Statement of Basis
Freebird Gas Storage, LLC
East Detroit Storage Facility
Lamar County
Facility/Permit No. 408-0009
This draft Major Source Operating Permit (MSOP) is issued under the provisions of ADEM
Admin. Code r. 335-3-16. The above named applicant has requested authorization to perform
the work or operate the facility shown on the application and drawing, plans, and other
documents attached hereto or on file with the Air Division of the Alabama Department of
Environmental Management, in accordance with the terms and conditions of this permit. This is
the first renewal of the Major Source Operating Permit (MSOP) for this facility. The current
MSOP was originally issued on February 1, 2010, and expired on January 31, 2015. The current
MSOP has undergone two modifications since the initial issuance. One modification, which was
effective on November 19, 2013, added a 468 hp Generac natural gas-fired emergency generator
as Emission Unit 010. In addition, on July 23, 2015, it was confirmed that Freebird removed
Emission Unit No. 008, a 0.5 MMBtu/hr BS&B, Inc. natural gas-fired glycol dehydrator/heater.
The addition of the emergency generator and the removal of the dehydrator/heater are being
incorporated into this MSOP renewal.
Freebird Gas Storage, L.L.C. (Freebird) is a depleted reservoir natural gas storage facility which
operates compressor engines to move gas from the reservoir, process the gas to remove entrained
water, and reintroduce the gas into the natural gas transmission pipeline. The significant sources
of air pollutants at this facility are three (3) 1,340 hp Caterpillar G3516, 4-stroke, lean-burn
(4SLB) natural gas-fired reciprocating engines (RICE) (Emission Unit Nos. 001 - 003); three (3)
2,370 hp Caterpillar G3608 4SLB, natural gas-fired RICE with oxidation catalysts (Emission
Unit Nos. 004 - 006); one 468 hp Generac 13.3 GTA 4-stroke, rich-burn (4SRB) natural gasfired RICE equipped with a non-selective catalytic reduction unit (NSCR) operating as an
emergency generator (Emission Unit No. 010); and one ETI dehydrator/heater equipped with a
condenser/thermal oxidizer (Emission Unit No. 009). Insignificant emission sources at this
station include four lube oil storage tanks (<1,000 gallons each), one glycol storage tank (<1,000
gallons), one used oil storage tank (<1,000 gallons), one coolant storage tank (<1,000 gallons),
one crankcase oil storage tank (1,000 gallons), and one process liquid “slop” tank (<1,000
gallons).
Applicability: Federal Regulations
Title V
This facility is a major source under Title V regulations because the potential emissions for
nitrogen oxides (NO X ) exceed the 100 TPY major source threshold. It is also a major source of
Hazardous Air Pollutants (HAP) because individual HAP potential emissions are greater than 10
TPY (17.65 TPY for Formaldehyde) and the total HAP potential emissions are greater than 25
TPY (26.38 TPY).
Prevention of Significant Deterioration (PSD)
This facility is located in an attainment area for all criteria pollutants and the facility operations
are not one of the listed major source categories. Therefore, the applicable major source
threshold is 250 TPY. It is not a major source for PSD because the facility-wide potential
emissions of criteria pollutants do not exceed 250 TPY.
NSPS
40 CFR Part 60, Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
The reciprocating engines (Emission Unit Nos. 001 – 006) are not subject to 40 CFR Part 60,
Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion
Engines (ICE) based on the date that these engines were manufactured.
Emission Unit No. 010 is subject to Subpart JJJJ because the unit was ordered on April 2011,
and was manufactured in August 2011, after the applicability date for this subpart. The
applicable requirements are:
Emission Limitations
In accordance with 40 CFR §60.4233(e), the emergency engine must meet a NOx emission
standard of 2.0 g/hp-hr (or 160 ppmvd at 15% O 2 ), a CO emission standard of 4.0 g/hp-hr (or
540 ppmvd at 15% O 2 ), and a VOC emission standard of 1.0 g/hp-hr (or 86 ppmvd at 15% O 2 ).
According to 40 CFR §60.4234, Freebird must operate and maintain the emergency engine in a
manner that meets these emission standards over the entire life of the engine.
Compliance Requirements
40 CFR §60.4243(d) requires the emergency generator to be operated according to the
requirements in 40 CFR §60.4243(d)(1) through (3). To be considered an emergency stationary
ICE, any operation other than emergency operation, maintenance and testing, emergency demand
response, and operation in non-emergency situations (not to exceed 50 hours per year), is
prohibited. If the engine is not operated according to the requirements in 40 CFR §60.4243(d)(1)
through (3), the engine will not be considered an emergency engine and must meet all
requirements for non-emergency engines. The emergency generator, Emission Unit No. 10, is
equipped with a NSCR unit. 40 CFR §60.4243(g) requires 4SRB engines using NSCR to
operate the air-to-fuel controller appropriately in order to ensure proper operation of the engine
and control device to minimize emissions at all times. 40 CFR §60.4237(a) requires the
installation of a non-resettable hour meter on the emergency engine because it does not meet the
standards applicable to non-emergency engines of the same size and model year. Emission Unit
No. 010 is a certified engine. 40 CFR §60.4243(b)(1) requires certified engines to be operated
according to the manufacturer’s emission related written instructions and records of all
maintenance must be maintained along with documentation from the manufacturer that the
engine is certified to demonstrate compliance with the emission standard.
Testing Requirements
Page 2 of 9
Since the emergency engine is a certified engine, it would not have to undergo an initial
compliance test or subsequent tests as long as Freebird operates the engine and the control device
according to the manufacturer’s emission-related written instructions. However, if Freebird does
not operate and maintain the engine and the control device according to the manufacturer’s
emission-related written instructions, then Freebird would have to demonstrate compliance by
performing an initial performance test.
Notification, Reports, and Records
40 CFR §60.4245(a) requires that owners and operators of all stationary SI ICE that are subject
to Subpart JJJJ keep records of: (1) all notifications submitted along with supporting
documentation, (2) all maintenance conducted on the engine, and (3) documentation from the
manufacturer that the engine is certified to meet the emission standards. In addition, 40 CFR
§60.4245(b) requires that Freebird keep records of the hours of operation for the emergency
engine that are recorded through the non-resettable hour meter. All records required under this
Subpart must be retained for at least five years from the date of generation and made available
for inspection upon request.
MACT
40 CFR Part 63, Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines (RICE MACT)
Emission Unit Nos. 001 – 003 are considered existing affected sources under the RICE MACT.
Since these engines were constructed prior to the major source applicability dates and they are
four-stroke lean-burn engines (4SLB), these engines do not have any applicable requirements
under this rule.
Emission Unit Nos. 004 – 006 are considered new affected sources under the RICE MACT. The
applicable requirements are:
1. Emission Limitation
The applicable emission limitations are found in Table 2a to Subpart ZZZZ. New 4SLB
engines are required to either reduce CO emissions by 93% or more or limit the
formaldehyde exhaust concentration to 14 ppmvd or less at 15% O 2 . The standard must be
achieved at 100 % load (± 10%). Freebird has chosen to demonstrate compliance by
reducing the CO emissions by utilizing an oxidation catalyst for each of these engines
instead of limiting the formaldehyde exhaust concentration.
2. Operating Limitations
The applicable operating limitations are found in Table 2b to Subpart ZZZZ. Since
Freebird utilizes an oxidation catalyst to comply with the standard, the catalyst must be
maintained such that the pressure drop across the catalyst does not change by more than 2
inches of water at 100% load (± 10%) from the pressure drop that was measured during the
initial performance test. In addition, the temperature of the engines’ exhaust must be
maintained such that the catalyst inlet temperature is > 450 oF and < 1350 oF.
Page 3 of 9
3. Performance Testing
Performance testing requirements are outlined in Table 4 to Subpart ZZZZ. Freebird is
required to test CO emissions to determine if the required 93% reduction emission
limitation is being achieved. To comply with the RICE MACT, an initial performance test
was required within 180 days of startup of each engine. Freebird conducted the initial
compliance test and demonstrated compliance for these units on August 22 and 23, 2007.
Freebird is also required to perform subsequent semiannual performance tests to
demonstrate compliance with the CO emission limitation. Since Freebird has demonstrated
compliance for two consecutive semiannual performance tests, the frequency of subsequent
performance tests has been reduced to annually. However, if performance tests in the
future indicate that an engine is not in compliance with the CO emission limitation, or the
engine has deviated from any operational limitation, Freebird must resume semiannual
performance testing.
4. Continuous Compliance
Freebird has proposed to meet the CO reduction requirements and implement a continuous
parameter monitoring system (CPMS). In accordance with Table 6 to Subpart ZZZZ,
Freebird is required to collect catalyst inlet temperature data (record a reading every 15
minutes) in accordance with the monitoring requirements of 40 CFR §63.6625(b) and
reduce the data to 4-hour rolling averages. In addition, Freebird is required to measure the
pressure drop across the catalyst once per month.
5. Notifications
Freebird is required to submit a Notification of Intent at least 60 days prior to conducting
each performance test. Following each test, Freebird is required to submit a Notification of
Compliance Status, including the performance test results, within 60 days of completing
each performance test.
6. Reports
The reporting requirements are outlined in Table 7 to Subpart ZZZZ. Freebird is required
to submit a semiannual compliance report based on calendar year periods January – June
and July – December. Once the MSOP is issued, Freebird would submit the semiannual
compliance report as part of their Semiannual Monitoring Report as required by General
Permit Proviso No. 21. The compliance report must contain the information outlined in 40
CFR §63.6650(c) and (e). An immediate startup, shutdown, and malfunction (SSM) report
must also be submitted when actions addressing a startup, shutdown, and malfunction are
inconsistent with the facility’s SSM plan.
7. Recordkeeping
All notifications and reports (and supporting documentation) as well as records pertaining
to initial and continuous compliance must be maintained for a period of 5 years from the
date of each record or report. They must be maintained on-site for at least 2 years and may
be kept off-site for the remaining 3 years.
Page 4 of 9
8. General Provisions (40 CFR Part 63, Subpart A)
Freebird is required to comply with all applicable general provisions of 40 CFR Part 63,
Subpart A, except the provisions related to opacity or visible emission standards and
COMS since Subpart ZZZZ does not contain these standards or requirements. Table 8 to
Subpart ZZZZ also specifies what sections of the subpart have additional or more stringent
requirements than the general provisions.
As mentioned previously, Emission Unit No. 010 is an affected source under the RICE MACT;
however, because this engine is a new affected source constructed after the June 12, 2006,
applicability date, Freebird must meet the requirements of the RICE MACT for this engine by
meeting the requirements of 40 CFR Part 60, Subpart JJJJ. No further requirements would apply
to the emergency engine under Subpart ZZZZ.
40 CFR Part 63, Subpart HHH, National Emissions Standards for Hazardous Air Pollutants
from Natural Gas Transmission and Storage Facilities
On August 16, 2012, the EPA amended Subpart HHH, which removed the exception for glycol
dehydrators whose actual annual average benzene emissions were less than 0.90 Mg/yr from
complying with the control device and testing requirements. Unit No. 009 is an affected source
under 40 CFR Part 63, Subpart HHH. In accordance with 40 CFR §63.1270(d)(3), Freebird must
achieve compliance with this Subpart no later than October 15, 2015. On March 30, 2015,
Freebird requested an extension to the compliance date to April 12, 2016. Freebird requested
this extension in order to purchase, install, and test a thermal oxidizer (TO). The TO would act
as a control device, which is expected to achieve 99.9% control efficiency as opposed to the
dehydration reboilers and the condenser, which currently act as control devices and only achieve
95% control efficiency. The Air Division approved this extension on April 21, 2015.
