MEMORANDUM March 26, Phillip Fielder, P.E., Permits and Engineering Group Manager

Transcription

1 OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION DRAFT MEMORANDUM March 26, 2013 TO: THROUGH: THROUGH: THROUGH: FROM: SUBJECT: Phillip Fielder, P.E., Permits and Engineering Group Manager Kendal Stegmann, Sr. Environmental Manager, Compliance & Enforcement Phil Martin, P.E., Engineering Manager, Existing Source Permits Section Peer Review Iftekhar Hossain, P.E., Engineering Section Evaluation of Permit Application No TVR2 Enbridge G & P (Oklahoma), LP Elk City Gas Processing Plant Section 15, T10N, R21W, Elk City, Beckham County, Oklahoma Latitude: N and Longitude: W Directions: Go 3.9 miles south on Hwy-6 of Elk City, turn west and go 0.14 mile into the facility which is located north side of the road. SECTION I. INTRODUCTION Enbridge G & P (Oklahoma), LP (Enbridge) has submitted an application for renewal of their Title V operating permit for the Elk City Gas Processing Plant. The facility is currently operating under Permit No TVR (M-3), issued on January 22, The facility is a natural gas processing plant (NAIC Code , SIC Code 1321) located in an attainment area. The emission sources at the facility consist of two 4,498-hp Solar Centaur C3066RTA turbines (C-1 and C-2), one 1,340-hp Caterpillar 3516LE compressor engine (C-6), two mole sieve regenerator heaters (H-1 and H-2), an amine unit that is ducted to the amine off-gas enclosed flare (FL-1), three condensate storage tanks (T-1, T-2, and T-3), truck loading operations (L-1), and site fugitives (FUG). There are also engine oil tanks, engine coolant tanks, amine tanks, and pressurized condensate and NGL tanks which are considered insignificant sources or have no emissions limitations. No dehydration unit is located at the facility. Since the facility emits more than 100 TPY of a regulated pollutant, it is subject to Title V permitting requirements. Emission units (EU) are arranged into Emission Unit Groups (EUG) in the Equipment section. Pipeline-grade natural gas is the primary fuel with the facility being operated continuously.

2 PERMIT MEMORANDUM TVR2 DRAFT Page 2 SECTION II. PROCESS DESCRIPTION The Elk City gas processing plant is a cryogenic natural gas processing plant (SIC 1321) that processes field gas to produce residue gas and natural gas liquids (NGL). Field gas enters the plant and the gas is split between two processing skids, each following a similar process. The gas is then routed through a mole sieve bed to remove water. The mole sieve regenerator heaters (H-1 for Skid 1 and H-2 for Skid 2) provide heat to regenerate the bed when it becomes saturated. The dry gas is then routed through gas/liquid and gas/gas exchangers, a cold separator, an expander turbine and a demethanizer. Liquids that drop out in the exchangers, separator and expander turbine are routed to the demethanizer. Liquid product from the demethanizer of each skid is routed to a single amine contactor to remove excess CO 2 and H 2 S and then to product (liquid) pipelines. CO 2 and H 2 S emissions from the amine reboiler vent are routed to the amine off-gas enclosed flare (FL-1). The applicant submitted a gas analysis performed from August 2012 to February 2013, which indicated an average 0.5 ppm of H 2 S in the inlet gas. Conservatively, an inlet concentration of 8 ppm of H 2 S has been used in the calculations to show compliance with the applicable regulations. This low sulfur content, combined with the presence of the flare with 98% control, results in very low SO 2 emissions. The plant has a processing capacity of 130 MMscf/day. The majority of the residue gas (mostly methane) from the demethanizer is routed to the compressor inlet, compressed and discharged into a gas pipeline. A portion of the residue gas is used as fuel in the fired equipment (C-1, C-2, C-6, H-1, and H-2). Condensate is stored in the condensate storage tanks (TK-1, TK-2, and TK-3) and removed by truck (L-1). SECTION III. EQUIPMENT Similar types of emission units have been grouped together as emissions unit group (EUG) to facilitate the tracking of the emission units. The following tables show the listing of all equipment at the facility. EUG-1 has been reserved for general requirements that apply to all emission sources at the site. EUG 2. Turbines EU Point Mfg. Date/ Make/Model HP Serial Number ID# ID# (Const. Date) C-1 C-1 Solar Centaur C3066RTA 4,498 OHK09-C /(12/06) C-2 C-2 Solar Centaur C3066RTA 4,498 OHK09-C /(10//99) EUG 3: Internal Combustion Engine EU Point Serial Mfg. Date/ EU Name/Model HP ID# ID# Number (Const. Date) C-6 C-6 Caterpillar 3516LE compressor engine 1, /2008 (4/2009)

