deq requests comments on northwest pipeline, …...reciprocating compressor with associated rod...

Eastern Region 475 NE Bellevue Dr., #110 Bend, OR 97701 Phone: 541-388-6146 866-863-6668 Fax: 541-388-8283 Contact: Permit Writer, Paul DeVito www.oregon.gov/DEQ DEQ is a leader in restoring, maintaining and enhancing the quality of Oregon’s air, land and water. Notice Issued: 7/2/2020 By: Nancy Swofford Permit number: 30-0076

Public Notice

DEQ Requests Comments on Northwest Pipeline, Walla Walla Compressor Station’s Proposed Air Quality Permit The Oregon Department of Environmental Quality invites the public to submit written comments on the conditions of the Northwest Pipeline, Walla Walla Compressor Station’s proposed air quality permit, known officially as a Simple Air Contaminant Discharge Permit. Summary The proposed permit is a new air permit for Northwest Pipeline LLC. The permittee proposes to construct and operate the Walla Walla Compressor Station near the existing Milton-Freewater Meter Station on the Walla Walla natural gas lateral, approximately milepost 22.5. How do I participate? To submit your comments for the public record, send them by mail, fax or email: Nancy Swofford, Air Quality Permit Coordinator 475 NE Bellevue Dr., Suite 110 Bend, OR 97701 Fax: 541-388-8283 Email: [email protected] Written comments are due by 5 p.m. Monday, Aug. 3, 2020 About the facility This new permit is for the Walla Walla Compressor Station located at 0.7 miles on Milton Cemetery Road near Milton-Freewater, Oregon. The station will consist of an electrically driven reciprocating compressor with associated rod packing leaks and blowdown emissions, a 500-gallon waste oil storage tank and process piping component fugitive emissions. What air pollutants would the permit regulate? This permit regulates emissions of the pollutants listed in the table at the end of this document. How does DEQ determine permit requirements? DEQ evaluates types and amounts of pollutants and the facility’s location, and determines permit requirements according to state and federal regulations.

How does DEQ monitor compliance with the permit requirements? This permit would require the facility to monitor pollutants using federally approved monitoring practices and standards. Formulas to calculate emissions are contained in the permit. The permittee is required to calculate facility-wide emissions and submit an emissions report to DEQ semi-annually. DEQ will conduct onsite inspections to ensure compliance with emission limitations. What happens after the public comment period ends? DEQ will consider and provide responses to all comments received at the close of the comment period. DEQ will hold a public hearing if requested by 10 or more individuals or one person representing a group of 10 or more individuals. DEQ may modify provisions in the proposed permit, but the permit writers can only modify conditions of the permit in accordance with the rules and statutes under the authority of DEQ. Participation in the rulemaking or the legislative process is the only way to change the rules or statutes. Ultimately, if a facility meets all legal requirements, DEQ will issue the facility’s air quality permit. Where can I get more information? Find out more and view the draft documents online at DEQ’s “Public Notices” page or contact Nancy Swofford, Air Permit Coordinator: Phone: 541-633-2021 or 866-863-6668 Fax: 541-388-8283 Email: [email protected] View the draft permit and related documents in person at the Milton-Freewater Public Library at 8 SW 8th Ave., or at the DEQ office in Pendleton. For a review appointment, call Bobbi DeMauro at 541-278-4614. Alternative Formats DEQ can provide documents in an alternate format or in a language other than English upon request. Call DEQ at 800-452-4011 or email [email protected].

http://www.oregon.gov/DEQ

mailto:[email protected]

http://www.oregon.gov/deq/Get-Involved/Pages/Public-Notices.aspx



Emissions Limits Criteria Pollutants: Table 1 below presents maximum allowable emissions of criteria pollutants for the facility. The current emission limit reflects maximum emissions the facility can emit under the existing permit. The proposed emission limit reflects maximum emissions the facility would be able to emit under the proposed permit. Typically, a facility’s actual emissions are less than maximum limits established in a permit; however, actual emissions can increase up to the permitted limit. Table 1

Criteria Pollutant Proposed Limit1 (tons/yr) Particulate matter N/A

Small particulate matter N/A Fine particulate matter N/A

Nitrogen oxides N/A Sulfur dioxide N/A

Carbon monoxide N/A Volatile organic compounds N/A

Greenhouse Gas N/A 1This permit contains no plant Site Emission Limits since potential-to-emit emissions of all criteria pollutants are less than de minimis levels of one ton per year of criteria pollutants and less than the de minimis level of 2760 tons per year of GHG. This is in accordance with OAR 340-222-0020(3)(a). For more information about criteria pollutants, go to EPA’s: Criteria Air Pollutants page. Hazardous Air Pollutants: The Walla Walla Compressor Station does not have the potential to be a major source of hazardous air pollutants. EPA has determined that these types of businesses do not warrant such regulation. The estimated total hazardous air pollutants emissions are less than 0.01 tons per year and 0.005 tons per year of n-Hexane. Table 2

Hazardous Air Pollutants Potential Emissions (tons/yr) n-Hexane 0.005 All other HAPs 0.0024 Total HAPs Less Than 0.01

For more information about hazardous air pollutants, go to: Health Effects Notebook for Hazardous Air Pollutants

http://www.epa.gov/criteria-air-pollutants

https://www.epa.gov/haps/health-effects-notebook-hazardous-air-pollutants

Draft Permit Number: 30-0076-SI-01 06/29/2020 Expiration Date: <5 Years from Date of Issuance>

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OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

SIMPLE AIR CONTAMINANT DISCHARGE PERMIT Eastern Region

475 NE Bellevue Drive, Suite 110 Bend, OR 97701

This permit is being issued in accordance with the provisions of ORS 468A.040 and based on the land use compatibility findings included in the permit record.

ISSUED TO: Northwest Pipeline LLC 295 Chipeta Way Salt Lake City, UT 84108

INFORMATION RELIED UPON: Application No.: 31947 Date Received: 2/5/2020

PLANT SITE LOCATION: Walla Walla Compressor Station 0.7 miles east on Milton Cemetery Road Milton-Freewater, OR 97862

LAND USE COMPATIBILITY FINDING: Approving Authority: Umatilla County Approval Date: 3/31/2020

ISSUED BY THE DEPARTMENT OF ENVIRONMENTAL QUALITY _________________________________________________ _______________________ Mark W. Bailey, Eastern Region Air Quality Manager Dated

Source(s) Permitted to Discharge Air Contaminants (OAR 340-216-8010):

Table 1 Code Source Description SIC/NAICS Part B, #88 Natural Gas Transmission 4922/486210


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TABLE OF CONTENTS 1.0 DEVICE, PROCESS AND POLLUTION CONTROL DEVICE (PCD)

IDENTIFICATION..............................................................................................................3

2.0 GENERAL EMISSION STANDARDS AND LIMITS ......................................................3

3.0 NSPS SUBPART OOOOa PERFORMANCE AND EMISSION STANDARDS .............4

4.0 OPERATION AND MAINTENANCE REQUIREMENTS .............................................12

5.0 PLANT SITE EMISSION LIMITS ...................................................................................12

6.0 COMPLIANCE DEMONSTRATION ..............................................................................13

7.0 SOURCE TESTING ..........................................................................................................13

