Oklahoma Department of Environmental Quality s26
PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 17
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM April 26, 2006
TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality
THROUGH: Grover Campbell, P.E., Existing Source Permits Section
THROUGH: Phil Martin, P.E., New Source Permits Section
THROUGH: Peer Review
FROM: Eric L. Milligan, P.E., Engineering Section
SUBJECT: Evaluation of Permit Application 2006-051-TVR
Duke Energy Field Services, L.P.
Carney Gas Plant (SIC 1321)
NE/4 of NW/4 of Section 12-T15N-R2E, Lincoln County
Directions: 1 mile south of Carney and 1½ miles west of Hwy 177
SECTION I. INTRODUCTION
Duke Energy Field Services has requested renewal of their current Part 70 operating permit. The facility is currently operating as authorized by Permit No. 96-355-TV (M-3), dated January 21, 2006. This permit incorporates CAM for the rich-burn internal combustion engines with catalytic converters that have the potential to emit greater than 100 TPY prior to control (engines P-ENG3 and P-ENG15). The following changes requested by the company have also been incorporated:
· Revision of serial numbers, in the permit memorandum, of engines that were replaced;
· Removal of P-ENG12 which is permanently taken out of service;
· Engine P-ENG14 is only used for emergency electrical generation and qualifies as an insignificant emission unit and the company requests that it not be included with the other compressor engines;
· Add a new 210-barrel atmospheric/environmental water tank (EU-3, P-T32);
· Remove tanks P-T22 and P-T23 since they are permanently out of service;
· Other minor revisions to listed tank sizes;
The permittee requested two operating scenarios. One scenario when the gas plant was operating and NSPS, Subpart KKK is applicable and the other scenario when the gas plant is not operating and NSPS, Subpart KKK is not applicable. However, applicability of NSPS, Subpart KKK can only change if the gas plant is permanently shut down and never restarted.
SECTION II. FACILITY DESCRIPTION
The facility was constructed as a cryogenic natural gas processing plant, to extract hydrocarbon liquids from raw natural gas streams. Two raw natural gas streams (high-pressure and low-pressure) are delivered to the plant. After extraction of the hydrocarbon liquids, residue gas and liquids are sold as product. The facility is currently operating as a booster station and the gas is sent to the Kingfisher Gas Plant after compression and dehydration. It is anticipated that the hydrocarbon liquids extraction process will be restarted at a future date.
Low-pressure gas enters the plant through a separator, for removal of free liquids, and is then compressed by the inlet compressors (Engines # 2, 3, 8, 9, and 10). This stream and the high-pressure gas stream are then combined upstream of a glycol dehydration unit. Depending on future field conditions, the high-pressure stream may bypass glycol dehydration and combine with the low-pressure inlet downstream of this unit.
The glycol dehydration unit uses triethylene glycol (TEG) to remove entrained water from the gas stream. Gas and glycol counter flow in the dehydrator, where the TEG through direct contact with the gas removes the water vapor. After regeneration, “lean” glycol is recirculated through the system.
Dry gas from the contactor is then compressed by pre-boost compressors (Engines #6 and/or 7) prior to process dehydration. Process dehydration is accomplished by two molecular sieve beds, one in service while the other is being regenerated. Regeneration of the molecular sieve is conducted by passing a heated gas slipstream through the bed for removal of water. The wet gases are then cooled and condensed removing the water.
Dehydrated gas is cooled through a series of heat exchangers. Condensed liquids are fed directly to the demethanizer while vapors are routed to the turboexpander. A near isotropic expansion reduces pressure and temperature while also delivering shaft work to the recompressor.
Mixed hydrocarbon product (ethane, propane, butane, condensate (EPBC)) is separated from the residue gas (primarily methane) in the demethanizer. EBPC is transported via pipeline to ONEOK for fractionation. Residue gas is transported from the plant via pipeline after compression (engines #5 or 11). Condensate from the separators is transported via pipeline. Condensate from the low pressure inlet scrubber and low-pressure dumps are transported by truck.
Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) in the following outline. There is only one operating scenario for the facility. For this scenario, pipeline-quality natural gas is the primary fuel for the engines, which are operated continuously.