3 PERMIT MEMORANDUM TVR2 DRAFT Page 3 EUG 4. Regeneration Heaters EU ID# Point ID# Description Capacity/Size Construction Date H-1 H-1 Molecular Sieve Regeneration Heater 6.0 MMBtu/hr 2000 H-2 H-2 Molecular Sieve Regeneration Heater 2.26 MMBtu/hr 1993 EUG 5. Amine Off-Gas Enclosed Flare EU ID # Point ID# Emission Units MMSCF/yr Construction Date FL-1 FL-1 Amine Off-Gas Enclosed Flare 8.59 MMSCF/yr 1983 EUG 6. Condensate Tanks & Flashing Losses EU ID# Point Capacity ID# Gallons (bbl) Material Stored Serial # Construction Date TK-1 TK-1 8,820 (210) Condensate 7348C TK-2 TK-2 8,820 (210) Condensate /98 TK-3 TK-3 16,800 (400) Condensate /2000 EUG 7. Condensate Truck Loading EU ID# Point ID# Material Serviced Construction Date TL-1 TL-1 Condensate Truck Loading 1985 EUG 8. Fugitive VOC Emission Sources EU ID# Point ID# Equipment Service Count Construction Date Valves Residue Gas Flange/Connections Residue Gas 1, FUG-1 FUG-1 Compressor Seals Residue Gas Relief Valves Residue Gas Pump Seals Residue Gas Others Residue Gas EUG 9. Fugitive VOC Emission Sources Subject to LDAR under NSPS Subpart KKK EU ID# Point ID# Equipment Service Count Construction Date Valves Gas/Vapor /2000 Flanges Gas/Vapor 1, /2000 Connectors Gas/Vapor 1, /2000 FUG-2 FUG-2 Pump Seals Light Liquid /2000 Valves Light Liquid /2000 Flanges Light Liquid /2000 Connectors Light Liquid /2000 * Numbers of fugitive components are estimates from the LDAR Master Component List. Numbers of fugitive components change periodically with facility maintenance.

4 PERMIT MEMORANDUM TVR2 DRAFT Page 4 SECTION IV. EMISSIONS Emissions from the turbines and engine are based on manufacturer s data shown below except for NOx emissions from the turbines which are based on the NSPS, Subpart GG limitation. Emissions from the heaters are based on AP-42 (7/98), Section 1.4. Estimated emissions for the tanks are based on AP-42 (1/95), Chapter 7.1. VOC emissions of working and breathing losses for three (3) condensate storage tanks are based on AP-42 (1/98), Chapter 7.1 and a total throughput of 1,800,000 gallons per year. Flash emissions of VOCs from the condensate tanks are estimated using a flash factor determined by laboratory-staged flash analysis and the Equation of State. The flash emissions are combined with the working and breathing losses of the condensate tank emissions (TANKS). Fugitive VOC emissions are based on EPA s 1995 Protocol for Equipment Leak Emission Estimates (EPA-453/R ), equipment counts, and an estimated % C3+. VOC emissions from the truck loading are based on AP-42 (1/95), Chapter 5.2, Transportation and Marketing of Petroleum Liquids, Tables and and an estimated throughput of approximately 1,800,000 gallons per year. Emissions from the amine unit flare are based on AP-42 (1/95), Section 13.5, except SO 2. Emissions of SO 2 from the amine off-gas flare are based on an inlet H 2 S concentration of 8 ppm, a gas throughput of 130 MMscf/day, and an H 2 S combustion efficiency of 98%. Emissions Factors (g/hp-hr) Source Description EU ID # NO X CO VOC Solar Centaur C3066RTA Turbine Engine C-1 (K-610) Solar Centaur C3066RTA Turbine Engine C-2 (K-630) Caterpillar 3516LE Compressor Engine C-6 (2041) Engine/Turbine Stack Parameters Parameter C-1 (K-610) C-2 (K-630) C-6 (2041) Manufacturer Solar Centaur Turbine Solar Centaur Turbine Caterpillar Model C3066RTA C3066RTA G3516LE Horsepower (max) 4,498 4,498 1,340 Fuel Consumption (BTU/hp-hr) 9,802 9,802 8,573 Fuel Usage (SCFH) 42,312 42,312 8,762 Stack Diameter (Inches) Height above Grade (Feet) Exhaust Flow (ACFM) 138, ,405 7,873 Exhaust Temperature ( o F) Moisture Content (%)

5 PERMIT MEMORANDUM TVR2 DRAFT Page 5 Facility-wide Total Potential Emissions NO X CO VOC SO 2 EU lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY C C C H H TK TK TK L FUG FUG FL Totals * Includes working & breathing and flashing losses. The following ppmdv concentrations for turbines were calculated based on the formula in NSPS Subpart GG 40 CFR (a)(2). Maximum Pollutant Concentrations for the Turbines Source NO X ppmdv C-1 (K-610) 165.6* C-2 (K-630) 165.6* * Corrected to 15% oxygen Hazardous Air Pollutants (HAPs) Emissions The internal combustion engine and turbines have emissions of HAP, the most significant being formaldehyde. Formaldehyde emission estimates are based on continuous operations and the emission factors below. The factors for the turbines are from AP-42 Section 3.1 (4/00). The factor for the lean-burn engine is manufacturer s data. Formaldehyde Emissions from the Turbines/Engine EU Source Factor Est. Emissions MMBtu/hr lb/mmbtu lb/hr TPY C-1 Solar Centaur C3066RTA Turbine Engine C-2 Solar Centaur C3066RTA Turbine Engine HP g/hp-hr C-6 Caterpillar 3516LE Engine 1, Totals As shown in the table above, the individual and the total emissions of HAPs do not exceed the major source thresholds of 10/25 TPY. The facility, therefore, is not a major source of HAP.