8.0 RECORDKEEPING REQUIREMENTS ..........................................................................13

9.0 REPORTING REQUIREMENTS .....................................................................................14

10.0 ADMINISTRATIVE REQUIREMENTS .........................................................................16

11.0 DEQ CONTACTS / ADDRESSES ...................................................................................17

12.0 GENERAL CONDITIONS AND DISCLAIMERS ..........................................................18

13.0 ABBREVIATIONS, ACRONYMS AND DEFINITIONS ...............................................20


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1.0 DEVICE, PROCESS AND POLLUTION CONTROL DEVICE (PCD) IDENTIFICATION

The devices, processes, and pollution control devices regulated by this permit are the following:

Devices and Processes Description

Device ID

Pollution Control Description

Pollution Control ID

Blowdowns – Reciprocating Compressor and Emergency Shutdowns

BD None NA

Fugitive Emissions - Process Piping Components

FUG-Piping

Leak Detection and Repair program LDAR

Fugitive Emissions – Reciprocating Compressor Rod Packing

FUG-CRP None NA

Fugitive Emissions – Waste Oil Tank

FUG-Tank None NA

2.0 GENERAL EMISSION STANDARDS AND LIMITS 2.1. Visible Emissions Visible emissions from any air contaminant source must not equal or exceed 20% opacity for any six-minute block average using EPA Method 9. [OAR 340-208-0110(4)] 2.2. Fugitive Dust Emissions

a. The permittee must take reasonable precautions to prevent fugitive dust emissions from leaving the property of a source. Reasonable precautions include, but are not limited to: [OAR 340-208-0210] i. Using, where possible, water or chemicals for control of dust in the demolition of

existing buildings or structures, construction operations, the grading of roads or the clearing of land;

ii. Applying water or other suitable chemicals on unpaved roads, materials stockpiles and other surfaces which can create airborne dusts;

iii. Enclosing (full or partial) materials stockpiles in cases where application of water or other suitable chemicals are not sufficient to prevent particulate matter, including dust, from becoming airborne; and,

iv. Developing a DEQ approved fugitive dust emission control plan upon request by DEQ if the above precautions are not adequate and implementing the plan whenever fugitive dust emissions leave the property for more than 18 seconds in a six-minute period.


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b. In no case may fugitive dust emissions leave the property of a source for a period or periods totaling more than 18 seconds in a six-minute period. Fugitive emissions must be measured by EPA Method 22 with the minimum observation time of six minutes.

2.3. Particulate Matter Emissions Particulate matter emissions from any device or process (other than fugitive emissions sources, fuel burning equipment, refuse burning equipment, or solid fuel burning devices certified under OAR 340-262-0500) that is installed, constructed or modified after April 16, 2015 must not exceed 0.10 grains per dry standard cubic foot. [OAR 340-226-0210(2)(c)] 2.4. Particulate Matter Fallout The permittee must not cause or permit the deposition of any particulate matter larger than 250 microns in size at sufficient duration or quantity, as to create an observable deposition upon the real property of another person. [OAR 340-208-0450] 2.5. Nuisance and Odors The permittee must not cause or allow air contaminants from any source to cause a nuisance. Nuisance conditions will be verified by DEQ personnel. [OAR 340-208-0300] The permittee must maintain a log of each nuisance complaint received by the permittee. A plant representative must immediately investigate the condition following the receipt of the nuisance complaint and provide a response to the complainant within 24 hours, if possible. 3.0 NSPS SUBPART OOOOa PERFORMANCE AND EMISSION

STANDARDS 3.1. The compressor station is subject to the requirements of 40 CFR Part 60, Subpart

OOOOa, “Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015.” Subpart OOOOa affected facilities include the reciprocating compressor and the natural gas fugitive emission components. The following conditions include Subpart OOOOa requirements for operating and maintenance, monitoring, recordkeeping and reporting.

3.2. The permittee must be in compliance with the standards of NSPS Subpart OOOOa upon

startup. [§60.5370a(a)] 3.3. The initial compliance period begins upon initial startup, and ends no later than 1 year

after the initial startup date of an affected facility. The initial compliance period may be less than one full year.

3.4. At all times, including periods of startup, shutdown and malfunction, the permittee must

maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures


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are being used will be based on information available to DEQ which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. The provisions for exemption from compliance during periods of startup, shutdown and malfunctions provided for in 40 CFR 60.8(c) do not apply to Subpart OOOOa. [§60.5370a(b)]

3.5. Reciprocating Compressor Rod Packing Replacement The permittee must replace the reciprocating compressor rod packing according to either of the following: [§60.5385a]

a. On or before the compressor has operated for 26,000 hours. The number of hours of operation must be continuously monitored beginning upon initial startup of the reciprocating compressor affected facility, or the date of the most recent reciprocating compressor rod packing replacement, whichever is later.

b. Prior to 36 months from the date of the most recent rod packing replacement, or 36 months from the date of startup for a new reciprocating compressor for which the rod packing has not yet been replaced.

3.6. Reciprocating Compressor Initial Compliance To achieve initial compliance with the standards for each reciprocating compressor affected facility, the permittee must: [§60.5410a(c)]

a. Continuously monitor the number of hours of operation or track the number of months since the last rod packing replacement to comply with Condition 3.5.

b. Maintain the records for the reciprocating compressor as specified in Condition 3.8. c. Submit the initial annual report for the reciprocating compressor as required in Condition

3.14. 3.7. Reciprocating Compressor Continuous Compliance To achieve continuous compliance with Condition 3.5 for each reciprocating compressor affected facility, the permittee must: [§60.5415a(c)]

a. Continuously monitor the number of hours of operation for each reciprocating compressor affected facility or track the number of months since initial startup or the date of the most recent reciprocating compressor rod packing replacement, whichever is later.

b. Replace the reciprocating compressor rod packing on or before the total number of hours of operation reaches 26,000 hours or the number of months since the most recent rod packing replacement reaches 36 months.

c. Perform the recordkeeping as required by Condition 3.8. d. Submit annual reports as required in Condition 3.14.


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3.8. Reciprocating Compressor Recordkeeping The permittee must maintain the following records for the reciprocating compressor. These records must be maintained either onsite or at the nearest local field office for at least 5 years. [§60.7(f)(b) and §60.5420a(c)(3)]

a. Records of the occurrence and duration of any startup, shutdown or malfunction in the operation of the reciprocating compressor.

b. Records of the cumulative number of hours of operation or number of months since initial startup, or the previous replacement of the reciprocating compressor rod packing, whichever is later.

c. Records of the date and time of each reciprocating compressor rod packing replacement. d. Records of deviations in cases where the reciprocating compressor was not operated in

compliance with the requirements specified in Condition 3.5. 3.9. Fugitive Emission Component Compliance Requirements The permittee must monitor all fugitive emission components that have the potential to emit fugitive emissions of methane or VOC at the compressor station, including, but not limited to valves, connectors, pressure relief devices, open-ended lines, flanges and covers. Monitoring must be conducted in accordance with Conditions 3.10 and 3.11. The permittee must repair all sources of fugitive emissions in accordance with Condition 3.12. The permittee must keep records in accordance with Condition 3.13 and report in accordance with Condition 3.14. Fugitive emissions, relative to Subpart OOOOa permit conditions, are defined as “Any visible emission from a fugitive emissions component observed using optical gas imaging or an instrument reading of 500 ppm or greater using Method 21.” [§60.5397a(a)] 3.10. Fugitive Emission Component Monitoring Plan Elements The permittee must develop a fugitive emission component monitoring plan that includes the following elements. [§60.5397a(b)]

a. Frequency for conducting surveys. Surveys must be conducted at least as frequently as required by Conditions 3.11.b and 3.11.c.

b. Technique for determining fugitive emissions (i.e., Method 21 at 40 CFR Part 60, Appendix A-7, or optical gas imaging).

c. Manufacturer and model number of fugitive emissions detection equipment to be used. d. Procedures and timeframes for identifying and repairing fugitive emissions components

from which fugitive emissions are detected, including timeframes for fugitive emission components that are unsafe to repair. The repair schedule must meet the requirements of Condition 3.12 at a minimum.

e. Procedures and timeframes for verifying fugitive emission component repairs. f. Records that will be kept and the length of time records will be kept. g. If using optical gas imaging, permittee’s plan must also include the following elements:

i. Verification that the optical gas imaging equipment meets the specifications of Conditions A and B, below. This verification is an initial verification and may either be performed by the permittee, by the manufacturer, or by a third party. For the


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purposes of complying with the fugitives emissions monitoring program with optical gas imaging, a fugitive emission is defined as any visible emissions observed using optical gas imaging. A. The optical gas imaging equipment must be capable of imaging gases in the

spectral range for the compound of highest concentration in the potential fugitive emissions.

