WEST VIRGINIA AIR QUALITY BOARD CHARLESTON, WEST VIRGINIA WEST VIRGINIA OIL & NATURAL GAS ASSOCIATION AppeIIant, Appeal No. V. jG-Oa- AtG*B DIRECTOR, DIVISION OF AIR QUALITY, DEPARTMENT OF ENVIRONMENTAL PROTECTION, Appellee. NOTICE OF APPEAL The appellant named above respectfully represent that it is aggrieved by the issuance of Class II General Permit G35-C ("the Permit,) on December 18, 2015. The appellant therefiore prays that this matter be reviewed and that the Board revise the Permit to incorporate changes that are addressed more fully on the attached objections. The speciflC Objections tO this action, including questions Of fact and law tO be determined by the Board, are set fiorth in detail in separate numbered paragraphs and attached hereto. The objections may be factual or legal. Amendment ofthis Notice ofAppeal may be had only by leave ofthe Board, and only for good cause shorn. Dated this 15th day ofJanuary, 2016. Specific Objections to the Action ofthe Director Appellant West Virginia Oil & Natural Gas Association (WVONGA) is the oldest association serving the oil and gas industry in West Virginia. It is composed ofWest Virginia oil and gas producers and transporters, as well as ancillary businesses in the state that support the industry. Its members apply for air emission permits such as the G35-C Class II General Permit for the prevention and Control of Air Pollution in regard to the Construction, Modification, Relocation, Administrative Update and Operation of Natural Gas Dehydration Facilities (ccthe Permit"). Compressor and/or WVONGA commented on the Permit when it was proposed for adoption. Appellants offer the following specific objections to the action ofthe Director, Division of Air Quality) Department of Environmental Protection (6Cthe Director9?) regarding the December 18, 2015 issuance ofthe Pe-it: 1. Section 3.2.8 of the Permit states that cc[t]he registrant shall not create a nuisance to the sunTOunding COmmunity by Way Of unreasonable noise and light during OPeratiOn.,, The Director has no authority under the authorizing statute (the Air Pollution Control Act, W 7,cz. cocze 22-5-1 er segJ to impose conditions in the Permit related to noise or light. Even if the Director had authority to regulate noise and light, this condition'ofthe Permit is void because it is vague and provides no criteria for evaluating whether noise or light at any level is ¬cunreasonable,, or a £cnuisance." The vagueness ofthe standard imposed by the Director leaves the permittee unable to determine whether it is in violation of the Permit, and as a result the condition is a violation ofthe permittees' due process rights under the West Virginia and United States constitutions. 2. Section 4.1.4 of the Permit requires all components of the permitted source to operate c6with no detectable emissions, as determined using audio-visual-olfactory (AVO) inspections, USEPA 40CFR60 Method 21, USEPA altemative work practice to detect leaks from equipment using optical gas imaging (OGI) camera (ex. FLIR camera), or some combination thereof.'' As an initial objection, the Director is essentially developing a leak detection and repair (LDAR) program without first having established the parameters of such a program through rulemaldng. Even ifthe Director has the authority to develop such a program, it must be consistent with, and no more stringent than, applicable federal law, absent some finding that conditions specific tO West Virginia. See W. Vc). Coc7e 22-5-4(a)(4). The LDAR program established by the Permit is more stringent than federal LDAR programs, which at this time do not include the equipment at facilities that would be regulated under the G35-C. Second, the standards established by the Permit are unreasonable. Under the Permit, every leak seen through an OGI camera, no matter how small, is a violation, even though the amount ofthe leak that is seen may be below actionable thresholds, or may not even be a release of VOCs. That standard is more stringent than federal LDAR requirements, and it discourages the use of FLIR cameras and similar devices. It renders even the smallest leak a violation, when a different set of criteria, such as Method 21, might allow a higher significance threshold. 3. Section 7.1.5 of the Permit states that cc[f]resh replacements for all carbon being used in the carbon adsorption system shall be kept on site." The Director has no authority to specify where pollution control supplies are kept. The Director can reasonably require proper operation of carbon adsoxption systems, and it has done so in Section 7.1.5.i.v ofthe Permit, but requiring re-supplies to be kept on site exceeds his authority. Canisters that are kept at unmarmed stations are subject to theft, and central storage of supplies makes sense for many types ofsupplies, such as carbon canisters. 4. The United States Environmental Protection Agency has proposed changes to 40 CFR 60 Subpart OOOO which would result in the adoption of Subpart OOOOa. Subpart OOOOa, when finalized, will likely apply to facilities that will be covered by the Permit. While the federal requirements ofSubpart OOOOa cannot be imposed inthe Permit, it is reasonable for this Permit to allow permittees to choose to comply with those requirements in lieu of the requirements ofthe Permit, once Subpart OOOOa is adopted. Otherwise, permittees could be in the position of complying with the Permit or the federal requirements of Subpart OOOOa when it is issued. The sections of the Permit that could conflict with Subpart OOOOa when it is issuedinclude §§5.1.5.1; 5.3.2; 7.1.3.2; 7.1.6.i; 7.2.2; and 7.4.5. 5. Tanks holding fluids that are 90% or more water or brine have minimal VOC emissions and should not be regulated under the Permit. Section 5.0 should be revised to recognize de minimis tank emissions. 6. There are many types of emission control and reduction devices that could be found at a permitted facility that would be useful, and should be covered under the Permit. For example, flares controlling blowdovIIS Oi Pigging Should be allowed. As presently drafted, subsection 7.1 of the Permit does not allow such control or reduction devices. 7. Sections 7.1.2.2.i, 7.1.2.2.iv and 7.1.2.3.i require vapors that are controlled by flares to be routed to the flares or an enclosed combustion device at all times. This prevents very brief dovIltimeS for maintenance, unless a separate flare or combustion device is brought in. There is a need for short periods where emissions are not routed to the flare or combustion device, when those periods are occasionedby emergencies or maintenance. 8. Section 7.1.8.a requires routing of vapors and overheads from still columns to be routed through a condenser when vapors can be generated firom the still column. Still column emissions can,i be directly recycled back due to high water content. VIere the still column emissions are going through a condenser, such emissions are already covered under subsection 7.1.6. 9. Section 7.5.2 requires reporting of bypasses of emission control devices. Such bypasses should not be reportable lmless they result in emission limit violations. Ifthey do not, 1ogging ofthe bypasses inthe facility record should be sufficient. Questions ofFact Presented 1. What levels oflight and noise constitute a nuisance under the Permit? 2. How is a light and noise nuisance evaluated under the Permit? 3. How is aviolation offugitive emission limitations in the Permit determined? 4. lThat are the federal LDAR requirements that apply to facilities that can qualify for the Permit? 5. What problems are posed by allowing pollution control supplies to be kept in central locations? 6. Will the requirements ofSubpat OOOOa applyto Permit registrants when finalized? 7. What levels of VOC or other emissions can be expected from tanks holding fluids that are 90% or greater water or brine? 8. VIlat emission COntrOl or reduction devices could be used at a permitted facility? 9. Does the Permit require emissions to be routed to a flare or combustion device even when it is undergoing maintenance? 10. What configurations are commonly used for emissions from glycol dehydration units, flash tanks, and still columns? ll. VIlat are Safe and reasonable options for handling emissions from glycol dehydration units, still columns, and related equipment and devices? Questions ofLaw Presented 1. Does the Director have statutory authority to regulate noise and light? 2. VIlat levels ofnoise and light constitute anuisance under the Permit? 3. Is the requirement to avoid creating a nuisance by not generating unreasonable noise and an excessively vague permit condition that violates state and federal constitutional protections ofdue process? 4. Does the Director have authority to establish an LDAR program without undertaking rulemaking to establishthe limitations ofsuch a program? 5. Is the LDAR program established in the Permit more stringent than federal LDAR requirements? 6. If it is more stringent than federal LDAR requirements, does it violate W 7rcz. Coc7e §225-4(a)(4)? 7. Does the Director have the authority to require storage ofpollution control supplies at the stationary source where they are used? 8. Can Permit registrants elect to be regulated in accordance with Subpart OOOOa when it is issued? 9. Does the Director have authority to regulate de minimis emissions from tanks holding fluids that are 90% or greater water or brine? 10. What emission control or reduction devices are allowable, or should be allowed, at a permitted facility? 1 1. What federal or state requirements apply to flare or combustion device operation? 12. What are the federal and state requirements for controlling emissions from glycol dehydration units, still columns, and similar devices? 13. Are there any state or federal statutes or regulations requiring reporting of bypasses of control devices? 14. Has the Director acted reasonably in issuing the Permit? 15. Has the Director acted arbitrarily or capriciously, or in contravention of law, in issuing the Permit? West VirginiaDepartnent ofErvironmeutal Proteedon Division ofAir Qualtry EarlGR%%rblin R.aanb%nCgsHe#g I. Class II General Permit G35-C forthe Prevention and Control ofAir Pollution in regard to the Constnlction, Modification, Relocation, Administrative Update and Opendon ofNatural Gas Compressor and/or Dehydration Facilities This permit is issued inaccordance with the west virgjhiaAir Polhicln Control Act nyest VirginiaCode §§ 22-5-1_ e_i seq.) and 4fCSR13 - Permitsfor Coutruction Modiifeation Relcration and Operation ofStolior'ary Sources ofAir Polhaaun, Noti;flcation RJequirenatS, Temporary Permits. General Permits and Procedrresfor Ervaluation` IItrector Issued: December 18, 2015 G35-C 2of38 Natural Gas Compressor and/or Dehydration Facility 4_a_y_p_e_:.:?I_r!Lh_OJS::_ir:Sr:s:_ybay be affected, inclxping, but xp_i necessarily_lipeited to' the applicaat and any person wh_:.r1:r:1:::r_at:,a.:_n_i::_:_rib_I:_C :OTmert PrOCS:s, !y a Permit issued. mod_-ified a: de;ted b;i.h;-i-::;:;;i-%arr;;;ir±al such action ofthe secretary1,i_a_ tle fir g.:,altty_,PoqrP puryurpt_to attic1_6 a_ne_[§_§22B-I:I et seq.-I,-Ch;;;;;2irf;; the Code ofWest Virginia. West Virginia Code §§22-5-14. The source is not subject to 45CSR30_ Ge_n_a_r:I_fe_r_i:_S3_:i:_au:,h:r?es.:he c'on.f:r.uctio±, modtftca.ti?r. ad_In_inistra_tire update and/or operation ofnatural ?_Xf?:rfr=s_::__rrq/or d^ehrdrati?Pfa?i.litie_s. The_appltfability ofGeneral Perwiit G35-C may.inelnde a;y of;i-e fol_I:w.ing:.. nature.I gas-fired spark ign:tlor irttTna_I?a_mb_uStiOri ehgines, diesel-fired compres'sioj;;;;t;;{iJ1;;;aI combustion engines, star:ge.v?ssel.:/larks.' gay_col dekydration ufos and associated equ:pment, ei-:;;I:ir;i;:ir, truck loadingl uwloading operations, and pneumatic conhol[;rs. West Virginia Department ofEnvironmental Protect_ion Division ofAir Quality G35-a Natural Gas Compressor and/or Dekydration Facility 3 of38 Table ofContents 1.0. Emission Units........,..........................,................................,.........................................,s 1.1. General Pe-it Registration `........... 2.0. General Conditions...........................................,.....,.........,................".........................5 2. I. 2.2, 2,3. ...,...."....",."....5 .,,......"....,.,.,.."......,..."6 2.4. Definitions 2.5. 2.6. 2.7. Acronyus .........._..",..........................I Pemit Expiration and Renewal Adndristrative Update to General PermitRegistration 2.8. Modification to GeneralPermitRegistration..,.,."........ 2.9. 2.IO. .,................i Dutyto Comply....................--......._. IuspectionandEntry_.......... .....,........8 2.l1. 2.12. Need to Halt orReduce Activitynot aDefense Emergency 2.13. Fedqully-EnforoeableRequiremeuts....................................... 2.14. Dutyto Provide lrfomation 2.15. 2.l6. Duty t9 Supplement and Correctlfo-ation..,.....,.......... CredibleEvidence..'. ... 2.17. . PropertyRights..........I..."............. 2.19. 2.20. Notification Requirements Suspension ofActivities... ...."9 . 10 ..,.,..,.............,........... 10 Severability...............-..........._...... 2.18' 2.2l. 3.0. Puxpose........I.-.I................-...............- Authority Applicability ."...,................ 10 .. ... +. .....,..."........,.................",......10 Transferability......,....I.'......._.............. ........"....",..."........... 10 Facility-Wide Requirements....,...............................................................................,."11 3!.i:I 3.4. 3.5. 4.0. #T::a.tcfienR£ed::S:t:ij'eid:;:'i:::.::i:.::I:.i:,:.::.:.:..,::,:::::.::.::i,:,::..::,::,i..i:::,.:.::...:i::::i.:.i..:..:..;...;.:;:i...:...:.::i:...:i:.:1:i Testing Requirements .".,...,...............,.,...,....... l2 Recordkeeping Reqirirements .,."..,...........,...,..,......."....... 13 3.6. Reporting Requirements........ ........... 13 Source-Specifflc Requirequents....................................................................,................15 4.I. 4'2. a.0. Limitations and standards ".......I....,......._..I Recordkeeping Requhemen.ts.'.. Source-Speciflc Reqllirements [Storage .,._........".."..",................ 