Public Comment Opportunity
U.S. EPA
Notice
&
Administrative Record
Northwest Pipeline -
Pocatello Compressor Station
Pocatello, Idaho
Proposal to Renew Title V Operating Permit
Public Comment Period
March 10, 2020
to
April 13, 2020
Page 1 of 270
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The information listed below is included in the administrative record for this permitting action pursuant to
40 CFR § 71.11 (c) (2). Material relied upon that is published, generally available or readily available at
the permitting authority may not be physically included with the rest of the administrative record.
Document Page
Public Notice 3
Draft Title V Permit 5
Draft Title V Statement of Basis (including Appendix A) 34
Title V Renewal Application
2019-09-09 Part 71 Renewal Application 79
2019-11-04 Part 71 Renewal Application Additional Information 122
2020-01-31 Part 71 Renewal Application Additional Information 124
1998-01-01 Engines 1, 2, 3 and 4 Testing Report 130
Other Documents and Supporting Materials
2019-11-07 EPA Part 71 Completeness Determination Letter 138
2019-11-18 EPA Tribal Consultation Letter 140
2019-10-16-Email-to-Williams-Additional-Info_Request#l 142
2019-10-21-Email-from-Williams-Additional-Info_Request#l 143
2019-11-4-Email-to-Williams-Additional-Info_Request#l 145
2019-1 l-5-Email-from-Williams-Additional-Info_Request#l 147
2019-11-5-Email-to-Williams-Additional-Info_Request#l 150
2019-1 l-6-Email-from-Williams-Additional-Info_Request#l 153
2019-11-7-Email-to-Williams-Completeness-Determination 156
2019-11-18-Email-to-Tribe-Tribal-Consultation 157
2019-11-20-Email-to-Tribe-Public-Notice 158
2019-11-25-Email-from-Tribe-Public-Notice 160
2019-11-26-Email-from-Tribe-Public-Notice 162
2019-11-26-Email-to-Tribe-Public-Notic e 165
2020-l-29-Email#l-from-Williams-Additional-Info_Request# 2 168
2020-l-29-Email#l-to-Williams-Additional-Info_Request#2 170
2020-l-29-Email#2-from-Williams-Additional-Info_Request#2 171
2020-l-29-Email#2-to-Williams-Additional-Info_Request#2 173
2020-l-29-Email-from-Williams-2016-Attachment-Additional-Info_Request#2 176
2020-l-31-Email-from-Williams-Additional-Info_Request#2 178
2020-1-3 l-Email-from-Williams-Attachment-Additional-Info_Request#2 180
2020-1-31-Email-to-Williams-Additional-Info_Request#2 183
2020-2-6-Email-to-Williams-Additional-Info_Request#2 188
2020-2-14-Email-to-Tribe-Draft-Material 191
2020-2-14-Email-to-Williams-Draft-Material 192
Williams P71 Permit Pre-Draft 200214 193
Williams P71 SOB Pre-Draft 200214 222
Williams P71 SOB App A Draft 200213 249
2020-2-27-Email-from-Tribe-Draft-Material 267
2020-2-27-Email-from-Williams-Draft-Material 269
Page 2 of 270
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I
PUBLIC COMMENT OPPORTUNITY
pncfi&
EPA plans to issue an air permit for a natural gas transmission compressor station in
Pocatello, Idaho
Public comment period ends April 13, 2020
The United States Environmental Protection Agency (EPA) has prepared a draft Clean Air Act Title V
permit for the Northwest Pipeline LLC - Pocatello compressor station located in Pocatello, Idaho, on the
Fort Hall Reservation. The facility's Title V operating permit is being renewed for five years in accordance
with 40 CFR Part 71. Because the facility is located within the exterior boundaries of the Fort Hall
Reservation and because the Shoshone-Bannock Tribes do not have an EPA-approved permitting program,
it is the EPA's responsibility to issue the air quality permit.
The facility is a natural gas transmission compressor station located in Pocatello, Idaho. Northwest Pipeline
owns and operates a natural gas pipeline. The pipeline extends from Washington State to New Mexico,
passing through Oregon, Idaho, Wyoming, and Colorado. The pipeline serves commercial, industrial and
utility natural gas customers. The Pocatello compressor station is one of many compressor stations located
along the pipeline that assist in the transport of natural gas through the pipeline. At maximum operation, the
facility has the potential to emit more than 100 tons per year of nitrogen oxides and carbon monoxide and
more than 10 tons per year of a hazardous air pollutant, making it a major source of air pollution subject to
the Title V permitting program. This permitting action allows the facility to continue operating the facility
for another five years.
How can I get more information? You can review the draft permit, the permit statement of basis, the
permit application, and all supporting material from EPA's website at
https://www.epa.gov/publicnotices/notices-search/location/Idaho.
Will there be a public hearing? You can request a public hearing on the draft permit. Requests for a
hearing must be received in writing by EPA at the contact address listed below on or before the end of the
comment period and contain your reasons for requesting a hearing. If a public hearing is held, the comment
period will be extended through the date of the public hearing.
How do I comment on the permit? Any interested person may submit written comments on the draft
permit by mail or e-mail. If you believe that any condition of the draft permit is inappropriate, you must
raise all reasonably ascertainable issues and submit all reasonably ascertainable arguments supporting your
position on or before the end of the comment period. Any documents supporting your comments must be
included in full and may not be incorporated by reference, unless they are already part of the administrative
record for the draft permits or consist of tribal, state or federal statutes or regulations or other generally
available referenced materials. EPA will consider all comments received in making a final decision on the
permit. In accordance with 40 CFR 71.11, EPA will prepare a statement of reasons for changes made to the
draft permit and responses to comments received and will send them, along with the final permit, to
everyone who comments on the draft permit. Please submit all written comments or written requests for a
public hearing as follows:
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Mail comments to:
Title V Permits Coordinator
U.S. Environmental Protection Agency, Region 10
1200 Sixth Avenue, Suite 155, 15-H13
Seattle, WA 98101-3188
E-mail comments to:
R10_Air_Permits@epa.gov (Include "Northwest Pipeline" in the
subject line)
For questions call:
Christopher Familiare at (206) 553-1250
Would you like to be on our mailing list? If you would like to be added to our mailing list to receive
future information about permits, please contact the EPA at the address or telephone number listed above.
For people with disabilities: Please contact the EPA's Region 10 Office at the contact information listed
above before the end of the comment period if you have any special requests for reasonable
accommodations. For TTY users: please call the Federal Relay Service at 1-800-877-8339.
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United States Environmental Protection Agency Permit Number: R10T5110200
Region 10, Air & Radiation Division Issued: Draft
1200 Sixth Avenue, Suite 155, 15-H13 Effective: Draft
Seattle, Washington 98101-3188 Expiration: Five years from issue
Replaces: R10T5110100
AFS Plant I.D. Number: 16-005-00049
Title V Air Quality Operating Permit
Permit Renewal #2
In accordance with the provisions of Title V of the Clean Air Act (42 U.S.C. 7401 et seq), 40 CFR Part
71 and other applicable rules and regulations,
Williams Corporation, Northwest Pipeline LLC
Pocatello Compressor Station
is authorized to operate air emission units and to conduct other air pollutant emitting activities in
accordance with the conditions listed in this permit. This source is authorized to operate in the following
location:
Location: Fort Hall Indian Reservation
2605 Gas Plant Road
Pocatello, Idaho
Latitude: 42° 48' 55" N
Longitude: 112° 42' 13" W
Responsible Official: Camilo Amezquita, Vice President & General Manager
Northwest Pipeline LLC
PO Box 58900
Salt Lake City, UT 84158-0900
Phone: 713-215-2524
E-mail: Camilo.Amezquita@williams.com
Company Contact: Derek Forsberg
Northwest Pipeline LLC
Environmental Compliance
P.O. Box 58900
Salt Lake City, UT 84158-0900
Phone: 801-584-6748
E-mail: Derek.Forsberg@williams.com
The United States Environmental Protection Agency (EPA) has also developed a statement of basis that
describes the bases for conditions contained in this permit.
Kelly McFadden, Chief Date
Air Permits and Toxics Branch
Air and Radiation Division
U.S. EPA, Region 10
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Table of Contents
Abbreviations & Symbols
1. Source Information and Emission Units
2. Standard Terms and Conditions
Compliance with the Permit
Permit Shield
Other Credible Evidence
Permit Actions
Permit Expiration and Renewal
Off-Permit Changes
Emissions Trading and Operational Flexibility
Severability
Property Rights
3. General Requirements
General Compliance Schedule
Inspection and Entry
Open Burning Restrictions
Visible Emissions Limits
Fugitive Particulate Matter Requirements and Recordkeeping .
Other Work Practice Requirements and Recordkeeping
General Testing and Associated Recordkeeping and Reporting
General Recordkeeping
General Reporting
Part 71 Emission and Fee Reporting
Annual Registration
Periodic and Deviation Reporting
Annual Compliance Certification
Document Certification
Permit Renewal
4. Facility-Specific Requirements
Fees and Emission Reports Due Date
Fuel Restriction
Fuel Sulfur Limits
Fuel Sulfur Monitoring and Recordkeeping
Visible and Fugitive Emission Monitoring and Recordkeeping
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Page 2 of
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Table of Contents
Monitoring for Modifications to the Facility not Undergoing PSD Review
Reporting for Modifications to the Facility not Undergoing PSD Review
NESHAP Work Practice Requirements
NESHAP Recordkeeping Requirements
NESHAP Notification and Reporting Requirements
5. Unit-Specific Requirements - NESHAP Subpart ZZZZ for Unit #5 (Emergency Generator
Engine)
Unit #5 Work Practice Requirements
Unit #5 Monitoring and Recordkeeping Requirements
Unit #5 Reporting Requirements
6. Unit-Specific Requirements - NESHAP Subpart DDDDD for Units #6 (Boiler) and 7 (Process
Heater)
Units #6 and 7 Work Practice Requirements
Units #6 and 7 Monitoring and Recordkeeping Requirements
Units #6 and 7 Notification and Reporting Requirements
22
23
23
23
24
24
24
26
26
27
27
28
28
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200
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Abbreviations & Symbols
# Number
% Percent
ASTM American Society for Testing and Materials
Btu British thermal units
BBL Barrels (42 gallons)
CAA Clean Air Act [42 U.S.C. section 7401 et seq.]
CBI Confidential Business Information
CFR Code of Federal Regulations
CMS Continuous Monitoring System
CO Carbon monoxide
COMS Continuous opacity monitoring system
EPA United States Environmental Protection Agency (also U.S. EPA)
EU Emission Unit
FARR Federal Air Rules for Reservations
Hr Hour
IEU Insignificant Emission Unit
MMBtu One million Btu
NESHAP National Emission Standards for Hazardous Air Pollutants (40 CFR Parts 61 and 63)
No. Number
NOx Nitrogen oxides
NSR New Source Review
PM Particulate matter
PM io Particulate matter less than or equal to 10 microns in aerodynamic diameter
PM2.5 Particulate matter less than or equal to 2.5 microns in aerodynamic diameter
PSD Prevention of Significant Deterioration
SO2 Sulfur dioxide
VOC Volatile organic compound
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200
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1. Source Information and Emission Units
The Pocatello Compressor Station operates remotely from Northwest Pipeline's headquarters
located in Salt Lake City, Utah. The compressor station is used to transmit natural gas along the
company's natural gas pipeline. All emission units are fired exclusively on natural gas. The
emission units are listed in Table 1.
Table 1: Emission Units (EU) & Control Devices
EU ID#
Emission Unit Description
Control Device
Unit 1
Clark TLA-6 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas fired, 14.8
MMBtu/hr, 2,000 horsepower; SN: 73546, installed 1956
None
Unit 2
Clark TLA-6 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas-fired, 14.8
MMBtu/hr, 2,000 horsepower; SN: 73547, installed 1956
None
Unit 3
Clark TLA-6 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas fired, 14.8
MMBtu/hr, 2,000 horsepower; SN: 73548, installed 1956
None
Unit 4
Clark TCV-10 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas fired; 21.7
MMBtu/hr, 4,300 horsepower; SN: 107027, installed
1956
None
Unit 5
Caterpillar 3408 Emergency Generator Engine; Four-
stoke, rich-burn, reciprocating IC engine; natural gas
fired, 3.76 MMBtu/hr natural gas fired, 400 horsepower;
SN: CA 00844, installed 1998
None
Unit 6
Sellers Boiler; Model C80W; natural gas fired, 3.35
MMBtu/hr; Provides glycol heat to keep compressor
engines on warm standby, installed 1989
None
Unit 7
Sivallis Fuel Gas Heater; Model SB16-16; natural gas
fired, 0.5 MMBtu/hr natural gas fired; Pre-heats fuel for
compressor engines and the Sellers boiler, installed 2000
None
Unit 8*
Miscellaneous non-fugitive activities (MNFA) consist of
furnaces and space heaters that generate emissions inside
buildings.
None
Unit 9*
System Blowdown Gas: Once per year where the source
conducts an Emergency Shutdown Test where the source
is isolated from the natural gas line and the system is
purged venting natural gas to the atmosphere.
Approximately 350,000 cubic feet of natural gas is vented
during this MNFA Emergency Shutdown Test.
None
Unit 10*
Miscellaneous fugitive activities (MFA) consist of leaks
from the piping valves, flanges, and open-ended lines, and
compressors associated with the source.
None
Unit 11*
Used Oil Tank, 2,940 gallons (70 BBL); Used Lube Oil
Tank, 11,760 gallons (280 BBL); Scrubber Oil Tank,
1,250 gallons (29.8 BBL) - Scrubber tank stores oil that is
removed (knockout) from the natural gas prior to
compression.
None
* Insignificant Emission Units (IEU).
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Page 5 of 29
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2. Standard Terms and Conditions
2.1. Terms not otherwise defined in this permit have the meaning assigned to them in the referenced
regulations. The language of the cited regulation takes precedence over paraphrasing except the
text of terms specified pursuant to any of the following sections is directly enforceable: section
304(f)(4) of the Federal Clean Air Act (CAA), 40 CFR 71.6(a) (3) (i)(B) and (C), 71.6(a) (3) (ii),
71.6(b), and 71.6(c) (1), or any other term specifically identified as directly enforceable.
Compliance with the Permit
2.2. The permittee must comply with all conditions of this Part 71 permit. All terms and conditions of
this permit are enforceable by EPA and citizens under the Clean Air Act. Any permit
noncompliance constitutes a violation of the Clean Air Act and is grounds for enforcement action;
for permit termination, revocation and reissuance, or modification; or for denial of a permit
renewal application. [40 CFR 71.6(a)(6)(i); 71.6(b)]
2.3. It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. [40 CFR 71.6(a) (6) (ii)]
Permit Shield
2.4. Compliance with the terms and conditions of this permit shall be deemed compliance with the
applicable requirements specifically listed in this permit as of the date of permit issuance.
[40 CFR 71.6(f)(1)]
2.5. Nothing in this permit shall alter or affect the following:
2.5.1. The provisions of section 303 of the Clean Air Act (emergency orders), including the
authority of EPA under that section;
2.5.2. The liability of a permittee for any violation of applicable requirements prior to or at
the time of permit issuance;
2.5.3. The applicable requirements of the acid rain program, consistent with section 408(a) of
the Clean Air Act; or
2.5.4. The ability of EPA to obtain information under section 114 of the Clean Air Act.
[40 CFR 71.6(f)(3)]
Other Credible Evidence
2.6. For the purpose of submitting compliance certifications in accordance with Condition Error!
Reference source not found, of this permit, or establishing whether or not the permittee has
violated or is in violation of any requirement of this permit, nothing shall preclude the use,
including the exclusive use, of any credible evidence or information, relevant to whether the
permittee would have been in compliance with applicable requirements if the appropriate
performance or compliance test or procedure had been performed.
[Section 113(a) and 113(e)(1) of the CAA, 40 CFR 49.123(d), 51.212, 52.12, 52.33, 60.11(g) and
61.12]
Permit Actions
2.7. This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing
of a request by the permittee for a permit modification, revocation and reissuance, or termination,
or of a notification of planned changes or anticipated noncompliance does not stay any permit
condition. [40 CFR 71.6(a) (6) (iii)]
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Page 6 of 29
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2.8. The permit may be reopened by EPA and the permit revised prior to expiration under any of the
circumstances described in 40 CFR 71.7(f). [40 CFR 71.7(f)]
Permit Expiration and Renewal
2.9. This permit shall expire on the expiration date on page one of this permit or on an earlier date if
the source is issued a Part 70 or Part 71 permit by a permitting authority under an EPA approved
or delegated permit program. [40 CFR 71.6(a) (11)]
2.10. Expiration of this permit terminates the permittee's right to operate unless a timely and complete
permit renewal application has been submitted at least six months, but not more than 18 months,
prior to the date of expiration of this permit.
[40 CFR 71.5(a) (1) (iii), 71.7(b) and 71.7(c) (l)(ii)]
2.11. If the permittee submits a timely and complete permit application for renewal, consistent with 40
CFR 71.5(a)(2), but EPA has failed to issue or deny the renewal permit, then all the terms and
conditions of the permit, including any permit shield granted pursuant to 40 CFR 71.6(f) shall
remain in effect until the renewal permit has been issued or denied. This protection shall cease to
apply if, subsequent to the completeness determination, the permittee fails to submit by the
deadline specified in writing by EPA any additional information identified as being needed to
process the application. [40 CFR 71.7(c)(3) and 71.7(b)]
Off-Permit Changes
2.12. The permittee is allowed to make certain changes without a permit revision, provided that the
following requirements are met:
2.12.1. Each change is not addressed or prohibited by this permit;
2.12.2. Each change meets all applicable requirements and does not violate any existing permit
term or condition;
2.12.3. The changes are not changes subject to any requirement of 40 CFR Parts 72 through 78
or modifications under any provision of Title I of the Clean Air Act;
2.12.4. The permittee provides contemporaneous written notice to EPA of each change, except
for changes that qualify as insignificant activities under 40 CFR 71.5(c) (11), that
describes each change, the date of the change, any change in emissions, pollutants
emitted, and any applicable requirements that would apply as a result of the change;
2.12.5. The changes are not covered by a permit shield provided under 40 CFR 71.6(f) and
Conditions 2.4 and 2.5 of this permit; and
2.12.6. The permittee keeps a record describing all changes that result in emissions of any
regulated air pollutant subject to any applicable requirement not otherwise regulated
under this permit, and the emissions resulting from those changes.
[40 CFR 71.6(a) (12)]
Emissions Trading and Operational Flexibility
2.13. The permittee is allowed to make a limited class of changes under section 502(b) (10) of the Clean
Air Act within this permitted facility that contravene the specific terms of this permit without
applying for a permit revision, provided:
2.13.1. The changes do not exceed the emissions allowable under this permit (whether
expressed therein as a rate of emissions or in terms of total emissions);
2.13.2. The changes are not modifications under any provision of Title I of the Clean Air Act;
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Page 7 of 29
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2.13.3. The changes do not violate applicable requirements;
2.13.4. The changes do not contravene federally enforceable permit terms and conditions that
are monitoring (including test methods), recordkeeping, reporting, or compliance
certification requirements;
2.13.5. The permittee sends a notice to EPA, at least seven days in advance of any change
made under this provision, that describes the change, when it will occur and any change
in emissions and identifies any permit terms or conditions made inapplicable as a result
of the change and the permittee attaches each notice to its copy of this permit; and
2.13.6. The changes are not covered by a permit shield provided under 40 CFR 71.6(f) and
Conditions 2.4 and 2.5 of this permit.
[40 CFR 71.6(a) (13) (i) and 71.6(c)(1)]
2.14. No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are provided
for in this permit. [40 CFR 71.6(a)(8)]
Severability
2.15. The provisions of this permit are severable, and in the event of any challenge to any portion of
this permit, or if any portion is held invalid, the remaining permit conditions shall remain valid
and in force. [40 CFR 71.6(a)(5)]
Property Rights
2.16. This permit does not convey any property rights of any sort, or any exclusive privilege.
[40 CFR 71.6(a) (6) (iv)]
3. General Requirements
General Compliance Schedule
3.1. For applicable requirements with which the source is in compliance, the permittee will continue
to comply with such requirements. [40 CFR 71.6(c) (3) and 71.5(c) (8) (iii) (A)]
3.2. For applicable requirements that will become effective during the permit term, the permittee shall
meet such requirements on a timely basis. [40 CFR 71.6(c) (3) and 71.5(c) (8) (iii) (B)]
Inspection and Entry
3.3. Upon presentation of credentials and other documents as may be required by law, the permittee
shall allow EPA or an authorized representative to perform the following:
3.3.1. Enter upon the permittee's premises where a Part 71 source is located or emissions-
related activity is conducted, or where records must be kept under the conditions of the
permit;
3.3.2. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of the permit;
3.3.3. Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practices, or operations regulated or required under the
permit; and
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Page 8 of 29
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3.3.4. As authorized by the Clean Air Act, sample or monitor at reasonable times substances
or parameters for the purpose of assuring compliance with the permit or applicable
requirements.
[40 CFR 71.6(c)(2)]
Open Burning Restrictions
3.4. Except as exempted in 40 CFR 49.131(c), the permittee shall not openly burn, or allow the open
burning of, the following materials:
3.4.1. Garbage;
3.4.2. Dead animals or parts of dead animals;
3.4.3. Junked motor vehicles or any materials resulting from a salvage operation;
3.4.4. Tires or rubber materials or products;
3.4.5. Plastics, plastic products, or styrofoam;
3.4.6. Asphalt or composition roofing, or any other asphaltic material or product;
3.4.7. Tar, tarpaper, petroleum products, or paints;
3.4.8. Paper, paper products, or cardboard other than what is necessary to start a fire or that is
generated at single-family residences or residential buildings with four or fewer
dwelling units and is burned at the residential site;
3.4.9. Lumber or timbers treated with preservatives;
3.4.10. Construction debris or demolition waste;
3.4.11. Pesticides, herbicides, fertilizers, or other chemicals;
3.4.12. Insulated wire;
3.4.13. Batteries;
3.4.14. Light bulbs;
3.4.15. Materials containing mercury (e.g., thermometers);
3.4.16. Asbestos or asbestos-containing materials;
3.4.17. Pathogenic wastes;
3.4.18. Hazardous wastes; or
3.4.19. Any material other than natural vegetation that normally emits dense smoke or noxious
fumes when burned.
[40 CFR 49.131(c) and (d)(1)]
3.5. Open burning shall be conducted as follows:
3.5.1. All materials to be openly burned shall be kept as dry as possible through the use of a
cover or dry storage;
3.5.2. Before igniting a burn, noncombustibles shall be separated from the materials to be
openly burned to the greatest extent practicable;
3.5.3. Natural or artificially induced draft shall be present, including the use of blowers or air
curtain incinerators where practicable;
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Page 9 of 29
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3.5.4. To the greatest extent practicable, materials to be openly burned shall be separated
from the grass or peat layer; and
3.5.5. A fire shall not be allowed to smolder.
[40 CFR 49.131(e)(1)]
3.6. Except for exempted fires set for cultural or traditional purposes, a person shall not initiate any
open burning when:
3.6.1. The Regional Administrator has declared a burn ban; or
3.6.2. An air stagnation advisory has been issued or an air pollution alert, warning or
emergency has been declared by the Regional Administrator.
[40 CFR 49.131(d)(2), (d)(3) and (e)(2), and 49.137(c) (4) (i)]
3.7. Except for exempted fires set for cultural or traditional purposes, any person conducting open
burning when such an advisory is issued or declaration is made shall either immediately
extinguish the fire, or immediately withhold additional material such that the fire burns down.
[40 CFR 49.131 (e) (3) and 49.137(c) (4) (ii)]
3.8. Nothing in this section exempts or excuses any person from complying with applicable laws and
ordinances of local fire departments and other governmental jurisdictions.
[40 CFR 49.131(d)(4)]
Visible Emissions Limits
3.9. Except as provided for in Conditions 3.10 and 3.11, the visible emissions from any air pollution
source that emits, or could emit, particulate matter or other visible air pollutants shall not exceed
20% opacity, averaged over any consecutive six-minute period. Compliance with this emission
limit is determined as follows:
3.9.1. Using EPA Reference Method 9 found in Appendix A of 40 CFR part 60; or
3.9.2. Alternatively, using a continuous opacity monitoring system that complies with
Performance Specification 1 found in Appendix B of 40 CFR part 60.
[40 CFR 49.124(d)(1) and (e)]
3.10. The requirements of Condition 3.9 do not apply to open burning, agricultural activities, forestry
and silvicultural activities, non-commercial smoke houses, sweat houses or lodges, smudge pots,
furnaces and boilers used exclusively to heat residential buildings with four or fewer dwelling
units, or emissions from fuel combustion in mobile sources. [40 CFR 49.124(c)]
3.11. Exceptions to the visible emission limit in Condition 3.9 include:
3.11.1. The visible emissions from an air pollution source may exceed the 20% opacity limit if
the owner or operator of the air pollution source demonstrates to the Regional
Administrator's satisfaction that the presence of uncombined water, such as steam, is
the only reason for the failure of an air pollution source to meet the 20% opacity limit.
[40 CFR 49.124(d)(2)]
Fugitive Particulate Matter Requirements and Recordkeeping
3.12. Except as provided for in Condition 3.17, the permittee shall take all reasonable precautions to
prevent fugitive particulate matter emissions and shall maintain and operate all pollutant-emitting
activities to minimize fugitive particulate matter emissions. Reasonable precautions include, but
are not limited to the following:
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Page 10 of 29
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3.12.1. Use, where possible, of water or chemicals for control of dust in the demolition of
buildings or structures, construction operations, grading of roads, or clearing of land;
3.12.2. Application of asphalt, oil (but not used oil), water, or other suitable chemicals on
unpaved roads, materials stockpiles, and other surfaces that can create airborne dust;
3.12.3. Full or partial enclosure of materials stockpiles in cases where application of oil, water,
or chemicals is not sufficient or appropriate to prevent particulate matter from
becoming airborne;
3.12.4. Implementation of good housekeeping practices to avoid or minimize the accumulation
of dusty materials that have the potential to become airborne, and the prompt cleanup
of spilled or accumulated materials;
3.12.5. Installation and use of hoods, fans, and fabric filters to enclose and vent the handling of
dusty materials;
3.12.6. Adequate containment during sandblasting or other similar operations;
3.12.7. Covering, at all times when in motion, open bodied trucks transporting materials likely
to become airborne; and
3.12.8. The prompt removal from paved streets of earth or other material that does or may
become airborne.
[40 CFR 49.126(d)(1) and (2)]
3.13. Once each calendar year, during typical operating conditions and meteorological conditions
conducive to producing fugitive dust, the permittee shall survey the facility to determine the
sources of fugitive particulate matter emissions. For new sources or new operations, a survey
shall be conducted within 30 days after commencing operation.
3.13.1. The permittee shall record the results of the survey, including the date and time of the
survey and identification of any sources of fugitive particulate matter emissions found;
and
3.13.2. If sources of fugitive particulate matter emissions are present, the permittee shall
determine the reasonable precautions that will be taken to prevent fugitive particulate
matter emissions.
[40 CFR 49.126(e) (1) (i) and (ii)]
3.14. The permittee shall prepare, and update as necessary following each survey, a written plan that
specifies the reasonable precautions that will be taken and the procedures to be followed to
prevent fugitive particulate matter emissions, including appropriate monitoring and
recordkeeping.
3.14.1. For construction or demolition activities, a written plan shall be prepared prior to
commencing construction or demolition.
[40 CFR 49.126(e) (1) (iii) and (iv)]
3.15. The permittee shall implement the written plan, and maintain and operate all sources to minimize
fugitive particulate matter emissions. [40 CFR 49.126(e) (1) (iii) and (iv)]
3.16. Efforts to comply with this section cannot be used as a reason for not complying with other
applicable laws and ordinances. [40 CFR 49.126(e)(3)]
3.17. The requirements of Conditions 3.12 through 3.16 do not apply to open burning, agricultural
activities, forestry and silvicultural activities, sweat houses or lodges, non-commercial smoke
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houses, or activities associated with single-family residences or residential buildings with four or
fewer dwelling units. [40 CFR 49.126(c)]
Other Work Practice Requirements and Recordkeeping
3.18. The permittee shall comply with the requirements of the Chemical Accident Prevention
Provisions at 40 CFR Part 68 no later than the latest of the following dates:
3.18.1. Three years after the date on which a regulated substance, present above the threshold
quantity in a process, is first listed under 40 CFR 68.130; or
3.18.2. The date on which a regulated substance is first present above a threshold quantity in a
process.
[40 CFR 68.10 and 68.215(a)(1)]
3.19. Except as provided for motor vehicle air conditioners (MVACs) in 40 CFR Part 82, Subpart B,
the permittee shall comply with the stratospheric ozone and climate protection standards for
recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart F.
3.19.1. Persons opening appliances for maintenance, service, repair, or disposal must comply
with the required practices pursuant to 40 CFR 82.156.
3.19.2. Equipment used during the maintenance, service, repair, or disposal of appliances must
comply with the standards for recycling and recovery equipment pursuant to 40 CFR
82.158.
3.19.3. Persons performing maintenance, service, repair, or disposal of appliances must be
certified by an approved technician certification program pursuant to 40 CFR 82.161.
3.19.4. Persons disposing of small appliances, MVACs, and MVAC-like appliances must
comply with recordkeeping requirements pursuant to 40 CFR 82.166. ("MVAC-like
appliance" is defined at 40 CFR 82.152.)
3.19.5. Persons owning commercial or industrial process refrigeration equipment must comply
with the leak repair requirements pursuant to 40 CFR 82.156.
3.19.6. Owners/operators of appliances normally containing 50 or more pounds of refrigerant
must keep records of refrigerant purchased and added to such appliances pursuant to 40
CFR 82.166.
[40 CFR Part 82, Subpart F]
3.20. If the permittee performs a service on motor (fleet) vehicles when this service involves ozone-
depleting substance refrigerant (or regulated substitute substance) in the MVAC, the permittee
must comply with all the applicable requirements for stratospheric ozone and climate protection
as specified in 40 CFR Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners.
[40 CFR Part 82, Subpart B]
3.21. The permittee shall comply with 40 CFR Part 61, Subpart M for asbestos removal and disposal
when conducting any renovation or demolition at the facility. [40 CFR Part 61, Subpart M]
General Testing and Associated Recordkeeping and Reporting
3.22. In addition to the specific testing requirements contained in the facility and emission unit-specific
sections of this permit, the permittee shall comply with the generally applicable testing
requirements in Conditions 3.23 through 3.30 whenever conducting a performance test required
by this permit unless specifically stated otherwise in this permit.
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
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3.23. Test Notification. The permittee shall provide EPA at least 30 days prior notice of any
performance test, except as otherwise specified in this permit, to afford EPA the opportunity to
have an observer present. If after 30 days notice for an initially scheduled performance test, there
is a delay in conducting the scheduled performance test, the permittee shall notify EPA as soon as
possible of any delay in the original test date, either by providing at least seven days prior notice
of the rescheduled date of the performance test, or by arranging a rescheduled date with EPA by
mutual agreement. [40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.24. Test Plan. The permittee shall submit to EPA a source test plan 30 days prior to any required
testing. The source test plan shall include and address the following elements:
3.24.1. Purpose and scope of testing;
3.24.2. Source description, including a description of the operating scenarios and mode of
operation during testing and including fuel sampling and analysis procedures;
3.24.3. Schedule/dates of testing;
3.24.4. Process data to be collected during the test and reported with the results, including
source-specific data identified in the facility or emission unit-specific sections of this
permit;
3.24.5. Sampling and analysis procedures, specifically requesting approval for any proposed
alternatives to the reference test methods, and addressing minimum test length (e.g.,
one hour, eight hours, 24 hours, etc.) and minimum sample volume;
3.24.6. Sampling location description and compliance with the reference test methods;
3.24.7. Analysis procedures and laboratory identification;
3.24.8. Quality assurance plan;
3.24.9. Calibration procedures and frequency;
3.24.10. Sample recovery and field documentation;
3.24.11. Chain of custody procedures;
3.24.12. Quality assurance/quality control project flow chart;
3.24.13. Data processing and reporting;
3.24.14. Description of data handling and quality control procedures; and
3.24.15. Report content and timing.
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.25. Facilities for performing and observing the emission testing shall be provided that meet the
requirements of 40 CFR 60.8(e) and Reference Method 1 (40 CFR Part 60, Appendix A).
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.26. Unless EPA determines in writing that other operating conditions are representative of normal
operations or unless specified in the facility or emission unit-specific sections of this permit, the
source shall be operated at a capacity of at least 90% but no more than 100% of maximum during
all tests. [40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.27. Only regular operating staff may adjust the processes or emission control devices during or within
two hours prior to the start of a source test. Any operating adjustments made during a source test,
that are a result of consultation during the tests with source testing personnel, equipment vendors,
or consultants, may render the source test invalid. [40 CFR 71.6(a) (3) and 71.6(c) (1)]
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3.28. Each source test shall follow the reference test methods specified by this permit and consist of at
least three valid test runs.
3.28.1. If the reference test method yields measured pollutant concentration values at an
oxygen concentration other than specified in the emission standard, the permittee shall
correct the measured pollutant concentration to the oxygen concentration specified in
the emission standard by using the following equation:
pp - pr Y (20.9-X)
x X (20.9 - Y)
Where: PCx = Pollutant concentration at X percent;
PCm = Pollutant concentration as measured;
X = The oxygen concentration specified in the standard; and
Y = The measured average volumetric oxygen concentration.
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.28.2. Source test emission data shall be reported as the arithmetic average of all valid test
runs and in the terms of any applicable emission limit, unless otherwise specified in the
facility or emission unit-specific sections of this permit.
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.29. Test Records. For the duration of each test run (unless otherwise specified), the permittee shall
record the following information:
3.29.1. All data which is required to be monitored during the test in the facility or emission
unit-specific sections of this permit; and
3.29.2. All continuous monitoring system (CMS) data which is required to be routinely
monitored in the facility or emission unit-specific sections of this permit for the
emission unit being tested.
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.30. Test Reports. Unless the EPA approves in writing a different due date, emission test reports shall
be submitted to the EPA within 60 days of completing any emission test required by this permit
along with data required to be recorded in Condition 3.29 above.
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
General Recordkeeping
3.31. Monitoring Records. In addition to specific recordkeeping requirements contained in the source-
wide and emission unit-specific conditions of the permit, the permittee shall, where applicable,
keep records of required monitoring information that include the following:
3.31.1.
The
3.31.2.
The
3.31.3.
The
3.31.4.
The
3.31.5.
The
3.31.6.
The
[40 CFR 71.6(a) (3) (ii) (A)]
3.32. Off-Permit Change Records. The permittee shall keep a record describing all off-permit changes
allowed to be made under Condition 2.12 that result in emissions of any regulated air pollutant
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subject to any applicable requirement not otherwise regulated under this permit, and the
emissions resulting from those changes. [40 CFR 71.6(a) (12) (iv)]
3.33. Open Burning Records. For any open burning allowed under Conditions 3.4 through 3.8, the
permittee shall document the following:
3.33.1. The date that burning was initiated;
3.33.2. The duration of the burn;
3.33.3. The measures taken to comply with each provision of Condition 3.5; and
3.33.4. The measures taken to ensure that materials prohibited in Condition 3.4 were not
burned.
[40 CFR 71.6(a) (3) (i)(B) and 71.6(c)(1)]
3.34. Fee Records. The permittee shall retain in accordance with the provisions of Condition 3.35 of
this permit, all work sheets and other materials used to determine fee payments. Records shall be
retained for five years following the year in which the emissions data is submitted.
[40 CFR 71.9(i)]
3.35. Records Retention. The permittee shall retain records of all required monitoring data and support
information for a period of at least five years from the date of the monitoring sample,
measurement, report, or application. Support information includes all calibration and maintenance
records, all original strip-chart recordings for continuous monitoring instrumentation, and copies
of all reports required by this permit.
[40 CFR 71.6(a)(3)(ii)(B), 49.126(e)(l)(v) and 49.130(f)(2)]
General Reporting
3.36. Additional Information. The permittee shall furnish to EPA, within a reasonable time, any
information that EPA may request in writing to determine whether cause exists for modifying,
revoking, and reissuing, or terminating the permit, or to determine compliance with the permit.
Upon request, the permittee shall also furnish to EPA copies of records that are required to be
kept pursuant to the terms of the permit, including information claimed to be confidential.
Information claimed to be confidential must be accompanied by a claim of confidentiality
according to the provisions of 40 CFR Part 2, Subpart B.
[40 CFR 71.6(a)(6) (v) and 71.5(a)(3)]
3.37. Corrections. The permittee, upon becoming aware that any relevant facts were omitted or
incorrect information was submitted in the permit application, shall promptly submit such
supplementary facts or corrected information. Supplementary facts and corrected information
submitted pursuant to this permit condition shall be sent to the EPA at the following address. A
copy of each document submitted to the EPA that does not contain CBI shall be sent to the Tribal
address below:
Original documents go to the EPA at: Copies go to the Tribe at:
Part 71 Air Quality Permits Air Quality Manager
U.S. EPA - Region 10, 15-H13 Shoshone-Bannock Tribes
1200 Sixth Avenue, Suite 155 P.O. Box 306
Seattle, WA 98101-3188 Fort Hall, ID 83203
[40 CFR 71.5(b)]
3.38. Off-Permit Change Report. The permittee shall provide contemporaneous written notice to EPA
of each off-permit change allowed to be made under Condition 2.12, except for changes that
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qualify as insignificant activities under 40 CFR 71.5(c) (11). The written notice shall describe
each change, the date of the change, any change in emissions, pollutants emitted, and any
applicable requirements that would apply as a result of the change; [40 CFR 71.6(a) (12) (ii)]
3.39. Section 502(b)(10) Change Report. The permittee is required to send a notice to EPA at least 7
days in advance of any section 502(b) (10) change allowed to be made under Condition 2.13. The
notice must describe the change, when it will occur and any change in emissions, and identify any
permit terms or conditions made inapplicable as a result of the change. The permittee shall attach
each notice to its copy of this permit. [40 CFR 71.6(a) (13) (i) (A) and 71.6(c)(1)]
3.40. Address. Unless otherwise specified in this permit, any documents required to be submitted under
this permit, including reports, test data, monitoring data, notifications, compliance certifications
and fee calculation worksheets shall be submitted to the EPA address below. A copy of each
document submitted to EPA that does not contain CBI shall be sent to the Tribal address below:
Original documents go to the EPA at: Copies go to the Tribe at:
Clean Air Act Compliance Manager Air Quality Manager
U.S. EPA - Region 10, 20-C04 Shoshone-Bannock Tribes
1200 Sixth Avenue, Suite 155 P.O. Box 306
Seattle, WA 98101-3188 Fort Hall, ID 83203
[40 CFR 71.5(d), 71.6(c)(1) and 71.9(h)(2)]
Part 71 Emission and Fee Reporting
3.41. Part 71 Annual Emission Report. No later than the date specified in Condition 4.1 of each year,
the permittee shall submit to EPA an annual report of actual emissions for the preceding calendar
year. [40 CFR 71.9(h)(1)]
3.41.1. "Actual emissions" means the actual rate of emissions in tons per year of any
"regulated pollutant (for fee calculation)," as defined in 40 CFR 71.2, emitted from a
Part 71 source over the preceding calendar year. Actual emissions shall be calculated
using each emissions unit's actual operating hours, production rates, in-place control
equipment, and types of materials processed, stored, or combusted during the preceding
calendar year. [40 CFR 71.9(c)(6)]
3.41.2. Actual emissions shall be computed using methods required by the permit for
determining compliance. [40 CFR 71.9(h) (3) ]
3.41.3. Actual emissions shall include fugitive emissions. [40 CFR 71.9(c)(1)]
3.42. Part 71 Fee Calculation Worksheet. Based on the annual emission report required in Condition
3.41 and no later than the date specified in Condition 4.1 of each year, the permittee shall submit
to EPA a fee calculation worksheet (blank forms provided by EPA) and a photocopy of each fee
payment check (or other confirmation of actual fee paid).
[40 CFR 71.9(c)(1), 71.9(e)(1) and 71.9(h)(1)]
3.42.1. The annual emissions fee shall be calculated by multiplying the total tons of actual
emissions of each "regulated pollutant (for fee calculation)," emitted from the source
by the presumptive emission fee (in dollars/ton) in effect at the time of calculation. The
presumptive emission fee is revised each calendar year and is available from EPA prior
to the start of each calendar year. [40 CFR 71.9(c) (1)]
3.42.2. The permittee shall exclude the following emissions from the calculation of fees:
3.42.2.1 The amount of actual emissions of each regulated pollutant (for fee
calculation) that the source emits in excess of 4,000 tons per year;
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3.42.2.2 Actual emissions of any regulated pollutant (for fee calculation) already
included in the fee calculation; and
3.42.2.3 The insignificant quantities of actual emissions not required to be listed or
calculated in a permit application pursuant to 40 CFR 71.5(c) (11).
[40 CFR 71.9(c)(5)]
3.43. Part 71 Annual Fee Payment. No later than the date specified in Condition 4.1 of each year, the
permittee shall submit to EPA full payment of the annual permit fee based on the fee calculation
worksheet required in Condition 3.42. [40 CFR 71.9(a), 71.9(c)(1) and 71.9(h)(1)]
3.43.1. The fee payment and a completed fee filing form shall be sent to:
U.S.EPA
OCFO/OC/ACAD/FCB
Attn: Collections Team
1300 Pennsylvania Ave NW
Mail Code 2733R
Washington, DC 20004
[40 CFR 71.9(k) (2)]
3.43.2. The fee payment shall be in United States currency and shall be paid by money order,
bank draft, certified check, corporate check, or electronic funds transfer payable to the
order of the U.S. Environmental Protection Agency. [40 CFR 71.9(k) (1) ]
3.43.3. The permittee, when notified by EPA of additional amounts due, shall remit full
payment within 30 days of receipt of an invoice from EPA. [40 CFR 71.9 (j) (2)]
3.43.4. If the permittee thinks an EPA assessed fee is in error and wishes to challenge such fee,
the permittee shall provide a written explanation of the alleged error to EPA along with
full payment of the EPA assessed fee. [40 CFR 71.9(j) (3)]
3.43.5. Failure of the permittee to pay fees in a timely manner shall subject the permittee to
assessment of penalties and interest in accordance with 40 CFR 71.9(1).
[40 CFR 71.9(1)]
The annual emission report and fee calculation worksheet (and photocopy of each fee payment
check), required in Conditions 3.41 and 3.42, shall be submitted to EPA at the address listed in
Condition 3.40 of this permit.1 [40 CFR 71.9(k) (1) ]
The annual emission report and fee calculation worksheet (and photocopy of each fee payment
check), required in Conditions 3.41 and 3.42, shall be certified by a responsible official in
accordance with Condition 3.50 of this permit. [40 CFR 71.9(h)(2)]
Annual Registration
3.46. The permittee shall submit an annual registration report that consists of estimates of the total
actual emissions from the air pollution source for the following air pollutants: PM, PMio, PM2.5,
SOx, NOx, CO, VOC, lead and lead compounds, ammonia, fluorides (gaseous and particulate),
sulfuric acid mist, hydrogen sulfide, total reduced sulfur (TRS), and reduced sulfur compounds,
including all calculations for the estimates. Emissions shall be calculated using the actual
operating hours, production rates, in-place control equipment, and types of materials processed,
stored, or combusted during the preceding calendar year.
3.44.
3.45.
1 The permittee should note that an annual emissions report, required at the same time as the fee calculation
worksheet by 40 CFR 71.9(h), has been incorporated into the fee calculation worksheet.
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[40 CFR 49.138(e)(3), (e)(4) and (f)]
3.46.1. The emission estimates required by Condition 3.46 shall be based upon actual test data
or, in the absence of such data, upon procedures acceptable to the Regional
Administrator. Any emission estimates submitted to the Regional Administrator shall
be verifiable using currently accepted engineering criteria. The following procedures
are generally acceptable for estimating emissions from air pollution sources:
3.46.1
.1
Source-specific emission tests;
3.46.1
.2
Mass balance calculations;
3.46.1
.3
Published, verifiable emission factors that are applicable to the source;
3.46.1
.4
Other engineering calculations; or
3.46.1
.5
Other procedures to estimate emissions specifically approved by the
Regional Administrator.
[40 CFR 49.138(e)(4) and (f)]
3.46.2. The annual registration report shall be submitted with the annual emission report and
fee calculation worksheet required by Conditions 3.41 and 3.42 of this permit. The
permittee may submit a single combined report provided that the combined report
clearly identifies which emissions are the basis for the annual registration report, the
part 71 annual emission report, and the part 71 fee calculation worksheet. All
registration information and reports shall be submitted on forms provided by the
Regional Administrator. [40 CFR 49.138(d) and (f)]
Periodic and Deviation Reporting
3.47. Semi-Annual Monitoring Report. The permittee shall submit to EPA reports of any required
monitoring for each six month reporting period from July 1 to December 31 and from January 1
to June 30. All reports shall be submitted to EPA and shall be postmarked by the 60th day
following the end of the reporting period. All instances of deviations from permit requirements
must be clearly identified in such reports. All required reports must be certified by a responsible
official consistent with Condition 3.50. [40 CFR 71.6(a) (3) (iii) (A)]
3.48. Deviation Report. The permittee shall promptly report to EPA, by telephone, deviations from
permit conditions, including those attributable to upset conditions as defined in this permit, the
probable cause of such deviations, and any corrective actions or preventive measures taken. The
report shall be made to telephone number (206) 553-1331. [40 CFR 71.6(a)(3) (iii) (B)]
3.48.1. For the purposes of Conditions 3.47 and 3.48, deviation means any situation in which
an emissions unit fails to meet a permit term or condition. A deviation is not always a
violation. A deviation can be determined by observation or through review of data
obtained from any testing, monitoring, or record keeping required by this permit. For a
situation lasting more than 24 hours, each 24-hour period is considered a separate
deviation. Included in the meaning of deviation are any of the following:
3.48.1.1 A situation where emissions exceed an emission limitation or standard;
3.48.1.2 A situation where process or emissions control device parameter values
indicate that an emission limitation or standard has not been met;
3.48.1.3 A situation in which observations or data collected demonstrate
noncompliance with an emission limitation or standard or any work
practice or operating condition required by the permit (including indicators
of compliance revealed through parameter monitoring);
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3.48.1.4 A situation in which any testing, monitoring, recordkeeping or reporting
required by this permit is not performed or not performed as required;
3.48.1.5 A situation in which an exceedance or an excursion, as defined in 40 CFR
Part 64, occurs; and
3.48.1.6 Failure to comply with a permit term that requires submittal of a report.
[40 CFR 71.6(a) (3) (iii)(C) and 71.6(c)(1)]
3.48.2. For the purpose of Condition 3.48 of the permit, prompt is defined as any definition of
prompt or a specific time frame for reporting deviations provided in an underlying
applicable requirement as identified in this permit. Where the underlying applicable
requirement fails to address the time frame for reporting deviations, reports of
deviations will be submitted based on the following schedule:
3.48.2.1 For emissions of a hazardous air pollutant or a toxic air pollutant (as
identified in the applicable regulation) that continue for more than an hour
in excess of permit requirements, the report must be made within 24 hours
of the occurrence;
3.48.2.2 For emissions of any regulated pollutant excluding those listed in
Condition 3.48.2.1 above, that continue for more than two hours in excess
of permit requirements, the report must be made within 48 hours of the
occurrence; or
3.48.2.3 For all other deviations from permit requirements, the report shall be
submitted with the semi-annual monitoring report required in Condition
3.47.
[40 CFR 71.6(a) (3) (iii)(B)]
3.48.3. Within ten working days of the occurrence of a deviation as provided in Condition
3.48.2.1 or 3.48.2.2 above, the permittee shall also submit a written notice, which shall
include a narrative description of the deviation and updated information as listed in
Condition 3.48, to EPA, certified consistent with Condition 3.50 of this permit.
[40 CFR 71.6(a)(3)(i)(B) and (iii)(B), 71.6(c)(1)]
Annual Compliance Certification
3.49. The permittee shall submit to EPA a certification of compliance with permit terms and
conditions, including emission limitations, standards, or work practices, postmarked by the 60th
day of each year and covering the permit or permits in effect during the previous calendar year.
The compliance certification shall be certified as to truth, accuracy, and completeness by a
responsible official consistent with Condition 3.50 of this permit. [40 CFR 71.6(c) (5)]
3.49.1. The annual compliance certification shall include the following:
3.49.1.1 The identification of each permit term or condition that is the basis of the
certification;
3.49.1.2 The identification of the method(s) or other means used by the permittee
for determining the compliance status with each term and condition during
the certification period. Such methods and other means shall include, at a
minimum, the methods and means required in this permit. If necessary, the
permittee also shall identify any other material information that must be
included in the certification to comply with section 113(c) (2) of the Clean
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Air Act, which prohibits knowingly making a false certification or omitting
material information; and
3.49.1.3 The status of compliance with each term and condition of the permit for the
period covered by the certification, including whether compliance during
the period was continuous or intermittent. The certification shall be based
on the method or means designated above. The certification shall identify
each deviation and take it into account in the compliance certification. The
certification shall also identify as possible exceptions to compliance any
periods during which compliance is required and in which an excursion or
exceedance as defined under 40 CFR Part 64 occurred.
[40 CFR 71.6(c) (5) (iii) and 71.6(c)(1)]
Document Certification
3.50. Any document required to be submitted under this permit shall be certified by a responsible
official, as defined in 40 CFR 71.2, as to truth, accuracy, and completeness. Such certifications
shall state that based on information and belief formed after reasonable inquiry, the statements
and information in the document are true, accurate, and complete.
[40 CFR 71.5(d), 71.6(c)(1) and 71.9(h)(2)]
Permit Renewal
3.51. The permittee shall submit a timely and complete application for permit renewal at least six
months, but not more than 18 months, prior to the date of expiration of this permit. Applications
for permit renewal shall be sent to the EPA at the following address. A copy of each document
submitted to the EPA that does not contain CBI shall be sent to the Tribal address below:
Original documents go to the EPA at: Copies go to the Tribe at:
Part 71 Air Quality Permits Air Quality Manager
U.S. EPA - Region 10, 15-H13 Shoshone-Bannock Tribes
1200 Sixth Avenue, Suite 155 P.O. Box 306
Seattle, WA 98101-3188 Fort Hall, ID 83203
[40 CFR 71.5(a)(1) (iii), 71.7(b) and 71.7(c)(l)(ii)]
3.52. The application for renewal shall include the current permit number, a description of permit
revisions and off-permit changes that occurred during the permit term and were not incorporated
into the permit during the permit term, any applicable requirements that were promulgated and
not incorporated into the permit during the permit term, and other information required by the
application form. [40 CFR 71.5(a)(2) and 71.5(c)(5)]
4. Facility-Specific Requirements
Fees and Emission Reports Due Date
4.1. Unless otherwise specified, fees and emission reports required by this permit are due annually on
April 1. [40 CFR 71.9(a) and 71.9(h)]
Fuel Restriction
4.2. The permittee is prohibited from combusting any fuel other than natural gas in any emission unit.
[Section 304(f) (4) of the Federal Clean Air Act and 40 CFR 71.6(b)]
Fuel Sulfur Limits
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4.3. The permittee shall not sell, distribute, use, or make available for use any gaseous fuel that contains
more than 1.1 grams of sulfur per dry standard cubic meter. [40 CFR 49.130(d) (8)]
4.3.1. Compliance with the sulfur limit is determined using ASTM methods D1072-90
(Reapproved 1999), D3246-96, D4084-94 (Reapproved 1999), D5504-01, D4468-85
(Reapproved 2000), D2622-03, and D6228-98 (Reapproved 2003) (incorporated by
reference, see 40 CFR 49.123(e)). [40 CFR 49.130(e)(4)]
Fuel Sulfur Monitoring and Recordkeeping
4.4. The permittee shall keep records consisting of a current, valid purchase contract, tariff sheet or
transportation contract for the fuel showing that the gaseous fuel meets the definition of natural gas
in 40 CFR 72.2. [40 CFR 49.130(f) (1) (ii), 71.6(a) (3) (i)(B) and 71.6(c)]
Combustion Source Stack Emission Limits
4.5. Sulfur dioxide emissions from each combustion source stack shall not exceed an average of 500
parts per million by volume, on a dry basis and corrected to seven percent oxygen, during any
three-hour period.
4.5.1. Compliance with the SO2 limit is determined using EPA Reference Methods 6, 6A, 6B,
and 6C as specified in the applicability section of each method (see 40 CFR Part 60,
appendix A) or, alternatively, a continuous emission monitoring system (CEMS) that
complies with Performance Specification 2 found in Appendix B of 40 CFR Part 60.
[40 CFR 49.129(d)(1) and (e)]
4.6. Particulate matter emissions from each combustion source stack shall not exceed an average of
0.23 grams per dry standard cubic meter (0.1 grains per dry standard cubic foot), corrected to seven
percent oxygen, during any three-hour period.
4.6.1. Compliance with the PM limit is determined using EPA Reference Method 5 (see 40
CFR Part 60, Appendix A).
[40 CFR 49.125(d)(1) and (e)]
Visible and Fugitive Emission Monitoring and Recordkeeping
4.7. Once each calendar quarter, the permittee shall visually survey each potential source of fugitive
dust or visible particulate emissions for the presence of visible emissions or fugitive emissions of
particulate matter.
4.7.1. The observer conducting the visual survey must be trained and knowledgeable regarding
the effects of background contrast, ambient lighting, observer position relative to lighting
and wind, and the presence of uncombined water on the visibility of emissions (see 40
CFR Part 60, Appendix A, Method 22).
4.7.2. For the surveys, the observer shall select a position that enables a clear view of the
emission point to be surveyed, that is at least 15 feet, but not more than 0.25 miles, from
the emission point, and where the sunlight is not shining directly in the observer's eyes.
4.7.3. The observer shall continuously watch for visible emissions from each potential emission
point for at least 15 seconds.
4.7.4. Any observed visible emissions or fugitive emissions of particulate matter (other than
uncombined water) shall be recorded as a positive reading associated with the emission
unit or pollutant emitting activity.
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4.7.5. Surveys shall be conducted while the emission unit or pollutant emitting activity is
operating, and during daylight hours.
[40 CFR 71.6(a) (3) (i)(B)]
4.8. If the survey conducted pursuant to Condition 4.7 identifies any visible emissions or fugitive
emissions of particulate matter, the permittee shall:
4.8.1. Immediately upon conclusion of the visual survey in Condition 4.7, investigate the source
and reason for the presence of visible emissions or fugitive emissions; and
4.8.2. As soon as practicable, take appropriate corrective action.
[40 CFR 71.6(a) (3) (i)(B)]
4.9. If the corrective actions undertaken pursuant to Condition 4.8.2 do not eliminate the visible or
fugitive emissions, the permittee shall within 24 hours of the visual survey in Condition 4.7
determine the opacity of the emissions in question, for a 30-minute duration, using the procedures
specified in Condition 3.9.1. [40 CFR 71.6(a) (3) (i)(B)]
4.10. If any 6-minute average opacity determined pursuant to Condition 4.9 or 4.11 is greater than 20%,
the permittee shall determine the opacity of the emissions in question daily, for a 30-minute
duration each day, using the procedures specified in Condition Error! Reference source not
found, until no 6-minute average opacity is greater than 20% for two consecutive days. [40 CFR
71.6(a)(3) (i) (B) ]
4.11. If the opacity determination required in Condition 4.9, or if two consecutive daily opacity
determinations required by Condition 4.10, indicate no 6-minute average opacity greater than 20%,
the permittee shall determine opacity of the emissions in question weekly, for a 30-minute duration
each week, for three additional weeks using the procedures specified in Condition 3.9.1.
[40 CFR 71.6(a) (3) (i)(B)]
4.12. The permittee shall maintain records of the following:
4.12.1. Details of each visual survey, including date, time, observer and results for each emission
unit and any other pollutant emitting activity;
4.12.2. Date, time and type of any investigation conducted pursuant to Condition 4.8.1;
4.12.3. Findings of the investigation, including the reasons for the presence of visible emissions
or fugitive emissions of particulate matter;
4.12.4. Date, time and type of corrective actions taken pursuant to Condition 4.8.2;
4.12.5. Field, observation and data reduction records for any EPA Reference Method 9
determination conducted on the source of visible or fugitive emissions pursuant to
Conditions 4.9 through 4.11
[40 CFR 71.6(a) (3) (i)(B)]
4.13. Any 6-minute average opacity determined to be in excess of 20% is a deviation and subject to the
provisions of Conditions 3.47 and 3.48. [40 CFR 71.6(a) (3) (i)(B)]
Monitoring for Modifications to the Facility not Undergoing PSD Review
4.14. Where there is a reasonable possibility (as defined in 40 CFR 52.21(r)(6)(vi)) that a project (other
than projects at a source with a plantwide applicability limitation) that is not a part of a major
modification may result in a significant emissions increase of any regulated NSR pollutant and the
permittee elects to use the method specified in 40 CFR 52.21 (b) (41) (ii) (a) through (c) for
calculating projected actual emissions, the permittee shall perform the following:
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4.14.1. Before beginning actual construction of the project, document and maintain a record of
the following information.
4.14.1.1 A description of the project.
4.14.1.2 Identification of the emissions unit(s) whose emissions of a regulated NSR
pollutant could be affected by the project.
4.14.1.3 A description of the applicability test used to determine that the project is not a
major modification for any regulated NSR pollutant, including the baseline
actual emissions, the projected actual emissions, the amount of emissions
excluded under 40 CFR 52.21 (b) (41) (ii) (c) and an explanation for why such
amount was excluded, and any netting calculations, if applicable.
4.14.2. Monitor the emission of any regulated NSR pollutant that could increase as a result of the
project and that is emitted by any emissions unit identified in Condition 4.14.1.2; and
calculate and maintain a record of the annual emissions, in tons per year on a calendar
year basis, for a period of five years following resumption of regular operations after the
change, or for a period of ten years following resumption of regular operations after the
change if the project increases the design capacity or potential to emit of that regulated
NSR pollutant at such emissions unit.
[40 CFR 52.21 (r) (6)]
Reporting for Modifications to the Facility not Undergoing PSD Review
4.15. If monitoring and recordkeeping is required in Condition 4.14.2, the permittee shall report to the
EPA when the annual emissions, in tons per year, from the project identified in Condition 4.14.1.1
exceed the baseline actual emissions as documented and maintained pursuant to Condition 4.14.1.3
by a significant amount (as defined in 40 CFR 52.21(b) (23)) for that regulated NSR pollutant, and
when such emissions differ from the preconstruction projection as documented and maintained
pursuant to Condition 4.14.1.3. Such report shall be submitted to the EPA within 60 days after the
end of such year. The report shall contain the following.
4.15.1. The name, address and telephone number of the major stationary source.
4.15.2. The annual emissions as calculated pursuant to Condition 4.14.2.
4.15.3. Any other information that the owner or operator wishes to include in the report (e.g., an
explanation as to why the emissions differ from the preconstruction projection).
[40 CFR 52.2 l(r) (6)]
NESHAP Work Practice Requirements
4.16. NESHAP Circumvention. The permittee shall not build, erect, install, or use any article, machine,
equipment, or process to conceal an emission that would otherwise constitute noncompliance with
a relevant NESHAP standard. Such concealment includes, but is not limited to, the use of diluents
to achieve compliance with a relevant standard based on the concentration of a pollutant in the
effluent discharged to the atmosphere and the use of gaseous diluents to achieve compliance with a
relevant standard for visible emissions. [40 CFR 63.4(b)]
NESHAP Recordkeeping Requirements
4.17. NESHAP Records. The permittee shall maintain files of all information (including all reports and
notifications) required by a NESHAP Standard recorded in a form suitable and readily available for
expeditious inspection and review. The files shall be retained for at least 5 years following the date
of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum,
the most recent 2 years of data for Units #6 and 7 shall be retained on site. The remaining 3 years
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of data may be retained off site. Such files may be maintained on microfilm, on a computer, on
computer floppy disks, on magnetic tape disks, or on microfiche. The on-site data retention
requirement does not apply to Unit #5.
[40 CFR 63.10(b)(1), 63.6665 and Table 8 to Subpart ZZZZ of Part 63]
4.18. NESHAP Records. The permittee shall maintain relevant records for such source of all
documentation supporting initial notifications and notifications of compliance status under 40 CFR
63.9. [40 CFR 63.10(b)(2)(xiv)]
NESHAP Notification and Reporting Requirements
4.19. NESHAP Change in Information Already Provided. Any change in the information already
provided under a NESHAP standard shall be provided to the Administrator in writing within 15
calendar days after the change. [40 CFR 63.9(j)]
5. Unit-Specific Requirements - NESHAP Subpart ZZZZ for Unit
#5 (Emergency Generator Engine)
5.1. At all times the permittee shall be in compliance with NESHAP Subpart ZZZZ requirements that
apply to the permittee. [40 CFR 63.6605(a)]
5.2. The permittee shall comply with the applicable NESHAP Subpart A general provisions listed in
Table 8 to Subpart ZZZZ of Part 63, except that the requirement to submit all of the notifications
in 63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) does not apply.
[40 CFR 63.6645(a)(5), 63.6665 and Table 8 to Subpart ZZZZ of Part 63]
Unit #5 Work Practice Requirements
5.3. The permittee shall change the oil and filter every 500 hours of operation or annually, whichever
comes first. [40 CFR 63.6602 and Row 6.a. of Table 2c to Subpart ZZZZ of Part 63]
5.3.1. The permittee has the option of utilizing an oil analysis program in order to extend the
specified oil change requirement in Condition 5.3 as follows:
5.3.1.1 The analysis program must at a minimum analyze the following three
parameters: Total Acid Number, viscosity, and percent water content.
5.3.1.2 The condemning limits for these parameters are as follows: Total Acid Number
increases by more than 3.0 milligrams of potassium hydroxide (KOH) per gram
from Total Acid Number of the oil when new; viscosity of the oil has changed
by more than 20 percent from the viscosity of the oil when new; or percent
water content (by volume) is greater than 0.5.
5.3.1.3 If all these condemning limits are not exceeded, the engine owner or operator is
not required to change the oil.
5.3.1.4 If any of the limits are exceeded, the engine owner or operator must change the
oil within 2 business days of receiving the results of the analysis; if the engine is
not in operation when the results of the analysis are received, the engine owner
or operator must change the oil within 2 business days or before commencing
operation, whichever is later.
[40 CFR 63.6625 (j) and footnote 2 of Table 2c to Subpart ZZZZ of Part 63]
5.4. The permittee shall inspect air cleaner every 1,000 hours of operation or annually, whichever
comes first, and replace as necessary.
[40 CFR 63.6602 and Row 6.b. of Table 2c to Subpart ZZZZ of Part 63]
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5.5. The permittee shall inspect all hoses and belts every 500 hours of operation or annually, whichever
comes first, and replace as necessary.
[40 CFR 63.6602 and Row 6.c. of Table 2c to Subpart ZZZZ of Part 63]
5.6. If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements pursuant to Conditions 5.3, 5.4
and 5.5, or if performing the management practice would otherwise pose an unacceptable risk
under federal, state, or local law, the management practice shall be performed as soon as
practicable after the emergency has ended or the unacceptable risk under federal, state, or local law
has abated. [Footnote 1 of Table 2c to Subpart ZZZZ of Part 63]
5.7. Except as provided for in Condition 5.8, the permittee may operate Unit #5 outside of emergency
situations for up to 100 hours per calendar year and only for the following purposes:
5.7.1. Maintenance checks and readiness testing, provided that the tests are recommended by
federal, state or local government, the manufacturer, the vendor, the regional
transmission organization or equivalent balancing authority and transmission operator, or
the insurance company associated with the engine;
5.7.2. Emergency demand response for periods in which the Reliability Coordinator under the
North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-
3, Capacity and Energy Emergencies (incorporated by reference, see 40 CFR 63.14), or
other authorized entity as determined by the Reliability Coordinator, has declared an
Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-
3;
5.7.3. For periods when there is a deviation of voltage or frequency of 5 percent or greater
below standard voltage or frequency; and
5.7.4. Non-emergency situations up to 50 hours per calendar year. This 50-hour allowance
cannot be used for peak shaving or non-emergency demand response, or to generate
income for a facility to an electric grid or otherwise supply power as part of a financial
arrangement with another entity.
[40 CFR 63.6640(f)(1) through (3)]
5.8. The permittee may petition the Administrator for approval of additional hours to be used for
maintenance checks and readiness testing, but a petition is not required if the owner or operator
maintains records indicating that federal, state, or local standards require maintenance and testing
of emergency engines beyond 100 hours per calendar year. [40 CFR 63.6640(f) (2) (i)]
5.9. During periods of startup, the permittee shall minimize the engine's time spent at idle and
minimize the engine's startup time to a period needed for appropriate and safe loading of the
engine, not to exceed 30 minutes.
[40 CFR 63.6625(h) and Table 2c to Subpart ZZZZ of Part 63]
5.10. At all times the permittee shall operate and maintain the engine, including associated air pollution
control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emission does
not require the permittee to make any further efforts to reduce emissions if levels required by this
standard have been achieved. Determination of whether such operation and maintenance
procedures are being used will be based on information available to the Administrator which may
include, but is not limited to, monitoring results, review of operation and maintenance procedures,
review of operation and maintenance records, and inspection of the source.
[40 CFR 63.6605(b)]
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5.11. The permittee shall operate and maintain the engine and after-treatment control device (if any)
according to the manufacturer's emission-related written operation and maintenance instruction, or
alternatively, the permittee shall develop and follow its own maintenance plan which shall provide
to the extent practicable for the maintenance and operation of the engine in a manner consistent
with good air pollution control practice for minimizing emissions.
[40 CFR 63.6625(e), 63.6640(a) and Row 9 of Table 6 to Subpart ZZZZ of Part 63]
Unit #5 Monitoring and Recordkeeping Requirements
5.12. If the permittee utilizes an oil analysis program pursuant to Condition 5.3.1, the owner or operator
shall keep records of the parameters that are analyzed as part of the program, the results of the
analysis, and the oil changes for the engine. The analysis program shall be part of the maintenance
plan for the engine.
[40 CFR 63.6625 (j) and footnote 2 of Table 2c to Subpart ZZZZ of Part 63]
5.13. The permittee shall install a non-resettable hour meter if one is not already installed.
[40 CFR 63.6625(f)]
5.13.1. The permittee shall keep records of the hours of operation of the engine that is recorded
through the non-resettable hour meter.
5.13.2. The permittee shall document how many hours are spent for emergency operation,
including what classified the operation as emergency and how many hours are spent for
non-emergency operation.
5.13.3. If the engine is used for the purposes specified in Conditions 5.7.2 or 5.7.3, the permittee
shall keep records of the notification of the emergency situation, and the date, start time,
and end time of engine operation for these purposes.
[40 CFR 63.6655(f)]
5.14. The permittee shall keep records to show continuous compliance with Condition 5.11.
[40 CFR 63.6655(d)]
5.15. The permittee shall keep records of the maintenance conducted on the engine in order to
demonstrate that the permittee operated and maintained the engine and after-treatment control
device (if any) according to the permittee's own maintenance plan referred to in Condition 5.11.
[40 CFR 63.6655(e)]
Unit #5 Reporting Requirements
5.16. If Unit #5 operates or is obligated to be available for more than 15 hours per year for the purposes
specified in Conditions 5.7.2 and 5.7.3, the permittee shall submit annual reports as follows:
5.16.1. The report shall contain the following information: (1) company name and address where
the engine is located, (2) date of the report and beginning and ending dates of the reporting
period, (3) engine site rating and model year, (4) latitude and longitude of the engine in
decimal degrees reported to the fifth decimal place, (5) hours operated for the purposes
specified in Conditions 5.7.2 and 5.7.3, and (6) number of hours the engine is
contractually obligated to be available for the purposes specified in Conditions 5.7.2 and
5.7.3.
5.16.2. Annual reports for each calendar year must be submitted no later than March 31 of the
following calendar year.
5.16.3. The annual report shall be submitted electronically using the subpart specific reporting
form in the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed
through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the
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reporting form specific to this subpart is not available in CEDRI at the time that the report
is due, the written report must be submitted to EPA at the address specified in Condition
3.40.
[40 CFR 63.6650(a), (h) and Row 4 of Table 7 to Subpart ZZZZ of Part 63]
5.17. The permittee shall report in the semi-annual monitoring report required by Condition 3.47 any
failure to perform timely management practices as required by Conditions 5.3, 5.4 and 5.5 for
reasons afforded by Condition 5.6. Report also the federal, state or local law under which the risk
was deemed unacceptable.
[40 CFR 71.6(a) (3) (iii) (A) and footnote 1 of Table 2c to Subpart ZZZZ of Part 63)]
5.18. The permittee shall report in the semi-annual monitoring report required by Condition 3.47 each
instance in which the permittee did not meet the requirements in Table 8 to 40 CFR 63, Subpart
ZZZZ. [40 CFR 63.6640(e) and 71.6(a) (3) (iii) (A)]
5.19. The permittee shall report all deviations as defined in 40 CFR Part 63, Subpart ZZZZ in the semi-
annual monitoring report required by Condition 3.47. [40 CFR 63.6650(f)]
6. Unit-Specific Requirements - NESHAP Subpart DDDDD for
Units #6 (Boiler) and 7 (Process Heater)
Units #6 and 7 Work Practice Requirements
6.1. Tune-ups. The permittee shall conduct tune-ups of Units #6 and 7 every 5 years.
[40 CFR 63.7510(e) and 63.7500(a)(1)]
6.1.1. Tune-ups shall be conducted every 5 years to demonstrate continuous compliance. Each
5-year tune-up shall be no more than 61 months after the previous tune-up.
[40 CFR 63.7495(b), 63.7500(a)(1), 63.7510(e), 63.7515(d), 63.7540 (12) and Item 1 in
Table 3 to Subpart DDDDD]
6.1.2. For each unit not operating on the required date for a tune-up, the tune-up must be
conducted within 30 calendar days of startup. [40 CFR 63.7515(g) and 63.7540(a) (13)]
6.1.3. Tune-ups shall be conducted as follows:
6.1.3.1 As applicable, inspect the burner, and clean or replace any components of the
burner as necessary (the permittee may delay the burner inspection until the next
scheduled or unscheduled unit shutdown, but the permittee must inspect each
burner at least once every 72 months). At units where entry into a piece of
process equipment or into a storage vessel is required to complete the tune-up
inspections, inspections are required only during planned entries into the storage
vessel or process equipment;
6.1.3.2 Inspect the flame pattern, as applicable, and adjust the burner as necessary to
optimize the flame pattern. The adjustment should be consistent with the
manufacturer's specifications, if available;
6.1.3.3 Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that
it is correctly calibrated and functioning properly (the permittee may delay the
inspection until the next scheduled unit shutdown);
6.1.3.4 Optimize total emissions of CO. This optimization should be consistent with the
manufacturer's specifications; and
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6.1.3.5 Measure the concentrations in the effluent stream of CO in parts per million, by
volume, and oxygen in volume percent, before and after the adjustments are
made (measurements may be either on a dry or wet basis, as long as it is the
same basis before and after the adjustments are made). Measurements may be
taken using a portable CO analyzer.