B. The optical gas imaging equipment must be capable of imaging a gas that is half methane, half propane at a concentration of 10,000 ppm at a flow rate of ≤60g/hr from a quarter inch diameter orifice.

ii. Procedure for a daily verification check. iii. Procedure for determining the operator's maximum viewing distance from the

equipment and how the operator will ensure that this distance is maintained. iv. Procedure for determining maximum wind speed during which monitoring can be

performed and how the operator will ensure monitoring occurs only at wind speeds below this threshold.

v. Procedures for conducting surveys, including the items specified in Conditions A through C, below. A. How the operator will ensure an adequate thermal background is present in order

to view potential fugitive emissions. B. How the operator will deal with adverse monitoring conditions, such as wind. C. How the operator will deal with interferences (e.g., steam).

vi. Training and experience needed prior to performing surveys. vii. Procedures for calibration and maintenance. At a minimum, procedures must comply

with those recommended by the manufacturer. h. If using Method 21 of Appendix A-7 of 40 CFR Part 60, the plan must also include the

following elements. For the purposes of complying with the fugitive emissions monitoring program using Method 21 a fugitive emission is defined as an instrument reading of 500 ppm or greater. i. Verification that the monitoring equipment meets the requirements specified in

Section 6.0 of Method 21 at 40 CFR Part 60, Appendix A-7. For purposes of instrument capability, the fugitive emissions definition shall be 500 ppm or greater methane using a FID-based instrument. If using an analyzer other than a FID-based instrument, the permittee must develop a site-specific fugitive emission definition that would be equivalent to 500 ppm methane using a FID-based instrument (e.g., 10.6 eV PID with a specified isobutylene concentration as the fugitive emission definition would provide equivalent response to the compound of interest).

ii. Procedures for conducting surveys. At a minimum, the procedures shall ensure that the surveys comply with the relevant sections of Method 21 at 40 CFR Part 60, Appendix A-7, including Section 8.3.1.

i. Sitemap j. A defined observation path that ensures that all fugitive emissions components are within

sight of the path. The observation path must account for interferences. k. If using Method 21, the plan must also include a list of fugitive emissions components to

be monitored and method for determining location of fugitive emissions components to be monitored in the field (e.g. tagging, identification on a process and instrumentation diagram, etc.).


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l. The plan must also include the written plan developed for all of the fugitive emission components designated as difficult-to-monitor in accordance with Condition 3.11.d, and the written plan for fugitive emission components designated as unsafe-to-monitor in accordance with Condition 3.11.e.

3.11. Monitoring Surveys for Fugitive Emission Components [§60.5397a(e)-(g)]

a. Each monitoring survey shall observe each fugitive emissions component, as defined in §60.5430a, for fugitive emissions.

b. The permittee must conduct an initial monitoring survey within 60 days of the startup of a new compressor station.

c. A monitoring survey of the fugitive emissions components at the compressor station must be performed at least quarterly after the initial survey. Consecutive quarterly monitoring surveys must be conducted at least 60 days apart, with the exceptions noted in Conditions 3.11.d and 3.11.e., below.

d. Fugitive emissions components that cannot be monitored without elevating the monitoring personnel more than 2 meters above the surface may be designated as difficult-to-monitor. Fugitive emissions components that are designated difficult-to-monitor must meet the following specifications: i. A written plan must be developed for all of the fugitive emissions components

designated difficult-to-monitor. This written plan must be incorporated into the fugitive emissions monitoring plan required by Condition 3.10.

ii. The plan must include the identification and location of each fugitive emissions component designated as difficult-to-monitor.

iii. The plan must include an explanation of why each fugitive emissions component designated as difficult-to-monitor is difficult-to-monitor.

iv. The plan must include a schedule for monitoring the difficult-to-monitor fugitive emissions components at least once per calendar year.

e. Fugitive emissions components that cannot be monitored because monitoring personnel would be exposed to immediate danger while conducting a monitoring survey may be designated as unsafe-to-monitor. Fugitive emissions components that are designated unsafe-to-monitor must meet the following specifications: i. A written plan must be developed for all of the fugitive emissions components

designated unsafe-to-monitor. This written plan must be incorporated into the fugitive emissions monitoring plan.

ii. The plan must include the identification and location of each fugitive emissions component designated as unsafe-to-monitor.

iii. The plan must include an explanation of why each fugitive emissions component designated as unsafe-to-monitor is unsafe-to-monitor.

iv. The plan must include a schedule for monitoring the fugitive emissions components designated as unsafe-to-monitor.

3.12. Repair and Replacement of Identified Sources of Fugitive Emissions The permittee must repair and replace identified sources of fugitive emissions as follows: [§60.5397a(h)]


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a. Each identified source of fugitive emissions shall be repaired or replaced as soon as practicable, but no later than 30 calendar days after detection of the fugitive emissions.

b. If the repair or replacement is technically infeasible, would require a vent blowdown, a compressor station shutdown, or would be unsafe to repair during operation of the unit, the repair or replacement must be completed during the next scheduled compressor station shutdown, after a planned vent blowdown or within 2 years, whichever is earlier.

c. Each repaired or replaced fugitive emissions component must be resurveyed as soon as practicable, but no later than 30 days after being repaired, to ensure that there are no fugitive emissions.

d. For repairs that cannot be made during the monitoring survey when the fugitive emissions are initially found, the operator may resurvey the repaired fugitive emissions components using either Method 21 or optical gas imaging within 30 days of finding such fugitive emissions.

e. For each repair that cannot be made during the monitoring survey when the fugitive emissions are initially found, a digital photograph must be taken of that component or the component must be tagged for identification purposes. The digital photograph must include the date that the photograph was taken, must clearly identify the component by location within the site (e.g., the latitude and longitude of the component or by other descriptive landmarks visible in the picture).

f. Operators that use Method 21 to resurvey the repaired fugitive emissions components are subject to the following resurvey provisions: i. A fugitive emissions component is repaired when the Method 21 instrument indicates

a concentration of less than 500 ppm above background or when no soap bubbles are observed when the alternative screening procedures specified in Section 8.3.3 of Method 21 are used;

ii. Operators must use the Method 21 monitoring requirements specified in Condition 3.10.h.ii or the alternative screening procedures specified in Section 8.3.3 of Method 21.

g. Operators that use optical gas imaging to resurvey the repaired fugitive emissions components, are subject to the following resurvey provisions: i. A fugitive emissions component is repaired when the optical gas imaging instrument

shows no indication of visible emissions; ii. Operators must use the optical gas imaging monitoring requirements specified in

Condition 3.10.g. 3.13. Recordkeeping for Fugitive Emission Components Monitoring The permittee must keep the following fugitive emission components monitoring records: [60.5420a(c)(15)]

a. The fugitive emissions monitoring plan as required in Condition 3.10. b. The following records for each monitoring survey:

i. Date of the survey. ii. Beginning and end time of the survey. iii. Name of operator(s) performing survey with training and experience notated. iv. Monitoring instrument used.


