c.emissions unit terms and conditions · web viewexcept when maintenance or repair of the...

Permit Number: P010XXXXFacility Name:

Facility ID: 0000000000Leak Detection w/ Glycol Dehydration Unit

File Name: NG.processing.leaks.docx

Last Revised: 6/18/12 for OOOO leak requirementsTerms Last Revised: 6/02/2016

Note: Search for “XX” to fill in the TPY limit

Leak Detection for Natural Gas and Natural Gas Liquids Processing PlantsWith Major Source Dehydrator

Template Permit

Note: A Natural Gas Processing Plant is defined as any processing site engaged in the extraction of natural gas liquids (NGL) from field gas, or the fractionation of mixed NGL to natural gas products, or a combination of both (40 CFR 63.761).

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C. Emissions Unit Terms and Conditions

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1. Emissions Unit: Dehydration System, P001

Operations, Property and/or Equipment Description:

P001 Glycol dehydration unit(s) with flash separator (includes contact tower or absorption column and glycol dehydration unit reboiler) and gas-condensate-glycol (GCG) separator (flash separator).

a) This permit document constitutes a permit-to-install issued in accordance with ORC 3704.03(F) and a permit-to-operate issued in accordance with ORC 3704.03(G).

(1) For the purpose of a permit-to-install document, the emissions unit terms and conditions identified below are federally enforceable with the exception of those listed below which are enforceable under state law only.

a. None.

(2) For the purpose of a permit-to-operate document, the emissions unit terms and conditions identified below are enforceable under state law only with the exception of those listed below which are federally enforceable.

a. None.

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measuresa. ORC 3704.03(T) Emissions of Volatile Organic Compounds (VOC)

(excludes methane and ethane) shall not exceed XX tons/year.

Use of a dehydration system flash separator that captures flash vapors.

Use of control as needed to comply with the XX tons VOC/year emission limit.

The requirements of this rule include compliance with the applicable requirements of 40 CFR Part 63 Subpart HH.

See b)(2)a. and c.b. Part 63, Subpart HH, National

Emission Standards for hazardous air pollutants

Compliance with the applicable portions of 40 CFR Part 63, Subpart HH. Any final amendments to this rule will supersede the requirement(s) in this permit.

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Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures(NESHAP) from Oil and Natural Gas Production Facilities In accordance with 40 CFR 63.765 and 40 CFR

63.771, the glycol dehydration unit at a major source of HAP shall be vented through a closed-vent system to a control device that shall either:

1. reduce either TOC (minus methane and ethane) or total HAP by 95% or to less than 20 ppmv on a dry basis corrected to 3% oxygen; or

2. reduce benzene to a level less than 0.90 megagrams per year (MG/yr); or

3. the process vent emissions from the glycol dehydrator shall be controlled by an open flare designed and operated in accordance with 40 CFR 63.11; or

4. as an alternative, the process vent from the dehydrator may be connected to a process natural gas line through a closed vent system.

See b)(2)b. and c.c. OAC rule 3745-17-07(A)(1)(a) A major source for HAP is required to be operated

with a closed vent system with no visible emissions; therefore the requirements of this rule are less stringent than the requirements of Part 63, Subpart HH.

(2) Additional Terms and Conditions

a. The permittee has satisfied the Best Available Technology (BAT) requirements pursuant to OAC paragraph 3745-31-05(A)(3), as effective November 30, 2001, in this permit. On December 1, 2006, paragraph (A)(3) of OAC rule 3745-31-05 was revised to conform to ORC changes effective August 3, 2006 (S.B. 265 changes), such that BAT is no longer required by State regulation for NAAQS pollutant less than ten tons per year. However, that rule revision has not yet been approved by U.S. EPA as a revision to Ohio’s State Implementation Plan (SIP). Therefore, until the SIP revision occurs and the U.S. EPA approves the revision to OAC rule 3745-31-05, the requirement to satisfy BAT still exists as part of the federally–approved SIP for Ohio. Once U.S. EPA approves the December 1, 2006 version of 3745-31-05, then BAT no longer applies.

b. Compliance with the National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities, Part 63, Subpart HH shall be demonstrated through one of the following methods:

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i. using a closed vent system meeting the requirements of 40 CFR 63.771(c) and an enclosed combustion device meeting the requirements of 40 CFR 63.771(d), emissions of TOC (minus methane and ethane) or the emissions of total HAP from the dehydration unit shall be reduced by 95% or to less than 20 ppmv on a dry basis corrected to 3% oxygen, as determined in accordance with 40 CFR 63.772(e); or

ii. using a closed vent system meeting the requirements of 40 CFR 63.771(c) and a vapor recovery device meeting the requirements of 40 CFR 63.771(d), emissions of TOC (minus methane and ethane) or the emissions of total HAP from the dehydration unit shall be reduced by 95%, as determined in accordance with 40 CFR 63.772(e); or

iii. using a closed vent system meeting the requirements of 40 CFR 63.771(c) and a control device meeting the requirements of 40 CFR 63.771(d), emissions of benzene from the dehydration unit shall be reduced to a level less than 0.90 MG/yr; or

iv. emissions from the glycol dehydrator shall be vented through a closed vent system meeting the requirements of 40 CFR 63.771(c) to an open flare designed and operated in accordance with 40 CFR 63.11; or

v. as an alternative, the process vent from the dehydrator may be connected to a process natural gas line through a closed vent system meeting the requirements of 40 CFR 63.771(c).

[40 CFR 63.765], [40 CFR 63.771(c) and (d)], and [40 CFR 63.11(b)]

c. Where using a flare for compliance, i.e., subject to the control standards in Part 63, Subpart HH, there shall be no visible emissions from the flare, except for periods not to exceed a total of 5 minutes during any 2 consecutive hours.

[40 CFR 63.772(e)(2)] and [40 CFR 63.11(b)(4)]

d. Except when maintenance or repair of the dehydrator or closed-vent system cannot be completed without shutdown of the control device, each control device used to comply with the requirements of 40 CFR Part 63, Subpart HH shall be operated at all times during process operations.

[40 CFR 63.771(d)(4)(i)]

c) Operational Restrictions

Applicable Rule Requirement

(1) 40 CFR 63.765 and40 CFR 63.771(c) and (d)

Design and operational requirements for a closed-vent system and the control device used to comply with 40 CFR 63.764(d)(1).

(2) 40 CFR 63.771(c)(3); and40 CFR 63.773(c)(2)(iv)

Each bypass device to a closed-vent system meeting the requirements of 40 CFR 63.771(c) must be installed with a flow indicator which takes a reading once every 15 minutes and is installed with an alarm (for any bypass);

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or must install a car-seal or lock-and–key mechanism on the bypass device to maintain the bypass valve in a closed position.

(3)40 CFR 63.771(d)(1)(iii); and

40 CFR 63.772(e)(2).

A flare, used to demonstrate compliance with 40 CFR 63.771(d), must be designed and operated in accordance with 40 CFR 63.11(b).

(4)40 CFR 63.771(d)(1)(ii) and (d)(4)

A condenser used to demonstrate compliance with 40 CFR 63.764(d)(1) must be designed and operated to reduce TOC or total HAP by 95% in accordance with 40 CFR 63.772(g) and must be operated at all times during process operations.

(5)40 CFR 63.771(d)(1)(ii), (d)(4), and (d)(5)

A carbon adsorber used to demonstrate compliance with 40 CFR 63.764(d)(1) must be designed and operated to reduce TOC or total HAP by 95% and must be operated at all times during process operations. The spent carbon must be monitored, regenerated, reactivated, or burned as required in 40 CFR 63.771(d)(5).

(6)40 CFR 63.771(d)(1)(i) and (d)(4)

A combustion device, other than a flare, used to demonstrate compliance with 40 CFR 63.764(d)(1) must be designed and operated in accordance with this paragraph and must be operated at all times during process operations.

d) Monitoring and/or Recordkeeping Requirements

(1) The following monitoring and recordkeeping requirements are applicable to the dehydrator:


a. 40 CFR 63.760(a)(1)(ii) The owner or operator of the dehydration unit shall maintain records of the annual facility natural gas or hydrocarbon liquid throughput for each year.

b. 40 CFR 63.773(c) Inspection requirements for a closed-vent system for a dehydration unit subject to control.

c. 40 CFR 63.774(b)(5) through (8)

Records required for each inspection of the closed-vent system for a dehydration unit subject to control.

d. 40 CFR 63.773(d)(3)(i)(C) and

40 CFR 63.774(e)

Where a flare is used to comply with the requirements of 40 CFR 63.764(d), it must be equipped with a continuous recorder for the thermocouple or a heat sensing monitoring device for the pilot flame. A record must be maintained of: all periods of time when the pilot flame is out when process gas is being vented to it; all required visible emission readings; the flare design; and the heat content, flowrate, and exit velocity determinations.

e. 40 CFR 63.773(c)(2)(iv); A record shall be maintained for: the flow indicator readings for each bypass device to the closed-vent system and/or a record of the monthly inspection of

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40 CFR 63.773(d)(6)(v); and

40 CFR 63.771(c)(3)(i)

the car-seal/lock-and–key mechanism on the bypass device, and a record of each detected bypass.

f. 40 CFR 63.772(c),(e),(f), and (g); and40 CFR 63.774(a),(b), and (e)

For 40 CFR 63.764(c)

Must maintain the records required to demonstrate compliance, i.e., leak detection results demonstrating no detectable emissions from the closed-vent system and the appropriate performance test and emission test data of the control device.

g. 40 CFR 63.772(f) and (g);

40 CFR 63.773(d); and

40 CFR 63.774(b)(4)

If using an enclosed combustion or vapor recovery device to demonstrate compliance with Part 63, Subpart HH, the maximum or minimum monitoring parameter values must be recorded and maintained in accordance with these paragraphs.

h. 40 CFR 63.773(d)(3)(i)(E) A condenser used to demonstrate compliance with 40 CFR 63.764(c)(1) must be equipped with a temperature monitoring device and must meet the monitoring and recordkeeping requirements of this paragraph.

i. 40 CFR 63.773(d)(3)(i)(F) or (G)

A carbon adsorption system used to demonstrate compliance with 40 CFR 63.764(c)(1) must meet the monitoring and recordkeeping requirements of this paragraph.

j. 40 CFR 63.773(d)(3)(i)(A), (B) or (D)

A combustion device used to demonstrate compliance with 40 CFR 63.764(c)(1) must be equipped with a continuous temperature monitoring device and must meet the monitoring and recordkeeping requirements of this paragraph.

k. 40 CFR 63.772(e)(4) This paragraph allows for a design analysis to be conducted for the control device to meet the requirements of 40 CFR 63.771(d)(1) or (e)(3), the requirements for the compliance demonstration using each type of control device.

l. 40 CFR 63.773(d)(4) Using the continuous data collected and recorded as required in the 40 CFR 63.773(d)(3), the daily average value for each monitored operating parameter must be calculated for each operating day. Valid data points must be available for 75% of the operating hours each day.

m. 40 CFR 63.773(d)(5) For each operating parameter monitor installed in accordance w/ 40 CFR 63.773(d), a minimum or maximum operating parameter must be established to define conditions at which the control device must be operated to continuously achieve the performance requirements of 40 CFR 63.771(d)(1) or (e)(3). This paragraph allows operating parameter values to be established based on design analysis and the manufacturer’s recommendations.

n. 40 CFR 63.774(b) If subject to the requirements of Part 63, Subpart HH, the applicable records identified in 40 CFR 63.774 and 40 CFR 63.10 must be maintained for a period of 5

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years following the date of record and they must be accessible upon request.

o. Table 2 to Part 63, Subpart HH

Table 2 identifies the applicable recordkeeping requirements from the General Provisions of Part 63 (Subpart A, 40 CFR 63.8 and 40 CFR 63.10).

