oklahoma department of environmental quality · caterpillar g3516le 1,340-hp engines and the other...

DRAFT

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM August 3, 2009

TO: Phillip Fielder, P.E., Permits and Engineering Groups Manager,

Air Quality Division

THROUGH: Kendal Stegmann, Sr. Environmental Manager, Compliance & Enforcement

THROUGH: Phil Martin, P.E., Engineering Section

THROUGH: Peer Review

FROM: Jian Yue, P.E., Engineering Section

SUBJECT: Evaluation of Permit Application No. 2009-200-O

Atlas Pipeline Mid-Continent WestOK LLC

Wolgamott Compressor Station (SIC 1311)

Section 16, T29N, R16W, Woods County

Latitude: 36.992o, Longitude: -98.942

o

In Alva, take Hwy. 281 north to Hardtner, KS, from the intersection of Main

and Central, drive west on Hackberry (D0010 Rd) for 15.75 miles and then turn

south on N2300 Rd.

SECTION I. INTRODUCTION

Atlas Pipeline Mid-Continent WestOK LLC has requested a modification to change the Title V

Operating Permit No. 2006-157-TV issued on 6/8/2006 for the above referenced facility (SIC

1311) to a synthetic minor source operating permit. The facility has removed a compressor

engine (C-5: 1,775-hp Caterpillar G3606LE lean burn engine with oxidation catalyst) and has

reduced actual facility-wide pollutant emissions below the major source thresholds as shown in

Section IV. This modification is considered as a Tier II significant modification.

SECTION II. PROCESS DESCRIPTION

The natural gas inlet stream enters the facility through an inlet scrubber. From the scrubber, gas

pressure is boosted via four compressors. Two compressors are driven by natural gas-fired

Caterpillar G3516LE 1,340-hp engines and the other two are driven by natural gas-fired

Waukesha L7044 GSI 1,680-hp engines. To achieve low NOx emissions, each engine utilizes an

air/fuel ratio control system. The Caterpillar engines are further controlled with oxidation

catalyst control systems to reduce CO and VOC. In addition, the Waukesha engines have a

catalytic converter to reduce NOx, CO, and VOC. Expected gas throughput is approximately 21

MMCF/Day.

PERMIT MEMORANDUM 2009-200-O DRAFT

After the inlet gas is passed through the compressors, the gas enters the glycol dehydrator. The

glycol dehydrator is used to remove water from the gas before it exits the facility. In the

dehydration process, gas passes through a contactor vessel where water is absorbed by the glycol.

The “rich” glycol, containing absorbed water, goes to the glycol dehydrator reboiler where heat is

used to boil off the water. The heat is supplied by a natural gas fired 0.5 MMBTUH reboiler

heater. The water vapor boiled off of the rich glycol stream exits the system via the glycol

dehydrator vent, which utilizes a condenser to catch small amounts of BTEX compounds that are

inadvertently boiled off with the water vapor. Non-condensable constituents of this stream are

further routed to the reboiler heater firebox for destruction.

SECTION III. EQUIPMENT

Internal Combustion Engines

Point Make/Model Hp Serial #

C-1 Waukesha L7044 GSI w/Catalytic Converter 1,680 13860/1

C-2 Waukesha L7044 GSI w/Catalytic Converter 1,680 14045/1

C-3 Caterpillar G3516LE w/Oxidation Catalyst 1,340 4EK04123

C-4 Caterpillar G3516LE w/Oxidation Catalyst 1,340 4EK04124

Glycol Dehydrator Reboiler

Point Make/Model MMBTU/hr

H-400 dehy Glycol Reboiler 0.50

Glycol Dehydrator Still Vent W/Condenser

Point Make/Model MMBTU/hr

H-400 still vent Still Vent w/Condenser ---

Tanks

Point Contents Barrels Gallons

TK-806 Condensate 200 8,400

TK-807 Condensate 200 8,400

Fugitives

Number Items Type of Equipment

177 Valves

210 Connectors

129 Flanges

23 Open Ended Lines

22 Other

16 Pumps


Engine Parameters

Engine Stack Stack Stack Stack

Source

(make/model)

Fuel Usage

(BTU/hp-hr)

Height

(feet)

Dia.

(inches)

Flow

(ACFM)

Temp.