[40 CFR 63.7540(a) (10) (i) to (v) and 63.7540(a) (12)]
6.2. Good Air Pollution Control Practices. At all times, the permittee shall operate and maintain the
boilers, including associated air pollution control equipment and monitoring equipment, in a
manner consistent with safety and good air pollution control practices for minimizing emissions.
Determination of whether such operation and maintenance procedures are being used will be based
on information available that may include, but is not limited to, monitoring results, review of
operation and maintenance procedures, review of operation and maintenance records, and
inspection of the source. [40 CFR 63.7500(a)(3)]
Units #6 and 7 Monitoring and Recordkeeping Requirements
6.3. Records. The permittee shall keep and maintain records as follows:
6.3.1. A copy of each notification and report submitted to comply with NESHAP Subpart
DDDDD, including all documentation supporting any Initial Notification or Notification
of Compliance Status submitted according to the requirements in 63.10(b) (2) (xiv).
[40 CFR 63.7555(a)(1)]
6.3.2. Records of the calendar date, time, occurrence and duration of each startup and
shutdown. [40 CFR 63.7555 (i)]
6.3.3. Records of the type(s) and amount(s) of fuels used during each startup and shutdown.
[40 CFR 63.7555(j)]
6.3.4. On-site and submitted, if requested by the Administrator, an annual report containing the
following:
6.3.4.1 The concentrations of CO in the effluent stream in parts per million by volume,
and oxygen in volume percent, measured at high fire or typical operating load,
before and after the tune-up of the boiler; and
6.3.4.2 A description of any corrective actions taken as a part of the tune-up.
[40 CFR 63.7540(a) (10) (vi)]
6.3.5. Each record must be in a form suitable and readily available for expeditious review. Each
record shall be kept for 5 years following the date of each occurrence, measurement,
maintenance, corrective action, report, or record. Each record shall be kept on site, or
they shall be accessible from onsite (for example, through a computer network), for at
least 2 years after the date of each occurrence, measurement, maintenance, corrective
action, report, or record. The permittee can keep the records off site for the remaining 3
years. [40 CFR 63.7560(a) to (c)]
Units #6 and 7 Notification and Reporting Requirements
6.4. Annual Compliance Reports. The permittee shall submit 5-year compliance reports.
[40 CFR 63.7550(a) and Item l.a in Table 9 to Subpart DDDDD]
6.4.1. Each compliance report shall cover the 5-year reporting period from January 1 to
December 31, and be postmarked or submitted no later than January 31 of the year
following the reporting period.
[40 CFR 63.7550(b)(3) and (4)]
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6.4.2. The compliance report shall include the following information: [40 CFR 63.7550(c) (1)]
6.4.2.1 Company and Facility name and address. [40 CFR 63.7550(c)(5) (i)]
6.4.2.2 Process unit information. [40 CFR 63.7550(c) (5) (ii)]
6.4.2.3 Date of report and beginning and ending dates of the reporting period.
[40 CFR 63.7550(c) (5) (iii)]
6.4.2.4 The date of the most recent tune-up for each unit subject to only the requirement
to conduct a 5-year tune-up according to 40 CFR 63.7540(a) (12), and the date of
the most recent burner inspection if it was not done on a 5-year period and was
delayed until the next scheduled or unscheduled unit shutdown.
[40 CFR 63.7550(c)(5) (xiv)]
6.4.2.5 If there are no deviations from the requirements for work practice standards in
Table 3 to Subpart DDDDD of Part 63 that apply to the permittee, a statement
that there were no deviations from the work practice standards during the
reporting period. [Item l.b in Table 9 to Subpart DDDDD]
6.4.2.6 If the permittee has a deviation from a work practice standard during the
reporting period, the report must contain a description of the deviation and
information on the duration and cause of the deviation and corrective action
taken.
[Item l.c in Table 9 to Subpart DDDDD and 40 CFR 63.7550(d)(1) and (2)]
6.4.2.7 The information required to be recorded pursuant to Condition 6.3.4.
[40 CFR 63.7540(a) (10) (vi) and 71.6(a) (3) (iii) (A)]
6.4.2.8 A statement by a responsible official with that official's name, title, and
signature, certifying the truth, accuracy, and completeness of the content of the
report. [40 CFR 63.7550(c) (5) (xvii)]
6.4.3. All reports shall be submitted electronically using the Compliance and Emissions Data
Reporting Interface that is accessed through the EPA's Central Data Exchange
(www.epa.gov/cdx). If the reporting form specific to this subpart is not available in
CEDRI at the time that the report is due, the report shall be submitted to the address listed
in Condition 3.40. [40 CFR 63.7550(h)]
6.5. Notification of Fuel Switch or Physical Change. The permittee shall provide notice to the EPA
within 30 days of the switch/change if the permittee has switched fuels or made a physical change
to a boiler and the fuel switch or physical change resulted in the applicability of a different
subcategory of NESHAP Subpart DDDDD. The notice shall identify:
6.5.1. The name of the owner or operator of the boiler, the location of the boiler, identification
of the boiler that has switched fuels or was physically changed, and the date of the notice.
6.5.2. The currently applicable subcategory under NESHAP Subpart DDDDD.
6.5.3. The date upon which the fuel switch or physical change occurred.
[40 CFR 63.7545(h)]
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200
Page 33 of 270
Page 29 of 29
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United States Environmental Protection Agency
Region 10, Air & Radiation Division
1200 Sixth Avenue, Suite 155,15-H13
Seattle, Washington 98101-3188
Permit Number: R10T5110200
Expiration: Five years from issue
Replaces: R10T5110100
Effective: Draft
Issued: Draft
AFS Plant I.D. Number: 16-005-00049
Statement of Basis
Title V Air Quality Operating Permit
Permit Renewal #2
Permit Writer: Christopher Familiare
Williams Corporation, Northwest Pipeline LLC
Pocatello Compressor Station
Fort Hall Indian Reservation
Pocatello, Idaho
Purpose of Permit and Statement of Basis
Title 40 Code of Federal Regulations Part 71 establishes a comprehensive air quality operating permit
program under the authority of Title V of the 1990 amendments to the federal Clean Air Act. The air
quality operating permit is an enforceable compilation of all of the applicable air pollution
requirements that apply to an existing affected air emissions source. The permit is developed via a
public process, may contain additional new requirements to improve monitoring of existing
requirements, and contains procedural and prohibitory requirements related to the permit program
itself. The permit is valid for five years and may be renewed.
This document, the statement of basis, summarizes the legal and factual basis for the permit conditions
in the air quality operating permit to be issued to Northwest Pipeline for their Pocatello Compressor
Station (referred to herein as facility, source, or permittee). Unlike the air quality operating permit,
this document is not legally enforceable. This statement of basis summarizes the emitting processes
at the facility, air emissions, permitting and compliance history, the statutory or regulatory provisions
that relate to the subject facility, and the steps taken to provide opportunities for public review of the
permit. The permittee is obligated to follow the terms of the permit. Any errors or omissions in the
summaries provided here do not excuse the permittee from the requirements of the permit.
Page 34 of 270
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Table of Contents
Abbreviations & Symbols 3
1. EPA Authority to Issue Title V Permits 4
2. Facility Information 4
2.1 Location 4
2.2 Fort Hall Indian Reservation 4
2.3 Local Air Quality and Attainment Status 5
2.4 F acility Description 5
2.5 Identification of Emission Generating Activities 6
2.6 Permitting, Construction and Compliance History 8
3. Emission Inventory 9
3.1 Emission Inventory Basics 9
3.2 Potential to Emit (PTE) 9
3.3 Actual Emissions 10
4. Regulatory Analysis 11
4.1 Federal Air Quality Requirements 11
4.2 Other Federal Requirements and Responsibilities 17
5. Permit Content 18
5.1 Permit Conditions for Renewal Permit No. R10T5110200 18
5.2 Obsolete Permit Conditions from Expiring Permit No. R10T5110100 26
6. Public Participation 26
6.1 Public Notice and Comment 26
6.2 Response to Public Comments and Permit Issuance 27
Appendix A - PTE Emissions Inventory
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 35 of 270
Page 2 of 27
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Abbreviations & Symbols
#
Number
%
Percent
Btu
British thermal units
BBL
Barrels (42 gallons)
CAA
Clean Air Act [42 U.S.C. section 7401 et seq.]
CAM
Compliance Assurance Monitoring
CFR
Code of Federal Regulations
CO
Carbon monoxide
COMS
Continuous opacity monitoring system
EPA
United States Environmental Protection Agency (also U.S. EPA)
EU
Emission Unit
FARR
Federal Air Rules for Reservations
FR
Federal Register
gr/dscf
Grains per dry standard cubic foot
gr
grains (7,000 grains = 1 pound)
HAP
Hazardous Air Pollutant
Hr
Hour
IEU
Insignificant Emission Unit
IC
Internal combustion
lb
Pound (lbs = pounds)
MACT
Maximum Achievable Control Technology
MMBtu
One million Btu
NESHAP
National Emission Standards for Hazardous Air Pollutants (40 CFR Parts 61 and 63)
No.
Number
NOx
Nitrogen oxides
NSPS
New Source Performance Standards
NSR
New Source Review
02
Oxygen
PM
Particulate matter
PMio
Particulate matter less than or equal to 10 microns in aerodynamic diameter
PM2.5
Particulate matter less than or equal to 2.5 microns in aerodynamic diameter
ppmv
Parts per million on a volume basis
PSD
Prevention of Significant Deterioration
PTE
Potential to emit (based on 8,760 hours of operation per year)
RICE
Reciprocating internal combustion engines
S
Sulfur
scf
Standard cubic feet (for natural gas is at 1 atmosphere and 60 degrees F)
S02
Sulfur dioxide
tpy
Tons per year
voc
Volatile organic compound
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 36 of 270
Page 3 of 27
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1. EPA Authority to Issue Title V Permits
On July 1, 1996, EPA adopted regulations (see 61 Federal Register (FR) 34202) codified at 40 Code of
Federal Regulations (CFR) Part 71 setting forth the procedures and terms under which the Agency would
administer a federal operating permit program. These regulations were updated on February 19, 1999 (64
FR 8247) to incorporate EPA's approach for issuing federal operating permits to affected stationary
sources in Indian Country, and have been updated since from time to time.
As described in 40 CFR 71.4(b), EPA will implement and enforce a part 71 operating permit program in
Indian country when an operating permit program which meets the requirements of part 70 has not been
granted approval by the Administrator. Unlike States, Indian Tribes are not required to develop operating
permit programs, though EPA encourages Tribes to do so. See, for example, Indian Tribes: Air Quality
Planning and Management (63 FR 7253, February 12, 1998) (also known as the "Tribal Authority Rule").
EPA may delegate the authority to administer a part 71 operating permit program, in whole or in part, to
an Indian Tribe as described in 40 CFR 71.4(j) and 71.10.
2. Facility Information
2.1 Location
The Northwest Pipeline Pocatello Compressor Station is a privately-owned facility located at 2605 Gas
Plant Road in Power County, Idaho. It is approximately 12 miles west of the City of Pocatello, and 19
miles southeast of the town of Fort Hall. The facility is located within the boundaries of the Fort Hall
Indian Reservation and is in Indian Country, as defined by 40 CFR Part 71. A map of the local area
surrounding the facility is presented in Figure 2-1 with the Fort Hall Indian Reservation outlined in
burgundy, the Fort Hall PMio non attainment area highlighted in yellow and the Portneuf Valley PMio
maintenance area highlighted in green.
Craters of
the Moon NM
Pocatello Compressor
Station
Hall
'
,
iF^ortNM
i •,
Non-attainment Bridger
* V
Fitzpatr
Wilctefh
V . \ •
r.
j ' r
Wilderness
Portneuf Valley
Maintenance
a for PMk)
Figure 2-1 - Facility Location
Map produced by Idaho Department of Environmental Quality
2.2 Fort Hall Indian Reservation
The Northwest Pipeline Pocatello Compressor Station is located on the Fort Hall Indian Reservation in
south east Idaho. The Fort Hall Indian Reservation was established by the Bridger Treaty of 1868 as a
1,350 square mile reservation for the Shoshone and Bannock Tribes. The current size of the reservation is
849.8 square miles (543,900 acres). The total population residing on the Fort Hall Reservation is below
10,000. The map in Figure 2-1 above shows the location of the Northwest Pipeline Pocatello Compressor
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 37 of 270
Page: 4 of 27
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Station relative to its position within the Fort Hall Reservation.
Tribal Contact: Lori Howell
Air Quality Program Manager
Shoshone-Bannock Tribes
P.O. Box 306
Fort Hall, Idaho 83203
Phone: (208) 478-3794
Email: lhowell@sbtribes.com
2.3 Local Air Quality and Attainment Status
The EPA sets National Ambient Air Quality Standards for criteria air pollutants and then determines
whether areas in the country meet the standards. Areas that fail to meet national standards are called
nonattainment areas. Areas that meet national standards are called attainment areas (designated
"unclassifiable/attainment"). In some cases, the EPA is not able to determine an area's status after
evaluating the available information. Those areas are designated "unclassifiable." The Fort Hall Indian
Reservation and surrounding area has been designated unclassifiable/attainment for the PM2.5, ozone, CO,
NO2 and SO2 standards. As designated under 40 CFR 81.313 a PM10 nonattainment area lies within a
portion of the Fort Hall Indian Reservation. The compressor station lies about two miles west of the
nonattainment area (see Figure 2-1 above).
The closest Class I designated area to the compressor station is the Craters of the Moon National
Monument (see figure 2-1 above) which is located approximately 52 miles northwest of the Pocatello
Compressor Station. The Craters of the Moon National Monument is listed in 40 CFR 81.410 as a Class I
area for the purpose of major new source review (PSD) impact evaluation.
2.4 Facility Description
Northwest Pipeline Corporation is a subsidiary of Williams Gas Pipeline Company, LLC. Northwest
Pipeline Corporation owns and operates Williams' westernmost natural gas pipeline. The pipeline extends
from Washington State to New Mexico, passing through Oregon, Idaho, Wyoming, and Colorado. The
pipeline serves commercial, industrial and utility natural gas customers. The Pocatello Compressor
Station is one of many compressor stations located along the pipeline that assist in the transport of natural
gas through the pipeline. The compressor station fits under the standard industrial classification (SIC)
code 4922 for natural gas transmission. A plot plan of the facility is shown in Figure 2-2 below.
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 38 of 270
Page 5 of 27
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Figure 2-2 - Northwest Pipeline Pocatello Compressor Station Plot Plan
combustion units vent directly to the atmosphere through an individual stack, except for furnaces and
space heaters that generate emissions inside buildings. Installation dates for each emissions unit are listed
because they are important in determining applicability of federal NSPS and MACT standards (see further
discussion in Section 4).
An emission unit or activity qualifies as an insignificant emission unit (IEU) if it is an activity type listed
in 40 CFR 71.5(c) (1 l)(i) or emits less than 2 tons per year of any regulated air pollutant excluding HAPs
[40 CFR 71.5(c) (11) (ii) (A)] and less than 1000 pounds per year of any HAP or the de minimis HAP level
established under Section 112(g), whichever is lower [40 CFR 71.5(c)(11)(ii)(B)]. IEUs that are listed
activity types need not be included in permit applications and fee calculations as long as the permit
application does not omit information needed to determine the applicability of, or to impose, any
applicable requirements. IEUs that qualify because they meet the insignificant emission levels
(thresholds) only need to be listed in permit applications (and again as long as the application does not
omit information needed for applicability), but cannot be excluded from fee calculations. IEUs are in no
way exempt from applicable requirements, or any other requirement of the Title V permit.
Northwest Pipeline claimed three oil storage tanks (EU11) as IEUs on EPA Form IE in their Title V
application. Northwest Pipeline also noted that natural gas-fired space heaters (Unit #8) and the natural
gas pipeline and fuel system (Units #9 & 10) are IEUs. The emission units are not listed IEU activity
types, but the potential to emit for each of the emission units is below the IEU thresholds. Because all of
the IEUs qualify by meeting the IEU thresholds, their emissions must be included in fee calculations; as
such, these emission units have been included in the emission inventory in Appendix A.
2.5 Identification of Emission Generating Activities
The air pollution emission units and control devices that exist at Northwest Pipeline are listed in Tables 2-
1 below by emission unit identification (EU ID) and categorized as either generating fugitive or non-
fugitive emissions. Installation dates (if known) for each emission unit are listed because they are
important in determining applicability of federal PSD, NSPS and MACT standards (see further discussion
in Section 4). Capacities are listed for several emission units based on the best information available from
the applicant. Those control devices that are required by rule or this permit are so noted.
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 39 of 270
Page 6 of 27
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Table 2-1: Emission Units (EU) & Control Devices
EU ID#
Emission Unit Description
Control Device
Unit 1
Clark TLA-6 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas fired, 14.8
MMBtu/hr, 2,000 horsepower; SN: 73546, installed 1956
None
Unit 2
Clark TLA-6 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas-fired, 14.8
MMBtu/hr, 2,000 horsepower; SN: 73547, installed 1956
None
Unit 3
Clark TLA-6 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas fired, 14.8
MMBtu/hr, 2,000 horsepower; SN: 73548, installed 1956
None
Unit 4
Clark TCV-10 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas fired; 21.7
MMBtu/hr, 4,300 horsepower; SN: 107027, installed
1956
None
Unit 5
Caterpillar 3408 Emergency Generator Engine; Four-
stoke, rich-burn, reciprocating IC engine; natural gas
fired, 3.76 MMBtu/hr natural gas fired, 400 horsepower;
SN: CA 00844, installed 1998
None
Unit 6
Sellers Boiler; Model C80W; natural gas fired, 3.35
MMBtu/hr; Provides glycol heat to keep compressor
engines on warm standby, installed 1989
None
Unit 7
Sivallis Fuel Gas Heater; Model SB16-16; natural gas
fired, 0.5 MMBtu/hr natural gas fired; Pre-heats fuel for
compressor engines and the Sellers boiler, installed 2000
None
Unit 8*
Miscellaneous non-fugitive activities (MNFA) consist of
furnaces and space heaters that generate emissions inside
buildings.
None
Unit 9*
System Blowdown Gas: Once per year where the source
conducts an Emergency Shutdown Test where the source
is isolated from the natural gas line and the system is
purged venting natural gas to the atmosphere.
Approximately 350,000 cubic feet of natural gas is vented
during this MNFA Emergency Shutdown Test.
None
Unit 10*
Miscellaneous fugitive activities (MFA) consist of leaks
from the piping valves, flanges, and open-ended lines, and
compressors associated with the source.
None
Unit 11*
Used Oil Tank, 2,940 gallons (70 BBL); Used Lube Oil
Tank, 11,760 gallons (280 BBL); Scrubber Oil Tank,
1,250 gallons (29.8 BBL) - Scrubber tank stores oil that is
removed (knockout) from the natural gas prior to
compression.
None
* Insignificant Emission Units (IEU). See the Statement of Basis Section 2.4 for more information.
An emission unit or activity qualifies as an IEU if it is an activity type listed in 40 CFR 71.5(c) (11) (i) or
emits less than two tons per year of any regulated air pollutant excluding HAPs [40 CFR
71.5(c) (11) (ii) (A)] and less than 1,000 pounds per year of any HAP or the de minimis HAP level
established under Section 112(g), whichever is lower [40 CFR 71.5(c)(11)(ii)(B)]. The IEUs listed in
Table 2-1 above have been identified by Northwest Pipeline as IEUs on the basis that each unit's potential
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 40 of 270
Page 7 of 27
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to emit (PTE) for any individual regulated air pollutant (excluding HAPs) does not exceed two tons per
year.
2.6 Permitting, Construction and Compliance History
The Pocatello Compressor Station was originally constructed in 1956 with the installation of three 2,000
hp Clark TLA-6 gas compressor engines. In 1969 a 4,300 hp Clark TCV-10 gas compressor engine was
installed at the site to increase the facility's compressor capacity. All four compressor engines are still in
use today. In 1998, an emergency backup generator was installed to ensure electrical reliability at the site.
Northwest Pipeline has not applied for, or received any new source review permits for the construction or
installation of equipment at the facility. Northwest Pipeline indicates that there have been no
modifications, or installations, of any large emission unit(s), after major new source review (PSD
permitting) requirements went into effect. EPA has not drawn any conclusions regarding compliance with
PSD permitting requirements, and no enforcement shield is implied or granted.
Either the EPA, or the Shoshone-Bannock Tribes Air Quality Program on behalf of EPA, have inspected
the Pocatello Compressor Station at least every other year since issuance of the initial Title V permit in
October 2002. The associated inspection reports indicate that the source has been operating in compliance
with applicable air pollution requirements.
A chronologic summary of Title V permit activities for the Pocatello Compressor Station is provided
below.
October 17, 2002
June 3,2005
June 1,2007
June 13,2007
July 6, 2007
October 29, 2007
December 5, 2007
July 30, 2015
August 29, 2015
September 28, 2015
September 30, 2015
September 9, 2019
November 13, 2019
EPA issues initial Title V permit with an effective date of December 2, 2002.
This is a five-year renewable permit with an expiration date of December 2,
2007. The renewal application was due on June 2, 2007, six months prior to
permit expiration.
EPA issues letter to Northwest Pipeline requiring the Title V application be
updated to include Federal Air Regulations for Reservations (FARR).
EPA receives Title V permit renewal application from Northwest Pipeline.
EPA receives additional information for the application regarding applicable
regulations, including FARR requirements.
EPA receives additional information for the application regarding the designation
of responsible officials.
Meeting with Northwest Pipeline at EPA Region 10 to review permit renewal
process and expectations. EPA requested additional information.
EPA receives additional information for the application including emission
factors, list of IEUs, plot plan and photographs of the facility.
EPA receives additional information for the application including applicable
requirements under 40 CFR Part 63 to the boiler and process heater.
Public comment period for draft permit and statement of basis begins
Public comment period for draft permit ends.
Final permit issued with an effective date of October 31, 2015. Expiration date
September 30, 2020.
EPA receives Title V permit renewal application from Northwest Pipeline.
EPA receives additional information regarding NSPS Subparts A/JJJJ
reconstruction/modification applicability for the facility's four engines.
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 41 of 270
Page 8 of 27
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February #, 2020 Public comment period for draft permit and statement of basis begins.
March #, 2020 Public comment period for draft permit ends.
3. Emission Inventory
3.1 Emission Inventory Basics
An emission inventory generally reflects either the "actual" or "potential" emissions from a source.
Actual emissions generally represent a specific period of time and are based on actual operation and
controls. Potential emissions, referred to as potential to emit (PTE), generally represent the maximum
capacity of a source to emit a pollutant under its physical and operational design, taking into
consideration regulatory restrictions, but only required control devices. PTE is often used to determine
applicability to several EPA programs, including Title V, PSD and Section 112 (MACT).
Emissions can be broken into two categories: point and fugitive. Fugitive emissions are those which could
not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening. Examples of
fugitive emissions are roads, piles that are not normally enclosed, wind blown dust from open areas, and
those activities that are normally performed outside buildings. Point sources of emissions include any
emissions that are not fugitive.
The equation below represents the general technique for estimating emissions (in tons per year) from each
emission unit at the facility. Emissions are calculated by multiplying an emission factor by an operational
parameter. To estimate actual emission, the permittee will need to track the actual operational rates. Note
that emission factors may be improved over time. For those estimation techniques that require substantial
site-specific parameter tracking, such as piles and roads, emissions associated with a defined operational
rate can be estimated to establish a set ratio that can be used to multiply by the actual operational rate in
future years, significantly simplifying the annual inventory effort. All of the techniques and site-specific
parameters and assumptions should be reviewed each year before estimating emissions to be sure they
remain appropriate.
E = EF x OP x K
Where:
E = pollutant emissions in tons/year
EF = emission factor (see Appendix A to this Statement of Basis)
OP = operational rate (or capacity for PTE)
K = 1 ton/2000 lbs for conversion from pounds per year to tons per year
3.2 Potential to Emit (PTE)
Northwest Pipeline submitted emission inventories of actual and potential emissions for the Pocatello
Compressor Station with its Title V permit renewal application. EPA reviewed Northwest Pipeline's
inventory and has documented the facility PTE in Appendix A. The PTE estimates for the compressor
station assumes all units operate 8760 hours per year and no enforceable emission controls exist that limit
emissions with the exception of the emergency backup electrical power generator which assumes no more
than 500 hours of operation. A summary of Northwest Pipeline's non-fugitive PTE (except for HAPs) is
presented in Table 3-1 below. Note that fugitive emissions are not included for non-HAP emissions,
because for compressor stations fugitive emissions are not used to determine program applicability as
explained in more detail in Section 4.1 of this Statement of Basis. HAPs are used to determine
applicability for MACT purposes.
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 42 of 270
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Table 3-1 - Pocatello Compressor Station Potential to Emit (tpy)1
Pollutant2
Emission Units
Total
Four
Natural Gas
Compressor
RICE
Backup
Generator
RICE
Boiler &
Heater
Heaters
&
Furnaces
System
Blowdown
Equipment
Leaks &
Oil Storage
T anks
CO
100.2
3.5
1.4
0.4
106
NOx
1087.6
2.1
1.7
0.5
1,092
PM
11.1
11
PMio
13.8
0.1
14
PM2.5
13.8
0.1
14
S02
15.8
0.1
1.0
0.3
17
VOC
32.4
0.1
0.2
33
GHG (C02e)
33,924
110
2,059
605
178
36,876
Facility-wide Single
HAP
16.0
Facility-wide Total HAP
23.2
1 Fugitive emissions are not included in this table (except for HAPs) because fugitives are not used in applicability
determinations for this source type (see Section 4.1). For fugitive emission estimates, see Appendix A.
2 CO = carbon monoxide; NOx = oxides of nitrogen; PM = particulate matter; PMio = inhalable coarse particulate
or particulate matter with diameter 10 microns or less; PM2.5 = fine particulate or particulate matter with diameter
2.5 microns or less; SO2 = sulfur dioxide; VOC = volatile organic compounds; GF1G = greenhouse gases; C02e =
carbon dioxide equivalent; F1AP = hazardous air pollutants [see CAA, Section 112(b)]; facility-wide total F1AP =
all FlAPs totaled; facility-wide single F1AP = highest individual F1AP.
Northwest Pipeline is expected to use the emission factors and calculation methods listed in Appendix A
unless Northwest Pipeline demonstrates that a more appropriate emission factor or calculation method
should be used (e.g., results of more recent source testing or sampling, revised emission factors published
in AP-42 or etc.). It is important to emphasize that to the extent Northwest Pipeline relies on any type of
emission control technique to estimate emissions used to determine annual fees, or the applicability of a
regulatory program, use of the technique must be fully documented and verifiable.
3.3 Actual Emissions
Northwest Pipeline is required to pay fees annually based on an inventory of its actual emissions for the
preceding calendar year (see Permit Conditions 3.41 through 3.45). Table 3-3 summarizes Northwest
Pipeline's reported actual emissions generated in calendar year 2018.1
1 Although Northwest Pipeline is not required to report CO emissions for the purpose of part 71 fee payment, CO
emissions were reported as required by the Federal Air Rules for Reservations (FARR). See 40 CFR 49.138(f) and
71.2. Greenhouse gas emissions were not reported as GF1G is not classified as a "regulated pollutant (for fee
calculation)" and GF1G is not a pollutant for which the FARR registration program requires annual reporting of
emissions. See 40 CFR 49.138(e) (3) (xii) and 71.2. PM emissions were not reported as PM is not a regulated
pollutant in the context of the part 71 program and PM is not a pollutant for which the FARR registration program
requires annual reporting of emissions. See 40 CFR 49.138(e)(3) (xii) and October 16, 1995 EPA memorandum
entitled, "Definition of Regulated Pollutant for Particulate Matter for Purposes of Title V." PM2.5 emissions were not
reported as they were assumed to be equivalent to PM10 emissions.
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
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Table 3-2: Pocatello Compressor Station Actual Emissions (tons) for Calendar Year 2018
Emission Units
Pollutant
Four
Natural Gas
Backup
Generator
Heaters
&
Furnaces
System
Equipment
Leaks &
T otal
Compressor
RICE
RICE,
Boiler & Heater
Blowdown
Oil Storage
T anks
CO
47.02
0.91
47.9
NOx
395.17
1.07
396.2
PMio
4.05
0.08
No emissions reported for fee
purposes as these emission units are
IEU's. See 40 CFR 71.9(c) (5) (iii).
4.1
S02
0.69
0.01
0.7
voc
9.56
0.06
9.6
Formaldehyde
(highest-emitting
HAP)
4.63
0.02
4.7
4. Regulatory Analysis
The EPA is required by 40 CFR part 71 to include in this Title V permit all emission limitations and
standards that apply to the facility, including operational, monitoring, testing, recordkeeping and reporting
requirements necessary to assure compliance. This section explains which air quality regulations apply to
this facility and how those requirements are addressed in the permit.
Located in Indian Country, the Pocatello Compressor Station is subject to federal air quality regulations,
and is not subject to state air quality regulations. The EPA does not consider permits issued by Idaho to
the Pocatello Compressor Station to be applicable requirements. The facility could be subject to tribal air
quality regulations; however, the Shoshone-Bannock Tribes has not gone through the process of obtaining
authorization to be treated in the same manner as states under 40 CFR 49.6 and 49.7 (Tribal Authority
Rule) and obtaining approval of air quality regulations as a "Tribal Implementation Plan." Therefore,
Tribal air quality regulations, if any, are not federally enforceable and do not meet the definition of
"applicable requirement" under 40 CFR part 71. As such, there are no Tribal air quality regulations
included in the Pocatello Compressor Station Title V permit.
The EPA relied on information provided in Northwest Pipeline's Title V permit application and on
supplementary information provided by Northwest Pipeline to determine the requirements that are
applicable to the Pocatello Compressor Station. Future modifications to the facility could result in
additional requirements.
4.1 Federal Air Quality Requirements
Title V Operating Permit Program. Title V of the CAA and the implementing regulation found in 40 CFR
part 71 require major sources (as well as specified non-major sources) of air pollution to obtain operating
permits and form the legal bases for this permit. A source is major if it has the potential to emit 100 tons
per year or more of any air pollutant subject to regulation, 25 tons per year or more of hazardous air
pollutants (totaled) or 10 tons per year or more of any single hazardous air pollutant (see 40 CFR 71.2).
The Pocatello Compressor Station is a major source subject to Title V because it has the potential to emit
more than 100 tons per year of NOx and CO and more than 10 tons per year of the HAP formaldehyde
(see Table 3-1 and Appendix A).
The Title V operating permit serves as a comprehensive compilation of the air quality requirements that
are applicable to a source. The permit also must assure compliance, so source-specific testing, monitoring,
recordkeeping and reporting have been added where necessary, as explained in Section 5 (Permit
Content) of this Statement of Basis below.
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
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New Source Review. The New Source Review (NSR) program requires stationary source owners or
operators to obtain a permit before they begin construction of a new source or a modification to an
existing source. In other words, facilities are required to obtain NSR permits for the construction of
entirely new facilities and for construction projects at existing facilities such as expansions, additions,
process changes, and equipment modifications. By requiring sources to meet pre-construction
requirements, the NSR program provides a mechanism to improve the air quality in nonattainment areas
and to maintain the air quality in attainment areas.
There are three types of NSR permitting programs, each with a different set of requirements. A facility
may be required to meet one or more of these sets of permitting requirements when the facility undertakes
a modification. The Prevention of Significant Deterioration (PSD) program applies to the construction of
a new major source or a major source making a major modification that is located in an attainment area.
The PSD program generally applies to facilities that have the potential to emit 250 tons per year (tpy) or
100 tpy or more of any regulated NSR pollutant. The thresholds depend on the type of source and there is
a list of 28 source categories for which the 100 tpy threshold applies. The Nonattainment NSR (NA NSR)
program applies to the construction of a new major source or a major source making a major modification
that is located in a nonattainment area. Generally, the NA NSR program applies to facilities that have the
potential to emit 100 tpy or more of a NAAQS pollutant. However, this threshold can be lower depending
on the nonattainment severity of the area where the source is or will locate. The Minor NSR program
applies to a new minor source and/or a minor modification at both major and minor sources, in both
attainment and nonattainment areas. Minor NSR will apply for those regulated NSR pollutants that are
emitted at or above the minor NSR thresholds specified in the Tribal minor NSR rule (Table 1 to 40 CFR
49.153) but below the major source thresholds.
Because the area in which the Pocatello Compressor Station is located is not classified non-attainment for
any pollutant, the NA NSR program is not currently relevant. Based upon our knowledge of the facility
and understanding of its potential emissions, the Pocatello Compressor Station is a PSD major source. It
has been a major source since the beginning of the PSD program. A modification to an existing major
source is subject to PSD review for each pollutant experiencing an emissions increase greater than
defined PSD significance level. A modification to an existing major source is subject to minor NSR for
each pollutant experiencing an emissions increase greater than the defined minor NSR significance level
but less than the defined PSD significance level. Whereas the minor NSR program became effective
August 30, 2011, the first version of the PSD program became effective in the late 1970's. The four main
gas compressor engines (Emission Units 1, 2, 3 and 4) were installed before the late 1970's. The backup
engine (Emission Unit 5), added to the facility in 1998, resulted in a potential increase of 36 tons per year
of NOx and 61 tons per year of CO.2 The thresholds for a significant increase are 40 and 100 tons per year
for NOx and CO, respectively, so the addition of the backup engine was not a major modification subject
to PSD review. The addition of the backup was not a modification subject minor NSR because that permit
program did not exist in 1998.
New Source Performance Standards (NSPS). There are no NSPS regulations applicable to the Pocatello
Compressor Station. The following is a list of four potentially applicable NSPS regulations and explains
why each is not applicable to the facility.
40 CFR Part 60 Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage
Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or
Modification Commenced After July 23, 1984.
2 The EPA September 6, 1995 guidance document entitled, "Calculating PTE for Emergency Generators," and its
statement that 500 hours is an appropriate default assumption for estimating the number of hours that an emergency
generator could be expected to operate under worst-case conditions, the construction of Unit #5 resulted in a
potential increase of 2.1 tpy NOx and 3.5 tpy CO. See Appendix A to this Statement of Basis for the calculation of
these values.
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NSPS Subpart Kb applies to storage vessels with a capacity greater than or equal to 75 cubic meters (m3)
(19,800 gal) used to store volatile organic liquids (VOL) for which construction, reconstruction, or
modification is commenced after July 23, 1984.
Conclusion: The largest storage tank at the Pocatello Compressor Station is 280 barrels (bbl) (11,760 gal)
of lubrication oil. This volume is less than the NSPS Subpart Kb requirement, and the facility commenced
operation prior to July 23, 1984; therefore, Subpart Kb does not apply. Construction of the newest storage
tank (scrubber oil tank) commenced after July 23, 1984, but its 1,250-gallon capacity is less than the
19,800-gallon applicability threshold. Subpart Kb does not apply to the newest tank.
40 CFR Part 60 Subpart KKK - Standards of Performance for Equipment Leaks of VOC from
Onshore Natural Gas Processing Plants
NSPS Subpart KKK applies to equipment leak components at onshore natural gas processing plants
that commenced construction after January 20, 1984. A natural gas processing plant is defined in
Subpart KKK as any processing site engaged in the extraction of natural gas liquids from field gas,
fractionation of mixed natural gas liquids to natural gas products, or both [40 CFR 60.631],
Conclusion: Pocatello Compressor Station is a natural compressor station and it does not extract or
fractionate natural gas liquids. Operation commenced prior to January 20, 1984; therefore, Subpart KKK
does not apply.
40 CFR Part 60 Subpart LLL - Standards of Performance for Onshore Natural Gas Processing:
SO; Emissions
NSPS Subpart LLL applies to facilities the following facilities that process natural gas: each sweetening
unit and each sweetening unit followed by a sulfur recovery unit.
Conclusion: The Pocatello Compressor Station does not operate natural gas sweetening units or sulfur
recovery units; therefore, Subpart LLL does not apply.
40 CFR Part 60 Subpart TTTT - Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
NSPS Subpart JJJJ applies to stationary spark ignition internal combustion engines that commence
construction after June 12, 2006, where the engines are manufactured:
• On or after July 1, 2007, for engines with a maximum engine power greater than or equal to 500
HP (except lean burn engines with a maximum engine power greater than or equal to 500 HP
and less than 1,350 HP);
• On or after January 1, 2008, for lean burn engines with a maximum engine power greater than or
equal to 500 HP and less than 1,350 HP;
• On or after July 1, 2008, for engines with a maximum engine power less than 500 HP; or
• On or after January 1, 2009, for emergency engines with a maximum engine power greater than
19 KW (25 HP).
Conclusion: Each of the stationary spark ignition internal combustion engines at the Pocatello Compressor
Station commenced construction prior to June 12, 2006; therefore, they are considered existing and
therefore not subject to the requirements of Subpart JJJJ [40 CFR 60.4230(a) (4)].
National Emission Standards for Hazardous Air Pollutants (NESHAP). With a few exceptions, NESHAP
standards promulgated under 40 CFR part 63 apply to "major sources" of HAP. Section 112(a) (1) and 40
CFR 63.2 define a "major source" as a stationary source or group of stationary sources located within a
contiguous area and under common control that emits or has the potential to emit considering controls in
the aggregate, 10 tons per year or more of any HAP or 25 tons per year or more of any combination of
HAP. The Northwest Pipeline Pocatello Compressor Station is a major source of HAP as it emits
approximately 16 tons of formaldehyde. See PTE emissions inventory in Appendix A.
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The following is a list of two potentially applicable NESHAP regulations and explains why each is not
applicable to the facility.
40 CFR Part 63 Subpart HH - National Emission Standards for Hazardous Air Pollutants from
Oil and Natural Gas Production Facilities
NESHAP Subpart HH applies to oil and natural gas production facilities that are major and area sources
of HAPs. A major source is defined as a stationary source that emits or has the potential to emit 10 tpy of
any single HAP or 25 tpy of total HAPs, and an area source is any stationary source of HAPs that is not a
major source [40 CFR 63.2],
For facilities that are major HAP sources, this subpart applies to facilities that process, upgrade or store
hydrocarbon liquids prior to the point of custody transfer or facilities that process, upgrade, or store
natural gas prior to the point at which natural gas enters the natural gas transmission and storage source
category or is delivered to a final end user.
The affected sources for major sources of HAPs include the following:
• Each glycol dehydration unit;
• Each storage vessel with the potential for flash emissions;
• Compressors or ancillary equipment operating in volatile hazardous air pollutant service located
at natural gas processing plants;
The affected sources for area sources of HAPs include the following:
• Each triethylene glycol (TEG) dehydration unit located at an oil and natural gas production
facility.
Conclusion: The Pocatello Compressor Station is a natural gas transmission compressor station and is a
major source of HAPs. The facility does not meet the NESHAP definition of a natural gas production
facility, there are no glycol dehydration units and there are no ancillary equipment operating in volatile
HAP service, therefore, Subpart HH does not apply.
40 CFR Part 63 Subpart HHH - National Emission Standards for Hazardous Air Pollutants from
Natural Gas Transmission and Storage Facilities
NESHAP Subpart HHH applies to owners and operators of natural gas transmission and storage facilities
that transport or store natural gas prior to entering the pipeline to a local distribution company or to a final
end user (if there is no local distribution company), and that are major sources of HAP emissions. The
applicable affected source is each glycol dehydration unit. An owner or operator of a facility that does not
contain a glycol dehydration unit is not subject to the requirements of this subpart.
Conclusion: The Pocatello Compressor Station is a natural gas transmission compressor station and is a
major source of HAPs, however, the facility does not operate a glycol dehydration unit, therefore, Subpart
HHH does not apply [40 CFR 63.1270(a), (b) & (c)].
40 CFR Part 63 Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
There are two NESHAP standards that are applicable to this facility: Subpart ZZZZ (Stationary
Reciprocating Internal Combustion Engines (RICE)) and Subpart DDDDD (Industrial, Commercial and
Institutional Boilers and Process Heaters at Major Sources). Subpart ZZZZ applies to the Emergency
Backup Electrical Power Generator (Unit #5) and Subpart DDDDD applies to the boiler and fuel gas
heater (Units #6 and 7). The applicable requirements in Subparts ZZZZ and DDDDD have been
incorporated into Sections 5 and 6 of the permit, respectively.
Any existing, new, or reconstructed stationary RICE located at a major or area source of HAP emissions,
excluding stationary RICE being tested at a stationary RICE test cell/stand is subject to 40 CFR 63
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Subpart ZZZZ. There are five stationary RICE at the Pocatello Compressor Station. In accordance with
40 CFR 63.6590(a), these engines are affected sources under 40 CFR Part 63, subpart ZZZZ. However, in
accordance with 40 CFR 63.6590(b) (3) (i), four of these engines (Units 1, 2, 3, and 4) do not have to meet
the requirements of 40 CFR Part 63, subpart ZZZZ or subpart A, including the initial notification
requirements. Table 4-1 below summaries MACT ZZZZ applicability.
Table 4-1 - MACT Subpart ZZZZ Applicability for IC Engines
EU I.D. #
Description
Fuel
Capacity
Subpart ZZZZ
Applicable?
1, 2 and 3
Clark TLA-6 Gas Compressor
Engine; Two-stroke, lean-burn;
Installed 1956
Natural
gas
14.8 MMBtu/hr
2,000
horsepower
Yes, under the category
of existing, two-stroke,
lean-burn engine
4
Clark TCV-10 Gas Compressor
Engine; Two-stroke, lean-burn;
Installed 1969
Natural
gas
21.7 MMBtu/hr
3,400
horsepower
Yes, under the category
of existing, two-stroke,
lean-burn engine
5
Caterpillar 3408 Emergency
Backup Generator Engine; Four-
stoke, rich-burn; Installed 1998
Natural
gas
3.76 MMBtu/hr
400 horsepower
Yes, emergency
stationary RICE.
The Caterpillar emergency backup electrical generator (Unit #5) is an affected source under Subpart
ZZZZ because it is an emergency stationary RICE under 40 CFR 63.6585(f). Under 40 CFR 63.6585(f),
an emergency stationary RICE must meet the definition of such a RICE under 40 CFR 63.6675, which
includes operating according to the provisions specified in 40 CFR 63.6640(f).
Each of the compressor engines at the facility are rated at greater than 500 horsepower, and therefore are
regulated engines under the rule. However, these engines are considered "existing" engines because they
were constructed and installed prior to December 19, 2002. Subpart ZZZZ has distinct requirements for
regulated engines depending on their design, use, and fuel. The compressor engines at the Pocatello
Compressor Station are categorized as spark-ignition, two-stroke, lean-burn (2SLB) engines under the
rule. Existing engines (Units 1, 2, 3, and 4) that are of the spark-ignition, two-stroke, lean-burn design are
not subject to any specific requirement under the rule, including being exempt for the initial notification
requirements of the NESHAP regulations.
If Northwest Pipeline were to modify any of the compressor engines in a manner that meets the definition
of reconstruction under NESHAP regulations, the engine may no longer be considered "existing' under
Subpart ZZZZ, and additional requirements from this subpart could apply.
40 CFR Part 63 Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants
for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters
Any new, reconstructed, or existing boiler or process heater located at a major source of HAP emissions,
excluding any units listed under 40 CFR 63.7491, is subject to 40 CFR 63 Subpart DDDDD. There are
two units at the Pocatello Compressor Station that meet the definition of "industrial, commercial, or
institutional boiler or process heater," the Sellers boiler and the Sivalls fuel gas line heater. None of the
exclusions apply to either of the units. In accordance with 40 CFR 63.7490(a)(1), these two units together
are the affected source under 40 CFR Part 63, subpart DDDDD. Table 4-2 below summarizes MACT
DDDDD applicability.
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Table 4-2 - MACT Subpart DDDDD Applicability for Boiler and Process Heater
EU I.D. #
Description
Fuel
Capacity
Subpart DDDDD
Applicable?
6
Sellers C80W Boiler,
Glycol Heater;
Installed 1989
Natural gas
(Gas 1)
3.35 MMBtu/hr
Yes, under the category of
existing, boiler
7
Sivalls Fuel Gas Line
Heater; Installed 2000
Natural gas
(Gas 1)
0.5 MMBtu/hr
Yes, under the category of
existing, process heater
According to the applicability criteria in 40 CFR 63.7490(b), (c), & (d), both the Sellers boiler and the
Sivalls heater are considered "existing" affected units as construction of each commenced prior to June 4,
2010 and because neither has been reconstructed since that date. Given the type of fuel combusted (Gas
1), neither of these units are subject to either an emissions limitation or operating limit according to 40
CFR 63.7500(e). Which Subpart DDDDD work practice standards apply depends upon the technical
specifications of the affected unit. Because each unit has a heat input capacity less than or equal to 5
MMBtu/hr, and because each unit is designed to burn Gas 1, each unit is subject to the requirement to
conduct a tune-up every five years pursuant to 40 CFR 63.7500(a)(1), (e) and Item No. 1 of Table 3 to
Subpart DDDDD. Because each unit is an existing unit located at a major source (and because neither is
a limit use unit), each unit is also subject to a one time-energy assessment pursuant to 40 CFR
63.7500(a)(1) and Item No. 4 of Table 3 to Subpart DDDDD.
Regional Haze Program. The Regional Haze Rule3 calls for state and federal agencies to work together to
improve visibility in 156 national parks and wilderness areas (Class 1 areas) such as the Grand Canyon,
Yosemite, the Great Smokies and Shenandoah. The 43,243-acre Craters of the Moon Wilderness Area is
the nearest Class 1 area to the facility. The southeast corner of this nearest Class 1 area is approximately
25 miles west of the facility. The area is managed by the United States Department of the Interior's
National Park Service.
The Western Regional Air Partnership (WRAP) is a voluntary partnership of states, tribes, federal land
managers, local air agencies and EPA whose purpose is to understand current and evolving regional air
quality issues in the West. The purpose of the WRAP Regional Haze Planning Work Group (RHPWG)4 is
to prepare the framework to support regional planning for the 15 western states, so that needed elements
will be available for Regional Haze state implementation plan (RH SIP) submissions in a timely fashion,
to meet the July 2021 deadline for implementation plans to be submitted in each of the 15 states
(including Idaho) for the second planning period of the federal Regional Haze Rule for visibility
protection at 118 Class I areas. Regional Haze SIPs or FIPs for the second planning period of the
Regional Haze Rule are due by July 2021 and may contain additional requirements for sources impacting
Class 1 areas.
Section 111(d) and Section 129 Regulations. There are no CAA, Section 111 (d) or 129 regulations that
apply to the type of emission units at the Northwest Pipeline Pocatello Compressor Station.
Federal Air Rules for Reservations (FARR). On April 8, 2005, EPA promulgated a Federal
Implementation Plan (FIP) for Reservations in Idaho, Oregon and Washington, commonly referred to as
the Federal Air Rules for Reservations (FARR). The EPA published the FARR rules that generally apply
to Indian Reservations in EPA Region 10 in 40 CFR 49.121 to 49.139. The FARR rules that specifically
apply on the Fort Hall Reservation (Sections 123, 124, 125, 126, 129, 130, 131, 135, 137, 138 and 139)
are codified at 40 CFR 49.10701 to 49.10730. FARR requirements that do not apply to Pocatello
Compressor Station are not included in the permit; requirements that apply generally to all subject sources
3 https://www.govinfo.gov/content/pkg/FR-2017-01-10/pdf/2017-0Q268.pdf
4 https://www.wrapair2.org/RHPWG.aspx
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but do not create specific requirements for Northwest Pipeline (e.g., applicability provisions, definitions,
provisions regarding delegation) are also not included in the permit. The applicable requirements in the
FARR have been incorporated into Sections 3 and 4 of the permit.
Compliance Assurance Monitoring. CAM applies at time of initial Title V permit issuance for emission
units that (a) are subject to an emission limit, (b) employ a control device to comply with the limit, and (c)
have post-control PTE equal to or greater than the major source threshold defined in Title V (generally,
100 tons per year). See 40 CFR 64.5(a). All units that meet the CAM applicability criteria must be in
compliance with CAM at initial permit issuance. The initial Title V permit was issued to Northwest
Pipeline on October 17, 2002. It was determined at that time that each of the four compressor engines at
the Pocatello Compressor Station has a PTE for NOx greater than 100 tons per year. However, because
none of the engines are equipped with a control device, CAM does not apply. That determination
continues to remain valid.
Chemical Accident Release Program. Northwest Pipeline has not reported storing a regulated substance
above the threshold quantity. The permit contains a placeholder provision requiring the permittee to
comply with the chemical accident prevention provisions in 40 CFR part 68 in a timely manner if it
becomes subject.
Protection of Stratospheric Ozone. The provisions of 40 CFR part 82, subparts B and F apply to facilities
that handle ozone depleting substances (e.g. refrigerants). The permit contains conditions that require the
permittee to manage ozone depleting substances and maintain records according to these subparts.
Acid Rain Program. Title IV of the CAA created a SO2 and NOx reduction program found in 40 CFR part
72. The program applies to any facility that includes one or more "affected units" that produce electricity.
The facility's boiler is not an "affected unit" as defined in 40 CFR 72.6 because it does not produce
electricity.
Mandatory Greenhouse Gas Reporting Rule. This rule requires sources above certain emission thresholds
to calculate, monitor, and report greenhouse gas emissions. According to the definition of "applicable
requirement" in 40 CFR 71.2, neither 40 CFR part 98, nor CAA 307(d) (1)(V), the CAA authority under
which part 98 was promulgated, are listed as applicable requirements for the purpose of Title V
permitting. Although the rule is not an applicable requirement under 40 CFR part 71, the source is not
relieved from the requirement to comply with the rule separately from compliance with their part 71
operating permit. It is the responsibility of each source to determine applicability to part 98 and to
comply, if necessary.
4.2 Other Federal Requirements and Responsibilities
EPA Trust Responsibility. As part of the EPA Region 10's direct federal implementation and oversight
responsibilities, EPA Region 10 has a trust responsibility to each of the 271 federally recognized Indian
tribes within the Pacific Northwest and Alaska. The trust responsibility stems from various legal
authorities including the U.S. Constitution, Treaties, statutes, executive orders, historical relations with
Indian tribes, and in this case the Bridger Treaty of 1868. In general terms, the EPA is charged with
considering the interest of tribes in planning and decision making processes. Each office within the EPA
is mandated to establish procedures for regular and meaningful consultation and collaboration with Indian
tribal governments in the development of EPA decisions that have tribal implications. EPA Region 10's
Air and Radiation Division has contacted the Shoshone-Bannock Tribes to invite consultation on the
Northwest Pipeline Pocatello Compressor Station Title V operating permit renewal application.
Endangered Species Act (ESA). Under this act, the EPA is obligated to consider the impact that a federal
project may have on listed species or critical habitats. It is the EPA's conclusion that the issuance of this
Title V permit will not affect a listed species or critical habitat because it does not authorize new
emissions units, increase existing emission limits or impose any new work practice requirements.
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Therefore, no additional analysis and no additional requirements will be added to this permit for ESA
reasons. The EPA's no-effect determination concludes the EPA's obligations under Section 7 of the ESA.
For more information about EPA's obligations, see the Endangered Species Consultation Handbook:
Procedures for Conducting Consultation and Conference Activities under Section 7 of the Endangered
Species Act, published by the FWS and NMFS (March 1998, Figure 1).
National Environmental Policy Act (NEPA). Under Section 793(c) of the Energy Supply and
Environmental Coordination Act of 1974, no action taken under the CAA shall be deemed a major
Federal action significantly affecting the quality of the human environment within the meaning of the
National Environmental Policy Act of 1969. This permit is an action taken under regulations
implementing the CAA and is therefore exempt from NEPA.
National Historic Preservation Act (NHPA). As noted earlier, the issuance of this Title V permit does not
authorize new emissions units, increase existing emission limits or impose any new work practice
requirements. No changes to the facility are expected as a result of this permit action. Consequently, no
adverse effects are expected, and further review under NHPA is not indicated.
Environmental Justice (ET) Policy. Under Executive Order 12898, Federal Actions to Address
Environmental Justice in Minority Populations and Low-Income Populations, signed on February 11,
1994, the EPA is directed, to the greatest extent practicable and permitted by law, to make achieving
environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately
high and adverse human health or environmental effects of its programs, policies, and activities on
minority populations and low-income populations in the United States. This permit action does not allow
new or additional emissions and therefore impacts. As a result, there is no information available that
indicates that there are disproportionately high and adverse impacts to a minority or low-income
population.
5. Permit Content
5.1 Permit Conditions for Renewal Permit No. R10T5110200
This Title V operating permit compiles all of the applicable requirements that apply to the permittee.
Additional monitoring, recordkeeping and reporting requirements have been created where necessary. In
general, each permit condition in the permit is explained below. Certain permit conditions are self-
explanatory, and thus are not further discussed. The permit is organized into the following six sections:
Front Page: Authorization to Operate in Accordance with the Permit
Permit Section 1: Source Information and Emission Units
Permit Section 2: Standard Terms and Conditions
Permit Section 3: General Requirements
Permit Section 4: Facility-Specific Requirements
Permit Section 5: Unit-Specific Requirements - NESHAP Subpart ZZZZ for Unit #5
(Emergency Backup Generator)
Permit Section 6: Unit-Specific Requirements - NESHAP Subpart DDDDD for Units #6
(Boiler) and 7 (Process Heater)
Front Page - Authorization to Operate in Accordance with the Permit
The first page of the permit specifies the relevant statutes within the Clean Air Act and the implementing
federal regulations that authorize EPA to issue the permit and allow the permittee to operate and conduct
air polluting activities in accordance with the conditions in the permit. The front page also identifies the
permittee's contact information as well as the location of the permitted facility.
On January 31, 2020, EPA Region 10 received a request to change the responsible official from Glen
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Jasek to Camilo Amezquita. Mr. Amezquita has replaced Mr. Jasek as Vice President and General
Manager of Northwest Pipeline LLC. The renewed permit reflects the change.
Permit Section 1 - Source Information and Emission Units
This permit section contains a brief description of the facility and a list of emission units. A more detailed
description of the facility can be found in Section 2 of this Statement of Basis. Northwest Pipeline reports
one modification to the facility having been undertaken during the five-year term of the current Title V
permit. Two 310-gallon (each) scrubber oil tanks have been replaced by one 1,250-gallon scrubber oil
tank. The new tank (like the ones it replaced) is recognized as part of Unit #11.
Permit Section 2 - Standard Terms and Conditions
This permit section includes generic compliance terms that are required in all Title V permits, but that
Region 10 does not expect to be addressed in the annual compliance certification required in Permit
Condition 3.49.
Permit Condition 2.1 explains that the language in the underlying regulations takes precedence over
paraphrased language in the permit. Some applicable requirements are paraphrased in the permit with the
intention of clarifying the requirement, but with no intention of changing the underlying meaning of the
requirement. Where there is a difference between the language in a permit and an underlying regulation,
the wording in the underlying regulation governs. This permit condition also notes some underlying
authorities that may have been used to create additional requirements in this permit. For instance, Region
10 is relying upon periodic monitoring authority in 40 CFR 71.6(a) (3) (i) (B) to create monitoring
requirements when an applicable underlying emission limitation is not accompanied by monitoring.
Region 10 is relying upon sufficiency monitoring authority in 40 CFR 71.6(c) (1) to create monitoring
requirements when an applicable underlying emission limitation is accompanied by monitoring that we
have determined is not sufficient to assure compliance with the limitation.5
Permit Conditions 2.4 and 2.5 address a general permit shield which states that compliance with the
permit is deemed compliance with the applicable requirements listed in the permit. The permittee is
responsible for complying with any applicable requirements that exist but have not been included in the
permit. The permittee did not request a specific permit shield for any specific requirement excluded from
this permit and none is being granted.
Permit Condition 2.6 incorporates the credible evidence rule as reflected in the various applicable
requirements cited as authority for this condition. It makes clear that language in the permit stating
"compliance is determined with" or "demonstrate compliance by" does not preclude the use of other
credible evidence to demonstrate that the permittee is not in compliance with an applicable requirement.
Permit Conditions 2.7 and 2.8 incorporate the Part 71 provisions regarding permit modification,
revocation, reopening, reissuance, and termination for cause.
Permit Conditions 2.9 through 2.11 address the expiration of the permit and the ramifications if the
permittee does or does not renew their permit. It is important to note that, if the permittee does not submit
a complete and timely renewal application, the permittee's right to operate is terminated. The expiration
date of the permit is listed on the top right-hand corner of the front page of the permit. Specific
requirements regarding permit renewal are in Permit Conditions 3.51 and 3.52.
Permit Conditions 2.12 through 2.14 address options for making certain physical and operational changes
5 In the Matter of Citgo Refining and Chemicals Company L.P., West Plant, Corpus Christi, Texas, Order on
Petition No. VI-2007-01 (May 28, 2009). Permitting authorities must incorporate applicable monitoring
requirements into the Title V permit, add monitoring when no underlying monitoring exists, and supplement existing
monitoring that is not sufficient to assure compliance with permit terms and conditions.
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in the facility that do not require a permit modification. If the permittee uses any of these options, they
must comply with the applicable recordkeeping requirement found in Permit Condition 3.32 and reporting
requirements found in Permit Conditions 3.38 and 3.39.
Permit Section 3 - General Requirements
This permit section includes conditions that are required in all Title V permits. In some cases, facility-
specific testing, monitoring, recordkeeping and reporting requirements for these permit conditions are
found in Section 4 of the permit because those requirements can vary from permit to permit. Unless
otherwise specified, emission units are subject to the general requirements in Section 3 of the permit as
well as the facility-specific and unit-specific requirements in Sections 4 through 6.
Permit Conditions 3.1 and 3.2 are general compliance schedule requirements. Because EPA is not aware
of any non-compliance at the time of permit issuance, there is no issue-specific compliance schedule in
the permit.
Permit Condition 3.3 requires the permittee to allow EPA-authorized representatives access to the facility
and required records.
Permit Conditions 3.4 through 3.8 restrict open burning. If the permittee performs any open burning,
recordkeeping requirements specific to open burning found in Permit Condition 3.33 will apply.
Permit Conditions 3.9 through 3.11 limit visible emissions, require the use of either RM9 or a continuous
opacity monitoring system (COMS) for determining compliance with the limit, and provide exceptions to
the rule. RM9 includes specific guidance for reading opacity when there is a wet plume (both attached
and detached and directs the observer to take readings excluding the portion of the plume that includes
uncombined water (droplets). In the vast majority of cases, the likelihood of exceeding the 20% opacity
limit due to the presence of uncombined water is very low because a certified reader would know that
he/she should not read that portion of the plume. However, there are meteorological conditions that can
prevent uncombined water (droplets) from completely evaporating in a plume (e.g., 100% relative
humidity and a saturated plume). The provision in Permit Condition 3.11 addresses that situation.
Because testing, monitoring, recordkeeping and reporting for assuring compliance with the visible
emission limit can change based on the emission unit in question, the testing, monitoring, recordkeeping
and reporting requirements are contained in facility-specific requirements in Section 4 of the permit, or in
each emission unit-specific section, as appropriate. The general monitoring, recordkeeping and reporting
for this requirement is the periodic visible emissions survey (plant walkthrough) specified in Permit
Conditions 4.7 through 4.13.
Permit Conditions 3.12 through 3.17 restrict fugitive particulate matter emissions and require a plan be
created to assure the use of reasonable precautions to prevent fugitive emissions. The plan is based on a
survey of the facility and is updated annually. This annual survey can be accomplished simultaneously
with the periodic visible emission survey requirement in Permit Conditions 4.7 through 4.13, as long as
both requirements are fully complied with.
Permit Condition 3.18 addresses requirements in the Chemical Accident Prevention Program found in 40
CFR part 68. This program requires sources that use or store regulated substances above a certain
threshold to develop plans to prevent accidental releases. Based on information in their application, there
are no regulated substances above the threshold quantities in this rule at this facility; therefore, the facility
is not currently subject to the requirement to develop and submit a risk management plan. However, this
requirement is included in the permit as an applicable requirement because the permittee has an ongoing
responsibility to submit a risk management plan if a substance is listed that the facility has in quantities
over the threshold amount, or if the facility ever increases the amount of any regulated substance above
the threshold quantity. Including this term in the permit minimizes the need to reopen the permit if the
facility becomes subject to the requirement to submit a risk management plan.
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Permit Conditions 3.19 and 3.20 address the Stratospheric Ozone and Climate Protection Program found
in 40 CFR part 82. This program requires sources that handle regulated materials to meet certain
procedural and certification requirements. There may be equipment at the facility that uses or contains
chlorofluorocarbons (CFCs) or other materials regulated under this program. All air conditioning and
refrigeration units must be maintained by certified individuals if they contain regulated materials.
Permit Condition 3.21 addresses asbestos demolition or renovation activity found in 40 CFR part 61,
Subpart M (NESHAP). This program requires sources that handle asbestos-containing materials to follow
specific procedures. If the permittee conducts any demolition or renovation activity at their facility, they
must assure that the project is in compliance with the federal rules governing asbestos, including the
requirement to conduct an inspection for the presence of asbestos. This requirement is in the permit to
address any demolition or renovation activity that may occur at the facility.
Permit Conditions 3.22 through 3.30 specify the procedures that must be followed whenever the permit
requires emissions testing or sampling in an emission unit-specific section of the permit. If there is a
conflict between these permit conditions and an emission unit-specific permit condition, the specific
permit condition governs. Concentration-based emission limits required to be corrected to a specific
oxygen concentration in the flue gas often do not contain a protocol to convert measured concentrations to
specified oxygen levels. Permit Condition 3.28 provides a protocol for such a conversion.
Permit Condition 3.31 describes general recordkeeping that has been added to the permit using Part 71
authority to assure that there is good documentation for any monitoring that the permittee performs.
Permit Condition 3.32 describes recordkeeping requirements that apply only if the permittee makes off-
permit changes. Certain off-permit changes are allowed in Permit Condition 2.12.
Permit Condition 3.33 describe recordkeeping requirements that apply if the permittee performs open
burning. The open burning recordkeeping was added using Part 71 authority. Open burning is restricted in
Permit Conditions 3.4 through 3.8.
Permit Condition 3.34 includes recordkeeping that applies to fee records including the duration that the
records must be maintained. The duration is consistent with that required by Title V (see Permit
Condition 3.35).
Permit Condition 3.35 sets the duration that records must be maintained. Both Title V and FARR records
must be maintained for five years. These two requirements have been combined (streamlined) into one
permit condition. If there is ever a conflict between these requirements and a more restrictive emission
unit-specific permit condition, the specific permit condition governs.
Permit Conditions 3.36 and 3.37 require the permittee to submit or correct submitted information when
requested by EPA and as needed. The permittee has an ongoing obligation to assure that all data in its
Title V application is correct and to notify EPA of any errors or omissions. This includes notifying
Region 10 if the application no longer reflects the type of fuel actually being fired in a combustion unit.
An address for submitting application correction directly to Region 10's air permitting program is
included in this condition.
Permit Condition 3.38 and 3.39 describe reporting requirements that apply only if the permittee makes
off-permit changes (Permit Condition 3.38) or section 502(b) (10) changes (Permit Condition 3.39).
Certain off-permit changes are allowed in Permit Condition 2.12. Section 502(b) (10) changes are allowed
in Permit Conditions 2.13.
Permit Condition 3.40 includes the address for submittals to Region 10 and to the Tribe. All reports and
notices, except for fee payments (see Permit Condition 3.43), Part 71 permit applications (see Permit
Condition 3.51) and Part 71 permit application corrections (see Permit Condition 3.37), must be sent to
this address with a copy sent to the Tribe.
Permit Conditions 3.41 through 3.45 require submittal of an annual emission inventory (of actual
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emissions) and payment of fees for Part 71 purposes. These requirements refer to Permit Condition 4.1 for
the actual due date by which fees and emissions must be submitted each year. The per-ton fee rate varies
each year; contact EPA to obtain the current rate. The submittal of the emission inventory is timed to
coincide with the payment of fees because annual Title V fees are based on actual emissions generated
during the previous calendar year. Appendix A to this statement of basis documents the methods,
techniques, and assumptions that EPA believes provide the most accurate basis for estimating actual
emissions for this facility. As explained in Section 3.2 of this statement of basis, Region 10 expects the
emission estimation techniques listed in this statement of basis to be used to calculate the annual
emissions inventory, unless the permittee has other information showing why another technique more
accurately represents emissions. Also note that the actual emission estimates differ from the facility's
PTE because actual emission are calculated based on actual operations, not maximum operational
capacity.
Note that the FARR emission inventory required in Permit Condition 3.46 to be reported at the same time
can be combined with the Part 71 emission inventory as long as it is clear which emissions inventory is
for which purpose, because the pollutant lists for each emission inventory are slightly different.
Permit Condition 3.46 requires submittal of an annual emission inventory (of actual emissions) for FARR
registration purposes. Appendix A to this statement of basis documents the methods, techniques, and
assumptions that EPA believes provide the most accurate basis for estimating actual emissions for this
facility. As explained in Section 3.2 of this statement of basis, Region 10 expects the emission estimation
techniques listed in this statement of basis to be used to calculate the annual emissions inventory, unless
the permittee has other information showing why another technique more accurately represents emissions.
Also note that the actual emission estimates differ from the facility's PTE because actual emission are
calculated based on actual operations, not maximum operational capacity.
Note that the FARR emission inventory is required to be submitted at the same time as the Part 71 fees
and emission inventory required in Permit Conditions 3.41 through 3.45. The Part 71 and FARR emission
inventories can be combined as long as it is clear which emissions inventory is for which purpose,
because the pollutant lists for each emission inventory are slightly different.
Permit Conditions 3.47 and 3.48 require semi-annual monitoring reports and prompt deviation reports.
Determinations of deviations, continuous or intermittent compliance status, or violations of the permit are
not limited to the testing or monitoring methods required by the underlying regulations or this permit.
Failure to meet any permit term or permit condition, including emission standards, is considered a
deviation. Other credible evidence (including any evidence admissible under the federal rules of
evidence) must be considered by the source and EPA in such determinations. The timing for reporting
deviations, as well as other data collected, depends on the circumstances, as explained in these permit
conditions.
Permit Condition 3.49 requires an annual compliance certification. The permittee must certify compliance
with the permit conditions in sections 3 through 13. The permittee does not need to annually certify
compliance with the provisions in permit sections 1 or 2. Consistent with Permit Condition 2.6, however,
if a permittee is aware of any information that indicates noncompliance, that information must be
included in the annual compliance certification. In a year when the permit is renewed or revised, the
permittee must address each permit for the time that permit was in effect. Forms for the annual
compliance certifications may be obtained on the internet at https://www.epa.gov/title-v-operating-
permits/epa-issued-operating-permits.
Permit Condition 3.50 requires the permittee to certify the truth, accuracy and completeness of all
documents (notices, reports, data, and etc) submitted to EPA. The certification must be signed by a
responsible official as defined in 40 CFR 71.2. The facility's responsible officials are listed on the first
page of the permit. The permittee must request an administrative amendment of the permit if the
responsible official for the facility changes.
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Permit Conditions 3.51 and 3.52 require the permittee to submit an application for renewal and describe
some of the information that must be included in the application. As explained in Permit Conditions 2.9
through 2.11, failure to submit a complete application on time terminates the permittee's right to operate.
The expiration date of the permit is listed on the top right-hand corner of the front page of the permit. An
address for submitting the renewal application directly to Region 10's air permitting program is included
in Permit Condition 3.51.
Permit Section 4 - Facility-Specific Requirements
This permit section includes applicable requirements and related testing, monitoring, recordkeeping and
reporting that apply either to multiple emission units or on a facility-specific basis. Unless otherwise
specified, emission units are subject to the facility-specific requirements in Section 4 of the permit as well
as the general and unit-specific requirements in Sections 3, 5 and 6 of the permit.
Permit Conditions 4.1 lists the due date for the annual fees and emission reports required in Permit
Conditions 3.41 through 3.46.
Permit Condition 4.2 restricts Northwest Pipeline to combusting only natural gas in all emission units.
Permit Conditions 4.3 and 4.4 limit the sulfur content of the natural gas fuel burned in any combustion
device, specify the method for determining compliance and specify the monitoring and recordkeeping.
Permit Condition 4.5 limits the sulfur dioxide (SO2) emissions from each of the combustion devices at the
facility (four gas compressor engines, one backup generator, one boiler and one fuel heater). As these
devices are all fired on natural gas, SO2 emissions are expected to be well below the emission limit. As an
example, assuming the maximum fuel sulfur content allowed (see Permit Condition 4.3), SO2
concentration is calculated as follows:
SO2 concentration =
(max fuel S) x (SO2 conversion) x (SO2 molar volume)
(f-factor) x (fuel heat content) x SO2 molar weight)
= 0.0000856 x 2 x 385xl06 x lxlO6
13096 x 1020x64
= 77 ppmv at 7 %02
where:
max fuel S
SO2 conversion
SO2 molar volume:
f-factor
fuel heat content
SO2 molar weight
conversion factor
(1.1 g/cm) / (454 g/lb) / (28.32 cf/cm) = 0.0000856 lbS/dscf, from 40
CFR 49.130
2 lbSCVlbS
385xl06 dscf/lbm
(8710) x (21%) / (21%-7%) = 13096 dscf/mmBtu at 7 %02, from 40
CFR 60, Appendix A, Method 19, Table 19-2
1020 Btu/dscf, from AP-42, Section 1.4
64 lbSCVlbm
lxlO6 parts per million parts
As shown in the calculations above, the maximum potential SO2 concentration from a combustion device,
based on the regulatory limit (40 CFR 49.130) of 1.1 grams of sulfur per dry standard cubic meter, is 77
ppmv, which is less than the FARR regulatory limit of 500 ppmv. Therefore, compliance is reasonably
assured through compliance with the fuel sulfur limit in 40 CFR 49.130. The records required to
document that natural gas is being combusted (see Permit Condition 4.4) should also assure compliance.