SECTION III. EQUIPMENT
The following table lists both the emission unit, engine designation by the company, and description including serial number to provide a tracking mechanism. The equipment listed represents the facility as it is currently.
EUG 1 and 2 Internal Combustion Engines
EUG / EU / Point / Make/Model / Hp / Serial # / Const. Date1 / 2 / P-ENG2 / White 8G825 W/CC / 800 / 15838 / 2000
1 / 3 / P-ENG3 / Waukesha L7042 GSI W/CC / 1,100 / 385982 / 2004
1 / 5 / P-ENG5 / White 6G825 W/CC / 600 / 17682R / 2000
1 / 6 / P-ENG6 / White 8G825 W/CC / 800 / 17620 /
2002
1 / 7 / P-ENG7 / White 8G825 W/CC / 800 / 17116 / 19801 / 8 / P-ENG8 / Clark RA-8 / 800 / 25508 / 1980
1 / 9 / P-ENG9 / White 8G825 W/CC / 800 / 2219277401 / 1999
1 / 10 / P-ENG10 / Caterpillar 399TA W/CC / 830 / 49C00900 / 1980
1 / 11 / P-ENG11 / White 6G825 W/CC / 600 / 283559 / 2000
1 / 15 / P-ENG15 / Waukesha P9390G W/CC / 1,194 / 288644 / 2005
W/CC - With Catalytic Converter.
EUG 3 Tanks
EUG / EU / Point / Contents / Gallons / VP(psia) / Const. Date
3 / EU-3 / P-T17 / Methanol / 1,000 / 1.6 / 1993
* / * / P-T18 / Antifreeze / 4,700 / 0.01 / ---
3 / EU-3 / P-T19 / Condensate / 8,820 / 3-8 / 1992
3 / EU-3 / P-T20 / Condensate / 8,820 / 3-8 / 1992
3 / EU-3 / P-T30 / Condensate / 8,820 / 3-8 / 2000
3 / EU-3 / P-T31 / Methanol / 8,820 / 1.6 / 2001
3 / EU-3 / P-T32 / Slop Water / 8,820 / <0.5 / 2003
* These tanks are not assigned to EUGs or EUs, because the emissions associated with these units are negligible. These tanks are included here only for the sake of completeness.
EUG 4 Tanks
4 / EU-4 / P-T21 / Mixed Gas Liquids (Pressurized) / 30,000 / 350 / Pre-19754 / EU-4 / P-T24 / Condensate (Pressurized) / 40,000 / 25 / Pre-1975
4 / EU-4 / P-T25 / Condensate (Pressurized) / 28,000 / 50 / Pre-1975
4 / EU-4 / P-T26 / Condensate (Pressurized) / 28,000 / 150 / Pre-1975
4 / EU-4 / P-T27 / Propane (Pressurized) / 16,000 / 100 / Pre-1975
* / * / P-T28 / Lube Oil / 5,000 / 0.01 / ---
* / * / P-T29 / Lube Oil / 6,500 / 0.01 / ---
* These tanks are not assigned to EUGs or EUs, because the emissions associated with these units are negligible. These tanks are included here only for the sake of completeness.
In addition to the tanks listed above, the facility has a water storage tank, a slop water tank, a 250-gallon triethylene glycol tank, a 1,000-gallon kerosene tank, and a 500-gallon diesel tank. There are also some tanks stored at the site, but which are not in service.
EUG 5 Condensate Truck Loading
EU / Type of Equipment1 / Loading Operations
EUG 6 Dehydration Unit’s Reboiler and Still Vent W/Condenser
EU / Type of Equipment / Rated Heat Input / Const Date1 / Reboiler / 0.5 MMBTUH / 1984
EUG 7 Fugitives Emissions
EU / Type of Equipment1 / Valves, flanges, and miscellaneous
Point / Make/Model / Height
(feet) / Dia.
(inches) / Flow
(ACFM) / Temp.