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v. When optical gas imaging is used to perform the survey, one or more digital photographs or videos, captured from the optical gas imaging instrument used for conduct of monitoring, of each required monitoring survey being performed. The digital photograph must include the date the photograph was taken and the latitude and longitude of the collection of fugitive emissions components at a compressor station imbedded within or stored with the digital file. As an alternative to imbedded latitude and longitude within the digital file, the digital photograph or video may consist of an image of the monitoring survey being performed with a separately operating GPS device within the same digital picture or video, provided the latitude and longitude output of the GPS unit can be clearly read in the digital image.

vi. Fugitive emissions component identification when Method 21 is used to perform the monitoring survey.

vii. Ambient temperature, sky conditions, and maximum wind speed at the time of the survey.

viii. Any deviations from the monitoring plan or a statement that there were no deviations from the monitoring plan.

ix. Documentation of each fugitive emission, including the following information: A. Location. B. Any deviations from the monitoring plan or a statement that there were no

deviations from the monitoring plan. C. Number and type of components for which fugitive emissions were detected. D. Number and type of difficult-to-monitor and unsafe-to-monitor fugitive emission

components monitored. E. Instrument reading of each fugitive emissions component that requires repair

when Method 21 is used for monitoring. F. Number and type of fugitive emissions components that were not repaired as

required in Condition 3.12. G. Number and type of components that were tagged as a result of not being repaired

during the monitoring survey when the fugitive emissions were initially found as required in Condition 3.12.e.

H. If a fugitive emissions component is not tagged, a digital photograph or video of each fugitive emissions component that could not be repaired during the monitoring survey when the fugitive emissions were initially found as required in Condition 3.12.e. The digital photograph or video must clearly identify the location of the component that must be repaired. Any digital photograph or video required under this paragraph can also be used to meet the requirements under Condition 3.13.b.v, as long as the photograph or video is taken with the optical gas imaging instrument, includes the date and the latitude and longitude are either imbedded or visible in the picture.

I. Repair methods applied in each attempt to repair the fugitive emissions components.

J. Number and type of fugitive emission components placed on delay of repair and explanation for each delay of repair.

K. The date of successful repair of the fugitive emissions component. L. Instrumentation used to resurvey a repaired fugitive emissions component that

could not be repaired during the initial fugitive emissions finding.


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3.14. Annual Reporting for Reciprocating Compressor and Fugitive Emission

Components The permittee must submit Annual Reports containing the following information: [§60.5420a(b)]

a. The following general information for all reports: i. The company name, facility site name associated with the affected facility, and

address of the affected facility. If an address is not available for the site, include a description of the site location and provide the latitude and longitude coordinates of the site in decimal degrees to an accuracy and precision of five (5) decimals of a degree using the North American Datum of 1983.

ii. An identification of each affected facility being included in the annual report. iii. Beginning and ending dates of the reporting period. iv. A certification by a Responsible Official certifying the truth, accuracy, and

completeness. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.

b. For the reciprocating compressor affected facility, the following specific information: i. The cumulative number of hours of operation or the number of months since initial

startup or since the previous reciprocating compressor rod packing replacement, whichever is later. Alternatively, a statement that emissions from the rod packing are being routed to a process through a closed vent system under negative pressure.

ii. Records of deviations specified in Condition 3.13.b.viii that occurred during the reporting period.

c. For the collection of fugitive emissions components at the compressor station, the records of each monitoring survey including the specific information specified in 3.14.c.i-xii, below: i. Date of the survey. ii. Beginning and end time of the survey. iii. Name of operator(s) performing survey. If the survey is performed by optical gas

imaging, note the training and experience of the operator. iv. Ambient temperature, sky conditions, and maximum wind speed at the time of the

survey. v. Monitoring instrument used. vi. Any deviations from the monitoring plan or a statement that there were no deviations

from the monitoring plan. vii. Number and type of components for which fugitive emissions were detected. viii. Number and type of fugitive emissions components that were not repaired as

required in Condition 3.12. ix. Number and type of difficult-to-monitor and unsafe-to-monitor fugitive emission

components monitored. x. The date of successful repair of the fugitive emissions component. xi. Number and type of fugitive emission components placed on delay of repair and

explanation for each delay of repair. xii. Type of instrument used to resurvey a repaired fugitive emissions component that

could not be repaired during the initial fugitive emissions finding.


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d. The permittee must submit Subpart OOOOa Annual Reports to the EPA via the CEDRI.

(CEDRI can be accessed through the EPA's CDX (https://cdx.epa.gov/ ). The permittee must use the appropriate electronic report in CEDRI for Subpart OOOOa or an alternate electronic file format consistent with the extensible markup language (XML) schema listed on the CEDRI Web site (https://www.epa.gov/chief). If the reporting form specific to Subpart OOOOa is not available in CEDRI at the time that the report is due, the permittee must submit the report to the Administrator at the appropriate address listed in §60.4. Once the form has been available in CEDRI for at least 90 calendar days, the permittee must begin submitting all subsequent reports via CEDRI. The reports must be submitted by the deadlines specified below, regardless of the method in which the reports are submitted. i. The initial Subpart OOOOa Annual Report is due no later than 90 days after the end

of the initial compliance period. (see Condition 3.3) ii. Subsequent Subpart OOOOa Annual Reports are due no later than same date each

year as the initial annual report. The permittee may submit one report for both affected facilities (reciprocating compressor and the fugitive emission components) provided the report contains all of the specific information required for each, as specified in Conditions 3.14.b and 3.14.c, above.

4.0 OPERATION AND MAINTENANCE REQUIREMENTS 4.1. Operation of Pollution Control Devices and Processes If air pollution control devices are installed at the facility, the permittee is required to operate and ensure proper functioning of the air pollution control devices and components at all times when the associated emission source is operating. [OAR 340-226-0120] 4.2. Highest and Best Practicable Treatment and Control The permittee must provide the highest and best practicable treatment and control of air contaminant emissions in every case so as to maintain overall air quality at the highest possible levels, and to maintain contaminant concentrations, visibility reduction, odors, soiling, and other deleterious factors at the lowest possible levels as provided below. [OAR 340-226-0100] 5.0 PLANT SITE EMISSION LIMITS This permit contains no Plant Site Emission Limits (PSELs) since potential-to-emit emissions of all criteria pollutants are less than de minimis levels of one ton per year of criteria pollutants and less than the de minimis level of 2760 tons per year of GHG.