(2) Except for any part of the closed-vent system that is/are designated as unsafe or difficult to inspect, each closed-vent system component, i.e., joints, seams, connections that are permanently or semi-permanently sealed, or other components, shall be inspected in accordance with the following procedures and schedule specified below:

a. The permittee shall conduct an initial inspection according to the procedures specified in 40 CFR 63.772(c) to demonstrate that the closed-vent system operates with no detectable emissions.

b. The permittee shall conduct annual visual inspections for defects that could result in air emissions. Defects include, but are not limited to, visible cracks, holes, or gaps in piping or ductwork; loose connections; or broken or missing caps or other closure devices. The permittee shall monitor a component or connection using the procedures in 40 CFR 63.772(c) to demonstrate that it operates with no detectable emissions following any time the component is repaired or replaced or the connection is unsealed.

c. In the event that a leak or defect is detected, the permittee shall make a first attempt at repair no later than 5 calendar days after the leak is detected. Repair shall be completed no later than 15 calendar days after the leak is detected. Delay of repair of a closed-vent system or cover for which leaks or defects have been detected is allowed if the repair is technically infeasible without a shutdown, as defined in 40 CFR 63.761, or if the permittee determines that emissions resulting from immediate repair would be greater than the fugitive emissions likely to result from delay of repair. Repair of such equipment shall be complete by the end of the next shutdown.

[40 CFR 63.773(c)]

(3) Except where the dehydrator vent stream is 1. introduced with or used as the primary fuel, or 2. controlled by a boiler or process heater with a design heat input capacity equal to or greater than 44 megawatts (exempt), the permittee shall install and operate a continuous parameter monitoring system designed and operated so that a determination can be made on whether the control device is achieving the applicable performance requirements of 40 CFR 63.771(d) or (e)(3). The continuous parameter monitoring system shall meet the following specifications and requirements:

a. Each continuous parameter monitoring system shall measure data values at least once every hour and record either each measured data value or each block average value for each 1-hour period or shorter periods, calculated from all measured data values during the period. If values are measured more frequently than once per minute, a single value for each minute may be used to calculate the hourly (or shorter period) block average instead of all measured values.

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b. The monitoring system must be installed, calibrated, operated, and maintained in accordance with the manufacturer's specifications or other written procedures that provide reasonable assurance that the monitoring equipment is operating properly.

c. The continuous monitoring device shall be equipped with a continuous recorder to measure the values of operating parameters appropriate for the control device and specified as follows:

i. A thermal vapor incinerator shall be equipped with a temperature monitoring device with a minimum accuracy of ±2%* of the temperature being monitored in °C or ±2.5 °C, whichever value is greater. The temperature sensor shall be installed at a location in the combustion chamber downstream of the combustion zone.

ii. A catalytic vapor incinerator shall be equipped with a temperature monitoring device capable of monitoring temperature at two locations and have a minimum accuracy of ±2%* of the temperature being monitored in °C, or ±2.5 °C, whichever value is greater. One temperature sensor shall be installed in the vent stream at the nearest feasible point to the catalyst bed inlet and a second temperature sensor shall be installed in the vent stream at the nearest feasible point to the catalyst bed outlet.

iii. A flare shall be equipped with a heat sensing monitoring device that indicates the continuous ignition of the pilot flame.

iv. A boiler or process heater with a design heat input capacity of less than 44 megawatts shall be equipped with a temperature monitoring device with a minimum accuracy of ±2%* of the temperature being monitored in °C, or ±2.5 °C, whichever value is greater. The temperature sensor shall be installed at a location in the combustion chamber downstream of the combustion zone.

v. A condenser shall be equipped with a temperature monitoring device with a minimum accuracy of ±2%* of the temperature being monitored in °C, or ±2.5 °C, whichever value is greater. The temperature sensor shall be installed at a location in the exhaust vent stream from the condenser. A condenser performance curve shall be used to establish the relationship between the condenser outlet temperature and condenser control efficiency.

vi. A regenerative-type carbon adsorption system shall be equipped with:

(a) A continuous parameter monitoring system to measure and record the average total regeneration stream mass flow or volumetric flow during each carbon bed regeneration cycle. The integrating regenerating stream flow monitoring device must have an accuracy of ±10%*; and

(b) A continuous parameter monitoring system to measure and record the average carbon bed temperature for the duration of the carbon bed steaming cycle and to measure the actual carbon bed

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temperature after regeneration within 15 minutes of completing the cooling cycle. The temperature monitoring device shall have a minimum accuracy of ±2%* of the temperature being monitored in °C, or ±2.5 °C, whichever value is greater.

vii. For a nonregenerative-type carbon adsorption system, the design carbon replacement interval shall be established using a performance test conducted in accordance with 40 CFR 63.772(e)(3) or a design analysis in accordance with 40 CFR 63.772(e)(4)(i)(F) and the carbon replacement schedule shall be based on the total carbon working capacity of the control device and source operating schedule.

viii. Where using a continuous organic compound monitoring system to measure the concentration level of organic compounds in the exhaust vent stream from the control device, it must be installed, certified, operated, and maintained in accordance with the requirements of Performance Specification 8 or 9 of Appendix B of 40 CFR part 60 and the manufacturer's specifications.

d. The permittee shall calculate the daily average value recorded for each monitored operating parameter for each operating day. If the dehydration unit operations are continuous, the operating day is a 24-hour period. If the dehydration unit operations are not continuous, the operating day is the total number of hours of operation per 24-hour period. Valid data points must be available for 75% of the operating hours in an operating day to compute the daily average.

e. The minimum operating parameter value or a maximum operating parameter value shall be established based on values measured during the performance test and supplemented, as necessary, by control device design analysis or manufacturer recommendations, to define the conditions at which the control device must be operated to continuously achieve the applicable performance requirements of 40 CFR 63.771(d)(1) or 63.771(e)(3)(ii).

* in the 8/23/11 proposed amendments to Subpart HH, the minimum accuracy of ±2% has been changed to ±1%; and for the regenerative carbon adsorption system, the regenerating stream flow monitoring device must have a measurement sensitivity of 5% of the flow rate or 10 ft3/minute, whichever is greater.

[40 CFR 63.773(d)(1) through (5)]

(4) The following records shall be maintained for the glycol dehydration unit(s), the control device(s), and closed-vent system(s):

a. the general recordkeeping requirements specified in 40 CFR 63.10(b)(2);

b. the records specified in 40 CFR 63.10(c) for each monitoring system operated in accordance with the requirements of 40 CFR 63.773(d);

c. continuous records of the control device operating parameters monitored to demonstrate compliance;

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d. records of the daily average value of each continuously monitored parameter for each operating day determined according to the procedures specified in 40 CFR 63.773(d); and in addition, for condensers installed to comply with 40 CFR 63.765, records of the annual 365-day rolling average condenser efficiency determined under 40 CFR 63.772(g);

e. hourly records of the flow indicator, as well as records of the times and durations of all periods when the vent stream is diverted from the control device or the flow monitor is not operating;

f. where a car-seal or lock-and-key type bypass closure mechanism is used to comply with the requirements of a closed-vent system, records from the monthly visual inspection of the seals or closure mechanism, and the duration of all periods when the car-seal or lock mechanism has been broken or the bypass line valve position has changed;

g. records identifying all parts of the closed-vent system that are designated as unsafe or difficult to inspect in accordance with 40 CFR 63.773(c)(5) or (6), with an explanation of why the equipment is unsafe or difficult to inspect, and the plan for inspecting the equipment;

h. records of the initial and annual leak detection inspection of the closed vent system, from the glycol dehydration unit’s process and reboiler vents to the control device; and for each inspection conducted in accordance with 40 CFR 63.773(c) during which a leak or defect is detected, a record of the following information:

i. the instrument identification numbers, operator name or initials, and identification of the equipment;

ii. the date the leak or defect was detected and the date of the first attempt to repair the leak or defect;

iii. the maximum instrument reading measured by the method specified in 40 CFR 63.772(c) after the leak or defect is successfully repaired or determined to be non-repairable;

iv. identification of any “repair delayed” and the reason for the delay, if a leak or defect is not repaired within 15 calendar days after its discovery;

v. the name, initials, or other form of identification of the operator (or designee) whose decision it was that repair could not be completed without a shutdown;

vi. the expected date of successful repair of the leak or defect if a leak or defect is not repaired within 15 calendar days;

vii. the dates of shutdowns that occur while the equipment is unrepaired; and

viii. the date of successful repair of each leak or defect;

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i. for each inspection conducted in accordance with 40 CFR 63.773(c) during which no leaks or defects are detected, a record that the inspection was performed, the date of the inspection, and a statement that no leaks or defects were detected;

j. records of glycol dehydration unit baseline operations calculated as required under 40 CFR 63.771(e)(1);

k. where approved and demonstrating compliance with the 95% control requirement through process modifications, the records documenting that the facility continues to operate under the conditions specified in 40 CFR 63.771(e)(2);

l. where electing to comply with the benzene emission limit specified in 40 CFR 63.765(b)(1)(ii), the method used for demonstrating compliance with 0.90 megagrams per year of benzene and the basis for using the compliance method;

m. where meeting the exemption criteria in 40 CFR 63.764(e)(1)(i) or (ii) the records of the actual annual average natural gas throughput to the glycol dehydration unit per day, as determined in accordance with 40 CFR 63.772(b)(1), or the actual average benzene emissions per year, as determined in accordance with 40 CFR 63.772(b)(2);

n. where meeting the exemption criteria for ancillary equipment and compressors under 40 CFR 63.764(e)(2), the information and data used to demonstrate that a piece of ancillary equipment or a compressor is not in VHAP service or not in wet gas service; and/or identification and location of ancillary equipment or compressors that is/are in VHAP service less than 300 hours per year;

o. the following records when using a flare to comply with 40 CFR 63.771(d):

i. the flare design (i.e., steam-assisted, air-assisted, or non-assisted);

ii. all visible emission readings, heat content determinations, flowrate measurements, and exit velocity determinations made during the compliance determination required by 40 CFR 63.772(e)(2); and

iii. all hourly records and other recorded periods when the pilot flame is absent.

The permittee shall maintain files of all required information (including all reports and notifications) for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, and report. The most recent 12 months of all applicable records shall be accessible from a central location by computer or other means that provides access within 2 hours following any request for them.

[40 CFR 63.774]

(5) Monitoring data recorded during periods identified below shall not be included in any average or percent leak rate computed under Part 63 Subpart HH; however, records shall be kept of the times and durations of all such periods and any periods during process or control device operations when any required monitors are not operating.

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a. monitoring system breakdowns, repairs, calibration checks, and zero (low-level) and high-level adjustments;

b. startups, shutdowns, or malfunctions events, where, records shall be maintained indicating whether or not the Startup, Shutdown, and Malfunction Plan, required under 40 CFR 63.762(d), was followed;

c. periods of non-operation resulting in cessation of the emissions; and

d. excursions due to invalid data as defined in 40 CFR 63.773(d)(6)(iv).

[40 CFR 63.774(b)(3)]

e) Reporting Requirements.