40 CFR §63.1271 defines a control device as any equipment used for recovering or oxidizing
HAP or volatile organic compound (VOC) vapors. Such equipment includes, but is not limited
to, absorbers, carbon absorbers, condensers, incinerators, flares, boilers, and process heaters. For
the purposes of this subpart, if gas or vapor from regulated equipment is used, reused (i.e.,
injected into the flame zone of an enclosed combustion device), returned back to the process, or
sold, then the recovery system used, including piping, connections, and flow inducing devices, is
not considered to be a control device or a closed-vent system. Freebird plans to continue using
the condenser and sell the condensate produced by the condenser. Therefore, the condenser
would not meet the definition of a control device. However, if Freebird does not sell the
condensate or discontinues selling the condensate, the condenser would be considered a control
device and subject to the requirements of this Subpart.
This unit meets the definition of an existing small glycol dehydration unit according to 40 CFR
§63.1271, since the average benzene emissions are less than 0.90 Mg/yr. The applicable
requirements are:
1. Emission Limitation
Page 5 of 9
Freebird must limit their BTEX (benzene, toluene, ethyl benzene, and xylene) emissions
below the calculated allowable emissions rate using Equation 1 found in 40 CFR
§63.1275(b)(iii) for existing small glycol dehydrators.
ELBTEX = 3.10x10-4 x Throughput x C LBTEX x 365 days/yr x 1Mg/1x106 gr).
Where:
ELBTEX =
Unit specific BTEX emission limit (megagrams/yr)
3.10x10-4 =
BTEX emission limit (gr BTEX/scm-ppmv)
Throughput=
annual average daily natural gas throughput (scm/day)
C LBTEX =
annual average BTEX concentration of the natural gas at the inlet
to the glycol dehydration unit (ppmv)
Freebird has chosen to meet this requirement by installing a thermal oxidizer in
conjunction with the existing condenser associated with this unit.
2. Performance Testing
Freebird would be required to demonstrate that the thermal oxidizer achieves the reduction
in BTEX emissions by performing an initial performance test by February 15, 2016, per the
agreed upon extension. Subsequent performance tests should be conducted no more than
60 months after the previous test.
This unit is required to be a closed vent system with no detectable emissions by routing all
gases, vapors, and fumes to the control device. Freebird would be required to demonstrate
this in accordance with 40 CFR §63.1282(b), and by performing annual visual inspections
for defects that could result in air emissions.
3. Continuous Compliance/Operating Limitations
Freebird will monitor the thermal oxidizer (and the condenser, if the condenser meets the
definition of a control device) with their CPMS. Freebird would be required to establish
specific site minimum or maximum parameter values for the thermal oxidizer as specified
in 40 CFR §63.1283(d)(5)(i) during the performance test. Using data collected by the
CPMS, Freebird must calculate a daily average for each monitored operating parameter for
each operating day to ensure that the unit is operating in compliance as specified in 40 CFR
§63.1283(d)(4). Compliance would be achieved when the daily average of the monitoring
value is either equal to or greater than the minimum value or equal to or less than the
maximum value.
4. Notifications
Freebird is required to submit a Notification of Intent at least 60 days prior to conducting
each performance test. Following each test, Freebird is required to submit a Notification of
Page 6 of 9
Compliance Status, including the performance test results, within 60 days of completing
each performance test.
5. Reports
Freebird would be required to submit Periodic Reports containing the information in 40
CFR §63.1285(e)(2)(i) through (xiii), semiannually based on the calendar year periods of
January – June and July – December. If a malfunction during the reporting period occurs,
the Periodic Report shall include the number, duration, and a brief description for each type
of malfunction which occurred during the reporting period and which caused or may have
caused any applicable emission limitation to be exceeded and include a description of
actions taken.
6. Recordkeeping
All notifications and reports (and supporting documentation) as well as records pertaining
to initial and continuous compliance must be maintained for a period of at least 5 years
following the date of each occurrence, measurement, maintenance, corrective action, report
or period. The most recent 12 months of records shall be retained on site or shall be
accessible from a central location by hardcopy, computer or other means. The following 4
years of records may be retained offsite. All applicable records shall be maintained in such
a manner that they can be readily accessed.
As a control device, the condenser would have to meet the following requirements:
Freebird would be required to notify the Air Division within 30 days if Freebird
discontinues selling the condensate from the condenser. Within 180 days of Freebird
discontinuing selling the condensate, Freebird would be required to establish a performance
curve for the condenser showing the relationship between the condenser outlet temperature
and condenser control efficiency. 40 CFR §63.1283(d)(5)(ii) gives Freebird the option to
either:
(i) Conduct a performance test to establish the performance curve based on the values
measured during the test;
(ii) Use a control device design analysis in accordance with the requirements of 40 CFR
§63.1282(d)(4)(i) to demonstrate that the condenser achieves the applicable
performance requirements and then base the condenser performance curve on the
design analysis; or,
(iii) As an alternative to using a control device design analysis, Freebird may elect to use
the procedures documented in the GRI report entitled “Atmospheric Rich/Lean
Method for Determining Glycol Dehydrator Emissions” as inputs for the model GRIGLYCalc, Version 3.0 or higher, to generate a condenser performance curve.
Freebird has the option to determine compliance by either the method specified in 40 CFR
§63.1282(e) or 40 CFR §63.1282(f). Freebird may switch between the two options only
after at least one year of operation in compliance with the selected approach.
Page 7 of 9
(i) 40 CFR §63.1282(e) requires Freebird to demonstrate compliance by using data
collected by the CPMS during the establishment of the site specific performance curve
and calculate a daily average for each monitored operating parameter for each
operating day to ensure that the unit is in compliance as specified in 40 CFR
§63.1283(d)(4). Compliance would be achieved when the daily average of the
monitoring value is either equal to or greater than the minimum value or equal to or
less than the maximum value; or
(ii) 40 CFR §63.1282(f) requires Freebird to use the site specific performance curve to
identify the minimum percent reduction necessary to meet the BTEX limit. Freebird
would calculate the daily average condenser outlet temperature and determine the
condenser efficiency for the current operating day using the daily average condenser
outlet temperature and the condenser performance curve. At the end of each operating
day, Freebird would calculate the 30-day average BTEX emission reduction from the
condenser efficiency for the preceding 30 operating days.
Applicability: State Regulations
Although the reciprocating engines and the natural gas-fired emergency generator at this facility
are fuel combustion sources, they are not subject to any particulate matter (as TSP) emission
limitation of ADEM Admin. Code r. 335-3-4 or any sulfur dioxide (SO 2 ) emission limitation of
ADEM Admin. Code r. 335-3-5 because they do not meet the definition of fuel burning
equipment nor is this facility considered one of the process industries, general or specific. The
engines and generator are, however, subject to the visible emissions standards of ADEM Admin.
Code r. 335-3-4-.01(1). Since the engines are fired exclusively with natural gas, they would be
expected to be able to comply with this standard.
The glycol dehydrator is subject to the particulate matter (as TSP) emission limitation of ADEM
Admin. Code r. 335-3-4, the sulfur dioxide (SO 2 ) emission limitation of ADEM Admin. Code r.
335-3-5, and the visible emissions standards of ADEM Admin. Code r. 335-3-4-.01(1) because
the glycol dehydrator is considered fuel burning equipment. However, because this unit is fired
exclusively with natural gas, it would be expected to be able to comply with these standards.
Emission Testing and Monitoring
In addition to the testing required to comply with 40 CFR Part 63, Subpart ZZZZ for Emission
Unit Nos. 004 – 006, Freebird would be required to certify on a semiannual basis that only
natural gas was burned in the six reciprocating engines and the emergency generator as a method
for monitoring compliance with the visible emission requirements of ADEM Admin. Code r.
335-3-4-.01(1). In addition the glycol dehydrator would be required to certify on a semiannual
basis that only natural gas was fired in the glycol dehydrator/heater and that natural gas was fired
in the thermal oxidizer with the exception of the waste gases generated by the glycol
dehydration/heater unit operations that are combusted and destroyed by the thermal oxidizer as a
Page 8 of 9
method for monitoring compliance with the visible emission requirements of ADEM Admin.
Code r. 335-3-4-.01(1).
Compliance Assurance Monitoring (CAM)
Although Emission Unit Nos. 004 - 006 and 010 utilize an active control device to meet an
emission standard, these units would not be subject to CAM because 40 CFR §64.2(b)(i)
exempts units subject to an emission standard proposed after November 15, 1990, pursuant to
section 111 or 112 of the Clean Air Act. These units are subject to the RICE MACT, which is a
standard that meets this exemption.
Recordkeeping and Reporting Requirements
In addition to the recordkeeping and reporting required to comply with 40 CFR Part 63, Subpart
ZZZZ for Emission Unit Nos. 004 – 006, 40 CFR Part 60, Subpart JJJJ for Emission Unit No.
010, and 40 CFR Part 63, Subpart HHH for Emission Unit No. 9, Freebird would be required to
submit a certification semiannually that only natural gas was fired in the engines, the emergency
generator, and the glycol dehydrator.
Recommendation
Based on the above analysis, I recommend that the Major Source Operating Permit (408-0009)
be issued with the requirements above pending a 30-day public comment period and a 45-day
EPA review.
Brandon R. Cranford
Chemical Branch
Air Division
DRAFT
Date
Page 9 of 9
MAJOR SOURCE OPERATING PERMIT
PERMITTEE:
FREEBIRD GAS STORAGE, L.L.C.
FACILITY NAME:
EAST DETROIT STORAGE FACILITY
FACILITY/PERMIT NO.: 408-0009
LOCATION:
SULLIGENT, LAMAR COUNTY, ALABAMA
In accordance with and subject to the provisions of the Alabama Air Pollution Control Act of 1971, as
amended, Ala. Code §§22-28-1 to 22-28-23 (2006 Rplc. Vol. and 2007 Cum. Supp.) (the "AAPCA") and
the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (2006
Rplc. Vol. and 2007 Cum. Supp.), and rules and regulations adopted there under, and subject further to
the conditions set forth in this permit, the Permittee is hereby authorized to construct, install and use the
equipment, device or other article described above.
Pursuant to the Clean Air Act of 1990, all conditions of this permit are federally enforceable by EPA,
the Alabama Department of Environmental Management, and citizens in general. Those provisions
which are not required under the Clean Air Act of 1990 are considered to be state permit provisions and
are not federally enforceable by EPA and citizens in general. Those provisions are contained in separate
sections of this permit.
