adeq operating air permit · the permit and gas was no longer being re-injected into the reservoir....

ADEQ OPERATING AIR PERMIT

Pursuant to the Regulations of the Arkansas Operating Air Permit Program, Regulation #26:

Permit #: 1677-AOP-R1 AFIN: 14-00124

IS ISSUED TO:

Petro-Chem Operating Co., dba Grayson Smackover Unit 411 Highway 19 North Magnolia, AR 71753

Columbia County THIS PERMIT AUTHORIZES THE ABOVE REFERENCED PERMITTEE TO INSTALL,

OPERATE, AND MAINTAIN THE EQUIPMENT AND EMISSION UNITS DESCRIBED IN THE PERMIT APPLICATION AND ON THE FOLLOWING PAGES. THIS PERMIT IS

VALID BETWEEN: December 11, 2000 and December 10, 2005

THE PERMITTEE IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED

HEREIN. Signed:

January 26, 2005 Michael Bonds Chief, Air Division

Date Modified

Petro-Chem Operating Co. Permit #: 1677-AOP-R1 AFIN: 14-00124

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List of Acronyms and Abbreviations A.C.A. Arkansas Code Annotated NOx Nitrogen Oxide

ACGIH The American Conference of Governmental Industrial Hygienists

NSPS New Source Performance Standard

ADEQ Arkansas Department of Environmental Quality

OAQPS Office of Air Quality Planning and Standards (EPA)

AFIN ADEQ Facility Identification Number PM Particulate Matter

AP-42 EPA compilation of air pollution emission factors

PM10 Particulate Matter Smaller Than Ten Microns

BTEX Benzene, toluene, ethyl benzene, and xylene

ppd lb/day

Btu British Thermal Unit pph lb/hr

CAA or CAAA Clean Air Act (Amendments) SN Source Number

CAM Compliance Assurance Monitoring System (40 CFR Part 64)

ppm Parts per Million

CAS# Chemical Abstract Service identification number for chemical compounds

RACT Reasonably Available Control Technology

CEMS Continuous Emission Monitoring System

RTMT Rolling 12-month total

CFR Code of Federal Regulations scfm Standard cubic feet per minute

CO Carbon Monoxide SIC# Standard Classification of Establishments by type of activity (U.S. OMB)

gpm gal/min SIP State Implementation Plan (Minor Source Air Permit)

HAP Hazardous Air Pollutant SNAP Significant New Alternatives Program (SNAP)

HHV Higher Heating Value SO2 Sulfur Dioxide

mg/m3

Milligrams per cubic meter SSM Startup, Shutdown, and Malfunction Plan

MM Million Title V Portion of CAAA dealing with Major Source operating permits (40 CFR Part 70)

MMcf or MMft3 Million cubic feet Title VI Portion of CAAA dealing with Acid Rain (40 CFR Parts 72 though 78)

MSDS Material Safety Data Sheet TLV Threshold Limit Values

MVAC Motor Vehicle Air Conditioner tpy ton/yr

NAICS Codes and Titles

North American Industrial Classification Codes

µg/m3

Micrograms per cubic meter

NESHAP National Emission Standards for Hazardous Air Pollutants

UTM Universal Transverse Mercator

No. Number VOC Volatile Organic Compound


3

Table of Contents LIST OF ACRONYMS AND ABBREVIATIONS................................................................. 2 TABLE OF CONTENTS ........................................................................................................ 3

SECTION I: FACILITY INFORMATION..................................................................................... 3 SECTION II: INTRODUCTION.................................................................................................... 3

SUMMARY ............................................................................................................................ 3 PROCESS DESCRIPTION .................................................................................................... 3 REGULATIONS..................................................................................................................... 3

SECTION III: PERMIT HISTORY................................................................................................ 3 SECTION IV: EMISSION UNIT INFORMATION....................................................................... 3

GROUP #1 .................................................................................................................................. 3 LOW PRESSURE COMPRESSOR, INJECTOR COMPRESSOR UNIT & REFRIGERATION COMPRESSOR...................................................................................... 3 SN-01, SN-04, & SN-05 ......................................................................................................... 3 SPECIFIC CONDITIONS...................................................................................................... 3

GROUP #2 .................................................................................................................................. 3 FLARE NO. 1 AND FLARE NO. 2 ....................................................................................... 3 SN-03 & SN-08....................................................................................................................... 3 SPECIFIC CONDITIONS...................................................................................................... 3 CAM PLAN FOR FLARE #1 (SN-03) .................................................................................. 3

GROUP #3 .................................................................................................................................. 3 FUGITIVE EMISSIONS........................................................................................................ 3 SN-07 ...................................................................................................................................... 3 SPECIFIC CONDITIONS...................................................................................................... 3

SECTION V: COMPLIANCE PLAN AND SCHEDULE ............................................................. 3 SECTION VI: PLANTWIDE CONDITIONS................................................................................ 3 SECTION VII: INSIGNIFICANT ACTIVITIES ........................................................................... 3 SECTION VIII: GENERAL PROVISIONS................................................................................... 3


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SECTION I: FACILITY INFORMATION

