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ANR Pipeline Company Houston, Texas 77002

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ANR Pipeline Company Houston, Texas 77002 App # 202000097 TransCanada US Pipelines USGO Integrity Services Department 700 Louisiana St. ANR Pipeline Company Houston, Texas 77002 May 27, 2020 Michigan Department of Environment, Great Lakes, and Energy – Air Quality Division Cadillac District – Cadillac Office (Northwest Lower Peninsula) 120 W Chapin Street Cadillac, MI 49601-2158 Re: Rule 215(3) Notification of Off-Permit Change ANR Pipeline Company – Reed City Compressor Station Reed City, MI State Registration Number (SRN): B3721 Dear Sir or Madam, Enclosed is the R 336.1215(3) (Rule 215) Notification of Off-Permit Change for ANR Pipeline Company for the Reed City Compressor Station. The Renewable Operating Permit (ROP) No. MI-ROP-B3721-2014a for the Reed City Compressor Station expired February 6, 2019. As required under Section A.35 of the Reed City Station ROP, ANR has submitted a permit renewal application 6 months prior to expiration of the permit or August 6, 2018; therefore, the station continues to operate under this ROP. This change, anticipated to take place in June 2020, is for replacement of the two (2) existing emergency generators, EURC019 rated at 355 hp and EURC020 rated at 475 hp with one (1) new emergency generator, EURC064, rated at 1,114 hp. The new emergency generator, EURC064 is exempt from the requirement to obtain a Permit-to- Install (PTI) under R 336.1278 and R 336.1285(2)(9), which exempts internal combustion engines with heat input less than 10 MMBtu/hr from obtaining a PTI. The facility is currently subject to Prevention of Significant Deterioration (PSD) rules incorporated under R 336.1119, however this change does not trigger major modification applicability. ANR is proposing to incorporate the new emergency as well as remove the existing emergency generators from Flexible Group Condition FG-EMERGENCY. In addition, the proposed emergency generator will be subject to 40 CFR Part 60 Subpart JJJJ. ANR is proposing to incorporate the applicable requirements into the current ROP. A thorough description of the change can be found in the forms attached to this submittal. Rule 215(3) allows for changes which do not conflict with or are not prohibited by an existing ROP at a stationary source, without revision to that permit if: • the change complies with all applicable requirements, • the change is not a major NSR modification, and • if the source is an affected source under the Title IV acid rain provisions and the change is not contrary to any applicable requirements of Title IV. App # 202000097 TransCanada US Pipelines USGO Integrity Services Department 700 Louisiana St. ANR Pipeline Company Houston, Texas 77002 The proposed generator will be in compliance with all applicable requirements. As shown in the emission calculations in Attachment A, the proposed project is not a major NSR modification. In addition, the proposed generator is not an affected source under Title IV acid rain provisions. Therefore, the generator replacement project can be made “off-permit” at a stationary source The Rule 215(3) off-permit change notification is required at least 7 days prior to the change and provides a description of the change including: • A description of the change – As described above, the project is to replace the existing two (2) existing emergency generators, EURC019 rated at 355 hp and EURC020 rated at 475 hp with one (1) new emergency generator, EURC064, rated at 1,114 hp. Additional information is provided in Attachment A. • The date of the change – The installation of the generator is scheduled for June 15, 2020. • Any change in emissions – Please see emission calculations in Attachment B. • Any permit term or condition that is no longer applicable as a result of the change – Flexible Group Conditions, FG-EMERGENCY in the current permit will need to be updated for the proposed generator. The existing generators are existing sources under 40 CFR Part 63 Subpart ZZZZ. However, the proposed generator will be a new source under 40 CFR Part 63 Subpart ZZZZ. In addition, the proposed generator will be subject to 40 CFR Part 60 Subpart JJJJ. A mark-up of the current ROP is included with this Off-Permit Change notification in Attachment C. Please find attached the Off-Permit Change notification including all necessary materials as listed below: • Form M-001 • Form C-001 • Form AI-001 • Supplemental Data – Emissions Calculations, Mark-up of Current Title V Permit If you have any questions or comments concerning this request, please contact me at (715) 758- 3341 or via email at [email protected]. Sincerely, Chris Waltman TransCanada US Pipelines Senior Environmental Specialist Cc: U.S. EPA, Air and Radiation Division, Attention: Permits – Michigan, 77 West Jackson Boulevard, Chicago, IL 60604 App # 202000097 Attachment A Application Forms Michigan