Issuance Date:
Effective Date:
Expiration Date:
January 31, 2020
Alabama Department of Environmental Management
TABLE OF CONTENTS
GENERAL PERMIT PROVISOS ............................................................................................................ 1
1. Transfer ............................................................................................................................... 1
2. Renewals ............................................................................................................................. 1
3. Severability Clause .............................................................................................................. 1
4. Compliance .......................................................................................................................... 1
5. Termination for Cause ......................................................................................................... 1
6. Property Rights .................................................................................................................... 2
7. Submission of Information ................................................................................................... 2
8. Economic Incentives, Marketable Permits, and Emissions Trading..................................... 2
9. Certification of Truth, Accuracy, and Completeness ............................................................ 2
10. Inspection and Entry ........................................................................................................... 2
11. Compliance Provisions ......................................................................................................... 3
12. Compliance Certification ...................................................................................................... 3
13. Reopening for Cause ........................................................................................................... 4
14. Additional Rules and Regulations ....................................................................................... 4
15. Equipment Maintenance or Breakdown .............................................................................. 4
16. Operation of Capture and Control Devices .......................................................................... 5
17. Obnoxious Odors ................................................................................................................. 5
18. Fugitive Dust ....................................................................................................................... 5
19. Additions and Revisions ...................................................................................................... 6
20. Recordkeeping Requirements .............................................................................................. 6
21. Reporting Requirements ...................................................................................................... 7
22. Emission Testing Requirements........................................................................................... 7
23. Payment of Emission Fees ................................................................................................... 8
24. Other Reporting and Testing Requirements ......................................................................... 8
25. Title VI Requirements (Refrigerants) .................................................................................... 8
26. Chemical Accidental Prevention Provisions ......................................................................... 8
27. Display of Permit ................................................................................................................. 9
28. Circumvention ...................................................................................................................... 9
29. Visible Emissions................................................................................................................. 9
30. Fuel-Burning Equipment ...................................................................................................... 9
31. Process Industries – General ............................................................................................... 9
32. Averaging Time for Emission Limits .................................................................................. 10
33. Open Burning .................................................................................................................... 10
34. Permit Shield ..................................................................................................................... 10
EMISSION UNIT NOS. 001, 002, AND 003 (ENGINE NOS. 489, 490, AND 491)............................. 11
Summary Page ........................................................................................................................ 11
Unit Specific Provisos............................................................................................................... 12
1. Applicability ...................................................................................................... 12
2. Emission Standards .......................................................................................... 12
3. Compliance and Performance Test Methods and Procedures ............................... 12
4. Emission Monitoring .......................................................................................... 12
5. Recordkeeping and Reporting Requirements ....................................................... 12
i
EMISSION UNIT NOS. 004, 005, AND 006 (ENGINE NOS. 492, 493, AND 494)............................. 13
Summary Page ........................................................................................................................ 13
Unit Specific Provisos............................................................................................................... 14
1. Applicability ...................................................................................................... 14
2. Emission Standards .......................................................................................... 14
3. Compliance and Performance Test Methods and Procedures ............................... 15
4. Emission Monitoring .......................................................................................... 15
5. Recordkeeping and Reporting Requirements ....................................................... 17
EMISSION UNIT NO. 009 (GLYCOL DEHYDRATOR) .................................................................... 20
Summary Page ........................................................................................................................ 20
Unit Specific Provisos............................................................................................................... 21
1. Applicability ...................................................................................................... 21
2. Emission Standards .......................................................................................... 21
3. Compliance and Performance Test Methods and Procedures ............................... 22
4. Emission Monitoring .......................................................................................... 23
5. Recordkeeping and Reporting Requirements ....................................................... 28
EMISSION UNIT NO. 010 (EMERGENCY GENERATOR NO. 2) ................................................... 31
Summary Page ........................................................................................................................ 31
Unit Specific Provisos............................................................................................................... 32
1. Applicability ...................................................................................................... 32
2. Emission Standards .......................................................................................... 32
3. Compliance and Performance Test Methods and Procedures ............................... 32
4. Emission Monitoring .......................................................................................... 33
5. Recordkeeping and Reporting Requirements ....................................................... 33
ii
General Permit Provisos
Federally Enforceable Provisos
Regulations
1. Transfer
This permit is not transferable, whether by operation of law or
otherwise, either from one location to another, from one piece of
equipment to another, or from one person to another, except as
provided in ADEM Admin. Code r. 335-3-16-.13(1)(a)5.
ADEM Admin. Code r.
335-3-16-.02(6)
2. Renewals
An application for permit renewal shall be submitted at least six
(6) months, but not more than eighteen (18) months, before the
date of expiration of this permit.
ADEM Admin. Code r.
335-3-16-.12(2)
The source for which this permit is issued shall lose its right to
operate upon the expiration of this permit unless a timely and
complete renewal application has been submitted within the time
constraints listed in the previous paragraph.
3. Severability Clause
The provisions of this permit are declared to be severable and if
any section, paragraph, subparagraph, subdivision, clause, or
phrase of this permit shall be adjudged to be invalid or
unconstitutional by any court of competent jurisdiction, the
judgment shall not affect, impair, or invalidate the remainder of
this permit, but shall be confined in its operation to the section,
paragraph, subparagraph, subdivisions, clause, or phrase of this
permit that shall be directly involved in the controversy in which
such judgment shall have been rendered.
ADEM Admin. Code r.
335-3-16-.05(e)
4. Compliance
(a) The permittee shall comply with all conditions of ADEM
Admin. Code 335-3. Noncompliance with this permit will
constitute a violation of the Clean Air Act of 1990 and ADEM
Admin. Code 335-3 and may result in an enforcement action;
including but not limited to, permit termination, revocation
and reissuance, or modification; or denial of a permit renewal
application by the permittee.
ADEM Admin. Code r.
335-3-16-.05(f)
(b) The permittee shall not use as a defense in an enforcement
action that maintaining compliance with conditions of this
permit would have required halting or reducing the permitted
activity.
ADEM Admin. Code r.
335-3-16-.05(g)
5. Termination for Cause
This permit may be modified, revoked, reopened, and reissued, or
terminated for cause. The filing of a request by the permittee for
a permit modification, revocation and reissuance, or termination,
or of a notification of planned changes or anticipated
noncompliance will not stay any permit condition.
Permit No. 408-0009
ADEM Admin. Code r.
335-3-16-.05(h)
Page 1 of 34
General Permit Provisos
Federally Enforceable Provisos
Regulations
6. Property Rights
The issuance of this permit does not convey any property rights
of any sort, or any exclusive privilege.
ADEM Admin. Code r.
335-3-16-.05(i)
7. Submission of Information
The permittee must submit to the Air Division, within 30 days or
for such other reasonable time as the Air Division may set, any
information that the Air Division may request in writing to
determine whether cause exists for modifying, revoking and
reissuing, or terminating this permit or to determine compliance
with this permit. Upon receiving a specific request, the permittee
shall also furnish to the Air Division copies of records required to
be kept by this permit.
ADEM Admin. Code r.
335-3-16-.05(j)
8. Economic Incentives, Marketable Permits, and Emissions
Trading
No permit revision shall be required, under any approved
economic incentives, marketable permits, emissions trading and
other similar programs or processes for changes that are provided
for in this permit.
ADEM Admin. Code r.
335-3-16-.05(k)
9. Certification of Truth, Accuracy, and Completeness
Any application form, report, test data, monitoring data, or
compliance certification submitted pursuant to this permit shall
contain certification by a responsible official of 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.
ADEM Admin. Code r.
335-3-16-.07(a)
10. Inspection and Entry
Upon presentation of credentials and other documents as may be
required by law, the permittee shall allow authorized
representatives of the Alabama Department of Environmental
Management and EPA to conduct the following:
ADEM Admin. Code r.
335-3-16-.07(b)
(a) Enter upon the permittee’s premises where a source is located
or emissions-related activity is conducted, or where records
must be kept pursuant to the conditions of this permit;
(b) Review and/or copy, at reasonable times, any records that
must be kept pursuant to the conditions of this permit;
(c) Inspect, at reasonable times, this facility’s equipment
(including monitoring equipment and air pollution control
equipment), practices, or operations regulated or required
pursuant to this permit;
Permit No. 408-0009
Page 2 of 34
General Permit Provisos
Federally Enforceable Provisos
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(d) Sample or monitor, at reasonable times, substances or
parameters for the purpose of assuring compliance with this
permit or other applicable requirements.
11. Compliance Provisions
(a) The permittee shall continue to comply with the applicable
requirements with which the company has certified that it is
already in compliance.
ADEM Admin. Code r.
335-3-16-.07(c)
(b) The permittee shall comply in a timely manner with
applicable requirements that become effective during the term
of this permit.
12. Compliance Certification
The permittee shall submit a complete and accurate compliance
certification by April 1 of each year for each annual reporting
period of this permit (February 1 – January 31).
ADEM Admin. Code r.
335-3-16-.07(e)
(a) The compliance certification shall include the following:
(1) The identification of each term or condition of this permit
that is the basis of the certification;
(2) The compliance status;
(3) The method(s) used for determining the compliance status
of the source, currently and over the reporting period
consistent with ADEM Admin. Code r. 335-3-16-.05(c)
(Monitoring and Recordkeeping Requirements);
(4) Whether compliance has been continuous or intermittent;
(5) Such other facts as the Air Division may require to
determine the compliance status of the source;
(b) The compliance certification shall be submitted to:
Alabama Department of Environmental Management
Air Division
P.O. Box 301463
Montgomery, AL 36130-1463
and to:
Air and EPCRA Enforcement Branch
EPA Region IV
61 Forsyth Street, SW
Atlanta, GA 30303
Permit No. 408-0009
Page 3 of 34
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13. Reopening for Cause
Under any of the following circumstances, this permit will be
reopened prior to the expiration of the permit:
ADEM Admin. Code r.
335-3-16-.13(5)
(a) Additional applicable requirements under the Clean Air
Act of 1990 become applicable to the permittee with a
remaining permit term of three (3) or more years. Such a
reopening shall be completed not later than eighteen (18)
months after promulgation of the applicable requirement.
No such reopening is required if the effective date of the
requirement is later than the date on which this permit is
due to expire.
(b) Additional requirements (including excess emissions
requirements) become applicable to an affected source
under the acid rain program. Upon approval by the
Administrator, excess emissions offset plans shall be
deemed to be incorporated into this permit.
(c) The Department or EPA determines that this permit
contains a material mistake or that inaccurate statements
were made in establishing the emissions standards or
other terms or conditions of this permit.
(d) The Administrator or the Department determines that this
permit must be revised or revoked to assure compliance
with the applicable requirements.
14. Additional Rules and Regulations
This permit is issued on the basis of Rules and Regulations
existing on the date of issuance. In the event additional Rules
and Regulations are adopted, it shall be the permit holder’s
responsibility to comply with such rules.
§22-28-16(d), Code of
Alabama 1975, as
amended
15. Equipment Maintenance or Breakdown
(a) In case of shutdown of air pollution control equipment (which
operates pursuant to any permit issued by the Director) for
necessary scheduled maintenance, the intent to shut down
such equipment shall be reported to the Air Division at least
(24) hours prior to the planned shutdown, unless such
shutdown is accompanied by the shutdown of the source
which such equipment is intended to control. Such prior
notice shall include, but is not limited to the following:
ADEM Admin. Code r.
335-3-1-.07(1),(2)
(1) Identification of the specific facility to be taken out of
service as well as its location and permit number;
(2) The expected length of time that the air pollution control
equipment will be out of service;
Permit No. 408-0009
Page 4 of 34
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(3) The nature and quality of emissions of air contaminants
likely to occur during the shutdown period;
(4) Measures such as the use of off-shift labor and equipment
that will be taken to minimize the length of the shutdown
period;
(5) The reasons that it would be impossible or impractical to
shut down the sources operation during the maintenance
period.
(b) In the event that there is a breakdown of equipment or upset
of process in such a manner as to cause, or is expected to
cause, increased emissions of air contaminants which are
above an applicable standard, the person responsible for such
equipment shall notify the Director within 24 hours or the
next working day and provide a statement giving all pertinent
facts, including the estimated duration of the breakdown. The
Director will be notified when the breakdown has been
corrected.