Permittee ................................................................................... Petro-Chem Operating Co., dba Grayson Smackover Unit

AFIN ......................................................................................... 14-00124

Permit number........................................................................... 1677-AOP-R1

Facility address ......................................................................... 411 Highway 19 North Magnolia, AR 71753

County....................................................................................... Columbus

Contact position ........................................................................ Plant Manager, Stan Brackett

Telephone number .................................................................... (870) 234 6592

Reviewing engineer .................................................................. Richard Nissen

UTM Zone ............................................................................... 15

UTM North-South (X) ............................................................. 3685.3

UTM East-West (Y)................................................................. 475.2


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SECTION II: INTRODUCTION

Petro-Chem Operating Company, Inc. operates a sour gas processing facility known as the Grayson Smackover Unit located on Arkansas Highway 19/US Highway 371, north of the US Highway 82 by-pass near Magnolia.

Summary An injection compressor, not currently permitted nor used, will be reactivated and again used to push gas into the oil reservoir. The compressor, driven by a Waukesha Pearce 3521 GU natural gas engine, was previously designated as emission point SN-04. The original Title V permit application did not include the injection compressor and engine; the produced sales gas was being sold, not re-injected. Petro-Chem is modifying their permit to allow for the emissions produced by the injector compressor and associated engine. The facility's allowable emissions will increase by the following: NOx – 8.7 tpy; CO – 6.8 tpy; TNMHC – 0.3 tpy. Additionally, a CAM plan was added for flare SN-03.

Process Description The oil and gas produced from the wells within the Grayson Smackover Lime Unit are separated at each well site. The gas is gathered from the wells by a 25 psig gathering system that delivers the wet gas to the inlet of the facility. The low pressure wet inlet gas is first compressed through a two stage gas compressor unit to approximately 500 psig. This low pressure compressor unit is driven by a 660 horsepower natural gas fired Superior 8G-825, naturally aspirated 4-cycle rich burn gas engine (SN-01). The engine exhaust is equipped with continuous air-fuel ratio controller and catalytic converter to control NOx, CO, and HAP emissions. The 500 psig gas is then processed through an amine treating unit which will remove the H2S and CO2 that are contained in the inlet gas stream. The amine unit reboiler is a 1.5 MMBtu/hr. natural gas fueled reboiler (SN-02). The H2S and CO2 removed in the amine treating unit are sent to two continuous flares (SN-03 & SN-08) for disposal where the H2S is oxidized to SO2 and H2O. The flares are equipped with flame detection devices which will shutdown the plant if the flare flame is extinguished. The sweet gas enters a refrigeration plant for removal of natural gas liquids. The refrigeration is provided by a 200 horsepower G3306 Caterpillar, naturally aspirated gas engine (SN-05) driving a propane compressor unit. The engine exhaust was previously equipped with an air-fuel ratio controller and catalytic converter to control NOx and CO emissions. The control devices have been removed because high Btu fuel used during start-up of the facility ruins the converter. The dehydration for the refrigeration plant is provided by a 5 gallon per minute tri-ethylene glycol system which is regenerated by a 0.5 MMBtu/hr natural gas fired reboiler (SN-06). The water vapors and potential BTEX (HAPs) vapors generated from the glycol regeneration are sent to the flares (SN-03 & SN-08) for thermal destruction. The natural gas liquids recovered in the refrigeration plant are stored in a pressurized storage tank, trucked, and sold off-site. The truck loading rack is equipped with a truck vapor return line to the storage tank and therefore will not emit VOCs during the loading process. The now sweet dry natural gas is sent to a natural gas pipeline for sales.


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Regulations This facility is subject to:

• Regulation under the Clean Air Act as amended; • The Arkansas Water and Air Pollution Control Act; • The Arkansas Air Pollution Control Code (Regulation 18); • The Arkansas Plan of Implementation for Air Pollution Control (Regulation 19); • The Regulations for the Arkansas Operating Air Permit Program (Regulation 26); • New Source Performance Standards 40 CFR 60 Subpart KKK • New Source Performance Standards 40 CFR 60 Subpart LLL • New Source Performance Standards 40 CFR 60 Subpart VV except for SN-01 which

is not subject to '60.482-3 of 40 CFR 60 Subpart VV because it is in wet gas service as defined by '60.632(f) of 40 CFR Subpart KKK (the compressor contains field gas prior to the natural gas liquids extraction process).

