COMMONWEALTil OF PENNSYLVANIAOep:lrlment of Environmental ProtectionSouthwest Regional Office

MEMO

TO

FROM

THROUGH

Air Quality Pemlit File PA-26-00588A

Alan A. Binder at\-15Air Quality Engineering SpecialistAir QU:llity Program

Mark R. Gorog, P.E. 11141:z.-­EnvironmcllIal Engineer ManagerAir Qunlity Program

M~~EProgrmn ManagerAir Quality Program

DATE

RE

September 27. 2012 (Revised October 4. 2012)

Review of Plan Approval ApplicationNaluml Gas Production FacilityLaurel Mountain Midstream. LLCShamrock Compressor St:uionGcnllan Township, Fayette COUIlIYAPS # 765203, Auth # 902871, PF # 731038

BACKGROUND

Laurel Mountain Midstream, LLC ("LMM") has submitted a plan approval application onNovember 2, 2011, to install and begin temporary operation of one new natural gas-Ii redcompressor turbine, mUlIt"al gas-fired emergency gcncrator, dchydrator with rcboiler, andproduccd water tank ,11 its Shamrock Comprcssor Station ("Shamrock") located in GcrmanTownship, Fayettc COllllty. Natural gas is currently drawn from ncarby wells, dewntered,compressed. and discharged downstrcam dircctly 10 a natural gas lransmission pipeline. This sitcis locntcd in a mral area offofNew Salcm Rd. approximately haifa mile south casl oflhc townof New Salelll. LMM proposes 10 inslallthc following sources and controls under PA-26­00588A authorization at this site:

• One (I) Solar, Model No. Titan 130~20502S, naturnl gas-fired turbinc, 19,553 1-1 P.• Onc (I) Caterpillar, Model G3516B. lean bum natural gas-fired emergency generator.

I. 18 bhp@ 1.800 rpm; controlled by an EMIT Technologies (or equivalent), Model No.ELX-4200Z-1616F-43CEE-24, oxidation catalyst; regnlated by an ADEM III (orequivalent) automatic air/fuel ratio controller.

• One (I) Trycr Process Equipment (or equivalent), Iri-ethylene glycol (TEG) dehydrator.200 MMscflday; still vent and nash tank emission capture and combustion as rcboilerfuel.

• One (I) natural gas-fired andlor dehydralor venl gas-fired rcboiler, 1.71 MMBlulhr.

• One (1) produced water tank:, 476 bbl capacity; uncontrolled.

LMM proposes the following additional changes under PA-26-00588A authorization at this site:

• A combined operational hours restriction of39,600 hours per year (previouslyunrestricted) on six (6) existing Caterpillar, Model No. G3516B, natural gas-firedcompressor engines, 1,380 bhp @ 1,400 rpm; controlled by EMIT Technologies, ModelNo. EAX·3050Z-1616F-20CEE, oxidation catalysts; regulated by an ADEM III (orequivalent) automatic air/fuel ratio controllers.

• A decreased site rating of t5,252 HP (previously 16,847 HP) on one (I) existing Solar,Model No. Mars IOO-16000S, natural gas-fired turbine.

• An operational change to one (I) existing TEG dehydrator, 200 MMscflday, to capturestill vent and flash tank emissions for use as reboiler combustion fuel.

• An increased site rating of 1.71 MMBtulhr (previously 1.6 MMBtulhr) and fuel change toinclude captured dehydrator vent gas on one (I) existing rehoiler.

• A tank: content clarification on one (I) existing storage tank, 476 bbl capacity, to identifyit as a produced water tank (previously identified as condensate).

On June 28, 2010, a general permit (GP5-26-00588) authorization was granted to LMM to allowinstallation and operation of three Caterpillar G35 I6LE compressor engines, one TEGdehydrator, and one storage tank. The G3516LE engines are lean burn natural gas-fired engineswith a NOx emission rate not to exceed 1.5 glbhp-hr. These engines were never installed at thisfacility prior to LMM obtaining authorization to install and operate lower emitting compressorengmes.

On September 7, 2010, a general permit (GP5-26-00588A) authorization was granted to LMM toanow installation and operation of three Caterpillar G3516B compressor engines, one TEGdehydrator, and one storage tank at the facility. The G3516B engines are "ultra" lean bumnatural gas-fired engines with a NOx emission rate not to exceed 0.5 g1bhp~hr. A total of threecompressor engines, one dehydrator, and one storage tank were authorized at the facility at thattime.