(1) The following information, where applicable, shall be included in the Notification of Compliance Status and/or in the semiannual periodic report. Reports shall be submitted to the Ohio EPA District Office or Local Air Agency or may be submitted through the Ohio EPA’s “e-Business Center: Air Services” online web portal:


a. 40 CFR 63.775(b) and

40 CFR 63.9(b)

For each dehydration unit, an Initial Notification must be submitted to include the information required by these paragraphs. An additional copy must be sent to U.S. EPA’s Office of Air Quality Planning & Standards, per 40 CFR 63.775(c)(1).

b. 40 CFR 63.775(b)(4) and (d);

40 CFR 63.772(e)(3);

Table 2 to Subpart HH; and

40 CFR 63.9(h)

For each dehydration unit, a Notification of Compliance Status Report must be submitted within 180 of startup operations, to include the information identified in 40 CFR 63.775(d).

c. 40 CFR 63.775(e)(1) and (2); and

40 CFR 63.10(e)(3)

A major source of HAP must submit semiannual reports to include the information identified in 40 CFR 63.775(e)(2).

d. OAC 3745-21-10(A)(3) and (4) and40 CFR 63.9(e), per Table 2 of Subpart HH

Must submit a Notice of Intent to Test to the district office or local air agency at least 60 calendar days before the performance test is scheduled. Test results must be submitted within 30 days after the performance test is completed.

e. 40 CFR 63.775(f) Notification of a process change, from information submitted in the Notification of Compliance Status Report, must be submitted within 180 days following the change.

f. Table 2 to Part 63, Subpart HH Table 2 identifies the applicable reporting requirements from the General Provisions of Part 63 (Subpart A, 40 CFR 63.9 and 40 CFR 63.10).

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(2) The permittee shall submit an annual Permit Evaluation Report (PER) to the Ohio EPA District Office or Local Air Agency by the due date identified in the Authorization section of this permit. The permit evaluation report shall cover a reporting period of no more than twelve months for each air contaminant source identified in this permit. It is recommended that the PER be submitted electronically through the Ohio EPA’s “e-Business Center: Air Services” although PERs can be submitted via U.S. postal service or can be hand delivered.

[OAC 3745-15-03(B)(2) and (D)]

(3) The permittee of the major source shall submit:

a. an initial notification that the facility is subject to the requirements of Part 63, Subpart HH, or any other applicable NESHAP, as required under 40 CFR 63.9(b)(2);

b. the date of any performance evaluation required to be conducted for a continuous monitoring system used to demonstrate compliance;

c. the planned date of a performance test at least 60 days before the test date and, if requested, a site-specific test plan;

d. the Notification of Compliance Status report as described in 40 CFR 63.775(d);

e. Periodic Reports as described in 40 CFR 63.775(e); and

f. the reports specified in 40 CFR 63.10(d)(5) for startup, shutdown, and malfunction.

In addition to submitting an initial notification to the appropriate district or local office of the Ohio EPA Division of Air Pollution Control, a copy of the initial notification must be submitted to EPA's Office of Air Quality Planning and Standards. Notification can be sent via e-mail to [email protected] or via mail delivery service to U.S. EPA, Sector Policies and Programs Division/Coatings and Chemicals Group (E143–01), Attn: Oil and Gas Project Leader, Research Triangle Park, NC 27711.\

Personnel from the Ohio EPA Central Office and the appropriate Ohio EPA District Office or local air agency shall be notified 30 days prior to initiation of the applicable tests and shall be permitted to examine equipment and witness the certification tests. Two copies of the test results shall be submitted to Ohio EPA, one copy to the appropriate Ohio EPA District Office or local air agency and one copy to Ohio EPA Central Office, and pursuant to OAC rule 3745-15-04, within 30 days after the test is completed.

[40 CFR 63.775(b)]; [40 CFR 63.9(b)(2)]; [40 CFR 63.8(e)(2)]; [40 CFR 63.7(b)]; [40 CFR 63.10(d)(5)]; and [OAC rule 3745-15-04]

(4) Following the initial performance test and each required sequential determination and/or demonstration of compliance, the permittee shall submit to the Director (appropriate Ohio EPA Division of Air Pollution Control, District Office or local air agency) notification of compliance with the applicable NESHAP, signed by the owner or operator or other responsible official who is certifying the accuracy and completeness of the report. The compliance notification shall be postmarked no later than 30 days following the

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completion of the compliance demonstration. The compliance report shall include the following information:

a. the NESHAP (applicable subpart) and emissions and/or other limitation(s) applicable to the glycol dehydration unit(s);

b. the method that was used to determine compliance with the applicable limitation and/or requirement and the date each compliance demonstration was conducted;

c. the results of any required performance tests, opacity or visible emission observations, continuous monitoring system (CMS) performance evaluations, and/or other monitoring procedures or methods that were conducted to demonstrate compliance;

d. the methods that will be used for determining continuing compliance, including a description of the monitoring, the records maintained of the process and/or equipment parameters, and test methods;

e. the mass emission rate of TOC (minus methane and ethane) or total HAP emitted by the dehydrator, as measured in accordance with the test methods specified in 40 CFR 63.772;

f. the analysis demonstrating whether the glycol dehydration unit(s) is/are a major source for HAP and the supporting potential and controlled emissions data to document the determination;

g. a description of the air pollution control equipment (or control method) for each emission point and the control efficiency (%) for each control device/method;

h. a statement, signed by a responsible official, as to whether the dehydrator has met the relevant standards, limitations, and/or other requirements of the NESHAP; and if not, the proposed method and time-line for achieving compliance;

i. if a closed-vent system and a control device other than a flare are used to demonstrate compliance, the permittee shall submit the following information:

i. the results of the closed-vent system initial inspections performed according to the requirements in 40 CFR 63.773(c)(2)(i) and (ii); and

ii. documentation of the design analysis as specified in 40 CFR 63.772(e)(4), if approved and electing to demonstrate compliance, as permitted, using the design analysis and gas analyses; or

iii. the performance test results, including the percent reduction of total HAP or TOC (minus methane and ethane) or the outlet concentration of HAP or TOC; and the value of the monitored parameters, averaged over the full period of the performance test;

j. if a closed-vent system and a flare are used to demonstrate compliance, the permittee shall submit performance test results to include the following information:

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i. all visible emission readings, heat content determinations, flowrate measurements, and exit velocity determinations; and

ii. a statement of whether a flame was present at the pilot light over the full period of the compliance determination;

k. the results of the initial inspection of the closed-vent system, performed in accordance with 40 CFR 63.773(c)(2)(i) and (ii);

l. one complete test report for each test method used to document compliance, to include: a description of the sampling site, the sampling and analysis procedures, any modifications to standard procedures, the quality assurance procedures, the record of operating conditions during the test, any record of preparation of standards, record of calibrations, the raw data sheets for field sampling and laboratory analyses, documentation of calculations, and any other information required by the test method;

m. for each operating parameter required to be monitored in accordance with the requirements of 40 CFR 63.773(d):

i. the minimum or maximum operating parameter value for the control device, established to define the conditions at which the control device must be operated to continuously achieve the applicable performance requirements of §63.771(d)(1) or (e)(3)(ii);

ii. an explanation of the rationale for why the operating parameter values were selected and any data and calculations used to develop the minimum or maximum value; and

iii. a definition of the source's operating day for purposes of determining daily average values of monitored parameters (hours of operation per day);

n. the results of any continuous monitoring system performance evaluations;

o. the method used to determine the maximum natural gas or hydrocarbon liquid throughput;

p. the method(s) used to demonstrate compliance with the chosen compliance option, i.e., for 0.90 MG/year benzene, 95% control of TOC or total HAP, 20 ppmv TOC or total HAP, or meeting the requirements of 40 CFR 63.11(b) for a flare; and

q. a statement as to whether the source has complied with the requirements of 40 CFR Part 63, Subpart HH.

[40 CFR 63.775(d)] and [OAC rule 3745-15-04, 30-day submission]

(5) Semiannual Reports shall be submitted for a major source, beginning 60 calendar days after the end of the applicable reporting period. The first report shall be submitted no later than 240 days after the date the Notification of Compliance Status Report is due and shall cover the 6-month period beginning on the date the Notification of Compliance Status Report is due. The following information shall be included in the semiannual report:

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a. the information required under 40 CFR 63.10(e)(3) for continuous monitoring systems;

b. a description of all excursions that occurred during the 6-month reporting period, as identified 40 CFR 63.773(d)(6);

c. for each excursion from the established daily average value of the operating parameter used to demonstrate continuous compliance, the report must include the daily average values of the monitored parameter, the applicable operating parameter limit, and the date and duration of the excursion;

d. for each excursion caused when the 365-day average condenser control efficiency is less than 95%, as specified in 40 CFR 63.773(d)(6)(ii), the report must include the 365-day average values of the condenser control efficiency, and the date and duration of the excursion;

e. for each excursion caused when condenser control efficiency is less than 90%, as calculated according to the procedures specified in 40 CFR 63.772(g)(2)(iii), the report must include the average values of the condenser control efficiency, and the date and duration of the excursion;

f. for each excursion caused by the lack of monitoring data, i.e., less than 75% of the operating hours in any day (per 40 CFR 63.773(d)(6)(iv)), the report must include the date and duration of time when the monitoring data were not collected and the reason;

g. for each inspection conducted in accordance with 40 CFR 63.773(c) during which a leak or defect is detected, the records specified in 40 CFR 63.774(b)(7) identifying each leak and information related to the date of its detection and repair;

h. for each closed-vent system with a bypass line, records of all periods when the vent stream is diverted from the control device through a bypass line and/or all periods in which the seal mechanism is broken, the bypass valve position has changed, or the key to unlock the bypass line valve was checked out.

i. the information necessary to document the glycol dehydration unit was in compliance during the reporting period;

j. identification of any changes made to the dehydration unit, the closed-vent system, or control device that would alter the method of compliance;

k. if there were no excursions during the reporting period, a statement to that effect;

l. if applicable, a statement that there no continuous monitoring system, used to demonstrate compliance, was inoperative, out of control, repaired, or adjusted during the reporting period;

m. if the compliance demonstration was approved to include a process modification to attain the 95% reduction of emissions, the information supporting compliance;

n. for flares, any periods of time when the pilot flame was absent and any record of visible emissions.

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[40 CFR 63.775(e)]

f) Testing Requirements

Compliance with the Emission Limitations and/or Control Requirements specified in section b) of these terms and conditions shall be determined in accordance with the following methods:

(1) Emissions Limitations :

Emissions from the glycol dehydration unit shall not exceed XX tons of VOC per year.

Unless the process vent from the dehydrator is connected through a closed vent system to a process natural gas line or open flare, TOC (minus methane and ethane) or total HAP shall be reduced by 95% or to less than 20 ppmv on a dry basis corrected to 3% oxygen in accordance with 40 CFR 63.772(e); or emissions of benzene from the dehydration unit shall be reduced to a level less than 0.90 MG/yr in accordance with 40 CFR 63.765(b)(1)(ii).