https://cdx.epa.gov/

https://www.epa.gov/chief


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6.0 COMPLIANCE DEMONSTRATION The permittee must demonstrate compliance with the requirements of NSPS Subpart OOOOa as required in Section 3.0. 7.0 SOURCE TESTING The permittee is not required to perform source testing. Testing in terms of fugitive emission monitoring is required by Section 3.0. 8.0 RECORDKEEPING REQUIREMENTS In addition to the recordkeeping requirements in Section 3.0, the permittee must perform the following recordkeeping: 8.1. Excess Emissions

a. The permittee must maintain the records of excess emissions listed below and as defined in OAR 340-214-0300 through 340-214-0340, recorded on occurrence. Typically, excess emissions are caused by process upsets, startups, shutdowns or scheduled maintenance. In many cases, excess emissions are evident when visible emissions are greater than 20% opacity as a six-minute block average. i. The date and time of the beginning of the excess emissions event and the duration or

best estimate of the time until return to normal operation; ii. The date and time the permittee notified DEQ of the event; iii. The equipment involved; iv. Whether the event occurred during planned startup, planned shutdown, scheduled

maintenance or as a result of a breakdown, malfunction or emergency; v. Steps taken to mitigate emissions and corrective action taken, including whether the

approved procedures for a planned startup, shutdown or maintenance activity were followed;

vi. The magnitude and duration of each occurrence of excess emissions during the course of an event and the increase over normal rates or concentrations as determined by continuous monitoring or best estimate (supported by operating data and calculations); and

vii. The final resolution of the cause of the excess emissions; b. If there is an ongoing excess emission caused by an upset or breakdown, the permittee

must immediately take action to minimize emissions by reducing or ceasing operation of the equipment or facility, unless doing so could result in physical damage to the equipment or facility, or cause injury to employees. In no case may the permittee operate more than 48 hours after the beginning of the excess emissions, unless continued operation is approved by DEQ in accordance with OAR 340-214-0330(4).


Page 14 of 20

c. In the event of any excess emissions which are of a nature that could endanger public

health and occur during non-business hours, weekends or holidays, the permittee must immediately notify DEQ by calling the Oregon Emergency Response System (OERS). The current number is 1-800-452-0311.

d. If the permittee anticipates that scheduled maintenance may result in excess emissions, the permittee must submit scheduled maintenance procedures used to minimize excess emissions to DEQ for prior authorization, as required in OAR 340-214-0320. New or modified procedures must be received by DEQ in writing at least 72 hours prior to the first occurrence of the excess emission event. The permittee must abide by the approved procedures and have a copy available at all times.

e. The permittee must maintain a log of all excess emissions in accordance with OAR 340-214-0340(3).

8.2. Complaint Log The permittee must maintain a log of all complaints received by the permittee in person, in writing, by telephone or through other means that specifically refer to air pollution concerns associated to the permitted facility. Documentation must include date of contact, date and time of observed nuisance condition, description of nuisance condition, location of receptor, status of plant operation during the observed period, and date and time of response to complainant. The log must include a record of the permittee’s actions to investigate the validity of each complaint and a record of actions taken for complaint resolution. [OAR 340-214-0114] 8.3. Retention of Records Unless otherwise specified, the permittee must retain all records for a period of at least five (5) years from the date of the monitoring sample, measurement, report or application and make them available to DEQ upon request. [OAR 340-214-0114] 9.0 REPORTING REQUIREMENTS 9.1. Excess Emissions The permittee must notify DEQ of excess emissions events if the excess emission is of a nature that could endanger public health.

a. The permittee must also submit follow-up reports in Condition 8.1 when required by DEQ. i. Such notice must be provided as soon as possible, but never more than one hour after

becoming aware of the problem. Notice must be made to the regional office identified in Condition 11.0 by email, telephone, facsimile or in person.

ii. If the excess emissions occur during non-business hours, the permittee must notify DEQ by calling the Oregon Emergency Response System (OERS). The current number is 1-800-452-0311.


Page 15 of 20

9.2. DEQ Annual Reports For each year this permit is in effect, the permittee must submit to DEQ by February 15 two (2) paper copies and one (1) electronic copy of the following information for the previous calendar year:

a. Copies of NSPS Subpart OOOOa Annual Reports submitted to EPA as required by Condition 3.14.d.

b. A brief summary listing the date, time, and the affected device/process for each excess emission that occurred during the reporting period.

c. Summary of complaints relating to air quality received by permittee during the year in accordance with Condition 8.2.

d. List any permanent changes made in facility process, production levels, and pollution control equipment which affected air contaminant emissions.

9.3. Greenhouse Gas Registration and Reporting

a. If the calendar year greenhouse gas emissions (CO2e) are ever greater than or equal to 2,756 tons (2,500 metric tons), the permittee must annually register and report its greenhouse gas emissions with DEQ in accordance with OAR 340 Division 215.

b. If the calendar year greenhouse gas emissions (CO2e) are less than 2,756 tons (2,500 metric tons) for three consecutive years, the permittee may stop reporting greenhouse gas emissions but must retain all records used to calculate greenhouse gas emissions for the five years following the last year that they were required to report. The permittee must resume reporting its greenhouse gas emissions if the calendar year greenhouse gas emissions (CO2e) are greater than or equal to 2,756 tons (2,500 metric tons) in any subsequent calendar year.

9.4. Initial Startup Notice The permittee must notify DEQ in writing of the date a newly permitted source is first brought into normal operation. The notification must be submitted no later than seven (7) days after the initial startup. [OAR 340-214-0110] 9.5. Notice of Change of Ownership or Company Name The permittee must notify DEQ in writing using a DEQ “Transfer Application” form within 60 days after the following:

a. Legal change of the name of the company as registered with the Corporations Division of the State of Oregon; or

b. Sale or exchange of the activity or facility.


Page 16 of 20

9.6. Construction or Modification Notices The permittee must notify DEQ in writing using a DEQ “Notice of Intent to Construct” form, or other permit application forms and obtain approval in accordance with OAR 340-210-0205 through 340-210-0250 before:

a. Constructing, installing or establishing a new stationary source that will cause an increase in any regulated pollutant emissions;

b. Making any physical change or change in operation of an existing stationary source that will cause an increase, on an hourly basis at full production, in any regulated pollutant emissions; or

c. Constructing or modifying any air pollution control equipment. 9.7. Air Toxics Emission Inventory The permittee must submit an air toxics emission inventory every three years. DEQ will notify the permittee in writing and provide a reporting form. [OAR 340-245-0040] 10.0 ADMINISTRATIVE REQUIREMENTS 10.1. Permit Renewal Application The permittee must submit the completed application package for renewal of this permit 180 days prior to the expiration date. Two (2) paper copies and one (1) electronic copy of the application must be submitted to the DEQ Permit Coordinator listed in Condition 11.2. [OAR 340-216-0040] 10.2. Permit Modifications Application for a modification of this permit must be submitted within 60 days prior to the source modification. When preparing an application, the applicant should also consider submitting the application 180 days prior to allow DEQ adequate time to process the application and issue a permit before it is needed. A special activity fee must be submitted with an application for the permit modification. The fees and two (2) copies of the application must be submitted to the DEQ Business Office. 10.3. Annual Compliance Fee The permittee must pay the annual fees specified in OAR 340-216-8020, Table 2, Part 2 and 3 for a Standard ACDP on December 1 of each year this permit is in effect. An invoice indicating the amount, as determined by DEQ regulations will be mailed prior to the above date. Late fees in accordance with Part 5 of the table will be assessed as appropriate.


Page 17 of 20

10.4. Change of Ownership or Company Name Fee The permittee must pay the non-technical permit modification fee specified in OAR 340-216-8020, Table 2, Part 4 with an application for changing the ownership or the name of the company. 10.5. Special Activity Fees The permittee must pay the special activity fees specified in OAR 340-216-8020, Table 2, Part 4 with an application to modify the permit. 11.0 DEQ CONTACTS / ADDRESSES 11.1. Business Office The permittee must submit payments for invoices, applications to modify the permit, and any other payments to DEQ’s Business Office:

Oregon Dept. of Environmental Quality Financial Services – Revenue Section 700 NE Multnomah St., Suite 600 Portland, OR 97232-4100

11.2. Permit Coordinator The permittee must submit all notices, reports (annual reports, source test plans and reports, etc.), and applications that do not include payment to the Permit Coordinator.