6 PERMIT MEMORANDUM TVR2 DRAFT Page 6 Based on estimated emissions, the following equipment/emission points are considered as insignificant sources. EU NO X CO VOC lb/hr TPY lb/hr TPY lb/hr TPY H H SECTION V. INSIGNIFICANT ACTIVITIES The insignificant activities identified and justified in the application are duplicated below. Records are available to confirm the insignificance of the activities. Appropriate recordkeeping of activities indicated below with * is specified in the Specific Conditions. 1. Space heaters, boilers, process heaters and emergency flares less than or equal to 5 MMBTUH heat input (commercial natural gas). Heater H-2 meets this criterion. 2. Emissions from crude oil or condensate marine and truck loading equipment operations at crude oil and natural gas production sites where the loading rate does not exceed 10,000 gallons per day averaged over a 30-day period. 3. Emissions from the operation of groundwater remediation wells including but not limited to emissions from venting, pumping, and collecting activities subject to de minimis limits for air toxics and HAPs. 4. * Activities that have the potential to emit no more than 5 TPY (actual) of any criteria pollutant. Heater H-1, lubricating oil storage tanks, and amine storage are in this category. SECTION VI. OKLAHOMA AIR POLLUTION CONTROL RULES OAC 252:100-1 (General Provisions) Subchapter 1 includes definitions but there are no regulatory requirements. [Applicable] OAC 252:100-2 (Incorporation by Reference) [Applicable] This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal Regulations. These requirements are addressed in the Federal Regulations section. OAC 252:100-3 (Air Quality Standards and Increments) [Applicable] Subchapter 3 enumerates the primary and secondary ambient air quality standards and the significant deterioration increments. At this time, all of Oklahoma is in attainment of these standards.

7 PERMIT MEMORANDUM TVR2 DRAFT Page 7 OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Applicable] Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission inventories annually, and pay annual operating fees based upon total annual emissions of regulated pollutants. Emission inventories have been submitted and fees paid for the past years. OAC 252:100-8 (Permits for Part 70 Sources) [Applicable] Part 5 includes the general administrative requirements for Part 70 permits. Any planned changes in the operation of the facility which result in emissions not authorized in the permit and which exceed the Insignificant Activities or Trivial Activities thresholds require prior notification to AQD and may require a permit modification. Insignificant activities mean individual emission units that either are on the list in Appendix I (OAC 252:100) or whose actual calendar year emissions do not exceed the following limits: 5 TPY of any one criteria pollutant 2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any threshold less than 10 TPY for single HAP that the EPA may establish by rule Emissions limitations for criteria pollutants were established from the limits in Permit No TVR and the application for this permit. OAC 252:100-9 (Excess Emissions Reporting Requirements) [Applicable] Except as provided in OAC 252: (a)(1), the owner or operator of a source of excess emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following working day of the first occurrence of excess emissions in each excess emission event. No later than thirty (30) calendar days after the start of any excess emission event, the owner or operator of an air contaminant source from which excess emissions have occurred shall submit a report for each excess emission event describing the extent of the event and the actions taken by the owner or operator of the facility in response to this event. Request for affirmative defense, as described in OAC 252: , shall be included in the excess emission event report. Additional reporting may be required in the case of ongoing emission events and in the case of excess emissions reporting required by 40 CFR Parts 60, 61, or 63. OAC 252: (Open Burning) [Applicable] Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in this subchapter. OAC 252: (Particulate Matter) [Applicable] This subchapter specifies a particulate matter (PM) emissions limitation of 0.6 lb/mmbtu from fuel-burning equipment with a rated heat input of 10 MMBTUH or less. The 4,498-hp turbines (C-1 and C-2) are rated at approximately 44.1 MMBTUH and are limited to approximately lb/mmbtu. For external combustion units burning natural gas, AP-42, Table (7/98), lists the total PM emissions for natural gas to be 7.6 lb/mmft 3 or about lb/mmbtu. For 4- cycle rich-burn and lean-burn engines burning natural gas, AP-42 (7/00), lists the total PM emissions as and 0.01 lb/mmbtu, respectively. For stationary gas turbines, AP-42 (4/00), Sec. 3.1 lists the total PM emissions from natural gas-fired turbines to be

8 PERMIT MEMORANDUM TVR2 DRAFT Page 8 lbs/mmbtu. The permit requires the use of natural gas for all fuel-burning equipment to ensure compliance with Subchapter 19. OAC 252: (Visible Emissions and Particulates) [Applicable] No discharge of greater than 20% opacity is allowed except for short-term occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. When burning natural gas there is very little possibility of exceeding these standards. OAC 252: (Fugitive Dust) [Applicable] No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. Under normal operating conditions, this facility will not cause a problem in this area, therefore it is not necessary to require specific precautions to be taken. OAC 252: (Sulfur Compounds) [Applicable] Part 2 limits the ambient air impact of hydrogen sulfide (H 2 S) emissions from any new or existing source to 0.2 ppm for a 24-hour average (equivalent to 280 g/m 3 ).The amine unit will be limited to 0.3 lb/hr H 2 S from the amine unit still vent. Given the stack data for the amine unit, with 98% conversion of H 2 S in the flare, AERSCREEN modeling shows that this will result in a maximum ambient impact of approximately 0.35 µg/m 3 on a 24-hour average, which is in compliance with this part. Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1, 1972). For gaseous fuels the limit is 0.2 lb/mmbtu heat input averaged over 3 hours. For fuel gas having a gross calorific value of 1,000 BTU/SCF, this limit corresponds to fuel sulfur content of 1,203-ppmv. The permit requires the use of gaseous fuel with sulfur content less than 343-ppmv to ensure compliance with Subchapter 31. Part 5 also requires oxidation or removal of sulfur compounds unless H 2 S emissions are 0.3 lb/hr or less. The off-gas from the amine unit is combusted in the amine off-gas enclosed flare. The H 2 S of 8 ppmv in 130 MMscf/day gas with 98% control efficiency is approximately equivalent to 0.08 lb/hr. The permit will require monthly testing of the inlet gas for measuring H 2 S concentration to show compliance with 0.3 lb/hr limit of this part. All applicable requirements have been incorporated into the permit. Part 5 also limits Sulfur dioxide (SO 2 ) emissions, calculated as sulfur dioxide, from any new gas sweetening plant by use of a sulfur recovery plant prior to release of the exhaust gas to the atmosphere. A facility is exempt from this requirement if it emits 100 lb/hr or less of sulfur dioxides expressed as sulfur dioxide, two-hour average. The requirements can be met alternatively by establishing that the sulfur content of the acid gas stream from any gas sweetening plant or refinery process is 0.54 long ton/day (LT/D) or less. The SO 2 emission from the amine unit is 0.04 LT/D; therefore, exempt from this requirement. OAC 252: (Nitrogen Oxides) [Not Applicable] None of the units exceed the 50-MMbtu/hr threshold for fuel combustion and therefore are not applicable to this subchapter.