Permit Condition 4.6 limits the particulate matter (PM) emissions from each of the combustion devices at
the facility (four gas compressor engines, one backup generator, one boiler and one fuel heater). As these
devices are all fired on natural gas, particulate matter emissions are expected to be well below the FARR
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standard. As an example, using the worst case emission factor (EF) for any combustion unit (gas
compressors have highest EF per heat input), particulate matter concentration is calculated as follows:
PM concentration = (EF) x (conversion factor)
(f-factor)
= 0.0483x7000
13096
= 0.026 gr/dscf at 7% O2
where:
EF = 0.0483 lb/mmBtu, from Table 3.2-1, AP-42, July 2000.
conversion factor = 7000 grains/lb
f-factor = (8710) x (21 %) / (21 %-7%) = 13096 dscf/mmBtu at 7% 02, from 40
CFR 60, Appendix A, Method 19, Table 19-2
As shown in the calculations above, the maximum potential PM concentration from combustion of natural
gas is expected to be approximately 0.026 gr/dscf at 7% O2, which is much lower than the applicable
FARR regulatory limit of 0.1 gr/dscf at 7% O2. Because of this margin of compliance, additional
monitoring is not required in this permit. The records required to document that natural gas is being
combusted (see Permit Condition 4.3) should also assure compliance.
Permit Conditions 4.7 through 4.13 require a quarterly survey (also called a plant walkthrough) for visible
and fugitive emissions as well as specific follow-up steps (investigation, corrective action, RM9
observation and additional recordkeeping and reporting) if visible or fugitive emissions are observed. If
observed visible or fugitive emissions cannot be eliminated within 24 hours, a tiered sequence of RM9
opacity determinations must be performed beginning with an initial 30-minute period of readings every
15 seconds. The frequency (e.g. daily or weekly) for conducting follow-up RM9 opacity readings is based
upon whether any 6-minute average opacity exceeds 20%. Observations of visible or fugitive emissions
during a survey are not considered deviations; however, any resulting RM9 6-minute average opacity
determination above 20% is considered a permit deviation pursuant to Permit Conditions 3.47 and 3.48.
The annual fugitive particulate matter survey required in Permit Condition 3.13 can be accomplished
simultaneously with a quarterly survey required in this permit condition as long as both requirements are
fully complied with. Not every emission generating activity is a potential source of fugitive dust or visible
emissions. For example, Unit #11 (oil storage tanks) are not potential sources of fugitive dust or visible
particulate matter emissions. Permit Condition 4.7, written slightly different from previous renewal
Permit No. R10T5110100, clarifies that the plant walkthrough requirement only applies to emission
generating activities that are a potential source of fugitive dust or visible emissions.
This permit condition serves as the periodic monitoring for several fugitive and particulate matter limits
found in the permit. This requirement applies to emission sources that normally do not exhibit visible or
fugitive emissions. If the permittee prefers a specific periodic monitoring approach for any emission
sources subject to this requirement, the permittee can propose a new approach as a permit modification.
Permit Conditions 4.14 and 4.15. have been include in the permit because a December 2002 change to the
PSD regulation applicability test for modifications resulted in a new applicable requirement for PSD
major sources. In summary, when the permittee considers a plant modification project to be exempt from
PSD via the method specified in 40 CFR 52.21 (b) (41) (ii) (a) through (c) and there is a reasonable
possibility that there will be a significant emissions increase resulting from the project, then the permittee
must fulfill specified requirements related to documentation, monitoring, and notification. This
requirement will be relevant to the facility only when the permittee is contemplating making physical or
operational changes to the facility. In those instances, it is strongly recommended that the permittee
contact Region 10 to discuss their plans and verify their assumptions.
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Permit Conditions 4.16 through 4.19 are generally applicable requirements that apply to the facility's
emission units subject to a NESHAP; emergency backup RICE (Unit #5) and the boiler and fuel gas
heater (Units #6 and 7). Permit Condition 4.17, written slightly different from previous renewal Permit
No. R10T5110100, clarifies that the on-site data retention requirement does not apply to Unit #5 pursuant
to 40 CFR 63.6665 and Table 8 to Subpart ZZZZ of Part 63.
Permit Section 5 - Unit-Specific Requirements - NESHAP Subpart ZZZZ for Unit #5 (Emergency
Generator Engine)
Permit Conditions 5.1 through 5.11 are MACT ZZZZ requirements to properly operate and maintain an
emergency stationary RICE. If the permittee does not operate the engine according to the requirements in
40 CFR 63.6640(f)(1) through (4), the engine will not be considered an emergency engine under
NESHAP Subpart ZZZZ and must meet all requirements for non-emergency engines. There is no time
limit on the use of the engine in emergency situations.
Permit Conditions 5.12 through 5.15 are MACT ZZZZ monitoring and recordkeeping requirements.
Northwest Pipeline is required to track hours of operation, and this provides Northwest Pipeline with
information useful to calculate its actual emissions.
Permit Conditions 5.16 through 5.19 are MACT ZZZZ reporting requirements. With issuance of this Title
V permit, EPA is specifying when certain MACT ZZZZ reports must be submitted.
Permit Section 6 - Unit-Specific Requirements - NESHAP Subpart DDDDD for Units #6 (Boiler)
and 7 (Process Heater)
Permit Condition 6.1 requires tune-ups of the Units #6 and 7 every five years (no later than 61 months
from previous tune-up) and specifies what must be included in the tune-ups. The date of the latest tune-up
conducted on Unit #6 is November 12, 2015. The date of the latest tune-up conducted on Unit #7 is
December 15, 2015. The next tune-up for Unit #6 and 7 shall be conducted no later than December 31,
2020 and January 31, 2021, respectively. If the unit is not operating on its scheduled tune-up due date
noted above, the tune-up must be conducted within 30 calendar days of the day it first operates after the
scheduled tune-up due date.
Permit Condition 6.2 is the general NESHAP requirement to employ good air pollution control practices
that was written specifically for boilers and process heaters subject to the major source MACT.
Permit Condition 6.3 specifies the records that must be maintained consistent with Condition 4.17.
Conditions 6.3 and 4.17 should be read together. Condition 6.3.5 clarifies that records only have to be
kept onsite for the first two of the required five years.
Permit Condition 6.4 requires annual compliance reports and describes the contents of the reports and
technique for submittal. For a tune-up completed in 2020, the associated compliance report must be
postmarked or submitted by January 31, 2021. For a tune-up completed in 2021, the associated
compliance report must be postmarked or submitted by January 31, 2022. Unlike the previous renewal
permit, this renewal requires the compliance report to contain the following information that is already
required to be recorded pursuant to 40 CFR 63.7540(a)(10)(vi):
• The concentrations of CO in the effluent stream in parts per million by volume, and
oxygen in volume percent, measured at high fire or typical operating load, before and
after the tune-up of the boiler; and
• A description of any corrective actions taken as a part of the tune-up.
Permit Condition 6.5 requires notification when switching fuels.
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5.2 Obsolete Permit Conditions from Expiring Permit No. R10T5110100
Northwest Pipeline has satisfied several one-time NESHAP requirements since issuance of previous
renewal Permit No. R10T5110100 on September 30, 2015. The requirements are no longer relevant to the
operation of the source. In other words, the requirements are obsolete. These requirements are not being
carried forward in the proposed renewal Permit No. R10T5110200. Each obsolete permit condition from
Permit No. R10T5110100 is generally explained below.
Permit Condition 4.19 required the permittee to submit a notification of compliance status (NOCS) with
respect to NESHAP Subpart DDDDD for Units #6 and 7. The permittee fulfilled this requirement when
the EPA received Northwest Pipeline's NESHAP Subpart DDDDD NOCS on February 26, 2016. This
requirement did not apply to Unit #5 as the permittee would have already been required (if applicable) to
submit a NOCS prior to issuance of Permit No. R10T5110100 on September 30, 2015. The MACT ZZZZ
compliance date was May 3, 2013.
Permit Condition 5.16.2 required, in part, the first NESHAP ZZZZ annual report be submitted no later
than March 31, 2016. The EPA could not find a report documenting this submittal for calendar year 2015.
The agency assumes that the engine must not have operated for more than 15 hours for the purposes
specified in Permit Conditions 5.7.2 and 5.7.3.
Permit Conditions 6.1.1 and 6.1.2 required, in part, the initial tune-up of Units #6 and 7 be conducted no
later than January 31, 2016 (or not later than 30 days after re-start of that unit if not operated between
January 31, 2013 and January 31, 2016). The permittee provided evidence of having satisfied this
requirement in a NESHAP Subpart DDDDD NOCS received on February 26, 2016.Permit Condition 6.2
required the permittee to conduct a one-time energy assessment of Units #6 and 7 (and major energy use
systems consuming energy from the units) no later than January 31, 2016. The permittee provided
evidence of having satisfied this requirement in a NESHAP Subpart DDDDD NOCS received on
February 26, 2016. According to the NOCS, Sage Environmental Consulting was contracted to conduct
the Energy Assessment and transmitted the energy assessment to Northwest Pipeline on September 9,
2015.
Permit Condition 6.5 required the permittee to submit a NESHAP Subpart DDDDD NOCS for Units #6
and 7. As stated above, EPA received from the permittee a NESHAP Subpart DDDDD NOCS on
February 26, 2016.
Permit Condition 6.6.1 required the permittee to submit the first NESHAP Subpart DDDDD annual
compliance report covering the time period of January 31, 2016 to December 31, 2016. This first report
was due on January 31, 2017. The permittee submitted this report on January 31, 2020. According to the
permittee, there were no deviations from the requirements for work practice standards during the reported
period.
6. Public Participation
6.1 Public Notice and Comment
As required in 40 CFR 71.11(a)(5) and 71.8, all draft operating permits must be publicly noticed and
made available for public comment. The public notice of permit actions and public comment period is
described in 40 CFR 71.11(d). There is a 30 day public comment period for actions pertaining to a draft
permit. For this permit action, the requirements of 40 CFR 71.11 (a) (5) and 71.8 will be satisfied as
follows:
1. Posting the public notice, draft permit, statement of basis and the draft administrative record
(which includes the application and relevant supporting materials) on EPA's website for the
duration of the public comment period.
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2. Providing a copy of the public notice to: the permit applicant, the affected states, the air pollution
control agencies of affected states, the Tribal, city and county executives, any comprehensive
land use planning agency, any state or federal land manager whose lands may be affected by
emissions from the source, the local emergency planning authorities which have jurisdiction over
the area where the source is located and all persons who submitted a written request to be
included on the EPA's mailing list for Title V permitting actions.
6.2 Response to Public Comments and Permit Issuance
As required in 40 CFR 71.11 (e), the EPA will consider all timely comments received when making a final
decision. The EPA's response to any comments received during the public comment period or public
hearing held for this permit will be addressed in this section of the final statement of basis. As required in
40 CFR 71.11 (i), the EPA will notify the applicant and each person who submits comments or requested
notice of the final permit decision.
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Appendix A
EPA Estimation of Northwest Pipeline
Pocatello Compressor Station
Potential Air Pollutant Emissions
Statement of Basis
Title V Air Quality Operating Permit Renewal #2
R10T5110200
Pocatello, Idaho
Page 61 of 270
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Appendix A: Potential Emissions Inventory
Summary of Facility Non-HAP Potential Emissions
Non-Fugitive Emissions1 (tons per year)
EU-1.2&3
ELM
EU-5
EU-6
EU-7
EU-8
EU-9
EU-10
EU-11
Non-
Fugitive
Subtotal
Three Clark
TLA-6 RICE
Clark TCV-10
RICE
Caterpillar
3408 RICE
Backup
Generator
Sellers Boiler
Sivallis Fuel
Gas Heater
Heaters and
Furnaces
System
Blowdown
Gas
Equipment
Leaks
Liquid Storage
Tanks
Carbon Monoxide (CO)
67.3
33.0
3.5
1.3
0.2
0.4
106
Hydrogen Sulfide (H2S)
0.01
0
Lead (Pb)
9.5E-05
4.7E-05
4.6E-07
7.5E-06
1.1E-06
2.5E-06
8.8E-08
0
Nitrogen Oxides (NOx)
730.0
357.5
2.1
1.5
0.2
0.5
1,092
Particulate (PM)2
7.5
3.7
0.01
0.03
0.004
0.01
11
Inhalable Coarse Particulate (PM10)
9.4
4.5
0.02
0.1
0.02
0.04
14
Fine Particulate (PM2 5)
9.4
4.5
0.02
0.1
0.02
0.04
14
Sulfur Dioxide (S02)
10.6
5.2
0.1
0.8
0.1
0.3
17
Volatile Organic Compounds (VOC)
21.8
10.7
0.03
0.1
0.01
0.03
0.2
0.4
33
Greenhouse Gas (C02e)
22,772
11,152
110
1,803
256
605
178
36,876
Fugitive Emissions, (tons per year)
EU-1.2&3
ELM
EU-5
EU-6
EU-7
EU-8
EU-9
EU-10
EU-11
Fugitive
Subtotal
Three Clark
TLA-6 RICE
Clark TCV-10
RICE
Caterpillar
3408 RICE
Backup
Generator
Sellers Boiler
Sivallis Fuel
Gas Heater
Heaters and
Furnaces
System
Blowdown
Gas
Equipment
Leaks
Liquid Storage
Tanks
Carbon Monoxide (CO)
0
Hydrogen Sulfide (H2S)
0.01
0
Lead (Pb)
8.8E-08
0
Nitrogen Oxides (NOx)
0
Particulate (PM)2
0
Inhalable Coarse Particulate (PM10)
0
Fine Particulate (PM2 5)
0
Sulfur Dioxide (S02)
0
Volatile Organic Compounds (VOC)
0.2
0
Greenhouse Gas (C02e)
178
178
Total Non-Fugitive and Fugitive Emissions, (tons per year)
EU-1.2&3
ELM
EU-5
EU-6
EU-7
EU-8
EU-9
EU-10
EU-11
Plantwide
PTE
Three Clark
TLA-6 RICE
Clark TCV-10
RICE
Caterpillar
3408 RICE
Backup
Generator
Sellers Boiler
Sivallis Fuel
Gas Heater
Heaters and
Furnaces
System
Blowdown
Gas
Equipment
Leaks
Liquid Storage
Tanks
Carbon Monoxide (CO)
67.3
33.0
3.5
1.3
0.2
0.4
106
Hydrogen Sulfide (H2S)
0.01
0.01
0
Lead (Pb)
9.5E-05
4.7E-05
4.6E-07
7.5E-06
1.1E-06
2.5E-06
8.8E-08
8.8E-08
0
Nitrogen Oxides (NOx)
730.0
357.5
2.1
1.5
0.2
0.5
1,092
Particulate (PM)2
7.5
3.7
0.01
0.03
0.004
0.01
11
Inhalable Coarse Particulate (PM10)
9.4
4.5
0.02
0.1
0.02
0.04
14
Fine Particulate (PM2 5)
9.4
4.5
0.02
0.1
0.02
0.04
14
Sulfur Dioxide (S02)
10.6
5.2
0.1
0.8
0.1
0.3
17
Volatile Organic Compounds (VOC)
21.8
10.7
0.03
0.1
0.01
0.03
0.2
0.2
0.4
33
Greenhouse Gas (C02e)
22,772
11,152
110
1,803
256
605
178
178
37,054
Notes:
1 Only non-fugitive emissions are considered for this facility in determining Title V applicability given that it is a natural gas compressor station and not one of the 27 listed source categories
required to consider fugitive emissions. See definition of "major source" at 40 CFR § 71.2.
2 PM is not a pollutant considered in determining whether a source is subject to the requirement to obtain a Title V permit; however, PM emissions are considered in determining whether a
facility/project is a major PSD source/modification and whether a source is subject to compliance assurance monitoring.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 62 of 270
Page A-2 of A-18
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Appendix A: Potential Emissions Inventory
Summary of Facility HAP Potential to Emit
Total Non-Fugitive and Fugitive Emissions, (tons per year)
EU-1.2&3
EU-4
EU-5
EU-6
EU-7
EU-8
EU-9
EU-10
EU-11
Hazardous Air Pollutants (HAP)
Three Clark TLA-6
RICE
One Clark TCV-10
RICE
One Caterpillar
3408 RICE
Backup Generator
Sellers Boiler
Sivallis Fuel
Gas Heater
Heaters and
Furnaces
System
Blowdown Gas
Equipment
Leaks
Liquid Storage
Tanks
Single HAP
Plantwide Totals
Trace Metal Compounds
Arsenic Compounds
3.81 E-05
1.87E-05
1.84E-07
3.02E-06
4.29E-07
1.01 E-06
6.1 E-05
Beryllium Compounds
2.29E-06
1.12E-06
1.11 E-08
1.81E-07
2.58E-08
6.08E-08
3.7E-06
Cadmium Compounds
2.10E-04
1.03E-04
1.01 E-06
1.66E-05
2.36E-06
5.57E-06
3.4E-04
Chromium Compounds (including hexavalent)
2.67E-04
1.31 E-04
1.29E-06
2.11 E-05
3.01 E-06
7.09E-06
4.3E-04
Cobalt Compounds
1.60E-05
7.84E-06
7.74E-08
1.27E-06
1.80E-07
4.25E-07
2.6E-05
Manganese Compounds
7.25E-05
3.55E-05
3.50E-07
5.74E-06
8.16E-07
1.92E-06
1.2E-04
Mercury Compounds
4.96E-05
2.43E-05
2.40E-07
3.92E-06
5.58E-07
1.32E-06
8.0E-05
Nickel Compounds
4.00E-04
1.96E-04
1.94E-06
3.17E-05
4.51 E-06
1.06E-05
6.5E-04
Selenium Compounds
4.58E-06
2.24E-06
2.21 E-08
3.62E-07
5.15E-08
1.22E-07
7.4E-06
Organic Compounds
1,1,2,2-Tetrachlorethane
1.29E-02
6.31 E-03
2.38E-05
1.9E-02
1,1,2-Trichloroethane
1.02E-02
5.02E-03
1.44E-04
1.5E-02
1,3-Butadiene
1.59E-01
7.81 E-02
6.23E-04
2.4E-01
1,3-Dichloropropene
8.52E-02
4.17E-02
1.19E-05
1.3E-01
2,2,4-Trimethylpentane
1.65E-01
8.06E-02
2.5E-01
Acetaldehyde
1.51E+00
7.39E-01
2.62E-03
2.3E+00
Acrolein
1.51E+00
7.41 E-01
2.47E-03
2.3E+00
Benzene
3.77E-01
1.85E-01
1.49E-03
3.17E-05
4.51 E-06
1.06E-05
5.6E-01
Biphenyl
7.68E-04
3.76E-04
1.1 E-03
Carbon Tetrachloride
1.18E-02
5.78E-03
1.66E-05
1.8E-02
Chlorobenzene
8.63E-03
4.23E-03
1.21 E-05
1.3E-02
Chloroform
9.16E-03
4.49E-03
1.29E-05
1.4E-02
Dichlorobenzene
1.81 E-05
2.58E-06
6.08E-06
2.7E-05
Ethylbenzene
2.10E-02
1.03E-02
2.33E-05
3.1 E-02
Ethylene Dibromide
1.43E-02
6.99E-03
2.00E-05
2.1 E-02
Formaldehyde
1.07E+01
5.26E+00
1.93E-02
1.13E-03
1.61 E-04
3.80E-04
1.6E+01
Methanol
4.82E-01
2.36E-01
2.88E-03
7.2E-01
Methylene Chloride
2.86E-02
1.40E-02
3.87E-05
4.3E-02
n-Hexane
8.65E-02
4.24E-02
1.13E-03
1.61 E-04
9.11 E-03
5.58E-03
5.58E-03
1.5E-01
Naphthalene1
1.87E-02
9.17E-03
9.13E-05
9.21 E-06
1.31 E-06
3.09E-06
2.8E-02
Phenol
8.19E-03
4.01 E-03
1.2E-02
Polycyclic Organic Matter (POM)2
6.28E-02
3.07E-02
1.33E-04
1.05E-05
1.50E-06
3.54E-06
9.4E-02
Styrene
1.07E-02
5.22E-03
1.12E-05
1.6E-02
Toluene
1.87E-01
9.17E-02
5.25E-04
5.13E-05
7.30E-06
1.72E-05
2.8E-01
Vinyl Chloride
4.80E-03
2.35E-03
6.75E-06
7.2E-03
Xylene
5.21 E-02
2.55E-02
1.83E-04
7.8E-02
TOTAL2
15.6
7.6
0.03
0.002
0.0003
0.01
0.01
0.01
0
Predicted Highest Plantwide Single HAP
Predicted Plantwide HAP Total
16.0
23.2
tons per year, formaldehyde
tons per year, based on summing estimates
1 designates a HAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds that, in aggregate, are subject to the same 10 tpy major source
threshold.
2 Because naphthalene is accounted for individually and in the calculation of POM EF, its individual contribution here is discounted so as to avoid double-counting.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 63 of 270
Page A-3 of A-18
-------
Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Emission Unit
Description
Control Device
Fuel
Installation Date
Design Maximum Output Capacity
Design Maximum Heat Input Capcity
Operation
NON-FUGITIVE EMISSIONS
EU-1, 2 and 3
Clark TLA-6 Reciprocating IC Compressor Engines, two-stroke, lean-burn, spark ignition
none
natural gas
1956
2,000 horsepower at 300 rpm
14.8 MMBtu/hr
8760 hours per year
Per Engine
All Three Engines
Criteria Pollutant Emissions
EF
PTE
PTE
EF Reference
(Ib/MMBtu)
(tPY)
(tPY)
Carbon Monoxide (CO)
0.346
22.4
67.3
1
Lead (Pb)
4.90E-07
0.00003
0.0001
2
Nitrogen Oxides (NOx)
3.754
243.3
730.0
1
Particulate (PM)
0.0384
2.5
7.5
3
Inhalable Coarse Particulate (PM10)
0.0483
3.1
9.4
3
Fine Particulate (PM2 5)
0.0483
3.1
9.4
3
Sulfur Dioxide (S02)
0.0544
3.5
10.6
4
Volatile Organic Compounds (VOC)
0.112
7.3
21.8
1
NON-FUGITIVE EMISSIONS
Per Engine
All Three Engines
Greenhouse Gas Emissions
(C02 Equivalent)
EF
(Ib/MMBtu)
PTE
(tpy)
PTE
(tpy)
EF Reference
Carbon Dioxide (C02)
116.977
7582.9
22748.8
5
Methane (CFI4)
0.055
3.6
10.7
5
Nitrous Oxide (N20)
0.066
4.3
12.8
5
TOTAL
7,591
22,772
EF Reference
Description
1
EU-1 performance test conducted June 11, 1998 at full load (~100%) and reduced load (~85%). Emission factors employed in this PTE El are worst-case (i.e. NOx
and VOC at full load and CO at reduced load.
2
Table 1.4-2 of AP-42, July 1998. EF (Ib/MMBtu) = (0.0005 lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
3
Table 3.2-1 of AP-42, July 2000. Filterable PM (< 1nm) = 3.84x10"2 Ib/MMBtu. Condensible PM ~ 9.91x103 Ib/MMBtu. PM EF equal to filterable portion. PM10 and
PM2 5 EF equal to sum of both; 0.0483 Ib/MMBtu. EPA did not employ the applicable FARR PM limit to calculate potential emissions because the resultant 0.1871
Ib/MMBtu PM EF is unrealistic for a natural gas fired engine. The calculation to derive the 0.1871 Ib/MMBtu PM EF is as follows:
Basis: FARR combustion source stack PM emission limit of 0.1 gr/dscf corrected to 7% 02 at 40 CFR 49.125(d)(1)
EF (Ib/MMBtu) = FARR PM Limit (gr/dscf@7%02) X CF7_^%02 X Fd (dscf/MMBtu) / CFgr^lb (gr/lb)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR PM
Calculated EF
(Ib/MMBtu)
FARR PM
Emission Limit
(gr/dscf @7%02)
CF 7—>0%O2
(unitless)
Fd
(dscf/MMBtu)
CF gr^|b
(gr/lb)
0.1871
0.1
1.504
8,710
7,000
Option 1: 0.0544 Ib/MMBtu. This emission factor is employed to determine PTE as it limits emissions to less than Option 2 or 3 below.
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (Ib/MMBtu) = Pipeline tariff S Limit (gr/100 ft3) / CF100ft3^Btu X CFBtu^MMBtu / CFgr^,b X CFS^S02
• CFS^S02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 105000 Btu/100 ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
Pipeline Tariff
Calculate S02 EF
(Ib/MMBtu)
Pipeline Tariff
Fuel Sulfur Limit
(qr/100 ft3)
CFft3^Btu
(Btu/100 ft3)
CF BtU_>MMBtu
(Btu/MMBtu)
CFgr^|b
(gr/lb)
CFs^so2
(lb S02/lb S)
0.0544
20
105000
1.E+06
7000
2
Option 2: 0.1308 Ib/MMBtu.
Basis: FARR gaseous fuel sulfur limit of 1.1 g/dry standard cubic meter at 40 CFR 49.130(d)(8)
EF (Ib/MMBtu) = FARR Fuel S Limit (g/m ) / CFm3_»ft3 / CFft3_>Btu X CFBtu->MMBtu! CFg_,.ib X CFs->so2
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 1050 Btu/ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
4
FARR Fuel S
Calculate S02 EF
(Ib/MMBtu)
FARR
Fuel Sulfur Limit
(g/rri3)
CF m3_>ft3
(ft3/m3)
CFft3^Btu
(Btu/ft3)
CFgtu—»MMBtu
(Btu/MMBtu)
CF g—b
(g/lb)
CF S—»S02
^iu JU2/IU
OA
0.1308
1.1
35.3147
1050
1.E+06
453.592
2
Option 3: 1.087 Ib/MMBtu.
Basis: FARR combustion source stack S02 emission limit of 500 parts per million by volume dry basis (ppmvd) corrected to 7% 02 at 40 CFR 49.129(d)(1)
EF (Ib/MMBtu) = FARR S02 Limit (ppmvd@7%02) X CF7^o»A02 X CFpprTW|b/dscfS02 X Fd (dscf/MMBtu)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• CFpprTW|b/dscfSo2 = 1 -660 X 10"7 lb S02/dscf / ppm S02. See Table 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR 500 ppm
Calculate S02 EF
(Ib/MMBtu)
FARR
JU2 L_l 1 IIS^IUI 1
1 im it
(ppmvd@7%02)
CF 7_>0%O2
(unitless)
C F ppm^| b/dscfS02
(lb/dscf / ppm)
Fd
(dscf/MMBtu)
1.087
500
1.504
1.66E-07
8710
EPA's March 2011 guidance document "PSD and Title V Permitting Guidance for Greenhouse Gases" states that the GFIG Report Rule (40 CFR 98), "should be
considered a primary reference for sources and permitting authorities in estimating GFIG emissions and establishing measurement techniques when preparing or
processing permit applications." Therefore, GFIG Reporting Rule emission factors will be employed to determine GFIG PTE.
Carbon Dioxide (CO?)
EF (lb C02e/MMBtu) = EF (kg C02/MMBtu) X CFkg^lb (lb/kg) X GWPC02 (lb C02e/lb C02)
Calculated C02e
EF for C02
(lb C02e/MMBtu)
40 CFR 98
Table C-1 EF
(kg C02/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb C02)
116.977
53.06
2.20462262
1
5
Methane (CFL)
EF (lb C02e/MMBtu) = EF (kg CH4/MMBtu) X CFkg^lb (lb/kg) X GWPCH4 (lb C02e/lb CH4)
Calculated C02e
E F for C Fl4
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg CH4/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb CH4)
0.055
0.001
2.20462262
25
Nitrous Oxide (N?0)
EF (lb C02e/MMBtu) = EF (kg N20/MMBtu) X CFkg^lb (lb/kg) X GWPN20 (lb C02e/lb N20)
Calculated C02e
EFfor N20
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg N20/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb N20)
0.066
0.0001
2.20462262
298
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 64 of 270
Page A-4 of A-18
-------
Appendix A: Potential Emissions Inventory
HAP Potential to Emit
Emission Unit: EU-1, 2 and 3
Description: Clark TLA-6 Reciprocating IC Compressor Engines, two-stroke, lean-burn, spark ignition
Control Device: none
Fuel: natural gas
Installation Date: 1956
Design Maximum Output Capacity: 2,000 horsepower at 300 rpm
Design Maximum Heat Input Capcity: 14.8 MMBtu/hr
Operation: 8760 hours per year
NON-FUGITIVE EMISSIONS
Per Engine
All Three Engines
Criteria Pollutant Emissions
EF
EF
PTE
PTE
(lb/1 x106 scf)
(Ib/MMBtu)
(tpy)
(tpy)
Trace Metal Compounds
Arsenic Compounds
2.0E-04
2.0E-07
1.27E-05
3.81 E-05
Beryllium Compounds
1.2E-05
1.2E-08
7.63E-07
2.29E-06
Cadmium Compounds
1.1E-03
1.1E-06
6.99E-05
2.10E-04
Chromium Compounds (including hexavalent)
1.4E-03
1.4E-06
8.90E-05
2.67E-04
Cobalt Compounds
8.4E-05
8.2E-08
5.34E-06
1.60E-05
Manganese Compounds
3.8E-04
3.7E-07
2.42E-05
7.25E-05
Mercury Compounds
2.6E-04
2.5E-07
1.65E-05
4.96E-05
Nickel Compounds
2.1E-03
2.1E-06
1.33E-04
4.00E-04
Selenium Compounds
2.4E-05
2.4E-08
1.53E-06
4.58E-06
Organic Compounds
1,1,2,2-Tetrachlorethane
6.63E-05
4.30E-03
1.29E-02
1,1,2-Trichloroethane
5.27E-05
3.42E-03
1.02E-02
1,3-Butadiene
8.20E-04
5.32E-02
1.59E-01
1,3-Dichloropropene
4.38E-04
2.84E-02
8.52E-02
2,2,4-Trimethylpentane
8.46E-04
5.48E-02
1.65E-01
Acetaldehyde
7.76E-03
5.03E-01
1.51E+00
Acrolein
7.78E-03
5.04E-01
1.51E+00
Benzene
1.94E-03
1.26E-01
3.77E-01
Biphenyl
3.95E-06
2.56E-04
7.68E-04
Carbon Tetrachloride
6.07E-05
3.93E-03
1.18E-02
Chlorobenzene
0)
4.44E-05
2.88E-03
8.63E-03
Chloroform
CO
0
4.71 E-05
3.05E-03
9.16E-03
Ethyl benzene
CL
CL
1.08E-04
7.00E-03
2.10E-02
Ethylene Dibromide
<
7.34E-05
4.76E-03
1.43E-02
Formaldehyde
-z.
5.52E-02
3.58E+00
1.07E+01
Methanol
2.48E-03
1.61E-01
4.82E-01
Methylene Chloride
1.47E-04
9.53E-03
2.86E-02
n-Hexane
4.45E-04
2.88E-02
8.65E-02
Naphthalene1
9.63E-05
6.24E-03
1.87E-02
Phenol
4.21 E-05
2.73E-03
8.19E-03
Polycyclic Organic Matter (POM)2
3.23E-04
2.09E-02
6.28E-02
Styrene
5.48E-05
3.55E-03
1.07E-02
Toluene
9.63E-04
6.24E-02
1.87E-01
Vinyl Chloride
2.47E-05
1.60E-03
4.80E-03
Xylene
2.68E-04
1.74E-02
5.21 E-02
TOTAL3 8.00E-02 5.2 15.6
1 Naphthalene is a HAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds
that, in aggregate, are subject to the same 10 tpy major source threshold.
2 See table below for list of individual polycyclic organic matter (POM) compounds. POM defines a broad class of compounds that generally includes all organic
structures having two or more fused aromatic rings (i.e., rings that share a common border), and that have a boiling point greater than or equal to 212°F (100°C).
See http://www.epa.g0v/ttn/atw/hlthef/polycycl.html#refl 1
3 Because naphthalene is accounted for individually and in the calculation of POM EF, its contribution here is discounted so as to avoid double-counting.
Trace Metal Compounds EF Basis: AP-42. Table 1.4-4. July 1998.
EF (Ib/MMBtu) = EF (Ib/1x106scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-4.
Or^ani£^om|3ounds=EF=Basisi^P=42Jable=^i2=2i=Jul^000i
POM Compounds
I I
(Ib/MMI'lu)
2-Methylnaphthalene
2.14E-04
Acenaphthene*
1.33E-06
Acenaphthylene*
3.17E-06
Anthracene*
7.18E-07
Benzo(a)anthracene*
3.36E-07
Benzo(a)pyrene*
5.68E-09
Benzo(b)fluoranthene*
8.51 E-09
Benzo(e)pyrene*
2.34E-08
Benzo(g,h,l)perylene*
2.48E-08
Benzo(k)fluoranthene*
4.26E-09
Chrysene*
6.72E-07
Fluoranthene*
3.61 E-07
Fluorene*
1.69E-06
lndeno(1,2,3-cd)pyrene*
9.93E-09
Naphthalene***
9.63E-05
Perylene
4.97E-09
Phenanthrene*
3.53E-06
Pyrene
5.84E-07
SUBTOTAL
3.23E-04
* designates a polycyclic aromatic hydrocarbon (PAH). PAHs are potent atmospheric pollutants that consist of fused aromatic rings and do not contain heteroatoms
or carry substituents. See http://en.wikipedia.Org/wiki/Polycyclic_aromatic_hydrocarbon#PAH_compounds
** designates a POM compound that is also an individual HAP.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 65 of 270
Page A-5 of A-18
-------
Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Emission Unit
Description
Control Device
Fuel
Installation Date
Design Maximum Output Capacity
Design Maximum Heat Input Capcity
Operation
NON-FUGITIVE EMISSIONS
EU-4
Clark TCV-10 Reciprocating IC Compressor Engines, two-stroke, lean-burn, spark ignition
none
natural gas
1969
3,400 horsepower at 300 rpm
21.743 MMBtu/hr
8760 hours per year
Criteria Pollutant Emissions
EF
(Ib/MMBtu)
PTE
(tPY)
EF Reference
Carbon Monoxide (CO)
0.346
33.0
1
Lead (Pb)
4.90E-07
0.00005
2
Nitrogen Oxides (NOx)
3.754
357.5
1
Particulate (PM)
0.0384
3.7
3
Inhalable Coarse Particulate (PM10)
0.0475
4.5
3
Fine Particulate (PM2 5)
0.0475
4.5
3
Sulfur Dioxide (S02)
0.0544
5.2
4
Volatile Organic Compounds (VOC)
0.112
10.7
1
NON-FUGITIVE EMISSIONS
Greenhouse Gas Emissions
(C02 Equivalent)
EF
(Ib/MMBtu)
PTE
(tpy)
EF Reference
Carbon Dioxide (C02)
116.977
11140.3
5
Methane (CFI4)
0.055
5.2
5
Nitrous Oxide (N20)
0.066
6.3
5
TOTAL
11,152
EF Reference
Description
1
EU-1 performance test conducted June 11, 1998 at full load (~100%) and reduced load (~85%). Emission factors employed in this PTE El are worst-case (i.e. NOx
and VOC at full load and CO at reduced load.
2
Table 1.4-2 of AP-42, July 1998. EF (Ib/MMBtu) = (0.0005 lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
3
Table 3.2-1 of AP-42, July 2000. Filterable PM (< 1nm) = 3.84x10"2 Ib/MMBtu. Condensible PM ~ 9.91x103 Ib/MMBtu. PM EF equal to filterable portion. PM10 and
PM2 5 EF equal to sum of both; 0.0483 Ib/MMBtu. EPA did not employ the applicable FARR PM limit to calculate potential emissions because the resultant 0.1871
Ib/MMBtu PM EF is unrealistic for a natural gas fired engine. The calculation to derive the 0.1871 Ib/MMBtu PM EF is as follows:
Basis: FARR combustion source stack PM emission limit of 0.1 gr/dscf corrected to 7% 02 at 40 CFR 49.125(d)(1)
EF (Ib/MMBtu) = FARR PM Limit (gr/dscf@7%02) X CF7_^%02 X Fd (dscf/MMBtu) / CFgr^lb (gr/lb)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR PM
Calculated EF
(Ib/MMBtu)
FARR PM
Emission Limit
(gr/dscf @7%02)
CF 7—>0%O2
(unitless)
Fd
(dscf/MMBtu)
CFgr^|b
(gr/lb)
0.1871
0.1
1.504
8,710
7,000
Option 1: 0.0544 Ib/MMBtu. This emission factor is employed to determine PTE as it limits emissions to less than Option 2 or 3 below.
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (Ib/MMBtu) = Pipeline tariff S Limit (gr/100 ft3) / CF100ft3^Btu X CFBtu^MMBtu / CFgr^,b X CFS^S02
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 105000 Btu/100 ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
Pipeline Tariff
Calculate S02 EF
(Ib/MMBtu)
Pipeline Tariff
Fuel Sulfur Limit
(qr/100 ft3)
CFft3^Btu
(Btu/100 ft3)
CFgtu->MMBtu
(Btu/MMBtu)
CFgr_>|b
(gr/lb)
CF S—»S02
(lb S02/lb S)
0.0544
20
105000
1.E+06
7000
2
Option 2: 0.1308 Ib/MMBtu.
Basis: FARR gaseous fuel sulfur limit of 1.1 g/dry standard cubic meter at 40 CFR 49.130(d)(8)
EF (Ib/MMBtu) = FARR Fuel S Limit (g/m ) / CFm3_»ft3 / CFft3_>Btu X CFBtu->MMBtu! CFg_,.ib X CFs->so2
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFft3^Btu = 1050 Btu/ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
4
FARR Fuel S
Calculate S02 EF
(Ib/MMBtu)
FARR
Fuel Sulfur Limit
(q/rri3)
CF m3_>ft3
(ft3/m3)
CFfo^etu
(Btu/ft3)
CF[3tu—>MMBtu
(Btu/MMBtu)
CFg^|b
(g/ib)
CFs^so2
(ju 0U2HU
C-N
0.1308
1.1
35.3147
1050
1.E+06
453.592
2
Option 3: 1.087 Ib/MMBtu.
Basis: FARR combustion source stack S02 emission limit of 500 parts per million by volume dry basis (ppmvd) corrected to 7% 02 at 40 CFR 49.129(d)(1)
EF (Ib/MMBtu) = FARR S02 Limit (ppmvd@7%02) X CF7^0%02 X CFpprTW|b/dscfSo2 X Fd (dscf/MMBtu)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
Xo2Fd = 0 ar|d X02farr = 7- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• CFpprTW|b/dscfSo2 = 1 -660 X 10"7 lb S02/dscf / ppm S02. See Table 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR 500 ppm
Calculate S02 EF
(Ib/MMBtu)
FARR
1— 1 1 1 I^OIWI 1
1 IfV* it
(ppmvd@7%02)
CF 7—»0%O2
(unitless)
C Fppm^i b/dscfS02
(lb/dscf / ppm)
Fd
(dscf/MMBtu)
1.087
500
1.504
1.66E-07
8710
EPA's March 2011 guidance document "PSD and Title V Permitting Guidance for Greenhouse Gases" states that the GFIG Report Rule (40 CFR 98), "should be
considered a primary reference for sources and permitting authorities in estimating GFIG emissions and establishing measurement techniques when preparing or
processing permit applications." Therefore, GFIG Reporting Rule emission factors will be employed to determine GFIG PTE.
Carbon Dioxide (CO-?)
EF (lb C02e/MMBtu) = EF (kg C02/MMBtu) X CFkg^lb (lb/kg) X GWPC02 (lb C02e/lb C02)
Calculated C02e
EF for C02
(lb C02e/MMBtu)
40 CFR 98
Table C-1 EF
(kg C02/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb C02)
116.977
53.06
2.20462262
1
5
Methane (CFL)
EF (lb C02e/MMBtu) = EF (kg CH4/MMBtu) X CFkg^lb (lb/kg) X GWPCH4 (lb C02e/lb CH4)
Calculated C02e
E F for C Fl4
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg CH4/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb CH4)
0.055
0.001
2.20462262
25
Nitrous Oxide (N?0)
EF (lb C02e/MMBtu) = EF (kg N20/MMBtu) X CFkg^lb (lb/kg) X GWPN20 (lb C02e/lb N20)
Calculated C02e
EFfor N20
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg N20/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb N20)
0.066
0.0001
2.20462262
298
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 66 of 270
Page A-6 of A-18
-------
Appendix A: Potential Emissions Inventory
HAP Potential to Emit
EU-4
Clark TCV-10 Reciprocating IC Compressor Engines, two-stroke, lean-burn, spark ignition
none
natural gas
1969
3,400 horsepower at 300 rpm
21.743 MMBtu/hr
8760 hours per year
NON-FUGITIVE EMISSIONS
Emission Unit:
Description:
Control Device:
Fuel:
Installation Date:
Design Maximum Output Capacity:
Design Maximum Heat Input Capcity:
Operation:
Criteria Pollutant Emissions
EF
(lb/1 x106 scf)
EF
(Ib/MMBtu)
PTE
(tpy)
Trace Metal Compounds
Arsenic Compounds
2.0E-04
2.0E-07
1.87E-05
Beryllium Compounds
1.2E-05
1.2E-08
1.12E-06
Cadmium Compounds
1.1 E-03
1.1E-06
1.03E-04
Chromium Compounds (including hexavalent)
1.4E-03
1.4E-06
1.31E-04
Cobalt Compounds
8.4E-05
8.2E-08
7.84E-06
Manganese Compounds
3.8E-04
3.7E-07
3.55E-05
Mercury Compounds
2.6E-04
2.5E-07
2.43E-05
Nickel Compounds
2.1 E-03
2.1E-06
1.96E-04
Selenium Compounds
2.4E-05
2.4E-08
2.24E-06
Organic Compounds
1,1,2,2-Tetrachlorethane
6.63E-05
6.31 E-03
1,1,2-Trichloroethane
5.27E-05
5.02E-03
1,3-Butadiene
8.20E-04
7.81 E-02
1,3-Dichloropropene
4.38E-04
4.17E-02
2,2,4-Trimethylpentane
8.46E-04
8.06E-02
Acetaldehyde
7.76E-03
7.39E-01
Acrolein
7.78E-03
7.41 E-01
Benzene
1.94E-03
1.85E-01
Biphenyl
3.95E-06
3.76E-04
Carbon Tetrachloride
6.07E-05
5.78E-03
Chlorobenzene
0)
4.44E-05
4.23E-03
Chloroform
CO
0
4.71 E-05
4.49E-03
Ethyl benzene
"q.
CL
1.08E-04
1.03E-02
Ethylene Dibromide
<
7.34E-05
6.99E-03
Formaldehyde
-Z.
5.52E-02
5.26E+00
Methanol
2.48E-03
2.36E-01
Methylene Chloride
1.47E-04
1.40E-02
n-Hexane
4.45E-04
4.24E-02
Naphthalene1
9.63E-05
9.17E-03
Phenol
4.21 E-05
4.01 E-03
Polycyclic Organic Matter (POM)2
3.23E-04
3.07E-02
Styrene
5.48E-05
5.22E-03
Toluene
9.63E-04
9.17E-02
Vinyl Chloride
2.47E-05
2.35E-03
Xylene
2.68E-04
2.55E-02
TOTAL3 8.00E-02 7.6
1 Naphthalene is a HAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds
that, in aggregate, are subject to the same 10 tpy major source threshold.
2 See table below for list of individual polycyclic organic matter (POM) compounds. POM defines a broad class of compounds that generally includes all organic
structures having two or more fused aromatic rings (i.e., rings that share a common border), and that have a boiling point greater than or equal to 212°F (100°C).
See http://www.epa.g0v/ttn/atw/hlthef/polycycl.html#refl 1
3 Because naphthalene is accounted for individually and in the calculation of POM EF, its contribution here is discounted so as to avoid double-counting.
Trace Metal Compounds EF Basis: AP-42. Table 1.4-4. July 1998.
EF (Ib/MMBtu) = EF (Ib/1x106scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-4.
Onuinic Compounds TT B;isis: AP 42. T;il>lo 3.2 1. Inly 2000.
POM Compounds
I I
(Ib/MMI'lu)
2-Methylnaphthalene
2.14E-04
Acenaphthene*
1.33E-06
Acenaphthylene*
3.17E-06
Anthracene*
7.18E-07
Benzo(a)anthracene*
3.36E-07
Benzo(a)pyrene*
5.68E-09
Benzo(b)fluoranthene*
8.51 E-09
Benzo(e)pyrene*
2.34E-08
Benzo(g,h,l)perylene*
2.48E-08
Benzo(k)fluoranthene*
4.26E-09
Chrysene*
6.72E-07
Fluoranthene*
3.61 E-07
Fluorene*
1.69E-06
lndeno(1,2,3-cd)pyrene*
9.93E-09
Naphthalene***
9.63E-05
Perylene
4.97E-09
Phenanthrene*
3.53E-06
Pyrene
5.84E-07
SUBTOTAL
3.23E-04
EF Basis: AP-42, Table 3.2-1, July 2000.
* designates a polycyclic aromatic hydrocarbon (PAH). PAHs are potent atmospheric pollutants that consist of fused aromatic rings and do not contain heteroatoms
or carry substituents. See http://en.wikipedia.Org/wiki/Polycyclic_aromatic_hydrocarbon#PAH_compounds
** designates a POM compound that is also an individual HAP.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 67 of 270
Page A-7 of A-18
-------
Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Control Device
Fuel
Installation Date
Design Maximum Output Capacity
Design Maximum Heat Input Capcity
Operation
Emission Unit: EU-5
Description: Caterpillar 3408 Backup Electrical Power Generator
Reciprocating IC Compressor Engine, four-stroke, rich-burn, spark ignition
none
natural gas
1998
400 horsepower
3.76 MMBtu/hr
500 hours per year1
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(Ib/MMBtu)
PTE
(tPV)
EF Reference
Carbon Monoxide (CO)
3.72
3.5
1
Lead (Pb)
4.90E-07
4.61 E-07
2
Nitrogen Oxides (NOx)
2.27
2.1
1
Particulate (PM)
0.0095
0.01
3
Inhalable Coarse Particulate (PM10)
0.01941
0.02
3
Fine Particulate (PM2 5)
0.01941
0.02
3
Sulfur Dioxide (S02)
0.0544
0.1
4
Volatile Organic Compounds (VOC)
0.0296
0.03
1
NON-FUGITIVE EMISSIONS
Greenhouse Gas Emissions
(C02 Equivalent)
EF
(Ib/MMBtu)
PTE
(tpy)
EF Reference
Carbon Dioxide (C02)
116.977
110.0
5
Methane (CFI4)
0.055
0.1
5
Nitrous Oxide (N20)
0.066
0.1
5
TOTAL 110
1 September 6, 1995 EPA memorandum entitled, "Calculating Potential to Emit (PTE) for Emergency Generators"
EF Reference
Description
1
Table 3.2-3 of AP-42, July 2000.
2
Table 1.4-2 of AP-42, July 1998. EF (Ib/MMBtu) = (0.0005 lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
3
Table 3.2-3 of AP-42, July 2000. Filterable PM (< 1nm) = 9.50x103 Ib/MMBtu. Condensible PM ~ 9.91x103 Ib/MMBtu. PM EF equal to filterable portion. PM10 and
PM2 5 EF equal to sum of both; 0.01941 Ib/MMBtu. EPA did not employ the applicable FARR PM limit to calculate potential emissions because the resultant 0.1871
Ib/MMBtu PM EF is unrealistic for a natural gas fired engine. The calculation to derive the 0.1871 Ib/MMBtu PM EF is as follows:
Basis: FARR combustion source stack PM emission limit of 0.1 gr/dscf corrected to 7% 02 at 40 CFR 49.125(d)(1)
EF (Ib/MMBtu) = FARR PM Limit (gr/dscf@7%02) X CF7^0%02 X Fd (dscf/MMBtu) / CFgr^lb (gr/lb)
• CF7_>o%02 = (20.9 - X02Fd) / (20.9 - X02FARR). To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR PM
Calculated EF
(Ib/MMBtu)
FARR PM
Emission Limit
(gr/dscf @7%02)
CF 7—>0%O2
(unitless)
Fd
(dscf/MMBtu)
CF gr^|b
(gr/lb)
0.1871
0.1
1.504
8,710
7,000
4
Option 1: 0.0544 Ib/MMBtu. This emission factor is employed to determine PTE as it limits emissions to less than Option 2 or 3 below.
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (Ib/MMBtu) = Pipeline tariff S Limit (gr/100 ft3) / CF100ft3^Btu X CFBtu^MMBtu / CFgr^,b X CFS^S02
• CFS^S02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 105000 Btu/100 ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
Pipeline Tariff
Calculate S02 EF
(Ib/MMBtu)
Pipeline Tariff
Fuel Sulfur Limit
(qr/100 ft3)
CFft3^Btu
(Btu/100 ft3)
CF BtU_>MMBtu
(Btu/MMBtu)
CFgr^|b
(gr/lb)
CFs^so2
(lb S02/lb S)
0.0544
20
105000
1.E+06
7000
2
Option 2: 0.1308 Ib/MMBtu.
Basis: FARR gaseous fuel sulfur limit of 1.1 g/dry standard cubic meter at 40 CFR 49.130(d)(8)
EF (Ib/MMBtu) = FARR Fuel S Limit (g/m ) / CFm3_»ft3 / CFft3_>Btu X CFBtu->MMBtu! CFg_,.ib X CFs->so2
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 1050 Btu/ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
FARR Fuel S
Calculate S02 EF
(Ib/MMBtu)
FARR
Fuel Sulfur Limit
(g/rri3)
CF m3_>ft3
(ft3/m3)
CFft3^Btu
(Btu/ft3)
CFgtu—»MMBtu
(Btu/MMBtu)
CF g—b
(g/lb)
CF S—»S02
^iu JU2/IU
OA
0.1308
1.1
35.3147
1050
1.E+06
453.592
2
Option 3: 1.087 Ib/MMBtu.
Basis: FARR combustion source stack S02 emission limit of 500 parts per million by volume dry basis (ppmvd) corrected to 7% 02 at 40 CFR 49.129(d)(1)
EF (Ib/MMBtu) = FARR S02 Limit (ppmvd@7%02) X CF7^o»A02 X CFpprTW|b/dscfS02 X Fd (dscf/MMBtu)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• CFpprTW|b/dscfSo2 = 1 -660 X 10"7 lb S02/dscf / ppm S02. See Table 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR 500 ppm
Calculate S02 EF
(Ib/MMBtu)
FARR
JU2 L_l 1 IIS^IUI 1
1 im it
(ppmvd@7%02)
CF 7_>0%O2
(unitless)
C F ppm^| b/dscfS02
(lb/dscf / ppm)
Fd
(dscf/MMBtu)
1.087
500
1.504
1.66E-07
8710
5
EPA's March 2011 guidance document "PSD and Title V Permitting Guidance for Greenhouse Gases" states that the GFIG Report Rule (40 CFR 98), "should be
considered a primary reference for sources and permitting authorities in estimating GFIG emissions and establishing measurement techniques when preparing or
processing permit applications." Therefore, GFIG Reporting Rule emission factors will be employed to determine GFIG PTE.
Carbon Dioxide (CO?)
EF (lb C02e/MMBtu) = EF (kg C02/MMBtu) X CFkg^lb (lb/kg) X GWPC02 (lb C02e/lb C02)
Calculated C02e
EF for C02
(lb C02e/MMBtu)
40 CFR 98
Table C-1 EF
(kg C02/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb C02)
116.977
53.06
2.20462262
1
Methane (CFI„)
EF (lb C02e/MMBtu) = EF (kg CH4/MMBtu) X CFk£Mb (lb/kg) X GWPCH4 (lb C02e/lb CH4)
Calculated C02e
E F for C Fl4
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg CH4/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb CH4)
0.055
0.001
2.20462262
25
Nitrous Oxide (N?0)
EF (lb C02e/MMBtu) = EF (kg N20/MMBtu) X CFk£Mb (lb/kg) X GWPN20 (lb C02e/lb N20)
Calculated C02e
EFfor N20
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg N20/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb N20)
0.066
0.0001
2.20462262
298
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 68 of 270
Page A-8 of A-18
-------
HAP Potential to Emit
Appendix A: Potential Emissions Inventory
Control Device
Fuel
Installation Date
Design Maximum Output Capacity
Design Maximum Heat Input Capcity
Operation
Emission Unit: EU-5
Description: Caterpillar 3408 Backup Electrical Power Generator
Reciprocating IC Compressor Engine, four-stroke, rich-burn, spark ignition
none
natural gas
1998
400 horsepower
3.76 MMBtu/hr
500 hours per year1
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 xl 06 scf)
EF
(Ib/MMBtu)
PTE
(tpy)
Trace Metal Compounds
Arsenic Compounds
2.0E-04
2.0E-07
1.84E-07
Beryllium Compounds
1.2E-05
1.2E-08
1.11E-08
Cadmium Compounds
1.1E-03
1.1E-06
1.01E-06
Chromium Compounds (including hexavalent)
1.4E-03
1.4E-06
1.29E-06
Cobalt Compounds
8.4E-05
8.2E-08
7.74E-08
Manganese Compounds
3.8E-04
3.7E-07
3.50E-07
Mercury Compounds
2.6E-04
2.5E-07
2.40E-07
Nickel Compounds
2.1E-03
2.1E-06
1.94E-06
Selenium Compounds
2.4E-05
2.4E-08
2.21 E-08
Organic Compounds
1,1,2,2-Tetrachlorethane
2.53E-05
2.38E-05
1,1,2-T richloroethane
1.53E-04
1.44E-04
1,3-Butadiene
6.63E-04
6.23E-04
1,3-Dichloropropene
1.27E-05
1.19E-05
Acetaldehyde
2.79E-03
2.62E-03
Acrolein
2.63E-03
2.47E-03
Benzene
1.58E-03
1.49E-03
Carbon Tetrachloride
1.77E-05
1.66E-05
Chlorobenzene
0)
1.29E-05
1.21 E-05
Chloroform
cu
0
1.37E-05
1.29E-05
Ethylbenzene
Q_
Q_
2.48E-05
2.33E-05
Ethylene Dibromide
<
2.13E-05
2.00E-05
Formaldehyde
-z.
2.05E-02
1.93E-02
Methanol
3.06E-03
2.88E-03
Methylene Chloride
4.12E-05
3.87E-05
Naphthalene2
9.71 E-05
9.13E-05
Polycyclic Organic Matter (POM)3
1.41E-04
1.33E-04
Styrene
1.19E-05
1.12E-05
Toluene
5.58E-04
5.25E-04
Vinyl Chloride
7.18E-06
6.75E-06
Xylene
1.95E-04
1.83E-04
TOTAL4 3.25E-02 3.05E-02
1 September 6, 1995 EPA memorandum entitled, "Calculating Potential to Emit (PTE) for Emergency Generators"
2 Naphthalene is a HAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds
that, in aggregate, are subject to the same 10 tpy major source threshold.
3 POM defines a broad class of compounds that generally includes all organic structures having two or more fused aromatic rings (i.e., rings that share a common
border), and that have a boiling point greater than or equal to 212°F (100°C). See http://www.epa.gOv/ttn/atw/hlthef/polycycl.html#ref11
4 Because naphthalene is accounted for individually and in the calculation of POM EF, its contribution here is discounted so as to avoid double-counting.
Trace Metal Compounds EF Basis: AP-42. Table 1.4-4. July 1998.
EF (Ib/MMBtu) = EF (Ib/1x106scf) X(1x106 scf/1020 MMBtu). See footnote a to Table 1.4-4.
Organic Compounds EF Basis: AP-42. Table 3.2-3. July 2000.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 69 of 270
Page A-9 of A-18
-------
Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Control Device
Fuel
Installation Date
Design Maximum Heat Input Capcity
Operation
Emission Unit: EU-6
Description: Sellers Model C80W Boiler
Boiler provides glycol heat to keep compressor engines on warm standby
none
natural gas
1989
3.5154
8760
MMBtu/hr
hours per year
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 x105 scf)
EF
(Ib/MMBtu)
PTE
ftpy)
EF Reference
Carbon Monoxide (CO)
84
0.0824
1.3
1
Lead (Pb)
0.0005
4.9E-07
7.55E-06
2
Nitrogen Oxides (NOx)
100
0.0980
1.5
1
Particulate (PM)
1.9
0.0019
0.03
3
Inhalable Coarse Particulate (PM10)
7.6
0.0075
0.11
3
Fine Particulate (PM2 5)
7.6
0.0075
0.11
3
Sulfur Dioxide (S02)
Not Applicable
0.0544
0.8
4
Volatile Organic Compounds (VOC)
5.5
0.0054
0.08
2
NON-FUGITIVE EMISSIONS
Greenhouse Gas Emissions
EF
EF
PTE
EF Reference
(C02 Equivalent)
(lb/1 x105 scf)
(Ib/MMBtu)
(tpy)
Carbon Dioxide (C02)
116.977
1801.2
5
Methane (CFI4)
Not Applicable
0.055
0.8
5
Nitrous Oxide (N20)
0.066
1.0
5
TOTAL 1,803
EF Reference
Description
1
Table 1.4-1 of AP-42, July 1998. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-1.
2
Table 1.4-2 of AP-42, July 1998. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
3
Table 1.4-2 of AP-42, July 1998. Filterable PM (< 1nm) = 1.9 lb/1 xl06 scf. Condensible PM -5.7 lb/1 xl06 scf. PM EF equal to filterable portion. PM10 and PM2 5 EF
equal to sum of both; 7.6 lb/1 xl06 scf. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
EPA did not employ the applicable FARR PM limit to calculate potential emissions because the resultant 0.1871 Ib/MMBtu PM EF is unrealistic for a natural gas fired
boiler. The calculation to derive the 0.1871 Ib/MMBtu PM EF is as follows:
Basis: FARR combustion source stack PM emission limit of 0.1 gr/dscf corrected to 7% 02 at 40 CFR 49.125(d)(1)
EF (Ib/MMBtu) = FARR PM Limit (gr/dscf@7%02) X CF7_^%02 X Fd (dscf/MMBtu) / CFgr^lb (gr/lb)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR PM
Calculated EF
(Ib/MMBtu)
FARR PM
Emission Limit
(gr/dscf @7%02)
CF 7—>0%O2
(unitless)
Fd
(dscf/MMBtu)
CFgr^|b
(gr/lb)
0.1871
0.1
1.504
8,710
7,000
4
Option 1: 0.0544 Ib/MMBtu. This emission factor is employed to determine PTE as it limits emissions to less than Option 2 or 3 below.
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (Ib/MMBtu) = Pipeline tariff S Limit (gr/100 ft3) / CF100ft3^Btu X CFBtu^MMBtu / CFgr^,b X CFS^S02
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 105000 Btu/100 ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
Pipeline Tariff
Calculate S02 EF
(Ib/MMBtu)
Pipeline Tariff
Fuel Sulfur Limit
(qr/100 ft3)
CFft3^Btu
(Btu/100 ft3)
CFgtu->MMBtu
(Btu/MMBtu)
CFgr_>|b
(gr/lb)
CF S—»S02
(lb S02/lb S)
0.0544
20
105000
1.E+06
7000
2
Option 2: 0.1308 Ib/MMBtu.
Basis: FARR gaseous fuel sulfur limit of 1.1 g/dry standard cubic meter at 40 CFR 49.130(d)(8)
EF (Ib/MMBtu) = FARR Fuel S Limit (g/m ) / CFm3_»ft3 / CFft3_>Btu X CFBtu->MMBtu! CFg_,.ib X CFs->so2
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFft3^Btu = 1050 Btu/ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
FARR Fuel S
Calculate S02 EF
(Ib/MMBtu)
FARR
Fuel Sulfur Limit
(q/rri3)
CF m3_>ft3
(ft3/m3)
CFfo^etu
(Btu/ft3)
CF[3tu—>MMBtu
(Btu/MMBtu)
CFg^|b
(g/ib)
CFs^so2
ON
0.1308
1.1
35.3147
1050
1.E+06
453.592
2
Option 3: 1.087 Ib/MMBtu.
Basis: FARR combustion source stack S02 emission limit of 500 parts per million by volume dry basis (ppmvd) corrected to 7% 02 at 40 CFR 49.129(d)(1)
EF (Ib/MMBtu) = FARR S02 Limit (ppmvd@7%02) X CF7^0%02 X CFpprTW|b/dscfSo2 X Fd (dscf/MMBtu)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
Xo2Fd = 0 ar|d X02farr = 7- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• CFpprTW|b/dscfSo2 = 1 -660 X 10"7 lb S02/dscf / ppm S02. See Table 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR 500 ppm
Calculate S02 EF
(Ib/MMBtu)
FARR
JW2 i_ 111 i^oiwi i
1 im it
(ppmvd@7%02)
CF 7—>0%O2
(unitless)
C Fppm^i b/dscfS02
(lb/dscf / ppm)
Fd
(dscf/MMBtu)
1.087
500
1.504
1.66E-07
8710
5
EPA's March 2011 guidance document "PSD and Title V Permitting Guidance for Greenhouse Gases" states that the GFIG Report Rule (40 CFR 98), "should be
considered a primary reference for sources and permitting authorities in estimating GFIG emissions and establishing measurement techniques when preparing or
processing permit applications." Therefore, GFIG Reporting Rule emission factors will be employed to determine GFIG PTE.
Carbon Dioxide (CO-?)
EF (lb C02e/MMBtu) = EF (kg C02/MMBtu) X CFkg^lb (lb/kg) X GWPC02 (lb C02e/lb C02)
Calculated C02e
EF for C02
(lb C02e/MMBtu)
40 CFR 98
Table C-1 EF
(kg C02/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb C02)
116.977
53.06
2.20462262
1
Methane (CFL)
EF (lb C02e/MMBtu) = EF (kg CH4/MMBtu) X CFkg^lb (lb/kg) X GWPCH4 (lb C02e/lb CH4)
Calculated C02e
E F for C Fl4
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg CH4/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb CH4)
0.055
0.001
2.20462262
25
Nitrous Oxide (N?0)
EF (lb C02e/MMBtu) = EF (kg N20/MMBtu) X CFkg^lb (lb/kg) X GWPN20 (lb C02e/lb N20)
Calculated C02e
EFfor N20
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg N20/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb N20)
0.066
0.0001
2.20462262
298
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 70 of 270
Page A-
10 of A-18
-------
HAP Potential to Emit
Appendix A: Potential Emissions Inventory
Control Device
Fuel
Installation Date
Design Maximum Heat Input Capcity
Operation
Emission Unit: EU-6
Description: Sellers Model C80W Boiler
Boiler provides glycol heat to keep compressor engines on warm standby
none
natural gas
1989
3.5154
8760
MMBtu/hr
hours per year
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 xl 06 scf)
EF
(Ib/MMBtu)
PTE
(tpy)
Trace Metal Compounds
Arsenic Compounds
2.0E-04
2.0E-07
3.02E-06
Beryllium Compounds
1.2E-05
1.2E-08
1.81E-07
Cadmium Compounds
1.1E-03
1.1E-06
1.66E-05
Chromium Compounds (including hexavalent)
1.4E-03
1.4E-06
2.11E-05
Cobalt Compounds
8.4E-05
8.2E-08
1.27E-06
Manganese Compounds
3.8E-04
3.7E-07
5.74E-06
Mercury Compounds
2.6E-04
2.5E-07
3.92E-06
Nickel Compounds
2.1E-03
2.1E-06
3.17E-05
Selenium Compounds
2.4E-05
2.4E-08
3.62E-07
Organic Compounds
Benzene
2.1E-03
2.1E-06
3.17E-05
Dichlorobenzene
1.2E-03
1.2E-06
1.81E-05
Formaldehyde
7.5E-02
7.4E-05
1.13E-03
Hexane
1.8E+00
1.8E-03
2.72E-02
Naphthalene1
6.1E-04
6.0E-07
9.21 E-06
Polycyclic Organic Matter (POM)2
7.0E-04
6.8E-07
1.05E-05
Toluene
3.4E-03
3.3E-06
5.13E-05
TOTAL3 1.89E+00 1.85E-03 2.85E-02
1 Naphthalene is a HAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds
that, in aggregate, are subject to the same 10 tpy major source threshold.
2 POM defines a broad class of compounds that generally includes all organic structures having two or more fused aromatic rings (i.e., rings that share a common
border), and that have a boiling point greater than or equal to 212°F (100°C). See http://www.epa.gOv/ttn/atw/hlthef/polycycl.html#ref11
3 Because naphthalene is accounted for individually and in the calculation of POM EF, its contribution here is discounted so as to avoid double-counting.
Trace Metal Compounds EF Basis: AP-42. Table 1.4-4. July 1998.
EF (Ib/MMBtu) = EF (Ib/1x106scf) X(1x106 scf/1020 MMBtu). See footnote a to Table 1.4-4.
Orc[ani£^om|30und=EF=Basis;=^P=42JableJ^4_3i=Jul^J=998i
POM Compounds
EF
(lb/105 scf)
EF
(Ib/MMBtu)
2-Methylnaphthalene
2.4E-05
2.4E-08
3-Methychloranthrene
1.8E-06
1.8E-09
7,12-Dimethylbenz(a)anthracene
1.6E-05
1.6E-08
Acenaphthene*
1.8E-06
1.8E-09
Acenaphthylene*
1.8E-06
1.8E-09
Anthracene*
2.4E-06
2.4E-09
Benzo(a)anthracene*
1.8E-06
1.8E-09
Benzo(a)pyrene*
1.2E-06
1.2E-09
Benzo(b)fluoranthene*
1.8E-06
1.8E-09
Benzo(g, h, I) perylene*
1.2E-06
1.2E-09
Benzo(k)fluoranthene*
1.8E-06
1.8E-09
Chrysene*
1.8E-06
1.8E-09
Dibenzo(a,h)anthracene
1.2E-06
1.2E-09
Fluoranthene*
3.0E-06
2.9E-09
Fluorene*
2.8E-06
2.7E-09
lndeno(1,2,3-cd)pyrene*
1.8E-06
1.8E-09
Naphthalene***
6.1E-04
6.0E-07
Phenanthrene*
1.7E-05
1.7E-08
Pyrene
5.0E-06
4.9E-09
SUBTOTAL
7.0E-04
6.8E-07
* designates a polycyclic aromatic hydrocarbon (PAH). PAHs are potent atmospheric pollutants that consist of fused aromatic rings and do not contain heteroatoms
** designates a POM compound that is also an individual HAP.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 71 of 270
Page A-11 of A-18
-------
Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Control Device
Fuel
Installation Date
Design Maximum Heat Input Capcity
Operation
Emission Unit: EU-7
Description: BS&B Model IH-3012-500M-T2 Heater (Refurbished)
Boiler provides glycol heat to keep compressor engines on warm standby
none
natural gas
?
0.50
8760
MMBtu/hr
hours per year
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 x106 scf)
EF
(Ib/MMBtu)
PTE
ftpy)
EF Reference
Carbon Monoxide (CO)
84
0.0824
0.2
1
Lead (Pb)
0.0005
4.9E-07
1.07E-06
2
Nitrogen Oxides (NOx)
100
0.0980
0.2
1
Particulate (PM)
1.9
0.0019
0.00
3
Inhalable Coarse Particulate (PM10)
7.6
0.0075
0.02
3
Fine Particulate (PM2 5)
7.6
0.0075
0.02
3
Sulfur Dioxide (S02)
Not Applicable
0.0544
0.1
4
Volatile Organic Compounds (VOC)
5.5
0.0054
0.01
2
NON-FUGITIVE EMISSIONS
Greenhouse Gas Emissions
EF
EF
PTE
EF Reference
(C02 Equivalent)
(lb/1 x105 scf)
(Ib/MMBtu)
(tpy)
Carbon Dioxide (C02)
116.977
256.2
5
Methane (CH4)
Not Applicable
0.055
0.1
5
Nitrous Oxide (N20)
0.066
0.1
5
TOTAL 256
EF Reference
Description
1
Table 1.4-1 of AP-42, July 1998. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-1.
2
Table 1.4-2 of AP-42, July 1998. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
3
Table 1.4-2 of AP-42, July 1998. Filterable PM (< 1nm) = 1.9 lb/1 xl06 scf. Condensible PM -5.7 lb/1 xl06 scf. PM EF equal to filterable portion. PM10 and PM2 5 EF
equal to sum of both; 7.6 lb/1 xl06 scf. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
EPA did not employ the applicable FARR PM limit to calculate potential emissions because the resultant 0.1871 Ib/MMBtu PM EF is unrealistic for a natural gas fired
boiler. The calculation to derive the 0.1871 Ib/MMBtu PM EF is as follows:
Basis: FARR combustion source stack PM emission limit of 0.1 gr/dscf corrected to 7% 02 at 40 CFR 49.125(d)(1)
EF (Ib/MMBtu) = FARR PM Limit (gr/dscf@7%02) X CF7_^%02 X Fd (dscf/MMBtu) / CFgr^lb (gr/lb)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR PM
Calculated EF
(Ib/MMBtu)
FARR PM
Emission Limit
(gr/dscf @7%02)
CF 7—>0%O2
(unitless)
Fd
(dscf/MMBtu)
CFgr^|b
(gr/lb)
0.1871
0.1
1.504
8,710
7,000
4
Option 1: 0.0544 Ib/MMBtu. This emission factor is employed to determine PTE as it limits emissions to less than Option 2 or 3 below.
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (Ib/MMBtu) = Pipeline tariff S Limit (gr/100 ft3) / CF100ft3^Btu X CFBtu^MMBtu / CFgr^,b X CFS^S02
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 105000 Btu/100 ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
Pipeline Tariff
Calculate S02 EF
(Ib/MMBtu)
Pipeline Tariff
Fuel Sulfur Limit
(qr/100 ft3)
CFft3^Btu
(Btu/100 ft3)
CFgtu->MMBtu
(Btu/MMBtu)
CFgr_>|b
(gr/lb)
CF S—»S02
(lb S02/lb S)
0.0544
20
105000
1.E+06
7000
2
Option 2: 0.1308 Ib/MMBtu.
Basis: FARR gaseous fuel sulfur limit of 1.1 g/dry standard cubic meter at 40 CFR 49.130(d)(8)
EF (Ib/MMBtu) = FARR Fuel S Limit (g/m ) / CFm3_»ft3 / CFft3_>Btu X CFBtu->MMBtu! CFg_,.ib X CFs->so2
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFft3^Btu = 1050 Btu/ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
FARR Fuel S
Calculate S02 EF
(Ib/MMBtu)
FARR
Fuel Sulfur Limit
(q/rri3)
CF m3_>ft3
(ft3/m3)
CFfo^etu
(Btu/ft3)
CF[3tu—>MMBtu
(Btu/MMBtu)
CFg^|b
(g/ib)
CFs^so2
ON
0.1308
1.1
35.3147
1050
1.E+06
453.592
2
Option 3: 1.087 Ib/MMBtu.