16. Operation of Capture and Control Devices
All air pollution control devices and capture systems for which
this permit is issued shall be maintained and operated at all
times in a manner so as to minimize the emissions of air
contaminants. Procedures for ensuring that the above equipment
is properly operated and maintained so as to minimize the
emission of air contaminants shall be established.
§22-28-16(d), Code of
Alabama 1975, as
amended
17. Obnoxious Odors
This permit is issued with the condition that, should obnoxious
odors arising from the plant operations be verified by Air Division
inspectors, measures to abate the odorous emissions shall be
taken upon a determination by the Alabama Department of
Environmental Management that these measures are technically
and economically feasible.
ADEM Admin. Code r.
335-3-1-.08
18. Fugitive Dust
(a) Precautions shall be taken to prevent fugitive dust emanating
from plant roads, grounds, stockpiles, screens, dryers,
hoppers, ductwork, etc.
ADEM Admin. Code r.
335-3-4-.02
(b) Plant or haul roads and grounds will be maintained in the
following manner so that dust will not become airborne. A
minimum of one, or a combination, of the following methods
shall be utilized to minimize airborne dust from plant or haul
roads and grounds:
Permit No. 408-0009
Page 5 of 34
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(1) By the application of water any time the surface of the
road is sufficiently dry to allow the creation of dust
emissions by the act of wind or vehicular traffic;
(2) By reducing the speed of vehicular traffic to a point below
that at which dust emissions are created;
(3) By paving;
(4) By the application of binders to the road surface at any
time the road surface is found to allow the creation of
dust emissions.
Should one, or a combination, of the above methods fail to
adequately reduce airborne dust from plant or haul roads and
grounds, alternative methods shall be employed, either
exclusively or in combination with one or all of the above
control techniques, so that dust will not become airborne.
Alternative methods shall be approved by the Air Division
prior to utilization.
19. Additions and Revisions
Any modifications to this source shall comply with the
modification procedures in ADEM Admin. Code r. 335-3-16-.13
or 335-3-16-.14.
ADEM Admin. Code r.
335-3-16-.13 and
335-3-16-.14
20. Recordkeeping Requirements
(a) Records of required monitoring information of the source
shall include the following:
(1) The date, place,
measurements;
and
time
of
all
sampling
ADEM Admin. Code r.
335-3-16-.05(c)2.
or
(2) The date analyses were performed;
(3) The company or entity that performed the analyses;
(4) The analytical techniques or methods used;
(5) The results of all analyses; and
(6) The operating conditions that existed at the time of
sampling or measurement.
(b) Retention of records of all required monitoring data and
support information of the source for a period of at least 5
years from the date of the monitoring sample, measurement,
report, or application.
Support information includes all
calibration and maintenance records and all original
strip-chart
recordings
for
continuous
monitoring
instrumentation and copies of all reports required by the
permit.
Permit No. 408-0009
Page 6 of 34
General Permit Provisos
Federally Enforceable Provisos
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21. Reporting Requirements
(a) Reports to the Air Division of any required monitoring shall be
submitted at least every 6 months. All instances of deviations
from permit requirements must be clearly identified in said
reports.
All required reports must be certified by a
responsible official consistent with ADEM Admin. Code r.
335-3-16-.04(9).
ADEM Admin. Code r.
335-3-16-.05(c)3.
(b) Deviations from permit requirements shall be reported within
48 hours or 2 working days of such deviations, including
those attributable to upset conditions as defined in the
permit. The report will include the probable cause of said
deviations, and any corrective actions or preventive measures
that were taken.
22. Emission Testing Requirements
Each point of emission which requires testing will be provided
with sampling ports, ladders, platforms, and other safety
equipment to facilitate testing performed in accordance with
procedures established by Part 60 of Title 40 of the Code of
Federal Regulations, as the same may be amended or revised.
ADEM Admin. Code r.
335-3-1-.05(3) and
335-3-1-.04(1)
The Air Division must be notified in writing at least 10 days in
advance of all emission tests to be conducted and submitted as
proof of compliance with the Department’s air pollution control
rules and regulations.
To avoid problems concerning testing methods and procedures,
the following shall be included with the notification letter:
ADEM Admin. Code r.
335-3-1-.04
(a) The date the test crew is expected to arrive, the date and time
anticipated of the start of the first run, how many and which
sources are to be tested, and the names of the persons
and/or testing company that will conduct the tests.
(b) A complete description of each sampling train to be used,
including type of media used in determining gas stream
components, type of probe lining, type of filter media, and
probe cleaning method and solvent to be used (if test
procedures require probe cleaning).
(c) A description of the process(es) to be tested including the feed
rate, any operating parameters used to control or influence
the operations, and the rated capacity.
(d) A sketch or sketches showing sampling point locations and
their relative positions to the nearest upstream and
downstream gas flow disturbances.
A pretest meeting may be held at the request of the source owner
or the Air Division. The necessity for such a meeting and the
required attendees will be determined on a case-by-case basis.
Permit No. 408-0009
ADEM Admin. Code r.
335-3-1-.04
Page 7 of 34
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Unless otherwise specified in this permit or applicable regulation,
all test reports must be submitted to the Air Division within 30
days of the actual completion of the test unless an extension of
time is specifically approved by the Air Division.
23. Payment of Emission Fees
(a) The permittee shall submit the annual Operating Permit Fees
required by ADEM Admin. Code r. 335-1-7-.04 according to
the schedule in ADEM Admin. Code r. 335-1-7-.05
ADEM Admin. Code r.
335-1-7-.05
(b) The permittee shall submit its estimates of actual emissions
for the previous calendar year according to the schedule in
ADEM Admin. Code r. 335-1-7-.05.
ADEM Admin. Code r.
335-1-7-.05
24. Other Reporting and Testing Requirements
Submission of other reports regarding monitoring records, fuel
analyses, operating rates, and equipment malfunctions may be
required as authorized in the Department's air pollution control
rules and regulations. The Department may require emission
testing at any time.
ADEM Admin. Code r.
335-3-1-.04(1)
25. Title VI Requirements (Refrigerants)
Any facility having appliances or refrigeration equipment,
including air conditioning equipment, which use Class I or Class
II ozone-depleting substances as listed in 40 CFR Part 82,
Subpart A, Appendices A and B, shall service, repair, and
maintain such equipment according to the work practices,
personnel certification requirements, and certified recycling and
recovery equipment specified in 40 CFR Part 82, Subpart F.
ADEM Admin. Code r.
335-3-16-.05(a)
No person shall knowingly vent or otherwise release any Class I
or Class II substance into the environment during the repair,
servicing, maintenance, or disposal of any device except as
provided in 40 CFR Part 82, Subpart F.
The responsible official shall comply with all reporting and
recordkeeping requirements of 40 CFR §82.166. Reports shall be
submitted to the US EPA and the Department as required.
26. Chemical Accidental Prevention Provisions
If a chemical listed in Table 1 of 40 CFR §68.130 is present in a
process in quantities greater than the threshold quantity listed in
Table 1, then:
40 CFR Part 68
(a) The owner or operator shall comply with the provisions in 40
CFR Part 68.
(b) The owner or operator shall submit one of the following:
Permit No. 408-0009
Page 8 of 34
General Permit Provisos
Federally Enforceable Provisos
Regulations
(1) A compliance schedule for meeting the requirements of 40
CFR Part 68 by the date provided in 40 CFR §68.10(a) or,
(2) A certification statement that the source is in compliance
with all requirements of 40 CFR Part 68, including the
registration and submission of the Risk Management
Plan.
27. Display of Permit
This permit shall be kept under file or on display at all times at
the site where the facility for which the permit is issued is located
and will make the permit readily available for inspection by any
or all persons who may request to see it.
ADEM Admin. Code r.
335-3-14-.01(1)(d)
28. Circumvention
No person shall cause or permit the installation or use of any
device or any means which, without resulting in the reduction in
the total amount of air contaminant emitted, conceals or dilutes
any emission of air contaminant which would otherwise violate
the Division 3 rules and regulations.
ADEM Admin. Code r.
335-3-1-.10
29. Visible Emissions
Unless otherwise specified in the Unit Specific provisos of this
permit, any source of particulate emissions shall not discharge
more than one 6-minute average opacity greater than 20% in any
60-minute period. At no time shall any source discharge a
6-minute average opacity of particulate emissions greater than
40%. Opacity will be determined by 40 CFR Part 60, Appendix A,
Method 9, unless otherwise specified in the Unit Specific provisos
of this permit.
ADEM Admin. Code r.
335-3-4-.01(1)
30. Fuel-Burning Equipment
Unless otherwise specified in the Unit Specific provisos of this
permit, no fuel-burning equipment may discharge particulate
emissions in excess of the emissions specified in ADEM Admin.
Code r. 335-3-4-.03.
ADEM Admin. Code r.
335-3-4-.03
Unless otherwise specified in the Unit Specific provisos of this
permit, no fuel-burning equipment may discharge sulfur dioxide
emissions in excess of the emissions specified in ADEM Admin.
Code r. 335-3-5-.01.
ADEM Admin. Code r.
335-3-5-.01
31. Process Industries – General
Unless otherwise specified in the Unit Specific provisos of this
permit, no process may discharge particulate emissions in excess
of the emissions specified in ADEM Admin. Code r. 335-3-4-.04.
Permit No. 408-0009
ADEM Admin. Code r.
335-3-4-.04
Page 9 of 34
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Federally Enforceable Provisos
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32. Averaging Time for Emission Limits
Unless otherwise specified in the permit, the averaging time for
the emission limits listed in this permit shall be the nominal time
required by the specific test method.
ADEM Admin. Code r.
335-3-1-.05
33. Open Burning
Precautions should be taken to ensure that no person shall
ignite, cause to ignite, permit to be ignited, or maintain any open
fire in such a manner as to cause the Department’s rules and
regulations applicable to open burning to be violated.
ADEM Admin. Code r.
335-3-3-.01
34. Permit Shield
A Permit Shield exists under this operating permit in accordance
with ADEM Admin. Code r. 335-3-16-.10 in that compliance with
the conditions of this permit shall be deemed compliance with
any applicable requirements as of the date of permit issuance,
provided that such applicable requirements are included and are
specifically identified in this operating permit.
Permit No. 408-0009
ADEM Admin. Code r.
335-3-16-.10
Page 10 of 34
Emission Unit Nos. 001, 002, and 003 (Engine Nos. 489, 490, and 491)
Summary Page
Description:
Three (3) 1,340 hp Caterpillar G3516, 4-stroke, lean-burn natural gas-fired
reciprocating engines
Permitted Operating Schedule:
24 Hours
Day
X
365 Days
Year
=
8760 Hours
Year
Emission limitations:
Emission
Point
No.
001
002
003
Description
1,340 hp caterpillar G3516,
4-stroke, lean-burn natural
gas-fired reciprocating engine
(Engine #489)
1,340 hp Caterpillar G3516,
4-stroke, lean-burn natural
gas-fired reciprocating engine
(Engine #490)
1,340 hp Caterpillar G3516,
4-stroke, lean-burn natural
gas-fired reciprocating engine
(Engine #491)
Permit No. 408-0009
Pollutant
Emission
limit
Regulation
NO x
N/A
N/A
CO
N/A
N/A
VOC
N/A
N/A
SO 2
N/A
N/A
PM
N/A
N/A
HAP
N/A
N/A
NOx
N/A
N/A
CO
N/A
N/A
VOC
N/A
N/A
SO 2
N/A
N/A
PM
N/A
N/A
HAP
N/A
N/A
NOx
N/A
N/A
CO
N/A
N/A
VOC
N/A
N/A
SO 2
N/A
N/A
PM
N/A
N/A
HAP
N/A
N/A
Page 11 of 34
Emission Unit Nos. 001, 002, and 003 (Engine Nos. 489, 490, and 491)
Unit Specific Provisos
Federally Enforceable Provisos
Regulations
1. Applicability
(a) These units are subject to the applicable requirements of
ADEM Admin. Code r. 335-3-16-.03, “Major Source Operating
Permits.”