Applicable Compliance Method:

Emissions from the dehydration unit shall be vented through a closed vent system meeting the requirements of 40 CFR 63.771(c) and to a control device meeting the requirements of 40 CFR 63.765 and 40 CFR 63.771(d); and the control device shall meet the following requirements:

a. An open flare used to demonstrate compliance with 40 CFR 63.764(d)(1) shall be designed and operated in accordance with 40 CFR 63.772(e)(2) and 40 CFR 63.11(b); and it must be equipped with a heat sensing monitoring device and recorder that indicates the continuous ignition of the pilot flame (40 CFR 63.773(d));

b. A demonstration of compliance using a combustion device*** or enclosed flare shall be conducted in accordance with 40 CFR 63.772(e)(3)* and it must be equipped with a continuous temperature monitoring device which shall be used to establish a minimum operating temperature** in accordance with 40 CFR 63.772(f) and 40 CFR 63.773(d);

c. A demonstration of compliance using a condenser may be conducted through a performance test in accordance with 40 CFR 63.772(e)(3)*; or a design analysis may be used in accordance with 40 CFR 63.772(e)(4); or a condenser performance curve may be generated using the GRI-GLYCalcTM model in accordance with 40 CFR 63.772(e)(5) and (g). The condenser must be equipped with a continuous parameter monitoring device and must establish a minimum or maximum operating parameter** in accordance with 40 CFR 63.773(d); and

d. A demonstration of compliance using a carbon adsorption system shall be conducted in accordance with 40 CFR 63.772(e)(3)* and it must be equipped with a continuous parameter monitoring device which shall be used to establish a minimum or maximum operating parameter** in accordance with 40 CFR

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63.773(d); or alternatively the carbon replacement for non-regenerative carbon may be monitored in accordance with 40 CFR 63.773(d).

e. The permittee may determine the mass rate of TOC (minus methane and ethane) or total HAP at the inlet of the control device and actual average benzene emissions using the GRI-GLYCalcTM model, Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCalcTM Technical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit(s) and shall be determined using the procedures documented in the Gas Research Institute (GRI) report entitled ‘‘Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions’’ (GRI–95/0368.1); or alternatively the permitee may demonstrate compliance with the emissions standards through direct measurement using, as applicable, Methods 18 or 25A of 40 CFR Part 60, Appendix A or ASTM D6420-99 (Standard Test Method for Determination of Gaseous Organic Compounds by Direct Interface Gas Chromatography-Mass Spectrometry).

f. Potential VOC, TOC, HAP and/or benzene emissions estimates shall be based on the maximum glycol circulation rate(s), in gallons per minute (gpm); the worst case pollutant concentrations from representative extended gas analyses of the inlet wet gas; and the maximum natural gas flow rate, as determined by 40 CFR 63.772(b)(1)(i); or for a new unit, potential emissions shall be estimated in accordance with 40 CFR 63.760(a) and increased by a factor of 1.2.

g. When required by Part 63 Subpart HH, the gas stream from the glycol dehydration unit process vent shall be routed through a closed-vent system to control device that meets the requirements of 40 CFR 63.771(d), except that the performance levels specified in 40 CFR 63.771(d)(1)(i) and (ii) do not apply if the actual average benzene emissions can be demonstrated to be less than 0.90 megagrams per year.

h. The actual flowrate of natural gas to the glycol dehydration unit shall be made by installing a monitoring instrument that directly measures natural gas flowrate to the glycol dehydration unit with an accuracy of plus or minus 2% or better. The annual natural gas flowrate shall be converted to a daily average by dividing the annual flowrate by the number of days per year the glycol dehydration unit processes natural gas.

* In accordance with 40 CFR 63.772(e)(3)(iii)(B)(4), the GRI-GLYCalcTM model, Version 3.0 or higher, can be used as an alternative to calculating the mass rate of TOC (minus methane and ethane) or total HAP at the inlet of the control device.

** Where the owner/operator is using a control device design analysis in accordance with 40 CFR 63.772(e)(4) and using the GRI-GLYCalc model to demonstrate compliance with the TOC or total HAP standards, the minimum or maximum operating parameter shall be established based on the control device design analysis and it may be supplemented by the manufacturer’s recommendations (40 CFR 63.773(d)(5)(i)(B)).

*** Following promulgation of the proposed amendment to Subpart HH, in accordance with new paragraphs at 40 CFR 63.772(h) and (i), it may be possible for the manufacturer to conduct and certify the performance test for a combustion control device.

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[40 CFR 63.765(b)(1) or (c)(1)], [40 CFR 63.771(c) and (d)], [40 CFR 63.772], [40 CFR 63.773(d)]; and [OAC rule 3745-31-05(E)]

(2) Closed-Vent Systems

Emissions Limitation:

As required by Part 63 Subpart HH, the gas stream from the dehydration unit process vents, shall be routed through a closed-vent system to a control device meeting the requirements of 40 CFR 63.771(c) and (d). The closed-vent system shall be designed and operated with no detectable emissions. The closed-vent system shall be considered to have no detectable emissions if the instrument reading is less than 500 parts per million by volume (ppmv) above background (per 40 CFR 63.772(c)(8)).


The detection of leaks shall be determined at the frequency required by any applicable rule for the ancillary equipment and compressors, and conducted in accordance with the test procedure set forth in U.S. EPA Method 21 and as identified in 40 CFR 63.772(c). This frequency may change with the promulgation of applicable New Source Performance Standards or through amendments to the NESHAP. Where a closed-vent system is required (from the dehydration unit to its control device) a potential leak interface is determined to operate with “no detectable organic emissions” if the organic concentration is less than 500 ppmv.

40 CFR 63.760(g)], [40 CFR 63.769], and [40 CFR 63.772(c)]

(3) Control Device other than a Flare


Where not demonstrating compliance using the model GRI-GLYCalcTM model, as allowed per 40 CFR 63.772(b)(2) for benzene, any control device used to demonstrate compliance with 40 CFR 63.771(d), other than an open flare (and the control devices/scenarios identified as exempt from the performance test requirements in 40 CFR 63.772(e)(1)), the permittee shall demonstrate that the control device either reduces the mass content of TOC (minus methane and ethane) or total HAP by 95% or reduces benzene to less than 0.90 MG per year.


The permittee demonstrating compliance through performance testing to meet the control requirements of 40 CFR 63.771(d) or (e) shall do so using the following methods and procedures:

a. Method 1 or 1A, 40 CFR Part 60, Appendix A, as appropriate, shall be used for selection of the sampling sites. Any references to particulate mentioned in Methods 1 and 1A do not apply.

i. To determine compliance with the control device percent reduction requirement, sampling sites shall be located at the inlet of the first control device, and at the outlet of the final control device.

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ii. To determine compliance with the enclosed combustion device total HAP concentration limit, the sampling site shall be located at the outlet of the combustion device.

b. Method 2, 2A, 2C, or 2D, 40 CFR Part 60, Appendix A shall be used to determine the gas volumetric flowrate.

c. For benzene, the GRI-GLYCalcTM model may be used in accordance with 40 CFR 63.772(b)(2)(i) or may be determined, in kilograms/hour, through direct measurement using Method 18, 40 CFR Part 60, Appendix A or ASTM D6420–99 (2004).

d. Method 18, 40 CFR Part 60, Appendix A or ASTM D6420–99 (2004) shall be used to determine compliance with the control device percent reduction performance requirement. As an alternative, the mass rate of either TOC (minus methane and ethane) or total HAP at the inlet of the control device (E i) may be calculated using the model GRI-GLYCalc. The following procedures shall be used to calculate percent reduction efficiency:

i. The minimum sampling time for each run shall be 1 hour in which either an integrated sample or a minimum of four grab samples shall be taken. If grab sampling is used, the samples shall be taken at approximately equal intervals in time, i.e., every 15-minute intervals during the run.

ii. The mass rate of either TOC (minus methane and ethane) or total HAP (Ei, Eo) shall be computed using the following equations:

nEi = K2 ( Cij Mij) Qi

j=1

nEo= K2 ( Coj Moj) Qo

j=1

Where:

Cij, Coj= Concentration of sample component j of the gas stream at the inlet and outlet of the control device, respectively, dry basis, parts per million by volume.

Ei, Eo= Mass rate of TOC (minus methane and ethane) or total HAP at the inlet and outlet of the control device, respectively, dry basis, kilogram per hour.

Mij, Moj= Molecular weight of sample component j of the gas stream at the inlet and outlet of the control device, respectively, gram/gram-mole.

Qi, Qo= Flowrate of gas stream at the inlet and outlet of the control device, respectively, dry standard cubic meter per minute.

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K2= Constant, 2.494×10−6 (parts per million) (gram-mole per standard cubic meter) (kilogram/gram) (minute/hour), where standard temperature (gram-mole per standard cubic meter) is 20 °C.

n = Number of components in sample.

When the TOC mass rate is calculated, all organic compounds (minus methane and ethane) measured by Method 18, 40 CFR part 60, appendix A, or Method 25A, 40 CFR part 60, appendix A, or ASTM D6420–99 (2004) as specified in §63.772(a)(1)(ii), shall be summed.

When the total HAP mass rate is calculated, only HAP chemicals listed in Table 1 of this subpart shall be summed.

iii. The percent reduction in TOC (minus methane and ethane) or total HAP shall be calculated as follows:

Rcd = (Ei – Eo)/Ei x 100%

Where:

Rcd= Control efficiency of control device, %.

Ei= Mass rate of TOC (minus methane and ethane) or total HAP at the inlet to the control device, kilograms TOC per hour or kilograms HAP per hour.

Eo= Mass rate of TOC (minus methane and ethane) or total HAP at the outlet of the control device, kilograms TOC per hour or kilograms HAP per hour.

iv. If the vent stream entering a boiler or process heater with a design capacity less than 44 megawatts is introduced with the combustion air or as a secondary fuel, the weight-percent reduction of total HAP or TOC (minus methane and ethane) across the device shall be determined by comparing the TOC (minus methane and ethane) or total HAP in all combusted vent streams and primary and secondary fuels with the TOC (minus methane and ethane) or total HAP exiting the device, respectively.

v. To determine compliance with the total HAP concentration limit, the permittee shall use the following procedures to calculate parts per million by volume concentration, corrected to 3% oxygen. The TOC concentration is the sum of the concentrations of the individual components and shall be computed for each run using the following equation:

x nCTOC = ( Cji) / x

i=1 j=1

Where:

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CTOC=entration of total organic compounds minus methane and ethane, dry basis, parts per million by volume.

Cji= Concentration of sample component j of sample i, dry basis, parts per million by volume.

n = Number of components in the sample.

x = Number of samples in the sample run.

The TOC concentration or total HAP concentration shall be corrected to 3% oxygen as follows:

(a) The emission rate correction factor for excess air, integrated sampling and analysis procedures of Method 3B, 40 CFR part 60, appendix A, shall be used to determine the oxygen concentration. The samples shall be taken during the same time that the samples are taken for determining TOC concentration or total HAP concentration.

(b) The TOC or HAP concentration shall be corrected for percent oxygen by using the following equation:

Cc = Cm (17.9 / 20.9 - %O2d)

Where:

Cc= TOC concentration or total HAP concentration corrected to 3% oxygen, dry basis, parts per million by volume.

Cm= TOC concentration or total HAP concentration, dry basis, parts per million by volume.

%O2d= Concentration of oxygen, dry basis, % by volume.

Operating parameters shall be established in accordance with 40 CFR 63.773(d), as applicable to the chosen control device, during the performance test to demonstrate continuous compliance.

[40 CFR 63.765], [40 CFR 63.771(d)], and [40 CFR 63.772(a)(1) and (e)(3)]

(4) Where approved to demonstrate compliance using the design analysis, it shall include an analysis of the vent stream characteristics and control device operating parameters for the applicable control device specified as follows:

a. For a thermal vapor incinerator, the design analysis shall include the vent stream composition, constituent concentrations, and flowrate and shall establish the design minimum and average temperatures in the combustion zone and the combustion zone residence time.