The following table is a summary of emissions from the facility. Specific conditions and emissions for each source can be found starting on the page cross referenced in the table. This table, in itself, is not an enforceable condition of the permit. EMISSION SUMMARY Emission Rates Reference SN Description Pollutant lb/hr tpy Page

Total Allowable Emissions PM 0.7 2.0 PM10 0..7 2.0

SO2 43.1 187.8

VOC 1.1 32.9

CO 8.8 38.0

NOX 16.2 70.3

01 Low Pressure Compressor PM 0.1 0.1 Superior 8G825 PM10 0.1 0.1 660 BHP SO2 0.1 0.1 3

VOC 0.5 2 CO 1.5 6.5 NOX 3.1 13.4

02 Amine Reboiler Insignificant Activity Group A1 1.5 MMBTU/Hr

03, Flare No. 1 PM 0.4 1.7 08 Flare No. 2 PM10 0.4 1.7 SO2 42.8 187.5 3

VOC 0.2 0.9 CO 5.3 23 NOx 0.8 3.4

04 Injection Compressor PM 0.1 0.1 3


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EMISSION SUMMARY Emission Rates Reference SN Description Pollutant lb/hr tpy Page

Superior 8G825 PM10 0.1 0.1 driven by a Waukesha Pearce SO2 0.1 0.1 3521 GU natural gas engine VOC 0.3 1.2 CO 1.6 6.8 NOx 2.0 8.7

05 Refrigeration Compressor PM 0.1 0.1 3 Caterpillar G3306NA PM10 0.1 0.1 200 BHP SO2 0.1 0.1 VOC 0.1 0.3 CO 0.4 1.7 NOx 10.3 44.8

06 Glycol Reboiler Insignificant Activity Group A1 07 Fugitives VOC -- 18.5 3


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SECTION III: PERMIT HISTORY

Permit No. 1677-A was issued to Petro-Chem Operating Company, Inc. - Grayson Smackover Lime Unit on March 26, 1996. This permit was for the initial construction of the facility. The permit limits were: PM/PM10 - 1.3 tpy, SO2 - 97.3 tpy, VOC - 24.0 tpy, CO - 31.0 tpy, and NOx - 28.4 tpy. Permit No. 1677-AOP-R0, December 11, 2000, replaced a SIP permit with a Title V permit because the throughput of sour field gas through the facility had increased to where the sulfur dioxide emissions from the flare will exceed 100 ton/yr. The facility was also permitted to install a second flare (SN-08) to be operated in parallel with the existing flare (SN-03). The Superior 6G825 engine driven 600 BHP injection compressor (SN-04) had been removed from the permit and gas was no longer being re-injected into the reservoir. The air fuel ratio controller and catalytic converter were removed from the Caterpillar G3306 engine driven 200 bhp refrigeration unit compressor (SN-05) due to start-up on high Btu unprocessed fuel causing catalytic converter failure. The engine is now operated with uncontrolled emissions.


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SECTION IV: EMISSION UNIT INFORMATION


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Group #1

Low Pressure Compressor, Injector Compressor Unit & Refrigeration Compressor

SN-01, SN-04, & SN-05 A two stage gas compressor compresses the inlet gas from approximately 25 psig to 500 psig. The compressor is powered by a 600 BHP Superior 8G825 rich burn 4-cycle engine (SN-01) equipped with a continuous air fuel ratio controller and catalytic converter. The low pressure compressor (SN-01) is not subject to '60.482-3 of 40 CFR 60 Subpart VV because it is in wet gas service as defined by '60.632(f) of 40 CFR Subpart KKK (the compressor contains field gas prior to the natural gas liquids extraction process). A Caterpillar G3306 rich burn 4-cycle engine (SN-05) drives a compressor which compresses propane which is used as the refrigerant in the natural gas liquids removal plant. The engine previously operated with a continuous air fuel ratio controller and catalytic converter. The control equipment has been removed because high Btu fuel used during start-up damages the catalyst. The propane compressor (SN-05) is subject to '60.482-3 of 40 CFR 60 Subpart VV because it is not in wet gas service as defined by '60.632(f) (propane is a VOC) of 40 CFR Subpart KKK. An injection compressor (reactivated with permit revision R1) is used to push gas into the oil reservoir. The compressor, driven by a Waukesha Pearce 3521 GU natural gas engine, is designated as emission point SN-04. The original Title V permit application did not include the injection compressor and engine; the produced sales gas was being sold, not re-injected.

Specific Conditions

1. The permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by the initial compliance test required in Specific Condition No. 6 and Specific Condition No. 3 and 4. [Regulations '19.501 of the Regulations of the Arkansas Plan of Implementation for Air Pollution Control (Regulation #19) effective December 19, 2004 and 40 CFR Part 52, Subpart E]

SN Pollutant lb/hr tpy 1 PM10 0.1 0.1 SO2 0.1 0.1 VOC1 0.5 2 CO 1.5 6.5 NOX 3.1 13.4

4 PM10 0.1 0.1 SO2 0.1 0.1 VOC1 0.3 1.2 CO 1.6 6.8 NOX 2.0 8.7

5 PM10 0.1 0.1 SO2 0.1 0.1 VOC1 0.1 0.3 CO 0.4 1.7 NOX 10.3 44.8

1 - Several De Minimus HAPs are included in the VOC totals.