Basis: FARR combustion source stack S02 emission limit of 500 parts per million by volume dry basis (ppmvd) corrected to 7% 02 at 40 CFR 49.129(d)(1)
EF (Ib/MMBtu) = FARR S02 Limit (ppmvd@7%02) X CF7^0%02 X CFpprTW|b/dscfSo2 X Fd (dscf/MMBtu)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
Xo2Fd = 0 ar|d X02farr = 7- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• CFpprTW|b/dscfSo2 = 1 -660 X 10"7 lb S02/dscf / ppm S02. See Table 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR 500 ppm
Calculate S02 EF
(Ib/MMBtu)
FARR
JW2 i_ 111 i^oiwi i
1 im it
(ppmvd@7%02)
CF 7—>0%O2
(unitless)
C Fppm^i b/dscfS02
(lb/dscf / ppm)
Fd
(dscf/MMBtu)
1.087
500
1.504
1.66E-07
8710
5
EPA's March 2011 guidance document "PSD and Title V Permitting Guidance for Greenhouse Gases" states that the GHG Report Rule (40 CFR 98), "should be
considered a primary reference for sources and permitting authorities in estimating GHG emissions and establishing measurement techniques when preparing or
processing permit applications." Therefore, GHG Reporting Rule emission factors will be employed to determine GHG PTE.
Carbon Dioxide (CO-?)
EF (lb C02e/MMBtu) = EF (kg C02/MMBtu) X CFkg^lb (lb/kg) X GWPC02 (lb C02e/lb C02)
Calculated C02e
EF for C02
(lb C02e/MMBtu)
40 CFR 98
Table C-1 EF
(kg C02/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb C02)
116.977
53.06
2.20462262
1
Methane (CH„)
EF (lb C02e/MMBtu) = EF (kg CH4/MMBtu) X CFkg^lb (lb/kg) X GWPCH4 (lb C02e/lb CH4)
Calculated C02e
E F for C H4
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg CH4/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb CH4)
0.055
0.001
2.20462262
25
Nitrous Oxide (N?0)
EF (lb C02e/MMBtu) = EF (kg N20/MMBtu) X CFkg^lb (lb/kg) X GWPN20 (lb C02e/lb N20)
Calculated C02e
EFfor N20
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg N20/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb N20)
0.066
0.0001
2.20462262
298
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis Page A-12 of A-18
Page 72 of 270
-------
HAP Potential to Emit
Appendix A: Potential Emissions Inventory
Emission Unit: EU-7
Description: BS&B Model IH-3012-500M-T2 Heater (Refurbished)
Boiler provides glycol heat to keep compressor engines on warm standby
Control Device
Fuel
Installation Date
Design Maximum Heat Input Capcity
Operation
none
natural gas
?
0.50
8760
MMBtu/hr
hours per year
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 xl 06 scf)
EF
(Ib/MMBtu)
PTE
(tpy)
Trace Metal Compounds
Arsenic Compounds
2.0E-04
2.0E-07
4.29E-07
Beryllium Compounds
1.2E-05
1.2E-08
2.58E-08
Cadmium Compounds
1.1E-03
1.1 E-06
2.36E-06
Chromium Compounds (including hexavalent)
1.4E-03
1.4E-06
3.01 E-06
Cobalt Compounds
8.4E-05
8.2E-08
1.80E-07
Manganese Compounds
3.8E-04
3.7E-07
8.16E-07
Mercury Compounds
2.6E-04
2.5E-07
5.58E-07
Nickel Compounds
2.1E-03
2.1 E-06
4.51 E-06
Selenium Compounds
2.4E-05
2.4E-08
5.15E-08
Organic Compounds
Benzene
2.1E-03
2.1 E-06
4.51 E-06
Dichlorobenzene
1.2E-03
1.2E-06
2.58E-06
Formaldehyde
7.5E-02
7.4E-05
1.61E-04
Hexane
1.8E+00
1.8E-03
3.86E-03
Naphthalene1
6.1E-04
6.0E-07
1.31E-06
Polycyclic Organic Matter (POM)2
7.0E-04
6.8E-07
1.50E-06
Toluene
3.4E-03
3.3E-06
7.30E-06
TOTAL3 1.89E+00 1.85E-03 4.05E-03
1 Naphthalene is a HAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds
that, in aggregate, are subject to the same 10 tpy major source threshold.
2 POM defines a broad class of compounds that generally includes all organic structures having two or more fused aromatic rings (i.e., rings that share a common
border), and that have a boiling point greater than or equal to 212°F (100°C). See http://www.epa.gOv/ttn/atw/hlthef/polycycl.html#ref11
3 Because naphthalene is accounted for individually and in the calculation of POM EF, its contribution here is discounted so as to avoid double-counting.
Trace Metal Compounds EF Basis: AP-42. Table 1.4-4. July 1998.
EF (Ib/MMBtu) = EF (Ib/1x106scf) X(1x106 scf/1020 MMBtu). See footnote a to Table 1.4-4.
Orc[ani£^om|30und=EF=Basis;=^P=42JableJ^4_3i=Jul^J=998i
POM Compounds
EF
(lb/105 scf)
EF
(Ib/MMBtu)
2-Methylnaphthalene
2.4E-05
2.4E-08
3-Methychloranthrene
1.8E-06
1.8E-09
7,12-Dimethylbenz(a)anthracene
1.6E-05
1.6E-08
Acenaphthene*
1.8E-06
1.8E-09
Acenaphthylene*
1.8E-06
1.8E-09
Anthracene*
2.4E-06
2.4E-09
Benzo(a)anthracene*
1.8E-06
1.8E-09
Benzo(a)pyrene*
1.2E-06
1.2E-09
Benzo(b)fluoranthene*
1.8E-06
1.8E-09
Benzo(g, h, I) perylene*
1.2E-06
1.2E-09
Benzo(k)fluoranthene*
1.8E-06
1.8E-09
Chrysene*
1.8E-06
1.8E-09
Dibenzo(a,h)anthracene
1.2E-06
1.2E-09
Fluoranthene*
3.0E-06
2.9E-09
Fluorene*
2.8E-06
2.7E-09
lndeno(1,2,3-cd)pyrene*
1.8E-06
1.8E-09
Naphthalene***
6.1E-04
6.0E-07
Phenanthrene*
1.7E-05
1.7E-08
Pyrene
5.0E-06
4.9E-09
SUBTOTAL
7.0E-04
6.8E-07
* designates a polycyclic aromatic hydrocarbon (PAH). PAHs are potent atmospheric pollutants that consist of fused aromatic rings and do not contain heteroatoms
** designates a POM compound that is also an individual HAP.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 73 of 270
Page A-13 of A-18
-------
Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Emission Unit:
Description:
Control Device:
Fuel:
Equipment List
EU-8
Heaters and Furnaces
none
natural gas
Rated Capacity (MMBtu/hr)
Shop Heater
0.25
Shop Heater
0.25
Breakroom Furnace
0.08
Old Office Furnace
0.07
Warehouse Shop Heater
0.16
Auxilary Room Heater
0.3691
Total 1.1791 MMBtu/hr
Operation: 8760 hours per year
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 xl 06 scf)
EF
(Ib/MMBtu)
PTE
(tpy)
EF Reference
Carbon Monoxide (CO)
40
0.0824
0.4
1
Lead (Pb)
0.0005
4.90E-07
2.5E-06
2
Nitrogen Oxides (NOx)
94
0.0980
0.5
1
Particulate (PM)
1.9
0.00186
0.01
3
Inhalable Coarse Particulate (PM10)
7.6
0.00745
0.04
3
Fine Particulate (PM2 5)
7.6
0.00745
0.04
3
Sulfur Dioxide (S02)
Not Applicable
0.0544
0.3
4
Volatile Organic Compounds (VOC)
5.5
0.0054
0.03
2
NON-FUGITIVE EMISSIONS
Greenhouse Gas Emissions
EF
EF
PTE
EF Reference
(C02 Equivalent)
(lb/1 x105 scf)
(Ib/MMBtu)
(tpy)
Carbon Dioxide (C02)
116.977
604.1
5
Methane (CH4)
Not Applicable
0.055
0.3
5
Nitrous Oxide (N20)
0.066
0.3
5
TOTAL 605
EF Reference
Description
1
Table 1.4-1 of AP-42, July 1998. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-1.
2
Table 1.4-2 of AP-42, July 1998. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
3
Table 1.4-2 of AP-42, July 1998. Filterable PM (< 1|im) = 1.9 lb/1 xl06 scf. Condensible PM ~ 5.7 lb/1 xl06 scf. PM EF equal to filterable portion. PM10 and PM25 EF
equal to sum of both; 7.6 lb/1 xl06 scf. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
EPA did not employ the applicable FARR PM limit to calculate potential emissions because the resultant 0.1871 Ib/MMBtu PM EF is unrealistic for a natural gas
fired boiler. The calculation to derive the 0.1871 Ib/MMBtu PM EF is as follows:
Basis: FARR combustion source stack PM emission limit of 0.1 gr/dscf corrected to 7% 02 at 40 CFR 49.125(d)(1)
EF (Ib/MMBtu) = FARR PM Limit (gr/dscf@7%02) X CF7^0%02 X Fd (dscf/MMBtu) / CFgr^lb (gr/lb)
• CF7—>0%o2 = (20.9 - X02pd) / (20.9 - X02farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
Xo2Fd = 0 ar|d X02farr = 7- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR PM
Calculated EF
(Ib/MMBtu)
FARR PM
Emission Limit
(gr/dscf @7%02)
CF 7_>0%O2
(unitless)
Fd
(dscf/MMBtu)
CF gr^|b
(gr/lb)
0.1871
0.1
1.504
8,710
7,000
4
Option 1: 0.0544 Ib/MMBtu. This emission factor is employed to determine PTE as it limits emissions to less than Option 2 or 3 below.
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (Ib/MMBtu) = Pipeline tariff S Limit (gr/100 ft3) / CF-ioo^Btu X CFBtu^MMBtu / CFgr^b X CFs^So2
• CFs—»so2 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFft3—>Btu = 105000 Btu/100 ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
Pipeline Tariff
Calculate S02 EF
(Ib/MMBtu)
Pipeline Tariff
Fuel Sulfur Limit
(qr/100 ft3)
CF ft3—>Btu
(Btu/100 ft3)
CF Btu—>MMBtu
(Btu/MMBtu)
CFgr_>|b
(gr/lb)
CF S—»S02
(lb S02/lb S)
0.0544
20
105000
1.E+06
7000
2
ODtion 2: 0.1308 Ib/MMBtu.
Basis: FARR gaseous fuel sulfur limit of 1.1 g/dry standard cubic meter at 40 CFR 49.130(d)(8)
EF (Ib/MMBtu) = FARR Fuel S Limit (g/m3) / CFm3_»ft3 / CFft3_>etu X CFetu-»MMBtu / CFg_,|b X CFs->so2
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 1050 Btu/ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
FARR Fuel S
Calculate S02 EF
(Ib/MMBtu)
FARR
Fuel Sulfur Limit
(q/rri3)
CF m3—>ft3
(ft3/rn3)
CF ft3—>Btu
(Btu/ft3)
CF(3tu—»MMBtu
(Btu/MMBtu)
CF g—b
(g/ib)
CF S—>S02
(lb S02/lb S)
0.1308
1.1
35.3147
1050
1.E+06
453.592
2
Option 3: 1.087 Ib/MMBtu.
Basis: FARR combustion source stack S02 emission limit of 500 parts per million by volume dry basis (ppmvd) corrected to 7% 02 at 40 CFR 49.129(d)(1)
EF (Ib/MMBtu) = FARR S02 Limit (ppmvd@7%02) X CF7^0%02 X CFpprTW|b/dsCfso2 X Fd (dscf/MMBtu)
• CF7—>0%o2 = (20.9 - X02Fd) / (20.9 - X02farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
Xo2Fd = 0 ar|d X02farr = 7- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• CFpprTW|b/dsCfso2 = 1 -660 X 10"7 lb S02/dscf / ppm S02. See Table 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR 500 ppm
Calculate S02 EF
(Ib/MMBtu)
FARR
OU2 Ql I llbblUI I
(ppmvd@7%02)
CF 7_>0%O2
(unitless)
CF ppm^|b/dscfS02
(lb/dscf / ppm)
Fd
(dscf/MMBtu)
1.087
500
1.504
1.66E-07
8710
5
EPA's March 2011 guidance document "PSD and Title V Permitting Guidance for Greenhouse Gases" states that the GHG Report Rule (40 CFR 98), "should be
Carbon Dioxide (CO?)
EF (lb C02e/MMBtu) = EF (kg C02/MMBtu) X CFk£Mb (lb/kg) X GWPC02 (lb C02e/lb C02)
Calculated C02e
EFfor C02
(lb C02e/MMBtu)
40 CFR 98
Table C-1 EF
(kg C02/MMBtu)
CFkg^lh
(lb/kg)
40 CFR 98 Table
A-1 GWPco2
(lb C02e/lb C02)
116.977
53.06
2.20462262
1
Methane (CH/i)
EF (lb C02e/MMBtu) = EF (kg CH4/MMBtu) X CFk£Mb (Ib/kc
]) X GWPCh4 (lb C02e/lb CH4)
Calculated C02e
EF for CH4
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg CH4/MMBtu)
CFkg^lb
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb CH4)
0.055
0.001
2.20462262
25
Nitrous Oxide (N?0)
EF (lb C02e/MMBtu) = EF (kg N20/MMBtu) X CFkg^lb (lb/kg) X GWPN20 (lb C02e/lb N20)
Calculated C02e
EF for N20
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg N20/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb N20)
0.066
0.0001
2.20462262
298
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 74 of 270
Page A-14 of A-18
-------
Appendix A: Potential Emissions Inventory
HAP Potential to Emit
Emission Unit
Description
Control Device
Fuel
EU-8
Heaters and Furnaces
none
natural gas
Equipment List
Rated Capacity (MMBtu/hr)
Shop Fleater
0.25
Shop Fleater
0.25
Breakroom Furnace
0.08
Old Office Furnace
0.07
Warehouse Shop Fleater
0.16
Auxilary Room Fleater
0.3691
Total 1.1791 MMBtu/hr
Operation: 8760 hours per year
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 x105 scf)
EF
(Ib/MMBtu)
PTE
(tpy)
Trace Metal Compounds
Arsenic Compounds
2.0E-04
2.0E-07
1.01 E-06
Beryllium Compounds
1.2E-05
1.2E-08
6.08E-08
Cadmium Compounds
1.1E-03
1.1E-06
5.57E-06
Chromium Compounds (including hexavalent)
1.4E-03
1.4E-06
7.09E-06
Cobalt Compounds
8.4E-05
8.2E-08
4.25E-07
Manganese Compounds
3.8E-04
3.7E-07
1.92E-06
Mercury Compounds
2.6E-04
2.5E-07
1.32E-06
Nickel Compounds
2.1E-03
2.1E-06
1.06E-05
Selenium Compounds
2.4E-05
2.4E-08
1.22E-07
Organic Compounds
Benzene
2.1E-03
2.1E-06
1.06E-05
Dichlorobenzene
1.2E-03
1.2E-06
6.08E-06
Formaldehyde
7.5E-02
7.4E-05
3.80E-04
Flexane
1.8E+00
1.8E-03
9.11E-03
Naphthalene1
6.1E-04
6.0E-07
3.09E-06
Polycyclic Organic Matter (POM)2
7.0E-04
6.8E-07
3.54E-06
Toluene
3.4E-03
3.3E-06
1.72E-05
TOTAL3 1.89E+00 1.85E-03 9.56E-03
1 Naphthalene is a FIAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds that,
in aggregate, are subject to the same 10 tpy major source threshold.
2 POM defines a broad class of compounds that generally includes all organic structures having two or more fused aromatic rings (i.e., rings that share a common
border), and that have a boiling point greater than or equal to 212°F (100°C). See http://www.epa.g0v/ttn/atw/hlthef/polycycl.html#refl 1
3 Because naphthalene is accounted for individually and in the calculation of POM EF, its contribution here is discounted so as to avoid double-counting.
Trace Metal Compounds EF Basis: AP-42. Table 1.4-4. July 1998.
EF (Ib/MMBtu) = EF (Ib/1x106scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-4.
Or2anic=Comgound=EF=Basis^Pi42feTab|eJi4;3feJu|^J=998i
POM Compounds
EF
(lb/105 scf)
EF
(Ib/MMBtu)
2-Methylnaphthalene
2.4E-05
2.4E-08
3-Methychloranthrene
1.8E-06
1.8E-09
7,12-Dimethylbenz(a)anthracene
1.6E-05
1.6E-08
Acenaphthene*
1.8E-06
1.8E-09
Acenaphthylene*
1.8E-06
1.8E-09
Anthracene*
2.4E-06
2.4E-09
Benzo(a)anthracene*
1.8E-06
1.8E-09
Benzo(a)pyrene*
1.2E-06
1.2E-09
Benzo(b)fluoranthene*
1.8E-06
1.8E-09
Benzo(g,h,l)perylene*
1.2E-06
1.2E-09
Benzo(k)fluoranthene*
1.8E-06
1.8E-09
Chrysene*
1.8E-06
1.8E-09
Dibenzo(a,h)anthracene
1.2E-06
1.2E-09
Fluoranthene*
3.0E-06
2.9E-09
Fluorene*
2.8E-06
2.7E-09
lndeno(1,2,3-cd)pyrene*
1.8E-06
1.8E-09
Naphthalene*'**
6.1E-04
6.0E-07
Phenanthrene*
1.7E-05
1.7E-08
Pyrene
5.0E-06
4.9E-09
SUBTOTAL
7.0E-04
6.8E-07
* designates a polycyclic aromatic hydrocarbon (PAFI). PAFIs are potent atmospheric pollutants that consist of fused aromatic rings and do not contain heteroatoms or
** designates a POM compound that is also an individual FIAP.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 75 of 270
Page A-15 of A-18
-------
Appendix A: Potential Emissions Inventory
HAP & Non-HAP Potential to Emit
Emission Unit: EU-9
Description: System Blowdown Gas
Once per year the source conducts an annual Emergency Shutdown Test where the source is isolated from the natural gas line and the system is purged venting
natural gas to the atmosphere.
Control Device: none
Natural Gas Purged: 0.35 1x106scf
NON-FUGITIVE EMISSIONS
HAP & Non-HAP Emissions
EF
(lb/1 x105 scf)
PTE
(tpy)
EF Reference
Hexane (HAP)
3.19E+01 |
0.01
1
Hydrogen Sulfide (H2S)
3.21 E+01
0.01
2
Lead (Pb)
5.00E-04
8.8E-08
3
Volatile Organic Compounds (VOC)
1.02E+03
0.2
4
NON-FUGITIVE EMISSIONS
Greenhouse Gas Emissions
(C02 Equivalent)
EF
(lb/1 x105 scf)
PTE
(tpy)
EF Reference
Methane (CH4)
1.02E+06
177.8
5
EF Reference
Description
EF (lb Hexane/1x10° scf) = (MWgas) X (wt. % Hexane/100) / (Densitygas) X CF100scf.
-~MMscf
Values for variables provided by applicant.
1
Hexane EF for CH4
MWgas
wt. % VOC/100
Densitygas
(lb/1 x105 scf)
(Ib/lb-mol)
(unitless)
(scf/lb rriol)
(scf/1x10° scf)
3.19E+01
19.25
0.000628
379
1.0E+06
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (lb/1 x10° scf) = Pipeline tariff S Limit (gr/100 ft3) X CF100scf_^
MMscf! CFg^it, X CFc
—»H2S
• CFs^h2s = 1-125 lb H2S/lb S. The MW S is 16 Ib/lb-mol, and the MW H2S is 18 Ib/lb-mol. The ratio of H2S to S = 18/16; 1.125.
2
Pipeline Tariff
Pipeline Tariff
Calculate H2S EF
Fuel Sulfur Limit
CF 100scf—> MMscf
' ^gr—>lb
CF S—»H2S
(lb/1 x105 scf)
(gr/100 ft3)
(100 scf/1x105 scf)
(gr/lb)
(lb H2S/lb S)
3.21 E+01
20
10000
7000
1.125
3
Table 1.4-2 of AP-42, July 1998. Lead is a
"pass through" pollutant.
EF (lb VOC/1x106 scf)
= (MWgas) X (wt. % VOC/100) / (Density
gas) X C Fi ooscf—~ MMSCf
Values for variables provided by applicant.
4
VOC EF for CH4
MWgas
wt. % VOC/100
Densitygas
scf—»M Mscf
(lb/1 xl 06 scf)
(Ib/lb-mol)
(unitless)
(scf/lb mol)
(scf/1x10° scf)
1.02E+03
19.25
0.019993
379
1.0E+06
EF (lb CO2e/1x105 scf)
= (MWqas) X (wt. % CH4/100) / (Density
qas) X C F-| 00SCf—>M MSCf
X GWPCh4 (lb C02e/lb CH4)
Estimate that wt. % CH
4 in natural gas is 80%.
5
C02e EF for CH4
MWgas
wt. % CH4/100
Densitygas
C FSCf_>M Mscf
40 CFR 98 Table
A-1 GWPC02
(lb CO2e/1x105 scf)
(Ib/lb-mol)
(unitless)
(scf/lb mol)
(scf/1x10° scf)
(lb C02e/lb CH4)
1.02E+06
19.25
0.8
379
1.0E+06
25
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 76 of 270
Page A-16 of A-18
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Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Emission Unit
Description
Control Device
FUGITIVE EMISSIONS
EU-10
Equipment Leaks
none
Type of Component
Quantity3
Emission Factor'3
kg/hr/source
TOC Emissions
VOC Emissions0
kg/hr
Ib/hr
tpy
Ib/hr
tpy
Valves
196
4.50E-03
8.82E-01
1.944
8.517
0.039
0.170
Flanges
245
3.90E-04
9.56E-02
0.211
0.923
0.004
0.018
Open-Ended Lines
27
2.00E-03
5.40E-02
0.119
0.521
0.002
0.010
Compressor
4
8.80E-03
3.52E-02
0.078
0.340
0.002
0.007
TOTAL
0.21
a Quantity of the components are estimated based on an inventory performed at the Green River compressor station, which is similar to the Pocatello compressor station in equipment and size.
b Emission factors are obtained from the document "Protocol for Equipment Leak Estimates," Emission Standards Division, U.S. Environmental Protection Agency, November 1995 Table 2.4.
c Average weight fraction of VOC in the stream is estimated as 2.00%. VOC is calculated as Total Organic Carbon (TOC) excluding methane and ethane.
Because VOC for EU-10 approximately equal to VOC for EU-9, and given the similar nature of the emission generating activities, estimate that EU-10 PTE approximately equal to that of EU-9 for
hexane, H2S, lead and methane. A summary of EU-9 potential emissions is transposed here and assumed equal to EU-10 PTE, except that EU-10 emissions are fugitive.
FUGITIVE EMISSIONS
FIAP & Non-HAP Emissions
EF
(lb/1 xl 06 scf)
PTE
(tpy)
Hexane (HAP)
3.19E+01
0.01
Hydrogen Sulfide (H2S)
3.21 E+01
0.01
Lead (Pb)
5.00E-04
8.8E-08
Volatile Organic Compounds (VOC)
1.02E+03
0.2
FUGITIVE EMISSIONS
Greenhouse Gas Emissions
(C02 Equivalent)
EF
(lb/1 xl 06 scf)
PTE
(tpy)
Methane (CH4)
1.02E+06
177.8
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 77 of 270
Page A-17 of A-18
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Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Emission Unit: EU-11
Description: Liquid Storage Tanks
Control Device: none
NON-FUGITIVE EMISSIONS
Liquid in Tank
Type of Tank
Capacity
(gallons)
VOC PTE
(tPY)
Scrubber Oil
Fixed Roof
310
0.1
Scrubber Oil
Fixed Roof
310
0.1
Lube Oil
Florizontal Fixed Roof
11,760
0.1
Used Lube Oil
Vertical Fixed Roof
2,940
0.1
Total
0.4
EPA TANKS 4.0.9d employed to estimate emissions resulting from storage of lube oil and used lube
oil. Engineering judgement employed to estimate emissions resulting from storage of scrubber oil.
Northwest Pipeline - Pocatello Compressor Station Page 78 0f 270
Title V Operating Permit R10T5110200 Statement of Basis Page A-18 of A-18
-------
• SFCEiVED SEP 0 9 2015
Williams
NOR ! (IWES f f'l^ELINT
E^.i^^rrenta ts'Y'Vs
J95 Cf'ipPta \'<3y ? Floor
Sa't Lnh>Ctw UT 5410^-1220
August 28, 2.019
Bryan Holtrop
Office of Air Waste & Toxics
Air Permits & Diesel Unit
U.S. Environmental Protection Agency, Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Re; Air Quality Title V Permit Renewal
Pocatello Compressor Station - Permit # R10T5110100
Dear Mr. Holtrop:
Northwest Pipeline LLC (Northwest) is submitting the attached Title V permit renewal application
for the Pocatello Compressor Station in accordance with the Air Pollution Operating Permit No.
R10T5110100. Included with the submittal are forms GIS, l-COMP, Federal Requirements
Applicability, Insignificant Emissions, the CTAC and backup documentation showing emission
calculations. A new 1,250-gallon scrubber oil tank is the only new emission source at the
Pocatello compressor station. The new tank replaces 2 smaller tanks that were previously onsite.
This new tank is also an insignificant emission source.
The responsible official, Mr. Glen Jasek, has signed and dated the CTAC.
If you have any questions about the renewal application I can be reached at either (801) 584-
6748 or (801) 873-1334,
Sincerely,
c—•) } ^ |
j,
Derek Forsberg ''
Environmental Specialist
cc: Doug Hardesty, EPA Region 10 Air Permits & Toxics Office
950 W. Bannock St., Suite 900
Boise, ID 83702
Shoshone-Bannock Tribes
File - Pocatello Air
Page 79 of 270
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CXr.:.
Page 80 of 270
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United States
Environmental Protection
Agency
OMB No. 2060-0336,
Approval Expires 05/31/2019
Federal Operating Permit Program (40 CFR Part 71)
CERTIFICATION OF TRUTH, ACCURACY, AND COMPLETENESS (CTAC)
This form must be completed, signed by the "Responsible Official" designated for the facility or
emission unit, and sent with each submission of documents (i.e., application forms, updates to
applications, reports, or any information required by a part 71 permit).
A, Responsible Official
Name; (Last) Jasek (First) Glen (MI)
Title VP GM Northwest Pipeline
B. Certification of Truth, Accuracy and Completeness (to be signed by the
responsible official)
I certify under penalty of law, based on information and belief formed after reasonable
inquiry, the statements and information contained in these documents are true, accurate
and complete.
Street or P.O. Box P^ox 58900
City Salt Lake City
Telephone ( 801 ) 584 - 6125 Ext.
State UT ZIP 84158 - 0900
Facsimile (
Name (typed)
Name (signed) _
Date: "f I 3 / / ^
EPA Form 5900-02
Page 81 of 270
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A rnA United States
Environmental Protection
M m Agency
OMB No. 2060-0336,
Approval Expires 05/31/2019
Federal Operating Permit Program (40 CFR Part 71)
GENERAL INFORMATION AND SUMMARY (GIS)
A. Mailing Address and Contact Information
Facility name Pocatello Compressor Station
Mailing address: Street or P.O. Box 295 Chipeta Way
City Salt Lake Citv State UT ZIP 84108
Contact person: Derek Forsbera Title Environmental Specialist
Telephone ( 801 ) 584 - 6748 Ext.
Facsimile ( ) -
B. Facility Location
Temporary source? Yes X No Plant site location 2605 Gas Plant Road
Citv Pocatello State ID County Power EPA Region 10
Is the facility located within:
Indian lands? X YES NO An offshore source in federal waters? YES X NO
Non-attainment area? X YES NO If yes, for what air pollutants? PM10
Within 50 miles of affected State? X YES _ NO If yes, What State(s)? Fort Hall Res. &
State of Idaho
C. Owner
Name Northwest Pipeline LLC
Citv Salt Lake City
Street/P.O. Box
State UT
295 Chipeta Way
ZIP 84108 -
Telephone ( 801 ) 584 - 6748
Ext
D. Operator
Name Same as owner
Street/P.O. Box
City
State
ZIP
Telephone ( )
Ext
EPA Form 5900-79
Page 82 of 270
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GIS
2
E. Application Type
Mark only one permit application type and answer the supplementary question appropriate for the type
marked.
Initial Permit X Renewal Significant Mod Minor Permit Mod(MPM)
Group Processing, MPM Administrative Amendment
For initial permits, when did operations commence? / /
For permit renewal, what is the expiration date of current permit? 9/30/20
F. Applicable Requirement Summary
Mark the types of applicable requirements that apply:
SIP _X_ FIP/TIP _X_ PSD X Non-attainment NSR
Minor source NSR Section 111 Phase I acid rain Phase II acid rain
Stratospheric ozone OCS regulations X NESHAP Sec. 112(d) MACT
Sec. 112(g) MACT Early reduction of HAP Sec 1120) MACT RMP [Sec.112(r)]
Section 129 NAAQS, increments or visibility but for temporary sources (This is rare)
Is the source subject to the Deepwater Port Act? YES X NO
Has a risk management plan been registered? YES X NO Aqencv
Phase II acid rain application submitted? YES X NO If YES, Permittinq Authority
G. Source-Wide PTE Restrictions and Generic Applicable Requirements
Cite and describe any emissions-limiting requirements and/or facility-wide "generic" applicable requirements.
EPA Form 5900-79
Page 83 of 270
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GIS
3
H. Process Description
List processes, products, and SIC codes for the facility.
Process
Products
SIC
Natural Gas Transmission
Compression of Natural Gas
4922
I. Emission Unit Identification
Assign an emissions unit ID and describe each emissions unit at the facility. Control equipment and/or alternative
operating scenarios associated with emissions units should by listed on a separate line. Applicants may exclude
from this list any insignificant emissions units or activities.
Emissions Unit ID
Description of Unit
1
Clark TLA-6 Reciprocating Engine
2
Clark TLA-6 Reciprocating Engine
3
Clark TLA-6 Reciprocating Engine
4
Clark TCV-10 Reciprocating Engine
5
Caterpillar Emergency Backup Generator Engine
6
Boiler/Heater
7
Fuel Gas Heater
EPA Form 5900-79
Page 84 of 270
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GIS
J. Facility Emissions Summary
Enter potential to emit (PTE) for the facility as a whole for each regulated air pollutant listed below. Enter the
name of the single HAP emitted in the greatest amount and its PTE. For all pollutants, stipulations to major
source status may be indicated by entering "major" in the space for PTE. Indicate the total actual emissions for
fee purposes for the facility in the space provided. Applications for permit modifications need not include actual
emissions information.
NOx 1232
tons/vr VOC 30 tons/vr S02 17
tons/yr
tons/yr
PM-10 14
tons/yr CO 153 tons/yr Lead NA
Total HAP 23
tons/vr
Sinale HAP with areatest amount Formaldehyde pte
16
tons/yr
Total of regulated pollutants (for fee calculation), Sec. F, line 5 of form FEE
NA
tons/yr
K. Existing Federally-Enforceable Permits
Permit number(s) 0T5110100
Permit tvDe Title V
Permittinq authority EPA
Permit number(s) None
Permit type
Permitting authority
L. Emission Unit(s) Covered by General Permits
Emission unit(s) subject to general permit None
Check one: Application made Coverage granted
General permit identifier Expiration Date
M. Cross-referenced Information
INSTRUCTIONS FOLLOW
EPA Form 5900-79
Page 85 of 270
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Federal Requirements Applicability
Tier I Renewal
Northwest Pipeline LLC - Pocatello Compressor Station
Permit No. R10T5110100
A Federal Requirements Applicability review has been performed for Northwest Pipeline Pocatello
Compressor Station and will address recent applicable changes to Federal air regulations.
All regulated sources at the Northwest Pipeline LLC Pocatello Compressor Station site have remained
unchanged since the permit renewal application in 2007.
Regulated emission sources for the Pocatello Compressor Station site are as follows:
REGULATED EMISSION SOURCES
Source Description
Unit 1. 2 & 3 TLA-6 Reciprocating engines
Manufacturer: Clark
Model: TLA-6
Rated Capacity: 2,000 hp
Burner Type: Reciprocating Engine
Fuel: Natural Gas
Unit 4 TCV-10 Reciprocating engine
Manufacturer: Clark
Model: TCV-10
Rated Capacity: 3.400 hp
Burner Type: Reciprocating Engine
Fuel: Natural Gas
Unit 5 Emergency Backup Generator
Manufacturer: Caterpillar
Model: 3408
• Rated Capacity: 3.76 MMBtu/hr, 400 hp
Burner Type: Reciprocating Engine
! Fuel: Natural Gas
Serial #: 6CA00844
Unit 6 Boiler
Manufacturer: Sellers
: Model: C80W
Rated Capacity: 3.5 MMBtu/hr
Burner Type: Heater provides glycol heat to keep
compressor engines on warm standby
Fuel: Natural Gas
Installed: 1989
'Serial #: 9l)4t)l
Northwest Pipeline
Pocatello Compressor Station
Federal Requirements Applicability 2
Page 86 of 270
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Unit 7 Line Heater
Manufacturer: Sivalls
Model: NA
Rated Capacity: 0.5 MMBtu/hr
Burner Type: Pre-heats fuel for compressor engines and
the Sellers boiler
Fuel: Natural Gas
Installed: 2000
Serial#: 9902-313
All other sources at the Northwest Pipeline Pocatello Compressor Station site have remained the same
and have not been replaced or had any changes in maintenance or operation since last permitted.
INSIGNIFICANT EMISSION UNITS
Emission Unit Description
Space Heaters (natural gas fired)
Natural gas pipeline and fuel system
Used oil, lube oil and scrubber oil tanks
Northwest Pipeline
Pocatello Compressor Station
Federal Requirements Applicability
3
Page 87 of 270
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TITLES OF REGULATIONS
FEDERAL REGULATIONS
40 CFR Part 52
Approval and Promulgation of SIPs
40 CFR Part 52.21 (b-w)
Prevention of Significant Deterioration of Air Quality
40 CFR Part 52, Subpart TT
SIP: Utah State
40 CFR 60
New Source Performance Standards (NSPS)
40 CFR 61
National Emission Standards for Hazardous Air Pollutants (NESHAPS)
40 CFR 63
National Emission Standards for Hazardous Air Pollutants for Source Categories
40 CFR Part 70
State Permit Programs
40 CFR Part 70.6(a)(3)
Permit Program Monitoring Rules
40 CFR Part 82
Stratospheric Ozone Protection
Federal Requirements Applicability
40 CFR Part 60 Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage Vessels
(Including Petroleum Liquid Storage Vessels) for Which Construction. Reconstruction, or Modification
Commenced After July 23. 1984
NSPS Subpart Kb applies to storage vessels with a capacity greater than or equal to 75 cubic meters
(m3) (19,800 gal) used to store volatile organic liquids (VOL) for which construction, reconstruction, or
modification is commenced after July 23,1984.
Conclusion: The largest storage tank at the Pocatello Compressor Station is 280 barrels (bbl)
(11,760 gal) of lubrication oil. This volume is less than the NSPS Subpart Kb requirement, and
the facility commenced operation prior to July 23, 1984; therefore, Subpart Kb does not apply.
40 CFR Part 60 Subpart KKK - Standards of Performance for Equipment Leaks of VOC from Onshore
Natural Gas Processing Plants
NSPS Subpart KKK applies to equipment leak components at onshore natural gas processing plants
that commenced construction after January 20,1984. A natural gas processing plant is defined in
Subpart KKK as any processing site engaged in the extraction of natural gas liquids from field gas,
fractionation of mixed natural gas liquids to natural gas products, or both [40 CFR 60.631].
Conclusion: Pocatello Compressor Station is a natural compressor station and it does not
extract or fractionate natural gas liquids. Operation commenced prior to January 20, 1984;
therefore, Subpart KKK does not apply.
40 CFR Part 60 Subpart LLL - Standards of Performance for Onshore Natural Gas Processing: SO?
Emissions
NSPS Subpart LLL applies to facilities the following facilities that process natural gas: each sweetening
unit and each sweetening unit followed by a sulfur recovery unit.
Conclusion: The Pocatello Compressor Station does not operate natural gas sweetening units or
Northwest Pipeline
Pocatello Compressor Station
Federal Requirements Applicability 4
Page 88 of 270
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sulfur recovery units; therefore, Subpart LLL does not apply.
40 CFR Part 60 Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
NSPS Subpart JJJJ applies to stationary spark ignition internal combustion engines that commence
construction after June 12, 2006, where the engines are manufactured:
• On or after July 1, 2007, for engines with a maximum engine power greater than or equal to 500
HP (except lean burn engines with a maximum engine power greater than or equal to 500 HP
and less than 1,350 HP);
• On or after January 1, 2008, for lean burn engines with a maximum engine power greater than
or equal to 500 HP and less than 1,350 HP;
• On or after July 1, 2008, for engines with a maximum engine power less than 500 HP; or
• On or after January 1, 2009, for emergency engines with a maximum engine power greater than
19 KW (25 HP).
Conclusion: Each of the stationary spark ignition internal combustion engines at the Pocatello
Compressor Station commenced construction prior to June 12, 2006; therefore, they are
considering existing and therefore not subject to the requirements of 40 CFR NSPS Subpart
JJJJ[§60.4230(a)(4)].
40 CFR Part 63 Subpart HH - National Emission Standards for Hazardous Air Pollutants from Oil and
Natural Gas Production Facilities
National Emission Standard for Hazardous Air Pollutant (NESHAP) Subpart HH applies to oil and natural
gas production facilities that are major and area sources of HAPs. A major source is defined as a
stationary source that emits or has the potential to emit 10 tpy of any single HAP or 25 tpy of total HAPs,
and an area source is any stationary source of HAPs that is not a major source [40 CFR 63.2],
For facilities that are major HAP sources this subpart applies to facilities that process, upgrade or store
hydrocarbon liquids prior to the point of custody transfer or facilities that process, upgrade, or store natural
gas prior to the point at which natural gas enters the natural gas transmission and storage source category
or is delivered to a final end user.
The affected sources for major sources of HAPs include the following:
• Each glycol dehydration unit;
• Each storage vessel with the potential for flash emissions;
• Compressors or ancillary equipment operating in volatile hazardous air pollutant service located
at natural gas processing plants;
The affected sources for area sources of HAPs include the following:
• Each triethylene glycol (TEG) dehydration unit located at an oil and natural gas production facility.
Conclusion: The Pocatello Compressor Station is a natural gas transmission compressor station
and is a major source of HAPs. The facility does not meet the NESHAP definition of a natural gas
production facility, there are no glycol dehydration units and there are no ancillary equipment
operating in volatile hazardous air pollutant service, therefore, Subpart HH does not apply.
Northwest Pipeline
Pocatello Compressor Station
Federal Requirements Applicability 5
Page 89 of 270
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40 CFR Part 63 Subpart HHH - National Emission Standards for Hazardous Air Pollutants from Natural Gas
Transmission and Storage Facilities
NESHAP Subpart HHH applies to owners and operators of natural gas transmission and storage facilities
that transport or store natural gas prior to entering the pipeline to a local distribution company or to a final
end user (if there is no local distribution company), and that are major sources of HAP emissions. The
applicable affected source is each glycol dehydration unit. An owner or operator of a facility that does not
contain a glycol dehydration unit is not subject to the requirements of this subpart.
Conclusion: The Pocatello Compressor Station is a natural gas transmission compressor station
and is a major source ofHAPs, however, the facility does not operate a glycol dehydration unit,
therefore, Subpart HHH does not apply [§63.1270(a) (b)& (c)].
Northwest Pipeline
Pocatello Compressor Station
Federal Requirements Applicability
6
Page 90 of 270
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40 CFR Part 61 - National Emission Standards for Hazardous Air Pollutants
Based upon station equipment, station emissions, and engineering judgment, only Subpart V Equipment
Leaks (Fugitive Sources) was further reviewed to determine regulatory applicability. The provisions of
Subpart V apply to a source that operates in volatile hazardous air pollutant (VHAP) service including
pumps, compressors, pressure relief devices, valves, etc.Equipment operating in VHAP service is
defined as a piece of equipment that either contains or contacts a fluid (liquid or gas) that is at least 10
percent by weight a volatile hazardous air pollutant (VHAP) as determined according to the provisions of
§61.245(d).
Conclusion: Based upon the station equipment, emissions, natural gas composition and
engineering judgment, the Pocatello Compressor Station does not have equipment that
processes or transfers a liquid or gas with 10% VHAP. Therefore, the provisions of Subpart V do
not apply and the remaining delegated Subparts do not apply.
40 CFR Part 63 Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for
Reciprocating Internal Combustion Engines
NESHAP Subpart 7777 applies to stationary reciprocating internal combustion engines (RICE) at major or
area sources of HAP emissions.
The Pocatello Compressor Station is a major source of HAPs and operates the following RICE:
• (3) 2,000 and (1) 3,400 hp 2SLB SI RICE
• 400 hp 4SRB SI RICE
CONCLUSIONS:
Applicability:
The three (3) 2,000 hp and one (1) 3,400 hp 2SLB RICE are considered existing stationary RICE and
are not subject because:
• The engines have a site rating greater than 500 hp, are at a major source of HAPs and commenced
construction prior to June 12, 2006, as per§ 63.6590 (a)(1)(i).
The 400 hp 4SRB emergency backup RICE is considered an existing stationary RICE because:
• The engine has a site rating less than 500 hp, is at a major source of HAPs and commenced
construction prior to June 12, 2006, as per§ 63.6590 (a)(1)(H).
Emission and Operating Limitations:
The three (3) 2,000 hp and one (1) 3,400 hp 2SLB RICE are not subject to any limitations under
subpart ZZZZ.
The 400 hp emergency RICE is subject to the maintenance requirements as described in Table 2c,
Item #6. The RICE is not subject to a numerical emission limitation. The maintenance
requirements include the following:
• Change oil and filter every 500 hours of operation or annually, whichever comes first;
inspect spark plugs every 1,000 hours of operation or annually, whichever comes first;
inspect all hoses and belts every 500 hours of operation or annually, whichever comes
first, and replace as necessary.
Northwest Pipeline
Pocatello Compressor Station
Federal Requirements Applicability 7
Page 91 of 270
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Testing and Initial Compliance Requirements:
The engine maintenance and operation practices will be consistent with good air pollution control
practices for minimizing emissions. A non-resettable hour meter is installed on each emergency
RICE and idle startup time shall not exceed 30 minutes as per§ 63.6625(f) and (h).
The Facility RICE engines are subject to the requirements identified in item #6 in Table 2c in this
subpart as listed above. The Facility has the option of utilizing an oil analysis program in order to
extend the specified oil change requirements. If this oil analysis program option is selected it will
be part of the Facility engine maintenance plan.
The Facility understands that the emergency RICE may be operated for the purpose of
maintenance checks and readiness testing no more than 100 hours per year as per § 63.6640.
Additional run hours for maintenance checks and readiness testing may be petitioned for approval
by the Administrator.
The Facility understands that the emergency RICE may be operated up to 50 hours per year in non-
emergency situations and count towards the 100 hours run time per year for maintenance checks
and readiness testing as per § 63.6640 (f)(iii). The Facility will maintain records of the emergency
RICE run time hours and the purposes for emergency engine operation as per § 63.6640. The
Facility emergency RICE do not have the ability to supply electrical power to another entity beyond
the Facility property boundary.
Notifications. Reports, and Records:
Northwest Pipeline LLC understands that the RICE engine is not subject to Initial Notification
requirements because the engine is classified as existing emergency RICE and is not subject to
any numerical emission standard as per § 63.6645 (a)(5).
The Facility will maintain work or management practice records for the emergency RICE. These
engine operation practices will be consistent with good air pollution control practices for
minimizing emissions as per § 63.6625 (e)(2). The Facility will maintain records of the hours of
operation for each engine as recorded on the non-resettable hour meter. Records will include run
hours for emergency operation, the classification of the emergency and hours run for non-
emergency operation as per § 63.6655. Records will be maintained by the Facility for a period of
five years.
40 CFR Part 63 Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for Major
Sources: Industrial. Commercial. Institutional Boilers and Process Heaters
NESHAP Subpart DDDDD applies to Industrial Boilers and Process Heaters at major sources of HAP
emissions.
The Pocatello Compressor Station is a major source of HAPs and operates the following:
• 3.35 MMBtu/hr Boiler and a 0.5 MMBtu/hr Fuel Gas Heater
Applicability:
Northwest Pipeline
Pocatello Compressor Station
Federal Requirements Applicability 8
Page 92 of 270
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The 3.35 MMBtu/hr Boiler and 0.5 MMBtu/hr Fuel Gas Heater are considered existing Boilers and
are subject because:
• The boiler and fuel gas heater burn gas 1 fuels, have a heat input capacity of less than or
equal to 5 MMBtu/hr and were installed prior to May 20, 2011.
Emission and Operating Limitations:
The boilers do not have any emission limitations. However, Northwest Pipeline must comply with
the work practice standards in Table 3 of Subpart DDDDD. Table 3 requires a bi-ennial tune-up for
the 3.35 MMBtu/hr Boiler as specified in §63.7540. In addition, because the facility is a major
source of HAP's, a one-time energy assessment must be conducted at the facility.
Testing and Initial Compliance Requirements:
The boiler maintenance and operation practices will be consistent with good air pollution control
practices for minimizing emissions.
The boilers are not subject to any emission limitations, therefore, no emission testing is required.
Notifications. Reports, and Records:
On May 29, 2013, Northwest Pipeline LLC provided an initial notification of Applicability to EPA
Region 10 and IDEQ for the boiler at the Pocatello Compressor Station. The boiler tune-up and the
energy assessment will be completed in 2015 and will be kept on file.
40 CFR Part 64 - Compliance Assurance Monitoring (CAM)
Part 64 applies to a pollutant-specific emissions unit at a major source that is required to obtain a part
70 or 71 permit if the unit satisfies all of the following criteria:
(1) The unit is subject to an emission limitation or standard for the applicable regulated air pollutant
(or a surrogate thereof), other than an emission limitation or standard that is exempt under
paragraph (b)(1) of this section;
(2) The unit uses a control device to achieve compliance with any such emission limitation or
standard; and
(3) The unit has potential pre-control device emissions of the applicable regulated air pollutant that
are equal to or greater than 100 percent of the amount, in tons per year, required for a source to
be classified as a major source. For purposes of this paragraph, "potential pre-control device
emissions" shall have the same meaning as "potential to emit," as defined in §64.1, except that
emission reductions achieved by the applicable control device shall not be taken into account.
Northwest Pipeline
Pocatello Compressor Station
Federal Requirements Applicability
9
Page 93 of 270
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40 CFR 64.2(b)(1)(i) states that the requirements of this part do not apply to emission limitations or
standards proposed by the Administrator after November 15,1990 pursuant to section 111 or 112 of
the Act.
Conclusion: The Pocatello Compressor Station has a total of four regulated natural gas driven
compressor engines as listed on page on one of this review. None of the engines have add-on
control devices to achieve compliance with an emission limit or standard. Therefore, Part 64
does not apply.
40 CFR Part 98 - Mandatory Greenhouse Gas Reporting. Subpart A. Subpart C & Subpart W
Subpart A of the Mandatory Greenhouse Gas Reporting rule applies to General Provisions that define the
purpose and scope, what types of facilities must report and establishes mandatory greenhouse gas (GHG)
reporting requirements for owners and operators of facilities that directly emit GHG emissions.
Subpart C establishes reporting requirements for stationary fuel combustion sources. The subpart defines
this source category as, "devices that combusts solid, liquid, or gaseous fuel, generally for the purposes of
producing electricity, generating steam, or providing useful heat or energy for industrial, commercial, or
institutional use, or reducing the volume of waste by removing combustible matter" [§98.30(a)]. The
definition also states that portable equipment, emergency generators and emergency equipment, as
defined in §98.6 are not included in Subpart C.
The rule requires monitoring, recordkeeping, and reporting for facilities where the aggregate maximum
rated heat input capacity of the stationary fuel combustion units at the facility is 30 MMBtu/hr or greater,
and the facility emits 25,000 metric tons (MT) carbon dioxide equivalent (C02e) or more per year in
combined emissions from all stationary fuel combustion sources [§98.2(a)(3)].
On November 8, 2010, EPA signed a rule that finalized greenhouse gas (GHG) reporting requirements for
the petroleum and natural gas industry under 40 CFR Part 98 Subpart W. Facilities must report GHG
emissions if they meet the definition of one of the identified industry segments and emit 25,000 metric tons
of carbon dioxide equivalent (MT C02e) or more per year in combined GHG emissions.
Onshore Natural Gas Transmission Compression is a Subpart W industry segment and, is defined as any
stationary combination of compressors that move natural gas at elevated pressure from production fields
or natural gas processing facilities in transmission pipelines to natural gas distribution pipelines or into
storage.
Conclusion: The Pocatello Compressor Station is subject to the requirements of 40 CFR Part 98
Subpart A, C & W. Actual fuel combustion estimates and associated emissions are performed
annually. The aggregate maximum heat input capacity of the stationary fuel combustion units is
greater than 30 MMBtu/hr and potential COze emissions is greater than 25,0000 MT. The facility
meets the definition of the transmission compression industry segment and is subject to Subpart
W if actual emissions from Subpart C sources and Subpart W sources exceed 25, 000 MT C02e. If
the facility is subject to Subpart C or W the facility is also subject to Subpart A.
Northwest Pipeline
Pocatello Compressor Station
Federal Requirements Applicability 1 (
Page 94 of 270
-------
United States
Environmental Protection
M m Agency
OMB No. 2060-0336,
Approval Expires 05/31/2019
Federal Operating Permit Program (40 CFR Part 71)
INSIGNIFICANT EMISSIONS (IE)
On this page list each insignificant activity or emission unit. In the "number" column, indicate the number
of units in this category. Descriptions should be brief but unique. Indicate which emissions criterion of
part 71 is the basis for the exemption.
Number
Description of Activities or Emissions Units
RAP
(except HAP)
HAP
1
70 Barrel Used Oil Tank
X
1
280 Barrel Lube Oil Tank
X
1
1250 Gallon Scrubber Oil Tank
X
EPA Form 5900-83
Page 95 of 270
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OMB Control No. 2060-0336
U.S. ENVIRONMENTAL PROTECTION AGENCY
APPLICATION FOR FEDERAL OPERATING PERMIT, 40 CFR PART 7]
FORM I-COMP - INITIAL COMPLIANCE PLAN & COMPLIANCE CERTIFICATION
INSTRUCTIONS: There are 3 pages to this form. On this page, complete Sections A, B, and C for each applicable requirement.
If different portions of an applicable requirement or compliance methods vary from unit to unit, prepare a separate form for each
unique set of requirements, methods, and units. For compliance plan purposes, assume permit issuance will occur by March 22,
2001, unless you are not required to submit an application until after March 22. 2000, in which case assume issuance will occur no
later than 18 months after submittal.
A. COMPLIANCE STATUS OF EACH APPLICABLE REQUIREMENT (Describe each applicable requirement and determine its compliance status)
Cite and Describe the Applicable Requirement
Unit ID(s):
Compliance status at
4 0 CFR
Part 49 Section 124 Rule for Limiting
Units 1-4
time of application :
Visible
Emissions
Generator
X In Compliance
Not In Compliance
B. METHODS USED TO DETERMINE COMPLIANCE (Describe all methods you used to determine compliance with this requirement)
The fuel usacre will be monitored to ensure that natural eras is the
sole fuel source for these units.
C. COMPLIANCE PLAN STATEMENTS (Respond to one of these statements for this applicable requirement)
1. If in compliance at this time,
I will continue to comply.
Yes No
2. If not in compliance at this time, 1 will be in
compliance by expected date of permit issuance.
Yes No Expected Date / /
3. For future-effective requirements. I
will meet this requirement on a timely
basis.
X Yes No
A. COMPLIANCE STATUS OF EACH APPLICABLE REQUIREMENT (Describe each applicable requirement and determine its compliance status)
Cite and Describe the Applicable Requirement
Unit ID(s):
Compliance status at
40 CFR Part 49 Section 125 Rule for Limiting
Units 1-4
lime of application :
the Emissions of Particulate Matter
Generator
X In Compliance
Not In Compliance
B. METHODS USED TO DETERMINE COMPLIANCE (Describe all methods you used to determine compliance with the requirement)
The fuel usage will be monitored to ensure that natural gas is the
sole fuel source for these units.
C. COMPLIANCE PLAN STATEMENTS (Respond to one of these statements for this applicable requirement)
1. If in compliance at this time,
I will continue to comply.
Yes
No
1. If not in compliance at this time. I will be in
compliance by expected date of permit issuance.
Yes No Expected Date / /
3. For future-effective requirements. I
will meet this requirement on a timely
basis.
X Yes No
Page 96 of 270
-------
FORM I-COMP (CONTINUED) 2
P. ADDITIONAL INFORMATION FOR COMPLIANCE PLAN STATEMENT #2
Compleie this section if you answered "YES" to the second statement in Section C. Complete this section for each such
applicable requirement. Identify the applicable requirement and describe the actions you will take prior to permit issuance to come
into compliance.
1. Applicable Requirement.
Unit(s) Applicable Requirement ___
2. Narrative Description or how Source will Achieve Compliance.
E. SCHEDULE OF COMPLIANCE
Complete this section if you answered "NO" to any of the statements in Section C. Complete this section for each such
applicable requirement. Identify the emission unit and the applicable requirement, the reasons for noncompliance, and describe
how the source will achieve compliance. If there are consent decrees or administrative orders that apply to this requirement,
attach a copy of them to this form. Finally, all sources required to complete this section must include a detailed schedule of
compliance.
1. Applicable Requirement
Unit(s) Applicable Requirement
2. Reason Tor Noncompliance. Briefly explain why the source will not be in compliance at lime of permit issuance or not meet future-
effective requirements on a timely basis.)
3. Narrative Description of how Source will Achieve Compliance. Briefly explain what you wilt do to bring the source into compliance
with this requirement.
4. Consent Decrees or Administrative Orders. Please attach a copy of any judicial consent decrees or administrative orders for this
applicable requirement.
5. Schedule of Compliance. Provide a schedule of remedial measures, including an enforceable sequence of actions with milestones, leading
to compliance, including a date for final compliance.
Remedial Measure or Action Date to be Achieved
Page 97 of 270
-------
FORM I-COMP (CONTINUED)
INSTRUCTIONS: Complete sections E, F, and G once for each facility.
F. SCHEDULE FOR SUBMISSION OF PROGRESS REPORTS
This section need only be prepared if you arc required to submit one or more schedules of compliance (by completing section E) or if an applicable
requirement requires you to submit a progress report. For most sources, the time frame for submittal of progress reports will be at least every 6
months. One progress report may include information on multiple schedules of compliance.
Contents of Progress Report (describe)
Report Starling date / / Submittal Frequency
Contents of Progress Report (describe)
Report Starting date / / Submittal Frequency
G. SCHEDULE FOR SUBMISSION OF COMPLIANCE CERTIFICATIONS
This section must be prepared by every source. Indicate how often you are required to submit compliance certifications after your
permit is issued and when the first one will be submitted. Compliance certifications are required to be submitted at least once per
year during the term of the permit.
Frequency of submittal Annul ell Beginning 10 /17 / 02
H. COMPLIANCE STATUS FOR ENHANCED MONITORING AND COMPLIANCE CERTIFICATION REQUIREMENTS
This section of the form must be completed for every source. Indicate compliance status for the requirement as a whole (to
certify compliance with the requirement as a whole, you must be able to certify compliance with each individual requirement that
can be categorized under this designation).
Enhanced Monitoring Requirements: NA In Compliance Not In Compliance
Compliance Certification Requirements: X In Compliance Not In Compliance
Page 98 of 270
-------
OMB Control No. 2060-0336
U.S. ENVIRONMENTAL PROTECTION AGENCY
APPLICATION FOR FEDERAL OPERATING PERMIT, 40 CFR PART 71
FORM l-COMP - INITIAL COMPLIANCE PLAN & COMPLIANCE CERTIFICATION
INSTRUCTIONS: There are 3 pages to this form. On this page, complete Sections A, B, and C for each applicable requirement.
If different portions of an applicable requirement or compliance methods vary from unit to unit, prepare a separate form for each
unique set of requirements, methods, and units. For compliance plan purposes, assume permit issuance will occur by March 22,
2001, unless you are not required to submit ail application until after March 22, 2000, in which case assume issuance will occur no
later than 18 months after submittal.
A. COMPEIANCE STA TUS Ol' EACH APPLICABLE REQUIREMENT (Describe each applicable requirement and determine its compliance status)
Cite and Describe the Applicable Requirement
Unit ID(s):
Compliance status at
40 CFR Part 49 Section 126 Rule for Limiting
Units 1-4
time of application :
Fugitive Particulate Matter Emissions
Generator
X In Compliance
Not In Compliance
B. METHODS USED TO DETERMINE COMPLIANCE (Describe all methods you used to determine compliance with this requirement)
A fugitive emissions complaint log will be maintained and complaints
will be investigated. Corrective actions will be listed in the log.
C. COMPLIANCE PLAN STATEMENTS (Respond to one of these statements for this applicable requirement)
1. If in compliance at this time,
I will continue to comply.
[f not in compliance at this time, 1 will be in
compliance by expected date of permit issuance.
Yes
No
Yes
No
Expected Date
3. For future-effective requirements. 1
will meet this requirement on a timely
basis.
X Yes No
A. COMPLIANCE STATUS OF EACH APPLICABLE REQUIREMENT (Describe each applicable requirement and determine its compliance status)
Cite and Describe the Applicable Requirement
Unit ID(s):
Compliance status at
40 CFR 49 Section 129 and 130 Rule for
Units 1-4
time of application :
Limiting Emissions of Sulfur Dioxide and Rule
Generator
X In Compliance
for Limiting Sulfur in Fuels
Not In Compliance
B. METHODS USED TO DETERMINE COMPLIANCE (Describe all methods you used to determine compliance with the requirement)
The fuel usage will be monitored to ensure that natural gas is the
sole fuel source for these units. The sulfur gas tariff specification
nf 70 grains/1 nn r.nhi r. feet will hp mpt
C. COMPLIANCE PLAN STATEMENTS (Respond to one of these statements for this applicable requirement)
1. If in compliance at this time,
2.
If not in compliance at this time, 1 will be in
3. For future-effective requirements. I
I will continue to comply.
compliance by expected date of permit issuance.
will meet this requirement on a timely
basis.
X Yes No
Yes No Uxpected Date / /
Yes No
Page 99 of 270
-------
FORM I-COMP (CONTINUED) 2
). ADDITIONAL INFORMATION FOR COMPLIANCE PLAN STATEMENT #2
Complete this section if you answered "YES" to the second statement in Section C. Complete this section for each such
applicable requirement. Identify the applicable requirement and describe the actions you will lake prior to permit issuance to come
into compliance.
1. Applicable Requirement.
Unit(s) Applicable Requirement
2. Narrative Description of how Source will Achieve Compliance*
E. SCHEDULE OF COMPLIANCE
Complete this section if you answered "NO" to any of the statements in Section C. Complete this section for each such
applicable requirement. Identify the emission unit and the applicable requirement, the reasons for noncompliance, and describe
how the source will achieve compliance. If there are consent decrees or administrative orders that apply to this requirement,
attach a copy of them to this form. Finally, all sources required to complete this section must include a detailed schedule of
compliance.
L Applicable Requirement
Unit(s) Applicable Requirement
2. Reason for Noncompliance. Briefly explain why the source will not be in compliance at time of permit issuance or not meet future-
effective requirements on a timely basis.)
3. Narrative Description of how Source will Achieve Compliance. Briefly explain what you will do to bring the source into compliance
with this requirement.
4. Consent Decrees or Administrative Orders. Please attach a copy of any judicial consent decrees or administrative orders for this
applicable requirement.
5. Schedule of Compliance. Provide a schedule of remedial measures, including an enforceable sequence of actions with milestones, leading
to compliance, including a date for final compliance.
Remedial Measure or Action Date to be Achieved
Page 100 of 270
-------
FORM I-COMP (CONTINUED)
INSTRUCTIONS: Complete sections K, F, and G once for each facility.
F. SCHEDULE FOR SUBMISSION OF PROGRESS REPORTS
This section need only be prepared if you arc required to submit one or more schedules of compliance (by completing section E) or if an applicable
requirement requires you to submit a progress report. For most sources, the time frame for submittal of progress reports will be at least every 6
months. One progress report may include information on multiple schedules of compliance.
Contents of Progress Report (describe)
Report Starting date / / Submittal Frequency
Contents of Progress Report (describe)
Report Starting dale / / Submittal Frequency
G. SCHEDULE FOR SUBMISSION OF COMPLIANCE CERTIFICATIONS
This section must be prepared by every source. Indicate how often you arc required to submit compliance certifications after your
permit is issued and when (he first one will be submitted. Compliance certifications are required to be submitted at least once per
year during the term of the permit.
Frequency of submittal S8rni~cinnUcil Beginning 1 0 /I 7 / Q 2
H. COMPLIANCE STATUS FOR ENHANCED MONITORING AND COMPLIANCE CERTIFICATION REQUIREMENTS
This section of the form must be completed for every source. Indicate compliance status for the requirement as a whole (to
certify compliance with the requirement as a whole, you must be able to certify compliance with each individual requirement that
can be categorized under this designation).
Enhanced Monitoring Requirements: NA In Compliance Not In Compliance
Compliance Certification Requirements: X In Compliance Not In Compliance
Page 101 of 270
-------
OMB Control No. 2060-0336
U.S. ENVIRONMENTAL PROTECTION AGENCY
APPLICATION FOR FEDERAL OPERATING PERMIT, 40 CFR PART 71
FORM I-COMP - INITIAL COMPLIANCE PLAN & COMPLIANCE CERTIFICATION
INSTRUCTIONS: There are 3 pages to this form. On this page, complete Sections A, B, and C for each applicable requirement.
If difFerent portions of an applicable requirement or compliance methods vary from unit to unit, prepare a separate form for each
unique set of requirements, methods, and units. For compliance plan purposes, assume permit issuance will occur by March 22,
2001, unless you are not required to submit an application until after March 22, 2000, in which case assume issuance will occur no
later than 18 months after submittal.
Cite and Describe the Applicable Requirement
40 CFR Part 49 Section 135 Rule for Emissions
Detrimental to Public Health or Welfare
Unit ID(s):
Units 1-4
Generator
Compliance status at
time of application :
X In Compliance
Not In Compliance
B. METHODS USED TO DETERMINE COMPLIANCE (Describe all methods you used to determine compliance with this requirement)
Williams will operate in accordance with the Pocatello
Compressor Station's Part 71 operating permit.
C. COMPLIANCE PLAN STATEMENTS (Respond to one of these statements for this applicable requirement)
1. If in compliance at this time,
I will continue to comply.
X Yes No
2. If not in compliance at this time, 1 will be in
compliance by expected date of permit issuance.
Yes No Expected Date / /
3. For future-effective requirements. I
will meet this requirement on a timely
basis.
Yes No
A. COMPLIANCE STATUS OF EACH APPLICABLE REQUIREMENT (Describe each applicable requirement and determine its compliance status)
Cite and Describe the Applicable Requirement
40 CFR Part 49 Section 137 Rule for Air
Pollution Episodes
Unit lD(s):
Units 1-4
Generator
Compliance status at
time of application :
X In Compliance
Not In Compliance
B. METHODS USED TO DETERMINE COMPLIANCE (Describe all methods you used to determine compliance with the requirement)
Natural gas will be the only fuel burned in these units at the
PocatelTo Compressor Station.
C. COMPLIANCE PLAN STATEMENTS (Respond to one of these statements for this applicable requirement)
1. If in compliance al this time,
I will continue to comply.
2. If not in compliance at this time, I will be in
compliance by expected date of permit issuance.
X Yes
No
Yes
No
Expected Date
3. For future-effective requirements. I
will meet this requirement on a timely
basis.
Yes No
Page 102 of 270
-------
FORM I-COMP (CONTINUED) 2
>. ADDITIONAL INFORMATION FOR COMPLIANCE PLAN STATEMENT #2
Complete this section if you answered "YES" to the second statement in Section C. Complete this section for each such
applicable requirement. Identify the applicable requirement and describe the actions you will take prior to permit issuance lo come
into compliance.
1. Applicable Requirement.
Unii(s) Applicable Requirement
2. Narrative Description of how Source will Achieve Compliance.
E. SCHEDULE OF COMPLIANCE
Complete this section if you answered "NO" to any of the statements in Section C. Complete this section for each such
applicable requirement. Identify the emission unit and the applicable requirement, the reasons for noncompliance, and describe
how the source will achieve compliance. If there are consent decrees or administrative orders that apply to this requirement,
attach a copy of them to this form. Finally, all sources required to complete this section must include a detailed schedule of
compliance.
Applicable Requirement
Unit(s)
Applicable Requirement
Reason for Noncompliance. Briefly explain why the source will not be in compliance at time of permit issuance or not meet future-
effective requirements on a timely basis.)
Narrative Description of how Source will Achieve Compliance. Briefly explain what you will do to bring the source into compliance
with this requirement.
Consent Decrees or Administrative Orders. Please attach a copy of any judicial consent decrees or administrative orders for this
applicable requirement.
Schedule of Compliance. Provide a schedule of remedial measures, including an enforceable sequence of actions with milestones, leading
to compliance, including a date for final compliance.
Remedial Measure or Action
Date to be Achieved
Page 103 of 270
-------
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Page 104 of 270
-------
OMB Control No. 2060-0336
U.S. ENVIRONMENTAL PROTECTION AGENCY
APPLICATION FOR FEDERAL OPERATING PERMIT. 40 CFR PART 71
FORM l-COMP - INITIAL COMPLIANCE PLAN & COMPLIANCE CERTIFICATION
INSTRUCTIONS; There are 3 pages to this form. On this page, complete Sections A, B, and C for each applicable requirement.
If different portions of an applicable requirement or compliance methods vary from unit to unit, prepare a separate form for each
unique set of requirements, methods, and units. For compliance plan purposes, assume permit issuance will occur by March 22,
2001, unless you are not required to submit an application until after March 22, 2000, in which case assume issuance will occur no
later than 18 months after submittal.
A. COMPLIANCE STATUS OF EACH APPLICABLE REQUIREMENT (Describe each applicable requirement and determine its compliance status)
Cite and Describe the Applicable Requirement
Unit lD(s):
Compliance status at
40 CFR Part 49 Section 138 Rule for the
Units 1-4
time of application :
Registration of Air Pollution Sources and the
Generator
X_ In Compliance
Reporting of Emissions
Not In Compliance
B. METHODS USED TO DETERMINE COMPLIANCE (Describe all methods you used to determine compliance with this requirement)
Williams will submit an annual registration report to the EPA.
C. COMPLIANCE PLAN STATEMENTS (Respond to one of these statements for this applicable requirement)
I. If in compliance at this time,
1 will continue to comply.
X Yes No
2. If not in compliance at this time, I will be in
compliance by expected date of permit issuance.
Yes No Expected Dale / /
3. For fiiture-eflective requirements. I
will meet this requirement on a timely
basis.
Yes No
A, COMPLIANCE STATUS OF EACH APPLICABLE REQUIREMENT (Describe each applicable requirement and determine its compliance status)
Cite and Describe the Applicable Requirement
Unit ID(s):
Compliance status at
40 CFR Part 49 Sections 122, 127, 128, 131,
time of application :
132, 133, 134 and 139
In Compliance
Not In Compliance
B. METHODS USED TO DETERMINE COMPLIANCE (Describe all methods you used to determine compliance with the requirement)
These FARR requirements are not applicable.
C~ COMPLIANCE PLAN STATEMENTS (Respond to one of these statements for this applicable requirement)
1. If in compliance at this time,
I will continue to comply.
Yes No
2. If not in compliance at this time, I will be in
compliance by expected date of permit issuance.
Yes No Expected Date / /
3. For future-effective requirements. I
will meet this requirement on a timely
basis.
Yes No
Page 105 of 270
-------
FORM I-COMP (CONTINUED)
D, ADDITIONAL INFORMATION FOR COMPLIANCE PLAN STATEMENT #2
Complete this section if you answered "YES" to the second statement in Section C. Complete this section for each such
applicable requirement. Identify the applicable requirement and describe the actions you will take prior to permit issuance to come
into compliance.
Applicable Requirement.
Unit(s)
Applicable Requirement
Narrative Description of how Source will Achieve Compliance.
E. SCHEDULE OF COMPLIANCE
Complete this section if you answered "NO" to any of the statements in Section C. Complete this section for each such
applicable requirement. Identify the emission unit and the applicable requirement, the reasons for noncompliance, and describe
how the source will achieve compliance. If there are consent decrees or administrative orders that apply to this requirement,
attach a copy of them to this form. Finally, all sources required to complete this section must include a detailed schedule of
compliance.
1. Applicable Requirement
Unit(s)
Applicable Requirement
2.
Reason for Noncompliance. Briefly explain why the source will not be in compliance at time of permit issuance or not meet future-
effective requirements on a timely basis.)
Narrative Description of how Source will Achieve Compliance. Briefly explain what you will do to bring the source into compliance
with this requirement.
Consent Decrees or Administrative Orders. Please attach a copy of any judicial consent decrees or administrative orders for this
applicable requirement.
Schedule of Compliance. Provide a schedule of remedial measures, including an enforceable sequence of actions with milestones, leading
to compliance, including a date for final compliance.
Remedial Measure or Action
Date to be Achieved
Page 106 of 270
-------
FORM I-COMP (CONTINUED)
INSTRUCTIONS: Complete sections E, F, and G once for each facility.
F. SCHEDULE FOR SUBMISSION OF PROGRESS REPORTS
This section need only be prepared if you arc required to submit one or more schedules of compliance (by completing section E) or if an applicable
requirement requires you to submit a progress report. For most sources, the time frame for submittal of progress reports will be at least every 6
months. One progress report may include information on multiple schedules of compliance.
Contents of Progress Report (describe)
Report Starting date / / Submittal Frequency
Contents of Progress Report (describe)
Report Starting date / / Submittal Frequency
11. SCHEDULE FOR SUBMISSION OF COMPLIANCE CERTIFICATIONS
This section must be prepared by every source. Indicate how often you arc required to submit compliance certifications after your
permit is issued and when the first one will be submitted. Compliance certifications are required to be submitted at least once per
year during the term of the permit.
Frequency of submittal Ssrni~a.nnUa.l Beginning 10/17/02
H. COMPLIANCE STATUS FOR ENHANCED MONITORING AND COMPLIANCE CERTIFICATION REQUIREMENTS
This section of the form must be completed for every source. Indicate compliance status for the requirement as a whole (to
certify compliance with the requirement as a whole, you must be able to certify compliance with each individual requirement that
can be categorized under this designation).
Enhanced Monitoring Requirements: NA In Compliance Not In Compliance
Compliance Certification Requirements: X In Compliance Not In Compliance
Page 107 of 270
-------
OMB Control No. 2060-0336
U.S. ENVIRONMENTAL PROTECTION AGENCY
APPLICATION FOR FEDERAL OPERATING PERMIT, 40 CFR PART 71
FORM l-COMP - INITIAL COMPLIANCE PLAN & COMPLIANCE CERTIFICATION
INSTRUCTIONS: There arc 3 pages to this form. On this page, complete Sections A, B, and C for each applicable requirement.