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b. For a catalytic vapor incinerator, the design analysis shall include the vent stream composition, constituent concentrations, and flowrate and shall establish the design minimum and average temperatures across the catalyst bed inlet and outlet, and the design service life of the catalyst.

c. For a boiler or process heater, the design analysis shall include the vent stream composition, constituent concentrations, and flowrate; shall establish the design minimum and average flame zone temperatures and combustion zone residence time; and shall describe the method and location where the vent stream is introduced into the flame zone.

d. For a condenser, the design analysis shall include the vent stream composition, constituent concentrations, flowrate, relative humidity, and temperature, and shall establish the design outlet organic compound concentration level, design average temperature of the condenser exhaust vent stream, and the design average temperatures of the coolant fluid at the condenser inlet and outlet. As an alternative to the design analysis, an owner or operator may elect to use the procedures specified in the GRI report entitled, “Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions” (GRI-95/0368.1) as inputs for the model Gri-GLYCalcTM, Version 3.0 or higher to determine condenser performance.

e. For a regenerable carbon adsorption system, the design analysis shall include the vent stream composition, constituent concentrations, flowrate, relative humidity, and temperature, and shall establish the design exhaust vent stream organic compound concentration level, adsorption cycle time, number and capacity of carbon beds, type and working capacity of activated carbon used for the carbon beds, design total regeneration stream flow over the period of each complete carbon bed regeneration cycle, design carbon bed temperature after regeneration, design carbon bed regeneration time, and design service life of the carbon.

f. For a nonregenerable carbon adsorption system, such as a carbon canister, the design analysis shall include the vent stream composition, constituent concentrations, flowrate, relative humidity, and temperature, and shall establish the design exhaust vent stream organic compound concentration level, capacity of the carbon bed, type and working capacity of activated carbon used for the carbon bed, and design carbon replacement interval based on the total carbon working capacity of the control device and source operating schedule. In addition, these systems will incorporate dual carbon canisters in case of emission breakthrough occurring in one canister.

If it is determined that the design analysis is not sufficient to demonstrate compliance, the permittee shall be required to conduce a performance test as described above.

[40 CFR 63.772(e)(4)]

(5) Compliance using an open flare


There shall be no visible emissions from a flare used to demonstrate compliance with Part 63, Subpart HH, except for periods not to exceed a total of 5 minutes during any 2

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consecutive hours of operation and the flare shall be designed and operated in accordance with 40 CFR 63.11(b).


Compliance with the visible emissions limitation shall be determined in accordance with U.S. EPA Method 22 in Appendix A of 40 CFR Part 60. The heat content, flowrate, and exit velocity shall be determined in accordance with 40 CFR 63.11(b).

[40 CFR 63.771(d)(iii)] and [40 CFR 63.772(e)(2)]

(6) Any amendment to Part 63, Subpart HH shall supersede the compliance limitations and/or options contained in this permit.

g) Miscellaneous Requirements

(1) The permittee shall meet the applicable requirements of Part 60 Subpart OOOO by the compliance date identified in 40 CFR 60.5370(a), following the final promulgation of the rule.

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1. Emissions Unit: Equipment/Pipeline Leaks, P002

Operations, Property and/or Equipment Description:

P002 Ancillary equipment1 and Associated equipment: compressors, pumps, piping, pneumatic controllers, gas-water/condensate/oil separators located at a natural gas processing plant.

Equipment/pipeline leaks from valves, flanges, pressure relief devices, open end valves or lines, and pump and compressor seals in VOC or wet gas service.

a) This permit document constitutes a permit-to-install issued in accordance with ORC 3704.03(F) and a permit-to-operate issued in accordance with ORC 3704.03(G).

(1) For the purpose of a permit-to-install document, the emissions unit terms and conditions in this permit are federally enforceable, with the exception of those listed below, which are enforceable under state law only.

a. None.

(2) For the purpose of a permit-to-operate document, the emissions unit terms and conditions in this permit are enforceable under state law only, with the exception of those listed below, which are federally enforceable.

a. None.

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(A)(3),as effective 11/30/01

Emissions of Volatile Organic Compounds (VOC) shall not exceed:

XX tons/year total from fugitive equipment leaks

See b)(2)a.b. OAC rule 3745-31-05(A)(3)(a)(ii),

as effective 12/01/06See b)(2)b.

c. ORC 3704.03(T) Requirements for detection and repair of leaks from process equipment and pipeline.

d. ORC 3704.03(T) There shall be no visible emissions from ancillary and/or associated equipment,

1

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compressors, pumps, and/or piping.e. Part 60, Subpart VVa:

Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry (SOCMI) for which construction, reconstruction, or modification commenced after 11/7/06.

The facility is subject to the provisions of Subpart VVa for equipment leaks of VOC.

f. 40 CFR 60.482-2a Equipment leak standards for pumps in light liquid service

g. 40 CFR 60.482-4a and40 CFR 60.5401(b)

Equipment leak standards for pressure relief devices in gas/vapor service

h. 40 CFR 60.5401(c) Sampling connection systems are exempt from the equipment leak standards found in 40 CFR 60.482-5a

i. 40 CFR 60.482-6a Equipment leak standards for open-ended valves or lines

j. 40 CFR 60.482-7a Equipment leak standards for valves in gas/vapor service and in light liquid service

k. 40 CFR 60.482-8a Equipment leak standards for pumps, valves, and connectors in heavy liquid service; and pressure relief devices in light liquid or heavy liquid service

l. 40 CFR 60.482-9a Standards for delay of repair of equipment leaks

m. 40 CFR 60.482-10a Standards for closed vent systems and control devices

n. 40 CFR 60.482-11a Equipment leak standards for connectors in gas/vapor service and light liquid service

o. 40 CFR 60.483-1a Alternative standards for valves, via percentage of valves leaking (≤ 2%)

p. 40 CFR 60.483-2a Alternative standards for valves, via skip period leak detection and repair

(2) Additional Terms and Conditions

a. The permittee has satisfied the Best Available Technology (BAT) requirements pursuant to OAC paragraph 3745-31-05(A)(3), as effective November 30, 2001, in this permit. On December 1, 2006, paragraph (A)(3) of OAC rule 3745-31-05 was revised to conform to ORC changes effective August 3, 2006 (S.B. 265 changes), such that BAT is no longer required by State regulation for NAAQS pollutant less than ten tons per year. However, that rule revision has not yet been approved by U.S. EPA as a revision to Ohio’s State Implementation Plan (SIP). Therefore, until the SIP revision occurs and the U.S. EPA approves the revision to OAC rule 3745-31-05, the requirement to satisfy BAT still exists as part of the federally–approved SIP for Ohio. Once U.S. EPA approves the December 1, 2006 version of 3745-31-05, then these emission limits/control measures no longer apply.

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b. These rule paragraphs apply once U.S. EPA approves the December 1, 2006 version of OAC rule 3745-31-05 as part of the State Implementation Plan, when the Best Available Technology (BAT) requirements under OAC rule 3745-31-05(A)(3) will not apply to the Sulfur Dioxide (SO2), Nitrogen Oxides (NOx), Particulate Emissions (PE) and Carbon Monoxide (CO) from this air contaminant source, since the uncontrolled potential to emit for SO2, NOx, PE and CO are less than ten tons per year.

c. Where any ancillary equipment and compressors contain or contact liquids or gas with a total VHAP concentration less than 10% by weight, as demonstrated by Method 18 of 40 CFR Part 60, Appendix A or ASTM D6420-99; or where the ancillary equipment and/or compressors are operated in VHAP service less than 300 hours per calendar year; and the equipment can also be demonstrated to not be in VOC, i.e., could never reasonably be expected to exceed 10.0% VOC by weight; and where the ancillary equipment and/or compressors do not operate in wet gas service, i.e., do not contain or come into contact with field gas before the extraction of natural gas liquids, such equipment is exempt from the leak detection requirements of 40 CFR 63.769 and Part 60 Subpart VVa.

[40 CFR 63.764(e)(2)], [40 CFR 63.772(a)], and [40 CFR 60.5400(f)]

c) Operational Restrictions

(1) When a leak is detected a weatherproof identification tag with the equipment identification number and the date detected shall be attached to the leaking equipment, valve, or seal. A record of the date the leak was first detected, the date of any attempted repair, and the date of final repair shall be entered into a log maintained for this purpose. Repair of a leak shall be attempted as soon as possible after it is detected.

[40 CFR 60.486a(b) and (c)] and [40 CFR 60.5421(b)(1) for pressure relief device]

(2) Following the compliance date of Part 60 Subpart OOOO, the permittee shall replace the reciprocating compressor rod packing every 26,000 hours of operation or, where not tracking the hours of operation, within 36 months following the compliance date or the date of startup (whichever is later), and subsequently every 36 months or 26,000 hours of operation from the date of the last rod packing replacement.

[40 CFR 60.5385(a)] and [40 CFR 60.5410(c)(3)]

(3) Except during pressure releases, each pressure relief device shall be operated with “no detectable emissions”, as indicated by an instrument reading of less than 500 ppm above background, as measured by Method 21 in 40 CFR 60 Appendix A and in accordance with 40 CFR 60.485a(c). A pressure relief device shall be returned to a condition of “no detectable emissions” as soon as practicable following a pressure release, but no later than 5 days after each pressure release. Any pressure relief device that is equipped with a closed-vent system capable of capturing and transporting leakage through the pressure relief device to the pipeline, process heater, or flare is excluded from these requirements.

[40 CFR 60.482-4a] and [40 CFR 60.5421(b)(1)]

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(4) A first attempt at repair of a leak shall be made no later than 5 days after each leak is detected. The leak shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected unless meeting the requirements of 40 CFR 60.482-9a, for delay of repair.

[40 CFR 60.482-2a(c) for pumps], [40 CFR 60.482-4a(b) and 40 CFR 60.5401(b)(3) for pressure relief devices], [40 CFR 60.482-7a(d) for valves], [40 CFR 60.482-8a(c) for pumps/valves/connectors], [40 CFR 60.482-10a(g) for closed vent systems & control device], [40 CFR 60.482-11a(d) for connectors]

(5) Each open ended valve or line shall be equipped with a cap, blind flange, plug, or a second valve which shall seal the open end at all times, except during operations requiring process fluid flow. If equipped with a second valve, the valve on the process fluid end shall be closed before the second valve is closed. Where 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 seal the open end at all other times.

[40 CFR 60.482-6a]

d) Monitoring and/or Recordkeeping Requirements

(1) The following information shall be recorded in a log that is kept in a readily accessible location.