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2. The permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by the compliance test required in Specific Condition No. 6 and Specific Condition No. 3 and 4. [Regulations '18.801 of the Arkansas Air Pollution Control Code (Regulation #18) effective February 15, 1999, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311]

SN Pollutant lb/hr tpy 1 PM 0.1 0.1 4 PM 0.1 0.1 5 PM 0.1 0.1

3. The permittee shall only use pipeline quality natural gas as a fuel in SN-01 and SN-05. Pipeline quality natural gas is defined as gas which contains less than 0.3 grain/100 SCF of H2S and that H2S constitutes greater than 50% by weight of the sulfur by weight in the natural gas. The permittee can fuel the engines during start-up with fuel gas which has not been processed through the refrigeration unit, but using fuel which has not been processed through the amine unit is not allowed at any time. [Regulations '19.705 of Regulation 19, A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, and 40 CFR 70.6]

4. The permittee shall not operate SN-01 without a functional fuel air ratio controller and catalytic converter. [Regulations '19.705 of Regulation 19, A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, and 40 CFR 70.6]

5. The permittee shall not exceed 5% opacity from SN-01 and SN-05. Compliance with Specific Condition No. 3 shall be deemed compliance with the opacity limit set in this Specific Condition. [Regulations '18.501 of Regulation 18 and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311]

6. The permittee shall simultaneously conduct tests for CO and NOx on each compressor engine (SN-01 & SN-05) in accordance with Plantwide Condition No. 4 and every 5 years thereafter. EPA Reference Method 7E shall be used to determine NOX and EPA Reference Method 10 shall be used to determine CO. The permittee shall test engines within 90% of their rated capacity. If the tests are not performed within this range, the permittee shall be limited to operating within 10% above the tested range. If the tested emission rate for any pollutant is in excess of the permitted emission rate, all engines shall be tested for that pollutant. Testing shall be coordinated in advance with the Compliance Inspector Supervisor, at the address below:

Arkansas Department of Environmental Quality Air Division ATTN: Compliance Inspector Supervisor P.O. Box 8913 Little Rock, AR 72219-8913


12

If prior testing has been performed on these engines and their associated control equipment within the past two years using the above test methods, the permittee can receive credit for initial testing by submitting the results to the above address with an explanatory cover letter. [Regulations '19.702 of Regulation 19 and 40 CFR Part 52, Subpart E]

7. The low pressure compressor (SN-01) is exempt from the compressor control requirements of 40 CFR 60.482-3 because it is a reciprocating compressor in wet gas service (the compressor contains field gas prior to the natural gas liquids extraction process). In order to document this exemption, the permittee shall record, in a log that is kept in a readily accessible location, information and data used to demonstrate that a reciprocating compressor is in wet gas service. [Regulations '19.304 of Regulation #19 and 40 CFR '60.633(f)]

8. The propane refrigeration compressor (SN-05) shall either be equipped as follows:

a. The seal is equipped with a closed vent system connected to the plant flare system capable of capturing and destroying any leakage as described in '60.482-3(h); or

b. Is demonstrated to be operating with no detectable emissions, as indicated by an instrument of reading of less than 500 ppm above background by an initial test and annually thereafter as described in '60.482-3(i).

[Regulations '19.304 of Regulation #19 and 40 CFR '60.482-3]


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Group #2

Flare No. 1 and Flare No. 2

SN-03 & SN-08 The H2S and CO2 removed in the amine treating unit are sent to a continuous flare (Flare No.1) where the H2S is oxidized to SO2 and H2O and the acid gases are vented. The Flare No. 1 is equipped with a flame detection device which will initiate a plant shutdown if the flare flame is extinguished. Flare No. 2 is a backup flare system for No. 1 and will assist Flare No. 1's duty of flaring inlet gas when the entire feed stream is flared due the amine plant being down. The sulfur dioxide emission rates will remain the same whether the hydrogen sulfide is flared with the feed stream or as the removed impurity vented from the amine still column.

Specific Conditions

9. The permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by the material balance required in Specific Condition No. 15. [Regulations '19.501 of Regulation #19 and 40 CFR Part 52, Subpart E]

SN Pollutant lb/hr tpy 03, 08 PM10 0.4 1.7

SO2 42.8 187.5 VOC 0.2 0.9 CO 5.3 23 NOX 0.8 3.4

10. The permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by the material balance required in Specific Condition No. 15. [Regulations '18.801 of the Arkansas Air Pollution Control Code (Regulation #18) effective February 15, 1999, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311]

SN Pollutant lb/hr tpy 03, 08 PM 0.4 1.7

11. The permittee shall meet the following requirements to show compliance with NSPS-Subpart LLL-Standards of performance for On Shore Natural Gas Processing: SO2 Emissions (Appendix A of this permit): a. To certify that this facility is exempt from the control requirements of Subpart

LLL, the owner or operator of this facility shall keep, for the life of the facility, an analysis demonstrating that the facility's design capacity is less than 2 long tons per day of hydrogen sulfide in the acid gas expressed as sulfur.