Oregon Dept. of Environmental Quality Eastern Region – Bend Office Air Quality Permit Coordinator 475 NE Bellevue Dr., Suite 110 Bend, OR 97701-7415 [email protected]

11.3. Report Submittals Unless otherwise notified or indicated in this permit, the permittee must submit all reports (annual reports, source test plans and reports, etc.) to DEQ’s Eastern Region. If the name of the Air Quality staff member responsible for the permit is known, please include it:

Oregon Dept. of Environmental Quality Eastern Region 475 NE Bellevue Drive, Suite 110 Bend, OR 97701-7415



Page 18 of 20

11.4. Web Site Information about air quality permits and DEQ’s regulations may be obtained from the DEQ web page at www.oregon.gov/deq/. 12.0 GENERAL CONDITIONS AND DISCLAIMERS 12.1. Permitted Activities

a. Until this permit expires or is modified or revoked, the permittee is allowed to discharge air contaminants from the following:

i. Processes and activities directly related to or associated with the devices/processes listed in Condition 1.0 of this permit;

ii. Any categorically insignificant activities, as defined in OAR 340-200-0020, at the source; and

iii. Construction or modification changes that are Type 1 or Type 2 changes under OAR 340-210-0225 that are approved by DEQ in accordance with OAR 340-210-0215 through 0250, if the permittee complies with all of the conditions of DEQ’s approval to construct and all of the conditions of this permit.

b. Discharge of air contaminants from any other equipment or activity not identified herein is not authorized by this permit.

12.2. Other Regulations

In addition to the specific requirements listed in this permit, the permittee must comply with all other applicable legal requirements enforceable by DEQ.

12.3. Conflicting Conditions

In any instance in which there is an apparent conflict relative to conditions in this permit, the most stringent conditions apply. [OAR 340-200-0010]

12.4. Masking of Emissions

The permittee must not cause or permit the installation of any device or use any means designed to mask the emissions of an air contaminant that causes or is likely to cause detriment to health, safety, or welfare of any person or otherwise violate any other regulation or requirement. [OAR 340-208-0400]

http://www.oregon.gov/deq/


Page 19 of 20

12.5. DEQ Access

The permittee must allow DEQ’s representatives access to the plant site and pertinent records at all reasonable times for the purposes of performing inspections, surveys, collecting samples, obtaining data, reviewing and copying air contaminant emissions discharge records and conducting all necessary functions related to this permit in accordance with ORS 468.095. 12.6. Permit Availability The permittee must have a copy of the permit available at the facility at all times. [OAR 340-216-0020(3)] 12.7. Open Burning The permittee may not conduct any open burning except as allowed by OAR 340, division 264. 12.8. Asbestos The permittee must comply with the asbestos abatement requirements in OAR 340, division 248 for all activities involving asbestos-containing materials, including, but not limited to, demolition, renovation, repair, construction, and maintenance. 12.9. Property Rights The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of federal, state, or local laws or regulations. 12.10. Permit Expiration

a. A source may not be operated after the expiration date of the permit, unless any of the following occur prior to the expiration date of the permit: [OAR 340-216-0082] i. A timely and complete application for renewal of this permit or for a different ACDP

has been submitted; or b. A timely and complete application for renewal or for an Oregon Title V Operating

Permit has been submitted, or c. Another type of permit (ACDP or Oregon Title V Operating Permit) has been issued

authorizing operation of the source. d. For a source operating under an ACDP or Oregon Title V Operating Permit, a

requirement established in an earlier ACDP remains in effect notwithstanding expiration of the ACDP, unless the provision expires by its terms or unless the provision is modified or terminated according to the procedures used to establish the requirement initially.

12.11. Permit Termination, Revocation, or Modification DEQ may terminate, revoke or modify this permit pursuant to OAR Chapter 340 Division 216. [OAR 340-216-0082].


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13.0 ABBREVIATIONS, ACRONYMS AND DEFINITIONS

ACDP Air Contaminant Discharge

Permit ASTM American Society for Testing

and Materials AQMA Air Quality Maintenance Area calendar year

The 12-month period beginning January 1st and ending December 31st

CAO Cleaner Air Oregon CFR Code of Federal Regulations CO CO2e

Carbon Monoxide Carbon Dioxide Equivalent

DEQ Oregon Department of Environmental Quality

dscf dry standard cubic foot EPA US Environmental Protection

Agency FCAA Federal Clean Air Act Gal GHG

Gallon(s) Greenhouse Gas

gr/dscf grains per dry standard cubic foot

HAP Hazardous Air Pollutant as defined by OAR 340-244-0040

I&M Inspection and Maintenance lb Pound(s) MMBtu Million British thermal units NA Not Applicable NESHAP National Emissions Standards

for Hazardous Air Pollutants NOX Nitrogen Oxides NSPS New Source Performance

Standard NSR New Source Review

O2 Oxygen OAR Oregon Administrative Rules ORS Oregon Revised Statutes O&M Operation and Maintenance Pb Lead PCD Pollution Control Device PM Particulate Matter PM10

PM2.5

Particulate Matter less than 10 microns in size Particulate Matter less than 2.5 microns in size

ppm parts per million PSD Prevention of Significant

Deterioration PSEL Plant Site Emission Limit PTE Potential to Emit RACT Reasonably Available Control

Technology scf standard cubic foot SER Significant Emission Rate SIC Standard Industrial Code SIP State Implementation Plan SO2 Sulfur Dioxide Special Control Area

as defined in OAR 340-204-0070

TACT Typically Achievable Control Technology

VE Visible Emissions VOC Volatile Organic Compound VMT Vehicle Miles Traveled Year A period consisting of any 12-

consecutive calendar months

Draft Permit No.: 30-0076-SI-01 06/29/2020 Application No: 31947 Page 1 of 16

SIMPLE AIR CONTAMINANT DISCHARGE PERMIT REVIEW REPORT Northwest Pipeline LLC

Walla Walla Compressor Station 0.7 miles east on Milton Cemetery Road

Milton-Freewater, OR 97862

Source Information: SIC 4922

NAICS 486210

Source Categories (Table 1 Part, code) Part B, #88

Public Notice Category II

Compliance and Emissions Monitoring Requirements: FCE Yes

Compliance schedule No

Unassigned emissions No

Emission credits No

Special Conditions No

Source test No

COMS No

CEMS No

PEMS No

Ambient monitoring No

Reporting Requirements Annual reports (due date)

DEQ due 02/15 EPA OOOOa due

per NSPS

Quarterly report (due dates) No

Monthly report (due dates) No

Excess emissions report Yes

Other (specify) No

Air Programs Synthetic Minor (SM) No

SM -80 No

NSPS (list subparts) OOOOa

NESHAP (list subparts) No

CAO Yes

NSR No

PSD No

GHG No

RACT No

TACT No

Other (specify) No

Draft Permit No.: 30-0076-SI-01 06/22/2020 Application No.: 31947

Page 2 of 16

TABLE OF CONTENTS

PERMITTING .................................................................................................................................3

SOURCE DESCRIPTION ...............................................................................................................4

COMPLIANCE HISTORY .............................................................................................................4

EMISSIONS ....................................................................................................................................5

TITLE V MAJOR SOURCE APPLICABILITY ............................................................................5

CLEANER AIR OREGON..............................................................................................................6

ADDITIONAL REQUIREMENTS .................................................................................................7

SOURCE TESTING ........................................................................................................................8

PUBLIC NOTICE ............................................................................................................................9

ATTACHMENT A – EMISSION DETAIL SHEETS ..................................................................10


Page 3 of 16

PERMITTING PERMITTEE IDENTIFICATION

1. The permittee is Northwest Pipeline LLC. The permitted source is the proposed Walla Walla Compressor Station, located 0.7 miles east on Milton Cemetery Road, Milton-Freewater, Oregon.