(°F)

Waukesha L7044 GSI

w/cc

7,655 18 12 7,981 1,152

Waukesha L7044 GSI

w/cc

7,655 18 12 7,981 1,152

Caterpillar G3516LE

w/oc

7,546 23 13.5 7,685 1,125

Caterpillar G3516LE

w/oc

7,546 23 13.5 7,685 1,125

SECTION IV. EMISSIONS

Emissions estimates for the engines are based on continuous operation and manufacturer’s

emission data shown below. Emission estimates for the glycol reboiler are based on AP-42

(7/98), Chapter 1.4. Emission estimates from the glycol dehydration unit still vent are based on

GRI-GLYCalc Version 4.0, an inlet gas analysis, a glycol recirculation rate of 3.5 gallons per

minute (gpm), a throughput of 21 MMSCFD, recycle/recompression of the flash tank off-gases,

condensation of the still vent off-gases, and combustion of the condenser off-gases with 98%

efficiency. Estimated emissions for the tanks are based on AP-42 (9/97), Chapter 7.1, and

throughput of 126,000 gallons/year. The applicant has also estimated flash emissions from the

tanks using the Vasquez-Beggs equation. Emissions from loading of condensate into tank trucks

were estimated using a throughput of 126,000 gallons per year. Fugitive VOC emissions are

based on EPA’s 1995 Protocol for Equipment Leak Emission Estimates (EPA-453/R-95-017),

11.5% VOC in the inlet gas, and estimate of components. Emissions from 500-gallon methanol

tank and 8,400-gallon Stop Water Tank are negligible.

Engine Emission Factors

Point #

Name/Model

NOX

(g/hp-hr)

CO

(g/hp-hr)

VOC

(g/hp-hr)

C-1, & C-2 Waukesha L7044GSI w/cc 1.8 1.8 0.5

C-3, & C-4 Caterpillar G3516LE w/oc 1.5 1.5 0.5

Fugitive Emissions

Equipment Emission Factor lb/hr TPY

Valves 0.00992 0.29 1.26

Connectors 0.00044 0.02 0.09

Flanges 0.00086 0.02 0.07

Open-Ended Lines 0.00441 0.02 0.08

Pumps 0.02866 0.04 0.17

Other 0.0194 0.13 0.56

Total Fugitive Emissions 0.52 2.23


Facility-Wide Criteria Pollutant Emissions

NOX CO VOC

Sources lb/hr TPY lb/hr TPY lb/hr TPY

1,680-hp Waukesha L7044GSI w/cc (C-1) 6.67 29.21 6.67 29.21 1.85 8.11


1,340-hp Caterpillar G3516LE w/oc (C-3) 4.43 19.41 4.43 19.41 1.48 6.47


H-400 Dehy 0.06 0.27 0.05 0.23 0.01 0.01

H-400 Still Vent --- --- --- --- --- 1.55

Condensate Tanks & Flashing Emissions* --- --- --- --- --- 16.78

Truck Loading --- --- --- --- --- 0.38

Fugitives --- --- --- --- --- 2.23

Total Emissions 22.26 97.51 22.25 97.47 6.67 50.11

* includes working, breathing, and flashing losses

Dehydration units using glycol desiccants will emit benzene, toluene, ethyl benzene, xylene, and

n-hexane from the glycol reboiler vent stack. These emissions are summarized in the table

below. All emissions of HAPs are below the major source levels

HAP Emissions from the Glycol Dehydration Unit

Estimated Emissions

Pollutant lb/hr TPY

Benzene 0.0459 0.2013

Toluene 0.0331 0.1448

Ethyl benzene 0.0035 0.0155

Xylene 0.0140 0.0614

n-Hexane 0.0086 0.0377

Totals 0.1051 0.4607

Emissions of formaldehyde were calculated for the two 1,680-hp Waukesha L7044 GSI

w/catalytic converter using Waukesha’s emission factor of 0.05 g/hp-hr with a 50% reduction for

the catalytic converter. Emissions of formaldehyde were calculated for the two 1,340-hp

Caterpillar G3516LE w/Oxidation Catalyst using Caterpillar’s emission factor of 0.3 g/hp-hr

with a 50% reduction for the oxidation catalyst. Formaldehyde emissions are below the major

source levels.

Formaldehyde Emissions from the Engines

Estimated Emissions

EU Source lb/hr TPY

1 1,680-hp Waukesha L7044 GSI w/CC 0.09 0.39

2 1,680-hp Waukesha L7044 GSI w/CC 0.09 0.39

3 1,340-hp Caterpillar G3516LE w/OC 0.44 1.94

4 1,340-hp Caterpillar G3516LE w/OC 0.44 1.94

Totals 1.06 4.66


SECTION V. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable]

Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-2 (Incorporation by Reference) [Applicable]

This Subchapter incorporates by reference applicable provisions of Title 40 of the Code of

Federal Regulations. These requirements are addressed in the “Federal Regulations” section.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]

Subchapter 3 enumerates the primary and secondary ambient air quality standards and the

significant deterioration increments. At this time, all of Oklahoma is in “attainment” of these

standards.

OAC 252:100-5 (Registration of Air Contaminant Sources) [Applicable]

Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission

inventories annually, and pay annual operating fees based upon total annual emissions of

regulated pollutants. Emission inventories have been submitted and fees paid for the past years.

OAC 252:100-7 (Permits for Minor Facilities) [Applicable]

This facility qualifies as a synthetic minor source after issuance of this permit because total

controlled emissions of each criteria pollutant do not exceed 100 TPY, excluding trivial activities

and Hazardous Air Pollutants (HAP) emissions do not exceed the 10 TPY, for any one HAP, or

25 TPY for any aggregate of HAP. ODEQ’s “Potential to Emit Fact Sheet” revised June 2, 2003

stated that emissions from activities identified as a “trivial activity” at OAC 252:100, Appendix J

need not be counted in determining potential to emit.