If different portions of an applicable requirement or compliance methods vary from unit to unit, prepare a separate form for each
unique set of requirements, methods, and units. For compliance plan purposes, assume permit issuance will occur by March 22,
2001, unless you are not required to submit an application until after March 22, 2000, in which case assume issuance will occur no
later than 18 months after submittal.
Cite and Describe the Applicable Requirement
Unit ID(s):
Compliance status at
Maximum Achievable Control Technology (MACT)
Units 1-4
lime of application :
standards for Reciprocating Internal Combustion
Generator
X In Compliance
Engines (RICE) to reduce Haz. Air Poll. (HAPs)
Not In Compliance
B. METHODS USED TO DETERMINE COMPLIANCE (Describe all methods you used to determine compliance with this requirement)
A letter was sent December 1, 2004 documenting compliance. The
applicability determination will he maintained onsite for any local
state or federal air quality aaencv to inspect.
C. COMPLIANCE PLAN STATEMENTS (Respond to one of these statements for this applicable requirement)
1. If in compliance at this time,
I will continue to comply.
If not in compliance at this time. 1 will be in
compliance by expected date of permit issuance.
X Yes
No
Yes
No
Expected Date
3. For future-effective requirements. I
will meet this requirement on a timely
basis.
Yes No
A. COMPLIANCE STATUS OF EACH APPLICABLE REQUIREMENT (Describe each applicable requirement and determine its compliance status)
Cite and Describe the Applicable Requirement
Unit ID(s):
Compliance status at
time of application :
In Compliance
Not In Compliance
B. METHODS USED TO DETERMINE COMPLIANCE (Describe all methods you used to determine compliance with the requirement)
C« COMPLIANCE PLAN STATEMENTS (Respond to one of these statements for this applicable requirement)
I. If in compliance at this time,
I will continue to comply.
2, If not in compliance at this time, 1 will be in
compliance by expected date of permit issuance.
Yes
No
Yes
No
Expected Date
3. For future-effective requirements. 1
will meet this requirement on a timely
basis.
Yes No
Page 108 of 270
-------
FORM I-COMP (CONTINUED)
D. ADDITIONAL INFORMATION FOR COMPLIANCE PLAN STATEMENT #2
Complete this section if you answered "YES" 10 the second statement in Section C. Complete this section for each such
applicable requirement. Identify the applicable requirement and describe the actions you will take prior to permit issuance to come
into compliance.
Applicable Requirement.
Unit(s)
Applicable Requirement
Narrative Description of how Source will Achieve Compliance.
E. SCHEDULE OF COMPLIANCE
Complete this section if you answered "NO" to any of the statements in Section C. Complete this section for each such
applicable requirement. Identify the emission unit and the applicable requirement, the reasons for noncompliance, and describe
how the source will achieve compliance. If there are consent decrees or administrative orders that appty to this requirement,
attach a copy of them to this form. Finally, all sources required to complete this section must include a detailed schedule of
compliance.
Applicable Requirement
Unit(s)
Applicable Requirement
Reason for Noncompliance. Briefly explain why the source will not be in compliance at time of permit issuance or not meet future-
effective requirements on a timely basis.)
Narrative Description of how Source will Achieve Compliance. Briefly explain what you will do to bring the source into compliance
with this requirement.
Consent Decrees or Administrative Orders. Please attach a copy of any judicial consent decrees or administrative orders for this
applicable requirement.
Schedule of Compliance. Provide a schedule of remedial measures, including an enforceable sequence of actions with milestones, leading
to compliance, including a date for final compliance.
Remedial Measure or Action
Date to be Achieved
Page 109 of 270
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FORM I-COMP (CONTINUED)
INSTRUCTIONS: Compleic sections K, F, and G once for each facility.
F. SCHEDULE FOR SUBMISSION OF PROGRESS REPORTS
This section need only be prepared if you are required to submit one or more schedules of compliance (by completing section F.) or if an applicable
requirement requires you to submit a progress report. For most sources, the time frame for submittal of progress reports will be at least every 6
months. One progress report may include information on multiple schedules of compliance.
Contents of Progress Report (describe)
Report Starting date / / Submittal Frequency
Contents of Progress Report (describe)
Report Starting date / / Submittal Frequency
G. SCHEDULE FOR SUBMISSION OF COMPLIANCE CERTIFICATIONS
This section must be prepared by every source. Indicate how often you are required to submit compliance certifications after your
permit is issued and when the first one will be submitted. Compliance certifications arc required to be submitted at least once per
year during the term of the permit.
Frequency of submittal S6mi~B.nnUB.l Beginning 10/17 /02
H. COMPLIANCE STATUS FOR ENHANCED MONITORING AND COMPLIANCE CERTIFICATION REQUIREMENTS
This section of the form must be completed for every source. Indicate compliance status for the requirement as a whole (to
certify compliance with the requirement as a whole, you must be able to certify compliance with each individual requirement that
can be categorized under this designation).
Enhanced Monitoring Requirements: NA in Compliance Not In Compliance
Compliance Certification Requirements: X In Compliance Not In Compliance
Page 110 of 270
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POTENTIAL EMISSIONS FROM RECIPROCATING ENGINES
Pocatello Compressor Station
Potential Emissions From Clark TLA-6 Reciprocating Engines (Unit 1, 2 and 3)
Pollutant
Emission
Factor
Units
Potential
Emission Rate
(tpy)
Potential Emission
Rate (Ib/hr)
Potential
Emission
Rate
(Ib/yr)
NOx
59.32
a Ib/hr
259.82
59.32
519,643
CO
4.22
a Ib/hr
18.48
4.22
36,967
S02
20
b gr/100 ft3
3.63
0.83
7,263
VOC
1.77
a Ib/hr
7.75
1.77
15,505
PM Filterable and
Condensable
4.83E-02
blb/MMBTU
3.13
0.71
6,262
Formaldehyde
5.52E-02
b Ib/MMBTU
3.58
0.82
7,157
Total HAPs
7.95E-02
b Ib/MMBTU
5.16
1.18
10,312
a Based on emission factors from the June 1998 emissions test
b Based on the William's Northwest Pipeline tariff specification of 20grains/100SCF
c Based on the July 2000 AP-42 Table 3.2-1 Uncontrolled Emission Factors for 2-Stroke Lean-Burn Engines
Assumptions
14.8 MMBTU/hr-natural gas input flowrate
14510 ft3/hr
8760 Potential Operating Hours Per Year
Calculations
Ib/hr = (20 gr/100ft3)*(fuel input rate ft3/hr)/(7000gr/lb)*[(64 Ib/lb-mol S02)/(32lb/lb-mol S)}
Ib/hr = (emission factor lb/MMft3)/106 ft3/MMft3)*(fuel flow ft3/hr)
tpy = (emissions lb/hr)*(8760 hr/yr)/(2000 lb/ton)
tpy = [(N.G. EF lb/MMBTU)*(fuel flow MMBTU/hr)*(8760 hr/yr)]/(2000 lb/ton)
Page 111 of 270
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POTENTIAL EMISSIONS FROM RECIPROCATING ENGINES
Pocatello Compressor Station
Potential Emissions From Clark TCV-10 Reciprocating Engine (Unit 4)
Pollutant
Emission
Factor
Units
Potential
Emission
Rate (tpy)
Potential
Emission
Rate (Ib/hr)
Potential
Emission
Rate (Ib/yr)
NOx
102.51
a Ib/hr
448.99
102.51
897,988
CO
21.06
a Ib/hr
92.24
21.06
184,486
S02
20
b gr/100 ft3
5.34
1.22
10,671
VOC
1.43
a Ib/hr
6.26
1.43
12,527
PM Filterable and
Condensable
4.83E-02
c Ib/MMBTU
4.60
1.05
9,200
Formaldehyde
5.52E-02
c Ib/MMBTU
5.26
1.20
10,514
Total HAPs
7.95E-02
c Ib/MMBTU
7.57
1.73
15,149
a Based on emission factors from the June 1998 emissions test
b Based on the William's Northwest Pipeline tariff specification of 20grains/100SCF
c Based on the July 2000 AP-42 Table 3.2-1 Uncontrolled Emission Factors for 2-Stroke Lean-Burn Engines
Assumptions
21.743 MMBTU/hr-natural gas input flowrate
21317 ft3/hr
8760 Potential Operating Hours Per Year
Calculations
Ib/hr = (20 gr/100ft3)*(fuel input rate ft3/hr)/(7000gr/lb)*[(64 Ib/lb-mol S02)/(32lb/lb-mol S)
Ib/hr = (emission factor lb/MMft3)/106 ft3/MMft3)*(fuel flow ft3/hr)
tpy = (emissions lb/hr)*(8760 hr/yr)/(2000 lb/ton)
tpy = [(N.G. EF Ib/MMBTU )*(fuel flow MMBTU/hr)*(8760 hr/yr)]/(2000 lb/ton)
Page 112 of 270
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Potential Emissions from the Generator
Pocatello Compressor Station
Potential Emissions from Caterpillar 3408 Standby Generator
Pollutant
Emission Factor
Units
Potential Emission Rate (tpy)
NOx
2.21
a Ib/MMBTU
2.08
CO
3.72
a Ib/MMBTU
3.50
S02
5.88E-02
b Ib/MMBTU
0.06
VOC
2.96E-02
a Ib/MMBTU
0.03
PM Filterable and
Condensable
1.94E-02
a Ib/MMBTU
0.02
Formaldehyde
2.05E-02
a Ib/MMBTU
0.02
Total HAPs
3.24E-02
a Ib/MMBTU
0.03
a July 2000 AP-42 Table 3.2-3 Uncontrolled
Emission Factors for 4-Stroke Rich-Burn Engines
b Based on July 2000 AP-42 Table 3.2-1 Uncontrolled Emission Factors for 2-Stroke Lean-Burn Engines
and the William's Northwest Pipeline tariff specification of 20grains/100SCF.
Assumptions
3.76 MMBTU/hr-natural gas input flowrate based on an input heat rate of 9,400 BTU/hp-hr
400 hp-site rated output power
500 maximum annual operating hours
Calculations
tpy = [(N.G. EF lb/MMBTU)*(fuel flow MMBTU/hr)*(500 hr/yr)]/(2000 lb/ton)
Page 113 of 270
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Potential Emissions from the Boiler
Pocatello Compressor Station
Potential Emissions from Sellers C80W Boiler
Pollutant
Emission Factor
Units
Emission Factor
Units
Potential Emission Rate (tpy)
NOx a
100.0
Ib/MMscf3
9.80E-02
Ib/MMBTU
1.51
O
O
03
84.0
lb/MMscfa
8.24E-02
Ib/MMBTU
1.27
S02 b
60.0
Ib/MMscfb
5.88E-02
Ib/MMBTU
0.91
VOCb
5.5
Ib/MMscfc
5.39E-03
Ib/MMBTU
0.08
PM Filterable and
Condensableb
7.6
Ib/MMscfc
7.45E-03
Ib/MMBTU
0.11
Formaldehydec
7.50E-02
Ib/MMscfd
7.35E-05
Ib/MMBTU
1.13E-03
Total HAPs c
1.88E+00
Ib/MMscf d
1.85E-03
Ib/MMBTU
0.03
a Based on the July 1998 AP-42 Table 1.4-1
b Based on the July 1998 AP-42 Table 1.4-2 and the William's Northwest Pipeline tariff
specification of 20grains/100SCF
c Based on the July 1998 AP-42 Table 1.4-2
d Based on the July 1998 AP-42 Table 1.4-3 Total HAPs
Assumptions
3.5154 MMBTU/hr-natural gas input flowrate
1020 BTU/scf (based on the guideline provided in AP-42 Table 1.4-1)
8760 hours per year
Calculations
tpy = [(N.G. EF lb/MMBTU)*(fuel flow MMBTU/hr)*(8760 hr/yr)]/(2000 lb/ton)
Page 114 of 270
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Potential Emissions from the Sivaiis Line Heater
Pocatello Compressor Station
Potential Emissions from the Heater
Pollutant
Emission Factor
Units
Emission Factor
Units
Potential Emission Rate (tpy)
NOx a
100.0
Ib/MMscfa
9.80E-02
Ib/MMBTU
0.21
COa
84.0
lb/MMscfa
8.24E-02
Ib/MMBTU
0.18
S02 b
60.0
Ib/MMscfb
5.88E-02
Ib/MMBTU
0.13
VOCb
5.5
Ib/MMscfb
5.39E-03
Ib/MMBTU
0.01
PM Filterable and
Condensable b
7.6
Ib/MMscfb
7.45E-03
Ib/MMBTU
0.02
Formaldehydec
7.50E-02
Ib/MMscf0
7.35E-05
Ib/MMBTU
1.61E-04
Total HAPs0
1.88E+00
Ib/MMscf0
1.85E-03
Ib/MMBTU
4.04E-03
a Based on the July 1998 AP-42 Table 1.4-1
b Based on the July 1998 AP-42 Table 1.4-2 and the William's Northwest Pipeline tariff
specification of 20g rains/1 OOSCF
c Based on the July 1998 AP-42 Table 1.4-2
d Based on the July 1998 AP-42 Table 1.4-3 Total HAPs
Assumptions
0.50 MMBTU/hr-natural gas input flowrate
1020 BTU/scf (based on the guideline provided in AP-42 Table 1.4-1)
8760 hours per year (based on the actual hours of operation in 2000
Calculations
tpy = [(N.G. EF lb/MMBTU)*(fuel flow MMBTU/hr)*(8760 hr/yr)]/(2000 lb/ton)
Page 115 of 270
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ESTIMATION OF FUGITIVE EMISSIONS FROM THE FACILITY
Pocatello Compressor Station
Type of Component
Quantity3
Emission Factor13
kg/hr/source
TOC Emissions
VOC Emissions0
kg/hr
Ib/hr
tpy
Ib/hr
tpy
Valves
196
4.50E-03
8.82E-01
1.944
8.517
0.039
0.170
Flanges
245
3.90E-04
9.56E-02
0.211
0.923
0.004
0.018
Open-Ended Lines
27
2.00E-03
5.40E-02
0.119
0.521
0.002
0.010
Compressor
4
8.80E-03
3.52E-02
0.078
0.340
0.002
0.007
Blow-Down
3.50E+02
Mscf
0.180
Sum
0.39
a Quantity of the components are estimated based on an inventory performed at the Green River compressor
station, which is similar to the Pocatello compressor station in equipment and size.
b Emission factors are obtained from the document "Protocol for Equipment Leak Estimates," Emission
Standards Division, U.S. Environmental Protection Agency, November 1995 Table 2.4.
c Average weight fraction of VOC in the stream is estimated as 2.00%. VOC is calculated as Total Organic
Carbon (TOC) excluding methane and ethane.
d Blow-down emissions in tons per year are estimated using an average annual blowdown
Page 116 of 270
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TOTAL POTENTIAL EMISSIONS FROM THE FACILITY
Pocatello Compressor Station
Emission Sources with Significant Emission Levels
Pollutant
Unit 1 (tpy)
Unit 2 (tpy)
Unit 3 (tpy)
Unit 4 (tpy)
Generator
(tpy)
Total (tpy)
NOx
259.82
259.82
259.82
448.99
2.08
1230.54
CO
18.48
18.48
18.48
92.24
3.50
151.19
S02
3.63
3.63
3.63
5.34
0.06
16.29
VOC
7.75
7.75
7.75
6.26
0.03
29.55
PM Filterable and
Condensable
3.13
3.13
3.13
4.60
0.02
14.01
Formaldehyde
3.58
3.58
3.58
5.26
0.02
16.01
Total HAPs
5.16
5.16
5.16
7.57
0.03
23.07
Emission Sources with Insignificant Emission Levels
Pollutant
Boiler (tpy)
Line Heater
(tpy)
Fugitive
Emissions
(tpy)
Total (tpy)
NOx
1.51
0.21
-
1.72
CO
1.27
0.18
-
1.45
S02
0.91
0.13
-
1.03
VOC
0.08
0.01
0.39
0.48
PM Filterable and
Condensable
0.11
0.02
0.13
Formaldehyde
1.13E-03
1.61 E-04
—
0.00
Total HAPs
0.03
4.04E-03
—
0.03
Facility To
tals
Units 1-4 &
Other
Generator
Sources
Facility
Pollutant
(tpy)
(tpy)
PTE (tpy)
NOx
1228.46
3.80
1232.26
CO
147.69
4.95
152.64
S02
16.23
1.09
17.32
VOC
29.52
0.48
30.01
PM Filterable and
Condensable
13.99
0.15
14.14
Formaldehyde
15.99
0.02
16.01
Total HAPs
23.04
0.06
23.10
Page 117 of 270
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Source Info
Pollutant
Emission
Factor
Reference
Emission
Rate
Insignificant Heaters and Furnaces
Size: 1.179 MMBtu/hr
Hours: 8,760 hrs
Fuel Use 10.1 MMscf
NOx
94 Ibs/MMscf
AP42 Table 1.4-1
0.4759
tons/yr
CO
40 Ibs/MMscf
AP42 Table 1.4-1
0.2025
tons/yr
VOC
5.5 Ibs/MMscf
AP42 Table 1.4-2
0.0278
tons/yr
S02
0.60 Ibs/MMscf
AP42 Table 1.4-2
0.0030
tons/yr
PM10 & PM2.5
7.6 Ibs/MMscf
AP42 Table 1.4-2
0.0385
tons/yr
Formaldehyde
0.075 Ibs/MMscf
AP42 Table 1.4-3
0.0004
tons/yr
Total HAPs
1.89 Ibs/MMscf
AP42 Tables 1.4-3 & 1.4-4
0.0096
tons/yr
Page 118 of 270
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VOCs and HAPs from Blowdown Gas (350 Mscf Natural Gas Yearly Average)*
Wt. %
Pounds/Year
Tons/Year
VOC
1.9993
355.42
0.18
Hexane
0.0628
11.16
0.01
*5-Year average gas loss during annual ESD. Calculated and tracked by Northwest
Pipeline technicians at the Pocatello compressor station.
VOC=Gas Vented*Gas MW * wt. % VOC * Conversion
VOC=350 Mscf * 19.25 lb/lb mol * 1.9993% VOC * 1 lb mol/379 scf = lbs
Page 119 of 270
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EMISSION FACTORS for UNIT 1-3 TLA-6
1995 Data
1998 Data
Unit 1
Low Load
Mid Load
High Load
1995
Full Load
Reduced Load
1998
Average of
83% Torque
90% Torque
100% Torque
Average
99-100
74-92%
Average
1995 & 1998
Nox
ppmV @15% 02
470.6
858.5
585.2
638.10
1280.3
526.6
903.45
770.78
Nox
Ibs/hr
30.8
59
44
44.60
59.32
22.21
40.765
42.68
CO
ppmV @15% 02
163.6
134.7
107
135.10
149.9
155.9
152.9
144.00
CO
Ibs/hr
6.5
5.6
4.9
5.67
4.22
3.99
4.105
4.89
S02
ppmV@15%02
1.2
2.5
3.9
2.53
**
**
**
**
S02
Ibs/hr
0.1
0.2
0.4
0.23
**
**
**
**
1VOC
ppmV @15% 02
34.9
37.1
13
28.33
109.2
39.5
74.35
51.34
1VOC
Ibs/hr
0.8
0.9
0.3
0.67
1.77
0.58
1.175
0.92
Emission factors from stack testing data.
"No Data
11998 VOC data as % of THC by weight from fuel gas analysis and 1995 VOC data conservatively estimated from TNMHC Emissions
Page 120 of 270
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EMISSION FACTORS for UNIT 4 TCV-10
1995 Data
1998 Data
Unit 4
Low Load
Mid Load
High Load
1995
Full Load
Reduced Load
1998
Average of
78% Torque
92% Torque
104% Torque
Average
107-110%
83-88%
Average
1995 & 1998
Nox
ppmV @15% 02
500.7
863.6
1012.2
792.17
1141.6
659.1
900.35
846.26
Nox
Ibs/hr
47.9
91.1
123.1
87.37
102.51
48.68
75.595
81.48
CO
ppmV @15% 02
261.9
273.1
390
308.33
385
262
323.5
315.92
CO
Ibs/hr
15.3
17.5
28.9
20.57
21.06
11.78
16.42
18.49
S02
ppmV @15% 02
1.2
3.1
1.6
1.97
**
**
**
**
S02
Ibs/hr
0.2
0.4
0.3
0.30
**
*W
**
**
Voc
ppmV @15% 02
~*
*~
**
**
24.4
55.4
39.9
39.9
1voc
Ibs/hr
~*
*~
**
**
0.77
1.43
1.1
1.1
Emission factors from stack testing data.
** No data
11998 VOC data as % of THC by weight from fuel gas analysis and 1995 VOC data conservatively estimated from TNMHC Emissions
Page 121 of 270
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WillSamk
NORTHWEST PIPELINE
Environmental Services
205 Chipela Way, 3"> Floor
Salt Lake City, UT 84108-1220
November 4, 2019
Christopher Familiare
Air Permits and Toxics Branch
U.S. Environmental Protection Agency, Region 10
1200 Sixth Avenue, Suite 155,15-H13
Seattle, Washington 98101
Re: Air Quality Title V Permit Renewal
Pocatello Compressor Station - Permit# R10T5110100
Dear Mr. Familiars:
Northwest Pipeline LLC (Northwest) received your October 16, 2019 email where you requested
additional information. Below is the text of your email;
The Region 10 air permits team is currently processing your application. In the application,
Williams Northwest Pipeline states that each of its four stationary spark ignition internal
combustion engines at the Pocatello Compressor Station commenced construction prior to June
12, 2006, and therefore each is an existing facility not subject to the requirements of Subpart JJJJ
to 40 CFR Part 60 (Standards of Performance for Stationary Spark Ignition Internal Combustion
Engines), Applicability is not solely determined based upon the date construction of the facility
commenced. NSPS Subpart JJJJ may apply to an existing facility if it was subsequently modified
and/or reconstructed (as those terms are defined in 40 CFR 60,14 and 60.15, respectively) after
the June 12, 2006 cutoff. The NSPS modification and reconstruction general provisions apply
pursuant to Table 3 to NSPS Subpart JJJJ. Pursuant to 40 CFR 71.5(c)(5), we are requesting
additional information as to whether NSPS Subpart JJJJ is applicable to any of the four engines.
Using the CTAC form at https;//vv\w/.epa.qov/title-v-operatinq-oermits/certification-truth-accuracv-
and-completeness-ctac, please certify that none of the four engines have been modified and/or
reconstructed as those terms are defined in 40 CFR 80.14 and 60.15, respectively,
None of the four engines have been modified and/or reconstructed as those terms are defined in
40 CFR 60.14 and 60.15, respectively. The responsible official, Mr, Glen Jasek, has signed and
dated the CTAC,
Sincerely,
&
I ^-—7 I
Derek Forsberg
Environmental Specialist
Page 122 of 270
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OMB No, 2060-0336,
Approval Expires 05/31/2019
Federal Operating Permit Program (40 CFR Part 71)
CERTIFICATION OF TRUTH, ACCURACY, AND COMPLETENESS (CTAC)
This form must be completed, signed by the "Responsible Official" designated for the facility or
emission unit, and sent with each submission of documents (i.e., application forms, updates to
applications, reports, or any information required by a part 71 permit).
A. Responsible Official
B, Certification of Truth, Accuracy and Completeness (to be signed by the
responsible official)
I certify under penalty of law, based on information and belief formed after reasonable
inquiry, the statements and information contained in these documents are true, accurate
and complete.
Name: (Last) Jasek
Title VP GM Northwest Pipeline
Street or P.O. Box P.O. Box 58900
(First) Glen
(Ml)
City Salt Lake City
Telephone f 801 > 584- 6125 Ext.
State UT ZIP 84158 - 0900
Facsimile (
Name (typed)
Name (signed)
Date: J
EPA Form 5900-02
Page 123 of 270
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Williams
NORTHWEST PIPELINE LLC
Environmental Services
295 Chipeta Way, T> Floor
Salt Late city, UT 84108 -1220
January 31, 2020
Clean Air Act Compliance Manager
U.S. EPA - Region 10, 20-C04
1200 Sixth Avenue, Suite 155
Seattle, WA 98101-3188
RE: Northwest Pipeline LLC - Poeatello Compressor Station
MACT Subpart 1)1)1)1)1) Notification of Compliance Status REVISED
Dear Clean Air Act Compliance Manager:
This submittal serves as a modification to the Notification of CompHanee Status letter sent on
February 16, 2016, Christopher Pamiliare, EPA Permit Engineer, while working on the
Poeatello Title V permit renewal, identified necessary permit condition modifications and
requested that Williams submit this report, Additionally, the original submittal did not identity
the beginning and ending dates of the reporting period. The submittal meets Subpart 1)1)1)1)1)
notification requirements (40 CFR 63.7545) and Subpart A (40 CFR (>3.0(h)(2)) for the
Northwest Pipeline LLC (Northwest) - Poeatello Compressor Station (Facility) located at 2605
Gas Plant Road, Poeatello, Idaho.
This facility only burns natural gas which is subject to this subpart. The following existing
process heaters are Subpart 1)1)1)1)1) applicable, but because they only burn a gas 1 fuel they are
not subject to emission limits in 'Fables I and 2 or 11 through 13, or the operating limits in Table
4 per §63.7500(e):
Unit #
Uc;i(
3.35 MMBtu/hr
0.5 MMBtu/hr
Jirak'r ] ype
Existing Process
I [eater
Existing Process
11 eater
TuiU'-l |i Frequency
(Table 3 to SubfKirf
1 niji al; Every 5 years
Jnitial; Every 5 years
Northwest contracted Sage Environmental Consulting to conduct the energy assessment as
required by Subpart DDDDL), This facility has had an energy assessment performed according to
§63.7530(e), The Energy Assessment report was received by Northwest on September 9, 2015.
The report describes the evaluation of the affected process heaters as well as their major energy-
use systems, and identifies and assesses any potential practical energy conservation measures
Page 124 of 270
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available thai exhibited a simple payback of two (2) years or less. This Lnergy Assessment repurt
will be kept ai the facility's field offiee.
An email from Christopher Familiare to me oil January J1, 2020 outlined the following "I items
listed in eonditiori 0,6 of the Poeateilo Title V permit that are required in this submittal. A eopy
of the email is attached to this submittal. The conditions and responses arc shown below;
I) The Company and facility name and address.
Williams Corporation. Northwest Pipeline IXC
2605 Gas Plant Road
I'oeatello, II)
Latitude: 42° 4><* 55" N
Longitude: 112° 42' I3"W
2) The Proeess unit information.
I nil
6
7
Ik>at raJin^
3.35 MMBtii/hr
0,5 MJVIHui/hr
I ieaici' i \]h>
(§63,7490)
I listing Process
11 eater
Existing Process
1Ieater
Tunc-Dp Frequency
(Tablf H) Subpart
I > I) I) I) I)}
Initial; Every 5 years_
Initial; Every 5 years
3) The date of report and beginning and ending dates of the reporting period.
• The date of this report is January 3 1, 2020.
• This report eovers the lime period from January 3 1, 2016 to I Jeeember 3 L 2016.
4) The date of the most recent tune-up for each unit subjeet to only the requirement to conduct a
5-year tune-up according to 40 CFR 63,?540(a)(12)
• 3.35 MMBtu/hr Proeess I leater Tunc Up: November 12,2015
• 0.5 MMBtu/hr Process I leaLer Tune Up: December 15, 2015
5) If there are no deviations from the requirements for work praetiee standards in 'fable 3 to
Subpart 1)1)1)1)1) of Part 63 that apply to the permittee, a statement that there were no deviations
from the work praetiee standards during the reporting period.
• "There were no deviations from the requirements for work praetiee standards
during the reporting period."
6) If the permittee has a deviation from a work praetiee standard during the reporting
period, the report must eontain a de.seription of the deviation and information on the duration
and eause of the deviation and eorreetive aetion taken.
• "There were no deviations from the requirements for work praetiee standards
during the reporting period.1'
Page 125 of 270
-------
7) A statement by a responsible oflicial (as defined in 40 (TR 71.2) wilh that official's name,
title, and signature, certifying the (ruth, accuracy, untl completeness (CTAC) of the content of the
report, CTAC form available at hup-*:,' w w \\ .epa.gt>v/sitcs^prtuliictionM'ilcsOO 1ft-
05 documentv'etae 5900-02.pdf
» The signed CTAC form is attached. Flea.se note the responsible official lias
changed for the Northwest Pipeline. The new responsible oflicial is Oamilo
Amczquila, Northwest Pipeline VP GML
If you have any questions or require additional in formation, please contact me at (801) 584-6748
or by email at ;u-ivk ii>rs'viV'..i om.
Sincerely,
Derek Forsbcrg
Knvironmental Specialist
Ce: Lori Howell
Shoshone-Bannock Tribe
Air Quality
P.O. Box 306
Fort Hall, ID 83203
Page 126 of 270
-------
Subject:
From:
Sent:
To:
Farniliare, Christopher S,
Friday, January 31, 2020 10:30 AM
Forsberg, Derek
[EXriiRNAL] Williams Northwest Pocatelto Compressor Station Compliance Report Submittal
Derek,
To fulfill permit condition 8,6, turn in to EPA Region 10 a compliance report that includes the following information:
1) The Company and Facility name and address,
2) The Process unit information.
3} The date of report and beginning and ending dates of the reporting period. {This report should cover the time
period from January 33, 2016 to December 31, 2016, not January 31, 2017 as Condition 6,6.1 states.)
4) The date of the most recent tune-up for each unit subject to only the requirement to conduct an 5-year tune-up
according to 40 CFR 6.3.7540(a)(12) (see Conditions 6,1.3 and 6.4.4), and the date of the most recent burner
inspection if it was not done on a 5-year period and was delayed until the next scheduled or unscheduled unit
shutdown.
5) If there are no deviations from the requirements for work practice standards in Table 3 to Subpart DDDDD of
Part 63 that apply to the permittee, a statement that there were no deviations from the work practice standards
during the reporting period.
6) If the permittee has a deviation from a work practice standard during the reporting period, the report must
contain a description of the deviation and information on the duration and cause of the deviation and
corrective action taken.
7) A statement by a responsible official (as defined in 40 CFR 71.2) with that official's name, title, and signature,
certifying the truth, accuracy, and completeness (CTAC) of the content of the report. CTAC form available at
h:/,/wv^.'vv.i'}v'/'Ji!iTi".-1!,u.r!0J Si 0S/
-------
Let me know if you have any questions.
Christopher Familiare
fcnvironmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 Gth Ave, Suite 155, 154-113
Seattle, WA 98101
(206)-h.S.H-IPSO | ui:; 1:: ;> .hn.U-rli. r..>-wa.gOV
: In--; >. in ill1 «i v.iiulf-unbiil.; i >) VVtllkmn U 1 ,«nli. in It ilii--die mL.iin. alt.
Hi!- if HI,lll« h'l
2
Page 128 of 270
-------
United States
Environmental Protection
# m Agency OMB No. 2080-0336, Expires 1
Federal Operating Permit Program (40 CFR Part 71)
CERTIFICATION OF TRUTH," ACCURACY, AND COMPLETENESS (CTAC)
This form must be completed, signed by the "Responsible Official" designated for the facility or
emission unit, and sent with each submission of documents (i.e., application forms, updates to
applications, reports, or any information required by a part 71 permit).
A. Responsible Official
Name: (Last) Amezquita (First) Camilo _______ (MI)
Title __ VP^M^Northwest Pipeline
Street or P.O. Box P.O. Box 58900
City Salt Lake City State UT ZIP 84158 - 0900
Telephone (713) 215 - 2524 _ Ext. _____ Facsimile ( ) _ -
B. Certification of Truth, Accuracy and Completeness (to be signed by the
responsible official)
I certify under penalty of law, based on information and belief formed after reasonable
inquiry, the statements and information contained in these documents arc true, accurate
and complete.
Name (signed)
y!>'
Name (typed) Camilo Amezquita
Date: / / ?/ / 2o2.fs
EPA Form 5900-02
Page 129 of 270
-------
2.0 SUMMARY OF TEST RESULTS i , :
i
The results of the sampling program are summarized in Tables ? 1 and 2-2 for
Engine Numbers I and 4, respectively. A lota! of six tests were conducted on the
engines at each of three operating load conditions. Appendices A and B contain the field
data for Engines 1 and 4, respectively.
The tables present average emission rates for each operating load as well as the
lest results for each run. Emission of the target pollutants arc reported in units of actua!
concentration in the slack gas (parts per million on a dry basis, ppmv), concentration
corrected to 15 percent oxygen, and emission rate (pounds per hour).
Total hydrocarbons and non-methane hydrocarbons were measured using simtma
canisters. Analysis of these canisters was performed by Environmental Analytical
Services, Inc. For Engine Number 1, 30 minute samples were taken at each toad
condition. For Engine Number 4, 15-minute samples were collected for each run.
A single velocity traverse was conducted to coincide with rach g;isetms test run.
One moisture run of 30 minutes duration was conducted with each similar load condition.
2-1
-------
a mm *ry of rem us
Northwest Pipeline ( orpo ration owns and operates the PocateMo
Compressor Station located ;tl 2ft'15 Gas Planr Road West, on the Fori I fall
Reservation in Power County, Idaho. Within thi> lacilit) are a Clark TCV-10
reciprocating enyine. designated as engine No, 4, an J a (Mark II V(>
reciprocaling engine, designated as engine No, 1. NOv C( K Oj, CO and
THC tas Cf) emissions were measured in the exhaust of each unit
The test matrix for each unit consisted of Ihiee one hour lest runs a(
each of two load conditions. Dining each test run, N"Ox, CO, and 11IC
emissions were continuously monitored via instrumental anal)ses Stack flow
tales and moisture content were determined s'oiehiomeineally using 1,1' \
Method ]c> during each of the twelve test runs
"f able 2 is a summary of the results of the three test runs eondncied on
Unif No, 4 at full load conditions Foi each test run, this tabular summary
contains the operational conditions, stack volumetric flow rates, oh sen ed
concentrations, and calculated mass emission tales, Tahle ^ is a summary of
the results mf" the three test runs conducted at reduced load condition on Unit
No 4 Table 4 is a summurv of the results ol full loud condition testing on
\ 'mi No I Fable "> presents she sesuhs of testing on i"nil No. I ai seduced
load eonditions.
Appendix A contains iieid data sheets and computer spreadsheet
calculation templates. Appendix B provides example calculations necessary
for presentation o! the results of this seciion. Appendix C contains the lesults
of the fuel analyses and Cuhix's fuel calculation spreadsheets. Documentation
of Quality Assurance/Quality Control procedure1- and activities may he found
in Appendix D. .Appendix E contains copies of" pertinent certification
documentation. The operating data was provided by Northwest Pipeline
Corporation personnel from I heir control room instrumentation and is found
in Appendix F. Copies of the strip chart records obtained during these tests
are available in Appendix G.
Page 131 of 270
-------
Cwntjwpi j .VWPL-WMIami r,4. llnni«r>.*-Uest
Lwaficn, PocatelSx Cmupjiwisi Station
Sourer: CUrk-HA-lO
I retoimrw: JT. RS
Engine R»(«d Hp 3Uf. ttt'M
Serial No.: 107027
Table 2
Unit 4 - Fi'i- f w
Test Rua No
T »
j 1
M
f |
HH
Engine Designation
1
J" '""ijTiJ-""
i
t
Date
hi 1 |
hi [ j ,"li
(, p->in 1
H,*4
Sn,
825
1 Uf 1 f InW ftiS"' i Mv !:t*l
639,0
I §49.6
M ! W
Jfttcl HtMling Valm i BiuiSCF HH\ >
llH- >
1063
I
liK, <
hino; r-i-jouTti-isdiiAtMHrri
! >if." t4
S65 i
HwsetMiwr' S po. i! n I-ne[ (".wnmplu'in P.n<' {Cn hp tu.l'HV i
~h (,[ 1
j "'if. If, t
"'hi Hi <
hurl f n>». i 8 II vtit i
J MI- •'C
; H IK I -Hi'"
1 rijiUK H>>r«STmvn
3693
I 3768
3773
!
i_OUli.SC K'fi.riH
JO" •,
iw*i
i i«»r;
A inhibit ('»»riiliiNV>
[
i
i'resiuti' .illiind!1 MSI (to
illvl H f
Asmospiicxt Pu-s'.ytf un. Hp)
25,30
i
Tt'm|VriUurr i T> l>r\ butS1
64
68
1 (-Mipcroinri f I"1 V>»ihnlh
,ty
.p(
«, i
f Iuntuhr> ' Ih/lb m i
0.0065
0.0051
U (HSM
^ r-4iu_i»'
_____
_____
Averages
NO\ ipptiu-i
l"i V"
1 IP
CI t (ppti'v l
354
394
390
•t \ 1
14,26
13.80
l.t
I "O? 1 v.il '"5 i
4,03
4.04
4,03
4.0 >
! H<. (ppm* ,*>. mfhwe i
Sti.^
s;,1
552
S57
VtX' !pp - ,j " nutU>(S(
77.8
75,6
75,6
*6..*
I'll Kk'lOt
i f> i
1.76
1 'ti
K-l1.
t xhaust I imiMnn LVmtentrutkiril> (c»«r«s 1« (kt I s|. tn li
NCn i ppim di > i
992.6
_____
"7:44
i 141,6
< I > tppmv, Jr\ i
355 8
vw s
399.5
< K' iv(>| ><5>, Jiv i
14 U
!3 X'
p W
1411?
<'or(\u!'> ki
3
FHt' tppm\ i
573
552
VOC j ppit",
7,81E+05 | 7.40E+05
7 *!l" ! 7,531
Calculated Masi Emission Rates fuu IT 1 \!»iSkx1 IS)
NO\ i Ibs'h' i
_____
"Tlj4 ~bi
109.97
102.51
> »«i itisihri
20 '^1
21,51
:i as
it.no
VOC (IWhn
i) ?4
0.77
KCH uot v/\ri
4IH ¦
45l> y.
4<. ! -
44 *>.0
CO r
Kh S
1'4;
,
92.3
V(.k; (Uhis/viI
%
? .>5
^ jr.
NlK ie'hp hi, on cumcrsrsMir Hpi
1 ! \H
i;
DM
12.41
C(! ig/hp-'ii, basfil on cr>mp!es<.rtr Hp*
; 4h
2 yi
2.58
2.55
VOC istfif hi biTiCuoncotnprrsj.il! Hpf
0,10
n in
O.tW
Teslifip by Ci.h'. Corperaiton, ASKiuitrrque, New Mr\ia
Page 132 of 270
-------
Tabic 3
Cumpanv: NWTL-Willwm> (.as Pipelines-West 4
location: Pocalcllo l'ompre>v»r Station
Sourff: Clark H'V |H
Trrhnicimiv. J'l, HS
f npue Ratwf 3400 Hp w' MM> RI'M
Serial N..,; 10702?
_____
T«m Bon No. ( 4
i
]
f npmr D«ifrtaiKtart 1 nnt
I t-fKl
I |.i f
J Ulu
(i ^
('unifti »'ipr SiKlnm Pirvuin* ipsig'
61 *
b 1 7
t' i'»
l\,nipr<.>,sor Lhsdhup Pnrwuc (psi^i
81 i
SK,1
797
1 uel How Hale |MCH>>
4.iH li
4J'
K!.*v:
Hpmv i
251
260
2(i <
258
02 i ,ul !t i
15.12
15 J 3
1 > u
if.K<
LU2 (vul VU
335
; (•.
3.30
iJ3
1 HC ippmv as Kittlkun:!
949
i 3«M
! 4*'i 1
I27S
VOC Sppoi* jy 1 1 oi lilt" in vwnfhi turns Hit'i i;.«v .itwlwM
! tll(i
ISMl W
:(u :
175.11
t'vi Fatiix
.. _ t*' ?_
i ?:
1.75
1.73 _
BiitaiptEmfastoa Coneentfatloas {corrected perEg, ft-1}
N( ix ipprnv, dn I
Tit) S
~650 (>"
5T ;
«s€i
i"t i , drv i
:i4 a
?b: a
2oH ¦>
:63.o
02 (vol tin-)
15 21)
iv:it
15.22
15.21
iCt 12 (vu!"i, dr> >
3 t!
"*.2K
1
n HC." Iprnnv >
n«n
1471
1271
,VOC ifpiriv t\ >: oi Uil bs trom luel analysi-. i
4 Li
hi. 4
b- j
55J
—j
1
: vitr FPA Mrih.*l i9, 02
"hVT+U'i
(t 2hF-*-t«^
o ;
"fcJHK+O?""
|_5€53i_ii_Hg~
_____
jNOx dhs.'ht j
53.62
1'3"74
" 48.h* ""
iCO (Ibs/lii i
i I 3h
11.97
f | iK|
11.78
VOCdh.vtm
1.07
1 5P
t fyi
1 43
NOx (ton-s/vr)
2.U H
:n :
IQ1 ft
213.2
CO 'lnt)\/yr'i
49.8
52 4
s; 5
51.6
VOC ttwiyyO
4 (•:
ft '»s
7.19
6.25
NOx (j!/hjvhr. ha<.ed on compressor Hp<
9.54
a M
8.12
8,9«
Ci i ijylip- h>, hawd on tompressoi Hpi
2.02
1 2"
2 22
2.18
VOC tyfltp hr. based on compressor lip i
(.1
0
0 30
11.27
Testing by Cubtx Corpora (son, Albuquerque, New Memco
Page 133 of 270
-------
Tabic 4
I nit 1 - Fall Load
I'ompiMi v N VVPI -WiHtims Gas !P1jiei«ir,%.\\est
I oc*tii«n. Pocatclto C itmprtuur Sttthun
Sourtt: Clark fl.A-ts
Tcchnkian. IT
Engine Kdied; 2000 Hp (ft1 3«# q>m
Serial No.; 73S4f>
1
[Test Run No.
7
.1
T~T~~
Itnprtc Dcsifmalutn
I
i
1
lliaie
WU/'K'
VUi'Jb
{», ".VK
I
Man 7 nn*
D8 5s
10:02
Stop 1 line
[N \ <
H:02
FriRint/ComprTMor Operation
I- _ .. j
Limine Speed irpm>
Mh'i
Hi'i
l uc! Gas tVwnc ipiij.11
| ? S
13.8
13.9
An ,\tamlnkl Pu*>.\utc ( 'Hgi
14 H
14 :
14.5
liiicmw Tinting
1 1 1 1 !
y ,f
<¦
'Compressot Suction Preinm* ipss^i
'
'
jCumjwiAfir Discharge Pressure ipwt
X?h
832
! \n"f How Kaic (Mt.T'Ui
355.3
,«h J
! h
Fuel Hejlinji V alur i IV i
MKh
luti I
hti.'
1 iiel 02 f--Ku lor [DSCFHfMMR I' ! 1
*
8t)^
H'.s^
jHo!'.cp4iwrr Spcciht hiel Ccmsunip'ioo Nate i!ira.hp ht.HHVj
7m | 4 H
7K"K t
?HSt) M
Hie! Flow sBTI Tu>
1 i .i
! orque Pi
m*-,
f«l".
IWl'r
Ambient <
. .
dlltttn.li' M.Hi 1 !! \
4v'U
45 I it
4 ^ l M i
Atmospheric PiecMin- On Hji>
i ^ 7
> »K
25.39
'U-mper.ituri' i 'Fi i :
Hutniilitv (1Mb ji: i
iWtiifyJ
(i oi is:
0.0089
Messurrd f- vliuu't J mission Concent i mums
A veraer*
N< H sppim i
1301 i
I.">r
" I2«5
l ' " i pium1
135
149
159
14H
i P ,v,.l
13.40
1 * n
13.45
' (V (\ i>l \"f i
4
4 :h
4J**
1 HC tpptm js tneili.iiit'i
926
731
mu
WtC ipptiiv 4 s I 1 •'/-'.i i»f 1 !H' hv Wi-H' is iti'T Mt'i v'.i'i ,m.iKsb>¦
US ft
99,2
¦! if 1 ( 1
108.S
I u F'jcici
[21
1.75
1Z4
Exhaust Emission Omrtntraliiuis t«i» ie< ted |**r h q fk •! 1
•\v*r.»w
N0\ (pprtu tirv'
'"m: 4
_____
i:«»- ii usti.3
CO tppniv. Un, i
i ^
i «<: 5
IN)~
o: (vol S", dn!i
13 bs
n 4f>
13 41
13.5:
COitvoi'i dry I
4 11
4
4 M
4.:*<
THC (jni'ivi
•n?
v.n
HI) 5
VOC i£pn>' iv '* 1.4 Tils h« k«ct£!it from liit'i irv jrulj\ts,
126.5
W 4
1W«.2
Sljclt \rolumcirk H.m Rjw«
t II 1 r * r»Ku>in. r< u, r uilH.I ' Hi F H 'In 1
~3 J» +05
Calculated Mas* femisvion Rites (via >'P\ Mrfl
NiH (Ibs/lin
5h 4:
5"J.J2~
CO rlbslit .
3 W
4 ;?
4. S|
4
VfT (Iln/hi i
: ;>i
;
I,b4
1,77
t*0\ itu.i}./vrs
y
261.7
y
25*.*
CO Uons.'ytl
17 0
!87
:<•> x
IS.S
VOC iismiAn
9 IU
b«h |
7.17
7.73
MtK jg,!hp lit, based ori coinprcs,nt Hu¦ |
13 Vi
.3,52
1 < 1?
!3 -i:
0"« ;g/hp nr bisfd <,tn cpmp'fsscr Hp1 •
U .Vt
0:W
1,01
a,'t~
^C'C igliji-h;, h.tvci] on qtrrprrssur Hp' [_
U 3d |
0,3?
0.40
Testing by Cubiv Corporation, Albuquerque, New Meuei
Page 134 of 270
-------
I' nit 1
' i-iru n« NHI'! thwMt; '>\t
I .x,ati.>n Fm'
1« hnician JT
Engine Ralrtl: l(MN)H|i ° .MHlipm
Serial 7J54fi _____ _ __
lest Him Nr. _
Enpiiif DeNipnJl'on
F use*
Sun firm
'Mop Time
Table 5
K«f»ic«f 1 i>»il
I wgitic/Comprfgnr Operation _ _
htgnw Spmi itpmi
f (id 0a% i'rch'.uir (psitf i
'Air M.miMd Pit vm.ic i Him
(UlJiition Tirruri,e i1 H IIX"i
lf ump
Tempt»i.Murp <'T( IV> Kith
! <*mpcr>>H!r'.' I '1 ¦; YHu Inith
Hunmliiy i IhAh -nij _ _ _ _
' mV»mi« rrf 1'n.tjrtMM V BWviinn ' 'niwnlt
th\t\ tpprwf
|i \ 1 p prnn1
P» ivol "!
H'Ci,1 fvol %i
I Hi" (ppm p» 'neiiumt* *
'V(X" i
co? n
C nkulated FhiKsimi Ratr^vi* Fl*4 Method 191
NOv I IhJbn
ro nhs.iifp
VOC i Ih.vlst i
N'Ox Moris SO
CO nom-'yt)
ia
i
(5/1 IN?
i; ;s
13:25
_L_
11
12
!
I
6/12/98
14:18
r in
lip f'
12.2
7,9
633
K.Y
270,0
!!V,'
I
7?2? "•
[Mf *il7
1 'viST
259,2
ion
865 3
H4W 3
I ]M iiti*
!.«>>
Kin
b, r:«b
iifi
.. -
!< >¦
11.7
U,:
795
;s t h
1 M(> I
m s? ?
1,12E+07
t 25i >
45 Mi
41^.1
25,39
2^ !fi
25.35
fv4
65
66
::irt
58
60
it i tn* s
o.oi i;
4-
,V|.i
44 S
333
1 }h
164
178
4.77
15.0!
15.13
3.61
3,41
1 Vl
126
SO*!-
! Ma
12.0
143.6
168.1
! i*l!
__L22_J_
1.75
8
VOC iinns/yrf
SOv igi'hp-Iii, cm rompr^s<>o! Hp>
CO lyfliji hr, btiyeJ on L"nipr^".NOr Hpi
\'Or i jji'hp hr f>ase<.i i'tt compressor Hp' __
Telling by Cubi< Corporaison, Alhutjuerquc. Ne'.v Mcvico
Page 135 of 270
-------
Table 2-2
Sampling Program .Results
Engine 4, Octobt t 17, 1994
Operating Condition
A
B
C
Run
Run I & 2
Ruti 3 & 4
Run 5 & 6
Sampling
Stan Time
12.40
14:16
15:50
T une
End Time
13:14
14:53
16:23
NO,
ppmV
562.4
1.4
1324.2
NO,
ppmV 35% 02
5C)0.7
863.6
1012.2
NO,
ibs/hr
47.9
91J
123.1
CO
ppmV
294,2
323.7
510.1 I
ro
ppmV @ 15% Oj
261.9
273.1
390.0
CO
!bs/hr
15.3
}7,5"r -
38 9
SOj
ppmV
1.3
3.7
7 1
SO,
ppmV @ 15% O
3 I
1.6
SO;
Ibs/hr
0.2
0 4
0. 3
1'NMHC
ppmC
!/J /
44.7
33 1
TNMHC
ppmC & i">% (l(
37.1
25.3
TNMHC
Ibs/hr
3.7
i.3(>
1.1 |
rue
ppmV
1983.2
984.2
638.8
TIIC
ppmV @15% 0} .
1765.6
817,7
480.6
THC
Ibs/hr
161.6
82.5
55.9
Oxygen
Percent |
14.3
13.8
13.2
co:
Percent
3.2
3.6
V. I
Velocity
FPS
75.1
80.3
89.3
Slack
AC KM
30975
33085
36818
| Flow
8CFM
11884
12226
12075
Moisture
Percent
9.6
9.7
10.1
J Content |
A 78% Torque, 2^7 rpro, 2644 bhp
B 92% Torque, 298 rpm, 3161 bhp
C 104% Torque, 298 rpm, 3^72 bhp
2-3
Page 136 of 270
-------
Table 2-1
Sampling Program Results
Engine 1, October II, 1994
Operating Condition
A
B
c 1
Run
Rim 1 k ?
Run 3 & 4
Run 5 & ft j
Sampling
Stan Time
11 '.30
13:07
14:29
Time
_
F.nd Time
12:10
13:4!
15:09
NO,
ppmV
537.0
1021.3
.8
NO,
ppmV ® 15% Oj
470.6
858.5
585.2
NO,
Ibs/hr
30.8
59.0
44.0
CO
ppmV
186.6
160.2
132.9
CO
ppinV & i5% O,
163.6
134.7
107.0
CO
Ibs/hr
6.5
5.6
4 9
so.
ppmV
1.4
3.0
4.8
so,
ppmV Ǥs 15% 02
1.2
2.5
3.9
j so,
Ibs/hr
0.1
0.2
0.4
TNMI1C
ppmC
?QJ
16.2
TNMHC
ppmC © 15% C)j
34.9
37 1
13.0
TNMHC
Ibs/hr
0.8
0.9
THC
ppmV
1031.5
1272.7
*
THC
ppmV @ 15% 02
904.1
1069.8
•
THC
Ibs/hr
56.5
70.3
m
Oxygen
Percent
14.2
13.9
13.0
Percent
3.6
3.7
3.9
Veloci1
FFS
3
121.0
126.2
Stack
ACPfvf
22681
22806
23783
Flow
SCFM
7995
8055
8451
Moisture
Percent
9.6
8.3
8,7
Content |
A
B
C
m
83% Torque, 304 rpm, 1664 blip
90$ Torque, 304 tpm, 1812 bhp
100% Torque, 305 rpm, 2021 bhp
Apparent sample leak. No THC data,
7.J
Page 137 of 270
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 Sixth Avenue, Suite 155
Seattle, WA 98101-3188
AIR & RADIATION
DIVISION
NOV . 7 2019
Mr. Glen Jasek
VP GM Northwest Pipeline
Williams Northwest Pipeline - Pocatello Compressor Station
295 Chipeta Way
Salt Lake City, Utah 84108-1220
Re: Title ¥ Application Completeness Determination
Dear Mr. Jasek;
On September 9, 2019, the U.S. Environmental Protection Agency. Region 10 received an application
from Northwest Pipeline LLC to renew its Title V (40 CFR Part 71) air quality operating permit. On
October 16, 2019, Region 10 requested additional information pertaining to the applicability of NSPS
Subpart JJJJ to your facility's four stationary spark ignition internal combustion engines. We received a
response from you on November 06, 2019, stating that the engines have neither been modified or
reconstructed as those terms are defined in 40 CFR 60.14 and 15, respectively. Region 10 has reviewed
the application, as well as this additional information, to determine whether it provides all the required
information. Pursuant to 40 CFR 71.7(a)(4), Region 10 has determined that the application is complete.
If, while processing the application, Region 10 determines that additional information is necessary to
evaluate or take final action on the application. Region 10 will request such information in writing and
set a reasonable deadline for a response. If the permit renewal is not issued by the time your current
permit expires (9/30/20), your current permit shall remain in effect until the permit renewal is issued
provided you submit any requested additional information by the specified deadline pursuant to
40 CFR 71.7(b). You also have a duty to promptly supplement or correct the application if you failed to
submit any relevant facts and/or submitted incorrect information in the penn.it application.
Region 10 looks forward to working with you to enable us to draft the renewal of the Title ¥ permit. If
you have any questions, please contact Christopher Familiare of my staff at (206) 553-1250 or
familiare.chiistopher@epa.gov.
Sincerely,
v
Kelly McFadden, Chief
Air Permits and Toxics Branch
Page 138 of 270
-------
cc:
Mr, Derek Forsberg
Environmental Specialist
Northwest Pipeline LLC
Ms. Lori Howell
Air Quality Manager
Shoshone-Bannock Tribe
Ms. Shayna Martin
Air Quality Specialist
Shoshone-Bannock Tribe
Mr. Jeff Carpenter
Air Quality Field Specialist
Shoshone-Bannock Tribe
Page 139 of 270
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
. ¦ REGION 10
~ 1200 Sixth Avenue, Suite 155
Seattle, WA 98101-3188 air & radiation
DIVISION
NOV 1 8 2019
The Honorable Chief Edmo
Chairman, Fort Hall Business Council
P.O. Box 306
Fort Hall, Idaho 83203
Dear Chairman Edmo:
The U.S. Environmental Protection Agency has begun to process Williams Northwest Pipeline LLC's
application to renew its Title V air quality operating permit for the Pocatello Compressor Station in
Pocatello, Idaho. The Pocatello Compressor Station is located within the boundaries of the Fort Hall
Reservation, and its operation may affect tribal interests. The EPA is notifying the Shoshone-Bannock
Tribe of this proposed action and will engage in government-to-governm ent consultation if requested.
On September 9, 2019, the EPA received a Title V permit renewal application from Williams. On
November 7, 2019, the EPA sent a completeness determination letter to the company stating that the
application was complete. The Shoshone-Bannock Tribe's air quality program staff have been copied on
our correspondence with the company.
The EPA recognizes its unique relationship with tribal governments as set forth in the United States
Constitution, treaties, statutes, executive orders, and court decisions. We also recognize the important
role tribes play in protecting air quality, and we want to ensure that we fully consider your tribe's
interests in our upcoming decision. The EPA will keep the tribe informed about the project progress
whether or not you desire to engage in consultation. In addition to the opportunity for tribal consultation,
there will be opportunities for public involvement through the public comment process; a public
comment period on the Title V permit will be open for at least 30 days.
Please contact Christopher Familiare at (206) 553-1250 or cliristopher.familiare@epa.gov within two
weeks of receipt of this letter to indicate whether you would like to initiate consultation regarding this
project and, if so, please provide Christopher with the name and contact information of the tribal contact
person for consultation planning and/or project communications. For your convenience, you may
complete and return the enclosed tribal consultation questionnaire.
Sincerely,
Krishna Viswanathan
Acting Director
Enclosure
Page 140 of 270
-------
U.S. Environmental Protection Agency, Region 10
Consultation Questionnaire
Tribal Government Name: Shoshone-Bannock Tribe
Project Name: Williams Northwest Pipeline - Pocatello Compressor Station, Application to Renew
Part 71 Air Quality Operating Permit No. R10T5110100
Please check the appropriate response(s) describing the level of involvement your tribal government
would like regarding the Williams application to renew its Part 71 permit.
~ We do not request government-to-government consultation at this time.
~ There are or may be issues of concern associated with this action and we request further
consultation.
~ I understand that the EPA will be in touch to develop a consultation plan. I am including
comments on how our tribal government would like to be consulted.
~ Our tribal government has its own consultation protocol; a copy is included with this
response.
The following tribal official has been designated to serve as the point of contact for this project:
Name:
Title:
E-mail:
Phone:
Fax:
Chairman Signature: Date:
Please return the completed form using the enclosed stamped/addressed envelope.
You may also scan and e-mail this form to Christopher Familiare at familiarexMstopher@epa.gov or
fax it to (206) 553-1250. If you have any questions regarding this project, please contact Christopher.
Thank you!
Page 141 of 270
-------
From:
To:
Cc:
Subject:
Date:
Familiare. Christopher S.
Derek.Forsbera (aWilliams.com
Mever. Dan
Northwest Pipeline - Pocatello Compressor Station Title V Renewal Additional Information Request
Wednesday, October 16, 2019 3:05:00 PM
Dear Mr. Forsberg,
The Region 10 air permits team is currently processing your application. In the application, Williams
Northwest Pipeline states that each of its four stationary spark ignition internal combustion engines
at the Pocatello Compressor Station commenced construction prior to June 12, 2006, and therefore
each is an existing facility not subject to the requirements of Subpart JJJJ to 40 CFR Part 60
(Standards of Performance for Stationary Spark Ignition Internal Combustion Engines). Applicability is
not solely determined based upon the date construction of the facility commenced. NSPS Subpart
JJJJ may apply to an existing facility if it was subsequently modified and/or reconstructed (as those
terms are defined in 40 CFR 60.14 and 60.15, respectively) after the June 12, 2006 cutoff. The NSPS
modification and reconstruction general provisions apply pursuant to Table 3 to NSPS Subpart JJJJ.
Pursuant to 40 CFR 71.5(c)(5), we are requesting additional information as to whether NSPS Subpart
JJJJ is applicable to any of the four engines. Using the CTAC form at https://www.epa.gov/title-v-
operatine-permits/certification-truth-accuracy-and-completeness-ctac . please certify that none of
the four engines have been modified and/or reconstructed as those terms are defined in 40 CFR
60.14 and 60.15, respectively.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
Page 142 of 270
-------
From:
To:
Cc:
Subject:
Date:
Forsbera. Derek
Familiare. Christopher S.
Mever. Dan
RE: Northwest Pipeline - Pocateiio Compressor Station Title V Renewal Additional Information Request
Monday, October 21, 2019 3:18:54 PM
Hello Chris. The engines at Pocateiio have not been modified or reconstructed. I will put it in a
letter and send it to you with the CTAC.
And hello Dan. I remember working with you on the Pocateiio permit renewal back around 2007. I
hope you are well sir.
Chris, let me know if you have any more questions. I'll get this letter mailed this week.
From: Familiare, Christopher S.
Sent: Wednesday, October 16, 2019 4:06 PM
To: Forsberg, Derek
Cc: Meyer, Dan
Subject: [EXTERNAL] Northwest Pipeline - Pocateiio Compressor Station Title V Renewal Additional
Information Request
Dear Mr. Forsberg,
The Region 10 air permits team is currently processing your application. In the application, Williams
Northwest Pipeline states that each of its four stationary spark ignition internal combustion engines
at the Pocateiio Compressor Station commenced construction prior to June 12, 2006, and therefore
each is an existing facility not subject to the requirements of Subpart JJJJ to 40 CFR Part 60
(Standards of Performance for Stationary Spark Ignition Internal Combustion Engines). Applicability is
not solely determined based upon the date construction of the facility commenced. NSPS Subpart
JJJJ may apply to an existing facility if it was subsequently modified and/or reconstructed (as those
terms are defined in 40 CFR 60.14 and 60.15, respectively) after the June 12, 2006 cutoff. The NSPS
modification and reconstruction general provisions apply pursuant to Table 3 to NSPS Subpart JJJJ.
Pursuant to 40 CFR 71.5(c)(5), we are requesting additional information as to whether NSPS Subpart
JJJJ is applicable to any of the four engines. Using the CTAC form at https://www.epa.gov/title-v-
operatine-permits/certification-truth-accuracy-and-completeness-ctac . please certify that none of
the four engines have been modified and/or reconstructed as those terms are defined in 40 CFR
60.14 and 60.15, respectively.
Thanks,
Derek
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
th
Page 143 of 270
-------
1200 6 Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
Page 144 of 270
-------
From: Familiare. Christopher S.
To: Forshern. Derek
Cc: Mever. Dan
Subject: RE: Northwest Pipeline - Pocateiio Compressor Station Title V Renewal Additional Information Request
Date: Monday, November 4, 2019 9:46:00 AM
Hi Derek,
Thank you for sending your email confirming that the engines at the facility have not been modified
and/or reconstructed since commencing operation. We have not received the mailed copy of the
letter with the CTAC, do you know if it had a tracking number associated with it? If so, could you
share it with us so that we may know when to expect it.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1 ?
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(7061-553-1 750 | famiIiare.christoDher@eDa.gov
From: Forsberg, Derek
Sent: Monday, October 21, 2019 3:19 PM
To: Familiare, Christopher S.
Cc: Meyer, Dan
Subject: RE: Northwest Pipeline - Pocateiio Compressor Station Title V Renewal Additional
Information Request
Hello Chris. The engines at Pocateiio have not been modified or reconstructed. I will put it in a
letter and send it to you with the CTAC.
And hello Dan. I remember working with you on the Pocateiio permit renewal back around 2007. I
hope you are well sir.
Chris, let me know if you have any more questions. I'll get this letter mailed this week.
Thanks,
Derek
From: Familiare, Christopher S.
Sent: Wednesday, October 16, 2019 4:06 PM
To: Forsberg, Derek
Cc: Meyer, Dan
Subject: [EXTERNAL] Northwest Pipeline - Pocateiio Compressor Station Title V Renewal Additional
Page 145 of 270
-------
Information Request
Dear Mr. Forsberg,
The Region 10 air permits team is currently processing your application. In the application, Williams
Northwest Pipeline states that each of its four stationary spark ignition internal combustion engines
at the Pocatello Compressor Station commenced construction prior to June 12, 2006, and therefore
each is an existing facility not subject to the requirements of Subpart JJJJ to 40 CFR Part 60
(Standards of Performance for Stationary Spark Ignition Internal Combustion Engines). Applicability is
not solely determined based upon the date construction of the facility commenced. NSPS Subpart
JJJJ may apply to an existing facility if it was subsequently modified and/or reconstructed (as those
terms are defined in 40 CFR 60.14 and 60.15, respectively) after the June 12, 2006 cutoff. The NSPS
modification and reconstruction general provisions apply pursuant to Table 3 to NSPS Subpart JJJJ.
Pursuant to 40 CFR 71.5(c)(5), we are requesting additional information as to whether NSPS Subpart
JJJJ is applicable to any of the four engines. Using the CTAC form at https://www.epa.gov/title-v-
operatine-permits/certification-truth-accuracy-and-completeness-ctac . please certify that none of
the four engines have been modified and/or reconstructed as those terms are defined in 40 CFR
60.14 and 60.15, respectively.
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christopherOepa.eov
Page 146 of 270
-------
From: Forsbera. Derek
To: Familiare. Christopher S.
Cc: Mever. Dan
Subject: RE: Northwest Pipeline - Pocateiio Compressor Station Title V Renewal Additional Information Request
Date: Tuesday, November 5, 2019 9:26:34 AM
Sorry for the delay Chris. We are going through a reorganization here so it's rather chaotic
currently. Our VP that is signing these is in Houston and I think he's in meetings all day every day. I
will attempt again this week to get it signed and returned. Again, sorry for the delay.
Derek
From: Familiare, Christopher S.
Sent: Monday, November 4, 2019 10:46 AM
To: Forsberg, Derek
Cc: Meyer, Dan
Subject: [EXTERNAL] RE: Northwest Pipeline - Pocateiio Compressor Station Title V Renewal
Additional Information Request
Hi Derek,
Thank you for sending your email confirming that the engines at the facility have not been modified
and/or reconstructed since commencing operation. We have not received the mailed copy of the
letter with the CTAC, do you know if it had a tracking number associated with it? If so, could you
share it with us so that we may know when to expect it.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
From: Forsberg, Derek
Sent: Monday, October 21, 2019 3:19 PM
To: Familiare, Christopher S.
Cc: Meyer, Dan
Subject: RE: Northwest Pipeline - Pocateiio Compressor Station Title V Renewal Additional
Information Request
Hello Chris. The engines at Pocateiio have not been modified or reconstructed. I will put it in a
letter and send it to you with the CTAC.
And hello Dan. I remember working with you on the Pocateiio permit renewal back around 2007. I
Page 147 of 270
-------
hope you are well sir.
Chris, let me know if you have any more questions. I'll get this letter mailed this week.
Thanks,
Derek
From: Familiare, Christopher S.
Sent: Wednesday, October 16, 2019 4:06 PM
To: Forsberg, Derek
Cc: Meyer, Dan
Subject: [EXTERNAL] Northwest Pipeline - Pocatello Compressor Station Title V Renewal Additional
Information Request
Dear Mr. Forsberg,
The Region 10 air permits team is currently processing your application. In the application, Williams
Northwest Pipeline states that each of its four stationary spark ignition internal combustion engines
at the Pocatello Compressor Station commenced construction prior to June 12, 2006, and therefore
each is an existing facility not subject to the requirements of Subpart JJJJ to 40 CFR Part 60
(Standards of Performance for Stationary Spark Ignition Internal Combustion Engines). Applicability is
not solely determined based upon the date construction of the facility commenced. NSPS Subpart
JJJJ may apply to an existing facility if it was subsequently modified and/or reconstructed (as those
terms are defined in 40 CFR 60.14 and 60.15, respectively) after the June 12, 2006 cutoff. The NSPS
modification and reconstruction general provisions apply pursuant to Table 3 to NSPS Subpart JJJJ.
Pursuant to 40 CFR 71.5(c)(5), we are requesting additional information as to whether NSPS Subpart
JJJJ is applicable to any of the four engines. Using the CTAC form at https://www.epa.gov/title-v-
operating-permits/certification-truth-accuracy-and-completeness-ctac . please certify that none of
the four engines have been modified and/or reconstructed as those terms are defined in 40 CFR
60.14 and 60.15, respectively.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
/* * x
U.S. EPA Region 10
I . -j
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(7061-553-1 750 | familiare.christopher@epa.Bov
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
Page 148 of 270
-------
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
Page 149 of 270
-------
From: Familiare. Christopher S.
To: Forshern. Derek
Cc: Mever. Dan
Subject: RE: Northwest Pipeline - Pocateiio Compressor Station Title V Renewal Additional Information Request
Date: Tuesday, November 5, 2019 10:18:00 AM
Hi Derek,
Thank you for getting back to us and letting us know about your situation. As soon as you are able to
get a signature from the Responsible Official, could you scan and send me the letter and CTAC via
email? We would like to have this additional information before the end of the 60 day completeness
determination period which concludes this Saturday 11/9/19. We would also request that you still
send us the hardcopy in the mail.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(2061-553-1250 1 familiare.christoDher@eDa.eov
From: Forsberg, Derek
Sent: Tuesday, November 5, 2019 9:26 AM
To: Familiare, Christopher S.
Cc: Meyer, Dan
Subject: RE: Northwest Pipeline - Pocateiio Compressor Station Title V Renewal Additional
Information Request
Sorry for the delay Chris. We are going through a reorganization here so it's rather chaotic
currently. Our VP that is signing these is in Flouston and I think he's in meetings all day every day. I
will attempt again this week to get it signed and returned. Again, sorry for the delay.
Derek
From: Familiare, Christopher S.
Sent: Monday, November 4, 2019 10:46 AM
To: Forsberg, Derek
Cc: Meyer, Dan
Subject: [EXTERNAL] RE: Northwest Pipeline - Pocateiio Compressor Station Title V Renewal
Additional Information Request
Hi Derek,
Thank you for sending your email confirming that the engines at the facility have not been modified
Page 150 of 270
-------
and/or reconstructed since commencing operation. We have not received the mailed copy of the
letter with the CTAC, do you know if it had a tracking number associated with it? If so, could you
share it with us so that we may know when to expect it.
From: Forsberg, Derek
Sent: Monday, October 21, 2019 3:19 PM
To: Familiare, Christopher S.
Cc: Meyer, Dan
Subject: RE: Northwest Pipeline - Pocatello Compressor Station Title V Renewal Additional
Information Request
Hello Chris. The engines at Pocatello have not been modified or reconstructed. I will put it in a
letter and send it to you with the CTAC.
And hello Dan. I remember working with you on the Pocatello permit renewal back around 2007. I
hope you are well sir.
Chris, let me know if you have any more questions. I'll get this letter mailed this week.
From: Familiare, Christopher S.
Sent: Wednesday, October 16, 2019 4:06 PM
To: Forsberg, Derek
Cc: Meyer, Dan
Subject: [EXTERNAL] Northwest Pipeline - Pocatello Compressor Station Title V Renewal Additional
Information Request
Dear Mr. Forsberg,
The Region 10 air permits team is currently processing your application. In the application, Williams
Northwest Pipeline states that each of its four stationary spark ignition internal combustion engines
at the Pocatello Compressor Station commenced construction prior to June 12, 2006, and therefore
each is an existing facility not subject to the requirements of Subpart JJJJ to 40 CFR Part 60
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christopher@epa.gov
Thanks,
Derek
Page 151 of 270
-------
(Standards of Performance for Stationary Spark Ignition Internal Combustion Engines). Applicability is
not solely determined based upon the date construction of the facility commenced. NSPS Subpart
JJJJ may apply to an existing facility if it was subsequently modified and/or reconstructed (as those
terms are defined in 40 CFR 60.14 and 60.15, respectively) after the June 12, 2006 cutoff. The NSPS
modification and reconstruction general provisions apply pursuant to Table 3 to NSPS Subpart JJJJ.
Pursuant to 40 CFR 71.5(c)(5), we are requesting additional information as to whether NSPS Subpart
JJJJ is applicable to any of the four engines. Using the CTAC form at https://www.epa.gov/title-v-
operatine-permits/certification-truth-accuracy-and-completeness-ctac . please certify that none of
the four engines have been modified and/or reconstructed as those terms are defined in 40 CFR
60.14 and 60.15, respectively.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christopherOepa.eov
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
Page 152 of 270
-------
From: Forsbera. Derek
To: Familiare. Christopher S.
