ ~'." Liquid Name Max . Daily rbrQughput (\ 000 gal/ds)') Max, Annual Throughput (1000 ga\/yr) ' -, . .. Loading Method J Jul- Sept Max , Fill Rate (gal/min) -, Average Fill Time (min/loading) Max, Bulk Liquid Temperature (OF) True Vapor Pressure 2 Cargo Vessel Condition 3 Control Equipment or Method 4 22 -439- Oct - Dec Max. Collection Efficiency (%) Max. Control Efficiency (%) Max.VOC Emission Rate Max.HAP Emission Rate Loading (lb/hr) Annual (ton/yr) Loading (lb/hr) Annual (ton/yr) ; ," Estimation MethodS 0" I 2 3 4 5 r'-" BF Bottom Fill SP Splash Fill SUB Submerged Fill At maximum bulk liquid temperature U Uncle.ured (dedicated service) B Ballasted Vessel C Cleaned o Other (describe) List as many as apply (complete and submit appropriate Air Pollution Control Device Sheets) CA Carbon Adsorption VB Dedicated VaporBalance (closed system) FI"I'€) ECD Enclosed Combustion Device F TO Thermal Oxidization or Incineration EPA EPA Emission Factor in AP-42 MB Material Balance TM Test Measurement based upon test data submittal 0 Other (describe) 23 -440- ATTACHMENT 0 - GLYCOL DEHYDRATION UNIT DATA......SHEET _... ...... .. - ....-... -_...__ .. ..- .. - .. _._ ....-.... _... .._--- - .. .. - ........ _....... _....._..... .... .... -.- ..__..__.. __._._ .. ... Complete this data sheet for each Glycol Dehydration Unit, Reboiler, Flash Tank and/or Regenerator at the facility. Include gas sample analysis and GRI- GL YCaic ™ input and aggregate report. Use extra pages if necessary. .•. " _ " .. ~ - " , • M • • • • • •_ _ _ ."' Model: Manufacturer: Reboiler Design Heat Input: mmscf/day Max. Dry Gas Flow Rate: Design Type: 0 TEG Date Installed/Modified/Removed 2 Source Status 1: 0 EG 0 DEG MMBTV/hr ,. .. Regenerator Still Vent APeD!ERD 3: : ,- Control Device/ERD 10#3: Fuel HV (BTV/scf) ' H2 S Content (gr/IOO scf): Operation (hoursl}'ear): --- " ", --. Pump Rate (scfm): ' . ,-- Water Content (wt %) in: Wet Gas: Dry Gas: Is the glycol dehydration unit exempt from 40CFR63 Section 764(d)?' DYes o No: If Yes, answer [he- following: The actual annual average flowrate of natural gas to the glycol'dehyd.ration unit is less than 85 thousand standard cubIC meters per day, as determined by the procedures specified in §63.772(b)(l) of this subplut. DYes o No ~ The actual average emissions of benzene from the glycol dehydration unit plocess vent to the atmosphere are less than 0.90 mega gram per year (I ton per year), as determined by the procedures specified in *63.772(b)(2) of this subpart. 0 Yes o No " Is the glycol dehydration unit located within an VrbaniJ:ed Area (VA) or Vrban Cluste.. (liC)? DYes , - Is a lean glycol pump optimization plan being utilized? 0 o Ye~ No - o No '. Recycling the glycol dehydration unit back to the flame zone of the reboiler. o No DYes Recycling the glycol dehydration u!lit back to the'flame zone 01 the reboiler and mixed with fuel. o No DYes What happens when temp~rature contl'olla shuts off fuel to tht, I eboiler? Still vent emissions to the atmosphert:. Still vent emissIons stop!)ed with valv(>. ' Still vent emissions to glo~ plug . ......" / .... Please indicate if the following tiquipm~ntili ptClicnt. Flash Tank Burner m.d4agement "ystem that continuously burns condenser or flash tank vapors o o o o o - __ \ ,,- Control Device Technical Data ' .. - Pollutants Controlled Manufacturer's Guaranteed Control Efficiency (%) - t- r----- -. " .---' Emissions Data Emission Unit ID I Emission Point ID4 Description Calculation Methodology5 PTE 6 Controlled Maximum Hourly Emissions (lb/hr) NO. CO Reboiler Vent VOC S02 PM IO 24 -441- Controlled Maximum Annual Emissions (tpy) GHG (C02 e) Glycol Regenerator Still Vent Glycol Flash Tank 2 3 4 5 6 GRI-GlyCalc ™ VOC GRI-GlyCalc ™ Benzene GRI-GlyCalc ™ Toluene GRI-GlyCalc ™ Ethylbenzene GRI-GlyCalc ™ Xylenes GRI-GlyCalc ™ n-Hexane GRI-GlyCalc ™ VOC GRI-GlyCalc ™ Benzene GRI-GlyCalc ™ Toluene GRI-GlyCalc ™ Ethylbenzene ,. ,/ ' . i GRI-GlyCalc ™ Xylenes GRI-GlyCalc ™ n-Hexane , --- . ..L Enter the Source Status using the following codes: NS Construction of New Source ES E)~ isting Source MS Modification of Existing Source Enter the date (or anticipated date) of the glycol dehydration un~t's mstallation (construction of source). 'modification or removal. ' Enter the Air Pollution Control Device (APCD)/Emission Reduction De~,ke (ERD) type designation using the following codes and the device ID number: NA None CD Condenser FL Flare CC Condenser/Combustion Combination liO Thermal OxidizeI' 0 Other (please list) Enter the appropriate Emission Unit ID Numbe:t.~and Emission Point ID Numbetl!i for the glycol dehydration unit reboiler vent and glycol regenerator still vent. The glycol d,ebydl'ation unit reboiler vent and glYl;oll'egenerator still vent should be designated RBV-I and RSV-I, respectively. Iftlle compre&Sot ~t,)ti(}n incorporatel.lmultiple glycol dehydration units, a Glycol Dehydration Emission Unit Data Sheet shall be completed foJ' each using Source Identification RBV-2 and RSV-2, RBV-3 and RSV-3, etc. Enter the Potential Emis'!jion~ Data Reference designation using the followi!lg codes: MD Manufactul'el" ;~ Data AP,' AP-42 GR GRI-GLYCalc1M , OT' Other ," (please list) Enter the Reboiler Vent and Glycol Regenerator Still V. 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