OAC 252:100-9 (Excess Emission Reporting Requirements) [Applicable]

Except as provided in OAC 252:100-9-7(a)(1), the owner or operator of a source of excess

emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following

working day of the first occurrence of excess emissions in each excess emission event. No later

than thirty (30) calendar days after the start of any excess emission event, the owner or operator

of an air contaminant source from which excess emissions have occurred shall submit a report

for each excess emission event describing the extent of the event and the actions taken by the

owner or operator of the facility in response to this event. Request for affirmative defense, as

described in OAC 252:100-9-8, shall be included in the excess emission event report. Additional

reporting may be required in the case of ongoing emission events and in the case of excess

emissions reporting required by 40 CFR Parts 60, 61, or 63.

OAC 252:100-13 (Open Burning) [Applicable]

Open burning of refuse and other combustible material is prohibited except as authorized in the

specific examples and under the conditions listed in this subchapter.


OAC 252:100-19 (Particulate Matter) [Applicable]

This subchapter specifies a particulate matter (PM) emissions limitation of 0.6 lb/MMBTU from

fuel-burning equipment with a rated heat input of 10 MMBTUH or less. For 4-cycle rich-burn

and lean-burn engines burning natural gas, AP-42 (7/00), lists the total PM emissions as

approximately 0.01 lb/MMBTU. AP-42 (7/98), Chapter 1.4, Table 1.4-1 lists natural gas TPM

emissions to be 7.6 lb/million SCF or about 0.0076 lb/MMBTU which is in compliance with this

subchapter. The permit requires the use of natural gas for all fuel-burning equipment to ensure

compliance with Subchapter 19.

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]

No discharge of greater than 20% opacity is allowed except for short-term occurrences which

consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed

three such periods in any consecutive 24 hours. In no case shall the average of any six-minute

period exceed 60% opacity. When burning natural gas, there is very little possibility of

exceeding the opacity standards.

OAC 252:100-29 (Fugitive Dust) [Applicable]

No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the

property line on which the emissions originate in such a manner as to damage or to interfere with

the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the

maintenance of air quality standards. Under normal operating conditions, this facility will not

cause a problem in this area, therefore it is not necessary to require specific precautions to be

taken.

OAC 252:100-31 (Sulfur Compounds) [Applicable]

Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1,

1972). For gaseous fuels the limit is 0.2 lb/MMBTU heat input averaged over 3 hours. For fuel

gas having a gross calorific value of 1,000 BTU/SCF, this limit corresponds to fuel sulfur content

of 1,203 ppmv. The permit requires the use of gaseous fuel with sulfur content less than 343

ppmv to ensure compliance with Subchapter 31.

OAC 252:100-33 (Nitrogen Oxides) [Not Applicable]

This subchapter limits NOX emissions from new fuel-burning equipment with rated heat input

greater than or equal to 50 MMBTUH. There are no emission units that exceed the 50

MMBTUH threshold.

OAC 252:100-35 (Carbon Monoxide) [Not Applicable]

None of the following affected processes are located at this facility: gray iron cupola, blast

furnace, basic oxygen furnace, petroleum catalytic cracking unit, or petroleum catalytic

reforming unit.

OAC 252:100-37 (Volatile Organic Compounds) [Applicable]

Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons

or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a


permanent submerged fill pipe or with an organic vapor recovery system. The condensate tanks

are subject to this requirement.

Part 3 requires VOC loading facilities with a throughput equal to or less than 40,000 gallons per

day to be equipped with a system for submerged filling of tank trucks or trailers if the capacity of

the vehicle is greater than 200 gallons. This facility does not have the physical equipment (loading

arm and pump) to conduct this type of loading. Therefore, this requirement is not applicable.

Part 5 limits the VOC content of coatings from any coating line or other coating operation. This

facility does not normally conduct coating or painting operations except for routine maintenance

of the facility and equipment, which is exempt.

Part 7 requires fuel-burning and refuse-burning equipment to be operated to minimize emissions

of VOC. Temperature and available air must be sufficient to provide essentially complete

combustion.

Part 7 requires all effluent water separator openings, which receive water containing more than

200 gallons per day of any VOC, to be sealed or the separator to be equipped with an external

floating roof or a fixed roof with an internal floating roof or a vapor recovery system. There are

no effluent water separators located at this facility.

OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Applicable]

This Subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in

areas of concern (AOC). Any work practice, material substitution, or control equipment required

by the Department prior to June 11, 2004, to control a TAC, shall be retained unless a

modification is approved by the Director. Since no AOC has been designated anywhere in the

state, there are no specific requirements for this facility at this time.

OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable]

This subchapter provides general requirements for testing, monitoring and recordkeeping and

applies to any testing, monitoring or recordkeeping activity conducted at any stationary source.

To determine compliance with emissions limitations or standards, the Air Quality Director may

require the owner or operator of any source in the state of Oklahoma to install, maintain and

operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant

source. All required testing must be conducted by methods approved by the Air Quality Director

and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol

shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests.

Emissions and other data required to demonstrate compliance with any federal or state emission

limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and

submitted as required by this subchapter, an applicable rule, or permit requirement. Data from

any required testing or monitoring not conducted in accordance with the provisions of this

subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive

use, of any credible evidence or information relevant to whether a source would have been in

compliance with applicable requirements if the appropriate performance or compliance test or

procedure had been performed.


The following Oklahoma Air Pollution Control Rules are not applicable to this facility:

OAC 252:100-11 Alternative Reduction not eligible

OAC 252:100-15 Mobile Sources not in source category

OAC 252:100-17 Incinerators not type of emission unit

OAC 252:100-23 Cotton Gins not type of emission unit

OAC 252:100-24 Grain Elevators not in source category

OAC 252:100-39 Nonattainment Areas not in a subject area

OAC 252:100-47 Landfills not type of source category

SECTION VI. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not Applicable]

Final total facility emissions are not greater than the PSD major source threshold of 250 TPY for

any regulated pollutant.

NSPS, 40 CFR Part 60 [Not Applicable]

Subparts K, Ka, Kb, VOL Storage Vessels. All tanks are below the de minimis of 19,813-gallons

for Subpart Kb.

Subpart GG, Stationary Gas Turbines. There are no turbines at this facility.

Subpart VV, Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing

Industry. This facility is not a SOCMI plant.

Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. The

facility does not engage in natural gas processing.

Subpart LLL, Onshore Natural Gas Processing: SO2 Emissions. There is no natural gas

sweetening operation at this site.

Subpart IIII, Stationary Compression Ignition Internal Combustion Engines. This subpart affects

stationary compression ignition (CI) internal combustion engines (ICE) based on power and

displacement ratings, depending on date of construction, beginning with those constructed after

July 11, 2005. For the purposes of this subpart, the date that construction commences is the date

the engine is ordered by the owner or operator. There are no stationary compression ignition

internal combustion engines at this facility.

Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion

Engines (SI-ICE). This subpart was published in the Federal Register on January 18, 2008. It

promulgates emission standards for all new SI engines ordered after June 12, 2006 and all SI

engines modified or reconstructed after June 12, 2006, regardless of size. The specific emission

standards (either in g/hp-hr or as a concentration limit) vary based on engine class, engine power

rating, lean-burn or rich-burn, fuel type, duty (emergency or non-emergency), and manufacture

date. Engine manufacturers are required to certify certain engines to meet the emission standards

and may voluntarily certify other engines. An initial notification is required only for owners and

operators of engines greater than 500 HP that are non-certified. Emergency engines will be

required to be equipped with a non-resettable hour meter and are limited to 100 hours per year of

operation excluding use in an emergency (the length of operation and the reason the engine was


in operation must be recorded). The engines in this permit were all manufactured before July 1,

2007 and are not subject to this subpart.

NESHAP, 40 CFR Part 61 [Not Applicable]

There are no emissions of any of the regulated pollutants: arsenic, asbestos, beryllium, benzene,

coke oven emissions, mercury, radionuclides or vinyl chloride except for trace amounts of

benzene. Subpart J, Equipment Leaks of Benzene only affects process streams, which contain

more than 10% benzene by weight. All process streams at this facility are below this threshold.

NESHAP, 40 CFR Part 63 [Subpart HH Applicable]

Subpart HH, Oil and Natural Gas Production Facilities: Area Sources. The final rule for area

sources were promulgated on January 3, 2007. This final rule affects each TEG dehydration unit

located at an area source oil and natural gas production facility that processes, upgrades, or stores

hydrocarbon liquids to the point of custody transfer and natural gas from the well up to and

including the natural gas processing plant. Sources with either an annual average natural gas

flowrate less than 3 MMSCF/D or benzene emissions less than 1.0 TPY are exempt from control

requirements. This facility emits 0.2 TPY of benzene and is only required to keep records of the

annual determination of these criteria as required in 63.774(d)(1).

Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart previously

affected only RICE with a site-rating greater than 500 brake horsepower that are located at a

major source of HAP emissions. On January 18, 2008, the EPA published a final rule that

promulgates standards for new and reconstructed engines (after June 12, 2006) with a site rating

less than or equal to 500 HP located at major sources, and for new and reconstructed engines

(after June 12, 2006) located at area sources. Owners and operators of new or reconstructed

engines at area sources and of new or reconstructed engines with a site rating equal to or less than

500 HP located at a major source (except new or reconstructed 4-stroke lean-burn engines with a

site rating greater than or equal to 250 HP and less than or equal to 500 HP located at a major

source) must meet the requirements of Subpart ZZZZ by complying with either 40 CFR Part 60

Subpart IIII (for CI engines) or 40 CFR Part 60 Subpart JJJJ (for SI engines). Owners and

operators of new or reconstructed 4SLB engines with a site rating greater than or equal to 250 HP

and less than or equal to 500 HP located at a major source are subject to the same MACT

standards previously established for 4SLB engines above 500 HP at a major source, and must

also meet the requirements of 40 CFR Part 60 Subpart JJJJ, except for the emissions standards

for CO. All engines were manufactured before June 12, 2006 and are not subject to this subpart.