Cc: Mever. Dan: Forshern. Derek
Subject: RE: Northwest Pipeline - Pocateiio Compressor Station Title V Renewal Additional Information Request
Date: Wednesday, November 6, 2019 3:00:09 PM
Attachments: Pocateiio CS Additional FPA Info Renuested.ndf
Here you go Chris. I'll be sending a hard copy out this week as well. Let me know if you need
anything else.
Thanks,
Derek
From: Familiare, Christopher S.
Sent: Tuesday, November 5, 2019 11:19 AM
To: Forsberg, Derek
Cc: Meyer, Dan
Subject: [EXTERNAL] RE: Northwest Pipeline - Pocateiio Compressor Station Title V Renewal
Additional Information Request
Hi Derek,
Thank you for getting back to us and letting us know about your situation. As soon as you are able to
get a signature from the Responsible Official, could you scan and send me the letter and CTAC via
email? We would like to have this additional information before the end of the 60 day completeness
determination period which concludes this Saturday 11/9/19. We would also request that you still
send us the hardcopy in the mail.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
t W !
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(7061-553-1 750 | familiare.chri8topher@epa.eov
From: Forsberg, Derek
Sent: Tuesday, November 5, 2019 9:26 AM
To: Familiare, Christopher S.
Cc: Meyer, Dan
Subject: RE: Northwest Pipeline - Pocateiio Compressor Station Title V Renewal Additional
Information Request
Sorry for the delay Chris. We are going through a reorganization here so it's rather chaotic
currently. Our VP that is signing these is in Houston and I think he's in meetings all day every day. I
Page 153 of 270
-------
will attempt again this week to get it signed and returned. Again, sorry for the delay.
Derek
From: Familiare, Christopher S.
Sent: Monday, November 4, 2019 10:46 AM
To: Forsberg, Derek
Cc: Meyer, Dan
Subject: [EXTERNAL] RE: Northwest Pipeline - Pocatello Compressor Station Title V Renewal
Additional Information Request
Hi Derek,
Thank you for sending your email confirming that the engines at the facility have not been modified
and/or reconstructed since commencing operation. We have not received the mailed copy of the
letter with the CTAC, do you know if it had a tracking number associated with it? If so, could you
share it with us so that we may know when to expect it.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
From: Forsberg, Derek
Sent: Monday, October 21, 2019 3:19 PM
To: Familiare, Christopher S.
Cc: Meyer, Dan
Subject: RE: Northwest Pipeline - Pocatello Compressor Station Title V Renewal Additional
Information Request
Hello Chris. The engines at Pocatello have not been modified or reconstructed. I will put it in a
letter and send it to you with the CTAC.
And hello Dan. I remember working with you on the Pocatello permit renewal back around 2007. I
hope you are well sir.
Chris, let me know if you have any more questions. I'll get this letter mailed this week.
Thanks,
Derek
Page 154 of 270
-------
From: Familiare, Christopher S.
Sent: Wednesday, October 16, 2019 4:06 PM
To: Forsberg, Derek
Cc: Meyer, Dan
Subject: [EXTERNAL] Northwest Pipeline - Pocatello Compressor Station Title V Renewal Additional
Information Request
Dear Mr. Forsberg,
The Region 10 air permits team is currently processing your application. In the application, Williams
Northwest Pipeline states that each of its four stationary spark ignition internal combustion engines
at the Pocatello Compressor Station commenced construction prior to June 12, 2006, and therefore
each is an existing facility not subject to the requirements of Subpart JJJJ to 40 CFR Part 60
(Standards of Performance for Stationary Spark Ignition Internal Combustion Engines). Applicability is
not solely determined based upon the date construction of the facility commenced. NSPS Subpart
JJJJ may apply to an existing facility if it was subsequently modified and/or reconstructed (as those
terms are defined in 40 CFR 60.14 and 60.15, respectively) after the June 12, 2006 cutoff. The NSPS
modification and reconstruction general provisions apply pursuant to Table 3 to NSPS Subpart JJJJ.
Pursuant to 40 CFR 71.5(c)(5), we are requesting additional information as to whether NSPS Subpart
JJJJ is applicable to any of the four engines. Using the CTAC form at https://www.epa.gov/title-v-
operatine-permits/certification-truth-accuracy-and-completeness-ctac . please certify that none of
the four engines have been modified and/or reconstructed as those terms are defined in 40 CFR
60.14 and 60.15, respectively.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christopher@eDa.gov
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
Page 155 of 270
-------
From: Familiare. Christopher S.
To: nlen. iasek@williams.com
Cc: Forshern. Derek: lhowell@shtrihes.com: icarpenter@shtrihes.com: smartin@shtrihes.com
Subject: Williams Northwest Pipeline - Pocatello Compressor Station Completeness Determination for Title V Renewal
Date: Thursday, November 7, 2019 4:20:52 PM
Attachments: Jasek. Glen, title V Annlicaiton Completeness Determination letter 11.7.19 final.ndf
Dear Mr. Jasek:
Region 10 has determined that your application for a Title V renewal permit is complete. Attached to
this email is an electronic copy of a letter notifying you of that. The letter is being mailed out today.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
Page 156 of 270
-------
From: Familiare. Christopher S.
To: lhowell@shtrihes.com
Cc: smartin@shtrihes.com: icarpenter@shtrihes.com
Subject: Williams Northwest Pipeline - Pocatello Compressor Station Tribal Consultation for Title V Renewal
Date: Monday, November 18, 2019 3:51:14 PM
Attachments: Fdmo. Chairman. Fort Hall Business Council. Title V letter 11.18.19.ndf
Hi Lori,
Attached is a copy of the letter being sent to the Chairman of the Fort Hall Business Council, The
Honorable Ladd Edmo, in regards to consultation for the Williams Northwest Pipeline - Pocatello
Compressor Station's title V renewal permit. Please let me know if you have any questions or
concerns. Thank you.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
Page 157 of 270
-------
From:
To:
Cc:
Subject:
Date:
Familiare. Christopher S.
I ori Howell
Mever. Dan
RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness Determination for Title V Renewal
Wednesday, November 20, 2019 3:06:00 PM
Hi Lori,
As you know, EPA Region 10 is processing the Williams Northwest Pipeline Title V permit renewal
application for the Pocatello Compressor Station. Within the next few months, we'll have a pre-draft
renewal permit ready to share with you and the company. Thereafter, we'll share a proposed permit
with the public. To satisfy our "public notice" obligations in 40 CFR 71.11(d)(3), we typically provide
notice to the public of our proposed permitting action electronically at https://www.eDa.gov/caa-
nermitting/caa-nermitting-enas-nacific-northwest-region and https://www.eDa.gov/Dublicnotices.
Providing notice in a newspaper is no longer compulsory. It's optional. Please let me know whether
the Tribe would like Region 10 to provide public notice in a local newspaper, and if so, which one.
We do not intend to provide notice in a local newspaper unless you specially request us to do so.
Also, do you know if there are any updates needed for the Tribal Contact listed below that is
currently in the permit?
Penny Weymiller
Air Quality Program Manager
Shoshone-Bannock Tribes
P.O. Box 306
Fort Hall, Idaho 83203
Phone: (208)478-3853
Fmail: Dwevmiller@sbtribes.coni
From: Lori Howell
Sent: Friday, November 8, 2019 8:14 AM
To: Familiare, Christopher S.
Subject: RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness
Determination for Title V Renewal
Thank you.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christopherOepa.eov
Page 158 of 270
-------
Thank You for the information.
From: Familiare, Christopher S.
Sent: Thursday, November 7, 2019 5:21 PM
To: glen.iasek@williams.com
Cc: Forsberg, Derek : Lori Flowell : Jeff
Carpenter : Shayna McCrary-Martin
Subject: Williams Northwest Pipeline - Pocatello Compressor Station Completeness Determination
for Title V Renewal
Dear Mr. Jasek:
Region 10 has determined that your application for a Title V renewal permit is complete. Attached to
this email is an electronic copy of a letter notifying you of that. The letter is being mailed out today.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.chrlstopher@epa.gov
Page 159 of 270
-------
From:
To:
Subject:
Date:
Lori Howell
Familiare. Christopher S.
RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness Determination for Title V Renewal
Monday, November 25, 2019 1:51:54 PM
Hi Christopher,
I apologize, I've been on leave. I am the AQ Manager now. Thank you for contacting us and I will
talk to Council on this.
From: Familiare, Christopher S.
Sent: Wednesday, November 20, 2019 4:07 PM
To: Lori Howell
Cc: Meyer, Dan
Subject: RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness
Determination for Title V Renewal
As you know, EPA Region 10 is processing the Williams Northwest Pipeline Title V permit renewal
application for the Pocatello Compressor Station. Within the next few months, we'll have a pre-draft
renewal permit ready to share with you and the company. Thereafter, we'll share a proposed permit
with the public. To satisfy our "public notice" obligations in 40 CFR 71.11(d)(3), we typically provide
notice to the public of our proposed permitting action electronically at https://www.eDa.gov/caa-
nermitting/caa-nermitting-enas-nacific-northwest-region and https://www.eDa.gov/Dublicnotices.
Providing notice in a newspaper is no longer compulsory. It's optional. Please let me know whether
the Tribe would like Region 10 to provide public notice in a local newspaper, and if so, which one.
We do not intend to provide notice in a local newspaper unless you specially request us to do so.
Also, do you know if there are any updates needed for the Tribal Contact listed below that is
currently in the permit?
Penny Weymiller
Air Quality Program Manager
Shoshone-Bannock Tribes
P.O. Box 306
Fort Hall, Idaho 83203
Phone: (208)478-3853
Fmail: pwevmiller@sbtribes.com
Hi Lori,
Thank you.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
Page 160 of 270
-------
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
From: Lori Howell
Sent: Friday, November 8, 2019 8:14 AM
To: Familiare, Christopher S.
Subject: RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness
Determination for Title V Renewal
Thank You for the information.
From: Familiare, Christopher S.
Sent: Thursday, November 7, 2019 5:21 PM
To: glen.iasek@williams.com
Cc: Forsberg, Derek : Lori Flowell : Jeff
Carpenter : Shayna McCrary-Martin
Subject: Williams Northwest Pipeline - Pocatello Compressor Station Completeness Determination
for Title V Renewal
Dear Mr. Jasek:
Region 10 has determined that your application for a Title V renewal permit is complete. Attached to
this email is an electronic copy of a letter notifying you of that. The letter is being mailed out today.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christopher@eDa.gov
Page 161 of 270
-------
From: Lori Howell
To: Familiare. Christopher S.
Subject: RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness Determination for Title V Renewal
Date: Tuesday, November 26, 2019 3:24:53 PM
Mine is 208-478-3794
Thanks
From: Familiare, Christopher S.
Sent: Tuesday, November 26, 2019 11:46 AM
To: Lori Howell
Subject: RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness
Determination for Title V Renewal
Thank you Lori. Did the phone number change or is it the same as the previously listed one?
Lori Howell
Air Quality Program Manager
Shoshone-Bannock Tribes
P.O. Box 306
Fort Hall, Idaho 83203
Phone:(208)478-3853
Fmail: lhowell@sbtribes.com
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
From: Lori Howell
Sent: Monday, November 25, 2019 1:52 PM
To: Familiare, Christopher S.
Subject: RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness
Determination for Title V Renewal
Hi Christopher,
I apologize, I've been on leave. I am the AQ Manager now. Thank you for contacting us and I will
talk to Council on this.
From: Familiare, Christopher S.
Sent: Wednesday, November 20, 2019 4:07 PM
Page 162 of 270
-------
To: Lori Howell
Cc: Meyer, Dan
Subject: RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness
Determination for Title V Renewal
Hi Lori,
As you know, EPA Region 10 is processing the Williams Northwest Pipeline Title V permit renewal
application for the Pocatello Compressor Station. Within the next few months, we'll have a pre-draft
renewal permit ready to share with you and the company. Thereafter, we'll share a proposed permit
with the public. To satisfy our "public notice" obligations in 40 CFR 71.11(d)(3), we typically provide
notice to the public of our proposed permitting action electronically at https://www.epa.gov/caa-
permitting/caa-permitting-epas-pacific-northwest-region and https://www.epa.gov/publicnotices.
Providing notice in a newspaper is no longer compulsory. It's optional. Please let me know whether
the Tribe would like Region 10 to provide public notice in a local newspaper, and if so, which one.
We do not intend to provide notice in a local newspaper unless you specially request us to do so.
Also, do you know if there are any updates needed for the Tribal Contact listed below that is
currently in the permit?
Penny Weymiller
Air Quality Program Manager
Shoshone-Bannock Tribes
P.O. Box 306
Fort Hall, Idaho 83203
Phone: (208)478-3853
Fmail: Dwevmiller@sbtribes.coni
From: Lori Howell
Sent: Friday, November 8, 2019 8:14 AM
To: Familiare, Christopher S.
Subject: RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness
Determination for Title V Renewal
Thank you.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christopherOepa.eov
Page 163 of 270
-------
Thank You for the information.
From: Familiare, Christopher S.
Sent: Thursday, November 7, 2019 5:21 PM
To: glen.iasek@williams.com
Cc: Forsberg, Derek : Lori Flowell : Jeff
Carpenter : Shayna McCrary-Martin
Subject: Williams Northwest Pipeline - Pocatello Compressor Station Completeness Determination
for Title V Renewal
Dear Mr. Jasek:
Region 10 has determined that your application for a Title V renewal permit is complete. Attached to
this email is an electronic copy of a letter notifying you of that. The letter is being mailed out today.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.chrlstopher@epa.gov
Page 164 of 270
-------
From: Familiare. Christopher S.
To: I ori Howell
Subject: RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness Determination for Title V Renewal
Date: Tuesday, November 26, 2019 10:46:00 AM
Thank you Lori. Did the phone number change or is it the same as the previously listed one?
Lori Howell
Air Quality Program Manager
Shoshone-Bannock Tribes
P.O. Box 306
Fort Hall, Idaho 83203
Phone:(208)478-3853
Email: lhowell@sbtribes.com
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
From: Lori Howell
Sent: Monday, November 25, 2019 1:52 PM
To: Familiare, Christopher S.
Subject: RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness
Determination for Title V Renewal
Hi Christopher,
I apologize, I've been on leave. I am the AQ Manager now. Thank you for contacting us and I will
talk to Council on this.
From: Familiare, Christopher S.
Sent: Wednesday, November 20, 2019 4:07 PM
To: Lori Howell
Cc: Meyer, Dan
Subject: RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness
Determination for Title V Renewal
Hi Lori,
As you know, EPA Region 10 is processing the Williams Northwest Pipeline Title V permit renewal
application for the Pocatello Compressor Station. Within the next few months, we'll have a pre-draft
Page 165 of 270
-------
renewal permit ready to share with you and the company. Thereafter, we'll share a proposed permit
with the public. To satisfy our "public notice" obligations in 40 CFR 71.11(d)(3), we typically provide
notice to the public of our proposed permitting action electronically at https://www.eDa.gov/caa-
nermitting/caa-nermitting-enas-nacific-northwest-region and https://www.epa.gov/publicnotices.
Providing notice in a newspaper is no longer compulsory. It's optional. Please let me know whether
the Tribe would like Region 10 to provide public notice in a local newspaper, and if so, which one.
We do not intend to provide notice in a local newspaper unless you specially request us to do so.
Also, do you know if there are any updates needed for the Tribal Contact listed below that is
currently in the permit?
Penny Weymiller
Air Quality Program Manager
Shoshone-Bannock Tribes
P.O. Box 306
Fort Hall, Idaho 83203
Phone: (208)478-3853
Fmail: Dwevmiller@sbtribes.coni
From: Lori Flowell
Sent: Friday, November 8, 2019 8:14 AM
To: Familiare, Christopher S.
Subject: RE: Williams Northwest Pipeline - Pocatello Compressor Station Completeness
Determination for Title V Renewal
Thank You for the information.
From: Familiare, Christopher S.
Sent: Thursday, November 7, 2019 5:21 PM
To: glen.iasek@williams.com
Cc: Forsberg, Derek : Lori Flowell : Jeff
Carpenter : Shayna McCrary-Martin
Subject: Williams Northwest Pipeline - Pocatello Compressor Station Completeness Determination
for Title V Renewal
Thank you.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christopher@eDa.gov
Page 166 of 270
-------
Dear Mr. Jasek:
Region 10 has determined that your application for a Title V renewal permit is complete. Attached to
this email is an electronic copy of a letter notifying you of that. The letter is being mailed out today.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
mm
1200 6th Ave, Suite 155, 15-H13
%' .01
Seattle, WA 98101
(7061-553-1 750 | familiare.christoDher@eDa.eov
Page 167 of 270
-------
From:
To:
Subject:
Date:
Forsbera. Derek
Familiare. Christopher S.
RE: Pocatello Report
Wednesday, January 29, 2020 9:12:37 AM
Thanks Christopher. Also, it looks like the requirements listed in the Pocatello permit are not
correct. From reading (C)(1), Williams does not need to submit total operating time as required by
(C)((5)(iv). Only (i), (ii) and (iii) apply. Let me know your thoughts.
(c) A compliance report must contain the following information depending
on how the facility chooses to comply with the limits set in this rule.
(1) If the fad 1, is subject to the > merits of a tune up you
must submit a compliance report with the information in paragraphs (c)
(5)(i) through > of this section, (xiv) and (xvii) of this section,
and paragraph (c)(5)(iv) of this section for limit- ^ 1,1 ¦ -cess
heater.
From: Familiare, Christopher S.
Sent: Wednesday, January 29, 2020 10:06 AM
To: Forsberg, Derek
Subject: [EXTERNAL] RE: Pocatello Report
Hi Derek,
Just wanted to let you know that I am looking deeper into this matter and will let you know what I
find out by the end of the day. Thanks.
Thanks,
Derek
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christopherOepa.eov
From: Forsberg, Derek
Sent: Wednesday, January 29, 2020 8:16 AM
To: Familiare, Christopher S.
Subject: Pocatello Report
Page 168 of 270
-------
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
Page 169 of 270
-------
From: Familiare. Christopher S.
To: Forshern. Derek
Subject: RE: Pocatello Report
Date: Wednesday, January 29, 2020 9:05:00 AM
Hi Derek,
Just wanted to let you know that I am looking deeper into this matter and will let you know what I
find out by the end of the day. Thanks.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
From: Forsberg, Derek
Sent: Wednesday, January 29, 2020 8:16 AM
To: Familiare, Christopher S.
Subject: Pocatello Report
Page 170 of 270
-------
From:
To:
Subject:
Date:
Forsbera. Derek
Familiare. Christopher S.
RE: Pocatello Report
Wednesday, January 29, 2020 9:37:31 AM
Additionally, the compliance periods seem to be off as listed in the permit 6.6.1. It states that the
period ends January 31, 2017, but the regulations in (b)(1) state that the period ends December 31.
Am I reading that correctly?
iler or process heater in , . s and ending on June 30 or
December 31, whichever date is the first date that occurs at least 180
days after the compliance date that is specified for your source in §
83.7495. If submitting an annual, biennial, or 5-year compliance report,
the first compliance report must cover the period beginning on
the £ a nee date that is specified for each boiler or process
heater in v . " ~ i 5 and ending on December 31 within 1, 2, or 5 years,
as applicable, after the compliance date that is specified for
your source in
From: Forsberg, Derek
Sent: Wednesday, January 29, 2020 10:12 AM
To: Familiare, Christopher S.
Subject: RE: Pocatello Report
Thanks Christopher. Also, it looks like the requirements listed in the Pocatello permit are not
correct. From reading (C)(1), Williams does not need to submit total operating time as required by
(C)((5)(iv). Only (i), (ii) and (iii) apply. Let me know your thoughts.
Thanks,
Derek
Page 171 of 270
-------
Thanks,
Derek
(c) A compliance report must contain the following information depending
on how the facility chooses to comply with the limits set in this rule.
(D If the facility is subject to the requirements of a tune up you
must submit a compliance report with the information in paragraphs (c)
(5) (i) through of this section, (xiv) and (xvii) of this section,
and paraorap of this section for
From: Familiare, Christopher S.
Sent: Wednesday, January 29, 2020 10:06 AM
To: Forsberg, Derek
Subject: [EXTERNAL] RE: Pocatello Report
Hi Derek,
Just wanted to let you know that I am looking deeper into this matter and will let you know what I
find out by the end of the day. Thanks.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
From: Forsberg, Derek
Sent: Wednesday, January 29, 2020 8:16 AM
To: Familiare, Christopher S.
Subject: Pocatello Report
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
Page 172 of 270
-------
From:
To:
Subject:
Date:
Familiare. Christopher S.
Forshern. Derek
RE: Pocatello Report
Wednesday, January 29, 2020 3:46:00 PM
Hi Derek,
I'm not able to complete my analysis of this by the end of today so I will follow up with you and send
you direction on how to proceed by tomorrow. Thanks.
From: Forsberg, Derek
Sent: Wednesday, January 29, 2020 9:37 AM
To: Familiare, Christopher S.
Subject: RE: Pocatello Report
Additionally, the compliance periods seem to be off as listed in the permit 6.6.1. It states that the
period ends January 31, 2017, but the regulations in (b)(1) state that the period ends December 31.
Am I reading that correctly?
-------
December 31, whichever date is the first date that occurs at least 180
days after the compliance date that is specified for your source in §
83.7495. If submitting an annual, biennial, or 5-year compliance report,
the first q £ report must cover the period beginning on
the compliance date that is specified for each boiler or process
heater in and ending on December 31 within 1, 2, or 5 years,
as applicable, after the rampliance_date that is specified for
your sourt 1 in , ; j .
From: Forsberg, Derek
Sent: Wednesday, January 29, 2020 10:12 AM
To: Familiare, Christopher S.
Subject: RE: Pocatello Report
Thanks Christopher. Also, it looks like the requirements listed in the Pocatello permit are not
correct. From reading (C)(1), Williams does not need to submit total operating time as required by
(C)((5)(iv). Only (i), (ii) and (iii) apply. Let me know your thoughts.
Thanks,
Derek
(c) A compliance report must contain the following information depending
on how the facility chooses to comply with the limits set in this rule.
(D If the facility is subject to the requirements of a tune up you
must submit a compliance report with the information in paragraphs (c)
(5) (i) through of this section, (xiv) and (xvii) of this section,
and pacagEiipliitlXBXivl of this section for limUsd^iJseJbQilei^ process
heater.
From: Familiare, Christopher S.
Sent: Wednesday, January 29, 2020 10:06 AM
To: Forsberg, Derek
Subject: [EXTERNAL] RE: Pocatello Report
Hi Derek,
Just wanted to let you know that I am looking deeper into this matter and will let you know what I
find out by the end of the day. Thanks.
Christopher Familiare
Page 174 of 270
-------
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
From: Forsberg, Derek
Sent: Wednesday, January 29, 2020 8:16 AM
To: Familiare, Christopher S.
Subject: Pocatello Report
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
Page 175 of 270
-------
Williams
NORTHWEST PIPELINE LLC
Environmental Services
295 Chipeta Way, 3ri Floor
Salt Lake City, UT 84108-1220
February 16, 2016
Janis Hastings
Director Office of Air, Waste and Toxics
EPA Region 10
1200 6th Ave., Suite 900
AWT-107
Seattle, WA 98101
RE: Northwest Pipeline LLC - Pocatello Compressor Station
MACT Subpart DDDDD Notification of Compliance Status
Deal- Ms. Hastings;
This submittal serves as the Notification of Compliance Status pursuant to Subpart DDDDD
notification requirements (40 CFR 63,7545) and Subpart A (40 CFR 63.9(h)(2)) for the
Northwest Pipeline LLC (Northwest) - Pocatello Compressor Station (Facility) located at 2615
Gas Plant Road, Pocatello, Idaho. This facility only burns natural gas which is subject to this
subpart. The following existing process heaters are Subpart DDDDD applicable, but because
they only bum a gas 1 fuel they are not subject to emission limits in Tables 1 and 2 or 11 through
13, or the operating limits in Table 4 per §63.7500(e):
Unit#
Heat rating
Heater Type
(§63.7490)
Tune-Up Frequency
(Table 3 to Subpart
DDDDD)
6
3,35 MMBtu/hr
Existing Process
Heater
Initial; Every 5 years
7
0.5 MMBtu/hr
Existing Process
Heater
Initial; Every 5 years
Northwest contracted Sage Environmental Consulting to conduct the energy assessment as
required by Subpart DDDDD. This facility has had an energy assessment performed according to
§63.7530(e). The Energy Assessment report was received by Northwest on September 9, 2015.
The report describes the evaluation of the affected process heaters as well as their major energy-
use systems, and identifies and assesses any potential practical energy conservation measures
available that exhibited a simple payback of two (2) years or less. This Energy Assessment report
will be kept at the Facility's field office.
Page 176 of 270
-------
In addition to the energy assessment, Northwest conducted initial tune-ups on the above listed
Subpart DDDDD affected heaters. This facility complies with the required initial tune-up
according to the procedures in §63.7540(a)(10).
Per 63.7545(e)(8) the following certification of compliance is signed below by the responsible
official.
If you have any questions or require additional information, please contact me at (801) 584-6748
or by email at derek.forsberg@Williams.com,
Sincerely,
Environmental Specialist
Cc: Lori Howell
Shoshone-Bannock Tribe
Air Quality
P.O. Box 306
Fort Hall, ID 83203
As the Responsible Official for the Northwest Pipeline LLC South Operations, I certify that this
Facility has conducted an energy assessment according to Table 3 to Subpart DDDDD and that
the report, completed as a part of the energy assessment, provides an accurate depiction of the
Facility at the time of the assessment, and that based on reasonable inquiry, the statements and
information contained in this notification are true, accurate, and complete to the best of my
knowledge.
Pete Richards Director, Operations South
Signature
Date
Page 177 of 270
-------
From:
To:
Cc:
Subject:
Date:
Attachments:
Forsbera. Derek
Familiare. Christopher S.
Forshern. Derek
RE: Williams Northwest Pocatello Compressor Station Compliance Report Submittal
Friday, January 31, 2020 1:09:05 PM
Scanned and Sinned I etter and CTAC.ndf
Christopher, Please see the attached report. Our responsible official signed the CTAC. I will FedEx
the original hard copy when I receive it on Monday. Our VP GM is not in Salt Lake today. Please let
me know what else you need.
From: Familiare, Christopher S.
Sent: Friday, January 31, 2020 10:30 AM
To: Forsberg, Derek
Subject: [EXTERNAL] Williams Northwest Pocatello Compressor Station Compliance Report Submittal
To fulfill permit condition 6.6, turn in to EPA Region 10 a compliance report that includes the
following information:
1. The Company and Facility name and address.
2. The Process unit information.
3. The date of report and beginning and ending dates of the reporting period. (This report should
cover the time period from January 31, 2016 to December 31, 2016, not January 31, 2017 as
Condition 6.6.1 states.)
4. The date of the most recent tune-up for each unit subject to only the requirement to conduct
an 5-year tune-up according to 40 CFR 63.7540(a)( 12) (see Conditions 6.1.3 and 6.4.4), and
the date of the most recent burner inspection if it was not done on a 5-year period and was
delayed until the next scheduled or unscheduled unit shutdown.
5. If there are no deviations from the requirements for work practice standards in Table 3 to
Subpart DDDDD of Part 63 that apply to the permittee, a statement that there were no
deviations from the work practice standards during the reporting period.
6. If the permittee has a deviation from a work practice standard during the reporting
period, the report must contain a description of the deviation and information on the
duration and cause of the deviation and corrective action taken.
7. A statement by a responsible official (as defined in 40 CFR 71.2) with that official's name, title,
and signature, certifying the truth, accuracy, and completeness (CTAC) of the content of the
report. CTAC form available at https://www.epa.gov/sites/production/files/2016-
05/documents/ctac 5900-02.pdf
Mail the report to the EPA Region 10 Clean Air Act Compliance Manager at the following address:
Thanks,
Derek
Derek,
Page 178 of 270
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Clean Air Act Compliance Manager
U.S. EPA-Region 10, 20-C04
1200 Sixth Avenue, Suite 155
Seattle, WA 98101-3188
Please email me a copy of the report after you mail it out. I'll make note of the submittal in the
statement of basis I'm drafting for the part 71 permit renewal.
As you correctly pointed out, although condition 6.6.3.4 states that you are required to report each
unit's total operating time during the reporting period, that requirement is not applicable (and
should not have been included in the permit) pursuant to 40 CFR 63.7550(c)(1).
Let me know if you have any questions.
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christopherOepa.eov
Page 179 of 270
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Williams
NORTHWEST PIPELINE LLC
Environmental Services
295 Chipeta Way, T> Floor
Salt Late city, UT 84108 -1220
January 31, 2020
Clean Air Act Compliance Manager
U.S. EPA - Region 10, 20-C04
1200 Sixth Avenue, Suite 155
Seattle, WA 98101-3188
RE: Northwest Pipeline LLC - Poeatello Compressor Station
MACT Subpart 1)1)1)1)1) Notification of Compliance Status REVISED
Dear Clean Air Act Compliance Manager:
This submittal serves as a modification to the Notification of CompHanee Status letter sent on
February 16, 2016, Christopher Pamiliare, EPA Permit Engineer, while working on the
Poeatello Title V permit renewal, identified necessary permit condition modifications and
requested that Williams submit this report, Additionally, the original submittal did not identity
the beginning and ending dates of the reporting period. The submittal meets Subpart 1)1)1)1)1)
notification requirements (40 CFR 63.7545) and Subpart A (40 CFR (>3.0(h)(2)) for the
Northwest Pipeline LLC (Northwest) - Poeatello Compressor Station (Facility) located at 2605
Gas Plant Road, Poeatello, Idaho.
This facility only burns natural gas which is subject to this subpart. The following existing
process heaters are Subpart 1)1)1)1)1) applicable, but because they only burn a gas 1 fuel they are
not subject to emission limits in 'Fables I and 2 or 11 through 13, or the operating limits in Table
4 per §63.7500(e):
Unit #
Uc;i(
3.35 MMBtu/hr
0.5 MMBtu/hr
Jirak'r ] ype
Existing Process
I [eater
Existing Process
11 eater
TuiU'-l |i Frequency
(Table 3 to SubfKirf
1 niji al; Every 5 years
Jnitial; Every 5 years
Northwest contracted Sage Environmental Consulting to conduct the energy assessment as
required by Subpart DDDDL), This facility has had an energy assessment performed according to
§63.7530(e), The Energy Assessment report was received by Northwest on September 9, 2015.
The report describes the evaluation of the affected process heaters as well as their major energy-
use systems, and identifies and assesses any potential practical energy conservation measures
Page 180 of 270
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available thai exhibited a simple payback of two (2) years or less. This Lnergy Assessment repurt
will be kept ai the facility's field offiee.
An email from Christopher Familiare to me oil January J1, 2020 outlined the following "I items
listed in eonditiori 0,6 of the Poeateilo Title V permit that are required in this submittal. A eopy
of the email is attached to this submittal. The conditions and responses arc shown below;
I) The Company and facility name and address.
Williams Corporation. Northwest Pipeline IXC
2605 Gas Plant Road
I'oeatello, II)
Latitude: 42° 4><* 55" N
Longitude: 112° 42' I3"W
2) The Proeess unit information.
I nil
6
7
Ik>at raJin^
3.35 MMBtii/hr
0,5 MJVIHui/hr
I ieaici' i \]h>
(§63,7490)
I listing Process
11 eater
Existing Process
1Ieater
Tunc-Dp Frequency
(Tablf H) Subpart
I > I) I) I) I)}
Initial; Every 5 years_
Initial; Every 5 years
3) The date of report and beginning and ending dates of the reporting period.
• The date of this report is January 3 1, 2020.
• This report eovers the lime period from January 3 1, 2016 to I Jeeember 3 L 2016.
4) The date of the most recent tune-up for each unit subjeet to only the requirement to conduct a
5-year tune-up according to 40 CFR 63,?540(a)(12)
• 3.35 MMBtu/hr Proeess I leater Tunc Up: November 12,2015
• 0.5 MMBtu/hr Process I leaLer Tune Up: December 15, 2015
5) If there are no deviations from the requirements for work praetiee standards in 'fable 3 to
Subpart 1)1)1)1)1) of Part 63 that apply to the permittee, a statement that there were no deviations
from the work praetiee standards during the reporting period.
• "There were no deviations from the requirements for work praetiee standards
during the reporting period."
6) If the permittee has a deviation from a work praetiee standard during the reporting
period, the report must eontain a de.seription of the deviation and information on the duration
and eause of the deviation and eorreetive aetion taken.
• "There were no deviations from the requirements for work praetiee standards
during the reporting period.1'
Page 181 of 270
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7) A statement by a responsible oflicial (as defined in 40 (TR 71.2) wilh that official's name,
title, and signature, certifying the (ruth, accuracy, untl completeness (CTAC) of the content of the
report, CTAC form available at hup-*:,' w w \\ .epa.gt>v/sitcs^prtuliictionM'ilcsOO 1ft-
05 documentv'etae 5900-02.pdf
» The signed CTAC form is attached. Flea.se note the responsible official lias
changed for the Northwest Pipeline. The new responsible oflicial is Oamilo
Amczquila, Northwest Pipeline VP GML
If you have any questions or require additional in formation, please contact me at (801) 584-6748
or by email at ;u-ivk ii>rs'viV'..i om.
Sincerely,
Derek Forsbcrg
Knvironmental Specialist
Ce: Lori Howell
Shoshone-Bannock Tribe
Air Quality
P.O. Box 306
Fort Hall, ID 83203
Page 182 of 270
-------
Subject:
From:
Sent:
To:
Farniliare, Christopher S,
Friday, January 31, 2020 10:30 AM
Forsberg, Derek
[EXriiRNAL] Williams Northwest Pocatelto Compressor Station Compliance Report Submittal
Derek,
To fulfill permit condition 8,6, turn in to EPA Region 10 a compliance report that includes the following information:
1) The Company and Facility name and address,
2) The Process unit information.
3} The date of report and beginning and ending dates of the reporting period. {This report should cover the time
period from January 33, 2016 to December 31, 2016, not January 31, 2017 as Condition 6,6.1 states.)
4) The date of the most recent tune-up for each unit subject to only the requirement to conduct an 5-year tune-up
according to 40 CFR 6.3.7540(a)(12) (see Conditions 6,1.3 and 6.4.4), and the date of the most recent burner
inspection if it was not done on a 5-year period and was delayed until the next scheduled or unscheduled unit
shutdown.
5) If there are no deviations from the requirements for work practice standards in Table 3 to Subpart DDDDD of
Part 63 that apply to the permittee, a statement that there were no deviations from the work practice standards
during the reporting period.
6) If the permittee has a deviation from a work practice standard during the reporting period, the report must
contain a description of the deviation and information on the duration and cause of the deviation and
corrective action taken.
7) A statement by a responsible official (as defined in 40 CFR 71.2) with that official's name, title, and signature,
certifying the truth, accuracy, and completeness (CTAC) of the content of the report. CTAC form available at
h:/,/wv^.'vv.i'}v'/'Ji!iTi".-1!,u.r!0J Si 0S/
-------
Let me know if you have any questions.
Christopher Familiare
fcnvironmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 Gth Ave, Suite 155, 154-113
Seattle, WA 98101
(206)-h.S.H-IPSO | ui:; 1:: ;> .hn.U-rli. r..>-wa.gOV
: In--; >. in ill1 «i v.iiulf-unbiil.; i >) VVtllkmn U 1 ,«nli. in It ilii--die mL.iin. alt.
Hi!- if HI,lll« h'l
2
Page 184 of 270
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United States
Environmental Protection
# m Agency OMB No. 2080-0336, Expires 1
Federal Operating Permit Program (40 CFR Part 71)
CERTIFICATION OF TRUTH," ACCURACY, AND COMPLETENESS (CTAC)
This form must be completed, signed by the "Responsible Official" designated for the facility or
emission unit, and sent with each submission of documents (i.e., application forms, updates to
applications, reports, or any information required by a part 71 permit).
A. Responsible Official
Name: (Last) Amezquita (First) Camilo _______ (MI)
Title __ VP^M^Northwest Pipeline
Street or P.O. Box P.O. Box 58900
City Salt Lake City State UT ZIP 84158 - 0900
Telephone (713) 215 - 2524 _ Ext. _____ Facsimile ( ) _ -
B. Certification of Truth, Accuracy and Completeness (to be signed by the
responsible official)
I certify under penalty of law, based on information and belief formed after reasonable
inquiry, the statements and information contained in these documents arc true, accurate
and complete.
Name (signed)
y!>'
Name (typed) Camilo Amezquita
Date: / / ?/ / 2o2.fs
EPA Form 5900-02
Page 185 of 270
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From:
To:
Bcc:
Subject:
Date:
Familiare. Christopher S.
Forshern. Derek
McFadden. Kellv: McClint.ock. Katie: Mever. Dan
Williams Northwest Pocatello Compressor Station Compliance Report Submittal
Friday, January 31, 2020 9:29:00 AM
Derek,
To fulfill permit condition 6.6, turn in to EPA Region 10 a compliance report that includes the
following information:
1. The Company and Facility name and address.
2. The Process unit information.
3. The date of report and beginning and ending dates of the reporting period. (This report should
cover the time period from January 31, 2016 to December 31, 2016, not January 31, 2017 as
Condition 6.6.1 states.)
4. The date of the most recent tune-up for each unit subject to only the requirement to conduct
an 5-year tune-up according to 40 CFR 63.7540(a)( 12) (see Conditions 6.1.3 and 6.4.4), and
the date of the most recent burner inspection if it was not done on a 5-year period and was
delayed until the next scheduled or unscheduled unit shutdown.
5. If there are no deviations from the requirements for work practice standards in Table 3 to
Subpart DDDDD of Part 63 that apply to the permittee, a statement that there were no
deviations from the work practice standards during the reporting period.
6. If the permittee has a deviation from a work practice standard during the reporting
period, the report must contain a description of the deviation and information on the
duration and cause of the deviation and corrective action taken.
7. A statement by a responsible official (as defined in 40 CFR 71.2) with that official's name, title,
and signature, certifying the truth, accuracy, and completeness (CTAC) of the content of the
report. CTAC form available at https://www.epa.gov/sites/production/files/2016-
05/documents/ctac 5900-02.pdf
Mail the report to the EPA Region 10 Clean Air Act Compliance Manager at the following address:
Clean Air Act Compliance Manager
U.S. EPA-Region 10, 20-C04
1200 Sixth Avenue, Suite 155
Seattle, WA 98101-3188
Please email me a copy of the report after you mail it out. I'll make note of the submittal in the
statement of basis I'm drafting for the part 71 permit renewal.
As you correctly pointed out, although condition 6.6.3.4 states that you are required to report each
unit's total operating time during the reporting period, that requirement is not applicable (and
should not have been included in the permit) pursuant to 40 CFR 63.7550(c)(1).
Let me know if you have any questions.
Page 186 of 270
-------
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
! _ *** ¦ JJ
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(2061-553-1250 1 familiare.christoDherOeDa.gov
Page 187 of 270
-------
From: Familiare. Christopher S.
To: Forshern. Derek
Subject: RE: Williams Northwest Pocatello Compressor Station Compliance Report Submittal
Date: Thursday, February 6, 2020 4:14:00 PM
Hi Derek,
Thank you for your quick submittal of the requested information. Can you confirm for me that the
email address and other contact information for the new Responsible Official for the Pocatello
Compressor Station is correct:
Camilo Amezquita, Vice President & General Manager
Northwest Pipeline LLC
PO Box 58900
Salt Lake City, UT 84158-0900
Phone: 713-215-2524
F-mail: Camilo.Ame7ayita@williams.com
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
From: Forsberg, Derek
Sent: Friday, January 31, 2020 1:09 PM
To: Familiare, Christopher S.
Cc: Forsberg, Derek
Subject: RE: Williams Northwest Pocatello Compressor Station Compliance Report Submittal
Christopher, Please see the attached report. Our responsible official signed the CTAC. I will FedEx
the original hard copy when I receive it on Monday. Our VP GM is not in Salt Lake today. Please let
me know what else you need.
Thanks,
Derek
From: Familiare, Christopher S.
Sent: Friday, January 31, 2020 10:30 AM
To: Forsberg, Derek
Subject: [EXTERNAL] Williams Northwest Pocatello Compressor Station Compliance Report Submittal
Page 188 of 270
-------
Derek,
To fulfill permit condition 6.6, turn in to EPA Region 10 a compliance report that includes the
following information:
1. The Company and Facility name and address.
2. The Process unit information.
3. The date of report and beginning and ending dates of the reporting period. (This report should
cover the time period from January 31, 2016 to December 31, 2016, not January 31, 2017 as
Condition 6.6.1 states.)
4. The date of the most recent tune-up for each unit subject to only the requirement to conduct
an 5-year tune-up according to 40 CFR 63.7540(a)( 12) (see Conditions 6.1.3 and 6.4.4), and
the date of the most recent burner inspection if it was not done on a 5-year period and was
delayed until the next scheduled or unscheduled unit shutdown.
5. If there are no deviations from the requirements for work practice standards in Table 3 to
Subpart DDDDD of Part 63 that apply to the permittee, a statement that there were no
deviations from the work practice standards during the reporting period.
6. If the permittee has a deviation from a work practice standard during the reporting
period, the report must contain a description of the deviation and information on the
duration and cause of the deviation and corrective action taken.
7. A statement by a responsible official (as defined in 40 CFR 71.2) with that official's name, title,
and signature, certifying the truth, accuracy, and completeness (CTAC) of the content of the
report. CTAC form available at https://www.epa.gov/sites/production/files/2016-
05/documents/ctac 5900-02.pdf
Mail the report to the EPA Region 10 Clean Air Act Compliance Manager at the following address:
Clean Air Act Compliance Manager
U.S. EPA-Region 10, 20-C04
1200 Sixth Avenue, Suite 155
Seattle, WA 98101-3188
Please email me a copy of the report after you mail it out. I'll make note of the submittal in the
statement of basis I'm drafting for the part 71 permit renewal.
As you correctly pointed out, although condition 6.6.3.4 states that you are required to report each
unit's total operating time during the reporting period, that requirement is not applicable (and
should not have been included in the permit) pursuant to 40 CFR 63.7550(c)(1).
Let me know if you have any questions.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
th
Page 189 of 270
-------
1200 6 Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
This email originates outside of Williams. Use caution if this message contains attachments, links or
requests for information.
Page 190 of 270
-------
From:
To:
Cc:
Bcc:
Subject:
Date:
Attachments:
Familiare. Christopher S.
I ori Howell
icarpenter@shtrihes.com: smartin@shtrihes.com: McFadden. Kelly
Mever. Dan: Hardestv. Doun
Williams Corporation Northwest Pipeline Pocatello Compressor Station Pre-Draft Review
Friday, February 14, 2020 8:49:00 AM
Williams P71 SOR Ann A draft 200213 xlsx
Williams P71 SOB Pre-Draft 200214.pdf
Williams P71 Permit Pre-Draft 200214.ndf
Hi Lori,
I tried contacting you yesterday regarding the attached pre-draft Title V permit, statement of basis
and appendices to the statement of basis for the Williams Pocatello compressor station. I will be
sharing the materials with the company later today, but I wanted to contact you first. If you have
questions or comments on the attached materials, it would be great if you could share those with us
by COB February 28th.
I am hoping to begin the 30-day public comment process around the beginning of March. I will be
providing public notice of Region 10's proposed permitting action via our website. The public will
have access to the administrative record (permit, statement of basis, and all supporting materials)
over that same website. I am not intending to provide public notice through newspaper, and I am
not intending to provide the public access to a hardcopy of the administrative record. Please let me
know if the tribe is okay with that approach.
Looking forward to hearing back from you.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
Page 191 of 270
-------
From:
To:
Cc:
Bcc:
Subject:
Date:
Attachments:
Familiare. Christopher S.
Forshern. Derek
McFadden. Kellv: lhowell@shtrihes.com
Mever. Dan: Hardestv. Doun: McClintock. Katie: McGown. Michael
Williams Corporation Northwest Pipeline Pocatello Compressor Station Pre-Draft Review
Friday, February 14, 2020 8:56:00 AM
Williams P71 SOR Pre-Draft 200214.pdf
Williams P71 Permit Pre-Draft 200214.pdf
Williams P71 SOR Ann A draft 200213 xlsx
Mr. Forsberg,
Attached is the pre-draft Title V permit, statement of basis and appendices to the statement of basis
for the Williams Corporation, Northwest Pipeline LLC - Pocatello Compressor Station facility. While
the upcoming public comment period is your opportunity to comment on the draft permit and
supporting documents, we are making a pre-draft version available to make sure we did not make
any errors regarding your equipment and operations.
Please review the documents and let me know whether you identify any errors. I am hoping to begin
the 30-day public comment process around the beginning of March. If you can send me any
questions or comments you have by COB February 28th, that would be very much appreciated.
I am open to receiving your input and questions via email, phone, letter, etc. Feel free to call if you
need me to explain anything. I look forward to hearing from you.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christoDher@eDa.gov
Page 192 of 270
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United States Environmental Protection Agency Permit Number: R10T5110200
Region 10, Air & Radiation Division Issued: Draft
1200 Sixth Avenue, Suite 155, 15-H13 Effective: Draft
Seattle, Washington 98101-3188 Expiration: Five years from issue
Replaces: R10T5110100
AFS Plant I.D. Number: 16-005-00049
Title V Air Quality Operating Permit
Permit Renewal #2
In accordance with the provisions of Title V of the Clean Air Act (42 U.S.C. 7401 et seq), 40 CFR Part
71 and other applicable rules and regulations,
Williams Corporation, Northwest Pipeline LLC
Pocatello Compressor Station
is authorized to operate air emission units and to conduct other air pollutant emitting activities in
accordance with the conditions listed in this permit. This source is authorized to operate in the following
location:
Location: Fort Hall Indian Reservation
2605 Gas Plant Road
Pocatello, Idaho
Latitude: 42° 48' 55" N
Longitude: 112° 42' 13" W
Responsible Official: Camilo Amezquita, Vice President & General Manager
Northwest Pipeline LLC
PO Box 58900
Salt Lake City, UT 84158-0900
Phone: 713-215-2524
E-mail: Camilo.Amezquita@williams.com
Company Contact: Derek Forsberg
Northwest Pipeline LLC
Environmental Compliance
P.O. Box 58900
Salt Lake City, UT 84158-0900
Phone: 801-584-6748
E-mail: Derek.Forsberg@williams.com
The United States Environmental Protection Agency (EPA) has also developed a statement of basis that
describes the bases for conditions contained in this permit.
Kelly McFadden, Chief Date
Air Permits and Toxics Branch
Air and Radiation Division
U.S. EPA, Region 10
Page 193 of 270
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Table of Contents
Abbreviations & Symbols
1. Source Information and Emission Units
2. Standard Terms and Conditions
Compliance with the Permit
Permit Shield
Other Credible Evidence
Permit Actions
Permit Expiration and Renewal
Off-Permit Changes
Emissions Trading and Operational Flexibility
Severability
Property Rights
3. General Requirements
General Compliance Schedule
Inspection and Entry
Open Burning Restrictions
Visible Emissions Limits
Fugitive Particulate Matter Requirements and Recordkeeping .
Other Work Practice Requirements and Recordkeeping
General Testing and Associated Recordkeeping and Reporting
General Recordkeeping
General Reporting
Part 71 Emission and Fee Reporting
Annual Registration
Periodic and Deviation Reporting
Annual Compliance Certification
Document Certification
Permit Renewal
4. Facility-Specific Requirements
Fees and Emission Reports Due Date
Fuel Restriction
Fuel Sulfur Limits
Fuel Sulfur Monitoring and Recordkeeping
Visible and Fugitive Emission Monitoring and Recordkeeping
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Page 2 of
Page 194 of 270
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Table of Contents
Monitoring for Modifications to the Facility not Undergoing PSD Review
Reporting for Modifications to the Facility not Undergoing PSD Review
NESHAP Work Practice Requirements
NESHAP Recordkeeping Requirements
NESHAP Notification and Reporting Requirements
5. Unit-Specific Requirements - NESHAP Subpart ZZZZ for Unit #5 (Emergency Generator
Engine)
Unit #5 Work Practice Requirements
Unit #5 Monitoring and Recordkeeping Requirements
Unit #5 Reporting Requirements
6. Unit-Specific Requirements - NESHAP Subpart DDDDD for Units #6 (Boiler) and 7 (Process
Heater)
Units #6 and 7 Work Practice Requirements
Units #6 and 7 Monitoring and Recordkeeping Requirements
Units #6 and 7 Notification and Reporting Requirements
22
23
23
23
24
24
24
26
26
27
27
28
28
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200
Page 195 of 270
Page 3 of 29
-------
Abbreviations & Symbols
# Number
% Percent
ASTM American Society for Testing and Materials
Btu British thermal units
BBL Barrels (42 gallons)
CAA Clean Air Act [42 U.S.C. section 7401 et seq.]
CBI Confidential Business Information
CFR Code of Federal Regulations
CMS Continuous Monitoring System
CO Carbon monoxide
COMS Continuous opacity monitoring system
EPA United States Environmental Protection Agency (also U.S. EPA)
EU Emission Unit
FARR Federal Air Rules for Reservations
Hr Hour
IEU Insignificant Emission Unit
MMBtu One million Btu
NESHAP National Emission Standards for Hazardous Air Pollutants (40 CFR Parts 61 and 63)
No. Number
NOx Nitrogen oxides
NSR New Source Review
PM Particulate matter
PM io Particulate matter less than or equal to 10 microns in aerodynamic diameter
PM2.5 Particulate matter less than or equal to 2.5 microns in aerodynamic diameter
PSD Prevention of Significant Deterioration
SO2 Sulfur dioxide
VOC Volatile organic compound
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200
Page 196 of 270
Page 4 of 29
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1. Source Information and Emission Units
The Pocatello Compressor Station operates remotely from Northwest Pipeline's headquarters
located in Salt Lake City, Utah. The compressor station is used to transmit natural gas along the
company's natural gas pipeline. All emission units are fired exclusively on natural gas. The
emission units are listed in Table 1.
Table 1: Emission Units (EU) & Control Devices
EU ID#
Emission Unit Description
Control Device
Unit 1
Clark TLA-6 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas fired, 14.8
MMBtu/hr, 2,000 horsepower; SN: 73546, installed 1956
None
Unit 2
Clark TLA-6 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas-fired, 14.8
MMBtu/hr, 2,000 horsepower; SN: 73547, installed 1956
None
Unit 3
Clark TLA-6 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas fired, 14.8
MMBtu/hr, 2,000 horsepower; SN: 73548, installed 1956
None
Unit 4
Clark TCV-10 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas fired; 21.7
MMBtu/hr, 4,300 horsepower; SN: 107027, installed
1956
None
Unit 5
Caterpillar 3408 Emergency Generator Engine; Four-
stoke, rich-burn, reciprocating IC engine; natural gas
fired, 3.76 MMBtu/hr natural gas fired, 400 horsepower;
SN: CA 00844, installed 1998
None
Unit 6
Sellers Boiler; Model C80W; natural gas fired, 3.35
MMBtu/hr; Provides glycol heat to keep compressor
engines on warm standby, installed 1989
None
Unit 7
Sivallis Fuel Gas Heater; Model SB16-16; natural gas
fired, 0.5 MMBtu/hr natural gas fired; Pre-heats fuel for
compressor engines and the Sellers boiler, installed 2000
None
Unit 8*
Miscellaneous non-fugitive activities (MNFA) consist of
furnaces and space heaters that generate emissions inside
buildings.
None
Unit 9*
System Blowdown Gas: Once per year where the source
conducts an Emergency Shutdown Test where the source
is isolated from the natural gas line and the system is
purged venting natural gas to the atmosphere.
Approximately 350,000 cubic feet of natural gas is vented
during this MNFA Emergency Shutdown Test.
None
Unit 10*
Miscellaneous fugitive activities (MFA) consist of leaks
from the piping valves, flanges, and open-ended lines, and
compressors associated with the source.
None
Unit 11*
Used Lube Oil Tank, 2,940 gallons (70 BBL); Used Lube
Oil Tank, 2,940 gallons (70 BBL); Scrubber Oil Tank,
1,250 gallons (29.8 BBL) - Scrubber tank stores oil that is
removed (knockout) from the natural gas prior to
compression.
None
* Insignificant Emission Units (IEU).
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2. Standard Terms and Conditions
2.1. Terms not otherwise defined in this permit have the meaning assigned to them in the referenced
regulations. The language of the cited regulation takes precedence over paraphrasing except the
text of terms specified pursuant to any of the following sections is directly enforceable: section
304(f)(4) of the Federal Clean Air Act (CAA), 40 CFR 71.6(a) (3) (i)(B) and (C), 71.6(a) (3) (ii),
71.6(b), and 71.6(c) (1), or any other term specifically identified as directly enforceable.
Compliance with the Permit
2.2. The permittee must comply with all conditions of this Part 71 permit. All terms and conditions of
this permit are enforceable by EPA and citizens under the Clean Air Act. Any permit
noncompliance constitutes a violation of the Clean Air Act and is grounds for enforcement action;
for permit termination, revocation and reissuance, or modification; or for denial of a permit
renewal application. [40 CFR 71.6(a)(6)(i); 71.6(b)]
2.3. It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. [40 CFR 71.6(a) (6) (ii)]
Permit Shield
2.4. Compliance with the terms and conditions of this permit shall be deemed compliance with the
applicable requirements specifically listed in this permit as of the date of permit issuance.
[40 CFR 71.6(f)(1)]
2.5. Nothing in this permit shall alter or affect the following:
2.5.1. The provisions of section 303 of the Clean Air Act (emergency orders), including the
authority of EPA under that section;
2.5.2. The liability of a permittee for any violation of applicable requirements prior to or at
the time of permit issuance;
2.5.3. The applicable requirements of the acid rain program, consistent with section 408(a) of
the Clean Air Act; or
2.5.4. The ability of EPA to obtain information under section 114 of the Clean Air Act.
[40 CFR 71.6(f)(3)]
Other Credible Evidence
2.6. For the purpose of submitting compliance certifications in accordance with Condition 3.49 of this
permit, or establishing whether or not the permittee has violated or is in violation of any
requirement of this permit, nothing shall preclude the use, including the exclusive use, of any
credible evidence or information, relevant to whether the permittee would have been in
compliance with applicable requirements if the appropriate performance or compliance test or
procedure had been performed.
[Section 113(a) and 113(e)(1) of the CAA, 40 CFR 49.123(d), 51.212, 52.12, 52.33, 60.11(g) and
61.12]
Permit Actions
2.7. This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing
of a request by the permittee for a permit modification, revocation and reissuance, or termination,
or of a notification of planned changes or anticipated noncompliance does not stay any permit
condition. [40 CFR 71.6(a) (6) (iii)]
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2.8. The permit may be reopened by EPA and the permit revised prior to expiration under any of the
circumstances described in 40 CFR 71.7(f). [40 CFR 71.7(f) ]
Permit Expiration and Renewal
2.9. This permit shall expire on the expiration date on page one of this permit or on an earlier date if
the source is issued a Part 70 or Part 71 permit by a permitting authority under an EPA approved
or delegated permit program. [40 CFR 71.6(a) (11)]
2.10. Expiration of this permit terminates the permittee's right to operate unless a timely and complete
permit renewal application has been submitted at least six months, but not more than 18 months,
prior to the date of expiration of this permit.
[40 CFR 71.5(a) (1) (iii), 71.7(b) and 71.7(c) (l)(ii)]
2.11. If the permittee submits a timely and complete permit application for renewal, consistent with 40
CFR 71.5(a)(2), but EPA has failed to issue or deny the renewal permit, then all the terms and
conditions of the permit, including any permit shield granted pursuant to 40 CFR 71.6(f) shall
remain in effect until the renewal permit has been issued or denied. This protection shall cease to
apply if, subsequent to the completeness determination, the permittee fails to submit by the
deadline specified in writing by EPA any additional information identified as being needed to
process the application. [40 CFR 71.7(c)(3) and 71.7(b)]
Off-Permit Changes
2.12. The permittee is allowed to make certain changes without a permit revision, provided that the
following requirements are met:
2.12.1. Each change is not addressed or prohibited by this permit;
2.12.2. Each change meets all applicable requirements and does not violate any existing permit
term or condition;
2.12.3. The changes are not changes subject to any requirement of 40 CFR Parts 72 through 78
or modifications under any provision of Title I of the Clean Air Act;
2.12.4. The permittee provides contemporaneous written notice to EPA of each change, except
for changes that qualify as insignificant activities under 40 CFR 71.5(c) (11), that
describes each change, the date of the change, any change in emissions, pollutants
emitted, and any applicable requirements that would apply as a result of the change;
2.12.5. The changes are not covered by a permit shield provided under 40 CFR 71.6(f) and
Conditions 2.4 and 2.5 of this permit; and
2.12.6. The permittee keeps a record describing all changes that result in emissions of any
regulated air pollutant subject to any applicable requirement not otherwise regulated
under this permit, and the emissions resulting from those changes.
[40 CFR 71.6(a) (12)]
Emissions Trading and Operational Flexibility
2.13. The permittee is allowed to make a limited class of changes under section 502(b) (10) of the Clean
Air Act within this permitted facility that contravene the specific terms of this permit without
applying for a permit revision, provided:
2.13.1. The changes do not exceed the emissions allowable under this permit (whether
expressed therein as a rate of emissions or in terms of total emissions);
2.13.2. The changes are not modifications under any provision of Title I of the Clean Air Act;
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2.13.3. The changes do not violate applicable requirements;
2.13.4. The changes do not contravene federally enforceable permit terms and conditions that
are monitoring (including test methods), recordkeeping, reporting, or compliance
certification requirements;
2.13.5. The permittee sends a notice to EPA, at least seven days in advance of any change
made under this provision, that describes the change, when it will occur and any change
in emissions and identifies any permit terms or conditions made inapplicable as a result
of the change and the permittee attaches each notice to its copy of this permit; and
2.13.6. The changes are not covered by a permit shield provided under 40 CFR 71.6(f) and
Conditions 2.4 and 2.5 of this permit.
[40 CFR 71.6(a) (13) (i) and 71.6(c)(1)]
2.14. No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are provided
for in this permit. [40 CFR 71.6(a)(8)]
Severability
2.15. The provisions of this permit are severable, and in the event of any challenge to any portion of
this permit, or if any portion is held invalid, the remaining permit conditions shall remain valid
and in force. [40 CFR 71.6(a)(5)]
Property Rights
2.16. This permit does not convey any property rights of any sort, or any exclusive privilege.
[40 CFR 71.6(a) (6) (iv)]
3. General Requirements
General Compliance Schedule
3.1. For applicable requirements with which the source is in compliance, the permittee will continue
to comply with such requirements. [40 CFR 71.6(c) (3) and 71.5(c) (8) (iii) (A)]
3.2. For applicable requirements that will become effective during the permit term, the permittee shall
meet such requirements on a timely basis. [40 CFR 71.6(c) (3) and 71.5(c) (8) (iii) (B)]
Inspection and Entry
3.3. Upon presentation of credentials and other documents as may be required by law, the permittee
shall allow EPA or an authorized representative to perform the following:
3.3.1. Enter upon the permittee's premises where a Part 71 source is located or emissions-
related activity is conducted, or where records must be kept under the conditions of the
permit;
3.3.2. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of the permit;
3.3.3. Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practices, or operations regulated or required under the
permit; and
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3.3.4. As authorized by the Clean Air Act, sample or monitor at reasonable times substances
or parameters for the purpose of assuring compliance with the permit or applicable
requirements.
[40 CFR 71.6(c)(2)]
Open Burning Restrictions
3.4. Except as exempted in 40 CFR 49.131(c), the permittee shall not openly burn, or allow the open
burning of, the following materials:
3.4.1. Garbage;
3.4.2. Dead animals or parts of dead animals;
3.4.3. Junked motor vehicles or any materials resulting from a salvage operation;
3.4.4. Tires or rubber materials or products;
3.4.5. Plastics, plastic products, or styrofoam;
3.4.6. Asphalt or composition roofing, or any other asphaltic material or product;
3.4.7. Tar, tarpaper, petroleum products, or paints;
3.4.8. Paper, paper products, or cardboard other than what is necessary to start a fire or that is
generated at single-family residences or residential buildings with four or fewer
dwelling units and is burned at the residential site;
3.4.9. Lumber or timbers treated with preservatives;
3.4.10. Construction debris or demolition waste;
3.4.11. Pesticides, herbicides, fertilizers, or other chemicals;
3.4.12. Insulated wire;
3.4.13. Batteries;
3.4.14. Light bulbs;
3.4.15. Materials containing mercury (e.g., thermometers);
3.4.16. Asbestos or asbestos-containing materials;
3.4.17. Pathogenic wastes;
3.4.18. Hazardous wastes; or
3.4.19. Any material other than natural vegetation that normally emits dense smoke or noxious
fumes when burned.
[40 CFR 49.131(c) and (d)(1)]
3.5. Open burning shall be conducted as follows:
3.5.1. All materials to be openly burned shall be kept as dry as possible through the use of a
cover or dry storage;
3.5.2. Before igniting a burn, noncombustibles shall be separated from the materials to be
openly burned to the greatest extent practicable;
3.5.3. Natural or artificially induced draft shall be present, including the use of blowers or air
curtain incinerators where practicable;
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3.5.4. To the greatest extent practicable, materials to be openly burned shall be separated
from the grass or peat layer; and
3.5.5. A fire shall not be allowed to smolder.
[40 CFR 49.131(e)(1)]
3.6. Except for exempted fires set for cultural or traditional purposes, a person shall not initiate any
open burning when:
3.6.1. The Regional Administrator has declared a burn ban; or
3.6.2. An air stagnation advisory has been issued or an air pollution alert, warning or
emergency has been declared by the Regional Administrator.
[40 CFR 49.131(d)(2), (d)(3) and (e)(2), and 49.137(c) (4) (i)]
3.7. Except for exempted fires set for cultural or traditional purposes, any person conducting open
burning when such an advisory is issued or declaration is made shall either immediately
extinguish the fire, or immediately withhold additional material such that the fire burns down.
[40 CFR 49.131 (e) (3) and 49.137(c) (4) (ii)]
3.8. Nothing in this section exempts or excuses any person from complying with applicable laws and
ordinances of local fire departments and other governmental jurisdictions.
[40 CFR 49.131(d)(4)]
Visible Emissions Limits
3.9. Except as provided for in Conditions 3.10 and 3.11, the visible emissions from any air pollution
source that emits, or could emit, particulate matter or other visible air pollutants shall not exceed
20% opacity, averaged over any consecutive six-minute period. Compliance with this emission
limit is determined as follows:
3.9.1. Using EPA Reference Method 9 found in Appendix A of 40 CFR part 60; or
3.9.2. Alternatively, using a continuous opacity monitoring system that complies with
Performance Specification 1 found in Appendix B of 40 CFR part 60.
[40 CFR 49.124(d)(1) and (e)]
3.10. The requirements of Condition 3.9 do not apply to open burning, agricultural activities, forestry
and silvicultural activities, non-commercial smoke houses, sweat houses or lodges, smudge pots,
furnaces and boilers used exclusively to heat residential buildings with four or fewer dwelling
units, or emissions from fuel combustion in mobile sources. [40 CFR 49.124(c)]
3.11. Exceptions to the visible emission limit in Condition 3.9 include:
3.11.1. The visible emissions from an air pollution source may exceed the 20% opacity limit if
the owner or operator of the air pollution source demonstrates to the Regional
Administrator's satisfaction that the presence of uncombined water, such as steam, is
the only reason for the failure of an air pollution source to meet the 20% opacity limit.
[40 CFR 49.124(d)(2)]
Fugitive Particulate Matter Requirements and Recordkeeping
3.12. Except as provided for in Condition 3.17, the permittee shall take all reasonable precautions to
prevent fugitive particulate matter emissions and shall maintain and operate all pollutant-emitting
activities to minimize fugitive particulate matter emissions. Reasonable precautions include, but
are not limited to the following:
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3.12.1. Use, where possible, of water or chemicals for control of dust in the demolition of
buildings or structures, construction operations, grading of roads, or clearing of land;
3.12.2. Application of asphalt, oil (but not used oil), water, or other suitable chemicals on
unpaved roads, materials stockpiles, and other surfaces that can create airborne dust;
3.12.3. Full or partial enclosure of materials stockpiles in cases where application of oil, water,
or chemicals is not sufficient or appropriate to prevent particulate matter from
becoming airborne;
3.12.4. Implementation of good housekeeping practices to avoid or minimize the accumulation
of dusty materials that have the potential to become airborne, and the prompt cleanup
of spilled or accumulated materials;
3.12.5. Installation and use of hoods, fans, and fabric filters to enclose and vent the handling of
dusty materials;
3.12.6. Adequate containment during sandblasting or other similar operations;
3.12.7. Covering, at all times when in motion, open bodied trucks transporting materials likely
to become airborne; and
3.12.8. The prompt removal from paved streets of earth or other material that does or may
become airborne.
[40 CFR 49.126(d)(1) and (2)]
3.13. Once each calendar year, during typical operating conditions and meteorological conditions
conducive to producing fugitive dust, the permittee shall survey the facility to determine the
sources of fugitive particulate matter emissions. For new sources or new operations, a survey
shall be conducted within 30 days after commencing operation.
3.13.1. The permittee shall record the results of the survey, including the date and time of the
survey and identification of any sources of fugitive particulate matter emissions found;
and
3.13.2. If sources of fugitive particulate matter emissions are present, the permittee shall
determine the reasonable precautions that will be taken to prevent fugitive particulate
matter emissions.
[40 CFR 49.126(e) (1)(i) and (ii)]
3.14. The permittee shall prepare, and update as necessary following each survey, a written plan that
specifies the reasonable precautions that will be taken and the procedures to be followed to
prevent fugitive particulate matter emissions, including appropriate monitoring and
recordkeeping.
3.14.1. For construction or demolition activities, a written plan shall be prepared prior to
commencing construction or demolition.
[40 CFR 49.126(e) (1) (iii) and (iv)]
3.15. The permittee shall implement the written plan, and maintain and operate all sources to minimize
fugitive particulate matter emissions. [40 CFR 49.126(e) (1) (iii) and (iv)]
3.16. Efforts to comply with this section cannot be used as a reason for not complying with other
applicable laws and ordinances. [40 CFR 49.126(e)(3)]
3.17. The requirements of Conditions 3.12 through 3.16 do not apply to open burning, agricultural
activities, forestry and silvicultural activities, sweat houses or lodges, non-commercial smoke
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houses, or activities associated with single-family residences or residential buildings with four or
fewer dwelling units. [40 CFR 49.126(c)]
Other Work Practice Requirements and Recordkeeping
3.18. The permittee shall comply with the requirements of the Chemical Accident Prevention
Provisions at 40 CFR Part 68 no later than the latest of the following dates:
3.18.1. Three years after the date on which a regulated substance, present above the threshold
quantity in a process, is first listed under 40 CFR 68.130; or
3.18.2. The date on which a regulated substance is first present above a threshold quantity in a
process.
[40 CFR 68.10 and 68.215(a)(1)]
3.19. Except as provided for motor vehicle air conditioners (MVACs) in 40 CFR Part 82, Subpart B,
the permittee shall comply with the stratospheric ozone and climate protection standards for
recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart F.
3.19.1. Persons opening appliances for maintenance, service, repair, or disposal must comply
with the required practices pursuant to 40 CFR 82.156.
3.19.2. Equipment used during the maintenance, service, repair, or disposal of appliances must
comply with the standards for recycling and recovery equipment pursuant to 40 CFR
82.158.
3.19.3. Persons performing maintenance, service, repair, or disposal of appliances must be
certified by an approved technician certification program pursuant to 40 CFR 82.161.
3.19.4. Persons disposing of small appliances, MVACs, and MVAC-like appliances must
comply with recordkeeping requirements pursuant to 40 CFR 82.166. ("MVAC-like
appliance" is defined at 40 CFR 82.152.)
3.19.5. Persons owning commercial or industrial process refrigeration equipment must comply
with the leak repair requirements pursuant to 40 CFR 82.156.
3.19.6. Owners/operators of appliances normally containing 50 or more pounds of refrigerant
must keep records of refrigerant purchased and added to such appliances pursuant to 40
CFR 82.166.
[40 CFR Part 82, Subpart F]
3.20. If the permittee performs a service on motor (fleet) vehicles when this service involves ozone-
depleting substance refrigerant (or regulated substitute substance) in the MVAC, the permittee
must comply with all the applicable requirements for stratospheric ozone and climate protection
as specified in 40 CFR Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners.
[40 CFR Part 82, Subpart B]
3.21. The permittee shall comply with 40 CFR Part 61, Subpart M for asbestos removal and disposal
when conducting any renovation or demolition at the facility. [40 CFR Part 61, Subpart M]
General Testing and Associated Recordkeeping and Reporting
3.22. In addition to the specific testing requirements contained in the facility and emission unit-specific
sections of this permit, the permittee shall comply with the generally applicable testing
requirements in Conditions 3.23 through 3.30 whenever conducting a performance test required
by this permit unless specifically stated otherwise in this permit.
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
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3.23. Test Notification. The permittee shall provide EPA at least 30 days prior notice of any
performance test, except as otherwise specified in this permit, to afford EPA the opportunity to
have an observer present. If after 30 days notice for an initially scheduled performance test, there
is a delay in conducting the scheduled performance test, the permittee shall notify EPA as soon as
possible of any delay in the original test date, either by providing at least seven days prior notice
of the rescheduled date of the performance test, or by arranging a rescheduled date with EPA by
mutual agreement. [40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.24. Test Plan. The permittee shall submit to EPA a source test plan 30 days prior to any required
testing. The source test plan shall include and address the following elements:
3.24.1. Purpose and scope of testing;
3.24.2. Source description, including a description of the operating scenarios and mode of
operation during testing and including fuel sampling and analysis procedures;
3.24.3. Schedule/dates of testing;
3.24.4. Process data to be collected during the test and reported with the results, including
source-specific data identified in the facility or emission unit-specific sections of this
permit;
3.24.5. Sampling and analysis procedures, specifically requesting approval for any proposed
alternatives to the reference test methods, and addressing minimum test length (e.g.,
one hour, eight hours, 24 hours, etc.) and minimum sample volume;
3.24.6. Sampling location description and compliance with the reference test methods;
3.24.7. Analysis procedures and laboratory identification;
3.24.8. Quality assurance plan;
3.24.9. Calibration procedures and frequency;
3.24.10. Sample recovery and field documentation;
3.24.11. Chain of custody procedures;
3.24.12. Quality assurance/quality control project flow chart;
3.24.13. Data processing and reporting;
3.24.14. Description of data handling and quality control procedures; and
3.24.15. Report content and timing.
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.25. Facilities for performing and observing the emission testing shall be provided that meet the
requirements of 40 CFR 60.8(e) and Reference Method 1 (40 CFR Part 60, Appendix A).