Department of Environment, Great Lakes, and Energy - Air Quality Division App # 202000097 RENEWABLE OPERATING PERMIT APPLICATION AI-001: ADDITIONAL INFORMATION This information is required by Article II, Chapter 1, Part 55 (Air Pollution Control) of P.A. 451 of 1994, as amended, and the Federal Clean Air Act of 1990. Failure to obtain a permit required by Part 55 may result in penalties and/or imprisonment. Please type or print clearly. Refer to instructions for additional information to complete this form. SRN: B3721 Section Number (if applicable): 1. Additional Information ID AI-001 Additional Information 2. Is This Information Confidential? Yes No Modification Summary: The ANR Pipeline Company - Reed City Compressor Station currently operates under and existing Renewable Operating Permit, MI-ROP-B3721-2014a, issued by the Michigan Department of Environmental Quality (DEQ) on February 6, 2014 and revised on November 16, 2015. The permit expired in February 6, 2019. In compliance with R 336.1210(9), the facility submitted a timely and complete application for renewal of the ROP on June 29, 2018. This change, anticipated to take place in June 2020, is for replacement of the two (2) existing emergency generators, EURC019 rated at 355 hp and EURC020 rated at 475 hp with one (1) new emergency generator, EURC064, rated at 1,114 hp. The new emergency generator, EURC064 is exempt from the requirement to obtain a Permit-to-Install (PTI) under R 336.1278 and R 336.1285(2)(g), which exempts internal combustion engines with heat input less than 10 MMBtu/hr from obtaining a PTI. The facility is currently subject to Prevention of Significant Deterioration (PSD) rules incorporated under R 336.1119, however this change does not trigger major modification applicability. Rule 215(3) allows for changes which do not conflict with or are not prohibited by an existing ROP at a stationary source, without revision to that permit if: • the change complies with all applicable requirements, • the change is not a major NSR modification, and • if the source is an affected source under the Title IV acid rain provisions and the change is not contrary to any applicable requirements of Title IV. The proposed generator will be in compliance with all applicable requirements. As shown in the emission calculations in Attachment A, the proposed project is not a major NSR modification. In addition, the proposed generator is not an affected source under Title IV acid rain provisions. Therefore, the generator replacement project can be made “off-permit” at a stationary source The Rule 215(3) off-permit change notification is required at least 7 days prior to the change and provides a description of the change including: • A description of the change – As described above, the project is to replace the existing two (2) existing emergency generators, EURC019 rated at 355 hp and EURC020 rated at 475 hp with one (1) new emergency generator, EURC064, rated at 1,114 hp. Additional information is provided in Attachment A. • The date of the change – The installation of the generator is scheduled for June 15, 2020. • Any change in emissions – Please see emission calculations in Attachment B. • Any permit term or condition that is no longer applicable as a result of the change – Flexible Group Conditions, FG-EMERGENCY in the current permit will need to be updated for the proposed generator. The existing generators are existing sources under 40 CFR Part 63 Subpart ZZZZ. However, the proposed generator will be a new source under 40 CFR Part 63 Subpart ZZZZ. In addition, the proposed generator will be subject to 40 CFR Part 60 Subpart JJJJ. A mark-up of the current ROP is included with this Off-Permit Change notification in Attachment C. Page 1 of 1 For Assistance www.michigan.gov/egle Contact: 800-662-9278 EQP5774 (Rev.4-22-2019) App # 202000097 Michigan Department of Environmental Quality Air Quality Division App # 202000097 RENEWABLE OPERATING PERMIT M-001: RULE 215 CHANGE NOTIFICATION RULE 216 AMENDMENT/MODIFICATION APPLICATION This information is required by Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended, and the Federal Clean Air Act of 1990. Failure to obtain a permit required by Part 55 may result in penalties and/or imprisonment. 1. SRN B3721 2. ROP Number B3721-2014a 3. County Osceola 4. Stationary Source Name ANR Pipeline Company – Reed City Compressor Station 5. Location Address 7677 230th Ave 6. City Reed City 7. Submittal Type - The submittal must meet the criteria for the box checked below. Check only one box. Attach a mark- up of the affected ROP pages for applications for Rule 216 changes. Rule 215(1) Notification of change. Complete Items 8 – 10 and 14 Rule 215(2) Notification of change. Complete Items 8 – 10 and 14 Rule 215(3) Notification of change. Complete Items 8 – 11 and 14 Rule 215(5) Notification of change. Complete Items 8 – 10 and 14 Rule 216(1)(a)(i)-(iv) Administrative Amendment.
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