On December 9,2010, LMM initiated construction ofa second set of three Caterpillar G3516Bcompressor engines at Shamrock prior to receiving approval for construction from theDepartment. This was in violation of25 Pa. Code 127.11. A plan approval application (PA-26­00588) including these air contamination sources had been received by the Department onAugust 25, 2010, and was undergoing technical review at that time. One February 25,2011,(two days after discovery by site inspection) the Department issued an Administrative Order toLMM requiring the cessation orall construction activities for the unauthorized compressorengines. LMM complied with the Order and subsequently entered into a Consent Assessment ofCivil Penalty ("CACP') with the Department on January 20,2012. A civil penalty of$7,OOOwas assessed to LMM for the violation, and it was settled on the same day LMM entered into theCACP.

On March 21,2011, a plan approval (PA-26-00588) was issued to LMM to allow installation andtemporary operation ofsix Caterpillar G3516B compressor engines, one Solar Mars compressor

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T bl 4 PSD A r bTl Ttl P . t E •. Ia e : .ppllca IIIY- oa rOjtC miSSion ncreases

NO/ CO voe PM PM 10 PM2.S SOl Ph FI H2SO4 COleNew emissions units PTE (tpy)

Solar Titan 130 Turbine 36.11 36.64 4.20 14.80 14.80 9.80 2.49 - · - 79,121Solar Titan 130 Turbine - 0.74 - - - - - - - 1,096Compressor Sealsb .Caterpillar G35168 EmeTgency 0.59 0.18 0.35 0.04 0.04 0.04 0.002 - · - 525GeneratorTitan 130 Turbine & G3516 O.ll 10.0 0.48 - - - - · - - 564Emergency Generator SSMReboiler #2c 0.90 0.54 0.04 0.06 0.06 0.06 . - - . 974Produced Water Tank #2 . - 0.24 - - - - · · - -Component Fugitive Emissions - - 1.07 - - - - - - - 561Total: New Emissions Units 37.71 47.36 7.12 14.90 14.90 9.90 2.49 - - - 82,841

Significant emission increase determination (tpy)

Total Emission Increases 37.71 47.36 7.12 14.90" 14.90" 9.90" 2.49 · - - 82,841Significant Emission PSD 40 100 40 25 15 10 40 0.6 3 7 75,000Increase Threshold

11 For purposes of this applicability analysis, all NO~ emissions arc assumed to be N02•

b The applicant originally included all turbine compressor seals in the application; however, consistent with the rest ofthe application, only the Titan 130 seals have been included here.

t Dehydrator PTE is estimated to be negligible because vapors are captured and routed to the reboiler as fuel.

d See PMu/PMz.s discussion on page 27.

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Table 12: Previously Authorized Sources (PA-26-00S88) PTE in Tons Per Yea'"

Air ContaminationNO" CO PM,o/PM2.S SOx VOCb HCHO HAP C02eSource

Caterpillar 03516B #1 5.02 1.71 0.38 0.02 1.91 0.90 1.05 5,593Caterpillar 03516B #2 5.02 1.71 0.38 0.02 1.91 0.90 1.05 5,593Caterpillar G3516B #3 5.02 1.71 0.38 0.02 1.91 0.90 1.05 5,593Caterpillar G3516B #4 5.02 1.71 0.38 0.02 1.91 0.90 1.05 5,593Caterpillar G3516B #5 5.02 1.71 0.38 0.02 1.91 0.90 1.05 5,593Caterpillar G3516B #6 5.02 1.71 0.38 0.02 1.91 0.90 1.05 5,593

Mars 100-1600081: 29.70 30.13 3.97 2.05 3.45 0.86 1.05 65,023Compressor Seals 1.58 0.53 2.335

Reboiler #1 0.90 0.54 0.06 - 0.04 - 0.01 974SSMd 0.08 7.09 - - 2.09 - 0.71 2,984

Component Leaksc - . - - ... - ... ...Prod Water Tank #1 - - - - 0.24 - 0.06 -

Truck LoadingC - - . - ... - ... .Total 60.8 48.02 6.31 2.17 18.86 6.26 8.66 104,874

II Accounts for engine hours limitation and lower Mars turbine rating.b Includes fonnaldehyde emissions.C Includes normal operntion and startup/shutdown emissions from the turbine.d Includes SSM from only the MaTS 100 turbine and each engine compressor.e Already accounted for in Table 11 above. It makes no practical difference to separate these emissions into newand

existing categories.

Table 13: Facility-Wide Potential to Emit

Air Contaminant3 Emission RateD(tpy)

NOx 98.51eo 95.35

PM/PM,o 21.21PM2.5 16.21SOx 4.67voe 26.38

Fonna1dehyde 7.42HW 10.76C02e 187,820

aTotal HAP Includes slIghtly more than 1.1 tpy ofunknown HAP estimated from fugitive emissions and a mixtureofacetaldehyde, acrolein, methanol, and n·Hexane from the internal combustion engines. Formaldehyde is theprimary HAP ofconcern al this facility and is listed separately as well as included in lhe total.

b Values may be slightly inconsistent out to the second decimal due to rounding

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