Subpart DDDDD, Industrial Boilers and Process Heaters. Subpart DDDDD regulated HAP

emissions from industrial boilers and process heaters. In March, 2007, the EPA filed a motion to

vacate and remand this rule back to the agency. The rule was vacated by court order, subject to

appeal, on June 8, 2007. No appeals were made and the rule was vacated on July 30, 2007.

Existing and new small gaseous fuel boilers and process heaters (less than 10 MMBtu/hr heat

rating) were not subject to any standards, recordkeeping, or notifications under Subpart DDDDD.

EPA is planning on issuing guidance (or a rule) on what actions applicants and permitting

authorities should take regarding MACT determinations under either Section112(g) or Section

112(j) for sources that were affected sources under Subpart DDDDD and other vacated MACTs.

It is expected that the guidance (or rule) will establish a new timeline for submission of section


112(j) applications for vacated MACT standards. At this time, AQD has determined that a

112(j) determination is not needed for sources potentially subject to a vacated MACT, including

Subpart DDDDD. This permit may be reopened to address Section 112(j) when necessary.

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable]

This facility will not process or store more than the threshold quantity of any regulated substance

(Section 112r of the Clean Air Act 1990 Amendments). More information on this federal

program is available on the web page: www.epa.gov/ceppo.

SECTION VII. COMPLIANCE

Inspection

The facility was inspected on September 28, 2007, by Garylee Walz of the Air Quality Division,

accompanied by Jay Faulkner, of Atlas. All equipment at the facility was confirmed to be in

accordance with permit specifications and conditions.

Testing

Engine testing results were provided and are in compliance with the applicable permit limits.

Tier Classification and Public Review

This application has been determined to be a Tier II based on the request for changing a Title V

operating permit to a synthetic minor source operating permit.

The permittee has submitted an affidavit that they are not seeking a permit for land use or for any

operation upon land owned by others without their knowledge. The affidavit certifies that the

applicant possesses a current lease or easement given by the landowner for the purpose or

purposes stated in the application.

The applicant will publish a “Notice of Filling a Tier II Application” and a “Notice of Draft Tier

II Permit” in local newspaper. The draft permit is also available on the DEQ Web site

http://www.deq.state.ok.us/. This facility is located within 50 miles of the Oklahoma-Kansas

border. Kansas will be notified of this draft permit.

Fees Paid

Significant modification to a Title V operating permit fee of $1,000.

Source

Permit

Limitations Test Results

Test Date NOx CO NOx CO

lb/hr lb/hr lb/hr lb/hr

1,680-hp Waukesha L7044GSI w/cc (C-1) 6.67 6.67 3.24 0.42 6/5/09

1,680-hp Waukesha L7044GSI w/cc (C-2) 6.67 6.67 6.60 3.29 5/21/09

1,340-hp Caterpillar G3516LE w/oc (C-3) 4.43 4.43 2.54 0.68 5/21/09

1,340-hp Caterpillar G3516LE w/oc (C-4) 4.43 4.43 2.87 0.30 6/16/09

http://www.epa.gov/ceppo


SECTION VIII. SUMMARY

The facility is as described in the permit application. Ambient air quality standards are not

threatened at this site. There are no active compliance or enforcement issues concerning this

facility. Issuance of the permit is recommended, contingent on EPA and public review.

DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

Atlas Pipeline Mid-Continent WestOK LLC Permit Number 2009-200-O

Wolgamott Compressor Station

The permittee is authorized to operate in conformity with the specifications submitted to Air

Quality on June 25, 2009. The Evaluation Memorandum dated August 3, 2009, explains the

derivation of applicable permit requirements and estimates of emissions; however, it does not

contain operating limitations or permit requirements. Continuing operation under this permit

constitutes acceptance of, and consent to, the conditions contained herein:

1. Points of emissions and emissions limitations for each point: [OAC 252:100-8-6 (a)(1)]

NOX CO VOC

Sources lb/hr TPY lb/hr TPY lb/hr TPY





H-400 Dehydrator Reboiler 0.06 0.27 0.05 0.23 0.01 0.01

H-400 Dehydrator Still Vent --- --- --- --- --- 1.55

Condensate Tanks & Flashing Emissions* --- --- --- --- --- 16.78

Truck Loading --- --- --- --- --- 0.38

Fugitives --- --- --- --- --- 2.23

* includes working, breathing, and flashing losses

2. The fuel-burning equipment shall be fired with pipeline grade natural gas or other gaseous

fuel with a sulfur content less than 343 ppmv. Compliance can be shown by the following

methods: for pipeline grade natural gas, a current gas company bill; for other gaseous fuel, a

current lab analysis, stain-tube analysis, gas contract, tariff sheet, and other approved methods.