Applicable Rule Requirementsa. 40 CFR 60.486a Recordkeeping requirementsb. 40 CFR 60.486a(b)

and40 CFR 60.5421(b)(1)

Requirements to attach a weatherproof identification tag to leaking equipment

c. 40 CFR 60.486a(c) Requirements to maintain a log of each leak detected for 2 years and the information to be maintained

d. 40 CFR 60.486a(d) Required records for the design for the closed vent systems and control devices and period of time when they were not in operation as required

e. 40 CFR 60.486a(e) Required records for equipment identification and records for each leak test conducted (dates and results)

f. 40 CFR 60.486a(f) Required records for valves and pumps identified as unsafe or difficult to monitor

g. 40 CFR 60.486a(g) Records required for valves where complying with 40 CFR 60.483-2a for skip leak detection and repair

h. 40 CFR 60.486a(h) Records required for design criteria for the seal for pumps and compressors, i.e., the barrier fluid system and sensor

i. 40 CFR 60.480a(d); and40 CFR 60.486a(i) and (j)

Records required for exemptions from the leak detection requirements, the analysis/data demonstrating that a piece of equipment is “not in VOC service” and the analysis demonstrating the design capacity of the process unit.

j. 40 CFR 60.5421(b)(2) and40 CFR 60.5401(b)

Additional recordkeeping and monitoring requirements for pressure relief devices at an onshore natural gas processing plant

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(2) Where meeting the exemption in 40 CFR 63.764(e)(2) or 40 CFR 60.5400(f), where it can be demonstrated that the VHAP concentration content could never reasonably be expected to exceed 10.0% by weight or where the ancillary equipment and/or compressors operate in VHAP service less than 300 hours per calendar year; and where it can be demonstrated that the VOC content could never reasonably be expected to exceed 10.0% by weight and where the ancillary equipment and/or compressors do not operate in wet gas service, i.e., do not contain or come into contact with field gas before the extraction of natural gas liquids, the permittee shall develop and implement a leak detection and repair program designed to monitor and repair leaks from ancillary equipment and compressors covered by this permit. This leak detection and repair program shall include the following elements:

a. An initial and then annual inspection of the ancillary and associated equipment and compressors shall be conducted to determine if a leak exists. Leaks shall be determined through the use of an analyzer meeting U.S. EPA Method 21, 40 CFR Part 60, Appendix A.

b. The analyzer shall be operated and maintained following the instrument manufacturer’s operation and maintenance instructions.

c. A leak shall be determined if the instrument reading is equal to or greater than 10,000 ppm total VOC or the instrument reading required per any applicable rule.

d. Documentation that includes the following:

i. the date the inspection was conducted;

ii. the name of the employee conducting the leak check;

iii. the identification of any component that was determined to be leaking; and

iv. the date the component was repaired and determined to no longer be leaking.

The records associated with the leak detection and repair program shall be maintained for at least 5 years and shall be made available to the Director or his representative upon verbal or written request.

(3) Where not meeting one of the exemptions in 40 CFR 63.764(e)(2) or 40 CFR 60.5400(f), the permittee shall develop and implement a leak detection and repair program designed to meet the requirements of 40 CFR 63.769 and/or 40 CFR 60.5400 as identified below; and the information shall be recorded in a log that is kept in a readily accessible location.

[40 CFR 63.769(b)] and [40 CFR 60.5400]

(4) The ancillary equipment, compressors, pumps, pressure relief devices, sampling connection systems, open end valves or lines, valves, flanges, and any other connectors in VOC service, shall be monitored to demonstrate that there are “no detectable emissions” using Method 21, 40 CFR Part 60, Appendix A; and the records of these inspections shall be maintained for 2 years following the date of inspection and shall be made available upon request.

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[40 CFR 60.485a(b)] and [40 CFR 60.486a(c)]

(5) Each pressure relief device in gas/vapor service shall be monitored quarterly*, in accordance with 40 CFR 60.485a(b) and (c) unless it is:

a. routed to a process or fuel gas system, or is equipped with a closed-vent-system that captures and transports leakage through a pressure release device to a control device; or

b. located at a non-fractionating plant that has a design capacity less than 283,200 standard cubic meters per day (<10,000,000 scf/day) of field gas.

As soon as practicable, but no later than 5 calendar days after each pressure release (except as allowed per 40 CFR 60.482-9a), the pressure relief device shall be returned to a condition of “no detectable emissions”, as indicated by a reading of less than 500 ppm above background. The pressure relief device shall be monitored to confirm conditions of “no detectable emissions” no later than 5 days after the pressure release, as indicated by an instrument reading of less than 500 ppm above background. Otherwise, when a leak is detected, it shall be repaired as soon as practicable, but no later than 15 calendar days after it is detected, unless meeting the requirements of 40 CFR 60.482-9a. A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. Any pressure relief device located at a non-fractionating plant that is monitored only by non-plant personnel may be monitored the next time the personnel are on-site after a pressure release, instead of within 5 days of the release; except no pressure relief device can be operated for more than 30 days after a pressure release without being monitored.

Where there is a rupture disk upstream of the pressure relief device, a new rupture disk shall be installed no later than 5 calendar days after the pressure release, unless meeting the requirements of 40 CFR 60.482-9a.

*monitored quarterly per 40 CFR 60.633(b)(1) and 40 CFR 60.5401(b)(1)

[40 CFR 60.482-4a], [40 CFR 60.5401(b) and (d)], and [60 CFR 60.5421(b)(1)]

(6) Each pump in light liquid service shall be monitored monthly, in accordance with 40 CFR 60.485a(b) for leaks, except where it:

a. meets the requirements for a closed-vent-system in 40 CFR 60.482a-10, that captures and transports leakage from the seals to a process or fuel gas system or control device; or

b. is designated for “no detectable emissions” (as indicated by a reading of less than 500 ppmv above background, in accordance with 40 CFR 60.485a(c)); or

c. is equipped with a dual mechanical seal system that includes a barrier fluid system meeting the requirements of 40 CFR 60.482-2a(d), where it is visually inspected daily or weekly if equipped with a sensor with an audible alarm; or

d. is located at a non-fractionating plant that has a design capacity less than 283,200 standard cubic meters per day (<10,000,000 scf/day) of field gas.

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Each pump in light liquid service shall be visually inspected each calendar week for indications of liquids dripping from the pump seal, except as provided in 40 CFR 60.482-1a(f) for a batch process. A pump located at an unmanned plant site is exempt from the weekly visual inspections; however each pump must be visually inspected as often as practicable and at least monthly.

For a pump, an instrument reading of 2,000 ppm or greater is a “leak detected”. When a leak is detected or a visual inspection determines liquids dripping from the pump, it shall be repaired as soon as practicable, but not later than 15 days after it is detected unless meeting the requirements of 40 CFR 60.482-9a. A first attempt repair of a detected leak shall be made within 5 days of detection.

[40 CFR 60.482-2a(a) through (h)] and [40 CFR 60.5401(d)]

(7) Following the compliance date of Part 60 Subpart OOOO, the permittee shall either continuously monitor and record the number of hours of operation of the reciprocating compressor or track the number of months since the last rod packing replacement. Records shall be maintained of the date and time of the replacement of the compressor rod packing for each reciprocation compressor in operation at the facility. Records of deviations from the 26,000 hours or 36 months of operation between rod packing replacements shall also be maintained. These records shall be maintained for at least 5 years.

[40 CFR 60.5385(b)], [40 CFR 60.5410(c)], [40 CFR 60.5415(c)(1)], and [40 CFR 60.5420(c)(3)]

(8) Each valve in gas/vapor service and light liquid service shall be monitored monthly, in accordance with 40 CFR 60.485a(b) for leaks, with the following exceptions:

a. if the valve is designated for “no detectable emissions”, as indicated by a reading of less than 500 ppm above background in accordance with 40 CFR 60.485a(c), and has no external actuating mechanism in contact with the process fluids, it may be monitored initially upon designation and annually in accordance with 40 CFR 60.485a(c) thereafter; or

b. the valve is located at a non-fractionating plant that has a design capacity less than 283,200 standard cubic meters per day (<10,000,000 scf/day) of field gas.

Alternative standards for valve leak detection, based on 2.0% of valves leaking in accordance with 40 CFR 60.483-1a and 40 CFR 60.482-7a(a)(2)(ii); or alternative work practice standards in accordance with 40 CFR 60.483-1a and 40 CFR 60.482-7a(a)(2)(ii), may be approved by the Director.

Any valve for which a leak is not detected for 2 consecutive months may be monitored the first month of every quarter, beginning with the next quarter and until a leak is detected, where monitoring shall again be required monthly until another successive 2 months of no leakage has been documented. As an alternative to monitoring the first month of every quarter, the owner/operator may subdivide the process units into 2 or 3 subgroups of valves and monitor each subgroup in a different month of the quarter provided each group is monitored every 3 months and records are maintained of the subgroups; if a leak is detected, the valve must be monitored monthly until a leak is not detected for 2 successive months.

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An instrument reading of 500 ppm or greater is a “leak detected”. If a leak is detected it shall be repaired as soon as practicable, but not later than 15 days after it is detected, unless meeting the requirements of 40 CFR 60.482-9a. A first attempt repair of a detected leak shall be made within 5 days of detection and would include (but not be limited to) work practices identified in 40 CFR 60.482-7a(e).

[40 CFR 60.482-7a(a) through (f)] and [40 CFR 60.5401(d)]

(9) Each connector in gas/vapor service and in light liquid service shall be monitored for leaks within 12 months after initial startup, following any process change for the connectors involved, and in accordance with 40 CFR 60.482-11a. Except as required for closed-vent-systems, all such connectors shall be monitored according to the following schedule:

a. if the percent of leaking connectors in the process unit is greater than or equal to 0.5%, then subsequent monitoring to detect leaks must be conducted within 12 months; or

b. if the percent of leaking connectors in the process unit is greater than or equal to 0.25% but less than 0.5%, then subsequent monitoring to detect leaks must be conducted within 4 years, with the option to monitor at least 40% of the connectors within 2 years of the start of the monitoring period, provided all the connectors are monitored by the end of the 4-years; or

c. if the percent of leaking connectors in the process unit is less than 0.25%, the permittee shall monitor at least 50% of the connectors within 4 years of the start of the monitoring period and then establish the monitoring schedule as follows:

i. if the percent of leaking connectors is greater than or equal to 0.35% of the monitored connectors, all of the connectors not yet monitored shall be monitored as soon as practical, but no later than within the next 6 months; and

ii. if the percent of leaking connectors is less than 0.35% of the monitored connectors, all of the connectors not yet monitored shall be monitored within the next 8 years of the start of the monitoring period.

A new monitoring period shall be established pursuant to the above schedule, based on the percent of the leaking connectors within the total connectors monitored.

d. records must be maintained for the start date and end date of each monitoring period, and the monitoring results to support the scheduled used.

If an instrument reading greater than or equal to 500 ppm is measured, a leak is detected.

[40 CFR 60.482-11a]

(10) Closed-vent-systems and control devices shall be operated in compliance with the following provision:

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a. Vapor recovery systems (e.g., condensers and absorbers) shall be designed and operated to recover the VOC emissions vented to them with an efficiency of 95% or greater, or to an exit concentration of 20 ppmv, whichever is less stringent.

b. Enclosed combustion devices shall be designed and operated to reduce VOC emissions vented to them with an efficiency of 95% or greater, or to an exit concentration of 20 ppmv, on a dry basis, corrected to 3% oxygen, whichever is less stringent; or to provide a minimum residence time of 0.75 seconds at a minimum temperature of 816 °C.

c. Flares shall comply with the requirements of 40 CFR 60.18 and 40 CFR 60.485a(g).

d. Each control device shall be monitored to ensure they are operated and maintained in conformance with their design.

e. Each closed-vent-system shall be inspected initially and annually thereafter in accordance with 40 CFR 60.482-10a(f) and monitored in accordance with 40 CFR 60.485a(b). A vapor recovery system or closed-vent-system is exempt from this inspection requirement if operated under a vacuum.

f. Leaks, as indicated by an instrument reading of 500 ppmv above background or by visual inspection, shall be repaired as soon as practicable, but not later than 15 days after it is detected, unless meeting the requirements of delay of repair in accordance with 40 CFR 60.482-10a(h). A first attempt repair of a detected leak shall be made within 5 days of detection.

g. Closed-vent-systems and control devices shall be operated at all times when emissions may be vented to them.