9 PERMIT MEMORANDUM TVR2 DRAFT Page 9 OAC 252: (Carbon Monoxide) [Not Applicable] This facility has none of the affected sources: gray iron cupola, blast furnace, basic oxygen furnace, petroleum catalytic cracking unit, or petroleum catalytic reforming unit. OAC 252: (Volatile Organic Compounds) [Applicable] Part 3 requires new storage tanks constructed after December 28, 1974, with a capacity of 400 gallons or more and containing a VOC with a vapor pressure greater than 1.5-psia at maximum storage temperature to be equipped with a permanent submerged fill pipe or with an organic vapor recovery system. The condensate tanks are subject to this rule. Part 3 requires loading facilities with a throughput equal to or less than 40,000 gallons per day to be equipped with a system for submerged filling of tank trucks or trailers if the capacity of the vehicle is greater than 200 gallons. The loading operation is subject to this rule. Part 5 limits the VOC content of coatings used in coating operations. This facility does not normally conduct coating or painting operations except for routine maintenance of the facility and equipment which is exempt. Part 7 requires all effluent water separators openings or floating roofs to be sealed or equipped with an organic vapor recovery system. No effluent water separators are located at this facility. Part 7 also requires fuel-burning equipment to be operated and maintained so as to minimize emissions. Temperature and available air must be sufficient to provide essentially complete combustion. OAC 252: (Toxic Air Contaminants (TAC)) [Applicable] This subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in areas of concern (AOC). Any work practice, material substitution, or control equipment required by the Department prior to June 11, 2004, to control a TAC, shall be retained, unless a modification is approved by the Director. Since no AOC has been designated there are no specific requirements for this facility at this time. OAC 252: (Sampling and Testing Methods) [Applicable] This subchapter provides general requirements for testing, monitoring and recordkeeping and applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To determine compliance with emissions limitations or standards, the Air Quality Director may require the owner or operator of any source in the state of Oklahoma to install, maintain and operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All required testing must be conducted by methods approved by the Air Quality Director and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests. Emissions and other data required to demonstrate compliance with any federal or state emission limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any required testing or monitoring not conducted in accordance with the provisions of this subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.

10 PERMIT MEMORANDUM TVR2 DRAFT Page 10 The following Oklahoma Air Pollution Control Rules are not applicable to this facility: OAC 252: Alternative Emissions Reduction not requested OAC 252: Mobile Sources not in source category OAC 252: Incinerators not type of emission unit OAC 252: Cotton Gins not type of emission unit OAC 252: Grain Elevators not in source category OAC 252: Nonattainment Areas not in area category OAC 252: Landfills not in source category SECTION VII. FEDERAL REGULATIONS PSD, 40 CFR Part 52 [Not Applicable] PSD does not apply. Final total emissions are less than the threshold of 250 TPY of any single regulated pollutant and the facility is not one of the 26 specific industries with a threshold of 100 TPY. NSPS, 40 CFR Part 60 [Subparts GG, KKK, LLL, and JJJJ Applicable] Subparts K and Ka, Petroleum Liquids Storage Vessels. None of the tanks are subject to any of the subparts because they were either installed prior to an applicable date or are too small. Subpart Kb, VOL Storage Vessels. This subpart regulates hydrocarbon storage tanks larger than 19,813 gallons (472-bbl) capacity and built after July 23, The tanks at this facility are below the threshold; therefore, not subject to this subpart. Subpart GG, Stationary Gas Turbines. The turbines (C-1 & C-2) at the facility commenced construction, reconstruction, or modification after October 3, 1977, and have a heat input at peak load between 10 and 100 MMBTUH based on the lower heating value of the fuel. These units are subject to the nitrogen oxide emission limitations of 40 CFR (a)(2), the sulfur dioxide emission limitations of 40 CFR (a) or (b), and the fuel monitoring requirements of 40 CFR (h). Per (h)(2), monitoring of the fuel nitrogen content is not required if the owner or operator does not take a NO X allowance for fuel-bound nitrogen. Monitoring of fuel sulfur content is not required when a gaseous fuel is fired in the turbine and the owner or operator demonstrates that the gaseous fuel meets the definition of natural gas using one of the methods in (h)(3)(i) or (ii) defines natural gas as containing 20 grains or less of total sulfur per 100 standard cubic feet and is either composed of at least 70 percent methane by volume or has a gross caloric value between 950 and 1100 Btu/scf. Subpart VV, Equipment Leaks of VOC in the Synthetic Organic Chemical Manufacturing Industry. The equipment is not in a SOCMI plant. Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. This subpart applies to natural gas processing plants that commence construction, reconstruction, or modification after January 20, The facility is subject to this subpart. The permit requires all affected units to comply with all applicable requirements. Subpart LLL, Onshore Natural Gas Processing: SO 2 Emissions. This subpart affects sweetening units and sweetening units followed by a sulfur recover unit which commence construction or modification after January 20, This subpart requires facilities with a design capacity less than 2 LT/D of H 2 S in the acid gas (expressed as sulfur) to keep, for the life of the facility, a

