TECHNICAL REVIEW: AIR PERMIT BY RULE
Permit No.:
94132
Company Name:
Pioneer Natural Resources USA, Inc.
APD Reviewer:
Mr. Raymond D. Lay
Project No.:
161562
Unit Name:
POD 61-17
PBR No(s).:
106.352
GENERAL INFORMATION
Regulated Entity No.:
Customer Reference No.:
Account No.:
RN106039704
CN600130447
None
Project Type:
Date Received by TCEQ:
Date Received by Reviewer:
City/County:
Kenedy, Karnes County
Physical Location:
Permit by Rule Application
November 23, 2010
December 13, 2010 (Electronic copy)
December 15, 2010 (Original)
From the intersection of Hwy 72 & 181 W. of Kenedy go ~2.9 miles SW
on Hwy 72; then 0.3 miles on CR 160; and then 0.8 miles on CR 159.
CONTACT INFORMATION
Responsible Official/ Primary
Contact Name and Title:
Technical Contact/ Consultant
Name and Title:
Mr. James H. Sherrard
Environmental Director
Mr. Tom White
Production Superintendent
GENERAL RULES CHECK
Is confidential information included in the application?
Are there affected NSR or Title V permits for the project?
Phone No.:
Fax No.:
Phone No.:
Fax No.:
YES
NO
X
X
Is each PBR > 25/250 tpy?
Are PBR sitewide emissions > 25/250 tpy?
Are there permit limits on using PBRs at the site?
Is PSD or Nonattainment netting required?
X
X
X
X
Do NSPS, NESHAP, or MACT standards apply to this registration?
Does NOx Cap and Trade apply to this registration?
Is the facility in compliance with all other applicable rules and
regulations?
X
X
X
X
X
X
X
Federal Standard
MACT Subpart HH
MACT Subpart ZZZZ
NSPS Subpart A
NSPS Subpart GG
NSPS Subpart JJJJ
NSPS Subpart K
NSPS Subpart Ka
NSPS Subpart Kb
Name
National Emission Standards for Hazardous Air Pollutants From
Oil and Natural Gas Production Facilities
National Emission Standard for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
General Provisions 60.18
Standards of Performance for Stationary Gas Turbines
Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
Standards of Performance for Storage Vessels for Petroleum
Liquids for Which Construction, Reconstruction, or
Modification Commenced After June 11, 1973, and Prior to
May 19, 1978
Standards of Performance for Storage Vessels for Petroleum
Liquids for Which Construction, Reconstruction, or
Modification Commenced After May 18, 1978, and Prior to July
23, 1984
Standards of Performance for Volatile Organic Liquid Storage
Vessels (Including Petroleum Liquid Storage Vessels) for
Which Construction, Reconstruction, or Modification
Commenced after July 23, 1984
(972) 969-3913
(972) 969-3588
(361) 456-7201
(361) 456-7207
Email:
[email protected]
Email:
[email protected]
COMMENTS
Non-confidential information was submitted.
There are no NSR or Title V Permits associated with the Pioneer Natural
Resources USA, Inc. (PIONEER) POD 61-17 Facility (POD61-17).
Certified Site-Wide Emissions: 14.111 tpy of VOC and 0.2944 tpy of H2S.
See the Estimated Emissions table below.
N/A, there are no permit limits on using PBRs at the POD61-17.
The project has not triggered a PSD review. The POD61-17 is located in
Karnes County, which is classified as an attainment county. The project has
not triggered a nonattainment review.
See the Federal Standard table below.
The POD61-17 is not located in Houston/Galveston area.
PIONEER has demonstrated that the POD61-17 is in compliance under Title
30 Texas Administrative Code (TAC) § 106.352.
PIONEER claims that the site is compliance with all other applicable rules and
regulations.
Chapter 111: There is no flare at the POD61-17. Other stationary vents will
not have visible emissions.
Chapter 112: H2S will not be significant from this sour gas site. No screen
modeling was requested.
Chapter 115: Karnes County is an attainment county.
Chapter 117: Karnes County is an attainment county.