[40 CFR 60.482-10a]

(11) If evidence of a potential leak is found by visual, audible, olfactory, or any other detection methods at pumps, valves, and/or connectors in heavy liquid service; and pressure relief devices in light liquid or heavy liquid service; and the evidence is not eliminated within 5 days of detection, the permittee shall follow these procedures:

a. Monitor the equipment within 5 days by the appropriate method specified in 40 CFR 60.485a. An instrument reading of 10,000 ppm or greater is a “leak detected”.

b. If a leak is detected it shall be repaired as soon as practicable, but not later than 15 days after it is detected unless meeting the requirements of 40 CFR 60.482-9a. A first attempt at repair shall be made within 5 days of detection and would include (but not be limited to) work practices identified in 40 CFR 60.482-2a(c)(2) and 40 CFR 60.482-7a(e).

[40 CFR 60.482-8a]

(12) The permittee may monitor at any time during the specified (per rule) monitoring period (i.e., monthly, quarterly, annually) which is a reasonable interval after completion of the previous monitoring event, as long as the time interval meets these requirements:

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a. when monitoring is conducted quarterly, monitoring events must be separated by at least 30 calendar days;

b. when monitoring is conducted annually, monitoring events must be separated by at least 120 calendar days;

c. when monitoring is conducted 3 quarters per year, monitoring events must be separated by at least 90 calendar days; and

d. when qualified and monitoring is conducted semiannually (every 2 quarters), monitoring events must be separated by at least 60 calendar days.

[40 CFR 60.482-1a(f)(3)]

(13) The permittee shall record and maintain all of the records required to document visual inspections and monitoring of all ancillary equipment, compressors, pumps, pressure relief devices, sampling connection systems, open end valves or lines, valves, flanges, and any other connectors in VOC service, as identified above, using a list of equipment identification numbers assigned to each potential point of leakage. The permittee shall also comply with the recordkeeping requirements and maintain the records identified in 40 CFR 60.486a, including the date each leak was detected and dates of attempted and final repairs.

[40 CFR 60.486a]

(14) Any determination that a piece of ancillary equipment is unsafe or difficult to monitor shall be documented to meet the appropriate requirements identified in Part 60, Subpart VVa, e.g., as identified in: 40 CFR 60.482-2a(g) for pumps; 40 CFR 60.482-6a(d) or (e) for open-ended valves or lines; 40 CFR 60.482-7a(g) and (h) for valves; 40 CFR 60.482-10a(j), (k), or (l) for closed-vent-systems; and 40 CFR 60.482-11a(e) for connectors. Records must be maintained for each determination, in accordance with 40 CFR 60.486a(f). Any delay of repair shall meet the requirements of 40 CFR 60.482-9a.

[40 CFR 60.482-2a through 11a]

(15) The permittee shall maintain a record of the following information for each monitoring event required to demonstrate compliance with the standards for pumps in light liquid service in 40 CFR 60.482–2a; compressors in 40 CFR 60.482–3a; valves in gas/vapor and light liquid service in 40 CFR 60.482–7a; pumps, valves, and connectors in heavy liquid service and pressure relief devices in light liquid and heavy liquid service in 40 CFR 60.482–8a; connectors in gas/vapor and light liquid service in 40 CFR 60.482–11a; and valves in 40 CFR 60.483–2a:

a. monitoring instrument identification;

b. operator identification;

c. equipment identification;

d. date of monitoring; and

e. instrument reading.

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[40 CFR 60.486a(a)(3)]

(16) When each leak is detected as specified in 40 CFR 60.482–2a for pumps in light liquid service; 40 CFR 60.482–3a for compressors; 40 CFR 60.482–7a for valves in gas/vapor and light liquid service; 40 CFR 60.482–8a for pumps, valves, and connectors in heavy liquid service and pressure relief devices in light liquid and heavy liquid service; 40 CFR 60.482–11a for connectors in gas/vapor and light liquid service; and 40 CFR 60.483–2a for valves, the following requirements apply:

a. the leaking equipment shall be marked with a clearly visible, weatherproof tag showing the equipment identification number;

b. the tag identification on a valve may be removed after it has been monitored for 2 successive months as specified in 40 CFR 60.482–7a(c) and no leak has been detected during those 2 months;

c. the tag identification on a connector may be removed after it has been monitored as specified in 40 CFR 60.482–11a(b)(3)(iv) and no leak has been detected during that monitoring; and

d. the tag identification on all other equipment, including a pressure relief device, may be removed after it has been repaired.

[40 CFR 60.486a(b)] and [40 CFR 60.5421(b)(1)]

(17) The following information shall be recorded in a log for each leak that is detected and these records shall be kept for 2 years in a readily accessible location:

a. the identification numbers of the monitoring instrument and leaking equipment;

b. the name of the operator conducting the monitoring;

c. the date each leak was detected and the date(s) of each attempt to repair them;

d. the repair methods applied in each attempt to repair each leak;

e. the maximum instrument reading measured by Method 21 of Appendix A–7 of Part 60 at the time the leak is successfully repaired or at the time it is determined to be non-repairable (except where a pump is repaired by eliminating dripping liquids);

f. identification of equipment exceeding the applicable leak detention limit 15 days after discovery of the leak and the maximum instrument reading measured by Method 21;

g. the reason for any delay of repair, where a leak is not repaired within 15 calendar days after being discovered;

h. if a decision has been made that repair of a leak cannot be completed without a process shutdown, the signature of the person authorized to make that determination;

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i. the expected date of successful repair of each leak that is not repaired within 15 days;

j. dates of process unit shutdowns that occur while the equipment is unrepaired; and

k. the date of successful repair of each leak.

[40 CFR 60.486a(c)] and [40 CFR 60.5421(b)(2)]

(18) The following information pertaining to the design requirements for closed vent systems and control devices shall be recorded and kept in a readily accessible location:

a. detailed schematics, design specifications, and piping and instrumentation diagrams;

b. the dates and descriptions of any changes in the design specifications;

c. a description of the parameter(s) monitored, as required in 40 CFR 60.482–10a(e), to ensure that control devices are operated and maintained in conformance with their design;

d. an explanation of why the parameter(s) was/were selected for the monitoring;

e. periods when the closed vent systems and control devices required in 40 CFR 60.482–2a, 40 CFR 60.482–3a, 40 CFR 60.482–4a, and 40 CFR 60.482–5a are not operated as designed, including periods when a flare pilot light does not have a flame; and

f. the dates of startups and shutdowns of the closed vent systems and control devices required per 40 CFR 60.482–2a, 40 CFR 60.482–3a, 40 CFR 60.482–4a, and 40 CFR 60.482–5a.

[40 CFR 60.486a(d)] and [40 CFR 60.482–10a]

(19) The following information pertaining to all equipment subject to the requirements in 40 CFR 60.482–1a to 40 CFR 60.482–11a shall be recorded in a log that is kept in a readily accessible location:

a. a list of identification numbers for equipment subject to the requirements of Part 60 Subpart VVa;

b. a list of identification numbers for equipment that are designated for “no detectable emissions” under the provisions of 40 CFR 60.482–2a(e) for pumps in light liquid service; 40 CFR 60.482–3a(i) for compressors; 40 CFR 60.482-4a(b) and 40 CFR 60.5421(b)(2) for pressure relief devices following a release; and 40 CFR 60.482–7a(f) for valves in gas/vapor and light liquid service; and the designation of equipment as subject to these requirements signed by the person authorized to make this determination;

c. a list of equipment identification numbers for pressure relief devices required to comply with 40 CFR 60.482–4a;

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d. for each compliance demonstration conducted as required in 40 CFR 60.482–2a(e), for pumps in light liquid service; 40 CFR 60.482–3a(i), for compressors; 40 CFR 60.482–4a, for pressure relief devices; and 40 CFR 60.482–7a(f), for valves in gas/vapor and light liquid service:

i. the dates of each compliance test;

ii. the background level measured during each compliance test; and

iii. the maximum instrument reading measured at the equipment during each compliance test;

e. a list of identification numbers for equipment in vacuum service;

f. a list of identification numbers for equipment that the permittee designates as operating in VOC service less than 300 hr/yr in accordance with 40 CFR 60.482–1a(e), a description of the conditions under which the equipment is in VOC service, and rationale supporting the designation that it is in VOC service less than 300 hr/yr;

g. the date and results of the weekly visual inspection for indications of liquids dripping from pumps in light liquid service;

h. records of the information for monitoring instrument calibrations conducted according to sections 8.1.2 and 10 of Method 21 of Appendix A–7 of Part 60 and 40 CFR 60.485a(b).

i. date of calibration and initials of operator performing the calibration;

ii. calibration gas cylinder identification, certification date, and certified concentration;

iii. instrument scale(s) used;

iv. a description of any corrective action taken if the meter readout could not be adjusted to correspond to the calibration gas value in accordance with section 10.1 of Method 21 of appendix A–7 of this part;

v. results of each calibration drift assessment required by 40 CFR 60.485a(b)(2) (i.e., the instrument reading for calibration at end of monitoring day and the calculated percent difference from the initial calibration value); and

vi. if the permittee makes their own calibration gas, a description of the procedure used;

i. the connector monitoring schedule for each process unit as specified in 40 CFR 60.482–11a(b)(3)(v); and

j. the records of each release from a pressure relief device subject to the requirements of 40 CFR 60.482–4a.

[40 CFR 60.486a(e)] and [40 CFR 60.5421(b)(2)]

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(20) The following information pertaining to all valves subject to the requirements of 40 CFR 60.482–7a(g) and (h), all pumps subject to the requirements of 40 CFR 60.482–2a(g), and all connectors subject to the requirements of 40 CFR 60.482–11a(e) shall be recorded in a log that is kept in a readily accessible location:

a. a list of identification numbers for valves, pumps, and connectors that are designated as unsafe-to-monitor, an explanation for each valve, pump, or connector stating why the valve, pump, or connector is unsafe-to-monitor, and the plan for monitoring each valve, pump, or connector; and

b. a list of identification numbers for valves that are designated as difficult-to-monitor, an explanation for each valve stating why the valve is difficult-to-monitor, and the schedule for monitoring each valve.

[40 CFR 60.486a(f)]

(21) The following information shall be recorded for valves complying with the alternative monitoring standards for valves, where after 2 consecutive quarterly leak detection periods the percent of valves leaking is less than or equal to 2.0%:

a. a schedule of the monitoring, which shall meet the requirements of 40 CFR 60.483–2a(b); and

b. the percent of valves found leaking during each monitoring period.

[40 CFR 60.486a(g)] for [40 CFR 60.483-2a]

(22) The following information shall be recorded in a log that is kept in a readily accessible location:

a. the design criterion for each sensor that is used to indicate failure of the seal system or barrier fluid system in a pump, as required in 40 CFR 60.482–2a(d)(5), and/or in a compressor, as required by 40 CFR 60.482–3a(e)(2); and explanation of the design criterion; and

b. any changes to this criterion and reasons for the changes.

[40 CFR 60.486a(h)] for [40 CFR 60.482–2a(d)(5) and 40 CFR 60.482–3a(e)(2)]

(23) The following information shall be recorded in a log that is kept in a readily accessible location for use in determining exemptions as provided in 40 CFR 60.480a(d):

a. an analysis demonstrating the design capacity of the affected facility;

b. a statement listing the feed or raw materials and products from the affected facilities; and an analysis demonstrating whether these chemicals are heavy liquids or beverage alcohol; and

c. an analysis demonstrating that equipment is not in VOC service.