11 PERMIT MEMORANDUM TVR2 DRAFT Page 11 record demonstrating that the facility s design capacity is less than 2 LT/D of H 2 S. All applicable requirements have been incorporated into the permit. Subpart IIII, Stationary Compression Ignition Internal Combustion Engines (CI-ICE). This subpart promulgates emission standards for all CI engines based on power and displacement ratings, depending on date of construction, beginning with those constructed after July 11, For the purposes of this subpart, the date that construction commences is the date the engine is ordered by the owner or operator. There are no compression ignition internal combustion engines at this facility. Subpart JJJJ, Stationary Spark Ignition Internal Combustion Engines (SI-ICE). This subpart promulgates emission standards for all new SI engines ordered after June 12, 2006, and all SI engines modified or reconstructed after June 12, 2006, regardless of size. The specific emission standards (either in g/hp-hr or as a concentration limit) vary based on engine class, engine power rating, lean-burn or rich-burn, fuel type, duty (emergency or non-emergency), and numerous manufacture dates. This subpart affects lean burn engines 500-hp and < 1,350-hp that were manufactured after January 1, Engine C-6 was constructed after June 12, 2006 and was manufactured after January 1, 2008, and is subject to this subpart. Manufacturers may choose to certify their stationary SI-ICE with a maximum engine power greater than or equal to 100-hp to either the emission standards in Table 1 of Subpart JJJJ or to the certification emission standards for new non-road SI engines in 40 CFR Part 1048, applicable to engines that are not severe duty engines for engines with a maximum engine power greater than or equal to 500-hp and manufactured prior to July 1, The standards in Table 1 of Subpart JJJJ and 40 CFR Part 1048 are listed below. Emission Standards from Table 1, Subpart JJJJ, g/hp-hr 15%O 2 ) For Non-Emergency SI Lean-Burn Engines Burning Natural Gas Rated Power (hp) Mfg. Date NO X CO VOC 500 hp < 1,350 1/1/ (160) 4.0 (540) 1.0 (86) Emission Standards from (a)(2) g/hp-hr Tier Model Year HC+NO X CO Tier & later Engine C-6 is not a certified engine and will be labeled by the manufacturer according to (e) and The owner/operator of a stationary SI-ICE with a maximum engine power greater than or equal to 100-hp must comply with the emission standards in Table 1 of Subpart JJJJ. Since the engine is a non-certified engine, the owner/operator must keep a maintenance plan and records of conducted maintenance and must, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, the owner/operator must conduct an initial performance test and subsequent performance testing every 8,760 hours of operation or 3 years, whichever comes first, thereafter to demonstrate compliance. Performance tests must comply with the requirements specified in All applicable requirements have been incorporated into the permit. Subpart KKKK, Stationary Combustion Turbines. This subpart establishes emission standards and compliance schedules for the control of emissions from stationary combustion turbines with

12 PERMIT MEMORANDUM TVR2 DRAFT Page 12 a heat input at peak load equal to or greater than 10.7 gigajoules (10 MMBtu) per hour, based on the higher heating value of the fuel, that commenced construction, modification, or reconstruction after February 18, Stationary combustion turbines regulated under this subpart are exempt from the requirements of Subpart GG of this part. The turbines at this facility are exempt because they were manufactured before February 18, Subpart OOOO, Crude Oil and Natural Gas Production, Transmission, and Distribution. This subpart was promulgated on August 16, 2012, and affects the following sources that commence construction, reconstruction, or modification after August 23, 2011: 1. Each single gas well; 2. Single centrifugal compressors using wet seals that are located between the wellhead and the point of custody transfer to the natural gas transmission and storage segment; 3. Reciprocating compressors which are single reciprocating compressors located between the wellhead and the point of custody transfer to the natural gas transmission and storage segment; 4. Single continuous bleed natural gas driven pneumatic controllers with a natural gas bleed rate greater than 6 SCFH, which commenced construction after August 23, 2011, located between the wellhead and the point of custody transfer to the natural gas transmission and storage segment and not located at a natural gas processing plant; 5. Single continuous bleed natural gas driven pneumatic controllers which commenced construction after August 23, 2011, and is located at a natural gas processing plant; 6. Single storage vessels located in the oil and natural gas production segment, natural gas processing segment, or natural gas transmission and storage segment; 7. All equipment, except compressors, within a process unit at an onshore natural gas processing plant; 8. Sweetening units located at onshore natural gas processing plants. All equipment of this facility was constructed before the effective date of this subpart. NESHAP, 40 CFR Part 61 [Not Applicable] There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium, coke oven emissions, mercury, radionuclides or vinyl chloride except for trace amounts of benzene. Subpart J, Equipment Leaks of Benzene, only affects process streams which contain more than 10% benzene by weight. All process streams at this facility are below this threshold. NESHAP, 40 CFR Part 63 [Subpart ZZZZ Applicable] Subpart HH, Oil and Natural Gas Production Facilities. This subpart applies to affected emission points that are located at facilities which are major sources of HAPs and either process, upgrade, or store hydrocarbons prior to the point of custody transfer or prior to which the natural gas enters the natural gas transmission and storage source category. Subpart HH affects glycol dehydration units (unless benzene emissions are less than 1 TPY), unit process vents, storage vessels with potential for flash emissions (which are defined to include only those vessels with a daily throughput of 21,000 gallons or more), and compressors and ancillary equipment (valves, flanges, etc.) in VHAP service (i.e., more than 10% by weight VHAP) which are located at gas plants. The facility does not have a glycol dehydration unit and it is not a major source of HAPs.