16 Vessels Containing Condensate and/or Produced Water]...........".........................................................................................,.................17 5.1. 5.2. 5_3. 5.4. 6.0. himitations and Standards Monitoring Requirements Recordkeeping Requirements...... Notification and Reporting Requirements...........,..,.,.....,.,.....................................19 Source-Speciflc Requirements [Standards of Performanee for storage ves=e] Affected Facilities aNSPS; Subpart OOOO)I...........................................................................20 6.I. . Limitations and Standards ..,.........20 7.0. Source-Specific Requirements [Coutrol I)evices and Emission Reduction Devices not subject to NSPS Subpart OOOO and/or NESIIAP Subpart HH]...,.....................................20 7.1. 7.2. Liinitations and Standards Monitoring Requirements 7.3. Testing Requirements.I.......... 7.4. Recordkeeping Requirements 7.5. _,...,....,,............20 ReportingRequirements-,..,..,.".,.,..-....,.......,.."..."......,.".. West Virginia Departlnent ofEnvironlnental Protection Division ofAir Quality ,..I 28 G35-C 4 of38 Natural Gas Compressor and/or DehydrationFacility 8.0. Source-SpecifIC Requirements [Small Heaters and Rebof]ers not subject to 40CFR60 Subpart Dc]..............................................,.............................................,..........................".......zg 8.1. Limitations and Standards.......-.,..,.,.....,....."."..."... 8.2. 8.3 8.4I 9.0. 29 Monitoring Requirements Testing Requirements Recordkeeping.Requirements. Source-Specific Requirements .,.,...."........,....,29 [Pneumatic Contro]ltrs Affected Facility (NSPS, Subpirt OOOO)I.......................................................................................................................30 9.1. 10.0. Limitations and Standards Source-Specific Requirements [Centrifuga] Compressor Affected Facility OrSPS, Subpart 0000)I.........................,.........................................................................."...............,.30 10.1. ll.0. Limitations and Standards I....I.............I...... Source-Specific Requirements [Reciprocating Compressor Affected Facility quSPS, Subpart 0000)I...............................................................................................,.......................30 ll.I. 12.0. Limitations and Standards.......-...............,...,",......... - , . 30 Source-Specific Requ'irements [Reciprocating lutermal Combusfron Engine(s) (RICE), Generators, Microturbine Generators].................."a.I...,......,......................,..........................31 l2.1. Limitations and Standards .....................".,....31 12.2. Monitoring Requirements 12.3. Recordkeaping Requirements. 12.4. Testing Requhements.. .......,..............".........................3.2 12.5. Reporting Requirements + t=J ___ _I_-__-_-_--- ---_---I_I--_..`'.I.''..`''.'''''.I...I...'I II ®'®' '''''''.I..' .'' '® ®®II .. ' ..JJ 33 13.0. Source-SI]eCifilC Requirements.[Thnker Truck LoadiH!g].........................................,34 13.1. Limitations and' Standards .................,..34 13.2. 14.0 Recordkeeping Requirenents...-..-,.,.......................... ....................34 Source-Specific Requirements [GIycolI)etrydration Units]..'...I...............................3S 14.I. Limitations and Standards 14.2. Monitoring Requirements...-'..........I 14.3. 14.4. 14.5. ..".,..,...."....,..............35 TestingRequtrements....:.........-..........,...........,...................,........ I . . 37 Recordkeeping Requirements..-,..,.,......,............,..................,...."..,..,....................37 I Reporting Requirements..............,..-.:...,.,..,............"....................,,.,......................37 CERTIFICATION OF DATA ACCURACY..........................................................................38 West Virginia Department ofEnvironmental Protection. Divis]'on ofAir Quality G35-C Natural Gas Compressor and/or Dehydration Facility 1.0. 5 of38 Emission Units 1.1. General Permit Registration 1.1.1. Only those emissionunitstsounes as identified in the G35-a General Permit Registration,.with the exception ofany a?a rm,.jzl,rmjs sources as idendrled underTable 45-13B of45CSR13, are authorized at the registered facility. 1.1.2. In accordance with the info-ation filed in the G35-'C General Pe-it Registration Application, the equipment/processes identified in the Emissions Unit Table ofthe 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 maxiqum design capacities, shall use the specified control devices, and shall not exceed the emission limits listed in the General PermitRegistration. 1.1.3. A4z'#orSloorrae a/Hazflrdo#sJ4!.rPo/?#zfl#fs ¢Z4jJ/. The facilityshall not exceed lO tors per year of,any single hazardous airpolhant which has been listedpusuant to § I l2(b) ofthe Clean Air Act or25 tons per year ofany combination ofhazardous air pollutauts. Compliance with this section shall ensure that the facility is a minor souse ofIIAPs. i.1.4.. A4z.ceorSo#re; a/Regiv¢fedJfo//#fents. The facinty shall not exceed 100 tons per year ofany regulated air pollutant. The fugitive endssious ofa statiormry source shall not be co.nsidered in dote-ining whether it is a major stationary source for the purposes of45CSRIO-2.26-b. Compliance with this Section shall ensure that the facility is a minor source ofregulated all pollutants. 1.1.5.. fl4lj#orSo#ree Coxp/Z¢#ce, The registrant shall maintain records ofamual HAD and an other regulated air pollutant emissions using AP-42 emission factors, GRI-GLYCalc model inputs and outputs, flashing simulation model inputs and outputs, manufacturer guarmteedvalue;, sample and/or test data, calculation methods used inpreparation ofthe registration application or other methods approved byDAQ demonstrating that facility-wide enrissions are less than those apecified in Sections 1.I'3 and I.1.4. 2.0. General Conditions 2.1. Purpose The purpose ofthis Class II General Permit is to authorize the consthlction, modification, administrative updatq, relocation. and operation ofeligible natural gas compressor and/or dehydration facilities through a Class II General Permit Registrationprocess. The requirements, provisions, standards and conditions of this Class II General Perfut address the prevention and control ofregulatedpollutants from the operation of anaturalgas compressor and/or dedydration facility. 2.2. Authority This pe-it is issued in accordance with west virgi'nia airpollution control law w.va. code §§ 22-5-1. et seq. and the following Legislative Rules promulgated thereunder: 2.2.i. 4_5C:SRI3 I P_er_mi!±fol. Coy_st"_ctton, Modification, Relocation and'Op-eration ofStationary S_ounces of'_A.ir Pqllutins, Notifeatton ReqLli1.eneutS, Admthistl-alive Updates, Temporary P_erxpits. Genel.al Permits. Permission to Commence Coust"ctivn, tlnd Procedure;fior E+1aluatiOn. West Virginia Depannent ofEnvironmental Protection. DMsion ofAir Quality G35-C 6 of38 Natural Gas Compressor and/or Detrydration Facility 2.3. Applicability 2.3.1. All natural gas compressor and/or dekydration facilities designed and operated for the pxpose of compressing and/or dehydratingnatural gas and included in the following NAICS and/or SIC codes are eligible for General Pendt registration except for those instances listed in (a) through (h) below: NAICS Code SIC Code 211111 131l 213ll2 1382, 1389 221210 4923 486210 4922 Descriplion Crude Petroleum andNatural Gas Extraction Support Activities forOil and Gas Qperatious Natural Gas Distribution Pipeline Transportation ofNatural Gas a. Any natural gas compressor and/or dehydration facility which is a major source ofpollutants h Anynatural gas compressorand/or dekydration facility that is located inputnan courty Kanawha County, Cabell Couty, Wayne County, or Wood County and is requiredby 45CSR21 to conduct a ReasonablyAvailable Control Technology ¢ACT) dialysis and/or as defined in 45CSR14, 45CSRl9 or45CSR30. subject tO 45CSR21 Section 29 (Leaks from Natural Gas/Gasolihe Processing Equipment). Any natural gas processingplant (a.g. production ofethane, propane, butane, andpentane) as defmed in40 CFR i60.5430. d' Anynatural gas sweeteningplant. e. Any natural gas compressor and/or.ddydration facility with a storage tank sut)ject to.NSPS, Subpart Kb. f. i Any steam generatingunit (as defmed in §60.41c) subject to NSPS, SubpartI)a (i 10 a. MMBTuthr). g. Any turbine sulject to NSPS, SubpanKKKK. h. Any natural gas compressor and/'or dekydration facility which will require an individual air quality permitreview process (45CSRl3 construction/modification permit) to ineoIPOrate regulatory requirement(s) other than those establishedby General Permit G35-C. This wcluld imclude '¬sxpthetic minor' pe-itting actidus, as they are required to undergo Notice Level C under 45CSR13 Section 8.5. 6CSynthetic minor permitting actions would include limjtatioms onphysical or operational capacity to remainbelow major stationary source thresholds (including 45CSRl4g 45CSR19, 45CSR30 and 45CSR34). 2.3.2. For the purposes OfGeneral.Permit G35-a #¢fttr¢/grzs coxpressors!¢fro# means reciprocating intemal combustion engine driven compressor(s) or combination ofequipment (including but not limited to compressor engines,.energeney standby generators, engine driven air compressors, boilers, line heaters, tanks, glycol dehydration units, airpollution control devices, eke.) that I supplies energy to move natural gas atincreased pressure from gathering systems, in transmission pipelines or into storage. Engine means any compressor engine, emergencystandby engine, auxiliary engine or air compressor engine located at a natural gas compessor station. 2.3,3, The West Virginia Division ofAir Quality reserves the right to reopen this pe-it or any authorization issued under this pe-it ifthe area in which the facility is located is federally designated as nan-attalrment for specifiedpollutants. Ifsubsequently any proposed cousrfuction, modification and/Or OPeratiOn does not demonstrate eligibility and/or compliance with the requirementsS provisions, standards and conditions ofthis General Permit, this General Permit registration shall be denied and an individual permit for the proposed activity shall be required. West Virgimia Depatnent ofEnvironmemtal Protection. Division ofAir Quality G35-a Natural Gas Compressorand/or Dehydration Facmty 2.4. 7 of38 DeflhitiOnS 2.4.1. All references to the west virgI.nia 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" m.Cans those provisions contained in 42 U.S.a. !§ 7401 to 767]q, and regulations promulgated thereunder. 2.4.3. c¬Secretary', means the Seeretary ofthe Department ofEnvironmental Protection or such other person to whom the Secretaryhas delegated authority or duties pusuant to w.va. code §§ 22-1-6 or 22-1-8 (45CSR§30-2. I2.). The Director ofthe Divisi.on ofA.ir Quality is the Secretary,s designated xpresentat`ive forthepunlposes ofthis permit_ 2.4.4, 2.5, The te-s established in applicable deflnitiOus codified in the Code ofFederal Regulations inclpding 40 CFRPart 60 NSPS Subparts A, IIII, JJJJ, and OOOO or 40 CFRPart 63 MACT Subparts A, rm and ZZZZ shall also apply to those sections ofGeneral Permit G35-C wl ere these subparts are incorporated or otherwise addressed. Acronyms BBLorbbl BaneI CAAA Clean AirAct Amendments CBI Confidential Business lfomation GEM CES a.F.R, CO a.S.R. DAQ DEB Continuous EmissionMonitor CertifiedEmission Statement Code ofFederalRegulations CarbonMonoxide Code ofState Rules Division ofAir Qunlfty Department ofEnvironmental Protection FC)IA Freedom ofInformation Act HAP Hazardous AirPollutant HP Horsepower lbthr Pounds perhour LDAR LeakDetection and Repair M orm Thousand MACT Maximum Ach`ievable . Control Technology M)HI MaximumDesignHeat Input MM or.mm Million MhffiTUth MillionBritishThemal Units Per Hour h"CF/hr N/A NAAQS MillionCubic FeetperH6ur Not Applicable National Ainbient Air Quality LAT Standards National Endssions Standards for Hazardous AirPollutants Latitude ION Longitude NESHAPS NOx NSCR NSPS PM PM2,5 Nitrogen Oxides Nor Selective Catalytic Reduction New Source Perfo:lmance Standards Particulafe Matter Partioulate Matterless than 2.5 LLm in diameter PMla Particulate Matter less the 10 pm in diameter rpm ppfty PSD pst RICE I arts per mimon. Parts per rfullion byvolume Prevention ofSignificant Deteriorinon Pounds persquare inch Reciprocating hatemal Combustion Engine SCR SIC Selective Catalyrfic Reduction Standard Industrial Classification SIP State lmplementationPlan SOB TAP TPY TSP USIPA UTM VEE Vac VRU Sulfro Dioxide Toxic Air Pollutant Tons per year Total Suspehded Particulate United Stales Environmental Protection Agency Universal Tramsverse Mercator Visual Emissions Evaluation Volatile Organic Compounds Vapor Recovery Uric West Virginia Department ofEnvironmental Protection. Division ofAir Qunljty G35-C 8 of38 Natural Gas Compressor and/or Dedydration Facility 2.6. Permit Expiration and Renewal 2.6.1. This Class II General Pe-it shall remain valid, condnuous and in effect unless it is revised, suspended, revoked or.otherwise changed under an applicable provision of45CSR13 orany other applicable legislative rule- 2.6.2. General Pe-it registrations granted dy the secretary shall remallValid, COntinuOuS and in effect unless suspended orrevoked by the secretry. Ifthe 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.[4SCSR§ 3-10.2, 45CSR§ 3-10.3] a.7. , Administrative Update to.GeneralPermit Registration 2.7.1. The registrantmayrequest an admhistrative update to their General Perfut registration as deflned in and according to the procedures specified in 45CSR§134. [4SCSR§13ul1.I 2.8. Modification to General PermitRegistration 2,8.1. 2.9. The registrantmayrequest a minorpqurit modificationto their General Permitregistration as defined in and according to theprocedures specified in45CSR§13-5. [45CSR§13-§.I . DutytoComply I 2.9.1. I The registered facility.shall be constructed and operated in accordance with ire.information filed in the General Prmit Registration Application and any amendinents 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 appHcable conditions ofthis class II GeneralPermit, Any GeneralPermit noncomplianee constitutes a violation ofthe west vlrginia Code, and/.or.che clean AirAct, and is grounds for enforcement actionbyds secretary orUSEPA. 