ADEM Admin. Code r.
335-3-16-.03
(b) These units are affected sources under 40 CFR Part 63,
Subpart ZZZZ, National Emission Standards for Hazardous
Air Pollutants for Stationary Reciprocating Internal
Combustion Engines (RICE), and meet the criteria for
stationary RICE subject to limited requirements as specified
in 40 CFR §63.6590(b)(3).
ADEM Admin. Code r.
335-3-11-.06(103)
and 40 CFR Part 63,
Subpart ZZZZ
2. Emission Standards
The permittee shall not cause or allow visible emissions with a
six-minute average opacity greater than 20% to be emitted more
than once during any 60-minute period. The permittee shall not
cause or allow visible emissions with a six-minute average opacity
greater than 40% to be emitted at any time.
ADEM Admin. Code r.
335-3-4-.01(1)
3. Compliance and Performance Test Methods and Procedures
If testing is required, opacity shall be determined by 40 CFR Part
60, Appendix A, Reference Method 9.
40 CFR Part 60
4. Emission Monitoring
The permittee shall certify semiannually that only natural gas
was fired in these units.
ADEM Admin. Code r.
335-3-16-.05(c)
5. Recordkeeping and Reporting Requirements
The permittee shall submit a Semiannual Monitoring Report
(SMR), as required by General Permit Proviso No. 21(a), no later
than 60 days after the end of each semiannual reporting period
(January 1 – June 30 and July 1 – December 31). The report
shall include a certification that only natural gas was fired in
these units.
Permit No. 408-0009
ADEM Admin. Code R.
335-3-16-.05(c)
Page 12 of 34
Emission Unit Nos. 004, 005, and 006 (Engine Nos. 492, 493, and 494)
Summary Page
Description:
Three (3) 2,370 hp Caterpillar G3608, 4-stroke, lean-burn natural gas-fired
reciprocating engines with MIRATECH Oxidation Catalyst
Permitted Operating Schedule:
24 Hours
Day
X
365 Days
Year
=
8760 Hours
Year
Emission limitations:
Emission
Point
No.
004
005
006
Description
2,370 hp Caterpillar G3608,
4-stroke, lean-burn natural
gas-fired reciprocating engine
with MIRATECH oxidation
catalyst (Engine #492)
2,370 hp Caterpillar G3608,
4-stroke, lean-burn natural
gas-fired reciprocating engine
with MIRATECH oxidation
catalyst (Engine #493)
2,370 hp Caterpillar G3608,
4-stroke, lean-burn natural
gas-fired reciprocating engine
with MIRATECH oxidation
catalyst (Engine #494)
Permit No. 408-0009
Pollutant
Emission
limit
Regulation
NO x
N/A
N/A
CO
(Surrogate
for HAP)
93% Reduction
ADEM Admin. Code r.
335-3-11-.06(103) and
40 CFR §63.6600
VOC
N/A
N/A
SO 2
N/A
N/A
PM
N/A
N/A
NO x
N/A
N/A
CO
(Surrogate
for HAP)
93% Reduction
ADEM Admin. Code r.
335-3-11-.06(103) and
40 CFR §63.6600
VOC
N/A
N/A
SO 2
N/A
N/A
PM
N/A
N/A
NO x
N/A
N/A
CO
(Surrogate
for HAP)
93% Reduction
ADEM Admin. Code r.
335-3-11-.06(103) and
40 CFR §63.6600
VOC
N/A
N/A
SO 2
N/A
N/A
PM
N/A
N/A
Page 13 of 34
Emission Unit Nos. 004, 005, and 006 (Engine Nos. 492, 493, and 494)
Unit Specific Provisos
Federally Enforceable Provisos
Regulations
1. Applicability
(a) These units are subject to the applicable requirements of
ADEM Admin. Code r. 335-3-16-.03, “Major Source Operating
Permits.”
ADEM Admin. Code r.
335-3-16-.03
(b) These units are subject to the applicable provisions of 40 CFR
Part 63, Subpart ZZZZ, National Emission Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines, and 40 CFR 63, Subpart A as specified
in Table 8 to Subpart ZZZZ.
ADEM Admin. Code r.
335-3-11-.06(103)
and 40 CFR Part 63,
Subpart ZZZZ
2. Emission Standards
(a) Emission Limitation. In accordance with 40 CFR §63.6600
and Table 2a to Subpart ZZZZ, the permittee shall reduce
carbon monoxide (CO) emissions from each unit by 93% or
more.
40 CFR §63.6600(b)
(b) Operating Limitations. In accordance with 40 CFR §63.6600
and Table 2b to Subpart ZZZZ, the permittee shall:
40 CFR §63.6600(b)
(i) Maintain the catalyst so that the pressure drop across the
catalyst does not change by more than two inches of water
at 100 percent load plus or minus 10 percent from the
pressure drop across the catalyst measured during the
most recent performance test that demonstrated
compliance; and
(ii) Maintain the temperature of each unit’s exhaust so that
the catalyst inlet temperature is ≥450°F and ≤1350°F.
(c) The permittee shall comply with the applicable emission
limitations and operating limitations at all times, except
during periods of startup, shutdown, and malfunction.
40 CFR §63.6605(a)
(d) The permittee shall operate and maintain these units,
including air pollution control and monitoring equipment, in a
manner consistent with good air pollution control practices for
minimizing emissions at all times, including during startup,
shutdown, and malfunction.
40 CFR §63.6605(b)
(e) The permittee shall not cause or allow visible emissions with a
six-minute average opacity greater than 20% to be emitted
more than once during any 60-minute period. The permittee
shall not cause or allow visible emissions with a six-minute
average opacity greater than 40% to be emitted at any time.
ADEM Admin. Code r.
335-3-4-.01(1)
Permit No. 408-0009
Page 14 of 34
Federally Enforceable Provisos
Regulations
3. Compliance and Performance Test Methods and Procedures
(a) Performance tests to determine compliance with the carbon
monoxide (CO) emission limitation for these units shall be
conducted in accordance with the procedures and methods
specified in 40 CFR §63.6620 and Table 4 to Subpart ZZZZ.
40 CFR §63.6620
(b) If testing is required, opacity shall be determined by 40 CFR
Part 60, Appendix A, Reference Method 9.
40 CFR Part 60
(c) During each run of any performance testing conducted, the
permittee shall monitor and record the pressure differential
across the catalyst (inches of water column) at the beginning
and end of the test run and at least once every 10 minutes
during the test run. The average pressure differentials for
each test run that indicated compliance shall be averaged to
determine the overall average pressure differential for the
testing event. Using the overall average pressure differential
for the testing event, the pressure differential range that
demonstrates compliance shall be established according to
the following equation:
40 CFR §63.6600 and
Table 2b to Subpart
ZZZZ
P LOW = P T – 2
P HIGH = P T + 2
Where:
P HIGH =
Highest pressure differential across
catalyst that demonstrates compliance
the
P LOW =
Lowest pressure differential across
catalyst that demonstrates compliance
the
PT
Average pressure differential
catalyst for the testing event
the
=
across
4. Emission Monitoring
(a) The permittee shall conduct performance testing annually (no
more than 12 months elapsing between tests) to determine
compliance with the applicable emission limitation and
reestablish the operating limitation for the pressure drop
across the catalyst. If the results of any performance test
indicate an engine is not in compliance with the applicable
emission limitation or the permittee deviates from an
operating limitation, the permittee shall conduct semiannual
(no more than 6 months elapsing between tests) performance
tests for that engine until the permittee has demonstrated
compliance for two consecutive performance tests. For an
engine that is taken out of service 30 days or more prior to the
date the next performance test is due, the permittee shall
conduct the performance test within 60 days of restarting the
engine.
Permit No. 408-0009
40 CFR §63.6615 and
Table 3 to Subpart
ZZZZ
Page 15 of 34
Federally Enforceable Provisos
Regulations
(b) The permittee shall conduct a performance test and
reestablish the operating limitation for the pressure drop
across the catalyst within 90 days of restarting the engine
after completing a replacement of the catalyst for an engine.
The permittee shall continue to monitor and record all
operating parameters in accordance with the previously
established compliance ranges until new ranges are
established.
40 CFR §63.6640(b)
(c) The permittee shall install, calibrate, properly maintain, and
operate pressure gages in the inlet and outlet ducts of each
catalytic converter to measure the pressure differential across
the catalyst. Verification of operational status shall, at a
minimum, include completion of the manufacturer’s written
specifications or recommendations for installation, operation,
and calibration of the system and necessary parts maintained
for routine repairs.
40 CFR §63.6640,
Table 6 to Subpart
ZZZZ and 40 CFR
§63.8
(d) For each engine, the permittee shall monitor and record the
pressure differential across the catalyst at least once during
The
any calendar month that the engine is operated.
permittee shall conduct the required monitoring at least once
every 31 operating days. No monitoring shall be required
during any calendar month that an engine is not operated.
40 CFR §63.6640(a)
and Table 6 to
Subpart ZZZZ
(e) The permittee shall install, calibrate, properly maintain, and
operate a thermocouple in the inlet duct of each catalytic
converter to measure the inlet temperature of the catalyst.
Verification of operational status shall, at a minimum, include
completion of the manufacturer’s written specifications or
recommendations for installation, operation, and calibration
of the system and necessary parts maintained for routine
repairs.
40 CFR §63.6640,
Table 6 to Subpart
ZZZZ, and 40 CFR
§63.8
(f) The permittee shall install, calibrate, properly maintain, and
operate a continuous parameter monitoring system (CPMS) to
continuously monitor the catalyst inlet temperature of each
engine.
Verification of operational status shall, at a
minimum, include completion of the manufacturer’s written
specifications or recommendations for installation, operation,
and calibration of the system and necessary parts maintained
for routine repairs.
40 CFR §63.6625,
Table 5 to Subpart
ZZZZ, and 40 CFR
§63.8
(g) While each engine is in operation, the permittee shall
continuously monitor and record the inlet temperature of the
catalyst at least once every 15 minutes (four readings per
hour). The permittee shall reduce the data to 4-hour rolling
averages for each engine.
40 CFR §63.6640 and
Table 6 to Subpart
ZZZZ
(h) The permittee shall operate and maintain each engine,
including air pollution control and monitoring equipment,
according to the provisions in 40 CFR §63.6(e)(1) at all times.
40 CFR §63.6(e)(1)
(i) The permittee shall certify semiannually that only natural gas
was fired in these units.
ADEM Admin. Code r.