Applicability
N/A. No glycol dehydration unit at the POD61-17.
N/A.
N/A. No flares present at the POD61-17.
N/A. No turbines present at the POD61-17.
N/A.
Does not apply. Tank is <40,000 gallons and was constructed after May 19,
1978.
Does not apply. Tank is <40,000 gallons and was constructed after July 23,
1984.
Does not apply. Tank is <19,800 gallons.
DESCRIBE OVERALL PROCESS AT THE SITE
The POD61-17 is primarily a natural gas, condensate, and produced water production facility. The inlet production streams flow through high pressure separation equipment,
which separates the high pressure gas, condensate, and produced water streams. The separated high pressure gas and condensate streams flow offsite through pipelines to
another facility.
The separated high pressure produced water streams decrease pressure as they flow into the low pressure separator. The gas stream from the low pressure separator vents to
1
TECHNICAL REVIEW: AIR PERMIT BY RULE
Permit No.:
94132
Company Name:
Pioneer Natural Resources USA, Inc.
APD Reviewer:
Mr. Raymond D. Lay
Project No.:
161562
Unit Name:
POD 61-17
PBR No(s).:
106.352
atmosphere. The skim oil stream from the low pressure separator flows into the skim oil tank, from where the associated vapors vent to atmosphere and skim oil is
periodically loaded into transport trucks and removed from the site. The produced water stream from the low pressure separator flows into one or more of the produced water
tanks, from where the associated vapors vent to atmosphere and produced water is periodically loaded into transport trucks and removed from the site. A blowdown tank
exists to accumulate the expected negligible or very small volumes of condensed liquids associated with various equipment blowdown streams; where the separated skim oil
combines with the trucked skim oil and the separated produced water combines with the trucked produced water.
The expected maximum POD61-17 production rates are listed below.
High pressure gas stream rate: 15 million standard cubic feet per day (MMscfd)
High pressure condensate rate: 3,000,000 barrels per year (BPY)
Skim oil rate: 2,137 BPY
Produced water rate: 988,136 BPY
DESCRIBE PROJECT AND INVOLVED PROCESS
PIONEER has certified the emissions associated with the overall operation of the process equipment at the POD61-17 Facility under Title 30 Texas Administrative Code §
106.352.
The POD61-17 will consist of the following air pollutant emission sources:

One low pressure separator vent (Emission Point No. [EPN] EPN LPSEP);

One skim oil tank (EPN: SOTK);

Up to 3 produced water tanks (EPNS PWTK1 through PWTK3);

One blowdown tank (EPN BDTK);

Skim oil truck loading facilities (EPN LOAD1);

Produced water truck loading facilities (EPN LOAD2); and

Facility fugitive emission components (EPN FUG).
Planned MSS emissions for 12 blowdowns events per year from associated piping/vessels have been reviewed. These authorized MSS emissions are included on the
emissions table.
TECHNICAL SUMMARY - DESCRIBE HOW THE PROJECT MEETS THE RULES
Low Pressure Separator Vent
The separated high pressure produced water streams decrease pressure as they flow into the low pressure separator, from where the separated gas stream vents to atmosphere.
Pioneer used the BR&E process simulation to estimate the maximum expected low pressure separator vent stream composition and rate. In accordance with the 30 TAC
Chapter 101 definition of volatile organic compound (VOC), the calculated mass rates of the propane and heavier hydrocarbon components are summed to determine the
estimated total VOC mass emission rates. The process simulation estimated vent stream hydrogen sulfide (H 2S) content and rate were used to estimate the H2S mass
emission rates.
Skim Oil Tank
Since there is a pressure drop from the low pressure separator to the atmospheric skim oil tank, there will be flash, along with the normal working and breathing loss,
emissions from the tank. Pioneer used the BR&E process simulation to estimate the maximum expected skim oil tank flash vapor stream composition and rate. In
accordance with the 30 TAC Chapter 101 definition of VOC, the calculated mass rates of the propane and heavier hydrocarbon components are summed to determine the
estimated flash vapor total VOC mass emission rates from the tank. The process simulation estimated flash vapor stream H2S content and rate were used to estimate the
flash vapor H2S mass emission rates from the tank.