[40 CFR 60.486a(i)] for [exemptions in 40 CFR 60.480a(d)]

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(24) Information and data used to demonstrate that a piece of equipment is not in VOC service shall be recorded in a log that is kept in a readily accessible location.

[40 CFR 60.486a(j)]

e) Reporting Requirements

(1) The permittee shall submit an annual Permit Evaluation Report (PER) to the Ohio EPA District Office or Local Air Agency by the due date identified in the Authorization section of this permit. The permit evaluation report shall cover a reporting period of no more than twelve-months for each air contaminant source identified in this permit. It is recommended that the PER is submitted electronically through the Ohio EPA’s “e-Business Center: Air Services” although PERs can be submitted via U.S. postal service or can be hand delivered.

(2) The owner/operator shall submit semiannual reports that include the information identified in 40 CFR 60.487a and the report shall include the number of leaks detected during the reporting period, the identification of the equipment where each leak was detected, and the dates of attempted and final repair. The report shall include the date of any leak that was detected and not repaired within 15 days of discovery, the reason for the delay of repair, the date of final repair, and any Method 21 test results conducted for the leak during the reporting period.

[40 CFR 60.487a]

(3) The initial semiannual report shall include the following information:

a. the process unit identification;

b. the number of valves subject to the requirements of 40 CFR 60.482–7a, excluding those valves designated for “no detectable emissions” under the provisions of 40 CFR 60.482–7a(f);

c. the number of pumps subject to the requirements of 40 CFR 60.482–2a, excluding those pumps designated for “no detectable emissions” under the provisions of 40 CFR 60.482–2a(e) and those pumps complying with 40 CFR 60.482–2a(f);

d. the number of compressors subject to the requirements of 40 CFR 60.482–3a, excluding those compressors designated for “no detectable emissions” under the provisions of 40 CFR 60.482–3a(i) and those compressors equipped with a closed vent system to capture and transport leakage to a process, fuel gas system, or control device complying with 40 CFR 60.482–3a(h);

e. the number of connectors subject to the requirements of 40 CFR 60.482–11a; and

f. the number of pressure relief devices subject to the requirements of 40 CFR 60.5401(b), except for those pressure relief devices designated for “no detectable emissions” under the provisions of 40 CFR 60.482– 4a(a) and those pressure relief devices equipped with a closed vent system to capture and transport leakage to a process, fuel gas system, or control device complying with 40 CFR 60.482– 4a(c).

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[40 CFR 60.487a(a) and (b)] and [40 CFR 60.5422(b)]

(4) All subsequent semiannual reports shall include the following information, summarized from the recordkeeping requirements of 40 CFR 60.486a and identified for each process unit subject to Part 60 Subpart VVa:

a. For each month during the semiannual reporting period the semiannual report must include the following information:

i. number of valves for which leaks were detected as described in 40 CFR 60.482–7a(b) or 40 CFR 60.483–2a;

ii. number of valves for which leaks were not repaired as required in 40 CFR 60.482–7a(d)(1);

iii. number of pumps for which leaks were detected as described in 40 CFR 60.482–2a(b), (d)(4)(ii)(A) or (B), or (d)(5)(iii);

iv. number of pumps for which leaks were not repaired as required in 40 CFR 60.482–2a(c)(1) and (d)(6);

v. number of compressors for which leaks were detected as described in 40 CFR 60.482–3a(f);

vi. number of compressors for which leaks were not repaired as required in 40 CFR 60.482–3a(g)(1);

vii. number of connectors for which leaks were detected as described in 40 CFR 60.482–11a(b);

viii. number of connectors for which leaks were not repaired as required in 40 CFR 60.482–11a(d);

ix. number of pressure relief devices for which leaks were detected as required in 40 CFR 60.5401(b)(2);

x. number of pressure relief devices for which leaks were not repaired as required in 40 CFR 60.5401(b)(3); and

xi. the facts that explain each delay of repair and, where appropriate, why a process unit shutdown was technically infeasible;

b. dates of process unit shutdowns which occurred within the semiannual reporting period; and

c. revisions to items reported in the initial or subsequent semiannual compliance reports if changes have occurred since the last compliance report.

[40 CFR 60.487a(a) and (c)] and [40 CFR 60.5422(c)]

(5) If the permittee elects to comply with the provisions of 40 CFR 60.483–1a or 40 CFR 60.483–2a, the alternative standards for valves demonstrated to have less than or equal to 2.0% of the facility valves leaking, the permittee shall notify the appropriate district or

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local office of the Ohio EPA Division of Air Pollution Control of the intention to demonstrate compliance with the alternative standard at least 90 days before implementing either of these provisions.

[40 CFR 60.487a(d)]

(6) The permittee shall report the results of all performance tests in accordance with 40 CFR 60.8 of the General Provisions. The provisions of 40 CFR 60.8(d) do not apply to affected facilities subject to the provisions of Subpart VVa except that the permittee must notify the appropriate district or local office of the Ohio EPA Division of Air Pollution Control of the schedule for the initial performance tests at least 30 days before the initial compliance demonstration.

[40 CFR 60.487a(e)]

f) Testing Requirements

(1) The following testing requirements from Part 60 Subpart VVa apply to this emissions unit:

Applicable Rule* Requirementsa. 40 CFR 60.485a Test methods and proceduresb. 40 CFR 60.485a(b) Method 21 shall be used to determine the presence of a leak in

accordance with this paragraphc. 40 CFR 60.485a(c) Method 21 shall be used for determining compliance with “no

detectable emissions” in accordance with this paragraphd. 40 CFR 60.5400(f) Demonstration that a piece of equipment is “not in VOC service”

or is “in wet gas service”e. 40 CFR 60.485a(e)

and40 CFR 60.5401(f)

Demonstration that a piece of equipment is “in light liquid service”

f. 40 CFR 60.485a(f) Sample used to demonstrate “in VOC or liquid service” shall be representative of the process fluid or gas used in the determination.

g. 40 CFR 60.485a(g) Standards for a flare

(1) Compliance with the emission limitations shall be determined in accordance with the following methods and the compliance demonstration must be completed for all equipment within 180 days of startup in accordance with 40 CFR 60.482-1a(a):

a. Each piece of equipment shall be presumed to be “in VOC service” or “in wet gas service” unless the permittee demonstrates the equipment is “not in VOC service” or “not in wet gas service”. Any demonstration that a piece of equipment is “not in VOC service” shall meet the requirements of 40 CFR 60.5400(f), where the VOC content of the process fluid can reasonably be expected to never exceed 10.0% by weight. The VOC content (%) shall be determined using procedures that conform to methods described in ASTM E169-63, 77, or 93; E168-67, 77; or 92, or E260-73, 91, or 96. Samples shall be representative of the process fluid. For a piece of equipment to be considered “in wet gas

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service”, it must be determined that it contains or contacts the field gas before the extraction step in the process.

[40 CFR 60.5400(d) and (f)] and [40 CFR 60.485a(f)]

b. Any demonstration that a piece of equipment is in “light-liquid service” shall meet the requirements of 40 CFR 60.485a(e) or 40 CFR 60.5401(f), by showing the following conditions apply:

i. the vapor pressure of one or more of the organic compounds is greater than 0.3 kPa at 20°C (1.2 in. H2O at 68°F), where standard reference texts of ASTM D2879-83 is used to document the vapor pressures; and

ii. the total concentration of the pure organic compounds having a vapor pressure greater than 0.3 kPa at 20°C (1.2 in. H2O at 68°F) is equal to or greater than 20% by weight; and

iii. the fluid is a liquid at operating conditions; or

iv. the weight percent evaporated is greater than 10% at 150 C° (302 F°), as determined by ASTM Method D86-78, 82, 90, 95, or 96.

A piece of equipment is in “heavy liquid service” if the weight percent evaporated is 10% or less at 150 C° (302 F°), as determined by ASTM Method D86-78, 82, 90, 95, or 96.

Samples shall be representative of the process fluid for which the demonstration is being made.

[40 CFR 60.485a(e) and (f)] and [40 CFR 60.5401(f)]

c. Emission Limitation :

VOC from fugitive equipment leaks


The detection of leaks of VOC into the ambient air from equipment shall be determined as follows:

i. The detection of leaks shall be determined in accordance with the test procedure set forth in U.S. EPA Method 21 and the instrument shall be calibrated each day before use.

ii. The following calibration gases shall be used:

(a) zero air, which consists of less than 10 ppm of hydrocarbon in air; and

(b) a mixture of air and methane or n-hexane at a concentration no more than, 2,000 ppm greater than the leak definition concentration of the equipment monitored.

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iii. The leak detection instrument shall be calibrated before each use and shall meet the performance criteria of Method 21, from 40 CFR 60 Appendix A; and a calibration drift assessment shall be performed, at a minimum, at the end of each monitoring day in accordance with 40 CFR 60.485a(b)(2) or 40 CFR 60.5401(g).

[40 CFR 60.485a(b)] and [40 CFR 60.5401(g)]

d. Emission Limitation :

< 500 ppm VOC above background for demonstration of “no detectable emissions”


The detection of leaks of VOC into the ambient air from equipment and background level shall be determined as follows:

i. The detection of leaks shall be determined in accordance with the test procedure set forth in U.S. EPA Method 21 and the instrument shall be calibrated each day before use.

ii. The following calibration gases shall be used:

(a) zero air, which consists of less than 10 ppm of hydrocarbon in air; and

(b) a mixture of air and methane or n-hexane at a concentration no more than, 2,000 ppm greater than the leak definition concentration of the equipment monitored.

All potential leak interfaces shall be traversed as close to the interface as possible. The arithmetic difference between the maximum concentration indicated by the instrument and the background level is compared with 500 ppm for determining compliance. The leak detection instrument shall be calibrated before each use and shall meet the performance criteria of Method 21, from 40 CFR 60 Appendix A.

[40 CFR 60.485a(c)]

e. 1Emissions Standard:

Where complying with the alternative standards for valves in 40 CFR 60.483-1 or 40 CFR 60.483-1, determination of 2% of valves leaking shall be calculated in accordance with 40 CFR 60.485a(h).


The percent of valves leaking shall be determined using the following equation:

%VL = (VL/VT) x 100

Where:

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%VL = percent leaking valves

VL = number of valves found leaking

VT =sum of total number of valves monitored

[40 CFR 60.485a(h)]

f. 1Emissions Standard:

To determine the monitoring frequency for connectors in gas/vapor or light-liquid service the calculation from 40 CFR 60.482-11a(c) shall be used.


The monitoring frequency for connectors in gas/vapor or light-liquid service shall be determined using the following equation:

%CL = (CL/CT) x 100

Where:

%CL = percent of leaking connectors as determined through periodic monitoring

CL = number of connectors measured at 500 ppm or greater, by the method specified in 40 CFR 60.485(b)

CT = the total number of monitored connectors in the process unit or affected facility

[40 CFR 60.482-11a(c)]1

g. 1Emissions Limitation:

Emissions of VOC shall not exceed XX tons/year total from fugitive equipment leaks


The annual VOC limit is the estimated potential-to-emit, based upon the emissions unit’s maximum capacity and the design efficiency of the capture and control .systems.

h. Emission Limitation

There shall be no visible emissions from equipment, i.e., from valves, flanges, pressure relief devices, open end valves or lines, connectors, and pump and compressor seals in VOC or wet gas service

Applicable Compliance Method

Compliance with the visible emissions limitation shall be determined in accordance with U.S. EPA Method 22 in Appendix A of 40 CFR Part 60.

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g) Miscellaneous Requirements

(1) None.

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