335-3-16-.05(c)
Permit No. 408-0009
Page 16 of 34
Federally Enforceable Provisos
Regulations
5. Recordkeeping and Reporting Requirements
(a) The permittee shall maintain the following records and all
applicable records specified in 40 CFR §63.6655. These
records include, but may not be limited to:
(i)
A copy of each notification and report submitted to
comply with 40 CFR Part 63, Subpart ZZZZ, including
all documentation supporting any Initial Notification or
Notification of Compliance Status;
(ii)
Records of each startup, shutdown, and malfunction
in accordance with 40 CFR §63.6(e)(3)(iii) through (v);
(iii)
All results of performance
performance evaluations;
(iv)
Records of each period the CPMS is malfunctioning or
inoperative (including out-of-control periods);
(v)
All CPMS calibration checks;
(vi)
All monitoring data collected for the catalyst inlet
temperature, including the date and time of each
measurement;
(vii)
All 4 hour rolling averages calculated from the catalyst
inlet temperature monitoring data, including the date
and time period represented by the average;
(viii)
All monitoring data collected for the pressure drop
across the catalyst, including the date and time of
each measurement and the parameter range that was
applicable at the time the monitoring was performed;
and
(ix)
The date(s), time, nature, and results of any corrective
action taken when an exceedance of an operating
limitation occurred.
tests
and
CPMS
(b) The permittee shall keep each required record for 5 years
following the date of each occurrence, measurement,
maintenance, corrective action, report, or record.
The
permittee shall keep each record readily accessible in hard
copy or electronic form on site for at least 2 years after the
date of each occurrence, measurement, maintenance,
corrective action, report, or record. The permittee may keep
the records off site for the remaining 3 years.
Permit No. 408-0009
ADEM Admin. Code r.
335-3-16-.05(c) and
40 CFR §63.6655
ADEM Admin. Code r.
335-3-16-.05(c) and
40 CFR §63.6660
Page 17 of 34
Federally Enforceable Provisos
Regulations
(c) The permittee shall develop and maintain a written startup,
shutdown, and malfunction plan (SSMP) that describes, in
detail, procedures for operating and maintaining the engines
during periods of startup, shutdown, and malfunction and a
program of corrective action for malfunctioning processes, air
pollution control, and monitoring equipment used to comply
with the relevant standard.
40 CFR §63.6(e)(3)
(d) The permittee shall submit the following notifications and all
applicable notifications specified in 40 CFR §63.6645. These
notifications include, but may not be limited to:
ADEM Admin. Code r.
335-3-16-.05(c) and
40 CFR §63.6645
(i)
The permittee shall submit a written notification of the
intent to replace a catalyst to the Air Division at least
30 days prior to taking any action. The permittee shall
submit a written notification to the Air Division that
the replacement has been completed within 15 days of
completing the action.
(ii)
The permittee shall submit a written notification of the
intent to conduct a performance test to the Air Division
at least 60 days prior to conducting a performance
test. The notification shall include a copy of the sitespecific test plan required by 40 CFR §63.7(c)(2).
(iii)
The permittee shall submit a written notification of the
intent to conduct a performance evaluation of the
continuous monitoring system to the Air Division at
least 60 days prior to conducting a performance
evaluation. The notification shall include a copy of the
site-specific performance evaluation test plan required
by 40 CFR §63.8(e)(3).
(e) The permittee shall submit the following reports and all
applicable reports specified in 40 CFR §63.6650 and Table 7
to Subpart ZZZZ. These reports include, but may not be
limited to:
(i)
The permittee shall submit a report of the results of all
performance tests conducted to the Air Division within
60 days of completing the test. The report shall also
contain the pressure differential data collected during
testing and the calculation of the new operating
limitations for the pressure drop across the catalyst.
(ii)
A Semiannual Monitoring Report (SMR), as required by
General Permit Proviso No. 21(a), that includes a
certification that only natural gas was fired in these
units. The report shall be submitted no later than 60
days after the end of each semiannual reporting period
(January 1 – June 30 and July 1 – December 31).
Permit No. 408-0009
ADEM Admin. Code r.
335-3-16-.05(c) and
40 CFR §63.6650 and
Table 7 to Subpart
ZZZZ
Page 18 of 34
Federally Enforceable Provisos
(iii)
A Semiannual Compliance Report (SCR) which
contains the information in 40 CFR §63.6650(c)
through (f), as applicable.
The report shall be
submitted no later than 60 days after the end of each
semiannual reporting period (January 1 – June 30
and July 1 – December 31).
(iv)
An immediate startup, shutdown, and malfunction
report if a startup, shutdown, or malfunction occurs
during a reporting period that is not consistent with
the permittee’s SSMP.
Regulations
A. Initially, a report shall be submitted by fax or
telephone within 2 working days after starting
actions inconsistent with the SSMP and shall
identify the nature of the event and the actions
taken.
B. Subsequently, a report shall be submitted by letter
within 7 working days after the end of the event
(unless alternative arrangements have been
approved by the Air Division) and shall contain the
information specified in 40 CFR §63.10(d)(5)(ii).
Permit No. 408-0009
Page 19 of 34
Emission Unit No. 009 (Glycol Dehydrator)
Summary Page
Description:
1.0 MMBtu/hr ETI natural gas-fired glycol dehydrator/heater
w/condenser and thermal oxidizer
Permitted Operating Schedule:
24 Hours
Day
X
365 Days
Year
=
8760 Hours
Year
Emission limitations:
Emission
Point
No.
009
Description
1.0 MMBtu/hr ETI natural gasfired glycol dehydrator/heater
w/condenser and thermal oxidizer
Permit No. 408-0009
Pollutant
Emission
limit
Regulation
NOx
N/A
N/A
CO
N/A
N/A
VOC
N/A
N/A
SO 2
N/A
N/A
PM
N/A
N/A
BTEX
Equation 1
40 CFR
§63.1275(b)(1)(iii)
Page 20 of 34
Emission Unit No. 009 (Glycol Dehydrator)
Unit Specific Provisos
Federally Enforceable Provisos
Regulations
1. Applicability
(a) This unit is subject to the applicable requirements of ADEM
Admin. Code r. 335-3-16-.03, “Major Source Operating
Permits.”
ADEM Admin. Code r.
335-3-16-.03
(b) This unit is subject to the applicable requirements of 40 CFR
Part 63, Subpart HHH, National Emission Standards for
Hazardous Air Pollutants From Natural Gas Transmission
and Storage Facilities, and meets the definition of an existing
small glycol dehydration unit as defined by 40 CFR §63.1271.
ADEM Admin. Code r.
335-3-11-.06 and 40
CFR Part 63, Subpart
HHH
2. Emission Standards
(a) The permittee shall not cause or allow BTEX (benzene,
toluene, ethyl benzene, and xylene) emissions from this unit
in excess of the allowable emissions rate calculated using
Equation 1 as specified in 40 CFR §63.1275(b)(1)(iii) for
existing small glycol dehydration units:
40 CFR
§63.1275(b)(1)(iii)
EL BTEX =3.10x10-4 x Throughput x C LBTEX x 365 days x 1Mg
yr 1x106 gr
Where:
EL BTEX = Unit specific BTEX emission limit (megagrams/yr)
3.10x10-4 =
BTEX emission limit (gr BTEX/scm-ppmv)
Throughput= annual average daily natural gas throughput
(scm/day)
annual average BTEX concentration of the
C LBTEX =
natural gas at the inlet to the glycol dehydration unit (ppmv)
(b) This unit shall be operated with a thermal oxidizer at all
times.
40 CFR
§63.1281(f)(2)(i)
(c) The permittee shall operate and maintain this unit, including
air pollution control and monitoring equipment, in a manner
consistent with good air pollution control practices for
minimizing emissions at all times, including during startup,
shutdown, and malfunction.
40 CFR §63.1274(h)
(d) The permittee shall not cause or allow visible emissions with
a six-minute average opacity greater than 20% to be emitted
more than once during any 60-minute period. The permittee
shall not cause or allow visible emissions with a six-minute
average opacity greater than 40% to be emitted at any time.
ADEM Admin. Code r.
335-3-4-.01(1)
Permit No. 408-0009
Page 21 of 34
Federally Enforceable Provisos
Regulations
3. Compliance and Performance Test Methods and Procedures
(a)
(b)
(c)
The permittee shall determine the actual flowrate of natural
gas to the glycol dehydration unit by either:
(i)
Installing and operating a monitoring instrument that
directly measures natural gas flowrate to the glycol
dehydration unit with an accuracy of plus or minus 2%
or better.
The permittee shall convert the annual
natural gas flowrate to a daily average by dividing the
annual flowrate by the number of days per year the
glycol dehydration unit processed natural gas; or
(ii)
The permittee shall document the actual annual average
natural gas flowrate to the glycol dehydration unit.
The permittee shall determine the actual average benzene or
BTEX emissions from this unit by either:
(i)
Using the model GRI-GLYCalc Version 3.0 or higher,
and the procedures presented in the associated GRIGLYCalc Technical Reference Manual. Inputs to the
model shall be representative of actual operating
conditions of this unit and may be determined using
procedures in the Gas Research Institute (GRI) report
entitled
“Atmospheric
Rich/Lean
Method
for
Determining Glycol Dehydrator Emissions”; or
(i)
The average mass rate of benzene or BTEX emissions for
this unit shall be determined by 40 CFR Part 60,
Appendix A, Reference Method 18, or ASTM D6420-99
in accordance with a protocol/method approved in
advance by the Air Division.
40 CFR §63.1282(a)(1)
40 CFR §63.1282(a)(2)
The permittee shall determine that this unit has no
detectable emissions. The procedure shall be conducted in
association with 40 CFR Part 60, Appendix A, Reference
Method 21 in accordance with 40 CFR §63.1282(b) and a
protocol/method approved in advance by the Air Division.
40 CFR §63.1282(b)
(d) The permittee shall demonstrate that the thermal oxidizer
achieves the performance requirements of 40 CFR
§63.1281(f)(1) by conducting a performance test as specified
in 40 CFR §63.1282(d)(3)(i) through (v), along with a
protocol/method approved in advance by the Air Division.
40 CFR §63.1282(d)
(e)
Subsequent performance testing shall be conducted on the
thermal oxidizer no more than 60 months after the previous
test.
40 CFR
§63.1282(d)(3)(vi)(B)
(f)
If testing is required for this unit, opacity shall be
determined by 40 CFR Part 60, Appendix A, Reference
Method 9.
40 CFR Part 60,
Permit No. 408-0009
Appendix A
Page 22 of 34
Federally Enforceable Provisos
Regulations
4. Emission Monitoring
(a) The permittee shall conduct an initial performance test no
later than February 15, 2016, to ensure that the thermal
oxidizer achieves the performance requirements of 40 CFR
§63.1281(f)(1).
40 CFR
§63.1282(d)(3)(vi)
(b) Periodic performance tests shall be conducted on the thermal
oxidizer no later than 60 months following the previous test
or whenever a source desires to establish a new operating
limit.
40 CFR
§63.1282(d)(3)(vi)
(c) Compliance for the thermal oxidizer shall be demonstrated by
the following requirements:
40 CFR §63.1282(e)
(i) The permittee shall establish a site specific maximum or
minimum monitoring parameter value (as appropriate for
the control device) according to the requirements specified
in 40 CFR §63.1283(d)(5)(i).
(ii) The permittee shall calculate the daily average of the
applicable monitored parameter in accordance with 40
CFR §63.1283(d)(4), except that the inlet gas flowrate to
the thermal oxidizer shall not be averaged.
(iii) Compliance is achieved when the daily average of the
monitoring value calculated is either equal to or greater
than the minimum or equal to or less than the maximum
monitoring value established.
For inlet gas flowrate,
compliance with the operating parameter limit is achieved
when the value is equal to or less than the value
established under the performance test conducted under
40 CFR §63.1282(d).
(d) If at any time the condenser meets the definition of a control
device as defined by 40 CFR §63.1271, the permittee shall
notify the Air Division within 30 days of the change in status.