(°F) / Fuel
(SCFH)
P-ENG2 / White 8G8251 / 19 / 11 / 4,608 / 1,340 / 6,200
P-ENG3 / Waukesha L7042 GSI1 / 31 / 11 / 5,091 / 1,028 / 8,269
P-ENG5 / White 6G8251 / 24 / 8 / 3,160 / 1,250 / 4,800
P-ENG6 / White 8G8251 / 23 / 11 / 4,608 / 1,340 / 6,200
P-ENG7 / White 8G8251 / 28 / 8 / 4,608 / 1,340 / 6,200
P-ENG8 / Clark RA-8 / 28 / 14 / 6,985 / 1,400 / 8,000
P-ENG9 / White 8G8251 / 19 / 11 / 4,608 / 1,340 / 6,200
P-ENG10 / Caterpillar 399TA1 / 18 / 12 / 3,767 / 1,108 / 6,673
P-ENG11 / White 6G8251 / 15 / 8 / 3,160 / 1,250 / 4,800
P-ENG15 / Waukesha P9390G1 / 20 / 12 / 6,095 / 1,114 / 9,225
1 - with catalytic converter
SECTION IV. EMISSIONS
Emissions from the engines are based on continuous operation and the following emission factors.
Engine Emissions Factors (g/hp-hr)
Sources / NOX / CO / VOCWhite 8G825 engines W/CC; P-ENG2, P-ENG6, P-ENG9 / 3.0 / 2.0 / 0.5
Waukesha L7042 GSI engine W/CC; P-ENG3 / 3.0 / 3.0 / 0.5
White 6G825 engines W/CC; P-ENG5 / 3.0 / 2.0 / 0.5
White 8G825 engines W/CC; P-ENG7 / 3.0 / 3.0 / 0.5
Clark RA-8 engine; P-ENG8 / 22.3 / 5.0 / 2.0
Caterpillar 399TA engine W/CC; P-ENG10 / 3.0 / 3.0 / 0.5
White 6G825 engines W/CC; P-ENG11 / 3.0 / 3.0 / 0.5
Waukesha P9390G W/CC; P-ENG15 / 3.0 / 3.0 / 0.5
W/CC – With Catalytic Converter
Emissions from the tanks are based on TANKS3.1. There are no emissions from the pressurized tanks. Flashing losses/emissions from the condensate tanks are based on the Vasquez-Beggs gas/oil correlation method and a throughput of 777,400-gallons per year. Emissions from loading of condensate are based on AP-42 (1/95), Section 5.2 (4.85 lb/1,000 gallons) and 777,400 gallons splash-loaded per year. Fugitive VOC emissions are based on EPA’s “1995 Protocol for Equipment Leak Estimates” (EPA-453/R-95-017) average emission factors for oil and gas production, an estimated % C3+, and an estimated number of components. Emissions from the glycol dehydration unit’s reboiler and the mole sieve heater are based on AP-42 (7/98), Chapter 1.4, and continuous operation. Emissions of VOC from the glycol dehydration unit equipped with a flash tank and a condenser are based on an extended gas analysis, a natural gas throughput of 24 MMSCFD, a lean glycol recirculation rate of 3.5 gallon per minute (gpm), and GRI-GlyCalc Version 4.0 with the exhaust gases from the flash tank being combusted in the reboiler and the still vent being routed through a condenser. Dehydration units using glycol desiccants will emit benzene, toluene, ethyl benzene, xylene, and n-hexane from the glycol reboiler vapor stack/condenser. These compounds are regulated as HAP. Emissions of HAP are below the major source thresholds.