Compliance shall be demonstrated at least once annually.

3. The permittee shall be authorized to operate this facility continuously (24 hours per day, every

day of the year).

4. Engines C-1 and C-2 shall be set to operate with an automatic air/fuel ratio controller and with

exhaust gases passing through a properly functioning catalytic converter. Engines C-3 and C-4 shall

be set to operate with an automatic air/fuel ratio controller and with exhaust gases passing through a

properly functioning oxidation catalyst.

SPECIFIC CONDITIONS 2009-200-O DRAFT 2

5. Each engine shall have a permanent identification plate attached, which shows the make,

model number, and serial number.

6. At least once per calendar quarter, the permittee shall conduct tests of NOx and CO

emissions in exhaust gases from each engine/turbine and each replacement engine/turbine when

operating under representative conditions for that period. Testing is required for any engine or

replacement engine, which runs for more than 220 hours during that calendar quarter. Engines

shall be tested no sooner than 20 days after the last test. Testing shall be conducted using a

portable engine analyzer in accordance with a protocol meeting the requirements of the “AQD

Portable Analyzer Guidance” document or an equivalent method approved by Air Quality. When

four consecutive quarterly tests show an engine to be in compliance with the emissions

limitations shown in the permit, then the testing frequency may be reduced to semi-annual

testing. A semi-annual test may be conducted no sooner than 60 calendar days nor later than 180

calendar days after the most recent test. Likewise, when the following two consecutive semi-

annual tests show compliance, the testing frequency may be reduced to annual testing. An annual

test may be conducted no sooner than 120 calendar days nor later than 365 calendar days after the

most recent test. Upon any showing of non-compliance with emissions limitations or testing that

indicate that emissions are within 10% of the emission limitation, the testing frequency shall

revert to quarterly. Reduced engine testing does not apply to engines with catalytic converters

and oxidation catalysts.

7. When periodic compliance testing shows engine exhaust emissions in excess of the lb/hr

limits in Specific Condition Number 1, the permittee shall comply with the provisions of OAC

252:100-9 for excess emissions. Requirements of OAC 252:100-9 include immediate

notification and written notification of Air Quality and demonstrations that the excess emissions

meet the criteria specified in OAC 252:100-9.

8. Replacement (including temporary periods of 6 months or less for maintenance purposes), of

the internal combustion engines with emissions specified in this permit with engines/turbines of

lesser or equal emissions of each pollutant (in lbs/hr and TPY) is authorized under the following

conditions.

a. The permittee shall notify AQD in writing not later than 10 days after the startup of

the replacement engine(s)/turbine(s). Said notice shall identify the equipment

removed and shall include the new engine(s)/turbine(s) make, model, and

horsepower; date of the change, and any change in emissions.

b. Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be

conducted to confirm continued compliance with NOx and CO emissions

limitations. A copy of the first quarter testing shall be provided to AQD within 60

days of start-up of each replacement or additional engine/turbine. The test report

shall include the engine/turbine fuel usage, stack flow (ACFM), stack temperature

(oF), stack height (feet), stack diameter (inches), and pollutant emission rates (g/hp-

hr, lb/hr, and TPY) at maximum rated horsepower for the altitude/location.

c. Replacement of equipment and emissions are limited to equipment and emissions that

are not subject to NSPS, NESHAP, or PSD.


9. The glycol dehydration unit shall be installed and operated as follows:

a. The glycol dehydration unit shall be equipped with a condenser.

b. All emissions from the glycol dehydration unit’s still vent shall be vented through the

condenser. Condenser off gas shall be routed to the reboiler firebox.

c. The natural gas throughput of the glycol dehydration unit shall not exceed 21

MMSCFD (monthly average).

d. The glycol dehydration unit shall be equipped with a flash tank on the rich glycol

stream. All emissions from the glycol dehydration unit’s flash tank shall be

recycled/recompressed into the facility’s inlet stream.

e. The lean glycol recirculation rate shall not exceed 3.5 gallons per minute. The

permittee shall monitor and record the lean glycol circulation rate at least once a

month. When three consecutive months show no exceedance of the limit, the

frequency may be reduced to quarterly. Upon any showing of non-compliance, the

monitoring and recordkeeping frequency shall revert to monthly. With each

inspection the lean glycol circulation rate shall be recorded as follows:

Circulation rate, as found (gal/min, strokes/min) _______

Circulation rate, as left (gal/min, strokes/min) _______

Date of inspection _______

Inspected by _______

The requirement to monitor and record glycol circulation rate shall not apply if the

pump capacity does not exceed 3.5 gpm. If so, the capacity of the pump shall be

shown on the pump, or records of capacity shall be kept on site or at the field office.

f. The permittee shall comply with all applicable requirements of the National Emission

Standards for Hazardous Air Pollutants (NESHAP) for Oil and Natural Gas Production,

Subpart HH, for each affected dehydration unit by the dates specified in 63.760(f).