40 CFR §63.1271
(e) If the condenser meets the definition of a control device as
defined by 40 CFR §63.1271, the permitee shall comply with
the following requirements:
(i) Within 180 days from the change in the condenser’s
status, the permittee shall establish a condenser
performance curve showing the relationship between
condenser outlet temperature and condenser control
efficiency. The curve shall be established as follows:
Permit No. 408-0009
40 CFR
§63.1283(d)(5)(ii)
Page 23 of 34
Federally Enforceable Provisos
Regulations
A. If the permittee conducts a performance test in
accordance with the requirements of 40 CFR
§63.1282(d)(3) to demonstrate that the condenser
achieves the applicable performance requirements
of 40 CFR §63.1281(f)(1), then the condenser
performance curve shall be based on values
measured during the performance test and
supplemented as necessary by control device design
analysis,
or
control
device
manufacturer’s
recommendations, or a combination of both.
40 CFR
§63.1283(d)(5)(ii)(A)
B. If the permittee uses a control device design
analysis in accordance with the requirements of 40
CFR §63.1282(d)(4)(i) to demonstrate that the
condenser achieves the applicable performance
requirements of 40 CFR §63.1281(f)(1), then the
condenser performance curve shall be based on the
condenser
design
analysis
and
may
be
supplemented by the control device manufacturer’s
recommendation.
40 CFR
§63.1283(d)(5)(ii)(B)
C. As an alternative to 40 CFR §63.1283(d)(5)(ii)(B),
the permittee may elect to use the procedures
documented in the GRI report entitled “Atmospheric
for
Determining
Glycol
Rich/Lean
Method
Dehydrator Emissions” as inputs for the model
GRI-GLYCalc, Version 3.0 or higher, to generate a
condenser performance curve.
40 CFR
§63.1283(d)(5)(ii)(C)
(ii) Compliance shall be demonstrated using the requirements
specified in 40 CFR §63.1282(e)(1) through (3). As an
alternative, the permittee may demonstrate compliance as
specified in 40 CFR §63.1282(f). The permittee may
switch between compliance with 40 CFR §63.1282(e) and
compliance with 40 CFR §63.1282(f) only after at least 1
year of operation in compliance with the selected
approach. Notification of such change in the compliance
method shall be reported in the next Periodic Report
following the change, as required in 40 CFR §63.1285(e).
40 CFR §63.1282(e)
(f) The closed-vent system shall route all gases, vapors, and
fumes emitted from the material of this unit to the control
device.
40 CFR §63.1281(c)(1)
(g) The closed-vent system shall be designed and operated with
no detectable emissions.
40 CFR §63.1281(c)(2)
(h) If the closed-vent system contains one or more bypass devices
that could be used to divert all or a portion of the gases,
vapors, or fumes from entering the control device, the
permittee shall:
40 CFR §63.1281(c)(3)
Permit No. 408-0009
Page 24 of 34
Federally Enforceable Provisos
Regulations
(i) At the inlet to the bypass device that could divert the
stream away from the control device to the atmosphere,
properly install, calibrate, maintain, and operate a flow
indicator that is capable of taking periodic readings and
sounding an alarm when the bypass device is open such
that the stream is being, or could be, diverted away from
the control device to the atmosphere; or
(ii) Secure the bypass device valve installed at the inlet to the
bypass device in the non-diverting position using a carseal or a lock-and-key type configuration.
(i) For each closed-vent system joints, seams, or other
connections that are permanently or semi-permanently
sealed, the permittee shall:
40 CFR §63.1283(c)
(i) Conduct an initial inspection according to the procedures
specified in 40 CFR §63.1282(b) to demonstrate that the
closed-vent system operates with no detectable emissions.
(ii) Conduct annual visual inspections for defects that could
result in air emissions. Defects include, but are not
limited to, visual cracks, holes, or gaps in piping; loose
connections; or broken or missing caps or other closure
devices. The permittee shall monitor a component or
connection using the procedures specified in 40 CFR
§63.1282(b) to demonstrate that it operates with no
detectable emissions following any time the component or
connection is repaired or replaced or the connection is
unsealed.
(j) For closed-vent system components other than those specified
in paragraph (h), the permittee shall:
40 CFR §63.1283(c)
(i) Conduct an initial inspection according to the procedures
specified in 40 CFR §63.1282(b) to demonstrate that the
closed-vent system operates with no detectable emissions.
(ii) Conduct annual inspections according to the procedures
specified in 40 CFR §63.1282(b) to demonstrate that the
components or connections operate with no detectable
emissions.
(iii) Conduct annual visual inspections for defects that could
result in air emissions. Defects include, but are not
limited to, visual cracks, holes, or gaps in ductwork; loose
connections; or broken or missing caps or other closure
devices.
(k) For each bypass device, except as provided for in 40 CFR
§63.1281(c)(3)(ii), the permittee shall:
Permit No. 408-0009
40 CFR §63.1283(c)
Page 25 of 34
Federally Enforceable Provisos
Regulations
(i) At the inlet to the bypass device that could divert the
stream away from the thermal oxidizer to the atmosphere,
set the flow indicator to take a reading at least once every
15 minutes; or
(ii) If the bypass device valve installed at the inlet to the
bypass is secured in the non-diverting position using a
car-seal or a lock-and-key type configuration, visually
inspect the seal or closure mechanism at least once every
month to verify that the valve is maintained in the nondiverting position and the vent stream is not diverted
through the bypass device.
(l) In the event that a leak or defect is detected, the permittee
shall repair the leak or defect as soon as practicable.
40 CFR §63.1283(c)
(i) The first attempt at repair shall be made no later than five
(5) calendar days after the leak is detected. Repairs shall
be completed no later than fifteen (15) calendar days after
the leak is detected.
(ii) Delay of repairs of a closed-vent system for which leaks or
defects have been detected is allowed if the repair is
technically infeasible without a shutdown as defined in 40
CFR §63.1271, or if the permittee determines that
emissions resulting from immediate repair would be
greater than the fugitive emissions likely to result from
delay of repair. Repairs of such equipment shall be
completed by the end of the next shutdown.
(m) The permittee shall install and operate a continuous
parameter monitoring system (CPMS) in accordance with the
requirements of 40 CFR §63.1283(d)(3) through (7). The
CPMS shall be designed and operated so that a determination
can be made on whether the control device is achieving the
applicable performance requirements.
40 CFR §63.1283(d)
(n) The CPMS shall measure data values at least every hour and
record either:
40 CFR §63.1283(d)
(i) Each measured data value; or
(ii) Each block average value for each 1-hour period or
shorter periods calculated from all measured data values
If values are measured more
during each period.
frequently than once per minute, a single value for each
minute may be used to calculate the hourly (or shorter
period) block average instead of all measured values.
Permit No. 408-0009
Page 26 of 34
Federally Enforceable Provisos
Regulations
(o) The permittee shall prepare a site-specific monitoring plan
that addresses the monitoring system design, data collection,
and the quality assurance and quality control elements
outlined in 40 CFR §63.1283(d) and 40 CFR §63.8(d). Each
CPMS must be installed, calibrated, operated, and maintained
in accordance with the procedures in the approved sitespecific monitoring plan. Using the process described in 40
CFR §63.8(f)(4), the permittee may request approval of
monitoring system quality assurance and quality control
procedures alternative to those specified in 40 CFR
§63.1283(d)(1)(ii)(A) through (E).
40 CFR §63.1283(d)
(p) The permittee must conduct the CPMS equipment
performance checks, system accuracy audits, or other audit
procedures specified in the site-specific monitoring plan at
least every 12-months.
40 CFR §63.1283(d)
(q) The permittee must conduct a performance evaluation of the
CPMS in accordance with the site-specific monitoring plan.
40 CFR §63.1283(d)
(r) Except for periods of monitoring system malfunctions, repairs
associated with monitoring system malfunctions, and
required monitoring system quality assurance or quality
control activities (including, as applicable, system accuracy
audits and required zero and span adjustments), the CPMS
must be operated at all times the glycol dehydrator is
operating.
40 CFR §63.1282(e)(4)
(s) Data recorded during monitoring system malfunctions,
repairs associated with monitoring system malfunctions, or
required monitoring system quality assurance or control
activities may not be used in calculations used to report
emissions or operating levels. All the data collected during all
other required data collection periods must be used in
assessing the operation of the control device and associated
control system.
40 CFR §63.1282(e)(5)
(t) Except for periods of monitoring system malfunctions, repairs
associated with monitoring system malfunctions, and
required quality monitoring system quality assurance or
quality control activities (including, as applicable, system
accuracy audits and required zero and span adjustments),
failure to collect required data is a deviation of the monitoring
requirements.
40 CFR §63.1282(e)(6)
(u) An excursion for a given control device is determined to have
occurred when the monitoring data or lack of monitoring data
result in any one of the criteria specified in 40 CFR
§63.1283(d)(6)(i) through (v) being met.
When multiple
operating parameters are monitored for the same control
device and during the same operating day, and more than one
of these operating parameters meets an excursion criterion
specified in 40 CFR §63.1283(d)(6)(i) through (v), then a single
excursion is determined to have occurred for the control
device for that operating day.
40 CFR §63.1283(d)(6)
Permit No. 408-0009
Page 27 of 34
Federally Enforceable Provisos
Regulations
(v) The permittee shall certify semiannually:
(i) That only natural gas
dehydrator/heater; and
was
fired
ADEM Admin. Code r.
335-3-16-.05(c)
in
the
glycol
(ii) That only natural gas was fired in the thermal oxidizer
with the exception of the waste gases generated by the
glycol dehydrator/heater unit operations that are
combusted and destroyed in the thermal oxidizer.
5. Recordkeeping and Reporting Requirements
(a) The permittee shall maintain the following records and all
applicable records specified in 40 CFR §63.1284. These
records include, but may not be limited to:
ADEM Admin. Code r.
335-3-16-.05(c) and
40 CFR §63.1284
(i) All information, including reports and notifications,
required by 40 CFR Part 63, Subpart HHH. The files shall
be retained for at least 5 years following the date of each
occurrence, measurement, maintenance, corrective action,
report or period. The most recent 12 months of records
shall be retained on site or shall be accessible from a
central location by hardcopy, computer or other means.
The following 4 years of records may be retained offsite.
All applicable records shall be maintained in such a
manner that they can be readily accessed.
(ii) All records specified in 40 CFR §63.10(b)(2)
(iii) Records specified in 40 CFR §63.10(c), for each
monitoring system operated by the permittee in
accordance with 40 CFR §63.1283(d).
(iv) Records of the time and duration of all such periods
during process or control device operation when monitors
are not operating or failed to collect required data,
including:
A. Monitoring system breakdowns, repairs, calibration
checks,
and
zero
(low-level)
and
high-level
adjustments.
B. Periods of non-operation resulting in cessation of the
emissions to which the monitoring applies; and
C. Excursions due to invalid data as defined in 40 CFR
§63.1283(d)(6)(iii).
(v) Continuous records of the equipment operating
parameters specified to be monitored under 40 CFR
§63.1283(d) or specified by the Administrator in
accordance with 40 CFR §63.1283(d)(3)(iii).
Permit No. 408-0009
Page 28 of 34
Federally Enforceable Provisos
Regulations
(vi) Records of the daily average value of each continuously
monitored parameter for each operating day determined
according to the procedures specified in 40 CFR
§63.1283(d)(4), except as specified in 40 CFR
§63.1284(b)(4)(ii)(A) through (C).