[Regulations '19.304 of Regulation #19 and NSPS Subpart LLL '60.647(c)]


14

12. The permittee shall ensure that the flare complies with all applicable requirements of 40 CFR '60.18. 40 CFR '60.18 can be found in Appendix D of this permit. [Regulations '19.304 of Regulation #19 and 40 CFR '60.18]

13. The permittee shall install, maintain, and operate a device to continuously measure the flow rate of sour field gas to the amine sweetening unit. The monitoring device reading shall be recorded at least once per hour during each 24-hour period. The average acid gas flow rate shall be computed from the individual readings. Records shall be kept on the amount of sour field gas processed daily. These records shall be kept on site and made available to Department personnel upon request. [Regulations '19.705 of Regulation #19 and 40 CFR Part 52, Subpart E]

14. The concentration of hydrogen sulfide in the sour gas entering the facility shall be measured at least once per month. This sample shall be analyzed by the Tutwiler procedure in 40 CFR §60.648. These records shall be kept on site and be made available to Department personnel upon request. [Regulations '19.705 of Regulation #19 and 40 CFR Part 52, Subpart E]

15. This facility shall not emit more than 16.0 tons per month of sulfur dioxide from the flares. The permittee shall calculate the amount of sulfur dioxide emitted from the flares each month by using the following equation: (0.8425)(H2S)(MMSCF gas processed that month) = tons/month SO2. Where: H2S is the most recent H2S content of the sour gas, in mole or volume percent. (1700 ppm = 0.17 mole percent) The permittee shall keep all records of the monthly emissions of SO2 from the flares on site and available for inspection by Department personnel. Copies of these records shall be submitted with the semi-annual report required in General Provision No. 7. The facility shall not emit more than 187.5 tons of SO2 during any 12-month consecutive period. [Regulations '19.705 of Regulation #19 and 40 CFR Part 52, Subpart E]

16. The permittee shall not exceed 0% opacity from SN-03 and SN-08, except for periods not to exceed a total of 5 minutes during any consecutive 2 hour period. Reference Method 22 shall be used to determine compliance with the visible emissions portions of this permit for SN-03 and SN-08. The observation period is 2 hours and shall be used according to Method 22. [Regulations '19.705 of Regulation 19 and 40 CFR 52, Subpart E and 40 CFR '60.18(b)]


15

17. Observations of the opacity from these sources shall be conducted by personnel familiar with the permittee=s visible emissions. The permittee shall maintain personnel familiar with EPA Reference Method 9 and 22. If visible emissions which appear to be in excess of the permitted opacity are detected, the permittee shall immediately take action to identify the cause of the visible emissions, implement corrective action, and document that visible emissions did not appear to be in excess of the permitted opacity following the corrective action. The permittee shall maintain records which contain the following items in order to demonstrate compliance with this Specific Condition. These records shall be updated weekly, kept on site, and made available to Department personnel upon request. a. The date and time of the observation; b. If visible emissions which appeared to be above the permitted limit were detected; c. If visible emissions which appeared to be above the permitted limit were detected;

the cause of the exceedance of the opacity limit, the corrective action taken, and if the visible emissions appeared to be below the permitted limit after the corrective action was taken; and

d. The name of the person conducting the opacity observations. [Regulations '19.705 of Regulation 19 and 40 CFR 52, Subpart E]

CAM plan for Flare #1 (SN-03)

18. The permittee shall install, operate, and maintain a flame detection device on the flare’s pilot during the the time that the plant is operational. [Regulation 19, §19.703 of Regulation 19 - Regulations of the Arkansas Plan of Implementation for Air Pollution Control and 40 CFR part 52, Subpart E, and 40 CFR Section 64.6]

19. An Alarm (visible and/or audible) shall be triggered when the flame detection device fails to detect a flame in the flare. [Regulation 19, §19.703 of Regulation 19 - Regulations of the Arkansas Plan of Implementation for Air Pollution Control and 40 CFR part 52, Subpart E, and 40 CFR Section 64.6(c)(1)]


16

Group #3

Fugitive Emissions

SN-07 The valves, pumps, compressor seals, flanges and relief valves periodically have leaks which escape to atmosphere. The volume of these leaks is based on EPA 453/R-93-026, Factors for Gas Plants, EPA AP-42, Factors for Petroleum Refineries, and good operating practices.

Specific Conditions

20. The permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by the good operating practices which are in the other Specific Conditions for this Source. [Regulations '19.501 of Regulation #19 and 40 CFR Part 52, Subpart E]

SN Pollutant lb/hr tpy 7 VOC -- 18.5

21. Each pump shall be checked by visual inspection each calendar week for indications of liquids dripping from the pump seal. If there are indications of liquids dripping from the pump seal a leak is detected. When a leak is detected, it shall be repaired as soon as practical, but not later than 15 calendar days after it is detected. A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. Delay of repair for pumps will be allowed if repair requires the use of a dual mechanical seal system that includes a barrier fluid system, and repair is completed as soon as practicable, but not later than 6 months after the leak was detected. [Regulations '19.304 of Regulation #19 and 40 CFR '60.482-2 paragraphs (a)2, (b)2, (c)1, and c(2)]

22. Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or a second valve. The cap, blind flange, plug, or second valve shall seal the open end at all times except during operations requiring process fluid flow through the open-ended valve or line. Each open-ended valve or line equipped with a second valve shall be operated in a manner such that the valve on the process fluid end is closed before the second valve is closed. When a double block-and-bleed system is being used, the bleed valve or line may remain open during operations that require venting the line between the block valves but shall comply with the first two sentences in this Specific Condition. [Regulations '19.304 of Regulation #19 and 40 CFR '60.482-6 paragraphs (a)1, (b), and (c)]