PERMITTING ACTION

2. The proposed permit is a new Simple ACDP for a new source. The source is subject to NSPS under 40 CFR Part 60 Subpart OOOOa, which identify standards for performance for crude oil and natural gas facilities for which construction commenced after September 18, 2015. In accordance with OAR 340-216-8010 Table 1, Part B (88), all sources covered under a NSPS under OAR 340-238, are required to have a General, Simple or Standard ACDP. DEQ has adopted Subpart OOOOa by reference under OAR 340-238-0060(3)(iiii). There is no General ACDP for which the source qualifies to be assigned. DEQ proposes to issue a Simple ACDP as opposed to a Standard ACDP since the potential to emit will be less than the Generic PSELs, and the department does not expect that an inordinate amount of staff time will be required to permit, inspect and assure compliance status of the permit.

3. The proposed facility has been determined to be a new source for the purposes of Cleaner

Air Oregon in accordance with OAR 340-245-0020 because the air quality permit application was not submitted and deemed complete, nor had construction commenced on this facility before November 16, 2018. As a new source the permittee is required to perform a risk assessment in accordance with OAR 340-245-0050, and demonstrate compliance with the Risk Action Levels for a “New and Reconstructed Source” in OAR 340-245-8010 Table 1.

OTHER PERMITS

4. No other DEQ land quality or water quality permits have been issued or are required for this source.

ATTAINMENT STATUS

5. The source is located in an attainment area for all pollutants.

6. The source is not located within 10 kilometers of any Class I Air Quality Protection Areas .


Page 4 of 16

SOURCE DESCRIPTION OVERVIEW

7. The permittee proposes to construct and operate the Walla Walla Compressor Station. The station will be built near the existing Milton-Freewater Meter Station on the Walla Walla natural gas lateral, at approximately milepost 22.5. The station will consist of an electrically driven reciprocating compressor with associated rod packing leaks and blowdown emissions, a 500-gallon waste oil storage tank and process piping component fugitive emissions.

PROCESS AND CONTROL DEVICES

8. Proposed air contaminant sources at the facility consist of the following:

a. One (1) 500 hp electric motor driven reciprocating compressor; i. Compressor blowdown / Emergency shutdown testing; and ii. Compressor rod packing (fugitive emissions);

b. One (1) 500-gallon waste oil storage tank (fugitive emissions); and c. Process piping and equipment leaks (fugitive emissions).

9. A leak detection and repair (LDAR) program will be implemented as required by NSPS

Subpart OOOOa. OPERATION AND MAINTENANCE

10. NSPS requires that replacement of the reciprocating compressor rod packing must occur on or before every 26,000 hours of compressor operation or every 36 months since startup or last rod packing replacement. If the permittee opts to replace the rod packing based upon hours of operation, then an hour meter device will be needed to continuously track operation hours.

COMPLIANCE HISTORY

11. The facility will be inspected by DEQ personnel to ensure compliance with the permit conditions.


Page 5 of 16

EMISSIONS

12. Proposed PSEL information: Since the maximum potentials to emit are less than the regulatory de minimis levels of 1 tpy for criteria pollutants and 2,760 tpy for GHG, the permit will not include PSELs in accordance with OAR 340-222-0020(3)(a).

SIGNIFICANT EMISSION RATE ANALYSIS

13. A significant emission rate analysis is not applicable since there are no PSELs proposed for the permit.

TITLE V MAJOR SOURCE APPLICABILITY

14. A major source is a facility that has the potential to emit 100 tons/year or more of any criteria pollutant or 10 tons/year or more of any single HAP or 25 tons/year or more of combined HAPs.

15. A source that has potential to emit at the major source levels but accepts a PSEL below

major source levels is called a Synthetic Minor (SM).

16. A source that has the potential to emit above the Title V major source thresholds but is willing to take a limit that is 80% or greater of the major source thresholds (e.g., 80 tons per year or greater for criteria pollutants) is called a Synthetic Minor 80 (SM-80).

17. A source that has the potential to emit less than major source thresholds is called a True

Minor.

18. A source that has the potential to emit less than major source thresholds but is required by rule to obtain a Title V permit is called a Title V Minor Source.

CRITERIA POLLUTANTS

19. This facility is a True Minor source of criteria pollutant emissions. The basis for this determination can be found in Attachment A, Emission Detail Sheets, of this Review Report.


Page 6 of 16

HAZARDOUS AIR POLLUTANTS

20. This source is not a major source of hazardous air pollutants. The basis for this determination can be found in Attachment A, Emission Detail Sheets, of this Review Report.

Hazardous Air Pollutants Potential to Emit (pounds/year)

n-Hexane 10 (0.005 tpy) All other HAPs 4.8 (0.0024 tpy) Total HAP Emissions 15 (0.01 tpy)

CLEANER AIR OREGON

21. Cleaner Air Oregon Risk Assessment Summary:

Risk Type Facility Risk Risk Assessment Results

Cancer Risk – added cancer risk per million with 70 years of exposure Residential (e.g. homes near facility) 0.03

Facility Risk is below the Risk Action Level* limit of 10

Non-Residential Child (e.g. school near facility) 0.001

Non-Residential Worker (e.g. office near facility) 0.002

Non-cancer Risk – Hazard Index (less than or equal to 1 is considered safe) Annual Exposure-Residential (e.g. home) 0.001

Facility Risk is below the Risk Action Level limit of 1

Annual Exposure-Non-Residential Child (e.g. school) 0.0002

Annual Non-Residential Worker (e.g. office) 0.0002

24-Hour Exposure (acute) 0.004 Facility Risk is below the Risk Action limit of 1

*DEQ requires risk reduction if risk is above these Risk Action Levels.

22. The project is considered a new source for Cleaner Air Oregon as defined in OAR 340-245-0020(33). A level 1 risk assessment was conducted for the facility based on an air toxics emissions inventory and the dispersion factors in OAR 340-245-8050. The calculated risk for all scenarios was less than the 0.5 Source Permit Level established in OAR 340-245-8010. In accordance with OAR 340-245-0050(7), the facility is determined to be a de minimis source of air toxics.


Page 7 of 16

TOXICS RELEASE INVENTORY

23. The Toxics Release Inventory (TRI) is a federal program that tracks the management of certain toxic chemicals that may pose a threat to human health and the environment, over which DEQ has no regulatory authority. It is a resource for learning about toxic chemical releases and pollution prevention activities reported by certain industrial facilities. Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) created the TRI Program. In general, chemicals covered by the TRI Program are those that cause:

a. Cancer or other chronic human health effects; b. Significant adverse acute human health effects; or c. Significant adverse environmental effects.

24. There are currently over 650 chemicals covered by the TRI Program. Facilities that

manufacture, process or otherwise use these chemicals in amounts above established levels must submit annual TRI reports on each chemical.

25. The proposed Walla Walla Compressor Station is not covered by the TRI program

because it will not manufacture, process or use TRI-listed chemicals in quantities above threshold levels in a given year.