2.9.3. VIolation ofany ofthe applicable requirements, provisions, standards or conditions coutained in this Class II GenerarPermit, or incorporated hereinby reference, 1my subject the registrant to civil and/or criminal penalties for each Violation and further actiom orremedies asprovided by west VIrginia Code 22-5-6 and 22-5-7. 2.9.4. Registrationunder this Class II General Permit does not relieve the registraut herein ofthe responsibility to apply for and obtain all other permits, liceuses' and/or approvals from other agencies; i.e. local, State and federal, which may havejurisdiction over the construction and/or operation ofthe source(s) and/orfacility herein permitted. 2. 0. Inspection and Entry 2."1. The registrant shall allowi any authorized representative ofthe secretay 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 perfut; West Virginia Department ofEnvironmental Protection. Division ofAir Quality G35-a Natural Gas Compressor and/or Dekydration Facility 2.l1. 9 of38 b. Have access to and copy, at reasonable times, anyrecords that rest be kept underthe conditions ofthis Class II General Permit; a. Inspect atreasonable times (including all tines in which the facility is in operation) any facilities, equipment (including monitoring and airpollution control equipment), practices, or operations regulated orrequired under this class II General Permit;. a. Sample or monitor tat reasonable times, substances orparameters to determine compfiance with the pe-it or applicable requirements or ascertain the amounts and types ofairpollutants discharged. iveed to Halt orReduce Activity notaDefense 2.I I.1. It shall not be a defense for a registrant in an enforcement action that it would have been necessary to halt or reduce thepermitted activity in order to maintaincompliance with the conditions ofthis Class II General Pendt. How-ever, nothing in this paragraph shall be construed as precluding consideration ofa need to halt or.reduce activityas a mitigating factor in determhing penalties for noneompliance ifthe health, safety, or enviroflmental impacts ofllalting or reducing operations would be more serious than the inpacts ofcontinued operations. 2.12. Emergency 2.12.1.. An "emergency" means any situation arising from sudden andreasonal)lyunforeseeable events beyond the confrol ofthe source, inluding acts ofGod, whicfrsituation requires immediate corrective action to restore no-al operation9 and that Causes the SouCe tO exceed a technologybased emission limitation under this Class II General Permit, due to unavoidible increases in endssions attributable to the emergency- An emergency shallnot include noncompliance to the extent caused byinproperly designed equipment, lack ofpreventative maintenance, careless or inproper operation, oroperatorerror. 2.12.2. In anyenforcement proceeding, the registrant seeking to establish fro occurrence ofan emergency has the burden ofproof. 2.12.3. 2.13. This provision is in addition to any emergency or upset provision contained in.any applicable requirement' Federally-Enforceable Requirements 2.13.1. All terms and conditions in this permit are enforce'able by the secretary, USEPA, and citizens under the Clean Air Act. 2.13.2. 2. 4. Those provisions specifically designated in the permit as i¬state-enforceable only,. shall become ¬'Federally-Enforceable" requirememts upon SIP approval by the USEPA` ` Duty to Provide Information 2.14.1. The registrant shall fumish to the Secretary widin areasonable tine any information the secretary may request in whting to dete-ire whether cause exists for modif3ringJ reVcking and reissuing, Or tendnating this Class II General Pe-it Registration or to deterlrine compliance with this General Pemit. Upon request theregistrant shall also fumish to the secretary copies ofrecords required West VirginI'a I)epartprent ofEnvironmental Protection. Division ofAir Quality .G35-C NItural Gas Compressor and/o'r DehydrationFacility 10 of38 to be keptby the registrant. Forinformation claimed to be confidential, de registrant shall fumish suchrecords to the Secretaryalong with a claim ofconfidentiality inaccordance with 45CSRI1. Ifconfidential information is to be sent to USEPA, the registrant shall dhectlyprovide such information to USEPAalong with a claim ofconfidentiality in accordance with40 C.F.R. Part 2- 2.15. Duty to Supplement and Correct Information 2.15.1. Upon becondng aware ofa failure to submit any relevant facts or a submittal ofincorrect information in anyregistration application, the registiant shall promptly submit to the secretary suchsupplemental facts or coneeted info-ation- 2.16.I Credible Evidence 2-16.1. Nothing in this Class II General Perfut shall alter or affect the abilityofany person to establish compHance with, or a violation of, any applicable requirement through the use ofcredible "evidence to the extent authorized by law. Noting inthis pendt shall be construed to walTe any defenses otherwise available to the registrant including butrotlinited to any challenge to the credible evidquce mle in the context ofany future proceeding. 2.17. Severability 2.l7.I, The provisions ofthis Class II General Permit are severable. Ifanyprovision ofthis class II General Permit orthe application ofany provision ofthis class II General Permit to any cireumstance is held invalidby a court ofcoxpetentjurisdiction, the remaining class n General Permit tems and conditions or their application to other ofrcunlStanCeS Sllall remain in ffll force and effect. 2.l8. Property Rights 2.18.1. Registrationunder this class II General Permit does not convey anypropertyrights ofany sort or anyexclusive privilege- 2. 9, NotifICafon Requirements 2.19.1. The registrant shall notify the Secretary, in vlfting' nO later than thirty (30) calendar days afterthe actual startup ofthe operations authorizedunder this permit. 2.20. Suspension ofActivities 2.20.1. In the event the registrant should deem it necessaryto suspend, for aperiod in excess ofone (1) year, all operations authorized by this permit, the registrant shallnotifythe Secretary, in writingJ within two (2) calendar weeks ofthe passing ofthe one (1) year ofthe suspensionperiod. 2.21. Transferat)ility 2.2l.1. This permit is transferable in accordance with the requirements outlined in section 10.I of 45CSR13. [4SCSR§ 3-10,1.I West Virginia Department ofEnvironmental Protection. I)]'vision ofAir Quality G35-C Natural Gas Compressor and/of Dehydration Facility 3.0. ll of38 . Facility-Wide Requirements 3.1. SitingCriteria 3.". All persons submitting a class II General Perfut Registration Application to coustrucq modify or relocate a natural gas compressor andior ddydrion facility shall be subject to the following Biting criteria: a. No edssion nit shall be constructed, located orrelocated within 300 feet ofany occupied dwelling, business, public building, school,,church, communitybuilding institutional buildihg orpubnc park. An orrmer ofan occupied delling or business may elect to waive the SOD foot Citing criteria.. b. 3.2. Anyperson proposing to construct, modify or relocate any emission unit(s) within 300 feet of any occupied dw-elling, 6psiness, public building, school, church, cormunity iustitufronal building orpublic parkmay elect to obtain an individual permit pursuant to 45CSR13' Limitations and Standards 3.2.I. Open burning. The openbuming ofrefuse by anyperson is prohibited except as noted in 45CSR§6-3.1. [45CSR§6-3.I.I 3.2.2. Open burning exemptions. The exemptions listed in45CSR§6-3.1 are subject to the following stipulation: Upon notification.by the secretary, no person shall cause orauow any form ofopen buming during existing drpredictedperiods ofatmospheric stagnation. Notifroation shall be made by suchmeans as the Secretary may deem necessary and feasible. [45CSR§6-3.2.I 3.2.3. Asbestos. The registrapt is responsible for thoroughly inspecting the facility} orpart ofthe facility, prior to commencement ofdemolition or renovation forthe presence ofasbestos and complying with 40 a.F.R. § 61.145, 40 a.F.R. § 61.148, and 40 a..F.R. § 61.150. Theregistranq ouner, or operatormust notify the Secretary at leastten (10) working days prior to the commencement ofany asbestos removal on the forms prescribedbythe secretary ifthe registrmt is sutlject to the notification requirements of40 a.I.R. § 61.145ap)(3)(i). USEPA, the Division of Water and Waste Management a)WVA4)a and the Department ofHea1[h and Human Resources (DHHR) - Office ofEnvironmental Health Serviees (OEHS) require a copy ofthis. notice to be sent to them. r40CFR§61.145m) and 45CSR§34] 3.2.4. Odor. Nq person sham cause, suffer, allow orpermit the discharge ofair pollutants which cause or contribute to an objectionable odor at any location occupiedby the publie. L45CS"§4-3.1] [Stote Enif;orcechle OnlyJ 3.2.5. Permanent shutdown. A source which has not operated at least 500 hour in one, twelve (l2) month period within the previous five (5) year time period maybe consideredpemanently s11utdOun] unless Such Source Can Provide to the Secretary, with reasonable specificity, info-ation to the contrary. All pendts may be modified or revoked and/orreapplication or application fornew permits maybe required for any souree detelndned to bepermanently sP±:b,I,rm. This reqwienehi doesint apply to emergency generder(s) perm;tiedto ape;ate only 500 hours per year. [4SCSR§13-1O,5.I West Virginia Department ofEt]vironmental Protection. DivisI-On OfAir Quality 12 of38 G35-a Natural Gas Compressor and/or Dedydration Facility 3.2.6. Standby plan for reducing emissions. wllenrequestedby the Secretary, the registrant shall " prepare Standbyplans for reducing the emissions ofair pollutants in accordance with the objectives set forth in Tables I, II, andIll of45CSR11. [4SCSR§11-a.2.I 3.2.7. Minindzafron ofFugitive Emissions. The registrant shall operate consistent With info-atiOn provided in regI.Strant,§ G35_a General Pendt Registration Application for fugitive emission Sources. [4SCSR§13-5.ll.I 3.2.8. . 3.3. The registraut shall not create a nuisance to the surrounding COmmunityby Way OfuneaS;nable noise and light during operation. Monitoring Requirements See Seedon 4.2. 3.4. Testing Requirem`ents 3.4,1. Stack testing. As per provisions set forth in this Permit Or as Otherwise required bythe Secretryy, in accordance withthe west virginia code, underlying regulations,.permits and orders, the registrant shall conduct test(s) to determihe compliance With the emissionliritations set forth in this.class n General Permit and/or established or set forth inunderlying documents. The secretay, or their duly authorized representative, may at histheroption witness'or conduct sueh test(s)., should the Secretary exercise histher option tO COndrCt Such test(S), the OPerator Shall provide all necessary sampling Connections and sampling ports to be located in Such manner aS the secretary may iequire, power for test equipment and the required safety equipment, such as scaffolding, railings and ladders, to comply with generally acceptedgood s.afetyPractices. Such tests shall be condueted in accordance withthe methods andProcedures Set forth inthis Permit Or as otherwhe approved or apecifled by the Secretary in accordance with the following: a. The Secretarymay on a source:specific basis approve Or SPeCify additional testing Or altemative testing to the t-estnethods specifled in the Permit for demonstrating COmPHance with40 C.I.R. Parts 60, 61, and 63 in accordance with the Secretary's delegated authority and I any established equivalencydetermination methods Which ale applicable. Ifa testing method is specified or approved which effectively replaces a test method specified in the Class II GeneralPermit, the perinit maybe revised in accordance with45CSR§13-4. or45CSR§13-5.4 as applicable. I). a. The Secretarymayona source_specific basis require, approve Or SPeCifyadditional.testing or. altemative testing to the test methods specified in the Class II GeneralPermit for demonstrating compliance with applicable requirements which do not involve federal delegation. In specifying or approving Such altematiVe testing to the test methods, the secretary, to the extentpossible, shall utilize the sane equivalencycriteria as would be used in approving such changes under section 3.4.1.a. ofthis general permit. Ira testing method is specified or approved which effectivelyreplaces a test method specified inthe Pe-it, the permit may be revised inaccordance with 45CSR!l34. or 45CSR§13-5.4 as applicable. All periodic tests to determine mass emission limits from Orair POlfutaut COnCentrationS in discharge stacks and such other tests as specified in this Class II General Pemit shall be conducted in accordance with an approved testprotocol, suchprotocols shallbe submitted to the secretary in writing at least thirty (30) days prior to any testing and Shall contain the information set forthbythe secretary. ha addition, the registrant shall motifythe Secretary at least fifteen (15) days prior to any testing SO the Secretary may have the oppOmndtyto observe such tests. This notffication shall include the actual date and time during whichthe west virginia Department ofEnvironmental Protection I Division ofAir Quality G35-C Natunl Gas Compressor and/orDehydrationFacility 13 of38 testwill be conducted and, ifappropriate, verifroation that the tests will fully confo- to a referencedprotocol peviously approwidbythe secretay. a., The registrant shall submit a report ofthe results ofthe stacktest within sixty (60) days of completion ofthe test. The test report shall provide the 1.nformatiOn neCeSSay to.doCuneut the objectives ofthe test and to deterfune whether properprocedures were used to accompush these objectives and any operating parameters required to be m6initored. The report shall include the following: the certifi6ation described inparagraph 3.6.I; a statement of compliance status, also signed by a i.esponsible official; and, a summary ofconditious which form the basis for the compliance status evaluation. The sunrmay'ofconditions shall include the following: 1. The pe-it orrule evaluated, with the citation mlmber and lariguage;. 