10. Total condensate throughput shall not exceed 126,000 gallons per year.

11. The permittee shall maintain records of operations as listed below. These records shall be

maintained on-site or at a local field office for at least five years after the date of recording

and shall be provided to regulatory personnel upon request.

a. Periodic emission testing of NOx and CO exhaust from each engine and each

replacement engine.

b. Operating hours for the engines if less than 220 hours per quarter and not tested.

c. For fuel(s) burned, the appropriate document(s) as described in Specific Condition 2.

d. Records as required by 40 CFR Part 63, Subpart HH.

e. Natural gas throughput of the dehydration unit (monthly).

f. Glycol circulation rate (monthly/quarterly) if applicable under Specific Condition No.

9.e.


g. Total condensate throughputs (monthly average and 12-month rolling total).

12. No later than 30 days after the issuance of this synthetic minor operating permit, the

permittee shall submit to Air Quality Division of DEQ, with a copy to the US EPA, Region 6,

a certification of compliance with the terms and conditions of the Part 70 operating permit for

the time period, which has not been covered by any previous certification of compliance and

the issuance date of this permit.

13. This permit supercedes all previous Air Quality permits for this facility, which are now null

and void.

MINOR SOURCE PERMIT TO OPERATE / CONSTRUCT

AIR POLLUTION CONTROL FACILITY

STANDARD CONDITIONS

(September 1, 2005)

A. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma

Department of Environmental Quality (DEQ) in accordance with and under the authority of the

Oklahoma Clean Air Act. The permit does not relieve the holder of the obligation to comply

with other applicable federal, state, or local statutes, regulations, rules, or ordinances. This

specifically includes compliance with the rules of the other Divisions of DEQ: Land Protection

Division and Water Quality Division.

B. A duly issued construction permit or authorization to construct or modify will terminate and

become null and void (unless extended as provided in OAC 252:100-7-15(g)) if the construction

is not commenced within 18 months after the date the permit or authorization was issued, or if

work is suspended for more than 18 months after it is commenced. [OAC 252:100-7-15(f)]

C. The recipient of a construction permit shall apply for a permit to operate (or modified

operating permit) within 60 days following the first day of operation. [OAC 252:100-7-18(a)]

D. Unless specified otherwise, the term of an operating permit shall be unlimited.

E. Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this

facility is required and shall be made in writing by the transferor within 10 days after such date.

A new permit is not required. [OAC 252:100-7-2(f)]

F. The following limitations apply to the facility unless covered in the Specific Conditions:

1. No person shall cause or permit the discharge of emissions such that National Ambient Air

Quality Standards (NAAQS) are exceeded on land outside the permitted facility.

[OAC 252:100-3]

2. All facilities that emit air contaminants are required to file an emission inventory and pay

annual operating fees based on the inventory. Instructions and forms are available on the Air

Quality section of the DEQ web page. www.deq.state.ok.us [OAC 252:100-5]

3. All excess emissions shall be reported to the Director of the Air Quality Division as soon as

practical during normal office hours and no later than the next working day following the

malfunction or release. Within ten (10) business days further notice shall be tendered in

writing containing specific details of the incident. [OAC 252:100-9]

4. Open burning of refuse and other combustible material is prohibited except as authorized in

the specific examples and under the conditions listed in the Open Burning subchapter.

[OAC 252:100-13]

5. No particulate emissions from new fuel-burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 lbs/MMBTU. [OAC 252:100-19]

http://www.deq.state.ok.us/

MINOR SOURCE STANDARD CONDITIONS 2

September 1, 2005

6. No discharge of greater than 20% opacity is allowed except for short-term occurrences which

consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed

three such periods in any consecutive 24 hours. In no case shall the average of any six-

minute period exceed 60% opacity. [OAC 252:100-25]

7. No visible fugitive dust emissions shall be discharged beyond the property line on which the

emissions originate in such a manner as to damage or to interfere with the use of adjacent

properties, or cause air quality standards to be exceeded, or interfere with the maintenance of

air quality standards. [OAC 252:100-29]

8. No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2

lbs/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur

dioxide. [OAC 252:100-31]

9. Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and with a

capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or greater

under actual conditions shall be equipped with a permanent submerged fill pipe or with an

organic material vapor-recovery system. [OAC 252:100-37-15(b)]

10. All fuel-burning equipment shall at all times be properly operated and maintained in a

manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

G. Any owner or operator subject to provisions of NSPS shall provide written notification as

follows: [40 CFR 60.7 (a)]

1. A notification of the date construction (or reconstruction as defined under §60.15) of an

affected facility is commenced postmarked no later than 30 days after such date. This

requirement shall not apply in the case of mass-produced facilities which are purchased in

completed form.