23. The pumps, valves, and pressure relief devices are exempt from the routine monitoring requirements of 40 CFR 60.482-2(a)(1) and 60.482-7(a), and 60.633(b)(1) because this facility does not have the design capacity to process more than 10 million standard cubic feet per day of field gas. [Regulations '19.304 of Regulation #19 and 40 CFR '60.633(d)]


17

24. The permittee shall submit semiannual reports to the Compliance Inspector Supervisor, Arkansas Department of Environmental Quality, 8001 National Drive, P.O. Box 8913, Little Rock, AR 72219, accompanying the reporting required in General Provision No. 7. Each report to this Department shall include the following information: a. Process unit identification; b. Number of pumps subject to the requirements of Specific Condition 19 of this

permit; c. Number of pumps for which leaks were detected as described in Specific

Condition No. 19 of this permit; d. Number of pumps for which leaks were not repaired as required in Specific

Condition No. 19 of this permit; e. The facts that explain each delay of repair and, where appropriate, why a process

unit shutdown was technically infeasible; f. Dates of process unit shutdowns which occurred within the semiannual reporting

period; g. Revisions to items reported in the semiannual report if changes have occurred

since the initial report or subsequent revisions to the initial report. [Regulations '19.304 of Regulation #19 and 40 CFR '60.487]

25. The permittee shall comply with the following record keeping requirements: a. When each leak is detected on a pump, a weatherproof and readily visible

identification, marked with equipment identification number, shall be attached to the leaking pump.

b. The identification may be removed after the leak has been repaired. c. When each leak is detected as specified in Specific Condition No. 21, the

following information shall be kept for 2 years in a readily accessible location: i. The equipment identification number; ii. The date the leak was detected and the dates of each attempt to repair the

leak; iii. Repair methods applied in each attempt to repair the leak; iv. "Repair Delayed" and the reason for the delay if a leak is not repaired

within 15 calendar days after discovery of the leak; v. The signature of the owner or operator (or designate) whose decision it

was that repair could not be effected without a process shutdown; vi. The expected date of successful repair of the leak if a leak is not repaired

within 15 days; vii. Dates of process unit shutdown that occur while the equipment is not

repaired; and viii. The date the leak was repaired.

d. The following information pertaining to the design requirements for the flare as described in 40 CFR 60.18 and in Specific Condition No. 12 of this permit shall be recorded and kept in a readily accessible location:


18

i. Detailed schematics, design specifications, and piping and instrumentation diagrams; and

ii. The dates and descriptions of changes in the design specifications.

e. A description of the parameters monitored, as required in 40 CFR §60.18 and Specific Condition No. 12 of this permit to ensure that the flare is operated and maintained in conformance with its design and an explanation of why that parameter (or parameters) was selected for the monitoring. i. Periods when the flare is not operated as designed, including periods when

the flare pilot light does not have a flame; and ii. Dates of flare startups and shutdowns.

f. A list of identification numbers for the flare and pumps shall be recorded in a log that is kept in a readily accessible location.

[Regulations '19.304 of Regulation #19 and 40 CFR '60.486]

26. The permittee shall insure that all VOC and HAP vapors produced by the regeneration of the glycol solution in the dehydration unit still column are routed to the flares (SN-03 & SN-08) for thermal destruction. The permittee shall also bottom load all NGL products trucked for sale from this facility into a truck rated at least 200 psig MWP with a properly connected vapor return line resulting in no detectable VOC and HAP loading losses. [Regulations '19.705 of Regulation 19, A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, and 40 CFR 70.6]


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SECTION V: COMPLIANCE PLAN AND SCHEDULE

Petro-Chem Operating Co., Inc. dba Grayson Smackover Unit will continue to operate in compliance with those identified regulatory provisions. The facility will examine and analyze future regulations that may apply and determine their applicability with any necessary action taken on a timely basis.


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SECTION VI: PLANTWIDE CONDITIONS

1. The permittee shall notify the Director in writing within thirty (30) days after commencing construction, completing construction, first placing the equipment and/or facility in operation, and reaching the equipment and/or facility target production rate. [Regulation 19, §19.704, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

2. If the permittee fails to start construction within eighteen months or suspends construction for eighteen months or more, the Director may cancel all or part of this permit. [Regulation 19, §19.410(B) and 40 CFR Part 52, Subpart E]

3. The permittee must test any equipment scheduled for testing, unless stated in the Specific Conditions of this permit or by any federally regulated requirements, within the following time frames: (1) new equipment or newly modified equipment within sixty (60) days of achieving the maximum production rate, but no later than 180 days after initial start up of the permitted source or (2) operating equipment according to the time frames set forth by the Department or within 180 days of permit issuance if no date is specified. The permittee must notify the Department of the scheduled date of compliance testing at least fifteen (15) days in advance of such test. The permittee shall submit the compliance test results to the Department within thirty (30) days after completing the testing. [Regulation 19, §19.702 and/or Regulation 18 §18.1002 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

4. The permittee must provide: [Regulation 19, §19.702 and/or Regulation 18, §18.1002 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311] a. Sampling ports adequate for applicable test methods; b. Safe sampling platforms; c. Safe access to sampling platforms; and d. Utilities for sampling and testing equipment.