2. The result ofthe test for each permit or rule condition; and, 3. A statement ofcompliance or noncompliance with eachpermit oriule condition. [WV Code § 22-a-4(a)(14-l5) and 45CSRl3]. 3.5. 3.6, Recordkeeping Requirements 3.5.1. Retention ofrecords. The registraut shall ndntain records ofall information (including monitoring data, support info-ation, reports, and notifications) requlndbythispermitrecorded in a form suitable and readily available for expeditious inspection andreview. support infomation includes all calibration.and maintenance records. The files shall bemaintained for at leastfive (5) years following the date ofeach occurence, measurement; maintermce, conective action, report orrecord.. Said records shall be maintalfied bn site or in a readily ace;ssible off-site location maintained by the registrant for aperiod offive (5) years, Said records shall b; readily available to the Secretary ofthe Diwiion ofAir.Quality orhis/her duly authorized repesentative for expeditious insp.ection and review. Anyrecords submitted to the ieencypusuant to a requirement ofthis permit orupon requestby the secretary shall be certifiedby aiespousible official. Where appropriate, the regishaut maymaintain records electronically. I 3.5.2. Odors. For the prxposes of45CSR4, the registrant shall maintain a record ofall odor complaints received, any investigation performed in response.to such a complaint, and any re§pousive action(s) taken. [45CSR§4. Slr¢rt?JE#/t,rcgch/e andy.I Reporting Requirements 3.6.1. Responsible offlcial. Anyapplication fong report, or compliance certifroation.required by this permit to be submitted to the DAQ and/orUSEPA shall contain a certifroa'tion tythe responsible official that states that, based on information.and belieffanned after reasonable inquiry, the statements and information in the document are tme, accurate, and complete. . i. 3.6.2. Confidential information. A registrant may request corfldeutial froatment for the submission of reporting required by this permitpursuant to the limitations and procedhes a.f w.va. code § 225-10 and 45CSR3I. 3.6.3. Correspondence. All notices, requests, dermnds, submissious and other communieations required orpendtted to be made to the Secretary ofDEP and/or USEPA shall be made in whting and'shall be deemed to have been duly given when delivered by hand, e-malted or mailed first class withpostage prepaid to the address(es) set forthbelow or to such otherp'erson or addess as the Secretary ofthe Department ofEnvironmental Protection may designate: West Virginia Departlne'nt ofEnvironmental Protection. Divisiotl ofAir Quality G35-C 14 of38 Natural Gas Compressor and/or Dehydration Facility Ifto the DAQ.. Ifto the US ETA: Director 601 57th Street SE Associate Director Office ofAirEnforcement and Compliance ASsistanee (3AP20) U.S. Environnental Protection Agency Charleston, WV 25304-2345 RegionIll ThTVDEP Division ofAir Qunlfty 1650 Areh Street Philadelphia, PA I9103-2029 3.6.4. Emission inventory. At such tine(s) as the Secretarymay designate, the registrantherein shall prepare and submit an emission inventory for the prwious year, addressing the emissions from the facility and/orprocess(es) authorized herein, in accordance with the emission inventory submittal requirements ofthe.DAQ. After the initial submittal, the secretaymay, based upon the.type and quantity ofthe pollutants enritted, establish a frequency otherthan on an armual basis. 3.6.5. OperatingFee 3.6.5.1. In accordance with 45CSR22 - Air Qunlfty Management Fee Program, the registrant shall not operate nor Cause to OPerate the Permitted facility Or Other associated facilities on the sane or contiguous sites comprising the plant without fust obtaining an.a having in cureut eifect a Certificate to Operate (CTO). Such Certificate to Operate (CTO) shat.I be renewed anrmany} shall 6e maintained on the premises for which the'certiflcate has been issued, and shall be made immediately available for inspection by the secretary or histher duly anthchzed rapresentative. West Virginia DepartmentofEnvironmental protection. Division ofAir QuaII-ty G35-C 15 of38 Natural Gas Compressorand/or Dekydration Facility 4.0. Source-Specific Requirements 4.1. Limitations and Standards 4.1.i-. - Operation a;nd Maintenance ofAir Pollution Control Equipment and Emissioln Redrction Deices. The registrant shall, to the extent practicable, install, maintain, and operate all pollution control equipment and emissionreductiondevices listed in the issued General Permnd Registrationand associated monitoring equipment to comply with limits set forth inthis General Permit or as set foth by any state rule, Federal regulation, or altemative cbntrol plan approvedby the secretary. [45CSR?13-5. .I 4.1.2. Applteability ofState and Federal Regulations. "e registraut is subSect to the provistoms ofthe following State Rules and Federal Regulations, to the extent applicable based.on its registratiom a. b. a. d. 45CSR2 - Particulate AirPollutioll from Combustion ofFuel in IndirectHeat,Exchangers 45CSR6 - To Prevent and Control Air Pollution from the Combustion ofRealse 45CSR10 - To Prevent and Confrol AirPollution from the Emissions ofSulfilfOxides 45CSRl3 - Pe-its for Coustmction, Modification, Relocation and C)peration ofStationay Sources ofAirPollutantsj Notiflcation Requirements, Administrative Updates, Temporary Pe-its, General Permits, and Procedures forEvaluation e. 45CSR16 - Standards ofPerformance forNew Stationary Sources Pursuantto 40 CFRPart co I. 45CSk22 - Air Qilality ManagementFee Program g, 40CFR60 SubpartIIII - Standards ofPerfo-ance for Stationarycompression Ignition Intemal Combustion Engines h. 40CFR60 SubpatJJJJ - Standards ofPerfo-ance for Stationary SparkIgnition Intemal Combustion Engines i. 40CFR60 Subpart OOOO - Standsrds ofPerfoman'ce for Crude Oil andNatural Gas production, Transmission, and Distributiori i. 40CFR63 SubpartHH -National Endssion Standards forHazardous AirPollutants from Oil and Natural Gas ProductionFacilities k. 40CFR63 SubpartZZZZ - National Emission Standards for Hazardous Air Pollutants for ` Reciprocating Intemal Combustion Engines 4.1.3, The registrant shall install, maintain, and operate all above-ground piping valves, pumps, eta. that service lines in the transport ofpotential sources ofregulated airpollutants to ndnimjze any fugitive escape ofregulated airpollutints (lea]O. Any above-ground piping, valves, pumps, eta. that shows signs ofexcess wear and that have a reasonable potential for fugitive emissions of regulated airpoHutants shall be repaired orreplaced as needed. 4.1.4, The registrant sm monitor andmaintain quarterlyrecords (calendar year) for each facility component that was inspected for fugitive escape ofregulated airpollutants. Each component shall operate with no detectable emissions, as determinedusing audio-visual-olfactory (AVO) inspections, USEPA 40CFR60 Method 2I, USEPA altemative workpractice to detect leaks from equipmentusing optical gas imaging (OGI) camera (ex. FLIR. camera)I 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, Ifregistrant useslan OGI camera, then_no detectable emissions is defined as no visible leaks detected in accordance with.USEPA altemative OGI workpractices. Ifany leak is detected, the registrant shall repairthe leak as soon as possible. The fust attempt at repair must be made within five (5) calendar days ofdiscovering the leak9 and the final repair must be inade within fifteen (15) calendar days ofdiscovering the leak. The registrant shall record each leak detected and the associated repair. The leak will notbe consideredrepaired until the same monitoring method or a more detailed insthrment determines the leak is repaired. West Virginia Department of EnviromneutaI Protection. Division ofAir Qual]'ty G35-a Natural Gas Compressor and/orDehydration 16of38 Delay ofrapair ofa closed vent system for which leaks or defects have been detected is allowed ifqe xpairis technically infeasible without a shutdovvn, or ifyou deterndne that emissions resulting from immediate repair.wouldbe greaterthan the fugitive endssions likely to result from delayofxpair. you mustcompleterepair ofsuch equipmentbythe end ofthenext shutdoun. [45CSR§13-S.11.I I 4.2. RecordkeepingRequirements 4.2.1. uro#!'torz'ng F'%rrmCZfZ'Oj2. The registrant shall keep records ofmoritoring information that include the following: i. The date, place as defmed in thispe-it and time ofsampling orneasurements; b. The date(s) analyses were perfcl:rmed; c. The company or entitythatperfo-ed the analyses; d. e. i. The analytical techniques or methods used; The results.ofthe analyses; and The operating conditions existing at the time ofsampling ormeasurement. 4.2..2. RJeCCnd ofMatnteranee ofAir Polhaion Corttrol riqutpmehi and Emission REduetion Devices. For allpollution control equipment and emission reduction devises listed in the General remit Registrinon, the registrant shall maintain accurate records ofall required pollution control egivpment and endssionreduction devices inspection and/orpreventative maintenance procedures specificallyrequired in this GeneralPermit. 4.2-3. Record ofMaifuncttous ofAir Pollution Control Equipment andEmission R:educton I)eviees. For au airpollution control equipment and emissionreduction devices listed in the General Permit Registration, the registrant shallmaintainrecords ofthe ocourmce andduntion ofany malfroction or operational shutdounofthe airpollution control egivipment.and emission reduction devices during which excess emissions above the apphicable perndt limit occur. For each such case, the following information shall be rec.ord;d: a. b. a. d. The equipment involved Steps taken to minimize endssions during the event' The duration ofthe event' The estimated increase in emissions during the event. For each such case assof;iated with an equipment malfunction, the additional information shall also be recorded:' a. f. g. The cause ofthe malfunction. Steps taken to correct the malfunction. Any changes or modifications to equipment or procedures that w'ould help prevent future recurrences ofthe malfunction. West Virginia Deparment ofEnvironmental Protection. Division ofAir Quality G35-a Natural Gas Compressor and/or Dehydration Facility 17of38 5,0. Source-SI)eCiflC Requirements [Storage Vessels Containing Condensate and/or Produced Water] 5.1. Limitations and Standards 5.I.1. Ermissto# Lr#!ts. The maximum design capacity for any registered storage vessel (condensate and/or produced water) listed in the G35-a General Permit Registration shall not exceed the maximum design capacity recorded with the registrmt's General Pe-.I RegistratiQin. 5.I.2. A4lflxj7##ue Sronge Flare/ ZltrongkyttfZz.J"i.r¢fZ.O#. The registiant shall not exceed the throughput recorded with the registrant's G35-a General Permit Registration without first obtaining a modification br administrative update: Compliance with the armual throughput limitation shall be. ?eta-inedusing a twelve (l2) month rolling total. A twelve (12) monthromng total shall mean the sum ofthe storage vessel throughput at any given time.during the previous twelve (l2) consecutive calendarmontris. 5.1.3. J!egiv¢fed Po//"f¢#f'£z.ovz.rerfz.on. The registrant shall not cause, suffer, allow or pe-it emis.sious ofany regulatedpollutant from any storage vessel (condeusate and/orproduced water) listed i.n the G35-a General Pe-it Registration to exceed the emission limi,I. in pounds per hour and tons per year recorded within the registranfs General Permit Registration without obtaining an administrative update ormodification. 5.1.4. EJ"isS,'Ous Cfeferm!.#¢fro#. The registrant shall determine the voa emissiohs for each. storage vessel (as defined in § 60.5430). to determine affected facility status (cormenced construetionJ modification Or reconstruction after 'August 23, 2O11) in accordance with the expJ.#fOus c7efermz.J!¢fZ.O7g required in40CFR60 Subpart OOOO. 5.1.5. Co##o/Dev!.ce£. The registrant shall installs operate, and -intainall control devices listed in the G35-a General Pe-it Registrationfor the purpose OfCOntrolling emissions from the Storage vessels im accordance with what was recorded vi/ith the registrant,a General Permit kegistration Application. 1. C!orl_ro_I D_gP:es thfit are yet syhiect to tPe.catnd devise requireneds ofNSPS, Subpart OOOO. Ifthe-registranthas determinedper section 5.1.4 ofthis general permit thatthe storage vessel(s) are mot subject to control requirements of40CFR60 Sutpart OOOO, the registrant shall choose whether they want to be subject to the control device and clog,ed vent system requirements ofsection 6.0 or section 7.0 ofthis general permit. 2. Pout:gl.Devicys that_are fuftyec! to the coritrol device requbements ofNSPSi Subpart OOOO. i. Ifthe registranthas determined per section 5.14 ofthis general permit that the storage vessel(s) are subject to control requirements of40CFR60 Subpart OOOO, fro registrant shall be subject to the control dew.ice and closed vent system requirehents ofsection 6.0 ofthis general permit. ii. S.+.6. The registered enclosed combustion den.ice, flare or incinerator is subject to 45CSR6. The registrant is subject to the applicable requirements specified in45CSR6. -Site specific sample. (Onlyfor storage v,essels with no air pollution control devices or i,RTs) 1. 4p/!'coaz./try. The requirements ofthis section apply to s'torage vessels that meet the requirements ofparagraphs (a) and (b). a. Any storage vessel that contains condensate and/orproduced water. West Virginia Department ofEnvironmental Protection. Division ofAir Quality G35-a Natural Gas Compressor and/orDehydration Facility b. 18 of38 Any storage vessel that is not subject to the control device requirements ofsection 5_1.5 ofdig generalpermit. a. 2. Any storage vessel that has an upstream lowpressure tower that meets the requirements ofsection 5.1l.4 ofdis general pendt is exinpt from the requirements ofthis section. Forregistrants that meet the applicahilityrequirements ofparaglxph (1) ofthis section, the registrant shall use a site specific sample to determine potential emissions. The registrant shall comply with the following: i. .The site specific sample shall be taken`within thirty (30) days ofstartup. ii. The'txpe and location ofthe sample shall be approprias for the calculation methodology or model (e.g. ProMax, E&P Tanksg HYSYS) being used fo calculate the emissions. The sample location shall be equipped with appropriate sampling access. iii. Ifthe Voa potential emissions are higher than the emission limits in the registration, DAQ shall be notified in accordance with section 5.4.1. a. s.2. Theregistrant shall re-evaluate the voa potential emissions based on the site specific sample within 90 chys ofreceiving the analysis ofthe site specifro sample dote-inedper section 5.1.4 qftl]is general permit- MonitoringRequirements 5.2'l. Flash einissiclns. 