(vii) Hourly records of the times and durations of all periods
when the vent stream is diverted from the control device
or the device is not operating.
(viii) Records identifying all parts of the closed-vent system
that are designated as unsafe or difficult to inspect, and
an explanation of why the equipment is unsafe or difficult
to inspect and the plan for inspecting the equipment.
(ix) For each inspection conducted in accordance with 40 CFR
§63.1283(c), during which a leak or defect is detected, a
record of the information specified in 40 CFR
§63.1284(b)(7)(i) through (viii).
(x) For each inspection conducted in accordance with 40 CFR
§63.1283(c) during which no leaks or defects are detected,
a record that the inspection was performed, the date of
the inspection, and a statement that no leaks or defects
were detected.
(xi) The permittee shall maintain records of the occurrence
and duration of each malfunction of operation (i.e. process
equipment) or the air pollution control equipment and
monitoring equipment.
The permittee shall maintain
records of actions taken during periods of malfunction to
minimize emissions in accordance with 40 CFR
§63.1274(h), including corrective actions to restore
malfunctioning process and air pollution control and
monitoring equipment to its normal or usual manner of
operation.
(b) The permittee shall submit the following notifications and all
applicable notifications specified in 40 CFR §63.1285. These
notifications include, but may not be limited to:
(i)
The permittee shall submit a written notification of the
intent to conduct a performance test to the Air Division
at least 60 days prior to conducting a performance test.
The notification shall include a copy of the site-specific
test plan required by 40 CFR §63.7(c)(2).
(ii)
The permittee shall submit a written notification of the
intent to conduct a performance evaluation of the
continuous monitoring system to the Air Division at least
60 days prior to conducting a performance evaluation.
The notification shall include a copy of the site-specific
performance evaluation test plan required by 40 CFR
§63.8(e)(2).
Permit No. 408-0009
ADEM Admin. Code r.
335-3-16-.05(c) and
40 CFR §63.1285
Page 29 of 34
Federally Enforceable Provisos
Regulations
(iii) The permittee shall submit a Notification of Compliance
Status Report as required under 40 CFR §63.9(h) by April
12, 2016. In addition, the Notification of Compliance
Status Report shall contain the information specified in
40 CFR §63.1285(d)(1) through (12).
(c) The permittee shall submit a Periodic Report containing the
information specified in 40 CFR §63.1285(e)(2)(i) through (xiii)
as applicable. The report shall be submitted no later than 60
days after the end of each semiannual reporting period
(January 1 – June 30 and July 1 – December 31).
(i)
ADEM Admin. Code r.
335-3-16-.05(c) and
40 CFR §63.1285
If there is a malfunction during the reporting period, the
Periodic Report shall include the number, duration, and
a brief description for each type of malfunction which
occurred during the reporting period and which caused
or may have caused any applicable emission limitation to
be exceeded. The report must also include a description
of actions taken by the permittee during the malfunction
to minimize emissions in accordance with 40 CFR
§63.1274(h).
(d) The permittee shall submit a Semiannual Monitoring Report
(SMR), as required by General Permit Proviso No. 21(a), that
includes a certification that:
(i) Only
natural
gas
dehydrator/heater;
was
fired
in
the
ADEM Admin. Code r.
335-3-16-.05(c)
glycol
(ii) And that only natural gas was fired in the thermal oxidizer
with the exception of the waste gases generated by the
glycol dehydrator/heater unit operations that are
combusted and destroyed by the thermal oxidizer; and
(iii) The report shall be submitted no later than 60 days after
the end of each semiannual reporting period (January 1 –
June 30 and July 1 – December 31).
Permit No. 408-0009
Page 30 of 34
Emission Unit No. 010 (Emergency Generator No. 2)
Summary Page
Description:
468 hp Generac 13.3GTA MG300, 4-Stroke, Rich-Burn Natural Gas-Fired
Reciprocating Engine with 3-Way Catalytic Converter (NSCR) Operating as
an Emergency Generator
Permitted Operating Schedule:
24 Hours
Day
X
365 Days
Year
=
8760 Hours
Year
Emission limitations:
Emission
Point
No.
010
Description
468 hp Generac 13.3GTA
MG300, 4-Stroke, Rich-Burn
Natural Gas-Fired Reciprocating
Engine with 3-Way Catalytic
Converter (NSCR) Operating as
an Emergency Generator
Permit No. 408-0009
Pollutant
Emission
limit
Regulation
NO x
2.0 g/Hp-hr or
160 ppmvd at
15% O2
ADEM Admin.
Code r. 335-3-10.02(88) and 40
CFR §60.4233(e)
CO
4.0 g/Hp-hr or
540 ppmvd at
15% O2
ADEM Admin.
Code r. 335-3-10.02(88) and 40
CFR §60.4233(e)
VOC
1.0 g/Hp-hr or
86 ppmvd at
15% O2
ADEM Admin.
Code r. 335-3-10.02(88) and 40
CFR §60.4233(e)
SO 2
N/A
N/A
PM
N/A
N/A
HAP
N/A
N/A
Page 31 of 34
Emission Unit No. 010 (Emergency Generator No. 2)
Unit Specific Provisos
Federally Enforceable Provisos
Regulations
1. Applicability
(a) This unit is subject to the applicable requirements of ADEM
Admin. Code r. 335-3-16-.03, “Major Source Operating Permits.”
ADEM Admin. Code r.
335-3-16-.03
(b) This unit is an affected source under 40 CFR Part 63, Subpart
ZZZZ, National Emission Standards for Hazardous Air Pollutants
for Stationary Reciprocating Internal Combustion Engines.
ADEM Admin. Code r.
335-3-11-.06(103) and
40 CFR Part 63,
Subpart ZZZZ
(c) This unit is subject to the applicable provisions of 40 CFR Part
60, Subpart JJJJ, Standards of Performance for Stationary
Spark Ignition Internal Combustion Engines (SI ICE).
The
permittee shall only operate this unit as an emergency generator
as defined in this standard.
ADEM Admin. Code r.
335-3-10-.02(88) and
40 CFR
§60.4230(a)(4)(iv) and
§60.4243(d)
2. Emission Standards
(a) The permittee shall not cause or allow emissions of nitrogen
oxides (NOx) from this unit to exceed 2.0 g/hp-hr or 160 ppmvd
at 15% O 2.
ADEM Admin. Code r.
335-3-10-.02(88) and
40 CFR §60.4233(e)
(b) The permittee shall not cause or allow emissions of carbon
monoxide (CO) from this unit to exceed 4.0 g/hp-hr or 540
ppmvd at 15% O 2.
ADEM Admin. Code r.
335-3-10-.02(88) and
40 CFR §60.4233(e)
(c) The permittee shall not cause or allow emissions of volatile
organic compounds (VOC) from this unit to exceed 1.0 g/hp-hr
or 86 ppmvd at 15% O 2.
ADEM Admin. Code r.
335-3-10-.02(88) and
40 CFR §60.4233(e)
(d) The permittee shall not discharge more than one six-minute
average opacity greater than 20% during any 60-minute period
from this unit. At no time shall the permittee discharge a sixminute average opacity of particulate emissions greater than
40% from this unit.
ADEM Admin. Code r.
335-3-4-.01(1)
(e) The permittee shall operate and maintain the certified stationary
SI internal combustion engine and control device according to
the manufacturer's emission-related written instructions and
shall keep records of conducted maintenance to demonstrate
compliance.
40 CFR §60.4243(a)(1)
(f) The permittee shall use an air-to-fuel ratio controller with the
operation of 3-way catalyst/non-selective catalytic reduction.
40 CFR §60.4243(g)
3. Compliance and Performance Test Methods and Procedures
(a) If testing is required, opacity shall be determined by 40 CFR Part
60, Appendix A, Reference Method 9.
Permit No. 408-0009
ADEM Admin. Code r.
335-3-1-.05
Page 32 of 34
Federally Enforceable Provisos
Regulations
(b) If testing is required, the nitrogen oxides (NOx) emission rate of
this unit shall be determined by EPA Reference Methods 1, 2, 3
and 4 or 19, and EPA Reference Method 7E in Appendix A of 40
CFR Part 60. Alternate test methods may be used provided prior
approval by the Air Division is granted.
ADEM Admin. Code r.
335-3-1-.05
(c) If testing is required, the carbon monoxide (CO) emission rate of
this unit shall be determined by EPA Reference Methods 1, 2, 3
and 4 or 19, and EPA Reference Method 10 in Appendix A of 40
CFR Part 60. Alternate test methods may be used provided prior
approval by the Air Division is granted.
ADEM Admin. Code r.
335-3-1-.05
(d) If testing is required, the volatile organic compounds (VOC)
emission rate of this unit shall be determined by EPA Reference
Methods 1, 2, 3 and 4 or 19, and EPA Reference Methods 25A
and/or 18 in Appendix A of 40 CFR Part 60. Alternate test
methods may be used provided prior approval by the Air Division
is granted.
ADEM Admin. Code r.
335-3-1-.05
4. Emission Monitoring
(a) The permittee shall install and operate a non-resettable hour
meter on this engine.
40 CFR §60.4237(b)
(b) The permittee shall not operate this engine except as provided in
40 CFR §60.4243(d)(1) through (d)(3), which includes but may
not be limited to:
40 CFR §60.4243(d)
(i)
Emergency situations;
(ii)
A total of 100 hours per year or less for the purposes
allowed by 40 CFR §60.4243(d)(2)(i)-(iii), which include
maintenance checks and readiness testing, emergency
demand response, and periods where deviation of voltage
or frequency of 5 percent or greater below standard
voltage or frequency; and
(iii)
A total of 50 hours per year or less for the non-emergency
situations allowed by 40 CFR §60.4243(d)(3); however,
those 50 hours are counted towards the 100 hours per
year allowed for maintenance checks and readiness
testing, emergency demand response, and voltage or
frequency deviations of 5 percent or greater.
(c) This unit is limited to the use of natural gas only as a fuel to fire
the engine. However, the permittee may operate the engine using
propane for a maximum of 100 hours per year and an alternate
fuel solely during emergency operations, but must keep records
of such use.
ADEM Admin. Code r.
335-3-16-.05(c) and 40
CFR §60.4243(e)
5. Recordkeeping and Reporting Requirements
(a) The permittee shall keep the following records for this engine in
accordance with 40 CFR §60.4245. At a minimum, these
records shall include:
Permit No. 408-0009
ADEM Admin. Code r.
335-3-16-.05(c) and
40 CFR §60.4245
Page 33 of 34
Federally Enforceable Provisos
Regulations
(i) A copy of all notifications submitted to comply with
NSPS, Subpart JJJJ and all documentation supporting
any notification;
(ii) For each period of operation, the permittee shall record
the date and length of operation and the reason the
engine was in operation during that time. For periods of
operation designated as “emergency operation,” the
records shall reflect what classified the operation as
emergency. The permittee shall subtotal the total
number of hours the engine was operated during a
calendar year by the reason the engine was in operation;
(iii) Documentation from the manufacturer that the engine is
certified to meet the applicable emission standards; and
(iv) The dates and nature of maintenance performed.
(b) The permittee shall submit a Semiannual Monitoring Report, as
required by general Permit Proviso No. 21(a), no later than 60
days after the end of each semiannual reporting period
(January 1 – June 30 and July 1 – December 31). The report
shall include a statement addressing whether only natural gas
was fired in these units during the reporting period.
Permit No. 408-0009
ADEM Admin. Code r.
335-3-16-.05(c)
Page 34 of 34