Pioneer used the BR&E process simulation to estimate the skim oil composition. Since the Environmental Protection Agency (EPA) TANKS 4.0.9d computer program does
not accept the input of components with operating temperature vapor pressures greater than atmospheric pressure, the BR&E estimated percentages of these components
were combined with the BR&E estimated percentages of iso-pentane and normal pentane to determine the skim oil composition to use with the EPA TANKS program. The
estimated skim oil composition, the maximum expected skim oil volume, the currently expected tank attributes, and the EPA TANKS program were used to estimate the
potential working and breathing loss VOC emissions from the tank.
The BR&E process simulation estimated flash VOC emissions were added to the EPA TANKS program estimated working and breathing loss VOC emissions for the
estimated total VOC emissions from the tank. The BR&E process simulation estimated flash H2S emissions were doubled for the estimated total H2S emissions from the
tank, in case there are any working & breathing loss H2S emissions from the tank.
Produced Water Tanks
This registration represents that there may be up to three produced water tanks at this site. Accordingly, the total estimated produced water rate is divided by three for the
produced water rate through each produced water tank. The discussion below is for each produced water tank.
Each Produced Water Tank
Since there is a pressure drop from the low pressure separator to the atmospheric produced water tank, there will be flash, along with the normal working and breathing loss,
emissions from the tank. Pioneer used the BR&E process simulation to estimate the maximum expected produced water tank flash vapor stream composition and rate. In
accordance with the 30 TAC Chapter 101 definition of VOC, the calculated mass rates of the propane and heavier hydrocarbon components are summed to determine the
estimated flash vapor total VOC mass emission rates from the tank. The process simulation estimated flash vapor stream H 2S content and rate were used to estimate the flash
vapor H2S mass emission rates from the tank.
Since the BR&E process simulation estimated essentially no hydrocarbon in the produced water, Pioneer assumed that up to one (1) volume percent (vol%) of the produced
water is skim oil. The estimated produced water composition, the maximum expected produced water volume, the currently expected tank attributes, and the EPA TANKS
program were used to estimate the potential working and breathing loss VOC emissions from the tank.
2
TECHNICAL REVIEW: AIR PERMIT BY RULE
Permit No.:
94132
Company Name:
Pioneer Natural Resources USA, Inc.
APD Reviewer:
Mr. Raymond D. Lay
Project No.:
161562
Unit Name:
POD 61-17
PBR No(s).:
106.352
The BR&E process simulation estimated flash VOC emissions were added to the EPA TANKS program estimated working and breathing loss VOC emissions for the
estimated total VOC emissions from the tank. The BR&E process simulation estimated flash H 2S emissions were doubled for the estimated total H2S emissions from the
tank, in case there are any working & breathing loss H2S emissions from the tank.
Blowdown Tank
Based on the combined volume of the associated piping/vessels and the average operating pressure, the maximum expected volume per maintenance/startup/shutdown (MSS)
blowdown event is determined. There should be no more than one full MSS blowdown event per hour and no more than 12 full MSS blowdown events per year. The
potential hourly and annual MSS vent gas rates are used with a representative gas analysis to determine the speciated mass H2S and VOC emission rates to the atmosphere
from the MSS vents. In accordance with the 30 TAC Chapter 101 definition of "VOC", the mass rates of the propane and heavier hydrocarbon components are summed to
determine the estimated total VOC emission rates.
Truck Loading Facilities
For Each of the Skim Oil and Produced Water Truck Loading Facilities
The uncontrolled truck loading emission rates are estimated using the EP A AP-42 Chapter 5.2.2.1.1 liquid loading equation of (L) = [(12.46) x (S) x (P) x (M)] ÷ (T) and
associated EP A guidance, as well as the TCEQ October 2000 draft document titled "Air Permit Technical Guidance for Chemical Sources: Loading Operations", where:
1.