1. 2. The requirements ofthis section apply to.storage vessels that meet de requhements of paragraphs (a) and a ofthis section.. , a. Any storage vessel that contains condensafe and/orproduced water. b. Any storage vessel that is not subject to the control device requirements off..1.5. a. Any storage vessel that has a VAU system that is designed and operated in accordance with section7.1'7 ofthis generalpermit is exempt from the requireinents ofthis.section. The registrant shall mohitor'and maintain quartedyrecords ofthe temperature.andpressure upstream ofany storage vessel containin'g condensate and/orproduced water at. th; appropriate separation unit based on the caleulation methodology ormodel'being used by the registrant to calculate their Vac flash emissions. Pressure monitoring shall not be required ifthe pressure setting is greater than the pressure safety valve for the storage vessel(s). 5.2.2. Uncontrolled production storage vessels that are fed by a gas to liquid separator shall perform the following: 1. Inspect and maintain records ofthe separator liquid level that opens the dump valve on an as needed basis and annually (at a minimum). 2. Inspect and maintain recprds of the separator dump valves operation per manufacturer "recc-mendations or annually (at aI]rihimum). West Virginia Depanment ofEnvironmental Protection. Division ofAir Quality G35-a Natural Gas Compressor and/or Dehydrafron Facility 5.3. l9 of38 RecordkeepingRequirements 5.3.1. To demonstrate compliance with section 5,1.I - 5.I.3 ofthis generalpermit, the registrant shall maintain a record ofthe aggregate throughput forthe storage vessel(s) that contain condensate and/orproduced water on a monthly androlling twelve (12) month total. AItematively, recording the.monthly and rolling twelve (12) month total ofcondensate and/orproduced wafer loaded into tanker trucks from the storage vessels according to section 14.2.1 can beused to demonstrate compliance. Sal¢ records shall be maintained in accordance with section 3.5.1 ofthis general permit. 5.3.2. To demonstrate con?pliance with section 5.1,4 ofthis general permit,.the registrant sham maintain records ofthe determination ofthe Voa emission rate per storage vessel, including identification ofthe model or calculation methodologyused to calculate the voc emissionrate. 5.3.3. To demonstrate compliance with section 5.I.6 ofthis general peIIhit, the regiStrant chall lnaintain records dfthe I.ype ofsample taken, the location ofthe 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 lras taken, the analysis ofthe sample, and the resulting emissions calculations using the site specific sample_ 5.4. Notification nnd Reporting RequiI.ementS 5.4-1. The registrint shan notifythe Director ofine DAQ in vliting for any instance when the POtential emissions determined with a site apeciflc sample in accordance with section 5.1.6 ofdig general pe-it were greater than thepotential emissions provided in the G35-a general.permit applieation. The notification shall include whetherornot this change in enissious affects applicability dete-ination to NSPS, Subpart OOOO for any storage vessel. Thenotification to the Director shallbe provided no later tIlan 30 days from the date ofdiscovery ofthe increased emissions. West Virginia Department ofEnv]'ronmental Protection , Division ofAir Quality G35-a Natural Gas Compressor and/or Dchydlndon Facility 6.0. 20 of38 Source-Specific Requirements [Standards ofPerformance for Storage Vessel Affected Facilities orSPS, SubpartOOOO)I 6.1. LilnitatiOnS and Standards 6.". The registrant ofeach storage vessel affected facility (commenced construction, modificndon or reconstruction afterAugust 23, 2011) shall comply with the applicable requirements specified in 40 CFRPart 60, Subpan OOOO, unless theyhave installed a VRU or haveFederally Enforceable Controls to limit each storage vessel(s) potential to emit below 6 tors per year ofVolatue Organic Compounds. 7.0. \ Source-Specific Requirements [ControI Devices and Emission Reduction Devices not subjectto NSPS Subpart OOOO and/or NESHAP SubpartHH] 7.1. Limitations and Standards Scope: The scope ofthis seetwn is to address requlrenentsfor cor[trol devices and enissiorl reduction " de`P;es i_h?i v:ill Pa ipstq_l!ed an_d_operated to control air endssiow at a natural gas compressor a_mq/or de_hpgrationI;acility cndthat are rot suftyect to NSPS, Subpart OOOC) or-NESHin, Subpa:iH¥ requirenems. Ifthe antrol device is stryect.to NSPs, sbtbpart oooo corlt;ol devise and closed syslen reqwiremehis' they are suftyect to section 6.0- Pass_ibl.a :or!trol and_emission !e_4rc_tion jevices meeting the scope ofthis seckon inckde: (1) a:_ytrol deyic_es _used to sontrol VO_C__a_xp H4P emissionsfrom the tinker truckloading ape;;tions; (_2_)LS_a_nt:o! devic_es_u_se_d fo co_ut!?I YqC and IIAP enissivusfrom the storage vessel(s-) inow the NSP.S, Subpar! OOPO th:Eshold of6 toy V9C. Corltr_ol devices that are pJ;witted irirder a legally and_pr_actically erif;orceable stc!tepermit achieve a "federally erferceab[e PTE" for VC)C: enissions at the storage vessels; and (3) coutyal dejtees used t6 control vac: and IIAP enissious from dekydrativn units. 7.1.1. Operation and Motinterarlce ofAir Pollbitiqn Cohirol Equipment and Emission Reduction Devices. Thae registrant shall, to the extentpracticable, install, maintain) and operate all air pollution control equipment and emissionreduction devices listed in the General Permit REgistration and associated monitoring equipment in amarmer consistent with safety and good airpollution control practices forndhimizing emissions, or comply with any more stringent limits set forthjfl this perfut or as set forth byany State rule' Federal regulation] or altemative control plan approved by the Secretary- [45CSR§13-5.11.I 7.1.2.. E#c/osed CoJ#a,i.Sffo7! I)er,jces cz#dF/¢ffes. The registrant shall comply with the requirements in this section for any registered enclosed combustion dev'ice orflare 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, eta.) where the control device is both subject to and not subject to NSPS, Subpart OOOO requirements depending on the emission §ouro; being controlled and ifthe control device was designed accordingly. Ifthe registraut uses the control device for multiple source types, they shall comply with the more stringentNSPS,. Subpart OOOO closed vent system and control device requirements for the entire system and shall comply with the applicable NSPS, Subpact OOOO closedvent syst.emand confrol requirements for storage vessels provided in section 6.0 oftIliS general Permit. West Virginia Department ofEmvironmentaI Protection. Divisidn ofAir Quality G35-C Natural Gas Compressor and/or Dehydration Facility 2, 21 of38 JI/d!res.- Ifthe registrant utilizes a flare control device, the registrant shall comply with the design and operating-requirements bE;low: i. Vapors that are being controued by the flan shall be routed to the flare at all times. ii. Flares shall be operated with a flanspresent at all times, as determined bythe methods speeifled in Section 7.2.1 ofthis general permit; iii. Flares shall be desigmed according to the requilenents specified in § 60.18; iv. Flares shall be operated at all times'when emissions are vended to them; v. To ensue compliance with 7.I.2,2 (iv) ofthis generalpermit, the registrant shall monfror in accordance with section 7'2.I ofthfs general pemit. vi. Flares shall be designed for and operated withno visible emissions as detendned by the methods specified inpermit section 7.3.I ofthis general pe-it exceptforperiods not to exceed a total of5 minutes during any 2 consecutive hers; and, I via. The registrant shall monitor the flare(s) to ensure that they are operated andmaintained in confomance with their designs. The registrant may claim a capture and control efficiencyofg8% for those unit meeting the requirements of2.i-vii. 3. E#c/ased Ca7"att£fZ'OreDevz'ces. Ifthe registrantutilizes an enclosed combustioncontrol device' the registrant shall comply with the designand operating requirements belovi: i. Vapors that are being controlled by the enclosed combustiondevice sham be routed to the enclosed combustion device at all times. ii. The enclosed combustion devic: shall be operated with a flalhe peSeut at all times, as dete-ined by the methods speeifled in sections 7.2'l and 7_2.3 oftlris geheralprmit. iii. Enclosed combustiom devices shall be desighed for and operated wiin no visible emissions as dote-ined bythe methods specified in section 7.3.1 ofthis gcheral permit except for either (a) or (b): - a. periods not to exceed a total ofone minute during any 15 rfunute period, determined on a monthly basis; or b. periods not to exceed a total oftwo (2) minutes during any hour,'determined on a quarterlybasis ifthe enclosed combustion device installed was a model tested under ! 60.5413(a) which meets the criteria in § 60.54I3(d)(11). iv. Enclosed combustion devices shall be operated at all times when erfussious are vented to them' v. To ensure compliance with 7.I.2.3(iv) above, the registrant sllall monitor in accordance with section 7.2.3 ofthis general pemrit. vi. The regiStrant shall operate and maintain the enclosed comhastion device according to the manufacturer's specifications.for operating and maintenance requirement; to maintain the guaranteed control efficiency listed in the General PermitRegistration. West Virginia Department ofEnvironmepral Protection. Diyisjon ofAir Quality G35-C 22 of38 Natural Gas Compressor and/or Dchydlalon Facility The registrantquayclaim a capture and control efficiency of98% for those units meeting the requirements of3.i-vi. 4. erosefZ 7eJZffysferm. The registrant shall compl) with the closed vent system requirements in section7`1_4. 5. A4dr!.ne#wi Des!.gr ffefffJJZj,#£ The maximum design heat input forany registered flare or enclosed coinbustion device listed in the Genend Permit Registration shall not exceed the -Maximum Design Heat Input (MMBtu/hr) recorded with the registrant's General Permit Registration. 6, 7,1.3. The registered enclosed combustion device or flare is subject to de applicable requirements specified in 45CSR6' CoverJieg#froJacerets. The regiStraut Shall COmPly viith the Cover requirements in this Section ifthe potential emissions that were calculated to. determine affected facility status did holnde recovered v-apors fi-om the storage vessel as allowed and in accordance with 5.1.4 ofdis generalpermit. 1, The cover and all openings on the cover (e.g.9 access hatdss, sampling ports, pressure relief valves and gauge wells) shall form a condnuous imperlneable barrier OVer the entire Surface area ofthe liquid in the storage vessel. 2. Each cover opening shall be secured in a clos'ed, sealedposition (e.g.) covered.bya gasketed lid or cap) whenevermaterial is in the unit on whch the.cover is installed exceptdyrfug those times when it is necessary to use an opening as fomows: (i) To add material to, or remove material from the unit (this inelndes openings necessaryto equalize orbalance the intemalpressure ofthe unit following changes in the level ofthe . material intheunit); (ii) To inspect or sample the material in the unit; (iii) To. inspect, maintain, repair, or replace equipmentlocated inside the unit; or (iv) To vent liquids, gases, oifi-es from the unitthrough aclosed-vent system designednd operated in accordance with the requirements of this general perhit to a control device or to a prlocess. 3. Each storage vessel thiefhatoh shall be weighted andpropedyseated. you must select gasket material for the hatch based on compositionofthe fluid in the storage vessel and weather conditions. [45CSR§13-S.11.I 7.1.4. Closet Vey! Sys!epe,s (a_pplies to all non 40CFREO Swbpart OOOO cohirols). TheregjsittITitchm comply with de closed vent system requirements in dig section ifthe potential emissions that were calculated to dete-ine affected facility status did include recovered vapors from the storage vessel as allowed and in accordance with 5.1.4 ofthis general permit. 