13 PERMIT MEMORANDUM TVR2 DRAFT Page 13 Subpart YYYY, Stationary Combustion Turbines. This subpart affects only turbines located at facilities that are major sources of HAP. If a facility is modified in such a manner that it becomes major for HAPs, the turbines are required to be in compliance with Subpart YYYY on the date the facility becomes major. This facility is not a major source of HAPs. Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart affects any existing, new, or reconstructed stationary RICE at a major or area source of HAP emissions, except if the stationary RICE is being tested at a stationary RICE test cell/stand. The following table differentiates existing, new, or reconstructed units based on their construction dates. Construction/Reconstruction Dates Engines > 500 hp Engines 500hp Existing Unit Located at Major HAP Source Before 12/19/02 Before 6/12/06 Located at Area HAP Source Before 6/12/06 New or Reconstructed Unit Located at Major HAP Source On and After 12/19/02 On and After 6/12/06 Located at Area HAP Source On and After 6/12/06 Based on emission calculations, this facility is a minor source of HAPs. A stationary RICE located at an area source of HAP emissions is new if construction commenced on or after June 12, Engine C-6 is a new engine because it commenced construction after June 12, 2006, and it will meet the requirements of Subpart ZZZZ by complying with 40 CFR Part 60 Subpart JJJJ (for SI engines). Subpart JJJJJJ, Industrial, Commercial, and Institutional Boilers Located at Area Sources. This proposed subpart affects new and existing boilers located at area sources of HAP, except for gasfired boilers. Gas fired boilers are defined as any boiler that burns gaseous fuel not combined with any solid fuels, liquid fuel only during periods of gas curtailment, gas supply emergencies, or periodic testing on liquid fuel. Periodic testing under this definition shall not exceed a combined total of 48 hours during any calendar year. Boiler means an enclosed device using controlled flame combustion in which water is heated to recover thermal energy in the form of steam or hot water. The heaters at this facility are gas fired and do not meet the definition of boiler and are not subject to this subpart. CAM, 40 CFR Part 64 [Not Applicable] Compliance Assurance Monitoring (CAM), as published in the Federal Register on October 22, 1997, applies to any pollutant specific emission unit at a major source that is required to obtain a Title V permit, if it meets all of the following criteria: It is subject to an emission limit or standard for an applicable regulated air pollutant. It uses a control device to achieve compliance with the applicable emission limit or standard. It has potential emissions, prior to the control device, of the applicable regulated air pollutant of 100 TPY. No emission unit meets all three of these conditions.

14 PERMIT MEMORANDUM TVR2 DRAFT Page 14 Chemical Accident Prevention Provisions, 40 CFR Part 68 [Applicable] This facility handles naturally occurring hydrocarbon mixtures at a natural gas processing plant and the Accidental Release Prevention Provisions are applicable to this facility. The facility was required to submit the appropriate accidental release emergency response program plan. This facility has submitted their plan to EPA Regional 6. More information on this federal program is available on the web page: Stratospheric Ozone Protection, 40 CFR Part 82 [Subparts A and F are Applicable] These standards require phase out of Class I & II substances, reductions of emissions of Class I & II substances to the lowest achievable level in all use sectors, and banning use of nonessential products containing ozone-depleting substances (Subparts A & C); control servicing of motor vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations which meet phase out requirements and which maximize the substitution of safe alternatives to Class I and Class II substances (Subpart D); require warning labels on products made with or containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons (Subpart H). Subpart A, Production and Consumption Controls. This subpart identifies ozone-depleting substances and divides them into two classes. Class I controlled substances are divided into seven groups; the chemicals typically used by the manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform (Class I, Group V). A complete phaseout of production of Class I substances is required by January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs. Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances, scheduled in phases starting by 2002, is required by January 1, Subpart F, Recycling and Emission reduction. This subpart requires that any persons servicing, maintaining, or repairing appliances except for motor vehicle air conditioners; persons disposing of appliances, including motor vehicle air conditioners; refrigerant reclaimers, appliance owners, and manufacturers of appliances and recycling and recovery equipment comply with the standards for recycling and emissions reduction. Conditions are included in the standard conditions of the permit to address the requirements specified at for persons opening appliances for maintenance, service, repair, or disposal; for equipment used during the maintenance, service, repair, or disposal of appliances; for certification by an approved technician certification program of persons performing maintenance, service, repair, or disposal of appliances; for recordkeeping; for leak repair requirements; and for refrigerant purchase records for appliances normally containing 50 or more pounds of refrigerant.