"L" is the pounds of emissions per 1,000 gallons of liquid loaded;
2.
"S" is the saturation factor - a saturation factor of 0.60 is used since the trucks are generally dedicated service trucks with submerged liquid loading lines;
3.
"P" is the loaded liquid vapor pressure in psia units - the liquid maximum and average vapor pressures from the liquid EPA TANKS program calculation are
respectively used for the hourly and annual loading calculations;
4.
"M" is the molecular weight of the vapors in pounds per pound mole (lbs/lb mole) units - this value is obtained from the liquid EPA TANKS program calculation;
and
5.
"T" is the loaded liquid temperature in degrees Rankine (OR) units - the liquid maximum and average liquid temperatures from the liquid EPA TANKS program
calculation are respectively used for the hourly and annual loading calculations.
The uncontrolled "L" value is multiplied by the estimated maximum number of thousands of gallons of liquid loaded per hour and year to determine the uncontrolled hourly
and annual total emission rates. The vapor weight percents (wt%s) from the liquid EPA TANKS program calculation are multiplied by the total emission rates to determine
the speciated hourly and annual emission rates. In accordance with the 30 TAC Chapter 101 definition of VOC, the calculated mass rates of the propane and heavier
hydrocarbon components are summed to determine the estimated total VOC hourly and annual emission rates. The potential H2S emissions from the truck loading activities
are estimated using the ratio of the determined H2S to total VOC emissions from the associated liquid tank multiplied by the potential total VOC emissions from the truck
loading activities.
Facilities Fugitive Emissions
The utilized fugitive emissions estimation methodologies follow those advocated by the October 2000 draft TCEQ guidance document titled "Air Permit Technical Guidance
for Chemical Sources: Equipment Leak Fugitives". The gas, skim oil, and produced water compositions that are based on the BR&E process simulation, estimated associated
fugitive emission components counts, and the American Petroleum Institute (API) oil and gas production facility empirical fugitive emission factors are used to estimate the
potential fugitive VOC and H2S emissions from the POD61-17. Per instructions from the TCEQ, the estimated hydrocarbon (only) compositions of the liquid stream types
are used with the pertinent API liquid stream type fugitive emission factors to estimate the speciated hydrocarbon fugitive emissions for each liquid stream type. The
estimated propane and heavier hydrocarbon fugitive component emissions are summed for the estimated total VOC fugitive emissions for each stream type. The estimated
total VOC, speciated VOC, and H2S fugitive emissions for each stream type are summed for the estimated fugitive emissions of the same from the POD61-17.
OIL AND GAS FACILITY GENERAL INFORMATION
Natural Gas Throughput (MMSCF/day):
High Pressure Condensate Throughput (bbl/day):
Skim Oil (bbl/day):
Produced Water Throughput (bbl/day):
PI-7 or PI-7 CERT?
15
8,219.1781
5.8548
H2S Content of Inlet Gas:
100
Is the gas sweet or sour?
Sour
Is this site operational/producing?
2,707.222
Has the site been registered before?
Under construction.
No.
PI-7-CERT
EQUIPMENT/PROCESSES AT SITE
Number of each:
Separators:
1
Storage Tanks:
5
30 TAC §106.352 RULE CHECK
REQUIREMENTS
If the site conditions the natural gas (with a glycol dehydrator, amine unit, sulfur recovery unit, etc.),
it handles less than two long tons per day of sulfur compounds (1 long ton = 2240 pounds).
(1) All compressors will meet the requirements of 106.512.
Truck Loading:
YES, NO,
or n/a
N/A
2
OTHER / COMMENTS
N/A
The POD61-17 does not have any gas conditioning
equipment.
There are no engines at the POD61-17.
(1) All flares will meet the requirements of 106.492.
N/A
There are no flares at the POD61-17.
(2) Total emissions, including process fugitives, combustion unit stacks, separator, or other process
vents, tank vents, and loading emissions from all such facilities constructed at a site under this
section, will be equal to or below 25 tons per year (tpy) each of sulfur dioxide (SO2), all other sulfur
YES
Certified Site-Wide Emissions: 14.111 tpy of VOC
and 0.2944 tpy of H2S.