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.26. Unless EPA determines in writing that other operating conditions are representative of normal
operations or unless specified in the facility or emission unit-specific sections of this permit, the
source shall be operated at a capacity of at least 90% but no more than 100% of maximum during
all tests. [40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.27. Only regular operating staff may adjust the processes or emission control devices during or within
two hours prior to the start of a source test. Any operating adjustments made during a source test,
that are a result of consultation during the tests with source testing personnel, equipment vendors,
or consultants, may render the source test invalid. [40 CFR 71.6(a)(3) and 71.6(c)(1)]
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3.28. Each source test shall follow the reference test methods specified by this permit and consist of at
least three valid test runs.
3.28.1. If the reference test method yields measured pollutant concentration values at an
oxygen concentration other than specified in the emission standard, the permittee shall
correct the measured pollutant concentration to the oxygen concentration specified in
the emission standard by using the following equation:
pp - pr Y (20.9-X)
x X (20.9 - Y)
Where: PCx = Pollutant concentration at X percent;
PCm = Pollutant concentration as measured;
X = The oxygen concentration specified in the standard; and
Y = The measured average volumetric oxygen concentration.
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.28.2. Source test emission data shall be reported as the arithmetic average of all valid test
runs and in the terms of any applicable emission limit, unless otherwise specified in the
facility or emission unit-specific sections of this permit.
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.29. Test Records. For the duration of each test run (unless otherwise specified), the permittee shall
record the following information:
3.29.1. All data which is required to be monitored during the test in the facility or emission
unit-specific sections of this permit; and
3.29.2. All continuous monitoring system (CMS) data which is required to be routinely
monitored in the facility or emission unit-specific sections of this permit for the
emission unit being tested.
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
3.30. Test Reports. Unless the EPA approves in writing a different due date, emission test reports shall
be submitted to the EPA within 60 days of completing any emission test required by this permit
along with data required to be recorded in Condition 3.29 above.
[40 CFR 71.6(a)(3) and 71.6(c)(1)]
General Recordkeeping
3.31. Monitoring Records. In addition to specific recordkeeping requirements contained in the source-
wide and emission unit-specific conditions of the permit, the permittee shall, where applicable,
keep records of required monitoring information that include the following:
3.31.1.
The
3.31.2.
The
3.31.3.
The
3.31.4.
The
3.31.5.
The
3.31.6.
The
[40 CFR 71.6(a)(3)(ii)(A)]
3.32. Off-Permit Change Records. The permittee shall keep a record describing all off-permit changes
allowed to be made under Condition 2.12 that result in emissions of any regulated air pollutant
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subject to any applicable requirement not otherwise regulated under this permit, and the
emissions resulting from those changes. [40 CFR 71.6(a) (12) (iv)]
3.33. Open Burning Records. For any open burning allowed under Conditions 3.4 through 3.8, the
permittee shall document the following:
3.33.1. The date that burning was initiated;
3.33.2. The duration of the burn;
3.33.3. The measures taken to comply with each provision of Condition 3.5; and
3.33.4. The measures taken to ensure that materials prohibited in Condition 3.4 were not
burned.
[40 CFR 71.6(a) (3) (i)(B) and 71.6(c)(1)]
3.34. Fee Records. The permittee shall retain in accordance with the provisions of Condition 3.35 of
this permit, all work sheets and other materials used to determine fee payments. Records shall be
retained for five years following the year in which the emissions data is submitted.
[40 CFR 71.9(i)]
3.35. Records Retention. The permittee shall retain records of all required monitoring data and support
information for a period of at least five years from the date of the monitoring sample,
measurement, report, or application. Support information includes all calibration and maintenance
records, all original strip-chart recordings for continuous monitoring instrumentation, and copies
of all reports required by this permit.
[40 CFR 71.6(a)(3)(ii)(B), 49.126(e)(l)(v) and 49.130(f)(2)]
General Reporting
3.36. Additional Information. The permittee shall furnish to EPA, within a reasonable time, any
information that EPA may request in writing to determine whether cause exists for modifying,
revoking, and reissuing, or terminating the permit, or to determine compliance with the permit.
Upon request, the permittee shall also furnish to EPA copies of records that are required to be
kept pursuant to the terms of the permit, including information claimed to be confidential.
Information claimed to be confidential must be accompanied by a claim of confidentiality
according to the provisions of 40 CFR Part 2, Subpart B.
[40 CFR 71.6(a) (6) (v) and 71.5(a) (3)]
3.37. Corrections. The permittee, upon becoming aware that any relevant facts were omitted or
incorrect information was submitted in the permit application, shall promptly submit such
supplementary facts or corrected information. Supplementary facts and corrected information
submitted pursuant to this permit condition shall be sent to the EPA at the following address. A
copy of each document submitted to the EPA that does not contain CBI shall be sent to the Tribal
address below:
Original documents go to the EPA at: Copies go to the Tribe at:
Part 71 Air Quality Permits Air Quality Manager
U.S. EPA - Region 10, 15-H13 Shoshone-Bannock Tribes
1200 Sixth Avenue, Suite 155 P.O. Box 306
Seattle, WA 98101-3188 Fort Hall, ID 83203
[40 CFR 71.5(b)]
3.38. Off-Permit Change Report. The permittee shall provide contemporaneous written notice to EPA
of each off-permit change allowed to be made under Condition 2.12, except for changes that
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qualify as insignificant activities under 40 CFR 71.5(c) (11). The written notice shall describe
each change, the date of the change, any change in emissions, pollutants emitted, and any
applicable requirements that would apply as a result of the change; [40 CFR 71.6(a) (12) (ii)]
3.39. Section 502(b)(10) Change Report. The permittee is required to send a notice to EPA at least 7
days in advance of any section 502(b) (10) change allowed to be made under Condition 2.13. The
notice must describe the change, when it will occur and any change in emissions, and identify any
permit terms or conditions made inapplicable as a result of the change. The permittee shall attach
each notice to its copy of this permit. [40 CFR 71.6(a) (13) (i) (A) and 71.6(c)(1)]
3.40. Address. Unless otherwise specified in this permit, any documents required to be submitted under
this permit, including reports, test data, monitoring data, notifications, compliance certifications
and fee calculation worksheets shall be submitted to the EPA address below. A copy of each
document submitted to EPA that does not contain CBI shall be sent to the Tribal address below:
Original documents go to the EPA at: Copies go to the Tribe at:
Clean Air Act Compliance Manager Air Quality Manager
U.S. EPA - Region 10, 20-C04 Shoshone-Bannock Tribes
1200 Sixth Avenue, Suite 155 P.O. Box 306
Seattle, WA 98101-3188 Fort Hall, ID 83203
[40 CFR 71.5(d), 71.6(c)(1) and 71.9(h)(2)]
Part 71 Emission and Fee Reporting
3.41. Part 71 Annual Emission Report. No later than the date specified in Condition 4.1 of each year,
the permittee shall submit to EPA an annual report of actual emissions for the preceding calendar
year. [40 CFR 71.9(h)(1)]
3.41.1. "Actual emissions" means the actual rate of emissions in tons per year of any
"regulated pollutant (for fee calculation)," as defined in 40 CFR 71.2, emitted from a
Part 71 source over the preceding calendar year. Actual emissions shall be calculated
using each emissions unit's actual operating hours, production rates, in-place control
equipment, and types of materials processed, stored, or combusted during the preceding
calendar year. [40 CFR 71.9(c)(6)]
3.41.2. Actual emissions shall be computed using methods required by the permit for
determining compliance. [40 CFR 71.9(h)(3)]
3.41.3. Actual emissions shall include fugitive emissions. [40 CFR 71.9(c)(1)]
3.42. Part 71 Fee Calculation Worksheet. Based on the annual emission report required in Condition
3.41 and no later than the date specified in Condition 4.1 of each year, the permittee shall submit
to EPA a fee calculation worksheet (blank forms provided by EPA) and a photocopy of each fee
payment check (or other confirmation of actual fee paid).
[40 CFR 71.9(c)(1), 71.9(e)(1) and 71.9(h)(1)]
3.42.1. The annual emissions fee shall be calculated by multiplying the total tons of actual
emissions of each "regulated pollutant (for fee calculation)," emitted from the source
by the presumptive emission fee (in dollars/ton) in effect at the time of calculation. The
presumptive emission fee is revised each calendar year and is available from EPA prior
to the start of each calendar year. [40 CFR 71.9(c) (1)]
3.42.2. The permittee shall exclude the following emissions from the calculation of fees:
3.42.2.1 The amount of actual emissions of each regulated pollutant (for fee
calculation) that the source emits in excess of 4,000 tons per year;
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3.42.2.2 Actual emissions of any regulated pollutant (for fee calculation) already
included in the fee calculation; and
3.42.2.3 The insignificant quantities of actual emissions not required to be listed or
calculated in a permit application pursuant to 40 CFR 71.5(c) (11).
[40 CFR 71.9(c)(5)]
3.43. Part 71 Annual Fee Payment. No later than the date specified in Condition 4.1 of each year, the
permittee shall submit to EPA full payment of the annual permit fee based on the fee calculation
worksheet required in Condition 3.42. [40 CFR 71.9(a), 71.9(c)(1) and 71.9(h)(1)]
3.43.1. The fee payment and a completed fee filing form shall be sent to:
U.S.EPA
OCFO/OC/ACAD/FCB
Attn: Collections Team
1300 Pennsylvania Ave NW
Mail Code 2733R
Washington, DC 20004
[40 CFR 71.9(k) (2)]
3.43.2. The fee payment shall be in United States currency and shall be paid by money order,
bank draft, certified check, corporate check, or electronic funds transfer payable to the
order of the U.S. Environmental Protection Agency. [40 CFR 71.9(k)(l)]
3.43.3. The permittee, when notified by EPA of additional amounts due, shall remit full
payment within 30 days of receipt of an invoice from EPA. [40 CFR 71.9 (j) (2)]
3.43.4. If the permittee thinks an EPA assessed fee is in error and wishes to challenge such fee,
the permittee shall provide a written explanation of the alleged error to EPA along with
full payment of the EPA assessed fee. [40 CFR 71.9(j) (3)]
3.43.5. Failure of the permittee to pay fees in a timely manner shall subject the permittee to
assessment of penalties and interest in accordance with 40 CFR 71.9(1).
[40 CFR 71.9(1)]
3.44. The annual emission report and fee calculation worksheet (and photocopy of each fee payment
check), required in Conditions 3.41 and 3.42, shall be submitted to EPA at the address listed in
Condition 3.40 of this permit.1 [40 CFR 71.9(k) (1) ]
3.45. The annual emission report and fee calculation worksheet (and photocopy of each fee payment
check), required in Conditions 3.41 and 3.42, shall be certified by a responsible official in
accordance with Condition 3.50 of this permit. [40 CFR 71.9(h)(2)]
Annual Registration
3.46. The permittee shall submit an annual registration report that consists of estimates of the total
actual emissions from the air pollution source for the following air pollutants: PM, PMio, PM2.5,
SOx, NOx, CO, VOC, lead and lead compounds, ammonia, fluorides (gaseous and particulate),
sulfuric acid mist, hydrogen sulfide, total reduced sulfur (TRS), and reduced sulfur compounds,
including all calculations for the estimates. Emissions shall be calculated using the actual
operating hours, production rates, in-place control equipment, and types of materials processed,
stored, or combusted during the preceding calendar year.
1 The permittee should note that an annual emissions report, required at the same time as the fee calculation
worksheet by 40 CFR 71.9(h), has been incorporated into the fee calculation worksheet.
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[40 CFR 49.138(e)(3), (e)(4) and (f)]
3.46.1. The emission estimates required by Condition 3.46 shall be based upon actual test data
or, in the absence of such data, upon procedures acceptable to the Regional
Administrator. Any emission estimates submitted to the Regional Administrator shall
be verifiable using currently accepted engineering criteria. The following procedures
are generally acceptable for estimating emissions from air pollution sources:
3.46.1
.1
Source-specific emission tests;
3.46.1
.2
Mass balance calculations;
3.46.1
.3
Published, verifiable emission factors that are applicable to the source;
3.46.1
.4
Other engineering calculations; or
3.46.1
.5
Other procedures to estimate emissions specifically approved by the
Regional Administrator.
[40 CFR 49.138(e) (4) and (f)]
3.46.2. The annual registration report shall be submitted with the annual emission report and
fee calculation worksheet required by Conditions 3.41 and 3.42 of this permit. The
permittee may submit a single combined report provided that the combined report
clearly identifies which emissions are the basis for the annual registration report, the
part 71 annual emission report, and the part 71 fee calculation worksheet. All
registration information and reports shall be submitted on forms provided by the
Regional Administrator. [40 CFR 49.138(d) and (f)]
Periodic and Deviation Reporting
3.47. Semi-Annual Monitoring Report. The permittee shall submit to EPA reports of any required
monitoring for each six month reporting period from July 1 to December 31 and from January 1
to June 30. All reports shall be submitted to EPA and shall be postmarked by the 60th day
following the end of the reporting period. All instances of deviations from permit requirements
must be clearly identified in such reports. All required reports must be certified by a responsible
official consistent with Condition 3.50. [40 CFR 71.6(a)(3)(iii)(A)]
3.48. Deviation Report. The permittee shall promptly report to EPA, by telephone, deviations from
permit conditions, including those attributable to upset conditions as defined in this permit, the
probable cause of such deviations, and any corrective actions or preventive measures taken. The
report shall be made to telephone number (206) 553-1331. [40 CFR 71.6(a)(3) (iii) (B)]
3.48.1. For the purposes of Conditions 3.47 and 3.48, deviation means any situation in which
an emissions unit fails to meet a permit term or condition. A deviation is not always a
violation. A deviation can be determined by observation or through review of data
obtained from any testing, monitoring, or record keeping required by this permit. For a
situation lasting more than 24 hours, each 24-hour period is considered a separate
deviation. Included in the meaning of deviation are any of the following:
3.48.1.1 A situation where emissions exceed an emission limitation or standard;
3.48.1.2 A situation where process or emissions control device parameter values
indicate that an emission limitation or standard has not been met;
3.48.1.3 A situation in which observations or data collected demonstrate
noncompliance with an emission limitation or standard or any work
practice or operating condition required by the permit (including indicators
of compliance revealed through parameter monitoring);
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3.48.1.4 A situation in which any testing, monitoring, recordkeeping or reporting
required by this permit is not performed or not performed as required;
3.48.1.5 A situation in which an exceedance or an excursion, as defined in 40 CFR
Part 64, occurs; and
3.48.1.6 Failure to comply with a permit term that requires submittal of a report.
[40 CFR 71.6(a) (3) (iii)(C) and 71.6(c)(1)]
3.48.2. For the purpose of Condition 3.48 of the permit, prompt is defined as any definition of
prompt or a specific time frame for reporting deviations provided in an underlying
applicable requirement as identified in this permit. Where the underlying applicable
requirement fails to address the time frame for reporting deviations, reports of
deviations will be submitted based on the following schedule:
3.48.2.1 For emissions of a hazardous air pollutant or a toxic air pollutant (as
identified in the applicable regulation) that continue for more than an hour
in excess of permit requirements, the report must be made within 24 hours
of the occurrence;
3.48.2.2 For emissions of any regulated pollutant excluding those listed in
Condition 3.48.2.1 above, that continue for more than two hours in excess
of permit requirements, the report must be made within 48 hours of the
occurrence; or
3.48.2.3 For all other deviations from permit requirements, the report shall be
submitted with the semi-annual monitoring report required in Condition
3.47.
[40 CFR 71.6(a) (3) (iii) (B)]
3.48.3. Within ten working days of the occurrence of a deviation as provided in Condition
3.48.2.1 or 3.48.2.2 above, the permittee shall also submit a written notice, which shall
include a narrative description of the deviation and updated information as listed in
Condition 3.48, to EPA, certified consistent with Condition 3.50 of this permit.
[40 CFR 71.6(a)(3)(i)(B) and (iii)(B), 71.6(c)(1)]
Annual Compliance Certification
3.49. The permittee shall submit to EPA a certification of compliance with permit terms and
conditions, including emission limitations, standards, or work practices, postmarked by the 60th
day of each year and covering the permit or permits in effect during the previous calendar year.
The compliance certification shall be certified as to truth, accuracy, and completeness by a
responsible official consistent with Condition 3.50 of this permit. [40 CFR 71.6(c) (5)]
3.49.1. The annual compliance certification shall include the following:
3.49.1.1 The identification of each permit term or condition that is the basis of the
certification;
3.49.1.2 The identification of the method(s) or other means used by the permittee
for determining the compliance status with each term and condition during
the certification period. Such methods and other means shall include, at a
minimum, the methods and means required in this permit. If necessary, the
permittee also shall identify any other material information that must be
included in the certification to comply with section 113(c) (2) of the Clean
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Air Act, which prohibits knowingly making a false certification or omitting
material information; and
3.49.1.3 The status of compliance with each term and condition of the permit for the
period covered by the certification, including whether compliance during
the period was continuous or intermittent. The certification shall be based
on the method or means designated above. The certification shall identify
each deviation and take it into account in the compliance certification. The
certification shall also identify as possible exceptions to compliance any
periods during which compliance is required and in which an excursion or
exceedance as defined under 40 CFR Part 64 occurred.
[40 CFR 71.6(c) (5) (iii) and 71.6(c)(1)]
Document Certification
3.50. Any document required to be submitted under this permit shall be certified by a responsible
official, as defined in 40 CFR 71.2, as to truth, accuracy, and completeness. Such certifications
shall state that based on information and belief formed after reasonable inquiry, the statements
and information in the document are true, accurate, and complete.
[40 CFR 71.5(d), 71.6(c)(1) and 71.9(h)(2)]
Permit Renewal
3.51. The permittee shall submit a timely and complete application for permit renewal at least six
months, but not more than 18 months, prior to the date of expiration of this permit. Applications
for permit renewal shall be sent to the EPA at the following address. A copy of each document
submitted to the EPA that does not contain CBI shall be sent to the Tribal address below:
Original documents go to the EPA at: Copies go to the Tribe at:
Part 71 Air Quality Permits Air Quality Manager
U.S. EPA - Region 10, 15-H13 Shoshone-Bannock Tribes
1200 Sixth Avenue, Suite 155 P.O. Box 306
Seattle, WA 98101-3188 Fort Hall, ID 83203
[40 CFR 71.5(a)(1) (iii), 71.7(b) and 71.7(c)(l)(ii)]
3.52. The application for renewal shall include the current permit number, a description of permit
revisions and off-permit changes that occurred during the permit term and were not incorporated
into the permit during the permit term, any applicable requirements that were promulgated and
not incorporated into the permit during the permit term, and other information required by the
application form. [40 CFR 71.5(a)(2) and 71.5(c)(5)]
4. Facility-Specific Requirements
Fees and Emission Reports Due Date
4.1. Unless otherwise specified, fees and emission reports required by this permit are due annually on
April 1. [40 CFR 71.9(a) and 71.9(h)]
Fuel Restriction
4.2. The permittee is prohibited from combusting any fuel other than natural gas in any emission unit.
[Section 304(f) (4) of the Federal Clean Air Act and 40 CFR 71.6(b)]
Fuel Sulfur Limits
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4.3. The permittee shall not sell, distribute, use, or make available for use any gaseous fuel that contains
more than 1.1 grams of sulfur per dry standard cubic meter. [40 CFR 49.130(d) (8)]
4.3.1. Compliance with the sulfur limit is determined using ASTM methods D1072-90
(Reapproved 1999), D3246-96, D4084-94 (Reapproved 1999), D5504-01, D4468-85
(Reapproved 2000), D2622-03, and D6228-98 (Reapproved 2003) (incorporated by
reference, see 40 CFR 49.123(e)). [40 CFR 49.130(e)(4)]
Fuel Sulfur Monitoring and Recordkeeping
4.4. The permittee shall keep records consisting of a current, valid purchase contract, tariff sheet or
transportation contract for the fuel showing that the gaseous fuel meets the definition of natural gas
in 40 CFR 72.2. [40 CFR 49.130(f)(1) (ii), 71.6(a) (3) (i)(B) and 71.6(c)]
Combustion Source Stack Emission Limits
4.5. Sulfur dioxide emissions from each combustion source stack shall not exceed an average of 500
parts per million by volume, on a dry basis and corrected to seven percent oxygen, during any
three-hour period.
4.5.1. Compliance with the SO2 limit is determined using EPA Reference Methods 6, 6A, 6B,
and 6C as specified in the applicability section of each method (see 40 CFR Part 60,
appendix A) or, alternatively, a continuous emission monitoring system (CEMS) that
complies with Performance Specification 2 found in Appendix B of 40 CFR Part 60.
[40 CFR 49.129(d)(1) and (e)]
4.6. Particulate matter emissions from each combustion source stack shall not exceed an average of
0.23 grams per dry standard cubic meter (0.1 grains per dry standard cubic foot), corrected to seven
percent oxygen, during any three-hour period.
4.6.1. Compliance with the PM limit is determined using EPA Reference Method 5 (see 40
CFR Part 60, Appendix A).
[40 CFR 49.125(d)(1) and (e)]
Visible and Fugitive Emission Monitoring and Recordkeeping
4.7. Once each calendar quarter, the permittee shall visually survey each potential source of fugitive
dust or visible particulate emissions for the presence of visible emissions or fugitive emissions of
particulate matter.
4.7.1. The observer conducting the visual survey must be trained and knowledgeable regarding
the effects of background contrast, ambient lighting, observer position relative to lighting
and wind, and the presence of uncombined water on the visibility of emissions (see 40
CFR Part 60, Appendix A, Method 22).
4.7.2. For the surveys, the observer shall select a position that enables a clear view of the
emission point to be surveyed, that is at least 15 feet, but not more than 0.25 miles, from
the emission point, and where the sunlight is not shining directly in the observer's eyes.
4.7.3. The observer shall continuously watch for visible emissions from each potential emission
point for at least 15 seconds.
4.7.4. Any observed visible emissions or fugitive emissions of particulate matter (other than
uncombined water) shall be recorded as a positive reading associated with the emission
unit or pollutant emitting activity.
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4.7.5. Surveys shall be conducted while the emission unit or pollutant emitting activity is
operating, and during daylight hours.
[40 CFR 71.6(a) (3) (i) (B) ]
4.8. If the survey conducted pursuant to Condition 4.7 identifies any visible emissions or fugitive
emissions of particulate matter, the permittee shall:
4.8.1. Immediately upon conclusion of the visual survey in Condition 4.7, investigate the source
and reason for the presence of visible emissions or fugitive emissions; and
4.8.2. As soon as practicable, take appropriate corrective action.
[40 CFR 71.6(a) (3) (i) (B) ]
4.9. If the corrective actions undertaken pursuant to Condition 4.8.2 do not eliminate the visible or
fugitive emissions, the permittee shall within 24 hours of the visual survey in Condition 4.7
determine the opacity of the emissions in question, for a 30-minute duration, using the procedures
specified in Condition 3.9.1. [40 CFR 71.6(a) (3) (i)(B)]
4.10. If any 6-minute average opacity determined pursuant to Condition 4.9 or 4.11 is greater than 20%,
the permittee shall determine the opacity of the emissions in question daily, for a 30-minute
duration each day, using the procedures specified in Condition 3.9.1 until no 6-minute average
opacity is greater than 20% for two consecutive days. [40 CFR 71.6(a) (3) (i) (B)]
4.11. If the opacity determination required in Condition 4.9, or if two consecutive daily opacity
determinations required by Condition 4.10, indicate no 6-minute average opacity greater than 20%,
the permittee shall determine opacity of the emissions in question weekly, for a 30-minute duration
each week, for three additional weeks using the procedures specified in Condition 3.9.1.
[40 CFR 71.6(a) (3) (i)(B)]
4.12. The permittee shall maintain records of the following:
4.12.1. Details of each visual survey, including date, time, observer and results for each emission
unit and any other pollutant emitting activity;
4.12.2. Date, time and type of any investigation conducted pursuant to Condition 4.8.1;
4.12.3. Findings of the investigation, including the reasons for the presence of visible emissions
or fugitive emissions of particulate matter;
4.12.4. Date, time and type of corrective actions taken pursuant to Condition 4.8.2;
4.12.5. Field, observation and data reduction records for any EPA Reference Method 9
determination conducted on the source of visible or fugitive emissions pursuant to
Conditions 4.9 through 4.11
[40 CFR 71.6(a) (3) (i) (B)]
4.13. Any 6-minute average opacity determined to be in excess of 20% is a deviation and subject to the
provisions of Conditions 3.47 and 3.48. [40 CFR 71.6(a) (3) (i)(B)]
Monitoring for Modifications to the Facility not Undergoing PSD Review
4.14. Where there is a reasonable possibility (as defined in 40 CFR 52.21 (r) (6) (vi)) that a project (other
than projects at a source with a plantwide applicability limitation) that is not a part of a major
modification may result in a significant emissions increase of any regulated NSR pollutant and the
permittee elects to use the method specified in 40 CFR 52.21 (b) (41) (ii) (a) through (c) for
calculating projected actual emissions, the permittee shall perform the following:
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4.14.1. Before beginning actual construction of the project, document and maintain a record of
the following information.
4.14.1.1 A description of the project.
4.14.1.2 Identification of the emissions unit(s) whose emissions of a regulated NSR
pollutant could be affected by the project.
4.14.1.3 A description of the applicability test used to determine that the project is not a
major modification for any regulated NSR pollutant, including the baseline
actual emissions, the projected actual emissions, the amount of emissions
excluded under 40 CFR 52.21 (b) (41) (ii) (c) and an explanation for why such
amount was excluded, and any netting calculations, if applicable.
4.14.2. Monitor the emission of any regulated NSR pollutant that could increase as a result of the
project and that is emitted by any emissions unit identified in Condition 4.14.1.2; and
calculate and maintain a record of the annual emissions, in tons per year on a calendar
year basis, for a period of five years following resumption of regular operations after the
change, or for a period of ten years following resumption of regular operations after the
change if the project increases the design capacity or potential to emit of that regulated
NSR pollutant at such emissions unit.
[40 CFR 52.2 l(r) (6)]
Reporting for Modifications to the Facility not Undergoing PSD Review
4.15. If monitoring and recordkeeping is required in Condition 4.14.2, the permittee shall report to the
EPA when the annual emissions, in tons per year, from the project identified in Condition 4.14.1.1
exceed the baseline actual emissions as documented and maintained pursuant to Condition 4.14.1.3
by a significant amount (as defined in 40 CFR 52.21(b) (23)) for that regulated NSR pollutant, and
when such emissions differ from the preconstruction projection as documented and maintained
pursuant to Condition 4.14.1.3. Such report shall be submitted to the EPA within 60 days after the
end of such year. The report shall contain the following.
4.15.1. The name, address and telephone number of the major stationary source.
4.15.2. The annual emissions as calculated pursuant to Condition 4.14.2.
4.15.3. Any other information that the owner or operator wishes to include in the report (e.g., an
explanation as to why the emissions differ from the preconstruction projection).
[40 CFR 52.21 (r) (6)]
NESHAP Work Practice Requirements
4.16. NESHAP Circumvention. The permittee shall not build, erect, install, or use any article, machine,
equipment, or process to conceal an emission that would otherwise constitute noncompliance with
a relevant NESHAP standard. Such concealment includes, but is not limited to, the use of diluents
to achieve compliance with a relevant standard based on the concentration of a pollutant in the
effluent discharged to the atmosphere and the use of gaseous diluents to achieve compliance with a
relevant standard for visible emissions. [40 CFR 63.4(b)]
NESHAP Recordkeeping Requirements
4.17. NESHAP Records. The permittee shall maintain files of all information (including all reports and
notifications) required by a NESHAP Standard recorded in a form suitable and readily available for
expeditious inspection and review. The files shall be retained for at least 5 years following the date
of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum,
the most recent 2 years of data for Units #6 and 7 shall be retained on site. The remaining 3 years
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of data may be retained off site. Such files may be maintained on microfilm, on a computer, on
computer floppy disks, on magnetic tape disks, or on microfiche. The on-site data retention
requirement does not apply to Unit #5.
[40 CFR 63.10(b)(1), 63.6665 and Table 8 to Subpart ZZZZ of Part 63]
4.18. NESHAP Records. The permittee shall maintain relevant records for such source of all
documentation supporting initial notifications and notifications of compliance status under 40 CFR
63.9. [40 CFR 63.10(b)(2)(xiv)]
NESHAP Notification and Reporting Requirements
4.19. NESHAP Change in Information Already Provided. Any change in the information already
provided under a NESHAP standard shall be provided to the Administrator in writing within 15
calendar days after the change. [40 CFR 63.9(j)]
5. Unit-Specific Requirements - NESHAP Subpart ZZZZ for Unit
#5 (Emergency Generator Engine)
5.1. At all times the permittee shall be in compliance with NESHAP Subpart ZZZZ requirements that
apply to the permittee. [40 CFR 63.6605(a)]
5.2. The permittee shall comply with the applicable NESHAP Subpart A general provisions listed in
Table 8 to Subpart ZZZZ of Part 63, except that the requirement to submit all of the notifications
in 63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) does not apply.
[40 CFR 63.6645(a)(5), 63.6665 and Table 8 to Subpart ZZZZ of Part 63]
Unit #5 Work Practice Requirements
5.3. The permittee shall change the oil and filter every 500 hours of operation or annually, whichever
comes first. [40 CFR 63.6602 and Row 6.a. of Table 2c to Subpart ZZZZ of Part 63]
5.3.1. The permittee has the option of utilizing an oil analysis program in order to extend the
specified oil change requirement in Condition 5.3 as follows:
5.3.1.1 The analysis program must at a minimum analyze the following three
parameters: Total Acid Number, viscosity, and percent water content.
5.3.1.2 The condemning limits for these parameters are as follows: Total Acid Number
increases by more than 3.0 milligrams of potassium hydroxide (KOH) per gram
from Total Acid Number of the oil when new; viscosity of the oil has changed
by more than 20 percent from the viscosity of the oil when new; or percent
water content (by volume) is greater than 0.5.
5.3.1.3 If all these condemning limits are not exceeded, the engine owner or operator is
not required to change the oil.
5.3.1.4 If any of the limits are exceeded, the engine owner or operator must change the
oil within 2 business days of receiving the results of the analysis; if the engine is
not in operation when the results of the analysis are received, the engine owner
or operator must change the oil within 2 business days or before commencing
operation, whichever is later.
[40 CFR 63.6625 (j) and footnote 2 of Table 2c to Subpart ZZZZ of Part 63]
5.4. The permittee shall inspect air cleaner every 1,000 hours of operation or annually, whichever
comes first, and replace as necessary.
[40 CFR 63.6602 and Row 6.b. of Table 2c to Subpart ZZZZ of Part 63]
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5.5. The permittee shall inspect all hoses and belts every 500 hours of operation or annually, whichever
comes first, and replace as necessary.
[40 CFR 63.6602 and Row 6.c. of Table 2c to Subpart ZZZZ of Part 63]
5.6. If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements pursuant to Conditions 5.3, 5.4
and 5.5, or if performing the management practice would otherwise pose an unacceptable risk
under federal, state, or local law, the management practice shall be performed as soon as
practicable after the emergency has ended or the unacceptable risk under federal, state, or local law
has abated. [Footnote 1 of Table 2c to Subpart ZZZZ of Part 63]
5.7. Except as provided for in Condition 5.8, the permittee may operate Unit #5 outside of emergency
situations for up to 100 hours per calendar year and only for the following purposes:
5.7.1. Maintenance checks and readiness testing, provided that the tests are recommended by
federal, state or local government, the manufacturer, the vendor, the regional
transmission organization or equivalent balancing authority and transmission operator, or
the insurance company associated with the engine;
5.7.2. Emergency demand response for periods in which the Reliability Coordinator under the
North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-
3, Capacity and Energy Emergencies (incorporated by reference, see 40 CFR 63.14), or
other authorized entity as determined by the Reliability Coordinator, has declared an
Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-
3;
5.7.3. For periods when there is a deviation of voltage or frequency of 5 percent or greater
below standard voltage or frequency; and
5.7.4. Non-emergency situations up to 50 hours per calendar year. This 50-hour allowance
cannot be used for peak shaving or non-emergency demand response, or to generate
income for a facility to an electric grid or otherwise supply power as part of a financial
arrangement with another entity.
[40 CFR 63.6640(f)(1) through (3)]
5.8. The permittee may petition the Administrator for approval of additional hours to be used for
maintenance checks and readiness testing, but a petition is not required if the owner or operator
maintains records indicating that federal, state, or local standards require maintenance and testing
of emergency engines beyond 100 hours per calendar year. [40 CFR 63.6640(f) (2) (i)]
5.9. During periods of startup, the permittee shall minimize the engine's time spent at idle and
minimize the engine's startup time to a period needed for appropriate and safe loading of the
engine, not to exceed 30 minutes.
[40 CFR 63.6625(h) and Table 2c to Subpart ZZZZ of Part 63]
5.10. At all times the permittee shall operate and maintain the engine, including associated air pollution
control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emission does
not require the permittee to make any further efforts to reduce emissions if levels required by this
standard have been achieved. Determination of whether such operation and maintenance
procedures are being used will be based on information available to the Administrator which may
include, but is not limited to, monitoring results, review of operation and maintenance procedures,
review of operation and maintenance records, and inspection of the source.
[40 CFR 63.6605(b)]
Northwest Pipeline - Pocatello Compressor Station
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5.11. The permittee shall operate and maintain the engine and after-treatment control device (if any)
according to the manufacturer's emission-related written operation and maintenance instruction, or
alternatively, the permittee shall develop and follow its own maintenance plan which shall provide
to the extent practicable for the maintenance and operation of the engine in a manner consistent
with good air pollution control practice for minimizing emissions.
[40 CFR 63.6625(e), 63.6640(a) and Row 9 of Table 6 to Subpart ZZZZ of Part 63]
Unit #5 Monitoring and Recordkeeping Requirements
5.12. If the permittee utilizes an oil analysis program pursuant to Condition 5.3.1, the owner or operator
shall keep records of the parameters that are analyzed as part of the program, the results of the
analysis, and the oil changes for the engine. The analysis program shall be part of the maintenance
plan for the engine.
[40 CFR 63.6625 (j) and footnote 2 of Table 2c to Subpart ZZZZ of Part 63]
5.13. The permittee shall install a non-resettable hour meter if one is not already installed.
[40 CFR 63.6625(f)]
5.13.1. The permittee shall keep records of the hours of operation of the engine that is recorded
through the non-resettable hour meter.
5.13.2. The permittee shall document how many hours are spent for emergency operation,
including what classified the operation as emergency and how many hours are spent for
non-emergency operation.
5.13.3. If the engine is used for the purposes specified in Conditions 5.7.2 or 5.7.3, the permittee
shall keep records of the notification of the emergency situation, and the date, start time,
and end time of engine operation for these purposes.
[40 CFR 63.6655(f)]
5.14. The permittee shall keep records to show continuous compliance with Condition 5.11.
[40 CFR 63.6655(d)]
5.15. The permittee shall keep records of the maintenance conducted on the engine in order to
demonstrate that the permittee operated and maintained the engine and after-treatment control
device (if any) according to the permittee's own maintenance plan referred to in Condition 5.11.
[40 CFR 63.6655(e)]
Unit #5 Reporting Requirements
5.16. If Unit #5 operates or is obligated to be available for more than 15 hours per year for the purposes
specified in Conditions 5.7.2 and 5.7.3, the permittee shall submit annual reports as follows:
5.16.1. The report shall contain the following information: (1) company name and address where
the engine is located, (2) date of the report and beginning and ending dates of the reporting
period, (3) engine site rating and model year, (4) latitude and longitude of the engine in
decimal degrees reported to the fifth decimal place, (5) hours operated for the purposes
specified in Conditions 5.7.2 and 5.7.3, and (6) number of hours the engine is
contractually obligated to be available for the purposes specified in Conditions 5.7.2 and
5.7.3.
5.16.2. Annual reports for each calendar year must be submitted no later than March 31 of the
following calendar year.
5.16.3. The annual report shall be submitted electronically using the subpart specific reporting
form in the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed
through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the
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reporting form specific to this subpart is not available in CEDRI at the time that the report
is due, the written report must be submitted to EPA at the address specified in Condition
3.40.
[40 CFR 63.6650(a), (h) and Row 4 of Table 7 to Subpart ZZZZ of Part 63]
5.17. The permittee shall report in the semi-annual monitoring report required by Condition 3.47 any
failure to perform timely management practices as required by Conditions 5.3, 5.4 and 5.5 for
reasons afforded by Condition 5.6. Report also the federal, state or local law under which the risk
was deemed unacceptable.
[40 CFR 71.6(a) (3) (iii) (A) and footnote 1 of Table 2c to Subpart ZZZZ of Part 63)]
5.18. The permittee shall report in the semi-annual monitoring report required by Condition 3.47 each
instance in which the permittee did not meet the requirements in Table 8 to 40 CFR 63, Subpart
ZZZZ. [40 CFR 63.6640(e) and 71.6(a)(3)(iii)(A)]
5.19. The permittee shall report all deviations as defined in 40 CFR Part 63, Subpart ZZZZ in the semi-
annual monitoring report required by Condition 3.47. [40 CFR 63.6650(f)]
6. Unit-Specific Requirements - NESHAP Subpart DDDDD for
Units #6 (Boiler) and 7 (Process Heater)
Units #6 and 7 Work Practice Requirements
6.1. Tune-ups. The permittee shall conduct tune-ups of Units #6 and 7 every 5 years.
[40 CFR 63.7510(e) and 63.7500(a)(1)]
6.1.1. Tune-ups shall be conducted every 5 years to demonstrate continuous compliance. Each
5-year tune-up shall be no more than 61 months after the previous tune-up.
[40 CFR 63.7495(b), 63.7500(a)(1), 63.7510(e), 63.7515(d), 63.7540 (12) and Item 1 in
Table 3 to Subpart DDDDD]
6.1.2. For each unit not operating on the required date for a tune-up, the tune-up must be
conducted within 30 calendar days of startup. [40 CFR 63.7515(g) and 63.7540(a) (13)]
6.1.3. Tune-ups shall be conducted as follows:
6.1.3.1 As applicable, inspect the burner, and clean or replace any components of the
burner as necessary (the permittee may delay the burner inspection until the next
scheduled or unscheduled unit shutdown, but the permittee must inspect each
burner at least once every 72 months). At units where entry into a piece of
process equipment or into a storage vessel is required to complete the tune-up
inspections, inspections are required only during planned entries into the storage
vessel or process equipment;
6.1.3.2 Inspect the flame pattern, as applicable, and adjust the burner as necessary to
optimize the flame pattern. The adjustment should be consistent with the
manufacturer's specifications, if available;
6.1.3.3 Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that
it is correctly calibrated and functioning properly (the permittee may delay the
inspection until the next scheduled unit shutdown);
6.1.3.4 Optimize total emissions of CO. This optimization should be consistent with the
manufacturer's specifications; and
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6.1.3.5 Measure the concentrations in the effluent stream of CO in parts per million, by
volume, and oxygen in volume percent, before and after the adjustments are
made (measurements may be either on a dry or wet basis, as long as it is the
same basis before and after the adjustments are made). Measurements may be
taken using a portable CO analyzer.
[40 CFR 63.7540(a) (10) (i) to (v) and 63.7540(a) (12)]
6.2. Good Air Pollution Control Practices. At all times, the permittee shall operate and maintain the
boilers, including associated air pollution control equipment and monitoring equipment, in a
manner consistent with safety and good air pollution control practices for minimizing emissions.
Determination of whether such operation and maintenance procedures are being used will be based
on information available that may include, but is not limited to, monitoring results, review of
operation and maintenance procedures, review of operation and maintenance records, and
inspection of the source. [40 CFR 63.7500(a) (3)]
Units #6 and 7 Monitoring and Recordkeeping Requirements
6.3. Records. The permittee shall keep and maintain records as follows:
6.3.1. A copy of each notification and report submitted to comply with NESHAP Subpart
DDDDD, including all documentation supporting any Initial Notification or Notification
of Compliance Status submitted according to the requirements in 63.10 (b) (2) (xiv).
[40 CFR 63.7555(a)(1)]
6.3.2. Records of the calendar date, time, occurrence and duration of each startup and
shutdown. [40 CFR 63.7555(i)]
6.3.3. Records of the type(s) and amount(s) of fuels used during each startup and shutdown.
[40 CFR 63.7555(j)]
6.3.4. On-site and submitted, if requested by the Administrator, an annual report containing the
following:
6.3.4.1 The concentrations of CO in the effluent stream in parts per million by volume,
and oxygen in volume percent, measured at high fire or typical operating load,
before and after the tune-up of the boiler; and
6.3.4.2 A description of any corrective actions taken as a part of the tune-up.
[40 CFR 63.7540(a) (10) (vi)]
6.3.5. Each record must be in a form suitable and readily available for expeditious review. Each
record shall be kept for 5 years following the date of each occurrence, measurement,
maintenance, corrective action, report, or record. Each record shall be kept on site, or
they shall be accessible from onsite (for example, through a computer network), for at
least 2 years after the date of each occurrence, measurement, maintenance, corrective
action, report, or record. The permittee can keep the records off site for the remaining 3
years. [40 CFR 63.7560(a) to (c)]
Units #6 and 7 Notification and Reporting Requirements
6.4. Annual Compliance Reports. The permittee shall submit 5-year compliance reports.
[40 CFR 63.7550(a) and Item l.a in Table 9 to Subpart DDDDD]
6.4.1. Each compliance report shall cover the 5-year reporting period from January 1 to
December 31, and be postmarked or submitted no later than January 31 of the year
following the reporting period.
[40 CFR 63.7550(b)(3) and (4)]
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6.4.2. The compliance report shall include the following information: [40 CFR 63.7550(c) (1)]
6.4.2.1 Company and Facility name and address. [40 CFR 63.7550(c)(5)(i)]
6.4.2.2 Process unit information. [40 CFR 63.7550(c) (5) (ii)]
6.4.2.3 Date of report and beginning and ending dates of the reporting period.
[40 CFR 63.7550(c) (5) (iii)]
6.4.2.4 The date of the most recent tune-up for each unit subject to only the requirement
to conduct a 5-year tune-up according to 40 CFR 63.7540(a) (12), and the date of
the most recent burner inspection if it was not done on a 5-year period and was
delayed until the next scheduled or unscheduled unit shutdown.
[40 CFR 63.7550(c)(5) (xiv)]
6.4.2.5 If there are no deviations from the requirements for work practice standards in
Table 3 to Subpart DDDDD of Part 63 that apply to the permittee, a statement
that there were no deviations from the work practice standards during the
reporting period. [Item l.b in Table 9 to Subpart DDDDD]
6.4.2.6 If the permittee has a deviation from a work practice standard during the
reporting period, the report must contain a description of the deviation and
information on the duration and cause of the deviation and corrective action
taken.
[Item l.c in Table 9 to Subpart DDDDD and 40 CFR 63.7550(d)(1) and (2)]
6.4.2.7 The information required to be recorded pursuant to Condition 6.3.4.
[40 CFR 63.7540(a) (10) (vi) and 71.6(a) (3) (iii) (A)]
6.4.2.8 A statement by a responsible official with that official's name, title, and
signature, certifying the truth, accuracy, and completeness of the content of the
report. [40 CFR 63.7550(c) (5) (xvii)]
6.4.3. All reports shall be submitted electronically using the Compliance and Emissions Data
Reporting Interface that is accessed through the EPA's Central Data Exchange
(www.epa.gov/cdx). If the reporting form specific to this subpart is not available in
CEDRI at the time that the report is due, the report shall be submitted to the address listed
in Condition 3.40. [40 CFR 63.7550(h)]
6.5. Notification of Fuel Switch or Physical Change. The permittee shall provide notice to the EPA
within 30 days of the switch/change if the permittee has switched fuels or made a physical change
to a boiler and the fuel switch or physical change resulted in the applicability of a different
subcategory of NESHAP Subpart DDDDD. The notice shall identify:
6.5.1. The name of the owner or operator of the boiler, the location of the boiler, identification
of the boiler that has switched fuels or was physically changed, and the date of the notice.
6.5.2. The currently applicable subcategory under NESHAP Subpart DDDDD.
6.5.3. The date upon which the fuel switch or physical change occurred.
[40 CFR 63.7545(h)]
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United States Environmental Protection Agency
Region 10, Air & Radiation Division
1200 Sixth Avenue, Suite 155,15-H13
Seattle, Washington 98101-3188
Permit Number: R10T5110200
Expiration: Five years from issue
Replaces: R10T5110100
Effective: Draft
Issued: Draft
AFS Plant I.D. Number: 16-005-00049
Statement of Basis
Title V Air Quality Operating Permit
Permit Renewal #2
Permit Writer: Christopher Familiare
Williams Corporation, Northwest Pipeline LLC
Pocatello Compressor Station
Fort Hall Indian Reservation
Pocatello, Idaho
Purpose of Permit and Statement of Basis
Title 40 Code of Federal Regulations Part 71 establishes a comprehensive air quality operating permit
program under the authority of Title V of the 1990 amendments to the federal Clean Air Act. The air
quality operating permit is an enforceable compilation of all of the applicable air pollution
requirements that apply to an existing affected air emissions source. The permit is developed via a
public process, may contain additional new requirements to improve monitoring of existing
requirements, and contains procedural and prohibitory requirements related to the permit program
itself. The permit is valid for five years and may be renewed.
This document, the statement of basis, summarizes the legal and factual basis for the permit conditions
in the air quality operating permit to be issued to Northwest Pipeline for their Pocatello Compressor
Station (referred to herein as facility, source, or permittee). Unlike the air quality operating permit,
this document is not legally enforceable. This statement of basis summarizes the emitting processes
at the facility, air emissions, permitting and compliance history, the statutory or regulatory provisions
that relate to the subject facility, and the steps taken to provide opportunities for public review of the
permit. The permittee is obligated to follow the terms of the permit. Any errors or omissions in the
summaries provided here do not excuse the permittee from the requirements of the permit.
Page 222 of 270
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Table of Contents
Abbreviations & Symbols 3
1. EPA Authority to Issue Title V Permits 4
2. Facility Information 4
2.1 Location 4
2.2 Fort Hall Indian Reservation 4
2.3 Local Air Quality and Attainment Status 5
2.4 F acility Description 5
2.5 Identification of Emission Generating Activities 6
2.6 Permitting, Construction and Compliance History 8
3. Emission Inventory 9
3.1 Emission Inventory Basics 9
3.2 Potential to Emit (PTE) 9
3.3 Actual Emissions 10
4. Regulatory Analysis 11
4.1 Federal Air Quality Requirements 11
4.2 Other Federal Requirements and Responsibilities 17
5. Permit Content 18
5.1 Permit Conditions for Renewal Permit No. R10T5110200 18
5.2 Obsolete Permit Conditions from Expiring Permit No. R10T5110100 26
6. Public Participation 26
6.1 Public Notice and Comment 26
6.2 Response to Public Comments and Permit Issuance 27
Appendix A - PTE Emissions Inventory
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Title V Permit No. R10T5110200 Statement of Basis
Page 223 of 270
Page 2 of 27
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Abbreviations & Symbols
#
Number
%
Percent
Btu
British thermal units
BBL
Barrels (42 gallons)
CAA
Clean Air Act [42 U.S.C. section 7401 et seq.]
CAM
Compliance Assurance Monitoring
CFR
Code of Federal Regulations
CO
Carbon monoxide
COMS
Continuous opacity monitoring system
EPA
United States Environmental Protection Agency (also U.S. EPA)
EU
Emission Unit
FARR
Federal Air Rules for Reservations
FR
Federal Register
gr/dscf
Grains per dry standard cubic foot
gr
grains (7,000 grains = 1 pound)
HAP
Hazardous Air Pollutant
Hr
Hour
IEU
Insignificant Emission Unit
IC
Internal combustion
lb
Pound (lbs = pounds)
MACT
Maximum Achievable Control Technology
MMBtu
One million Btu
NESHAP
National Emission Standards for Hazardous Air Pollutants (40 CFR Parts 61 and 63)
No.
Number
NOx
Nitrogen oxides
NSPS
New Source Performance Standards
NSR
New Source Review
02
Oxygen
PM
Particulate matter
PMio
Particulate matter less than or equal to 10 microns in aerodynamic diameter
PM2.5
Particulate matter less than or equal to 2.5 microns in aerodynamic diameter
ppmv
Parts per million on a volume basis
PSD
Prevention of Significant Deterioration
PTE
Potential to emit (based on 8,760 hours of operation per year)
RICE
Reciprocating internal combustion engines
S
Sulfur
scf
Standard cubic feet (for natural gas is at 1 atmosphere and 60 degrees F)
S02
Sulfur dioxide
tpy
Tons per year
voc
Volatile organic compound
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 224 of 270
Page 3 of 27
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1. EPA Authority to Issue Title V Permits
On July 1, 1996, EPA adopted regulations (see 61 Federal Register (FR) 34202) codified at 40 Code of
Federal Regulations (CFR) Part 71 setting forth the procedures and terms under which the Agency would
administer a federal operating permit program. These regulations were updated on February 19, 1999 (64
FR 8247) to incorporate EPA's approach for issuing federal operating permits to affected stationary
sources in Indian Country, and have been updated since from time to time.
As described in 40 CFR 71.4(b), EPA will implement and enforce a part 71 operating permit program in
Indian country when an operating permit program which meets the requirements of part 70 has not been
granted approval by the Administrator. Unlike States, Indian Tribes are not required to develop operating
permit programs, though EPA encourages Tribes to do so. See, for example, Indian Tribes: Air Quality
Planning and Management (63 FR 7253, February 12, 1998) (also known as the "Tribal Authority Rule").
EPA may delegate the authority to administer a part 71 operating permit program, in whole or in part, to
an Indian Tribe as described in 40 CFR 71.4(j) and 71.10.
2. Facility Information
2.1 Location
The Northwest Pipeline Pocatello Compressor Station is a privately-owned facility located at 2605 Gas
Plant Road in Power County, Idaho. It is approximately 12 miles west of the City of Pocatello, and 19
miles southeast of the town of Fort Hall. The facility is located within the boundaries of the Fort Hall
Indian Reservation and is in Indian Country, as defined by 40 CFR Part 71. A map of the local area
surrounding the facility is presented in Figure 2-1 with the Fort Hall Indian Reservation outlined in
burgundy, the Fort Hall PMio non attainment area highlighted in yellow and the Portneuf Valley PMio
maintenance area highlighted in green.
Craters of
the Moon NM
Pocatello Compressor
Station
Hall
'
,
iF^ortNM
i •,
Non-attainment Bridger
* V
Fitzpatr
Wilctefh
V . \ •
r.
j ' r
Wilderness
Portneuf Valley
Maintenance
a for PMk)
Figure 2-1 - Facility Location
Map produced by Idaho Department of Environmental Quality
2.2 Fort Hall Indian Reservation
The Northwest Pipeline Pocatello Compressor Station is located on the Fort Hall Indian Reservation in
south east Idaho. The Fort Hall Indian Reservation was established by the Bridger Treaty of 1868 as a
1,350 square mile reservation for the Shoshone and Bannock Tribes. The current size of the reservation is
849.8 square miles (543,900 acres). The total population residing on the Fort Hall Reservation is below
10,000. The map in Figure 2-1 above shows the location of the Northwest Pipeline Pocatello Compressor
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 225 of 270
Page:4 of 27
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Station relative to its position within the Fort Hall Reservation.
Tribal Contact: Lori Howell
Air Quality Program Manager
Shoshone-Bannock Tribes
P.O. Box 306
Fort Hall, Idaho 83203
Phone: (208) 478-3794
Email: lhowell@sbtribes.com
2.3 Local Air Quality and Attainment Status
The EPA sets National Ambient Air Quality Standards for criteria air pollutants and then determines
whether areas in the country meet the standards. Areas that fail to meet national standards are called
nonattainment areas. Areas that meet national standards are called attainment areas (designated
"unclassifiable/attainment"). In some cases, the EPA is not able to determine an area's status after
evaluating the available information. Those areas are designated "unclassifiable." The Fort Hall Indian
Reservation and surrounding area has been designated unclassifiable/attainment for the PM2.5, ozone, CO,
NO2 and SO2 standards. As designated under 40 CFR 81.313 a PM10 nonattainment area lies within a
portion of the Fort Hall Indian Reservation. The compressor station lies about two miles west of the
nonattainment area (see Figure 2-1 above).
The closest Class I designated area to the compressor station is the Craters of the Moon National
Monument (see figure 2-1 above) which is located approximately 52 miles northwest of the Pocatello
Compressor Station. The Craters of the Moon National Monument is listed in 40 CFR 81.410 as a Class I
area for the purpose of major new source review (PSD) impact evaluation.
2.4 Facility Description
Northwest Pipeline Corporation is a subsidiary of Williams Gas Pipeline Company, LLC. Northwest
Pipeline Corporation owns and operates Williams' westernmost natural gas pipeline. The pipeline extends
from Washington State to New Mexico, passing through Oregon, Idaho, Wyoming, and Colorado. The
pipeline serves commercial, industrial and utility natural gas customers. The Pocatello Compressor
Station is one of many compressor stations located along the pipeline that assist in the transport of natural
gas through the pipeline. The compressor station fits under the standard industrial classification (SIC)
code 4922 for natural gas transmission. A plot plan of the facility is shown in Figure 2-2 below.
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 226 of 270
Page 5 of 27
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Figure 2-2 - Northwest Pipeline Pocatello Compressor Station Plot Plan
combustion units vent directly to the atmosphere through an individual stack, except for furnaces and
space heaters that generate emissions inside buildings. Installation dates for each emissions unit are listed
because they are important in determining applicability of federal NSPS and MACT standards (see further
discussion in Section 4).
An emission unit or activity qualifies as an insignificant emission unit (IEU) if it is an activity type listed
in 40 CFR 71.5(c) (11) (i) or emits less than 2 tons per year of any regulated air pollutant excluding HAPs
[40 CFR 71.5(c) (11) (ii) (A)] and less than 1000 pounds per year of any HAP or the de minimis HAP level
established under Section 112 (g), whichever is lower [40 CFR 71.5 (c) (11) (ii) (B)]. IEUs that are listed
activity types need not be included in permit applications and fee calculations as long as the permit
application does not omit information needed to determine the applicability of, or to impose, any
applicable requirements. IEUs that qualify because they meet the insignificant emission levels
(thresholds) only need to be listed in permit applications (and again as long as the application does not
omit information needed for applicability), but cannot be excluded from fee calculations. IEUs are in no
way exempt from applicable requirements, or any other requirement of the Title V permit.
Northwest Pipeline claimed three oil storage tanks (EU11) as IEUs on EPA Form IE in their Title V
application. Northwest Pipeline also noted that natural gas-fired space heaters (Unit #8) and the natural
gas pipeline and fuel system (Units #9 & 10) are IEUs. The emission units are not listed IEU activity
types, but the potential to emit for each of the emission units is below the IEU thresholds. Because all of
the IEUs qualify by meeting the IEU thresholds, their emissions must be included in fee calculations; as
such, these emission units have been included in the emission inventory in Appendix A.
2.5 Identification of Emission Generating Activities
The air pollution emission units and control devices that exist at Northwest Pipeline are listed in Tables 2-
1 below by emission unit identification (EU ID) and categorized as either generating fugitive or non-
fugitive emissions. Installation dates (if known) for each emission unit are listed because they are
important in determining applicability of federal PSD, NSPS and MACT standards (see further discussion
in Section 4). Capacities are listed for several emission units based on the best information available from
the applicant. Those control devices that are required by rule or this permit are so noted.
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Title V Permit No. R10T5110200 Statement of Basis
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Page 6 of 27
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Table 2-1: Emission Units (EU) & Control Devices
EU ID#
Emission Unit Description
Control Device
Unit 1
Clark TLA-6 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas fired, 14.8
MMBtu/hr, 2,000 horsepower; SN: 73546, installed 1956
None
Unit 2
Clark TLA-6 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas-fired, 14.8
MMBtu/hr, 2,000 horsepower; SN: 73547, installed 1956
None
Unit 3
Clark TLA-6 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas fired, 14.8
MMBtu/hr, 2,000 horsepower; SN: 73548, installed 1956
None
Unit 4
Clark TCV-10 Gas Compressor Engine; Two-stroke, lean-
burn, reciprocating IC engine; natural gas fired; 21.7
MMBtu/hr, 4,300 horsepower; SN: 107027, installed
1956
None
Unit 5
Caterpillar 3408 Emergency Generator Engine; Four-
stoke, rich-burn, reciprocating IC engine; natural gas
fired, 3.76 MMBtu/hr natural gas fired, 400 horsepower;
SN: CA 00844, installed 1998
None
Unit 6
Sellers Boiler; Model C80W; natural gas fired, 3.35
MMBtu/hr; Provides glycol heat to keep compressor
engines on warm standby, installed 1989
None
Unit 7
Sivallis Fuel Gas Heater; Model SB16-16; natural gas
fired, 0.5 MMBtu/hr natural gas fired; Pre-heats fuel for
compressor engines and the Sellers boiler, installed 2000
None
Unit 8*
Miscellaneous non-fugitive activities (MNFA) consist of
furnaces and space heaters that generate emissions inside
buildings.
None
Unit 9*
System Blowdown Gas: Once per year where the source
conducts an Emergency Shutdown Test where the source
is isolated from the natural gas line and the system is
purged venting natural gas to the atmosphere.
Approximately 350,000 cubic feet of natural gas is vented
during this MNFA Emergency Shutdown Test.
None
Unit 10*
Miscellaneous fugitive activities (MFA) consist of leaks
from the piping valves, flanges, and open-ended lines, and
compressors associated with the source.
None
Unit 11*
Used Oil Tank, 2,940 gallons (70 BBL); Used Lube Oil
Tank, 11,760 gallons (280 BBL); Scrubber Oil Tank,
1,250 gallons (29.8 BBL) - Scrubber tank stores oil that is
removed (knockout) from the natural gas prior to
compression.
None
* Insignificant Emission Units (IEU). See the Statement of Basis Section 2.4 for more information.
An emission unit or activity qualifies as an IEU if it is an activity type listed in 40 CFR 71.5(c) (11) (i) or
emits less than two tons per year of any regulated air pollutant excluding HAPs [40 CFR
71.5(c) (11) (ii) (A)] and less than 1,000 pounds per year of any HAP or the de minimis HAP level
established under Section 112(g), whichever is lower [40 CFR 71.5(c)(11)(ii)(B)]. The IEUs listed in
Table 2-1 above have been identified by Northwest Pipeline as IEUs on the basis that each unit's potential
Northwest Pipeline - Pocatello Compressor Station
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to emit (PTE) for any individual regulated air pollutant (excluding HAPs) does not exceed two tons per
year.
2.6 Permitting, Construction and Compliance History
The Pocatello Compressor Station was originally constructed in 1956 with the installation of three 2,000
hp Clark TLA-6 gas compressor engines. In 1969 a 4,300 hp Clark TCV-10 gas compressor engine was
installed at the site to increase the facility's compressor capacity. All four compressor engines are still in
use today. In 1998, an emergency backup generator was installed to ensure electrical reliability at the site.
Northwest Pipeline has not applied for, or received any new source review permits for the construction or
installation of equipment at the facility. Northwest Pipeline indicates that there have been no
modifications, or installations, of any large emission unit(s), after major new source review (PSD
permitting) requirements went into effect. EPA has not drawn any conclusions regarding compliance with
PSD permitting requirements, and no enforcement shield is implied or granted.
Either the EPA, or the Shoshone-Bannock Tribes Air Quality Program on behalf of EPA, have inspected
the Pocatello Compressor Station at least every other year since issuance of the initial Title V permit in
October 2002. The associated inspection reports indicate that the source has been operating in compliance
with applicable air pollution requirements.
A chronologic summary of Title V permit activities for the Pocatello Compressor Station is provided
below.
October 17, 2002
June 3,2005
June 1,2007
June 13,2007
July 6, 2007
October 29, 2007
December 5, 2007
July 30, 2015
August 29, 2015
September 28, 2015
September 30, 2015
September 9, 2019
November 13, 2019
EPA issues initial Title V permit with an effective date of December 2, 2002.
This is a five-year renewable permit with an expiration date of December 2,
2007. The renewal application was due on June 2, 2007, six months prior to
permit expiration.
EPA issues letter to Northwest Pipeline requiring the Title V application be
updated to include Federal Air Regulations for Reservations (FARR).
EPA receives Title V permit renewal application from Northwest Pipeline.
EPA receives additional information for the application regarding applicable
regulations, including FARR requirements.
EPA receives additional information for the application regarding the designation
of responsible officials.
Meeting with Northwest Pipeline at EPA Region 10 to review permit renewal
process and expectations. EPA requested additional information.
EPA receives additional information for the application including emission
factors, list of IEUs, plot plan and photographs of the facility.
EPA receives additional information for the application including applicable
requirements under 40 CFR Part 63 to the boiler and process heater.
Public comment period for draft permit and statement of basis begins
Public comment period for draft permit ends.
Final permit issued with an effective date of October 31, 2015. Expiration date
September 30, 2020.
EPA receives Title V permit renewal application from Northwest Pipeline.
EPA receives additional information regarding NSPS Subparts A/JJJJ
reconstruction/modification applicability for the facility's four engines.
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February #, 2020 Public comment period for draft permit and statement of basis begins.
March #, 2020 Public comment period for draft permit ends.
3. Emission Inventory
3.1 Emission Inventory Basics
An emission inventory generally reflects either the "actual" or "potential" emissions from a source.
Actual emissions generally represent a specific period of time and are based on actual operation and
controls. Potential emissions, referred to as potential to emit (PTE), generally represent the maximum
capacity of a source to emit a pollutant under its physical and operational design, taking into
consideration regulatory restrictions, but only required control devices. PTE is often used to determine
applicability to several EPA programs, including Title V, PSD and Section 112 (MACT).
Emissions can be broken into two categories: point and fugitive. Fugitive emissions are those which could
not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening. Examples of
fugitive emissions are roads, piles that are not normally enclosed, wind blown dust from open areas, and
those activities that are normally performed outside buildings. Point sources of emissions include any
emissions that are not fugitive.
The equation below represents the general technique for estimating emissions (in tons per year) from each
emission unit at the facility. Emissions are calculated by multiplying an emission factor by an operational
parameter. To estimate actual emission, the permittee will need to track the actual operational rates. Note
that emission factors may be improved over time. For those estimation techniques that require substantial
site-specific parameter tracking, such as piles and roads, emissions associated with a defined operational
rate can be estimated to establish a set ratio that can be used to multiply by the actual operational rate in
future years, significantly simplifying the annual inventory effort. All of the techniques and site-specific
parameters and assumptions should be reviewed each year before estimating emissions to be sure they
remain appropriate.
E = EF x OP x K
Where:
E = pollutant emissions in tons/year
EF = emission factor (see Appendix A to this Statement of Basis)
OP = operational rate (or capacity for PTE)
K = 1 ton/2000 lbs for conversion from pounds per year to tons per year
3.2 Potential to Emit (PTE)
Northwest Pipeline submitted emission inventories of actual and potential emissions for the Pocatello
Compressor Station with its Title V permit renewal application. EPA reviewed Northwest Pipeline's
inventory and has documented the facility PTE in Appendix A. The PTE estimates for the compressor
station assumes all units operate 8760 hours per year and no enforceable emission controls exist that limit
emissions with the exception of the emergency backup electrical power generator which assumes no more
than 500 hours of operation. A summary of Northwest Pipeline's non-fugitive PTE (except for HAPs) is
presented in Table 3-1 below. Note that fugitive emissions are not included for non-HAP emissions,
because for compressor stations fugitive emissions are not used to determine program applicability as
explained in more detail in Section 4.1 of this Statement of Basis. HAPs are used to determine
applicability for MACT purposes.
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Table 3-1 - Pocatello Compressor Station Potential to Emit (tpy)1
Pollutant2
Emission Units
Total
Four
Natural Gas
Compressor
RICE
Backup
Generator
RICE
Boiler &
Heater
Heaters
&
Furnaces
System
Blowdown
Equipment
Leaks &
Oil Storage
T anks
CO
100.2
3.5
1.4
0.4
106
NOx
1087.6
2.1
1.7
0.5
1,092
PM
11.1
11
PMio
13.8
0.1
14
PM2.5
13.8
0.1
14
S02
15.8
0.1
1.0
0.3
17
VOC
32.4
0.1
0.2
33
GHG (C02e)
33,924
110
2,059
605
178
36,876
Facility-wide Single
HAP
16.0
Facility-wide Total HAP
23.2
1 Fugitive emissions are not included in this table (except for HAPs) because fugitives are not used in applicability
determinations for this source type (see Section 4.1). For fugitive emission estimates, see Appendix A.
2 CO = carbon monoxide; NOx = oxides of nitrogen; PM = particulate matter; PMio = inhalable coarse particulate
or particulate matter with diameter 10 microns or less; PM2.5 = fine particulate or particulate matter with diameter
2.5 microns or less; SO2 = sulfur dioxide; VOC = volatile organic compounds; GF1G = greenhouse gases; C02e =
carbon dioxide equivalent; F1AP = hazardous air pollutants [see CAA, Section 112(b)]; facility-wide total F1AP =
all FlAPs totaled; facility-wide single F1AP = highest individual F1AP.
Northwest Pipeline is expected to use the emission factors and calculation methods listed in Appendix A
unless Northwest Pipeline demonstrates that a more appropriate emission factor or calculation method
should be used (e.g., results of more recent source testing or sampling, revised emission factors published
in AP-42 or etc.). It is important to emphasize that to the extent Northwest Pipeline relies on any type of
emission control technique to estimate emissions used to determine annual fees, or the applicability of a
regulatory program, use of the technique must be fully documented and verifiable.
3.3 Actual Emissions
Northwest Pipeline is required to pay fees annually based on an inventory of its actual emissions for the
preceding calendar year (see Permit Conditions 3.41 through 3.45). Table 3-3 summarizes Northwest
Pipeline's reported actual emissions generated in calendar year 2018.1
1 Although Northwest Pipeline is not required to report CO emissions for the purpose of part 71 fee payment, CO
emissions were reported as required by the Federal Air Rules for Reservations (FARR). See 40 CFR 49.138(f) and
71.2. Greenhouse gas emissions were not reported as GF1G is not classified as a "regulated pollutant (for fee
calculation)" and GF1G is not a pollutant for which the FARR registration program requires annual reporting of
emissions. See 40 CFR 49.138(e) (3) (xii) and 71.2. PM emissions were not reported as PM is not a regulated
pollutant in the context of the part 71 program and PM is not a pollutant for which the FARR registration program
requires annual reporting of emissions. See 40 CFR 49.138(e) (3) (xii) and October 16, 1995 EPA memorandum
entitled, "Definition of Regulated Pollutant for Particulate Matter for Purposes of Title V." PM2.5 emissions were not
reported as they were assumed to be equivalent to PM10 emissions.
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Table 3-2: Pocatello Compressor Station Actual Emissions (tons) for Calendar Year 2018
Emission Units
Pollutant
Four
Natural Gas
Backup
Generator
Heaters
&
Furnaces
System
Equipment
Leaks &
T otal
Compressor
RICE
RICE,
Boiler & Heater
Blowdown
Oil Storage
T anks
CO
47.02
0.91
47.9
NOx
395.17
1.07
396.2
PMio
4.05
0.08
No emissions reported for fee
purposes as these emission units are
IEU's. See 40 CFR 71.9(c) (5) (iii).
4.1
S02
0.69
0.01
0.7
voc
9.56
0.06
9.6
Formaldehyde
(highest-emitting
HAP)
4.63
0.02
4.7
4. Regulatory Analysis
The EPA is required by 40 CFR part 71 to include in this Title V permit all emission limitations and
standards that apply to the facility, including operational, monitoring, testing, recordkeeping and reporting
requirements necessary to assure compliance. This section explains which air quality regulations apply to
this facility and how those requirements are addressed in the permit.
Located in Indian Country, the Pocatello Compressor Station is subject to federal air quality regulations,
and is not subject to state air quality regulations. The EPA does not consider permits issued by Idaho to
the Pocatello Compressor Station to be applicable requirements. The facility could be subject to tribal air
quality regulations; however, the Shoshone-Bannock Tribes has not gone through the process of obtaining
authorization to be treated in the same manner as states under 40 CFR 49.6 and 49.7 (Tribal Authority
Rule) and obtaining approval of air quality regulations as a "Tribal Implementation Plan." Therefore,
Tribal air quality regulations, if any, are not federally enforceable and do not meet the definition of
"applicable requirement" under 40 CFR part 71. As such, there are no Tribal air quality regulations
included in the Pocatello Compressor Station Title V permit.
The EPA relied on information provided in Northwest Pipeline's Title V permit application and on
supplementary information provided by Northwest Pipeline to determine the requirements that are
applicable to the Pocatello Compressor Station. Future modifications to the facility could result in
additional requirements.
4.1 Federal Air Quality Requirements
Title V Operating Permit Program. Title V of the CAA and the implementing regulation found in 40 CFR
part 71 require major sources (as well as specified non-major sources) of air pollution to obtain operating
permits and form the legal bases for this permit. A source is major if it has the potential to emit 100 tons
per year or more of any air pollutant subject to regulation, 25 tons per year or more of hazardous air
pollutants (totaled) or 10 tons per year or more of any single hazardous air pollutant (see 40 CFR 71.2).
The Pocatello Compressor Station is a major source subject to Title V because it has the potential to emit
more than 100 tons per year of NOx and CO and more than 10 tons per year of the HAP formaldehyde
(see Table 3-1 and Appendix A).
The Title V operating permit serves as a comprehensive compilation of the air quality requirements that
are applicable to a source. The permit also must assure compliance, so source-specific testing, monitoring,
recordkeeping and reporting have been added where necessary, as explained in Section 5 (Permit
Content) of this Statement of Basis below.
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New Source Review. The New Source Review (NSR) program requires stationary source owners or
operators to obtain a permit before they begin construction of a new source or a modification to an
existing source. In other words, facilities are required to obtain NSR permits for the construction of
entirely new facilities and for construction projects at existing facilities such as expansions, additions,
process changes, and equipment modifications. By requiring sources to meet pre-construction
requirements, the NSR program provides a mechanism to improve the air quality in nonattainment areas
and to maintain the air quality in attainment areas.
There are three types of NSR permitting programs, each with a different set of requirements. A facility
may be required to meet one or more of these sets of permitting requirements when the facility undertakes
a modification. The Prevention of Significant Deterioration (PSD) program applies to the construction of
a new major source or a major source making a major modification that is located in an attainment area.