15 PERMIT MEMORANDUM TVR2 DRAFT Page 15 SECTION VIII. COMPLIANCE Tier Classification and Public Review This application has been determined to be a Tier II based on being a request for a renewal of an operating permit for a facility that is currently permitted as a major source of emissions. The permittee has submitted an affidavit that they are not seeking a permit for land use or for any operation upon land owned by others without their knowledge. The affidavit certifies that the applicant owns the land. Information on all permit actions is available for review by the public on the Air Quality section of the DEQ web page at: The applicant will publish a Notice of Filing a Tier II Application and also a Notice of Tier II Draft Permit in a local newspaper in Beckham County where the facility is located. The notices will state that the application and the draft permit will be available for public review at the Elk City Gas Plant or the DEQ office in Oklahoma City. The notices will also state that the application and the draft permit will be available for public review at a local public library in Elk City, Oklahoma. The facility is located within 50 miles of the Oklahoma - Texas border. The state of Texas will be notified of the draft permit. Information on all permit actions is available on the Air Quality section of the DEQ web page at Inspection A full compliance inspection was conducted on June 22, 2011, by Melanie Foster, Environmental Programs Manager, and Sean Walker and Heather Sessing, Environmental Programs Specialists for the Air Quality Division. The facility was represented by the following individuals: Robert Rollo, Plant Manager; Brad Baxter, Area Superintendent; Joseph Campa, EH&S Coordinator; Mike Leverett, Operator; and Gary Burks, I&E Tech. The facility was physically as described in the permit application. Details of the inspection have been documented in the Full Compliance Evaluation Memorandum No The required records are maintained on-site, at the Elk City Gas Plant at Elk City, Oklahoma and at the Enbridge G & P (Oklahoma), Pampa, Texas office. Testing The 1,340-hp Caterpillar G3516 LE lean-burn engine (C-6) at the facility is subject to NSPS Subpart JJJJ. The owner/operator has submitted the NSPS initial performance test results to the DEQ which are shown in the table below. The test results demonstrate compliance with the applicable limitations. NO Load X CO Source Testing Date Limit* Tested* Limit* Tested* % (ppmvd) (ppmvd) (ppmvd) (ppmvd) C-6 (2041) 5/26/ % *Corrected to 15% oxygen

16 PERMIT MEMORANDUM TVR2 DRAFT Page 16 Quarterly tests of the engines/turbines were conducted on January 25 and 27, Listed below are the results from testing which show compliance with the applicable emissions limits. Permit Limit, lb/hr Test Results, lb/hr EU NOx CO NO x CO Test Date C /25/2011 C /27/2011 C /25/2011 ppm ppm C * * -- 01/25/2011 C * * -- 01/27/2011 *Corrected to 15% oxygen Fees Paid Renewal of Part 70 operating permit fee of $7,500. SECTION IX. SUMMARY The facility is constructed as described in the permit application. Ambient air quality standards are not threatened at this site. There are no active Air Quality compliance or enforcement issues that would prohibit the issuance of this permit. Issuance of the permit is recommended, contingent on public review and the EPA review.

17 PERMIT TO OPERATE AIR POLLUTION CONTROL FACILITY SPECIFIC CONDITIONS DRAFT Enbridge G & P (Oklahoma), LP Elk City Gas Plant Permit Number TVR2 The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on January 14, The Evaluation Memorandum, dated March 26, 2013, explains the derivation of applicable permit requirements and estimates of emissions; however, it does not contain operating limitations or permit requirements. Continuing operations under this permit constitutes acceptance of, and consent to, the conditions contained herein: 1. Points of emissions and emissions limitations for each point: [OAC 252: (a)] EUG 2. Turbines EU Make/Model NO x CO VOC lb/hr TPY lb/hr TPY lb/hr TPY C-1 Solar Centaur C3066RTA Turbine C-2 Solar Centaur C3066RTA Turbine Maximum Pollutant Concentrations per NSPS Subpart GG Source NO X (ppmdv) C * C * * Corrected to 15% oxygen EUG 3: Internal Combustion Engine NO EU Make/Model x CO VOC lb/hr TPY lb/hr TPY lb/hr TPY C-6 1,340-hp Caterpillar 3516LE Engine EUG 4. Regeneration Heaters The following emissions units are Insignificant Activities since emissions are less than 5 TPY. EU ID# Point ID# Description Capacity/Size H-1 H-1 Molecular Sieve Regeneration Heater 6.0 MMBtu/hr H-2 H-2 Molecular Sieve Regeneration Heater 2.26 MMBtu/hr EUG 5. Amine Off-Gas Enclosed Flare NO X CO VOC SO 2 EU lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY FL

18 SPECIFIC CONDITIONS TVR2 DRAFT Page 2 The amine off-gas enclosed flare is subject to 40 CFR General Control Requirements and the permittee shall comply with all requirements, including, but not limited to, the following. [40 CFR 60.18] (a) The flare shall be operated at all times when emissions may be vented to it. (b) The presence of a pilot flame shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame. (c) The following formula shall be used to show compliance with the TPY emission limits for SO 2: [OAC 252: (a) and (b)] SO 2 TPY = (Q inlet, MMSCFD)(C inlet C residue, ppmv)(1 lbmol H 2 S/ lbmol SO 2 )(64 lb SO 2 /lbmol)(8760 hr/yr) (380 ft 3 /lbmol)(24 hr/day)(2000 lb/ton) i. Compliance with the annual emission limits of SO 2 shall be based on a 12-month rolling total. The permittee shall calculate the total SO 2 emissions from the acid gas flare stack based on 98% conversion of H 2 S. The calculations shall be based on monthly tested H 2 S concentration measured at the following locations: (1) plant inlet gas streams, and (2) plant outlet gas stream and the daily average inlet gas flow rate for that month. The formula shows 8,760 hr/yr but the actual hours operated can be used if different than 8,760. These calculations will be submitted with the semiannual monitoring and deviation report. ii. The permittee shall use stain tubes (or an equivalent method) with a first scale mark no larger than 1 ppmv and a maximum measurement concentration of 15 ppmv or less. If an equivalent method is used, it must satisfy the same requirements for scale and maximum concentration. The permittee may assume outlet concentration is 0 ppmw. Testing shall be conducted each month. (d) The flare shall have installed, calibrated, maintained, and operated an alarm system that will signal non-combustion of the gas. [OAC 252: (c)] EUG 6. Condensate Tanks & Flashing Losses EU Contents Capacity T bbls T-2 Condensate 210-bbls T bbls VOC Emissions TPY (a) Site-wide condensate throughput shall be no more than 1,800,000 gallons in any 12 month period. EUG 7. Condensate Truck Loading Throughput VOC Emissions EU Description Gallons/year TPY L-1 Condensate Loading 1,800,