3
TECHNICAL REVIEW: AIR PERMIT BY RULE
Permit No.:
94132
Company Name:
Pioneer Natural Resources USA, Inc.
APD Reviewer:
Mr. Raymond D. Lay
Project No.:
161562
Unit Name:
POD 61-17
PBR No(s).:
106.352
compounds combined, or all volatile organic compounds (VOC) combined; and 250 tpy each of
nitrogen oxide and carbon monoxide.
Emissions of VOC and sulfur compounds other than SO2 must include gas lost by equilibrium flash
as well as gas lost by conventional evaporation.
(3) If the facility handles sour gas, it will be located at least ¼-mile from any recreational area or
residence or other structure not occupied or used solely by the owner or operator of the facility or the
owner of the property upon which the facility is located.
(4) Total emissions of sulfur compounds, excluding sulfur oxides, from all vents will be equal to or
below 4.0 pounds per hour (lb/hr).
(4) The height of each vent emitting sulfur compounds meets the following requirements, and is in no
case less than 20 feet.
(5) If the site handles sour gas, the company will register the site by submitting Form PI-7 or PI-7CERT before operations begin.
ESTIMATED EMISSIONS
EPN / Emission Source
LPSEP / Low Pressure Separator Vent
SOTK / Skim Oil Tank Flash, Working, &
Breathing
PWTK1 / Produced Water Tank 1 Flash,
Working, & Breathing
PWTK2 / Produced Water Tank 2 Flash,
Working, & Breathing
PWTK3 / Produced Water Tank 3 Flash,
Working, & Breathing
BDTK / Blowdown Tank MSS Emissions
LOAD1 / Skim Oil Truck Loading
LOAD2 / Produced Water Truck Loading
FUG / Facilities Fugitive Emissions
TOTAL EMISSIONS (TPY):
MAXIMUM OPERATING SCHEDULE:
SITE REVIEW / DISTANCE LIMIT
Site Review Required?
PBR Distance Limits Met?
Yes
X
VOC
NOx
lbs/hr
tpy lbs/hr tpy
2.0607 9.0257
0.1346 0.5894
CO
lbs/hr tpy
YES
Distance = >1,320 feet.
YES
Actual Sulfur Emissions = 0.1244 lb/hr.
YES
Actual Vent Height = At least 20 feet.
YES
PI-7-CERT
PM10
lbs/hr tpy
H2S
SO2
lbs/hr tpy lbs/hr tpy
0.0414 0.1815
0.0005 0.0024
0.0324 0.1417
0.0054 0.0236
0.0324 0.1417
0.0054 0.0236
0.0324 0.1417
0.0054 0.0236
86.0124
9.6239
0.2164
0.7501
0.0663
0.0385
0.0360
0.0005
0.5161
0.0474
0.2220
3.2853
14.111
Hours/Day
No
X
24
Days/Week
7
Description/Outcome
>10 feet to the nearest property line and >1,320 feet
to the nearest off-property structure.
TECHNICAL REVIEWER
PEER REVIEWER
Other
lbs/hr tpy
0.0004
0.0002
0.0370
0.0021
0.2944
52
Weeks/Year
Date
January 13, 2011
January 13, 2011
8,760
Hours/Year
Reviewed by
Mr. Raymond D. Lay
Mr. Raymond D. Lay
FINAL REVIEWER
SIGNATURE:
See Hard Copy.
PRINTED NAME:
DATE:
Mr. Raymond D. Lay
Mr. Howard T. Uhal
Ms. Anne M. Inman, P.E., Manager
January 13, 2011
01/13/2011
January 13, 2011
BASIS OF PROJECT POINTS
Base Points: 106.352
Project Complexity Description and Points:
Extra EPN
Extra tables
Technical Reviewer Project Points Assessment:
Final Reviewer Project Points Confirmation:
4
POINTS
2.00
0.25
0.50
2.75