5. The permittee must operate the equipment, control apparatus and emission monitoring equipment within the design limitations. The permittee shall maintain the equipment in good condition at all times. [Regulation 19, §19.303 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

6. This permit subsumes and incorporates all previously issued air permits for this facility. [Regulation 26 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]


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SECTION VII: INSIGNIFICANT ACTIVITIES

The following sources are insignificant activities. Insignificant and trivial activities will be allowable after approval and federal register notice publication of a final list as part of the operating air permit program. Any activity for which a state or federal applicable requirement applies is not insignificant even if this activity meets the criteria of '3(d) of Regulation 26 or is listed below. Insignificant activity determinations rely upon the information submitted by the permittee in an application dated June 24, 2004. [Regulation '26.3(d) of Regulation 26]

Description Category

SN-02 - Amine Reboiler - 1.5 MMBTU/Hr - natural gas fuel A1 SN-06 - Glycol Reboiler - 0.5 MMBTU/Hr - natural gas fuel A1

The following emission units, operations, or activities have been determined by the Department to be insignificant activities. Activities included in this list are allowable under this permit and need not be specifically identified. [Regulation '26.3(d) of Regulation 26]


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SECTION VIII: GENERAL PROVISIONS

1. Any terms or conditions included in this permit which specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 ) as the sole origin of and authority for the terms or conditions are not required under the Clean Air Act or any of its applicable requirements, and are not federally enforceable under the Clean Air Act. Arkansas Pollution Control & Ecology Commission Regulation 18 was adopted pursuant to the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 ). Any terms or conditions included in this permit which specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 ) as the origin of and authority for the terms or conditions are enforceable under this Arkansas statute. [40 CFR 70.6(b)(2)]

2. This permit shall be valid for a period of five (5) years beginning on the date this permit becomes effective and ending five (5) years later. [40 CFR 70.6(a)(2) and §26.701(B) of the Regulations of the Arkansas Operating Air Permit Program (Regulation 26), effective August 10, 2000]

3. The permittee must submit a complete application for permit renewal at least six (6) months before permit expiration. Permit expiration terminates the permittee’s right to operate unless the permittee submitted a complete renewal application at least six (6) months before permit expiration. If the permittee submits a complete application, the existing permit will remain in effect until the Department takes final action on the renewal application. The Department will not necessarily notify the permittee when the permit renewal application is due. [Regulation 26, §26.406]

4. Where an applicable requirement of the Clean Air Act, as amended, 42 U.S.C. 7401, (Act) is more stringent than an applicable requirement of regulations promulgated under Title IV of the Act, the permit incorporates both provisions into the permit, and the Director or the Administrator can enforce both provisions. [40 CFR 70.6(a)(1)(ii) and Regulation 26, §26.701(A)(2)]

5. The permittee must maintain the following records of monitoring information as required by this permit. [40 CFR 70.6(a)(3)(ii)(A) and Regulation 26, §26.701(C)(2)]

a. The date, place as defined in this permit, and time of sampling or measurements; b. The date(s) analyses performed; c. The company or entity performing the analyses; d. The analytical techniques or methods used; e. The results of such analyses; and f. The operating conditions existing at the time of sampling or measurement.


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6. The permittee must retain the records of all required monitoring data and support information for at least five (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 this permit. [40 CFR 70.6(a)(3)(ii)(B) and Regulation 26, §26.701(C)(2)(b)]

7. The permittee must submit reports of all required monitoring every six (6) months. If permit establishes no other reporting period, the reporting period shall end on the last day of the anniversary month of the initial Title V permit. The report is due within thirty (30) days of the end of the reporting period. Although the reports are due every six months, each report shall contain a full year of data. The report must clearly identify all instances of deviations from permit requirements. A responsible official as defined in Regulation No. 26, §26.2 must certify all required reports. The permittee will send the reports to the address below: [40 C.F.R. 70.6(a)(3)(iii)(A) and Regulation 26, §26.701(C)(3)(a)]

Arkansas Department of Environmental Quality Air Division ATTN: Compliance Inspector Supervisor Post Office Box 8913 Little Rock, AR 72219

8. The permittee will report to the Department all deviations from permit requirements, including those attributable to upset conditions as defined in the permit. a. For all those attributable to upset conditions and those that result in excess

emissions, the permittee will make an initial report to the Department by the next business day after the discovery of the occurrence. The initial report may be made by telephone and shall include: i. The facility name and location, ii. The process unit or emission source deviating from the permit limit, iii. The permit limit, including the identification of pollutants, from which

deviation occurs, iv. The date and time the deviation started, v. The duration of the deviation, vi. The average emissions during the deviation, vii. The probable cause of such deviations, viii. Any corrective actions or preventive measures taken or being taken to

prevent such deviations in the future, and ix. The name of the person submitting the report.