1. You mustdesign the closed vemt system to route all gases, vapors, and fumes emitted from the material inthe storage vessel to a control device that ineets the requirements of S-I-5 ofthis ge.neral permit or to a process. The registl-I shallperform an initial LDAR evaluation within thirty (30) days ofstart-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 endssions, as dete-inedusing audio-visual-olfrotory (AVO) inspections, USEPA 40CFR60 Method2I, West Virginia I)epartmentofEnvironITlentaI Protection. Division ofAir Quality G35-C Natural Gas Compressor and/or DedydrationFacility 23 of38 USEPA altemative workpractice to detect leaks from equipment using optieal gas irmging (OGI) camera (e,g. FLIR camin), or some combination thereof AVO inspections shall include, but not limited to, defects as visible cracks, holes, or gaps.inpiping; loose connections; liquid teds; or brcken or nds§ing caps or other closue devices. If registrant uses USEPA Method 21, then no detectable emissions is defined as less than 500 ppm in accordance with Method 2l. Ifregistrant uses an OGI Camera, then no detectable . emissions is defmed as no visible leaks detected in ace.ordance with USEPA altemative OGI work practices. ( 3. You must meetthe requirements ;pecified in (I) and (2) ofthis section ifthe closed vent system contains one ormore bypass devises that could be used to divert all or aportion of .the gases,. vapors, orfumes from entering the control device or to aprocess. i. Except as provided inparagraph (2) ofthis section, you must comply with either paragraph (A) or (B) ofthis sectionfor each bypass device. A. You mustproperly install, calibrate, maintain, and operate a flow indicatorat the inlet to the bypass device that could divert the steam away from the control device orproce.ss to the atmosphere that sounds an alarng orinitiates notification viaremote alam to the nearest field office, when the byp.ass device is open sueh that the stream is being, or could be, diverted.anny from the control device orprocess to the atmosphere. B. You must secure the bypass device valve installed at the inlet to the bypass device in the nan.diverting position using a oar_seal or a lock-and-key type configuntion. ii. Low leg drains, highpoint bleeds, analyzes vents, open-ended valves orlines, and safety devices are not subject to fro requirements ofparaglxph (i) ofthis section. [4SCSR§13-a.ll,I 7,I.5. carfroJZ4c7sorJ,ffo# Sysfeurs. The registrant shall comply with the requirements Lelow for any "registered carbon adsaption system that is listed as a control device in the General Permit Registration: i. The canon adsoxption system shall be designed to achieve the lninrfum guranteed control efflciqucy that is listed in the General Permit Registration for volatile orgalc compound IVOa).emissions; fi. The carbon adsorption system.must be operated at all times whengases9 Vapors, and.fumes are vented to it. Carbon canisters shall be operated in series as dual cafoon canisters, in case ofemissionbrealthrough in one cachon canister. iii, The carbon adscxption system must have a commercially manufactued saturation indicator installed. " iv. Prior to the loading ofeach truck, the saturation indicator on the carbon adsorption system shall be checked to ensure that the carbon is not sperfu These records must be kept in accordance with section 3.5.I ofthis general permit. Ifthe saturation indicator demonstrates " that the carbon is saturated, tmck loading is.prohibited and/or enrissious 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 saturafron indicator changes in color and indicates satuntion. vi. Fresh replacements for all carbon being used in the carbon adsoxption system shall be kept on site- West Virginia Depannent ofEnyironmental Protection. "vision ofAir Quality G35-C Natural Gas Compressorand/or Dekydration Fas.ility 24 of38 The registrant mayclaim a control efficiency of95% for those lndts meeting the requirements of 7.1'5.i-vi. 7..1.6. Co#deuser5+BrEFjr/z'#zz'#¢fo#5. The registrant shall comply with the requirements below for any registered condeuserneTEX EIindnator that is listed as a control devieefemission reduction device for a glycol dehydration unit in the General PermitRegistration: i. ii. Vapors that are being controlledby the condeuserreTEX Eliminator shall be routed through a closed vent system to the condenser/BTEX Eliminator at all times when there is a potendal that vapors (emissions) can be generated from the glycol dehydration still colurm. The condeuserreTEX Eliminatorshall be designed, operated,,and maintained according to good engineering practices and manufacturer,s speeificatious so as to achieve, at a hinimum, a capture and control efficiency of50%. a. The registrant may claim a capture and control efficiencygreater than 50% ifthe General Permit Registration was approved based on manufacturer.s specifications and the unit was operated as such. 7.LJ , Vapor Recovery Units OrR.Us) i. The registrant shall complywith the closed vent systemrequirements in section 7.1.4 ofthis generalpendt. ii. The registrant may claim a capure and control efficiency of95% rwfrjcfe coco##g.roy 5% expected downtime). ifi. The registrant may claim a.capture and control efficiencyof98% ifthe VRU has a backup flare (enclosed combustion device) that meet the requirements ofsection 7.1.2 ofthis general pendt. i I iv. The registrant may clain a capture and control efficiency Of98% ifthe VRU has a backup VRU. 7 i.8. Glyco! Dekyqrqtion.Units Re_prcliylg B_aceto Flame Zone ofthe Rebotler. IftlNeregjyS-iis reducing emissions by recycling the glycol dekydratich unit back to the flame zone ofthe reboiler, it shall be designed and operated in accordance with the following: a, The vapors/overheads from'the still colunm shall be routed through a condenser at all times whqu 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 cofurm and flash tank, and natural gas may be used as a supplemental fuel. a. The vapors/overheads from the still column shall be introduced into the flans zone ofthe reboiler as the primary fuel orwith the primary fuel I)efore the combustion chamber. The registrant may'claim a captllre and COntrOl efficiency Of50% for those units meeting the requirements ofeither a or b. The registrant may claim a captue and control efficiency greater - than 50% ifthe General PermitRegistration was approved based on manufacturer,s specifications and the unit was operated as such. West Virginia Depatmellt ofEnvironmental Protection. Division ofAir Qualtry G35-C 25 of38 Natural Gas Compressorand/or DehydrationFacility 7.2. Monitoring Requirements 7.2.I. To demonstrate compliance with the pilot flans requirements ofsections 7.1.2.2 and 7.I.2.3 of this generalpendt, the presence ofa pilotflans shall be continuously monitored using a thermocouple or any other equivalent device to detect the presence ofa flame when emissions are vented to it. The pilot shall be equipped such that it sounds an alarm, orhitiales notfficationvia remote alarm to the nearest field office, when the pilot ligfit is ant. 7.2.2. To demonstrate compliance with the closed vent system requhements ofsection 7,1.4 ofthis general permit, the registrant shall: a. J#Jfl'cz/ reg#z'rerme7Its. Conduct an initial AVO inspection or those methods listed in section 4.1.4 ofthis general permit for defects that could resultin air emissions within thirty (30) days ofstart-up. Defects include, but are not limited to, visible cracks, holes, or gaps in piping; loose corrections; liquid leaks; or broken ormissing caps or other closure device;' i. The initial inspection shall include the bypass inapection, conducted according to paragraph (a) ofthis section. ii: In the event that a leakor defect is detected, yori instrepair the leak or defect as soon aspracticable. Grease oranother applicable substance must be appliedto . deteriorating or cracked gaskets to inprove the seal whale awaiting repair. iii. Delay ofrepairofa closed vent system for which leaks or defects have been detected is auowed ifthe repairis technicallyinfeasible without a shutdong orifysu determine that emissions resulting from inrmediate repair wouldbe greater than de fugitive emissions likely to result from delay ofxpair. you must complete repair of such equipmentbythe endofthe next shutdoun' b. Co#fz'#unj,s reglfZ+eme#ts. The registraut shall monitor and maintain quartedyrecnds for each component that ilras inspected for fugitive escape ofregulated air pollutants. Each component shall operate withno detectable endssions, as dete-ined using AVO inapectious, USEPA 40CFR60 Method21, USEPA altemative workpractice to dcteet 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 connectichs; lidrid leaks; orbroken orlriiSSing Caps Or Other CIOSue devices'. If registrantusesUSEPA Method 21, thenno detectable endssions is defmed as less than 500 ppm in accordance with Me.thod 2l. Ifregistrantuses an OGI camera, then no detectable emissions is defined as no visible leaks detected in accordance withUSEPA altemative OGI workpractices. Ifany leak is detected, the registrant shall repair the leak as soon as possible. The fret attempt at repair mustbe made within flue (5) days ofdiscovering the leak, and the final repair must be made within fifteen (l5) days ofdiscovering the leak. The registrant shall record each leak detected and the associated repair. The leak will not be consideredrepaired until the same monitoring method that detected the leak determines the leak is repaired. Tile regiStrant Shall mainta.in records Ofall quarterly.mOnitOring for fugitive escape Of regulated airpot.htants. a. j]JfJ?¢.gis Z'Jxpeed'O#. Visually inspect the bypass valve dndng the initial inspection for the presence ofthe car seal or lock_and-key I)pe configuration to verify that the valve is maintained in the nan-diverting position to ensure that the veut stream is. not divertedthrough the bypass device, Iran alternative method is used, conduct the inspection ofthe bypass as described in the operating procedures. West Virginia Deparfuneut ofEmvironmentaI Protection. Divis]'on offir Qulity G35-C 26 of38 Natural Gas Compressorand/or Dehydration Facility a. L]#srfe fo z'xpectreg#,.,-enreents. you may designate anyparts ofthe closed vent system.as unsafe to inspect ifthe requirements imparagraphs (i) and (ii) ofthis section are met. uusafe to inspect parts'are exempt from the inspection requirements ofparagraphs (a) and fry) ofthis section. i. ii. You determine that the equipment is unsafe to inspect because inspecting personnel would be exposed to an imminent orpotential danger as a consequence ofcomplying with the requirements. You have a whttenplan thatrequires inspection ofthe equipment as frequently as practicable during safe-toiiuspect times. [4SCSR§13-5.11.I 7.2.3. To demonstrate compliance with the pilot flame requirements ofsectious 7.1,2.3 of this general pe-it, the registrant shall follow (i). i, For any absence ofpilot flame, or other indication ofsmoldng or improper equipment operation, you must ensure the equipment is retumed to proper operation as soon as practicable after the event occurs. At a mihirmm, you must: (1) Checkthe airvent for obstruction. Iran ot)stnlction is observed, you must clear the obstruction a§ soon as practicable. (2) Check forliquidreaching the combustor. ii. The registrant is exempt from thepilot.flame requirements ofpermit canditinn 7.2.3.i ofthis section ifthe registrant installed an enclosed combustiondevice model that was tested under a 60.5413(a) which meets the criteria in § 60.5413(a)(1 1)- 7.3. TestingRequirements 7.3.1. To demonstrate compliance with the visible eriissious requirements.ofsection 7.1.2.2, 7.1.2.3, and 7.1.2,6 ofthis gacral permit, the registrant shall conduct visible emission deds and/or opacitymonitoring and recordkeeping for all emission sources subject to an opacity lhit_ i, The visible emission check shall dete-ine the presence or absence ofvisible emissions. The observations shall be conducted according to. section ll 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 ligfrting, windl and the. presence ofuncombined water (condensie water vapor) on the visibility ofemissions. This training may be obtained from lwhtteh materials found in the References I and 2 from40CFR Part 60, Appendix A, MetllOd 22 or from the lecture portion ofthe 4OCFR Part 60, Appenck A, Method 9 certification couse. The observation perfud shall be: a. b. a. ii. a minimin of2 hours ifdemoustrating compliause with 7.I.2.2; a mininum of l5 minutes ifdemoustrating compliance with 7.'1.2.3(rii)(a); or a rfunimum of 1 hour ifdemonstrating coinpliance with 7.1.2.3 (iii)(b) The visible emission check shall be conducted initiallywithin 18O days ofstart-up to demonstrate compliance while vapors are being sent to the condol device. ifi. Ifduring this visible emission check or at any other time visible emissions ae observed, compliance with section 7.I.2.6 ofthis general permit shall be deterndned by conducting opacity tests in accordance with Method 9 or40 CFR 60, Appendix A. 7.3,2. A flare that is designed and operated in accordance with §60.18(b) shall notrequire performance testing, unless at the request ofthe sceretary, but must conduct visible emission check. West Virginia Department ofEnvironmental Protection. Division ofAir Quality G35-C 27 of38 Natural Gas Compressor and/or DehydrationFacility 7.3.3' Ere¬Jased cormG2,SfZ'OJg det,i.cos OrJ?¢reS. At such reasonable times as the Secretary maydesignate. the operator ofany incineratorshall be required to conduct orhave conducted stack tests to determine the particulafe matter loading', byusing 40 CFRPat 60, Appendix A Method 5, and volatile organic compound loading byusing Methods 18 and 25A of40 CFRPart. 60, Appendir A Method 320 of40 CFR Part 63, Appendix A, or ASTM D 6348-03 or other equivalent U.S. EPA approved method approved by the Secretary, in exhaustgases. Suchtests shall be conducted in such manner as the Secretary may specify andbe filed on fo-s.and in a manner acceptable to the Secretary. The Secretary may, at the Secretary's option, witness or conduct such stack tests'. Should the Secretaryexercise his orher option to conduct such tests,.the operatorwql provide all the necessary sampling corrections and sampling ports to be located in such marmer 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 safetypractices. TIle Secretary mayconduct such other tests as the Secretary may deem necessary to evaluate all pollution emissions other than those noted above. [45CSR6 §§7.1 and 7.2] 7.4. RecordkeepingRequirements 7.4.1. For the purpose ofdquonstrating compliance with the design requirements in section 7.1.2.2 of this permit, the registrant shall inaintain a record ofthe flare design evaluation. The flare design evaluation shall include, netheat value calculations, exit (tip) velocity calculalous, and all supporting concentration calculations. 7.4.2. For the purpose ofdemoustrating compliance with the continuous pilot flalrie requirements in sections 7.1.2.2 and 7.I.2.3 ofthis general permit, the registrant.chall maintainrecords.ofthe times and duration ofall periods whenthepilot flame was not presentand vapors were venfed to the device. i. Ifthe registrant is demonstrating compliance fo 7.2.3 ofthis general permitwithvisual inspections, the registrant shall malhainrecords ofthe inspections. ii. Ifthe registrant is demonstrating compliance to 7.2.3 ofthis general permit withan enclosed combustion device model that was tastedunder the conditions of§ 60.5413(a)I, arecord shall bemaintained of the perfomanct testresults. 