ADDITIONAL REQUIREMENTS NEW SOURCE PERFORMANCE STANDARDS APPLICABILITY

26. 40 CFR Part 60, Subpart OOOOa, “Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015”, is applicable to the source. NSPS Subpart OOOOa applies since Northwest Pipeline LLC will commence construction of the Walla Walla Compressor Station, including affected facilities, after the September 18, 2015 applicability date. Affected facilities include an electrically-driven reciprocating natural gas compressor and process piping component fugitives. Fugitive emissions components are defined as any components that have the potential to emit fugitive emissions of methane or VOC at a compressor station, including but not limited to valves, connectors, pressure relief devices, open-ended lines, flanges, covers and closed vent systems not subject to §60.5411a. The storage tank is not considered an affected facility since the potential for VOC emissions is less than 6 tpy per §60.5365a(e). Applicable requirements of Subpart OOOOa have been placed into the permit.

27. The source is subject to the following updated federal standards or requirements that, at

time of permit issuance, have not been adopted by the Environmental Quality Commission. For any violations of the following specific regulation, the permittee may

https://www.epa.gov/toxics-release-inventory-tri-program/tri-listed-chemicals


Page 8 of 16

be subject to enforcement action by EPA, but not DEQ. DEQ retains the authority to modify the permit or issue attachments as provided in Oregon Administrative Rule Chapter 340 Division 216 if the EQC adopts these regulations.

Applicable Federal Standards Not Yet Adopted by EQC

40 CFR Part Subpart Federal Register Citation Date of

Promulgation

60 A - General Provisions 83 FR 56720 11/14/2018

60 A - General Provisions 84 FR 47882 09/11/2019

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS APPLICABILITY

28. There are no sources at this facility for which a National Emission Standard for Hazardous Air Pollutant standard has been promulgated.

GREENHOUSE GAS REPORTING APPLICABILITY

29. The source is not subject to greenhouse gas reporting under Division 215 because actual greenhouse gas emissions are less than 2,500 metric tons (2,756 short tons) of CO2 equivalents per year. If the source ever emits more than this amount, they will be required to report greenhouse gas emissions.

REASONABLY AVAILABLE CONTROL TECHNOLOGY APPLICABILITY

30. The RACT rules are not applicable to this source because it is not in the Portland AQMA, Medford AQMA, or Salem SKATS.

TYPICALLY ACHIEVABLE CONTROL TECHNOLOGY APPLICABILITY

31. A TACT determination is not required of this new source since the facility is subject to the New Source Performance Standards of Subpart OOOOa, which is considered TACT.

SOURCE TESTING

32. The NSPS Subpart OOOOa does not require source testing for reciprocating compressors or for process piping component fugitive emissions. Since the potential emissions for all pollutants are expected to be de minimis, DEQ does not consider source testing warranted.


Page 9 of 16

PUBLIC NOTICE

33. Pursuant to OAR 340-216-0064(4)(a), issuance of Simple Air Contaminant Discharge Permits require public notice in accordance with OAR 340-209-0030(3)(b), which requires DEQ to provide notice of the proposed permit action and a minimum of 30 days for interested persons to submit written comments. The public notice was issued on July 2, 2020 and the comment period will end on Aug. 3, 2020.

PD:dw


Page 10 of 16

ATTACHMENT A – EMISSION DETAIL SHEETS

The results of a representative inlet gas analysis were used to develop conservative (worst case) estimates of component constituency in terms of pounds per MMscf and volume percent. Representative Inlet Gas Analysis

Pollutant Inlet Gas (lb/MMscf)

Worst Case1 (lb/MMscf) % Total % VOC

CO2 944.28 1,140 2.56 -- Methane (CH4) 40,171 42,750 95.85 -- N2/Water/Ethane/Etc. 3,034 240 0.54 -- VOC 391.29 470 1.05 100.00 Total Gas 44,540 44,600 100.00 --

HAPs Benzene -- 1.0 0.002 0.21 Ethylbenzene -- 1.0 0.002 0.21 n-Hexane 10.67 13.00 0.029 2.77 Methanol -- 1.0 0.002 0.21 Toluene -- 1.0 0.002 0.21 2,2,4-TMP -- 1.0 0.002 0.21 Xylenes -- 1.0 0.002 0.21 Total HAP -- 19.00 0.043 4.04

Note1: 20% minimum contingency assumed.


Page 11 of 16

Compressor Rod Packing (CRP) Emissions With regard to leakage rate, the manufacturer indicates that “Packing in new and broken-in condition will leak 5-10 scfh through the vent. This leakage rate will increase over time due to wear of the non-metalic sealing rings.” The applicant’s engineering department applied a conservative leak rate estimate of 12 scfh/cylinder.

Blowdown (BD) Emissions


Page 12 of 16

Storage Tank (TKS) Emissions

EPA TANKS 4.0.9d was used to estimate the working and breathing losses from the waste oil storage tank. Process Piping and Equipment Leak (FUG) Emissions


Page 13 of 16

Combined Totals (all emission units) for Criteria Pollutants, HAPs and GHGs Criteria Pollutants

HAPs


Page 14 of 16

GHGs


Page 15 of 16

Cleaner Air Oregon Toxic Air Contaminant Emission Details Compressor Rod Packing (CRP)

Pollutant Activity Emission

Factor* (lbs/MMscf)

Emissions

Annual Acute Annual [lb/yr]

Acute [lb/day]

Hexane

0.48 MMscf NG

0.0013 MMscf NG

13 6.29 1.72E-02 Benzene 1 0.48 1.32E-03 Ethyl benzene 1 0.48 1.32E-03 Methanol 1 0.48 1.32E-03 Toluene 1 0.48 1.32E-03 Xylene (mixture) 1 0.48 1.32E-03 2,2,4-Trimethylpentane 1 0.48 1.32E-03 *Manufacturer estimate Blowdowns (BD)

Pollutant Activity Emission

Factor (lbs/MMscf)

Emissions

Annual Acute Annual [lb/yr]

Acute [lb/day]

Hexane

0.16 MMscf NG

0.0004 MMscf NG

13 1.38E-03 3.79E-06 Benzene 1 1.06E-04 2.91E-07 Ethyl benzene 1 1.06E-04 2.91E-07 Methanol 1 1.06E-04 2.91E-07 Toluene 1 1.06E-04 2.91E-07 Xylene (mixture) 1 1.06E-04 2.91E-07 2,2,4-Trimethylpentane 1 1.06E-04 2.91E-07


Page 16 of 16

Waste Oil Storage Tank (TKS)

Pollutant Activity

Emission Factor* (lbs/bbl) Annual Acute Annual

[lb/yr] Hexane

285.71 barrels 0.78 barrels

4.84E-06 1.38E-03 Benzene 3.72E-07 1.06E-04 Ethyl benzene 3.72E-07 1.06E-04 Methanol 3.72E-07 1.06E-04 Toluene 3.72E-07 1.06E-04 Xylene (mixture) 3.72E-07 1.06E-04 2,2,4-Trimethylpentane 3.72E-07 1.06E-04

Pollutant Emissions 1,2

Annual [lb/yr] Acute [lb/day]

Hexane 1.79 1.34E-05 Benzene 0.14 1.03E-06 Ethyl benzene 0.14 1.03E-06 Methanol 0.14 1.03E-06 Toluene 0.14 1.03E-06 Xylene (mixture) 0.14 1.03E-06 2,2,4-Trimethylpentane 0.14 1.03E-06

deq requests comments on northwest pipeline, …...reciprocating compressor with associated rod...

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