The permittee will make a full report in writing to the Department within five (5) business days of discovery of the occurrence. The report must include, in addition to the information required by the initial report, a schedule of actions taken or planned to eliminate future occurrences and/or to minimize the amount the permit’s limits were exceeded and to reduce the length of time the limits were exceeded. The permittee may submit a full report in writing (by facsimile,


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overnight courier, or other means) by the next business day after discovery of the occurrence, and the report will serve as both the initial report and full report.

b. All other deviations, as well as those attributable to upset conditions, will be reported on semi-annual reporting and annual certifications as required in this permit.

[40 CFR 70.6(a)(3)(iii)(B), Regulation No. 26 §26.701(C)(3)(b), Regulation No. 19 §19.601 and §19.602]

9. If any provision of the permit or the application thereof to any person or circumstance is held invalid, such invalidity will not affect other provisions or applications hereof which can be given effect without the invalid provision or application, and to this end, provisions of this Regulation are declared to be separable and severable. [40 CFR 70.6(a)(5), Regulation 26, §26.701(E), and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

10. The permittee must comply with all conditions of this Part 70 permit. Any permit noncompliance with applicable requirements as defined in Regulation 26 constitutes a violation of the Clean Air Act, as amended, 42 U.S.C. §7401, and is grounds for enforcement action; for permit termination, revocation and reissuance, for permit modification; or for denial of a permit renewal application. [40 CFR 70.6(a)(6)(i) and Regulation 26, §26.701(F)(1)]

11. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity to maintain compliance with the conditions of this permit. [40 CFR 70.6(a)(6)(ii) and Regulation 26, §26.701(F)(2)]

12. The Department may modify, revoke, reopen and reissue the permit or terminate the permit for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition. [40 CFR 70.6(a)(6)(iii) and Regulation 26, §26.701(F)(3)]

13. This permit does not convey any property rights of any sort, or any exclusive privilege. [40 CFR 70.6(a)(6)(iv) and Regulation 26, §26.701(F)(4)]

14. The permittee must furnish to the Director, within the time specified by the Director, any information that the Director may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the permittee must also furnish to the Director copies of records required by the permit. For information the permittee claims confidentiality, the Department may require the permittee to furnish such records directly to the Director along with a claim of confidentiality. [40 CFR 70.6(a)(6)(v) and Regulation 26, §26.701(F)(5)]

15. The permittee must pay all permit fees in accordance with the procedures established in Regulation 9. [40 CFR 70.6(a) (7) and Regulation 26, §26.701(G)]


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16. No permit revision shall be required, under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes provided for elsewhere in this permit. [40 CFR 70.6(a)(8) and Regulation 26, §26.701(H)]

17. If the permit allows different operating scenarios, the permittee shall, contemporaneously with making a change from one operating scenario to another, record in a log at the permitted facility a record of the operational scenario. [40 CFR 70.6(a)(9)(i) and Regulation 26, §26.701(I)(1)]

18. The Administrator and citizens may enforce under the Act all terms and conditions in this permit, including any provisions designed to limit a source’s potential to emit, unless the Department specifically designates terms and conditions of the permit as being federally unenforceable under the Act or under any of its applicable requirements. [40 CFR 70.6(b) and Regulation 26, §26.702(A) and (B)]

19. Any document (including reports) required by this permit must contain a certification by a responsible official as defined in Regulation 26, §26.2. [40 CFR 70.6(c)(1) and Regulation 26, §26.703(A)]

20. The permittee must allow an authorized representative of the Department, upon presentation of credentials, to perform the following: [40 CFR 70.6(c)(2) and Regulation 26, §26.703(B)] a. Enter upon the permittee’s premises where the permitted source is located or

emissions related activity is conducted, or where records must be kept under the conditions of this permit;

b. Have access to and copy, at reasonable times, any records required under the conditions of this permit;

c. Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit; and

d. As authorized by the Act, sample or monitor at reasonable times substances or parameters for assuring compliance with this permit or applicable requirements.

21. The permittee shall submit a compliance certification with the terms and conditions contained in the permit, including emission limitations, standards, or work practices. The permittee must submit the compliance certification annually within 30 days following the last day of the anniversary month of the initial Title V permit. The permittee must also submit the compliance certification to the Administrator as well as to the Department. All compliance certifications required by this permit must include the following: [40 CFR 70.6(c)(5) and Regulation 26, §26.703(E)(3)] a. The identification of each term or condition of the permit that is the basis of the

certification; b. The compliance status; c. Whether compliance was continuous or intermittent;


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d. The method(s) used for determining the compliance status of the source, currently and over the reporting period established by the monitoring requirements of this permit;

e. and Such other facts as the Department may require elsewhere in this permit or by §114(a)(3) and §504(b) of the Act.

22. Nothing in this permit will alter or affect the following: [Regulation 26, §26.704(C)] a. The provisions of Section 303 of the Act (emergency orders), including the

authority of the Administrator under that section; b. The liability of the permittee for any violation of applicable requirements prior to

or at the time of permit issuance; c. The applicable requirements of the acid rain program, consistent with §408(a) of

the Act or, d. The ability of EPA to obtain information from a source pursuant to §114 of the

Act.

23. This permit authorizes only those pollutant emitting activities addressed in this permit. [A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

adeq operating air permit · the permit and gas was no longer being re-injected into the reservoir....

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