7.4.3' For thepurpose ofdemonstrating compliance with the visible erissions and opacity requirements, the registrant shall maintain records ofthe visible emission opacitytest? and checks. The registrant shall maintain records qfall monitoring datarequiredby section 7.3.I ofthis general permit documendng the date andtime ofeach visible emission check, the emissionpoint or equipinent/ source identification number, the name or means ofidentification ofthe observer, the results ofthe 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. surmy, approximately'80oF, 6-10 mphNE wind) during the visul emission check(s). 'should a visible emission observation be,required to be performed per the requirements specified inMethod 9' the data records ofeach observation shall be maintainedper the requirement.s ofMethod 9. For an emission unit otlt ofservice during the evahation, the record ofobservation may note "Out Of service" (O/S) or equivalent. 7.4.4. To demonstrate compliance with section 7.1.2.3.vi ofthis general permit, the registraut shall maintain records ofthe manufacturer's specifications for operating and maintenance requirements to maintain the control efflcieney.. 7.4.5. To demonstrate compliance with the closed veut monitoring requirements in section 7.2.2 ofthis general permit, records shall be maintained o£ i. The initial compliance requirements; West Virginia Departlnent ofEnvironlnental Protection. Division ofAir Quality \ G35-C 28 of38 Natural Ga; Compessorand/orDehydration Facility ii. Each AVO inspection, Method 21, infraredcamera or some combination thereof conducted to demonstrate continuous compliance, including records ofanyrepairs that were made as a result ofthe inspection; iii. Ifyou are subject to the bypass requirements, the following records shall also be maintained: (a) Each inspectionor each time the key is checked out or a record ofeach time the alafln is sounded; (b) Each occurrence that the control device was b)pa.ssed. Ifthe device was bypassed, the records shall include the date, time, and duration ofthe event and shall provide the reason that the event occurred. The record shall also include the estinate ofemissions that were rel:aged to the environment as a result ofthe bypass. iv. Any part ofthe system that has been designat.ed as i.unsafe to inspect" in accordance with 7.2.2(d). [45CSR§13-5.ll.I 7-4.6. To demonstrate compliance with section 7.1.5 ofthis general permit, records Sllall bekept on each carbon canister to indicate the date when the activated carbon was replaced and the date ofall indicator checks. 7.4.7. The registrant shall maintain records ofanytesting that is conducted according to section 7.3 of this general pemrit. 7.4.8, a All records requiredunder Section 7.4 shall be maintained on site orin a readfly accessible off-site locationmaintainedby the registraut for a period offive (5) years. Said records shall be readily available to the Director ofthe DAQ or his/'her duly authorized representative forexpeditious inspection and rewhw. Any records submitted to the agencypursuant to a requfroment ofthis permit or uponrequestby the Director shall be certified by a responsible official. 7.4.9. 7.5. To demonstrate compliance with section 7,1.2.5 ofthis generalpermit, theregistrant shall record " the volume ofgas flared on a monthlybasis. Reporting Requirements 7.5.1. Any deviation ofthe allowable visible emissionrequirement for any emission source discovered during observation using 40CFRPart 60, Appendix A, Mefrod 9 per section 7.3.1(iii) ofthis general pe-it must be reported in lndting to the Director ofthe I)AQ as soon as practicable, but within ten (10) calendar days, ofthe occurrence and shall include, af a minimum, the following info-ation: the results ofthe visible determination ofdyacity ofemissionsi, the cause or suspected cause ofthe violation(s), and anycorrective measues taken or plarmed. 7.5.2. Any bypass event ofthe registered control device mustbe reported in writing to the I)irector ofthe I DAQ as sclon as practicable, but within ten (lO) calendar days, ofthe ocourence and shall include, at a ndl]imum' the following infomation: the date ofthe bypass, the estimate ofvoc endssioris released to the atmosphere as a result ofthe bypass' the cause or suspected cause ofthe bypass. and any corrective measures taken orplarmed. 7.5.3. Any tinle the air POllutiOn COntrOl device iS mat OPerating When emissions are Vented to it, Shall be reported in whting to the Director ofthe DAQ as soon as practicable, but wirfun ten (10) calendar days ofthe discovery_ West Virginia Department ofEnviromnental Protection. Division ofAIr Quality G35{ Natlml Gas Compressor and/or DehydrationFacility 29 of38 8.0. Source-SI]ectfIC Requirements [SmalI Heaters and Reboilers not subject to 40CFR60 Subpart Dc] 8.1. , Limitations and Standards 8.1.1. 8.1.2. 8.2. Arfuxz'J#arne Deft,gr ffe¢!rxp#r. The maximum designheat input for any small hater and/or reboiler shall be less than 10 MMBTUthr. No person shall cause, suffer, allow or permit emission ofsmoke and/orparticulale matter into the open air from any fuel buming unit which is greater than ten (10) percent opaoftybased on a six - minute block average. [45CSR§Z-3.1.I . Monitoring Requirements 8.2.1. 8.3 At such reasonable times as' the secretarymay designate, the regiStrant shall conduct Method 9 endssion observations forthe burpose ofdemonstrating compliance with section 8.I.2 ofthis general pendL Method 9 shall be conducted in accordance with 40 CFR 60 Appendix A. TestingRequirements 8.3.1. Uponrequest by the Secretary, compliance with the visible emissionrequirements ofsection 8.I.2 ofthis general permit shall be dote-ineq in accordance with 40 CFR Part 60, Appendix A, Method 9 orbyusing measurements from continuous opacity monitgivg systems approved bythe Secretary. The Secretary may require the installation. calihation, rmiutenance and operation of continuous opacitymonitoring systems and may establishpoliofes for the evaluation ofcontinuous opacity monitoring results and the determination ofcompuance with the visible emission requirements ofsection 8.1,2 ofthis general permit. continuous opacity mchtors shall not be required on fuel buming units.which employ wet sombbing systems for endssion control. [45CSR§2-3.2.I 8.4. I RecordkedyingRequirements 8.4.I. The registrant shall maintain records ofau monitoring data required bysection 8.2.1 ofthis general permit docunenting the date and time ofeach visible eulssich check, the emissionpoint orequipmentrsource idendfication number, the name or means ofidentification ofthe chserver, the results ofthe check(s), whetherthe visible emissions are normal for theprocess, and, if applicable, all corrective measures taken orplarmed. The registlap shall also record the general . wegth.er conditions (i.e. surmy, approximately 80oF, 6 - 10 mphNE wind) during the visual ems.slOn check(s). Should a visible emission observation be required to beperfe-ed per the requreapents specified in Method 9, the data records ofeach observation shall be maintained per the requirements ofM.ethod 9. West Virginia Department ofEnvironmental Protection. Division ofAir Quality G35-a Natural Gas Compressor and/or Dekydration Facility 9'0.. 30 of38 Source-SpecifTIC Requirements [Pneumatic Controllers Affected Falcility quSPS, Subpart0000)I 9.1. Limitations and Standards 9.1.I. 10.0. The registrant ofeach pneumatic controller affected facility shall comply with the applic;b]e requirements specified in40 CFR Pat 60, Subpart OOOO` Source-Specific Requirements [Centrifugal Compressor Affected Facility (NSPS, SubpaI't 0000)I 10.1. Limitations and Standards 10.I.1. ll.0. Theregistrant ofeach centrifugal compressor affected faoilfty shall comply with the applieable. requirements specified in40 CFRPart 60, Subpart OOOO. Source-Specifif Requirements [Reciprocating CompressorAffected Facility quSPS, Subpart0000)I 11'1' Limitations and Standards 11.1.1. The-registrant ofeach reciprocating comp'ressor affected facility shall comply with the appncable requirements specified in40 CFRPart 60, Subpart OOOO. West Virginia Department ofEnvironmental Protection. Division ofAir Quality G35-C 31 of38 Natural Gas Compressorand/or Dehydration Facility 12.0. Source+Specific Requirements [ReciprocatiIlg Internal Combustion Engine(s) qlICE), Generators, ndicroturbine Generators] 12.1. u Limitations and Standards I2.1.1. jZeg#/fzfetJPo//atczJ!ZZ!.rmz'fclfZ'Oj!. The registrant shall not cause, surfer-, auow or permit emissions ofofany regulated pollutant listed in the General Permit Registration to exceed the emission limit (pounds perhour and tons peryear) recorded with the.registrant's General Permit Registration without affecting a modification or administrative update. 12.1.2. The applicable RICE(a) and/or generator(s) shall be operated and maintained as follows.. a. b. 12.1.3. ha accordance with the manufacturerls recommendations and specifications or in accordance with a site specific'maintenance plan; and, In a manner consistent with good operating practices, Reduirements for Use ofCatalytie Reduction Devices a. RIch-bumnatural gas-fred compressor engine(s) equippedwithnan-selectie catalytic reduction (NSCR) air polrfuon control devices shall be fitted with a closed-1oop9 automatic all/fuel ratio controller to ensue emissions ofregulatedpollutants do not exceed fro emissionhimitlisted in the General Pe-it Registration for any engineINSCR combination undervarving load. The closed-loop, automatic airrfuel ratio controller shall control a fuel metering valve fo ensure a fuel-rich mirtyre and aresultant ed]inst oxygen content ofless than or equal to 2%. b. IJean-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 c)iregulated pollutants do not exceed the emission limitlisted in the General PermitRegistrationfor any engine/SCR combina.tion under.varying load. The closed-loop automatic feedback controllershall provide properand efficient operati.on ofthe engine, ammonia irijection and SCR device, monitoremission.levels do-trean ofthe catalyst elenein and limit ammonia slip to less than 10 ppmv. a. Lean-bum natural gas compressor engine(s) equipped with oxid'ation catalyst air pollution control devices shall be fitted with a closed-loop automatic air/fuel ratio feedback a.ontrouer to ensure emissions ofregulated pollutants do not exceed the emissich lindt listed in tile General Pendt Registration for anyengine/oxidation catalyst combinatiori 1]nderVarying load. The closed-loop, automatic air/fuel ratio controller.shall control a fuel metering valve to ensure a lean-richmixture. a. For natural gas compressorengife(s), the registrant shall monitor the temperature to the inlet ofthe catalyst and in accordance with m'anufacturer,s specifications; a high temperature alarm shall shut offthe engine before thermal deactivation ofthe catalyst occur. Ifthe engine shuts offdue to high terierature, the registrant shall also cheek for thermal deactivation ofthe catalyst before normal operations are resumede. The registrant shall follow a written operation and maintenanceplan that provides the periodic and annual maintenance requirements. 12,I.4. The registrant shall comply with all applicable NSPS for Stationary Compression Ignition Intemal Combustion Engines specified in4O CFR Part 60, Subpart IIII, Stationary SparkIgnition Intemal Combustion Engines speeifled in40 CFR Pan 60, SubpartJJJJ, and/or theNational Emission Standards for Hazardous AirPollutants orESHAP) for Stationary Spark Ignition hitemal Combustion Engines specified in 40 CFR Paul 63, SubpartZZZZ West Virginia Depatnent ofEnvironmental Protection. Division of'Air Quality G35-a Natural Gas Compressor and/or Dehydration Facility 12.I.5. 32 of38 The emission limitations specifled in section 12.I.1 shall apply at all times except drringperiods ofstart-up and shut-dourprovided that the duration of.these periods does not exceed 30 minutes PerOccurrence. The registrant shall operate the engine in a ma]merccusistent with good air polhion oomtrol practices forminirfuzing emissions atall times, including periods ofstart-up and shat-dour. The emissions from start-up and shut-dovlm shall be included in the twelve (l2) month rolling total ofemissions. The registrant shall camp.ly with all applicable start-up and shut-dourrequirements in accordande with 40 CFR Part 60, Subparts IIII, JJJJ and 40 CFR Part 63, Subpart.2ZZZ' l2.1.6. Forthe puapdses ofGeneral Perfut G35-C, ermergr#cJ,gr#erflfOr means a generator whose purpose is to allow key systeus to condnue to operate without interruption during times ofutility Power OutageS. 12.2. Monitoring Requirements l2.2.1. Catal]rdc Reduction Devices a. The registrant shall regularly inspect properlymalutain and/orreplace catdytic.reduction devices and auxiliaryairpouution control devices to ensure fimctioml and effective Operation ofthe engine's physI'Cal and OPeratiOnal design. The registrmt shall ensureproperoperations maintenance andperfo-ance ofcatabrfic reduction devices and auxiliary airpollution control devices by: 12.3. 1. Maintainingproper operation ofthe automatic air/fuel rati'o controller or automatie feedback controuer. 2. Following the catalyst manrfecturer enrissions related operating and maintenance recommendations, or develop, inplement, or follow a site-speoffic marfuenanceplan. Recordkeeping Requirements l2.3.1, To demonstrate compliance withgeneralpemut section 12..1.3, the registrant shall maintain records ofthe maintenance performed on eachRICE and/orgenerator_ l2.3.2. To demonstrate compliance with general pe-it sections 12.2+ the registrant shall maintain a copy ofthe site specific maintenance planor manufacturer maintenance plan. 12.3.3. The regismnt shall comply with all applicable recordkeeping requirements underNSPS for Stationary CompressionIgnition Intemal Combustion Engines sPecried in40 CFR Part 60, Subpart IIII, Stationary Spark Ignition mternal Combustioin Engines specified in 40 CFR Part 60, Subpart JJu and/or the National Emission Standards.for Hazardous Air Pollutants quESHAP) for Stationary Spark Ignition Intemal Combustion Engines specified in 40 CFR Part 63, Subpart 7K1. l2.3.4. All records required by this section sfrall be maintained in accordance with section 3.5.1 ofthis general perndt. 