EUG-6 Dehydration Unit – HAP Emissions
Controlled EmissionsPollutant / CAS # / lb/hr / TPY
Benzene / 71432 / 0.0272 / 0.1191
Ethylbenzene / 108883 / 0.0022 / 0.0096
Toluene / 100414 / 0.0173 / 0.0758
Xylene / 1330207 / 0.0114 / 0.0499
n-Hexane / 110543 / 0.0653 / 0.2860
Totals / 0.1234 / 0.5404
EUG 7 Fugitive VOC Emissions
Equipment / %C3+ / Emission Factor / (lb/hr) / TPYWet Gas Service
680 Valves / 24 / 0.00992 / 1.61894 / 7.09096
1,764 Flanges / 24 / 0.00086 / 0.36409 / 1.59471
46 Others / 24 / 0.01940 / 0.21418 / 0.93811
Light Oil Service
570 Valves / 100 / 0.00550 / 3.13500 / 13.73130
1,425 Flanges / 100 / 0.00024 / 0.34200 / 1.49796
5 Pump Seals / 100 / 0.02866 / 0.14330 / 0.62765
Total Fugitive Emissions / 5.81751 / 25.48069
Emissions Summary - Criteria Pollutants
NOX / CO / VOCEUG/Pt /
lb/hr
/ TPY / lb/hr / TPY / lb/hr / TPY1/P-ENG2 / 5.29 / 23.18 / 3.53 / 15.45 / 0.88 / 3.86
1/P-ENG3 / 7.28 / 31.87 / 7.28 / 31.87 / 1.21 / 5.31
1/P-ENG5 / 3.97 / 17.38 / 2.65 / 11.59 / 0.66 / 2.90
1/P-ENG6 / 5.29 / 23.18 / 3.53 / 15.45 / 0.88 / 3.86
1/P-ENG7 / 5.29 / 23.18 / 5.29 / 23.18 / 0.88 / 3.86
1/P-ENG8 / 39.33 / 172.27 / 8.82 / 38.63 / 3.53 / 15.45
1/P-ENG9 / 5.29 / 23.18 / 3.53 / 15.45 / 0.88 / 3.86
1/P-ENG10 / 5.49 / 24.04 / 5.49 / 24.04 / 0.91 / 4.01
1/P-ENG11 / 3.97 / 17.38 / 3.97 / 17.38 / 0.66 / 2.90
1/P-ENG15 / 7.90 / 34.59 / 7.90 / 34.59 / 1.32 / 5.77
3 – Tanks / ---- / ---- / ---- / ---- / --- / 23.90
5 - Loading / ---- / ---- / ---- / ---- / --- / 1.89
6/1 Reboiler / 0.05 / 0.22 / 0.04 / 0.18 / <0.01 / 0.01
6/1 Still Vent / ---- / ---- / ---- / ---- / 1.51 / 6.61
7/1 / ---- / ---- / ---- / ---- / 5.82 / 25.48
ISA - Regen / 0.16 / 0.69 / 0.13 / 0.58 / 0.01 / 0.04
ISA - ENG14 / 13.50 / 3.38 / 14.74 / 3.69 / 1.10 / 0.28
Total / 102.81 / 394.54 / 66.90 / 232.08 / 20.26 / 109.99
ISA – Insignificant Activity not listed as an EU or EUG.
The internal combustion engines have emissions of HAP, the most significant being formaldehyde. Formaldehyde emission estimates are based on continuous operation and the emission factors below. The factors for the rich-burn engines with catalytic converters were reduced by 75% to estimate reductions due to the use of the catalytic converters. The facility is still a minor source of HAP.
Formaldehyde Emissions from the Engines
/ Factor / Est. EmissionsPoint /
Make/Model
/ Hp / MMBTUH / lb/MMBTU / lb/hr / TPYP-ENG2 / White 8G8251 / 800 / 6.20 / 0.0051 / 0.032 / 0.140
P-ENG3 / Waukesha L7042 GSI1 / 1,100 / 8.27 / 0.0051 / 0.042 / 0.184
P-ENG5 / White 6G8251 / 600 / 4.80 / 0.0051 / 0.024 / 0.105
P-ENG6 / White 8G8251 / 800 / 6.20 / 0.0051 / 0.032 / 0.140
P-ENG7 / White 8G8251 / 800 / 6.20 / 0.0051 / 0.032 / 0.140
P-ENG8 / Clark RA-8 / 800 / 8.00 / 0.0205 / 0.164 / 0.718
P-ENG9 / White 8G8251 / 800 / 6.20 / 0.0051 / 0.032 / 0.140
P-ENG10 / Caterpillar 399TA1 / 830 / 6.67 / 0.0051 / 0.034 / 0.149
P-ENG11 / White 6G8251 / 600 / 4.80 / 0.0051 / 0.024 / 0.105
P-ENG14 / Caterpillar G398TA1 / 625 / 5.24 / 0.0051 / 0.027 / 0.012
P-ENG15 / Waukesha P9390G1 / 1,194 / 9.23 / 0.0051 / 0.047 / 0.206
Totals
/ / 0.490 / 2.0391 - with catalytic converter.