2. A notification of any physical or operational change to an existing facility which may

increase the emission rate of any air pollutant to which a standard applies, unless that

change is specifically exempted under an applicable subpart or in §60.14(e). This notice

shall be postmarked 60 days or as soon as practicable before the change is commenced and

shall include information describing the precise nature of the change, present and proposed

emission control systems, productive capacity of the facility before and after the change, and

the expected completion date of the change. The Administrator may request additional

relevant information subsequent to this notice.

3. A notification of the actual date of initial start-up of an affected facility postmarked within

15 days after such date.

4. If a continuous emission monitoring system is included in the construction, a notification of

the date upon which the test demonstrating the system performance will commence, along

with a pretest plan, postmarked no less than 30 days prior to such a date.

H. Any owner or operator subject to provisions of NSPS shall maintain records of the

occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected

facility or any malfunction of the air pollution control equipment. [40 CFR 60.7 (b)]

I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all

measurements and other information required by this subpart recorded in a permanent file

MINOR SOURCE STANDARD CONDITIONS 3

September 1, 2005

suitable for inspection. This file shall be retained for at least five years following the date of

such measurements, maintenance, and records. [40 CFR 60.7 (d)]

J. Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)

and furnish to AQD a written report of the results of such test(s). Test(s) shall be conducted

within 60 days after achieving the maximum production rate at which the facility will be

operated, but not later than 180 days after initial start-up. [40 CFR 60.8]

PERMIT


STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 2009-200-O

Atlas Pipeline Mid-Continent WestOK LLC,

having complied with the requirements of the law, is hereby granted permission to

operate the Wolgamott Compressor Station facility located in Section 16, Township

29N, Range 16W, Woods County, Oklahoma, subject to standard conditions dated

September 1, 2005, and specific conditions, both attached.

________________________________ _

Permits & Engineering Group Manager, Date

Air Quality Division

DEQ Form #100-885 Revised 10/20/06


Attn: Mr. Bret A. Peterson

Environmental Specialist

110 West 7th

, Suite 2300

Tulsa, OK 74119

SUBJECT: Operating Permit No. 2009-200-O


Location: Section 16, T29N, R16W, Woods County

Dear Mr. Peterson:

Enclosed is the permit authorizing operation of the referenced facility. Please note that this

permit is issued subject to the standards and specific conditions, which are attached. These

conditions must be carefully followed since they define the limits of the permit and will be

confirmed by periodic inspections.

Also note that you are required to annually submit an emissions inventory for this facility. An

emissions inventory must be completed on approved AQD forms and submitted (hardcopy or

electronically) by April 1st of every year. Any questions concerning the form or submittal

process should be referred to the Emissions Inventory Staff at 405-702-4100.

Thank you for your cooperation. If you have any questions, please refer to the permit number

above and contact the permit writer at (405) 702-4215.

Sincerely,

Jian Yue, P.E.

Engineering Section


Enclosure


Attn: Mr. Bret A. Peterson

Environmental Specialist

110 West 7th

, Suite 2300

Tulsa, OK 74119




Dear Mr. Peterson:

Air Quality Division has completed the initial review of your permit application referenced

above. This application has been determined to be a Tier II. In accordance with 27A O.S. § 2-

14-301 & 302 and OAC 252:4-7-13(c) the application and enclosed draft permit are now ready

for public review. The requirements for public review include the following steps which you

must accomplish:

1. Publish at least one legal notice (one day) in at least one newspaper of general

circulation within the county where the facility is located. (Instructions enclosed)

2. Provide for public review (for a period of 30 days following the date of the newspaper

announcement) a copy of this draft permit and a copy of the application at a convenient

location (preferably a public location) within the county of the facility.

3. Send to AQD a copy of the proof of publication notice from Item #1 above together

with any additional comments or requested changes which you may have on the draft

permit.

In addition, you are also required to publish a Notice of Filing Tier II Air Quality Application in

at least one newspaper of general circulation within the county where the facility is located.

(Instruction enclosed) and send to AQD a copy of the proof of publication notice.


above and contact me at (405) 702-4100 or the permit writer, Jian Yue, at (405) 702-4205.

Sincerely,

Phillip Fielder, P.E., Permits and Engineering Group Manager


Enclosures

KDHE, BAR

Forbes Field, Building 283

Topeka, KS 66620




Dear Sir / Madame:

The subject facility has requested an operating permit. Air Quality Division has completed the

initial review of the application and prepared a draft permit for public review. Since this facility

is within 50 miles of the Oklahoma - Kansas border, a copy of the proposed permit will be

provided to you upon request. Information on all permit and a copy of this draft permit are

available for review by the public in the Air Quality Section of DEQ Web Page:

http://www.deq.state.ok.us.


above and contact me or the permit writer at (405) 702-4100.

Sincerely,

Phillip Fielder, P.E., Permits and Engineering Group Manager


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