12.4. Testing Requirements 12.4.1\ r The registrant shall comply with all applicable testing requirements underNSPS for Stationary Compl.ession Ignition Intemal Combustion Engines specified in40 CFRPart 60, Subpart HII, Stationary Spark Ignition.Intemal Combustion Engines specified in 40 CFR Part 60, Subpart JJJJ, and/or theNatiorml Endssion Standards forHazardous AIrPollutants quESIIAP) for Stationay Spark Ignition Intemal Combustion Engines specifled in40 CFRPart 63, Subpat ZZZZ. West Virginia Deparment ofEnvironmental Protection. Division ofAir Quality "33 of38 G35_a Natufal Gas Compressorand/or Dehydration Facility 12.4.2. To demonstrate Compliance- with general permit section 12,1.3(a), the registrant shall \chfy that the closed-loop9 automatic air/fuel ratio controller shall control a frol metering valve to ensure a fuel-rich mirtue and aresultant exhaust oxygen content ofless than or equal to 2% during any ` 2.5. performance testing. Reporting Requirements 12.5.1, The registrant shall comply with all applicable notification requirements underNSPS for Stafronary Compression Ignition intemal Combustion Engines specified in 40 CFR Part 60, Subpart IIII, Stationary SparkIgnition Intemal Combustion Engines specified in 40 CFRPart 60, Subpart JJJJ, and/or the Natiomal Emission Standards forHazardous AirPollutants OJESIIAP) for Stationary.Spark Ignition Intemal Combustion Engines specified in 40 CFR Part 63, Subpart rZ:HZ. West Virginia Department ofEnvironmental Protection. Division ofAjr Quality G35-a Natural Gas Compressor and/orDehydrationFacility 13.0. 34 of38 SouI'Ce-SpeciflC Require'ments [Tanker Truck Loading] 13.1. Limitations and Standards 13-1,1, Jtegiv¢fedPo//wfcz»!Iz,mz,£zzfro#. The registrant shall not cause, suffer, allow or penmit emissions from any registered TankerTruck Loading Facility ofany regulated pollutant listed in the General Pe-it Registration to exceed the emission limit (pounds perhour and tons peryear) recordedwith the registrant's General Permit Registration without effecting a. modification or administrative update. 13.:,1.2. A4arz`ffl4;,7Z r"ch.Le¢cJzng Z7iro¢!g#p#f£!'m!.ftzffo#. To demonstrate compliance with the tanker truck loading emissions in section l3,I.1, the registrant shall not exceed the maximum thoughput limit that VIS recorded With regiStranfS Gerleral Permit Registration without obtaining a modiflCatiOmor administrative update. Coinplianee with the Maximum Annual Throurfuut Limitation shall be determined using a twelve (12) month rolling total. A'tvlrelve (12) month rolling total shall mean the sum ofthetanker truck product throughput at anygiven time during the previous twelve (l2) consecutive calendarmonths. 13.1,3. Co#fro/De+,z'ces cz#d PRC/s. The registrant shall install, operate, and maintain all control devices and/or VRU(s) in accordance with the applicable require-ments ofsection 7.'O ofthis general permit. 13.1,4. The following applicable captur'e efficiencies are required: a. Fortanker trucks and/orrail cars notpassing one ofthe apnunl leak tests in 13.1.4co) or (a) and has vaporretum- 70% b. a. For tanker tnICkS and/Orrail Cars Passing theNSPS level annual leaktest- 98'7%. For tanker tnlcks and/orrail carspassing the MACT level annual leak test-99.2%. Compliance with this requirement shall be demonstratedby keeping records ofthe appncable MACT orNSPS A-uar LeakTestcertifroation foreverytnlck and railcar loaded/unloaded. This requirement can be satisfied ifthe tructdng/fail car codyanyprovided certiflCatiOn that all tinker trucks/rail cars servicing the location are compliant. 13.2. Rctordkeeping Requirements l3.2.I. To demonstrate compliance with the emission li'mitations in seetion'13.1.1 and with the throughput limitation in sedtion 13.1.2, the registrant shall maintain monthly and amual records that include the total quantity ofmaterial loaded into tanker tmcks. The armual records shall be calculated on a twelve (12) month rolling total. I3.2.2. For tlle purpose ofdemonstrating compliance with section 13.I.2, the registrant shall maintain records ofthe MACT and/oiNSPS Annual Leak Tests ofall tanker tmcks/rail cars loaded at the facility. This requirement can be satisfied ifthe trucking/rail car conpany provided certifroation that all tanker trucks/rail cars servicing the location are compliant. This certifroation must be submitted in `whting to the Director ofthe DAQ. West Virginia Department ofEnvironmental Protection. Division ofAir Quality G35-C 35 of38 Natural Gas Compressor and/orDehydration Facility 14.0 Source-Specific Requirements [GIycol Dehydration Uhits] 14.1. Limitations and Standards 14.1.1. The registraut ofeach glycol dedydration unitsubject to 40 CFR Part 63, Subpart RII Shall comply with the applicable requirements specified in40 CFR Part 63, Subpart HH. 14.1,2- A4lcz}.z'J#lfrm 7Hro4!gky#fZz'ur!.r#ffo#. The maximum dry natlrd gas ftyroughput to the glycol dehydration units/ still columns shall not.exceed the tllroughPut limit listed in the registrant.s G35_ a General Pe-it Registration. Compliance with the'Maxinun Throughput Limitatich shall be determined using a twelve (l2) month rolling total. A twelve (12) month rolling total Shall mean the sum ofthe quarterlythroughput at any given time during the previous twelve (12) consecutive calendarmonths. l4.1.3. ErmisJfo# Zz'neJfs. The registrant shall not cause, suffer, allow or permit emissions of HAPs and vacs to exceed the emission linits listed in the registramt's G35-a General PermitRegistration. L411.4. Emission Calculations. a. Forpxposes ofdeteminingpotential IIAI) emissions, the methods specified in40 CFR 63, b. Any source that has actual emissions of5 tons per'year or more ofa single IIAP, or 12.5 tors per year ormore ofa combination ofHAP (i.e_, 5O percent ofthe major source thesholds), shall update its major source detendnation witlrin 1 year oftheprior determination or October 15, 2012, whicheveris later, and quch year thereafer, using gas composition data measured during the prec6ding 12 months. [40CFR§63.760(a)I a. For the purposes ofdetermining actual annual average natural gas thonggivput or acfro[ average benzene emissions, the methods specified in § 63.772(b) of 40 CFR 63, SubpartIIII. shall be used ifthe registrapt is exempt from § 63_764(a). + 14.I.5. Subpart HH shall be.used. Co#fro/Devz.ces ¢#djJmz.ssz.o# jZedrctz.o# I)evz.ces. The registrant shall comply with all applicable control device and emission reduction device requirements provided in section 7.0 ofthis general permit for any control device and emission reduction device used to control emissions from the dehydration unit and that is listed in the G35-a GeneralPe-it Registration. Compliance will be demonstrated according to the requirements listed in section 7.0 ofthis generd perfut. 14.1.6. n4flerj'rm"ne Gfyco/jiec!'rcwh#o# Rftte. The maximum glycol recirculation rate chall not exceed the gallons per minute limit listed in the registrant's G35-a general`.permit application. Compliance with the Maximum Glycol Recfroulation Limitation shall be determined using an average ofa mihimun ofquarterlyreadings ofthe actual glycol pump(s) rate. Ifmore than one pump is operating sinultaneously then the rate ofeach operating pump shall 6e recorded and totaled for compliancepurposes. 14.2. Monitoring Requirements 14,2.1. To demonstrate compliance with section 14.I.2 ofthis general perrit, the registrant shall monitor the throughput ofdry natural gas from the dekydration system on a qu]arterlybasis for each glycol dehydration unit listed in the G35-a General Pe-it Registration. . 14.2.2. Representative gas sample collection and analysis frequencyfor dekydration units shall be determined as set forth in the schedule provided in Table 14.2.2 ofthis section. West Virginia Department ofEnvironmental ProtectI'On. Division ofAir Quality G35-C 36 of38 Natural Gas Compressor and/or Dedydration Facility Table 14.2.2 Wet Gas Sampling and AnalysisFrequency for Dchydl.ation Units Based on Potential HAP Emission Rates Each dekydrationunit exempt from§63.764(d)requir.emeutsandwithfederallyenforc6ablecontrols Upon requestby the Secretary. Each dehydration unit exempt from § 63.764(d) requirements and without federally enforceable controls 14.2.3. An initial compliance evaluation within 180 days ofregistration issuance or within 180 days of start-up ofthe dekydration unit, whichever is later. To demonstrate compliance with area source status and the b.enzene exemption in 14.1.4.a, the following parameters shall be measured at a ndnimum frequency ofonce per quarter, with the. exception ofnatural gas flowate annual dally average, natural gas flowrate maximum design capachy and vet gas composition, in order to define annual average values or, ifmchtoririg is notpractical, scme parameters maybe assigned default values as listed below. a, Natural Gas Flo RTate i. Operating hours per quarter. ii. Quarterlythroughput QTh4scflqualter) iii. Armunl daily average Oth4scffday), and b. iv. Marinm designcapacity Orfu4scffday) Absorber temperature and pressure a. IJean glyCOl oiroulationrate d. Glysolpump type and maxirm-design capacity (gpm) e. Flash tank temperature andpressure, ifappficable f. Stripping Gas flow rate, ifapplicable g. Wet gas composition (upstream ofthe absorber- dedydration column) sampled in. accordance with GPA method 2I66 and analyzed consistent with GPA extended method 2286 as well as the procedures presented inthe GRI-GLYCalc" Technical Reference UserManual and HandbookV4 h. Wet gas water contemt (lbs HiO/MMscD i. Dry gas water content (lbs H2on¢Mscf) at a point directlyafter exiling the dehydration column andbefore anyadditional separation points The following operating parameter(a) may be assigned default values when using GRI-GLYCalc: a.. Drygas water content can be assumed to be equivalent to pipeline qualityat 7 1b H2O / "scf b. wet £as veter content can be assumed to be satlmted a. I Lean glycol water content ifnot directlymeasured may use the default value of 1.5 % water as established by-GRI d. IJean glyCOI Circulationrate maybe eStinated using the TEG recirculation ratio of3 gal TEG / lb H2O removed. Note: Ifyou are measuring andusing actual wet or dryI?c,as water content, then you should also measure the glycol circulation rate rather thanusing the default TEG reciroulation ratioI L [4SCSR§13-S.ll,?63.772(b)(2)(i)I West Virginia Department ofErlvironmental Protection. Division ofAjr Quality G35-a Natural Gas Compressor and/orDedydration Facility 14J. 37 of38 Testing Requirements 14.3.I. The registrant shall sample wetnatural gas in accordance with the Gas ProcessorAssociation (GPA) Method 2166 and analyze the samples in accordance with GPA Method 2286. The registrantmayutilize other equivalent methods provided they are approved in advance byDAQ as part ofa testing protoc'ol. Ifaltemative methods are proposed, a test protocol shall be submitted for approval no later than 60 days before the'scheduled test date. jVofe.. The DAQ defines a representative wet gas sample to be one thatis characteristic ofthe average gas composition dehydrated throughout a calendaryear. Ifan isolated sample is not indicative ofthe,annual average composition, then a company may ddt to produce a weighted average based on throughputbetweenmultiple sampling events', which canbe used to. defme a more representative average amual gas composition profile. 14.4. RecordkcepingRequirements 14.4.1. The registrant shall maintain records ofthe quarterly drynatural gas throughput riough the glycol dekydration.unit(s), all monitoring.data, wet gas sampling> and GRI_GLYCalcTM endssion estimates. Said records shall be malntalned in accordance with section 3.5.1 ofthis general permit' 14.5. Reporting Requirements 14.5.1. Th.eregistrant shall submit the wet gas analysis xportrequiredbysection 14.2 ofthis general pe-it within 60 days ofconduoting the sampHrig ofthe wet gas stream as reqll]ired. This report shall include a pots.ntial to emit PIE) estinate using GRI-GkyCalc Version3.0 orhigher. incorporating the speoffic parameters measuredJ as Well aS a COPY Ofthe laboratory analysis. 14.5.2, Ifthe results ofthe compliance determination conducted as required in section 14.2 ofthis general perhitpredict the emissions to be at orabove 95% ofHAPs majorsource levels or 0.95 tors per year 6fbenzene, the registrant shall submit such determination and all supporting documentation to the Secretary within 15 days after making such detemlination' West Virginia Department ofEnvironmental Protection. Division ofAir Quality G35-C 38 of38 Natural Gas Compressor and/or Dehydration Facility CERTIFICATION OF DATAACCURACY I, the undersigned, hereby certify that, based on information and belief formed after reasonable inquiry, all info-ation contained in the attached 9 representing the period beginning I and any supporting documents appended hereto, is froe, accurate, and complete_ signature1 (please usj blue ink) Rcspousible Offlciol or Authorized Represe"ti\,a Name a Title (pleaseplint ortype) Telephone No. I Name Title FaxNo. "s form shall be signed by a ¬cResponsible Official." ¬cResponsible Officiar means one ofthe following: a. For a corporation: The presidents Secretary, treasurer,'Or vice-President of the corporation in charge of a principal business faction, or any other person who perfoms similar policy or decision-making fimctions for the corporation, or a duly authorized xpresentative ofsuch person if the representative is responsible for the overall operation ofone or more manufactl]ring, produetion, or operating facilities applying for or sutjectto apermit and either: (i) the facilities employ more than 250.persons orhave a gross annual sales or expenditures exceeding $25 minion (in second quarter l980 dollars), or (ii). the delegation.ofarithorityto such representative is approved in advance by the Director; b. For a parmership or sole proprietorship: a general pamler Or the PrOPrietap respectively; a, For a municipality, State, Federal, or other public entity: either a principal executive officer or ranking elected offlcia!. For the purposes ofthis part, a principal executive officer ofa Federal agency includes the chiefexecutive officer having responsibility for the overall operations ofa principal geographic unit ofthe agency (e.g., a Regional Administrator ofU.S. EPA); or d. The designated representative delegated with such authority and approved in advance bythe Director. West Virginia Department ofEnvironmental Protection. Division ofAir Quality