19 SPECIFIC CONDITIONS TVR2 DRAFT Page 3 (a) Site-wide condensate loading shall be no more than 1,800,000 gallons in any 12 month period. EUG 8. Fugitive VOC Emission Sources Fugitive VOC emissions are estimated based on existing equipment items but do not have a specific limitation. EU ID# Point ID# Equipment Number* Construction Date Valves Flange/Connections 1, FUG-1 FUG-1 Compressor Seals Relief Valves Pump Seals Others *Estimated only, not a permit limit. EUG 9. Fugitive VOC Emission Sources Subject to LDAR under NSPS Subpart KKK Fugitive VOC emissions are estimated based on existing equipment items. These sources are subject to NSPS Subpart KKK LDAR monitoring. EU ID# Point ID# Equipment Service Count Construction Date Valves Gas/Vapor /2000 Flanges Gas/Vapor 1, /2000 Connectors Gas/Vapor 1, /2000 FUG-02 FUG-02 Pump Seals Light Liquid /2000 Valves Light Liquid /2000 Flanges Light Liquid /2000 Connectors Light Liquid /2000 *Estimated only, not a permit limit. Numbers of fugitive components are estimates from the LDAR Master Component List. Numbers of fugitive components change periodically with facility maintenance. 2. All fuel-burning equipment shall be fired with pipeline grade natural gas or other gaseous fuel with a sulfur content less than 343 ppmv. Compliance can be shown by the following methods: for pipeline grade natural gas, a current gas company bill; for other gaseous fuel, a current lab analysis, stain-tube analysis, gas contract, tariff sheet, or other approved methods. Compliance shall be demonstrated at least once every calendar year. [OAC 252:100-31] 3. The permittee shall be authorized to operate this facility continuously (24 hours per day, every day of the year). [OAC 252: (a)] 4. Each engine/turbine at the facility shall have a permanent identification plate attached, which shows the make, model number, and serial number. [OAC 252:100-43]

20 SPECIFIC CONDITIONS TVR2 DRAFT Page 4 5. The permittee shall keep operation and maintenance (O&M) records for each engine/turbine that is not tested in a quarter. Such records shall at a minimum include the dates of operation and maintenance, type of work performed, and the increase, if any, in emissions as a result. [OAC 252: (a)(3)(b)] 6. At least once per calendar quarter, the permittee shall conduct tests of NO X and CO emissions in exhaust gases from each engine/turbine and from each replacement engine/turbine when operating under representative conditions for that period. Testing is required for each engine/turbine or any replacement engine/turbine that runs for more than 220 hours during that calendar quarter. A quarterly test may be conducted no sooner than 20 calendar days after the most recent test. Testing shall be conducted using a portable analyzer in accordance with a protocol meeting the requirements of the latest AQD Portable Analyzer Guidance document, or an equivalent method approved by Air Quality. When four consecutive quarterly tests show the engine/turbine to be in compliance with the emissions limitations shown in the permit, then the testing frequency may be reduced to semi-annual testing. A semi-annual test may be conducted no sooner than 60 calendar days nor later than 180 calendar days after the most recent test. Likewise, when the following two consecutive semi-annual tests show compliance, the testing frequency may be reduced to annual testing. An annual test may be conducted no sooner than 120 calendar days nor later than 365 calendar days after the most recent test. Upon any showing of non-compliance with emissions limitations or testing that indicates that emissions are within 10% of the emission limitations, the testing frequency shall revert to quarterly. Reduced testing frequency does not apply to engines with catalytic converters. Any reduction in the testing frequency shall be noted in the next required compliance certification. [OAC 252: (a)(3)(a)] 7. When periodic compliance testing shows exhaust emissions from the engine/turbines in excess of the lb/hr limits in Specific Condition No. 1, the permittee shall comply with the provisions of OAC 252: [OAC 252:100-9] 8. Replacement (including temporary periods of 6 months or less for maintenance purposes) of engine/turbines with emissions limitations specified in this permit with engine/turbines of lesser or equal emissions of each pollutant (in lb/hr and TPY) are authorized under the following conditions. [OAC 252: (a)(3)(a)] (a) (b) The permittee shall notify AQD in writing at least 7 days in advance of start-up of the replacement engine(s)/turbine(s). Said notice shall identify the old engine/turbine and shall include the new engine/turbine make and model, serial number, horsepower rating, and pollutant emission rates (g/hp-hr, lb/hr, and TPY) at maximum horsepower for the altitude/location. Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be conducted to confirm continued compliance with NOx and CO emissions limitations. A copy of the first quarter testing shall be provided to AQD within 60 days of start-up of each replacement engine/turbine. The test report shall include the engine/turbine fuel usage, stack flow (ACFM), stack temperature ( o F), and pollutant emission rates (g/hphr, lbs/hr, and TPY) at maximum rated horsepower for the altitude/location.