The PSD program generally applies to facilities that have the potential to emit 250 tons per year (tpy) or
100 tpy or more of any regulated NSR pollutant. The thresholds depend on the type of source and there is
a list of 28 source categories for which the 100 tpy threshold applies. The Nonattainment NSR (NA NSR)
program applies to the construction of a new major source or a major source making a major modification
that is located in a nonattainment area. Generally, the NA NSR program applies to facilities that have the
potential to emit 100 tpy or more of a NAAQS pollutant. However, this threshold can be lower depending
on the nonattainment severity of the area where the source is or will locate. The Minor NSR program
applies to a new minor source and/or a minor modification at both major and minor sources, in both
attainment and nonattainment areas. Minor NSR will apply for those regulated NSR pollutants that are
emitted at or above the minor NSR thresholds specified in the Tribal minor NSR rule (Table 1 to 40 CFR
49.153) but below the major source thresholds.
Because the area in which the Pocatello Compressor Station is located is not classified non-attainment for
any pollutant, the NA NSR program is not currently relevant. Based upon our knowledge of the facility
and understanding of its potential emissions, the Pocatello Compressor Station is a PSD major source. It
has been a major source since the beginning of the PSD program. A modification to an existing major
source is subject to PSD review for each pollutant experiencing an emissions increase greater than
defined PSD significance level. A modification to an existing major source is subject to minor NSR for
each pollutant experiencing an emissions increase greater than the defined minor NSR significance level
but less than the defined PSD significance level. Whereas the minor NSR program became effective
August 30, 2011, the first version of the PSD program became effective in the late 1970's. The four main
gas compressor engines (Emission Units 1, 2, 3 and 4) were installed before the late 1970's. The backup
engine (Emission Unit 5), added to the facility in 1998, resulted in a potential increase of 36 tons per year
of NOx and 61 tons per year of CO.2 The thresholds for a significant increase are 40 and 100 tons per year
for NOx and CO, respectively, so the addition of the backup engine was not a major modification subject
to PSD review. The addition of the backup was not a modification subject minor NSR because that permit
program did not exist in 1998.
New Source Performance Standards (NSPS). There are no NSPS regulations applicable to the Pocatello
Compressor Station. The following is a list of four potentially applicable NSPS regulations and explains
why each is not applicable to the facility.
40 CFR Part 60 Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage
Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or
Modification Commenced After July 23, 1984.
2 The EPA September 6, 1995 guidance document entitled, "Calculating PTE for Emergency Generators," and its
statement that 500 hours is an appropriate default assumption for estimating the number of hours that an emergency
generator could be expected to operate under worst-case conditions, the construction of Unit #5 resulted in a
potential increase of 2.1 tpy NOx and 3.5 tpy CO. See Appendix A to this Statement of Basis for the calculation of
these values.
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NSPS Subpart Kb applies to storage vessels with a capacity greater than or equal to 75 cubic meters (m3)
(19,800 gal) used to store volatile organic liquids (VOL) for which construction, reconstruction, or
modification is commenced after July 23, 1984.
Conclusion: The largest storage tank at the Pocatello Compressor Station is 280 barrels (bbl) (11,760 gal)
of lubrication oil. This volume is less than the NSPS Subpart Kb requirement, and the facility commenced
operation prior to July 23, 1984; therefore, Subpart Kb does not apply. Construction of the newest storage
tank (scrubber oil tank) commenced after July 23, 1984, but its 1,250-gallon capacity is less than the
19,800-gallon applicability threshold. Subpart Kb does not apply to the newest tank.
40 CFR Part 60 Subpart KKK - Standards of Performance for Equipment Leaks of VOC from
Onshore Natural Gas Processing Plants
NSPS Subpart KKK applies to equipment leak components at onshore natural gas processing plants
that commenced construction after January 20, 1984. A natural gas processing plant is defined in
Subpart KKK as any processing site engaged in the extraction of natural gas liquids from field gas,
fractionation of mixed natural gas liquids to natural gas products, or both [40 CFR 60.631],
Conclusion: Pocatello Compressor Station is a natural compressor station and it does not extract or
fractionate natural gas liquids. Operation commenced prior to January 20, 1984; therefore, Subpart KKK
does not apply.
40 CFR Part 60 Subpart LLL - Standards of Performance for Onshore Natural Gas Processing:
SO; Emissions
NSPS Subpart LLL applies to facilities the following facilities that process natural gas: each sweetening
unit and each sweetening unit followed by a sulfur recovery unit.
Conclusion: The Pocatello Compressor Station does not operate natural gas sweetening units or sulfur
recovery units; therefore, Subpart LLL does not apply.
40 CFR Part 60 Subpart TTTT - Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
NSPS Subpart JJJJ applies to stationary spark ignition internal combustion engines that commence
construction after June 12, 2006, where the engines are manufactured:
• On or after July 1, 2007, for engines with a maximum engine power greater than or equal to 500
HP (except lean burn engines with a maximum engine power greater than or equal to 500 HP
and less than 1,350 HP);
• On or after January 1, 2008, for lean burn engines with a maximum engine power greater than or
equal to 500 HP and less than 1,350 HP;
• On or after July 1, 2008, for engines with a maximum engine power less than 500 HP; or
• On or after January 1, 2009, for emergency engines with a maximum engine power greater than
19 KW (25 HP).
Conclusion: Each of the stationary spark ignition internal combustion engines at the Pocatello Compressor
Station commenced construction prior to June 12, 2006; therefore, they are considered existing and
therefore not subject to the requirements of Subpart JJJJ [40 CFR 60.4230(a)(4)],
National Emission Standards for Hazardous Air Pollutants (NESHAP). With a few exceptions, NESHAP
standards promulgated under 40 CFR part 63 apply to "major sources" of HAP. Section 112(a) (1) and 40
CFR 63.2 define a "major source" as a stationary source or group of stationary sources located within a
contiguous area and under common control that emits or has the potential to emit considering controls in
the aggregate, 10 tons per year or more of any HAP or 25 tons per year or more of any combination of
HAP. The Northwest Pipeline Pocatello Compressor Station is a major source of HAP as it emits
approximately 16 tons of formaldehyde. See PTE emissions inventory in Appendix A.
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The following is a list of two potentially applicable NESHAP regulations and explains why each is not
applicable to the facility.
40 CFR Part 63 Subpart HH - National Emission Standards for Hazardous Air Pollutants from
Oil and Natural Gas Production Facilities
NESHAP Subpart HH applies to oil and natural gas production facilities that are major and area sources
of HAPs. A major source is defined as a stationary source that emits or has the potential to emit 10 tpy of
any single HAP or 25 tpy of total HAPs, and an area source is any stationary source of HAPs that is not a
major source [40 CFR 63.2],
For facilities that are major HAP sources, this subpart applies to facilities that process, upgrade or store
hydrocarbon liquids prior to the point of custody transfer or facilities that process, upgrade, or store
natural gas prior to the point at which natural gas enters the natural gas transmission and storage source
category or is delivered to a final end user.
The affected sources for major sources of HAPs include the following:
• Each glycol dehydration unit;
• Each storage vessel with the potential for flash emissions;
• Compressors or ancillary equipment operating in volatile hazardous air pollutant service located
at natural gas processing plants;
The affected sources for area sources of HAPs include the following:
• Each triethylene glycol (TEG) dehydration unit located at an oil and natural gas production
facility.
Conclusion: The Pocatello Compressor Station is a natural gas transmission compressor station and is a
major source of HAPs. The facility does not meet the NESHAP definition of a natural gas production
facility, there are no glycol dehydration units and there are no ancillary equipment operating in volatile
HAP service, therefore, Subpart HH does not apply.
40 CFR Part 63 Subpart HHH - National Emission Standards for Hazardous Air Pollutants from
Natural Gas Transmission and Storage Facilities
NESHAP Subpart HHH applies to owners and operators of natural gas transmission and storage facilities
that transport or store natural gas prior to entering the pipeline to a local distribution company or to a final
end user (if there is no local distribution company), and that are major sources of HAP emissions. The
applicable affected source is each glycol dehydration unit. An owner or operator of a facility that does not
contain a glycol dehydration unit is not subject to the requirements of this subpart.
Conclusion: The Pocatello Compressor Station is a natural gas transmission compressor station and is a
major source of HAPs, however, the facility does not operate a glycol dehydration unit, therefore, Subpart
HHH does not apply [40 CFR 63.1270(a), (b) & (c)].
40 CFR Part 63 Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
There are two NESHAP standards that are applicable to this facility: Subpart ZZZZ (Stationary
Reciprocating Internal Combustion Engines (RICE)) and Subpart DDDDD (Industrial, Commercial and
Institutional Boilers and Process Heaters at Major Sources). Subpart ZZZZ applies to the Emergency
Backup Electrical Power Generator (Unit #5) and Subpart DDDDD applies to the boiler and fuel gas
heater (Units #6 and 7). The applicable requirements in Subparts ZZZZ and DDDDD have been
incorporated into Sections 5 and 6 of the permit, respectively.
Any existing, new, or reconstructed stationary RICE located at a major or area source of HAP emissions,
excluding stationary RICE being tested at a stationary RICE test cell/stand is subject to 40 CFR 63
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Subpart ZZZZ. There are five stationary RICE at the Pocatello Compressor Station. In accordance with
40 CFR 63.6590(a), these engines are affected sources under 40 CFR Part 63, subpart ZZZZ. However, in
accordance with 40 CFR 63.6590(b) (3) (i), four of these engines (Units 1,2,3, and 4) do not have to meet
the requirements of 40 CFR Part 63, subpart ZZZZ or subpart A, including the initial notification
requirements. Table 4-1 below summaries MACT ZZZZ applicability.
Table 4-1 - MACT Subpart ZZZZ Applicability for IC Engines
EU I.D. #
Description
Fuel
Capacity
Subpart ZZZZ
Applicable?
1, 2 and 3
Clark TLA-6 Gas Compressor
Engine; Two-stroke, lean-burn;
Installed 1956
Natural
gas
14.8 MMBtu/hr
2,000
horsepower
Yes, under the category
of existing, two-stroke,
lean-burn engine
4
Clark TCV-10 Gas Compressor
Engine; Two-stroke, lean-burn;
Installed 1969
Natural
gas
21.7 MMBtu/hr
3,400
horsepower
Yes, under the category
of existing, two-stroke,
lean-burn engine
5
Caterpillar 3408 Emergency
Backup Generator Engine; Four-
stoke, rich-burn; Installed 1998
Natural
gas
3.76 MMBtu/hr
400 horsepower
Yes, emergency
stationary RICE.
The Caterpillar emergency backup electrical generator (Unit #5) is an affected source under Subpart
ZZZZ because it is an emergency stationary RICE under 40 CFR 63.6585(f). Under 40 CFR 63.6585(f),
an emergency stationary RICE must meet the definition of such a RICE under 40 CFR 63.6675, which
includes operating according to the provisions specified in 40 CFR 63.6640(f).
Each of the compressor engines at the facility are rated at greater than 500 horsepower, and therefore are
regulated engines under the rule. However, these engines are considered "existing" engines because they
were constructed and installed prior to December 19, 2002. Subpart ZZZZ has distinct requirements for
regulated engines depending on their design, use, and fuel. The compressor engines at the Pocatello
Compressor Station are categorized as spark-ignition, two-stroke, lean-burn (2SLB) engines under the
rule. Existing engines (Units 1, 2, 3, and 4) that are of the spark-ignition, two-stroke, lean-burn design are
not subject to any specific requirement under the rule, including being exempt for the initial notification
requirements of the NESHAP regulations.
If Northwest Pipeline were to modify any of the compressor engines in a manner that meets the definition
of reconstruction under NESHAP regulations, the engine may no longer be considered "existing' under
Subpart ZZZZ, and additional requirements from this subpart could apply.
40 CFR Part 63 Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants
for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters
Any new, reconstructed, or existing boiler or process heater located at a major source of HAP emissions,
excluding any units listed under 40 CFR 63.7491, is subject to 40 CFR 63 Subpart DDDDD. There are
two units at the Pocatello Compressor Station that meet the definition of "industrial, commercial, or
institutional boiler or process heater," the Sellers boiler and the Sivalls fuel gas line heater. None of the
exclusions apply to either of the units. In accordance with 40 CFR 63.7490(a)(1), these two units together
are the affected source under 40 CFR Part 63, subpart DDDDD. Table 4-2 below summarizes MACT
DDDDD applicability.
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Table 4-2 - MACT Subpart DDDDD Applicability for Boiler and Process Heater
EU I.D. #
Description
Fuel
Capacity
Subpart DDDDD
Applicable?
6
Sellers C80W Boiler,
Glycol Heater;
Installed 1989
Natural gas
(Gas 1)
3.35 MMBtu/hr
Yes, under the category of
existing, boiler
7
Sivalls Fuel Gas Line
Heater; Installed 2000
Natural gas
(Gas 1)
0.5 MMBtu/hr
Yes, under the category of
existing, process heater
According to the applicability criteria in 40 CFR 63.7490(b), (c), & (d), both the Sellers boiler and the
Sivalls heater are considered "existing" affected units as construction of each commenced prior to June 4,
2010 and because neither has been reconstructed since that date. Given the type of fuel combusted (Gas
1), neither of these units are subject to either an emissions limitation or operating limit according to 40
CFR 63.7500(e). Which Subpart DDDDD work practice standards apply depends upon the technical
specifications of the affected unit. Because each unit has a heat input capacity less than or equal to 5
MMBtu/hr, and because each unit is designed to burn Gas 1, each unit is subject to the requirement to
conduct a tune-up every five years pursuant to 40 CFR 63.7500(a)(1), (e) and Item No. 1 of Table 3 to
Subpart DDDDD. Because each unit is an existing unit located at a major source (and because neither is
a limit use unit), each unit is also subject to a one time-energy assessment pursuant to 40 CFR
63.7500(a)(1) and Item No. 4 of Table 3 to Subpart DDDDD.
Regional Haze Program. The Regional Haze Rule3 calls for state and federal agencies to work together to
improve visibility in 156 national parks and wilderness areas (Class 1 areas) such as the Grand Canyon,
Yosemite, the Great Smokies and Shenandoah. The 43,243-acre Craters of the Moon Wilderness Area is
the nearest Class 1 area to the facility. The southeast corner of this nearest Class 1 area is approximately
25 miles west of the facility. The area is managed by the United States Department of the Interior's
National Park Service.
The Western Regional Air Partnership (WRAP) is a voluntary partnership of states, tribes, federal land
managers, local air agencies and EPA whose purpose is to understand current and evolving regional air
quality issues in the West. The purpose of the WRAP Regional Haze Planning Work Group (RHPWG)4 is
to prepare the framework to support regional planning for the 15 western states, so that needed elements
will be available for Regional Haze state implementation plan (RH SIP) submissions in a timely fashion,
to meet the July 2021 deadline for implementation plans to be submitted in each of the 15 states
(including Idaho) for the second planning period of the federal Regional Haze Rule for visibility
protection at 118 Class I areas. Regional Haze SIPs or FIPs for the second planning period of the
Regional Haze Rule are due by July 2021 and may contain additional requirements for sources impacting
Class 1 areas.
Section 111(d) and Section 129 Regulations. There are no CAA, Section 111(d) or 129 regulations that
apply to the type of emission units at the Northwest Pipeline Pocatello Compressor Station.
Federal Air Rules for Reservations (FARR). On April 8, 2005, EPA promulgated a Federal
Implementation Plan (FIP) for Reservations in Idaho, Oregon and Washington, commonly referred to as
the Federal Air Rules for Reservations (FARR). The EPA published the FARR rules that generally apply
to Indian Reservations in EPA Region 10 in 40 CFR 49.121 to 49.139. The FARR rules that specifically
apply on the Fort Hall Reservation (Sections 123, 124, 125, 126, 129, 130, 131, 135, 137, 138 and 139)
are codified at 40 CFR 49.10701 to 49.10730. FARR requirements that do not apply to Pocatello
Compressor Station are not included in the permit; requirements that apply generally to all subject sources
3 https://www.govinfo.gov/content/pkg/FR-2017-01-10/pdf/2017-0Q268.pdf
4 https://www.wrapair2.org/RHPWG.aspx
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but do not create specific requirements for Northwest Pipeline (e.g., applicability provisions, definitions,
provisions regarding delegation) are also not included in the permit. The applicable requirements in the
FARR have been incorporated into Sections 3 and 4 of the permit.
Compliance Assurance Monitoring. CAM applies at time of initial Title V permit issuance for emission
units that (a) are subject to an emission limit, (b) employ a control device to comply with the limit, and (c)
have post-control PTE equal to or greater than the major source threshold defined in Title V (generally,
100 tons per year). See 40 CFR 64.5(a). All units that meet the CAM applicability criteria must be in
compliance with CAM at initial permit issuance. The initial Title V permit was issued to Northwest
Pipeline on October 17, 2002. It was determined at that time that each of the four compressor engines at
the Pocatello Compressor Station has a PTE for NOx greater than 100 tons per year. However, because
none of the engines are equipped with a control device, CAM does not apply. That determination
continues to remain valid.
Chemical Accident Release Program. Northwest Pipeline has not reported storing a regulated substance
above the threshold quantity. The permit contains a placeholder provision requiring the permittee to
comply with the chemical accident prevention provisions in 40 CFR part 68 in a timely manner if it
becomes subject.
Protection of Stratospheric Ozone. The provisions of 40 CFR part 82, subparts B and F apply to facilities
that handle ozone depleting substances (e.g. refrigerants). The permit contains conditions that require the
permittee to manage ozone depleting substances and maintain records according to these subparts.
Acid Rain Program. Title IV of the CAA created a SO2 and NOx reduction program found in 40 CFR part
72. The program applies to any facility that includes one or more "affected units" that produce electricity.
The facility's boiler is not an "affected unit" as defined in 40 CFR 72.6 because it does not produce
electricity.
Mandatory Greenhouse Gas Reporting Rule. This rule requires sources above certain emission thresholds
to calculate, monitor, and report greenhouse gas emissions. According to the definition of "applicable
requirement" in 40 CFR 71.2, neither 40 CFR part 98, nor CAA 307(d) (1)(V), the CAA authority under
which part 98 was promulgated, are listed as applicable requirements for the purpose of Title V
permitting. Although the rule is not an applicable requirement under 40 CFR part 71, the source is not
relieved from the requirement to comply with the rule separately from compliance with their part 71
operating permit. It is the responsibility of each source to determine applicability to part 98 and to
comply, if necessary.
4.2 Other Federal Requirements and Responsibilities
EPA Trust Responsibility. As part of the EPA Region 10's direct federal implementation and oversight
responsibilities, EPA Region 10 has a trust responsibility to each of the 271 federally recognized Indian
tribes within the Pacific Northwest and Alaska. The trust responsibility stems from various legal
authorities including the U.S. Constitution, Treaties, statutes, executive orders, historical relations with
Indian tribes, and in this case the Bridger Treaty of 1868. In general terms, the EPA is charged with
considering the interest of tribes in planning and decision making processes. Each office within the EPA
is mandated to establish procedures for regular and meaningful consultation and collaboration with Indian
tribal governments in the development of EPA decisions that have tribal implications. EPA Region 10's
Air and Radiation Division has contacted the Shoshone-Bannock Tribes to invite consultation on the
Northwest Pipeline Pocatello Compressor Station Title V operating permit renewal application.
Endangered Species Act (ESA). Under this act, the EPA is obligated to consider the impact that a federal
project may have on listed species or critical habitats. It is the EPA's conclusion that the issuance of this
Title V permit will not affect a listed species or critical habitat because it does not authorize new
emissions units, increase existing emission limits or impose any new work practice requirements.
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Therefore, no additional analysis and no additional requirements will be added to this permit for ESA
reasons. The EPA's no-effect determination concludes the EPA's obligations under Section 7 of the ESA.
For more information about EPA's obligations, see the Endangered Species Consultation Handbook:
Procedures for Conducting Consultation and Conference Activities under Section 7 of the Endangered
Species Act, published by the FWS and NMFS (March 1998, Figure 1).
National Environmental Policy Act (NEPA). Under Section 793(c) of the Energy Supply and
Environmental Coordination Act of 1974, no action taken under the CAA shall be deemed a major
Federal action significantly affecting the quality of the human environment within the meaning of the
National Environmental Policy Act of 1969. This permit is an action taken under regulations
implementing the CAA and is therefore exempt from NEPA.
National Historic Preservation Act (NHPA). As noted earlier, the issuance of this Title V permit does not
authorize new emissions units, increase existing emission limits or impose any new work practice
requirements. No changes to the facility are expected as a result of this permit action. Consequently, no
adverse effects are expected, and further review under NHPA is not indicated.
Environmental Justice (ET) Policy. Under Executive Order 12898, Federal Actions to Address
Environmental Justice in Minority Populations and Low-Income Populations, signed on February 11,
1994, the EPA is directed, to the greatest extent practicable and permitted by law, to make achieving
environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately
high and adverse human health or environmental effects of its programs, policies, and activities on
minority populations and low-income populations in the United States. This permit action does not allow
new or additional emissions and therefore impacts. As a result, there is no information available that
indicates that there are disproportionately high and adverse impacts to a minority or low-income
population.
5. Permit Content
5.1 Permit Conditions for Renewal Permit No. R10T5110200
This Title V operating permit compiles all of the applicable requirements that apply to the permittee.
Additional monitoring, recordkeeping and reporting requirements have been created where necessary. In
general, each permit condition in the permit is explained below. Certain permit conditions are self-
explanatory, and thus are not further discussed. The permit is organized into the following six sections:
Front Page: Authorization to Operate in Accordance with the Permit
Permit Section 1: Source Information and Emission Units
Permit Section 2: Standard Terms and Conditions
Permit Section 3: General Requirements
Permit Section 4: Facility-Specific Requirements
Permit Section 5: Unit-Specific Requirements - NESHAP Subpart ZZZZ for Unit #5
(Emergency Backup Generator)
Permit Section 6: Unit-Specific Requirements - NESHAP Subpart DDDDD for Units #6
(Boiler) and 7 (Process Heater)
Front Page - Authorization to Operate in Accordance with the Permit
The first page of the permit specifies the relevant statutes within the Clean Air Act and the implementing
federal regulations that authorize EPA to issue the permit and allow the permittee to operate and conduct
air polluting activities in accordance with the conditions in the permit. The front page also identifies the
permittee's contact information as well as the location of the permitted facility.
On January 31, 2020, EPA Region 10 received a request to change the responsible official from Glen
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Jasek to Camilo Amezquita. Mr. Amezquita has replaced Mr. Jasek as Vice President and General
Manager of Northwest Pipeline LLC. The renewed permit reflects the change.
Permit Section 1 - Source Information and Emission Units
This permit section contains a brief description of the facility and a list of emission units. A more detailed
description of the facility can be found in Section 2 of this Statement of Basis. Northwest Pipeline reports
one modification to the facility having been undertaken during the five-year term of the current Title V
permit. Two 310-gallon (each) scrubber oil tanks have been replaced by one 1,250-gallon scrubber oil
tank. The new tank (like the ones it replaced) is recognized as part of Unit #11.
Permit Section 2 - Standard Terms and Conditions
This permit section includes generic compliance terms that are required in all Title V permits, but that
Region 10 does not expect to be addressed in the annual compliance certification required in Permit
Condition 3.49.
Permit Condition 2.1 explains that the language in the underlying regulations takes precedence over
paraphrased language in the permit. Some applicable requirements are paraphrased in the permit with the
intention of clarifying the requirement, but with no intention of changing the underlying meaning of the
requirement. Where there is a difference between the language in a permit and an underlying regulation,
the wording in the underlying regulation governs. This permit condition also notes some underlying
authorities that may have been used to create additional requirements in this permit. For instance, Region
10 is relying upon periodic monitoring authority in 40 CFR 71.6(a) (3) (i) (B) to create monitoring
requirements when an applicable underlying emission limitation is not accompanied by monitoring.
Region 10 is relying upon sufficiency monitoring authority in 40 CFR 71.6(c) (1) to create monitoring
requirements when an applicable underlying emission limitation is accompanied by monitoring that we
have determined is not sufficient to assure compliance with the limitation.5
Permit Conditions 2.4 and 2.5 address a general permit shield which states that compliance with the
permit is deemed compliance with the applicable requirements listed in the permit. The permittee is
responsible for complying with any applicable requirements that exist but have not been included in the
permit. The permittee did not request a specific permit shield for any specific requirement excluded from
this permit and none is being granted.
Permit Condition 2.6 incorporates the credible evidence rule as reflected in the various applicable
requirements cited as authority for this condition. It makes clear that language in the permit stating
"compliance is determined with" or "demonstrate compliance by" does not preclude the use of other
credible evidence to demonstrate that the permittee is not in compliance with an applicable requirement.
Permit Conditions 2.7 and 2.8 incorporate the Part 71 provisions regarding permit modification,
revocation, reopening, reissuance, and termination for cause.
Permit Conditions 2.9 through 2.11 address the expiration of the permit and the ramifications if the
permittee does or does not renew their permit. It is important to note that, if the permittee does not submit
a complete and timely renewal application, the permittee's right to operate is terminated. The expiration
date of the permit is listed on the top right-hand corner of the front page of the permit. Specific
requirements regarding permit renewal are in Permit Conditions 3.51 and 3.52.
Permit Conditions 2.12 through 2.14 address options for making certain physical and operational changes
5 In the Matter of Citgo Refining and Chemicals Company L.P., West Plant, Corpus Christi, Texas, Order on
Petition No. VI-2007-01 (May 28, 2009). Permitting authorities must incorporate applicable monitoring
requirements into the Title V permit, add monitoring when no underlying monitoring exists, and supplement existing
monitoring that is not sufficient to assure compliance with permit terms and conditions.
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in the facility that do not require a permit modification. If the permittee uses any of these options, they
must comply with the applicable recordkeeping requirement found in Permit Condition 3.32 and reporting
requirements found in Permit Conditions 3.38 and 3.39.
Permit Section 3 - General Requirements
This permit section includes conditions that are required in all Title V permits. In some cases, facility-
specific testing, monitoring, recordkeeping and reporting requirements for these permit conditions are
found in Section 4 of the permit because those requirements can vary from permit to permit. Unless
otherwise specified, emission units are subject to the general requirements in Section 3 of the permit as
well as the facility-specific and unit-specific requirements in Sections 4 through 6.
Permit Conditions 3.1 and 3.2 are general compliance schedule requirements. Because EPA is not aware
of any non-compliance at the time of permit issuance, there is no issue-specific compliance schedule in
the permit.
Permit Condition 3.3 requires the permittee to allow EPA-authorized representatives access to the facility
and required records.
Permit Conditions 3.4 through 3.8 restrict open burning. If the permittee performs any open burning,
recordkeeping requirements specific to open burning found in Permit Condition 3.33 will apply.
Permit Conditions 3.9 through 3.11 limit visible emissions, require the use of either RM9 or a continuous
opacity monitoring system (COMS) for determining compliance with the limit, and provide exceptions to
the rule. RM9 includes specific guidance for reading opacity when there is a wet plume (both attached
and detached and directs the observer to take readings excluding the portion of the plume that includes
uncombined water (droplets). In the vast majority of cases, the likelihood of exceeding the 20% opacity
limit due to the presence of uncombined water is very low because a certified reader would know that
he/she should not read that portion of the plume. However, there are meteorological conditions that can
prevent uncombined water (droplets) from completely evaporating in a plume (e.g., 100% relative
humidity and a saturated plume). The provision in Permit Condition 3.11 addresses that situation.
Because testing, monitoring, recordkeeping and reporting for assuring compliance with the visible
emission limit can change based on the emission unit in question, the testing, monitoring, recordkeeping
and reporting requirements are contained in facility-specific requirements in Section 4 of the permit, or in
each emission unit-specific section, as appropriate. The general monitoring, recordkeeping and reporting
for this requirement is the periodic visible emissions survey (plant walkthrough) specified in Permit
Conditions 4.7 through 4.13.
Permit Conditions 3.12 through 3.17 restrict fugitive particulate matter emissions and require a plan be
created to assure the use of reasonable precautions to prevent fugitive emissions. The plan is based on a
survey of the facility and is updated annually. This annual survey can be accomplished simultaneously
with the periodic visible emission survey requirement in Permit Conditions 4.7 through 4.13, as long as
both requirements are fully complied with.
Permit Condition 3.18 addresses requirements in the Chemical Accident Prevention Program found in 40
CFR part 68. This program requires sources that use or store regulated substances above a certain
threshold to develop plans to prevent accidental releases. Based on information in their application, there
are no regulated substances above the threshold quantities in this rule at this facility; therefore, the facility
is not currently subject to the requirement to develop and submit a risk management plan. However, this
requirement is included in the permit as an applicable requirement because the permittee has an ongoing
responsibility to submit a risk management plan if a substance is listed that the facility has in quantities
over the threshold amount, or if the facility ever increases the amount of any regulated substance above
the threshold quantity. Including this term in the permit minimizes the need to reopen the permit if the
facility becomes subject to the requirement to submit a risk management plan.
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Permit Conditions 3.19 and 3.20 address the Stratospheric Ozone and Climate Protection Program found
in 40 CFR part 82. This program requires sources that handle regulated materials to meet certain
procedural and certification requirements. There may be equipment at the facility that uses or contains
chlorofluorocarbons (CFCs) or other materials regulated under this program. All air conditioning and
refrigeration units must be maintained by certified individuals if they contain regulated materials.
Permit Condition 3.21 addresses asbestos demolition or renovation activity found in 40 CFR part 61,
Subpart M (NESHAP). This program requires sources that handle asbestos-containing materials to follow
specific procedures. If the permittee conducts any demolition or renovation activity at their facility, they
must assure that the project is in compliance with the federal rules governing asbestos, including the
requirement to conduct an inspection for the presence of asbestos. This requirement is in the permit to
address any demolition or renovation activity that may occur at the facility.
Permit Conditions 3.22 through 3.30 specify the procedures that must be followed whenever the permit
requires emissions testing or sampling in an emission unit-specific section of the permit. If there is a
conflict between these permit conditions and an emission unit-specific permit condition, the specific
permit condition governs. Concentration-based emission limits required to be corrected to a specific
oxygen concentration in the flue gas often do not contain a protocol to convert measured concentrations to
specified oxygen levels. Permit Condition 3.28 provides a protocol for such a conversion.
Permit Condition 3.31 describes general recordkeeping that has been added to the permit using Part 71
authority to assure that there is good documentation for any monitoring that the permittee performs.
Permit Condition 3.32 describes recordkeeping requirements that apply only if the permittee makes off-
permit changes. Certain off-permit changes are allowed in Permit Condition 2.12.
Permit Condition 3.33 describe recordkeeping requirements that apply if the permittee performs open
burning. The open burning recordkeeping was added using Part 71 authority. Open burning is restricted in
Permit Conditions 3.4 through 3.8.
Permit Condition 3.34 includes recordkeeping that applies to fee records including the duration that the
records must be maintained. The duration is consistent with that required by Title V (see Permit
Condition 3.35).
Permit Condition 3.35 sets the duration that records must be maintained. Both Title V and FARR records
must be maintained for five years. These two requirements have been combined (streamlined) into one
permit condition. If there is ever a conflict between these requirements and a more restrictive emission
unit-specific permit condition, the specific permit condition governs.
Permit Conditions 3.36 and 3.37 require the permittee to submit or correct submitted information when
requested by EPA and as needed. The permittee has an ongoing obligation to assure that all data in its
Title V application is correct and to notify EPA of any errors or omissions. This includes notifying
Region 10 if the application no longer reflects the type of fuel actually being fired in a combustion unit.
An address for submitting application correction directly to Region 10's air permitting program is
included in this condition.
Permit Condition 3.38 and 3.39 describe reporting requirements that apply only if the permittee makes
off-permit changes (Permit Condition 3.38) or section 502(b) (10) changes (Permit Condition 3.39).
Certain off-permit changes are allowed in Permit Condition 2.12. Section 502(b) (10) changes are allowed
in Permit Conditions 2.13.
Permit Condition 3.40 includes the address for submittals to Region 10 and to the Tribe. All reports and
notices, except for fee payments (see Permit Condition 3.43), Part 71 permit applications (see Permit
Condition 3.51) and Part 71 permit application corrections (see Permit Condition 3.37), must be sent to
this address with a copy sent to the Tribe.
Permit Conditions 3.41 through 3.45 require submittal of an annual emission inventory (of actual
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emissions) and payment of fees for Part 71 purposes. These requirements refer to Permit Condition 4.1 for
the actual due date by which fees and emissions must be submitted each year. The per-ton fee rate varies
each year; contact EPA to obtain the current rate. The submittal of the emission inventory is timed to
coincide with the payment of fees because annual Title V fees are based on actual emissions generated
during the previous calendar year. Appendix A to this statement of basis documents the methods,
techniques, and assumptions that EPA believes provide the most accurate basis for estimating actual
emissions for this facility. As explained in Section 3.2 of this statement of basis, Region 10 expects the
emission estimation techniques listed in this statement of basis to be used to calculate the annual
emissions inventory, unless the permittee has other information showing why another technique more
accurately represents emissions. Also note that the actual emission estimates differ from the facility's
PTE because actual emission are calculated based on actual operations, not maximum operational
capacity.
Note that the FARR emission inventory required in Permit Condition 3.46 to be reported at the same time
can be combined with the Part 71 emission inventory as long as it is clear which emissions inventory is
for which purpose, because the pollutant lists for each emission inventory are slightly different.
Permit Condition 3.46 requires submittal of an annual emission inventory (of actual emissions) for FARR
registration purposes. Appendix A to this statement of basis documents the methods, techniques, and
assumptions that EPA believes provide the most accurate basis for estimating actual emissions for this
facility. As explained in Section 3.2 of this statement of basis, Region 10 expects the emission estimation
techniques listed in this statement of basis to be used to calculate the annual emissions inventory, unless
the permittee has other information showing why another technique more accurately represents emissions.
Also note that the actual emission estimates differ from the facility's PTE because actual emission are
calculated based on actual operations, not maximum operational capacity.
Note that the FARR emission inventory is required to be submitted at the same time as the Part 71 fees
and emission inventory required in Permit Conditions 3.41 through 3.45. The Part 71 and FARR emission
inventories can be combined as long as it is clear which emissions inventory is for which purpose,
because the pollutant lists for each emission inventory are slightly different.
Permit Conditions 3.47 and 3.48 require semi-annual monitoring reports and prompt deviation reports.
Determinations of deviations, continuous or intermittent compliance status, or violations of the permit are
not limited to the testing or monitoring methods required by the underlying regulations or this permit.
Failure to meet any permit term or permit condition, including emission standards, is considered a
deviation. Other credible evidence (including any evidence admissible under the federal rules of
evidence) must be considered by the source and EPA in such determinations. The timing for reporting
deviations, as well as other data collected, depends on the circumstances, as explained in these permit
conditions.
Permit Condition 3.49 requires an annual compliance certification. The permittee must certify compliance
with the permit conditions in sections 3 through 13. The permittee does not need to annually certify
compliance with the provisions in permit sections 1 or 2. Consistent with Permit Condition 2.6, however,
if a permittee is aware of any information that indicates noncompliance, that information must be
included in the annual compliance certification. In a year when the permit is renewed or revised, the
permittee must address each permit for the time that permit was in effect. Forms for the annual
compliance certifications may be obtained on the internet at https://www.epa.gov/title-v-operating-
permits/epa-issued-operating-permits.
Permit Condition 3.50 requires the permittee to certify the truth, accuracy and completeness of all
documents (notices, reports, data, and etc) submitted to EPA. The certification must be signed by a
responsible official as defined in 40 CFR 71.2. The facility's responsible officials are listed on the first
page of the permit. The permittee must request an administrative amendment of the permit if the
responsible official for the facility changes.
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Permit Conditions 3.51 and 3.52 require the permittee to submit an application for renewal and describe
some of the information that must be included in the application. As explained in Permit Conditions 2.9
through 2.11, failure to submit a complete application on time terminates the permittee's right to operate.
The expiration date of the permit is listed on the top right-hand corner of the front page of the permit. An
address for submitting the renewal application directly to Region 10's air permitting program is included
in Permit Condition 3.51.
Permit Section 4 - Facility-Specific Requirements
This permit section includes applicable requirements and related testing, monitoring, recordkeeping and
reporting that apply either to multiple emission units or on a facility-specific basis. Unless otherwise
specified, emission units are subject to the facility-specific requirements in Section 4 of the permit as well
as the general and unit-specific requirements in Sections 3, 5 and 6 of the permit.
Permit Conditions 4.1 lists the due date for the annual fees and emission reports required in Permit
Conditions 3.41 through 3.46.
Permit Condition 4.2 restricts Northwest Pipeline to combusting only natural gas in all emission units.
Permit Conditions 4.3 and 4.4 limit the sulfur content of the natural gas fuel burned in any combustion
device, specify the method for determining compliance and specify the monitoring and recordkeeping.
Permit Condition 4.5 limits the sulfur dioxide (SO2) emissions from each of the combustion devices at the
facility (four gas compressor engines, one backup generator, one boiler and one fuel heater). As these
devices are all fired on natural gas, SO2 emissions are expected to be well below the emission limit. As an
example, assuming the maximum fuel sulfur content allowed (see Permit Condition 4.3), SO2
concentration is calculated as follows:
SO2 concentration =
(max fuel S) x (SO2 conversion) x (SO2 molar volume)
(f-factor) x (fuel heat content) x SO2 molar weight)
= 0.0000856 x 2 x 385xl06 x lxlO6
13096 x 1020x64
= 77 ppmv at 7 %02
where:
max fuel S
SO2 conversion
SO2 molar volume
f-factor
fuel heat content
SO2 molar weight
conversion factor
(1.1 g/cm) / (454 g/lb) / (28.32 cf/cm) = 0.0000856 lbS/dscf, from 40
CFR 49.130
2 lbSCVlbS
385xl06 dscf/lbm
(8710) x (21%) / (21%-7%) = 13096 dscf/mmBtu at 7 %02, from 40
CFR 60, Appendix A, Method 19, Table 19-2
1020 Btu/dscf, from AP-42, Section 1.4
64 lbSCVlbm
lxlO6 parts per million parts
As shown in the calculations above, the maximum potential SO2 concentration from a combustion device,
based on the regulatory limit (40 CFR 49.130) of 1.1 grams of sulfur per dry standard cubic meter, is 77
ppmv, which is less than the FARR regulatory limit of 500 ppmv. Therefore, compliance is reasonably
assured through compliance with the fuel sulfur limit in 40 CFR 49.130. The records required to
document that natural gas is being combusted (see Permit Condition 4.4) should also assure compliance.
Permit Condition 4.6 limits the particulate matter (PM) emissions from each of the combustion devices at
the facility (four gas compressor engines, one backup generator, one boiler and one fuel heater). As these
devices are all fired on natural gas, particulate matter emissions are expected to be well below the FARR
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standard. As an example, using the worst case emission factor (EF) for any combustion unit (gas
compressors have highest EF per heat input), particulate matter concentration is calculated as follows:
PM concentration = (EF) x (conversion factor)
(f-factor)
= 0.0483x7000
13096
= 0.026 gr/dscf at 7% O2
where:
EF = 0.0483 lb/mmBtu, from Table 3.2-1, AP-42, July 2000.
conversion factor = 7000 grains/lb
f-factor = (8710) x (21 %) / (21 %-7%) = 13096 dscf/mmBtu at 7% 02, from 40
CFR 60, Appendix A, Method 19, Table 19-2
As shown in the calculations above, the maximum potential PM concentration from combustion of natural
gas is expected to be approximately 0.026 gr/dscf at 7% O2, which is much lower than the applicable
FARR regulatory limit of 0.1 gr/dscf at 7% O2. Because of this margin of compliance, additional
monitoring is not required in this permit. The records required to document that natural gas is being
combusted (see Permit Condition 4.3) should also assure compliance.
Permit Conditions 4.7 through 4.13 require a quarterly survey (also called a plant walkthrough) for visible
and fugitive emissions as well as specific follow-up steps (investigation, corrective action, RM9
observation and additional recordkeeping and reporting) if visible or fugitive emissions are observed. If
observed visible or fugitive emissions cannot be eliminated within 24 hours, a tiered sequence of RM9
opacity determinations must be performed beginning with an initial 30-minute period of readings every
15 seconds. The frequency (e.g. daily or weekly) for conducting follow-up RM9 opacity readings is based
upon whether any 6-minute average opacity exceeds 20%. Observations of visible or fugitive emissions
during a survey are not considered deviations; however, any resulting RM9 6-minute average opacity
determination above 20% is considered a permit deviation pursuant to Permit Conditions 3.47 and 3.48.
The annual fugitive particulate matter survey required in Permit Condition 3.13 can be accomplished
simultaneously with a quarterly survey required in this permit condition as long as both requirements are
fully complied with. Not every emission generating activity is a potential source of fugitive dust or visible
emissions. For example, Unit #11 (oil storage tanks) are not potential sources of fugitive dust or visible
particulate matter emissions. Permit Condition 4.7, written slightly different from previous renewal
Permit No. R10T5110100, clarifies that the plant walkthrough requirement only applies to emission
generating activities that are a potential source of fugitive dust or visible emissions.
This permit condition serves as the periodic monitoring for several fugitive and particulate matter limits
found in the permit. This requirement applies to emission sources that normally do not exhibit visible or
fugitive emissions. If the permittee prefers a specific periodic monitoring approach for any emission
sources subject to this requirement, the permittee can propose a new approach as a permit modification.
Permit Conditions 4.14 and 4.15. have been include in the permit because a December 2002 change to the
PSD regulation applicability test for modifications resulted in a new applicable requirement for PSD
major sources. In summary, when the permittee considers a plant modification project to be exempt from
PSD via the method specified in 40 CFR 52.21 (b) (41) (ii) (a) through (c) and there is a reasonable
possibility that there will be a significant emissions increase resulting from the project, then the permittee
must fulfill specified requirements related to documentation, monitoring, and notification. This
requirement will be relevant to the facility only when the permittee is contemplating making physical or
operational changes to the facility. In those instances, it is strongly recommended that the permittee
contact Region 10 to discuss their plans and verify their assumptions.
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 245 of 270
Page 24 of 27
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Permit Conditions 4.16 through 4.19 are generally applicable requirements that apply to the facility's
emission units subject to a NESHAP; emergency backup RICE (Unit #5) and the boiler and fuel gas
heater (Units #6 and 7). Permit Condition 4.17, written slightly different from previous renewal Permit
No. R10T5110100, clarifies that the on-site data retention requirement does not apply to Unit #5 pursuant
to 40 CFR 63.6665 and Table 8 to Subpart ZZZZ of Part 63.
Permit Section 5 - Unit-Specific Requirements - NESHAP Subpart ZZZZ for Unit #5 (Emergency
Generator Engine)
Permit Conditions 5.1 through 5.11 are MACT ZZZZ requirements to properly operate and maintain an
emergency stationary RICE. If the permittee does not operate the engine according to the requirements in
40 CFR 63.6640(f)(1) through (4), the engine will not be considered an emergency engine under
NESHAP Subpart ZZZZ and must meet all requirements for non-emergency engines. There is no time
limit on the use of the engine in emergency situations.
Permit Conditions 5.12 through 5.15 are MACT ZZZZ monitoring and recordkeeping requirements.
Northwest Pipeline is required to track hours of operation, and this provides Northwest Pipeline with
information useful to calculate its actual emissions.
Permit Conditions 5.16 through 5.19 are MACT ZZZZ reporting requirements. With issuance of this Title
V permit, EPA is specifying when certain MACT ZZZZ reports must be submitted.
Permit Section 6 - Unit-Specific Requirements - NESHAP Subpart DDDDD for Units #6 (Boiler)
and 7 (Process Heater)
Permit Condition 6.1 requires tune-ups of the Units #6 and 7 every five years (no later than 61 months
from previous tune-up) and specifies what must be included in the tune-ups. The date of the latest tune-up
conducted on Unit #6 is November 12, 2015. The date of the latest tune-up conducted on Unit #7 is
December 15, 2015. The next tune-up for Unit #6 and 7 shall be conducted no later than December 31,
2020 and January 31, 2021, respectively. If the unit is not operating on its scheduled tune-up due date
noted above, the tune-up must be conducted within 30 calendar days of the day it first operates after the
scheduled tune-up due date.
Permit Condition 6.2 is the general NESHAP requirement to employ good air pollution control practices
that was written specifically for boilers and process heaters subject to the major source MACT.
Permit Condition 6.3 specifies the records that must be maintained consistent with Condition 4.17.
Conditions 6.3 and 4.17 should be read together. Condition 6.3.5 clarifies that records only have to be
kept onsite for the first two of the required five years.
Permit Condition 6.4 requires annual compliance reports and describes the contents of the reports and
technique for submittal. For a tune-up completed in 2020, the associated compliance report must be
postmarked or submitted by January 31, 2021. For a tune-up completed in 2021, the associated
compliance report must be postmarked or submitted by January 31, 2022. Unlike the previous renewal
permit, this renewal requires the compliance report to contain the following information that is already
required to be recorded pursuant to 40 CFR 63.7540(a)(10)(vi):
• The concentrations of CO in the effluent stream in parts per million by volume, and
oxygen in volume percent, measured at high fire or typical operating load, before and
after the tune-up of the boiler; and
• A description of any corrective actions taken as a part of the tune-up.
Permit Condition 6.5 requires notification when switching fuels.
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 246 of 270
Page 25 of 27
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5.2 Obsolete Permit Conditions from Expiring Permit No. R10T5110100
Northwest Pipeline has satisfied several one-time NESHAP requirements since issuance of previous
renewal Permit No. R10T5110100 on September 30, 2015. The requirements are no longer relevant to the
operation of the source. In other words, the requirements are obsolete. These requirements are not being
carried forward in the proposed renewal Permit No. R10T5110200. Each obsolete permit condition from
Permit No. R10T5110100 is generally explained below.
Permit Condition 4.19 required the permittee to submit a notification of compliance status (NOCS) with
respect to NESHAP Subpart DDDDD for Units #6 and 7. The permittee fulfilled this requirement when
the EPA received Northwest Pipeline's NESHAP Subpart DDDDD NOCS on February 26, 2016. This
requirement did not apply to Unit #5 as the permittee would have already been required (if applicable) to
submit a NOCS prior to issuance of Permit No. R10T5110100 on September 30, 2015. The MACT ZZZZ
compliance date was May 3, 2013.
Permit Condition 5.16.2 required, in part, the first NESHAP ZZZZ annual report be submitted no later
than March 31, 2016. The EPA could not find a report documenting this submittal for calendar year 2015.
The agency assumes that the engine must not have operated for more than 15 hours for the purposes
specified in Permit Conditions 5.7.2 and 5.7.3.
Permit Conditions 6.1.1 and 6.1.2 required, in part, the initial tune-up of Units #6 and 7 be conducted no
later than January 31, 2016 (or not later than 30 days after re-start of that unit if not operated between
January 31, 2013 and January 31, 2016). The permittee provided evidence of having satisfied this
requirement in a NESHAP Subpart DDDDD NOCS received on February 26, 2016.Permit Condition 6.2
required the permittee to conduct a one-time energy assessment of Units #6 and 7 (and major energy use
systems consuming energy from the units) no later than January 31, 2016. The permittee provided
evidence of having satisfied this requirement in a NESHAP Subpart DDDDD NOCS received on
February 26, 2016. According to the NOCS, Sage Environmental Consulting was contracted to conduct
the Energy Assessment and transmitted the energy assessment to Northwest Pipeline on September 9,
2015.
Permit Condition 6.5 required the permittee to submit a NESHAP Subpart DDDDD NOCS for Units #6
and 7. As stated above, EPA received from the permittee a NESHAP Subpart DDDDD NOCS on
February 26, 2016.
Permit Condition 6.6.1 required the permittee to submit the first NESHAP Subpart DDDDD annual
compliance report covering the time period of January 31, 2016 to December 31, 2016. This first report
was due on January 31, 2017. The permittee submitted this report on January 31, 2020. According to the
permittee, there were no deviations from the requirements for work practice standards during the reported
period.
6. Public Participation
6.1 Public Notice and Comment
As required in 40 CFR 71.11(a)(5) and 71.8, all draft operating permits must be publicly noticed and
made available for public comment. The public notice of permit actions and public comment period is
described in 40 CFR 71.11(d). There is a 30 day public comment period for actions pertaining to a draft
permit. For this permit action, the requirements of 40 CFR 71.11 (a) (5) and 71.8 will be satisfied as
follows:
1. Posting the public notice, draft permit, statement of basis and the draft administrative record
(which includes the application and relevant supporting materials) on EPA's website for the
duration of the public comment period.
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 247 of 270
Page 26 of 27
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2. Providing a copy of the public notice to: the permit applicant, the affected states, the air pollution
control agencies of affected states, the Tribal, city and county executives, any comprehensive
land use planning agency, any state or federal land manager whose lands may be affected by
emissions from the source, the local emergency planning authorities which have jurisdiction over
the area where the source is located and all persons who submitted a written request to be
included on the EPA's mailing list for Title V permitting actions.
6.2 Response to Public Comments and Permit Issuance
As required in 40 CFR 71.11 (e), the EPA will consider all timely comments received when making a final
decision. The EPA's response to any comments received during the public comment period or public
hearing held for this permit will be addressed in this section of the final statement of basis. As required in
40 CFR 71.11 (i), the EPA will notify the applicant and each person who submits comments or requested
notice of the final permit decision.
Northwest Pipeline - Pocatello Compressor Station
Title V Permit No. R10T5110200 Statement of Basis
Page 248 of 270
Page 27 of 27
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Appendix A
EPA Estimation of Northwest Pipeline
Pocatello Compressor Station
Potential Air Pollutant Emissions
Statement of Basis
Title V Air Quality Operating Permit Renewal #2
R10T5110200
Pocatello, Idaho
Page 249 of 270
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Appendix A: Potential Emissions Inventory
Summary of Facility Non-HAP Potential Emissions
Non-Fugitive Emissions1 (tons per year)
EU-1.2&3
ELM
EU-5
EU-6
EU-7
EU-8
EU-9
EU-10
EU-11
Non-
Fugitive
Subtotal
Three Clark
TLA-6 RICE
Clark TCV-10
RICE
Caterpillar
3408 RICE
Backup
Generator
Sellers Boiler
Sivallis Fuel
Gas Heater
Heaters and
Furnaces
System
Blowdown
Gas
Equipment
Leaks
Liquid Storage
Tanks
Carbon Monoxide (CO)
67.3
33.0
3.5
1.3
0.2
0.4
106
Hydrogen Sulfide (H2S)
0.01
0
Lead (Pb)
9.5E-05
4.7E-05
4.6E-07
7.5E-06
1.1E-06
2.5E-06
8.8E-08
0
Nitrogen Oxides (NOx)
730.0
357.5
2.1
1.5
0.2
0.5
1,092
Particulate (PM)2
7.5
3.7
0.01
0.03
0.004
0.01
11
Inhalable Coarse Particulate (PM10)
9.4
4.5
0.02
0.1
0.02
0.04
14
Fine Particulate (PM2 5)
9.4
4.5
0.02
0.1
0.02
0.04
14
Sulfur Dioxide (S02)
10.6
5.2
0.1
0.8
0.1
0.3
17
Volatile Organic Compounds (VOC)
21.8
10.7
0.03
0.1
0.01
0.03
0.2
0.4
33
Greenhouse Gas (C02e)
22,772
11,152
110
1,803
256
605
178
36,876
Fugitive Emissions, (tons per year)
EU-1.2&3
ELM
EU-5
EU-6
EU-7
EU-8
EU-9
EU-10
EU-11
Fugitive
Subtotal
Three Clark
TLA-6 RICE
Clark TCV-10
RICE
Caterpillar
3408 RICE
Backup
Generator
Sellers Boiler
Sivallis Fuel
Gas Heater
Heaters and
Furnaces
System
Blowdown
Gas
Equipment
Leaks
Liquid Storage
Tanks
Carbon Monoxide (CO)
0
Hydrogen Sulfide (H2S)
0.01
0
Lead (Pb)
8.8E-08
0
Nitrogen Oxides (NOx)
0
Particulate (PM)2
0
Inhalable Coarse Particulate (PM10)
0
Fine Particulate (PM2 5)
0
Sulfur Dioxide (S02)
0
Volatile Organic Compounds (VOC)
0.2
0
Greenhouse Gas (C02e)
178
178
Total Non-Fugitive and Fugitive Emissions, (tons per year)
EU-1.2&3
ELM
EU-5
EU-6
EU-7
EU-8
EU-9
EU-10
EU-11
Plantwide
PTE
Three Clark
TLA-6 RICE
Clark TCV-10
RICE
Caterpillar
3408 RICE
Backup
Generator
Sellers Boiler
Sivallis Fuel
Gas Heater
Heaters and
Furnaces
System
Blowdown
Gas
Equipment
Leaks
Liquid Storage
Tanks
Carbon Monoxide (CO)
67.3
33.0
3.5
1.3
0.2
0.4
106
Hydrogen Sulfide (H2S)
0.01
0.01
0
Lead (Pb)
9.5E-05
4.7E-05
4.6E-07
7.5E-06
1.1E-06
2.5E-06
8.8E-08
8.8E-08
0
Nitrogen Oxides (NOx)
730.0
357.5
2.1
1.5
0.2
0.5
1,092
Particulate (PM)2
7.5
3.7
0.01
0.03
0.004
0.01
11
Inhalable Coarse Particulate (PM10)
9.4
4.5
0.02
0.1
0.02
0.04
14
Fine Particulate (PM2 5)
9.4
4.5
0.02
0.1
0.02
0.04
14
Sulfur Dioxide (S02)
10.6
5.2
0.1
0.8
0.1
0.3
17
Volatile Organic Compounds (VOC)
21.8
10.7
0.03
0.1
0.01
0.03
0.2
0.2
0.4
33
Greenhouse Gas (C02e)
22,772
11,152
110
1,803
256
605
178
178
37,054
Notes:
1 Only non-fugitive emissions are considered for this facility in determining Title V applicability given that it is a natural gas compressor station and not one of the 27 listed source categories
required to consider fugitive emissions. See definition of "major source" at 40 CFR § 71.2.
2 PM is not a pollutant considered in determining whether a source is subject to the requirement to obtain a Title V permit; however, PM emissions are considered in determining whether a
facility/project is a major PSD source/modification and whether a source is subject to compliance assurance monitoring.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 250 of 270
Page A-2 of A-18
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Appendix A: Potential Emissions Inventory
Summary of Facility HAP Potential to Emit
Total Non-Fugitive and Fugitive Emissions, (tons per year)
EU-1.2&3
EU-4
EU-5
EU-6
EU-7
EU-8
EU-9
EU-10
EU-11
Hazardous Air Pollutants (HAP)
Three Clark TLA-6
RICE
One Clark TCV-10
RICE
One Caterpillar
3408 RICE
Backup Generator
Sellers Boiler
Sivallis Fuel
Gas Heater
Heaters and
Furnaces
System
Blowdown Gas
Equipment
Leaks
Liquid Storage
Tanks
Single HAP
Plantwide Totals
Trace Metal Compounds
Arsenic Compounds
3.81 E-05
1.87E-05
1.84E-07
3.02E-06
4.29E-07
1.01 E-06
6.1 E-05
Beryllium Compounds
2.29E-06
1.12E-06
1.11 E-08
1.81E-07
2.58E-08
6.08E-08
3.7E-06
Cadmium Compounds
2.10E-04
1.03E-04
1.01 E-06
1.66E-05
2.36E-06
5.57E-06
3.4E-04
Chromium Compounds (including hexavalent)
2.67E-04
1.31 E-04
1.29E-06
2.11 E-05
3.01 E-06
7.09E-06
4.3E-04
Cobalt Compounds
1.60E-05
7.84E-06
7.74E-08
1.27E-06
1.80E-07
4.25E-07
2.6E-05
Manganese Compounds
7.25E-05
3.55E-05
3.50E-07
5.74E-06
8.16E-07
1.92E-06
1.2E-04
Mercury Compounds
4.96E-05
2.43E-05
2.40E-07
3.92E-06
5.58E-07
1.32E-06
8.0E-05
Nickel Compounds
4.00E-04
1.96E-04
1.94E-06
3.17E-05
4.51 E-06
1.06E-05
6.5E-04
Selenium Compounds
4.58E-06
2.24E-06
2.21 E-08
3.62E-07
5.15E-08
1.22E-07
7.4E-06
Organic Compounds
1,1,2,2-Tetrachlorethane
1.29E-02
6.31 E-03
2.38E-05
1.9E-02
1,1,2-Trichloroethane
1.02E-02
5.02E-03
1.44E-04
1.5E-02
1,3-Butadiene
1.59E-01
7.81 E-02
6.23E-04
2.4E-01
1,3-Dichloropropene
8.52E-02
4.17E-02
1.19E-05
1.3E-01
2,2,4-Trimethylpentane
1.65E-01
8.06E-02
2.5E-01
Acetaldehyde
1.51E+00
7.39E-01
2.62E-03
2.3E+00
Acrolein
1.51E+00
7.41 E-01
2.47E-03
2.3E+00
Benzene
3.77E-01
1.85E-01
1.49E-03
3.17E-05
4.51 E-06
1.06E-05
5.6E-01
Biphenyl
7.68E-04
3.76E-04
1.1 E-03
Carbon Tetrachloride
1.18E-02
5.78E-03
1.66E-05
1.8E-02
Chlorobenzene
8.63E-03
4.23E-03
1.21 E-05
1.3E-02
Chloroform
9.16E-03
4.49E-03
1.29E-05
1.4E-02
Dichlorobenzene
1.81 E-05
2.58E-06
6.08E-06
2.7E-05
Ethylbenzene
2.10E-02
1.03E-02
2.33E-05
3.1 E-02
Ethylene Dibromide
1.43E-02
6.99E-03
2.00E-05
2.1 E-02
Formaldehyde
1.07E+01
5.26E+00
1.93E-02
1.13E-03
1.61 E-04
3.80E-04
1.6E+01
Methanol
4.82E-01
2.36E-01
2.88E-03
7.2E-01
Methylene Chloride
2.86E-02
1.40E-02
3.87E-05
4.3E-02
n-Hexane
8.65E-02
4.24E-02
1.13E-03
1.61 E-04
9.11 E-03
5.58E-03
5.58E-03
1.5E-01
Naphthalene1
1.87E-02
9.17E-03
9.13E-05
9.21 E-06
1.31 E-06
3.09E-06
2.8E-02
Phenol
8.19E-03
4.01 E-03
1.2E-02
Polycyclic Organic Matter (POM)2
6.28E-02
3.07E-02
1.33E-04
1.05E-05
1.50E-06
3.54E-06
9.4E-02
Styrene
1.07E-02
5.22E-03
1.12E-05
1.6E-02
Toluene
1.87E-01
9.17E-02
5.25E-04
5.13E-05
7.30E-06
1.72E-05
2.8E-01
Vinyl Chloride
4.80E-03
2.35E-03
6.75E-06
7.2E-03
Xylene
5.21 E-02
2.55E-02
1.83E-04
7.8E-02
TOTAL2
15.6
7.6
0.03
0.002
0.0003
0.01
0.01
0.01
0
Predicted Highest Plantwide Single HAP
Predicted Plantwide HAP Total
16.0
23.2
tons per year, formaldehyde
tons per year, based on summing estimates
1 designates a HAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds that, in aggregate, are subject to the same 10 tpy major source
threshold.
2 Because naphthalene is accounted for individually and in the calculation of POM EF, its individual contribution here is discounted so as to avoid double-counting.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 251 of 270
Page A-3 of A-18
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Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Emission Unit
Description
Control Device
Fuel
Installation Date
Design Maximum Output Capacity
Design Maximum Heat Input Capcity
Operation
NON-FUGITIVE EMISSIONS
EU-1, 2 and 3
Clark TLA-6 Reciprocating IC Compressor Engines, two-stroke, lean-burn, spark ignition
none
natural gas
1956
2,000 horsepower at 300 rpm
14.8 MMBtu/hr
8760 hours per year
Per Engine
All Three Engines
Criteria Pollutant Emissions
EF
PTE
PTE
EF Reference
(Ib/MMBtu)
(tPY)
(tPY)
Carbon Monoxide (CO)
0.346
22.4
67.3
1
Lead (Pb)
4.90E-07
0.00003
0.0001
2
Nitrogen Oxides (NOx)
3.754
243.3
730.0
1
Particulate (PM)
0.0384
2.5
7.5
3
Inhalable Coarse Particulate (PM10)
0.0483
3.1
9.4
3
Fine Particulate (PM2 5)
0.0483
3.1
9.4
3
Sulfur Dioxide (S02)
0.0544
3.5
10.6
4
Volatile Organic Compounds (VOC)
0.112
7.3
21.8
1
NON-FUGITIVE EMISSIONS
Per Engine
All Three Engines
Greenhouse Gas Emissions
(C02 Equivalent)
EF
(Ib/MMBtu)
PTE
(tpy)
PTE
(tpy)
EF Reference
Carbon Dioxide (C02)
116.977
7582.9
22748.8
5
Methane (CFI4)
0.055
3.6
10.7
5
Nitrous Oxide (N20)
0.066
4.3
12.8
5
TOTAL
7,591
22,772
EF Reference
Description
1
EU-1 performance test conducted June 11, 1998 at full load (~100%) and reduced load (~85%). Emission factors employed in this PTE El are worst-case (i.e. NOx
and VOC at full load and CO at reduced load.
2
Table 1.4-2 of AP-42, July 1998. EF (Ib/MMBtu) = (0.0005 lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
3
Table 3.2-1 of AP-42, July 2000. Filterable PM (< 1nm) = 3.84x10"2 Ib/MMBtu. Condensible PM ~ 9.91x103 Ib/MMBtu. PM EF equal to filterable portion. PM10 and
PM2 5 EF equal to sum of both; 0.0483 Ib/MMBtu. EPA did not employ the applicable FARR PM limit to calculate potential emissions because the resultant 0.1871
Ib/MMBtu PM EF is unrealistic for a natural gas fired engine. The calculation to derive the 0.1871 Ib/MMBtu PM EF is as follows:
Basis: FARR combustion source stack PM emission limit of 0.1 gr/dscf corrected to 7% 02 at 40 CFR 49.125(d)(1)
EF (Ib/MMBtu) = FARR PM Limit (gr/dscf@7%02) X CF7_^%02 X Fd (dscf/MMBtu) / CFgr^lb (gr/lb)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR PM
Calculated EF
(Ib/MMBtu)
FARR PM
Emission Limit
(gr/dscf @7%02)
CF 7—>0%O2
(unitless)
Fd
(dscf/MMBtu)
CF gr^|b
(gr/lb)
0.1871
0.1
1.504
8,710
7,000
Option 1: 0.0544 Ib/MMBtu. This emission factor is employed to determine PTE as it limits emissions to less than Option 2 or 3 below.
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (Ib/MMBtu) = Pipeline tariff S Limit (gr/100 ft3) / CF100ft3^Btu X CFBtu^MMBtu / CFgr^,b X CFS^S02
• CFS^S02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 105000 Btu/100 ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
Pipeline Tariff
Calculate S02 EF
(Ib/MMBtu)
Pipeline Tariff
Fuel Sulfur Limit
(qr/100 ft3)
CFft3^Btu
(Btu/100 ft3)
CF BtU_>MMBtu
(Btu/MMBtu)
CFgr^|b
(gr/lb)
CFs^so2
(lb S02/lb S)
0.0544
20
105000
1.E+06
7000
2
Option 2: 0.1308 Ib/MMBtu.
Basis: FARR gaseous fuel sulfur limit of 1.1 g/dry standard cubic meter at 40 CFR 49.130(d)(8)
EF (Ib/MMBtu) = FARR Fuel S Limit (g/m ) / CFm3_»ft3 / CFft3_>Btu X CFBtu->MMBtu! CFg_,.ib X CFs->so2
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 1050 Btu/ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
4
FARR Fuel S
Calculate S02 EF
(Ib/MMBtu)
FARR
Fuel Sulfur Limit
(g/rri3)
CF m3_>ft3
(ft3/m3)
CFft3^Btu
(Btu/ft3)
CFgtu—»MMBtu
(Btu/MMBtu)
CF g—b
(g/lb)
CF S—»S02
^iu JU2/IU
OA
0.1308
1.1
35.3147
1050
1.E+06
453.592
2
Option 3: 1.087 Ib/MMBtu.
Basis: FARR combustion source stack S02 emission limit of 500 parts per million by volume dry basis (ppmvd) corrected to 7% 02 at 40 CFR 49.129(d)(1)
EF (Ib/MMBtu) = FARR S02 Limit (ppmvd@7%02) X CF7^o»A02 X CFpprTW|b/dscfS02 X Fd (dscf/MMBtu)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• CFpprTW|b/dscfSo2 = 1 -660 X 10"7 lb S02/dscf / ppm S02. See Table 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR 500 ppm
Calculate S02 EF
(Ib/MMBtu)
FARR
JU2 L_l 1 IIS^IUI 1
1 im it
(ppmvd@7%02)
CF 7_>0%O2
(unitless)
C F ppm^| b/dscfS02
(lb/dscf / ppm)
Fd
(dscf/MMBtu)
1.087
500
1.504
1.66E-07
8710
EPA's March 2011 guidance document "PSD and Title V Permitting Guidance for Greenhouse Gases" states that the GFIG Report Rule (40 CFR 98), "should be
considered a primary reference for sources and permitting authorities in estimating GFIG emissions and establishing measurement techniques when preparing or
processing permit applications." Therefore, GFIG Reporting Rule emission factors will be employed to determine GFIG PTE.
Carbon Dioxide (CO?)
EF (lb C02e/MMBtu) = EF (kg C02/MMBtu) X CFkg^lb (lb/kg) X GWPC02 (lb C02e/lb C02)
Calculated C02e
EF for C02
(lb C02e/MMBtu)
40 CFR 98
Table C-1 EF
(kg C02/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb C02)
116.977
53.06
2.20462262
1
5
Methane (CFL)
EF (lb C02e/MMBtu) = EF (kg CH4/MMBtu) X CFkg^lb (lb/kg) X GWPCH4 (lb C02e/lb CH4)
Calculated C02e
E F for C Fl4
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg CH4/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb CH4)
0.055
0.001
2.20462262
25
Nitrous Oxide (N?0)
EF (lb C02e/MMBtu) = EF (kg N20/MMBtu) X CFkg^lb (lb/kg) X GWPN20 (lb C02e/lb N20)
Calculated C02e
EFfor N20
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg N20/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb N20)
0.066
0.0001
2.20462262
298
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 252 of 270
Page A-4 of A-18
-------
Appendix A: Potential Emissions Inventory
HAP Potential to Emit
Emission Unit: EU-1, 2 and 3
Description: Clark TLA-6 Reciprocating IC Compressor Engines, two-stroke, lean-burn, spark ignition
Control Device: none
Fuel: natural gas
Installation Date: 1956
Design Maximum Output Capacity: 2,000 horsepower at 300 rpm
Design Maximum Heat Input Capcity: 14.8 MMBtu/hr
Operation: 8760 hours per year
NON-FUGITIVE EMISSIONS
Per Engine
All Three Engines
Criteria Pollutant Emissions
EF
EF
PTE
PTE
(lb/1 x106 scf)
(Ib/MMBtu)
(tpy)
(tpy)
Trace Metal Compounds
Arsenic Compounds
2.0E-04
2.0E-07
1.27E-05
3.81 E-05
Beryllium Compounds
1.2E-05
1.2E-08
7.63E-07
2.29E-06
Cadmium Compounds
1.1E-03
1.1E-06
6.99E-05
2.10E-04
Chromium Compounds (including hexavalent)
1.4E-03
1.4E-06
8.90E-05
2.67E-04
Cobalt Compounds
8.4E-05
8.2E-08
5.34E-06
1.60E-05
Manganese Compounds
3.8E-04
3.7E-07
2.42E-05
7.25E-05
Mercury Compounds
2.6E-04
2.5E-07
1.65E-05
4.96E-05
Nickel Compounds
2.1E-03
2.1E-06
1.33E-04
4.00E-04
Selenium Compounds
2.4E-05
2.4E-08
1.53E-06
4.58E-06
Organic Compounds
1,1,2,2-Tetrachlorethane
6.63E-05
4.30E-03
1.29E-02
1,1,2-Trichloroethane
5.27E-05
3.42E-03
1.02E-02
1,3-Butadiene
8.20E-04
5.32E-02
1.59E-01
1,3-Dichloropropene
4.38E-04
2.84E-02
8.52E-02
2,2,4-Trimethylpentane
8.46E-04
5.48E-02
1.65E-01
Acetaldehyde
7.76E-03
5.03E-01
1.51E+00
Acrolein
7.78E-03
5.04E-01
1.51E+00
Benzene
1.94E-03
1.26E-01
3.77E-01
Biphenyl
3.95E-06
2.56E-04
7.68E-04
Carbon Tetrachloride
6.07E-05
3.93E-03
1.18E-02
Chlorobenzene
0)
4.44E-05
2.88E-03
8.63E-03
Chloroform
CO
0
4.71 E-05
3.05E-03
9.16E-03
Ethyl benzene
CL
CL
1.08E-04
7.00E-03
2.10E-02
Ethylene Dibromide
<
7.34E-05
4.76E-03
1.43E-02
Formaldehyde
-z.
5.52E-02
3.58E+00
1.07E+01
Methanol
2.48E-03
1.61E-01
4.82E-01
Methylene Chloride
1.47E-04
9.53E-03
2.86E-02
n-Hexane
4.45E-04
2.88E-02
8.65E-02
Naphthalene1
9.63E-05
6.24E-03
1.87E-02
Phenol
4.21 E-05
2.73E-03
8.19E-03
Polycyclic Organic Matter (POM)2
3.23E-04
2.09E-02
6.28E-02
Styrene
5.48E-05
3.55E-03
1.07E-02
Toluene
9.63E-04
6.24E-02
1.87E-01
Vinyl Chloride
2.47E-05
1.60E-03
4.80E-03
Xylene
2.68E-04
1.74E-02
5.21 E-02
TOTAL3 8.00E-02 5.2 15.6
1 Naphthalene is a HAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds
that, in aggregate, are subject to the same 10 tpy major source threshold.
2 See table below for list of individual polycyclic organic matter (POM) compounds. POM defines a broad class of compounds that generally includes all organic
structures having two or more fused aromatic rings (i.e., rings that share a common border), and that have a boiling point greater than or equal to 212°F (100°C).
See http://www.epa.g0v/ttn/atw/hlthef/polycycl.html#refl 1
3 Because naphthalene is accounted for individually and in the calculation of POM EF, its contribution here is discounted so as to avoid double-counting.
Trace Metal Compounds EF Basis: AP-42. Table 1.4-4. July 1998.
EF (Ib/MMBtu) = EF (Ib/1x106scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-4.
Or^ani£^om|3ounds=EF=Basisi^P=42Jable=^i2=2i=Jul^000i
POM Compoiilids
I I
(Ib/MMI'lu)
2-Methylnaphthalene
2.14E-04
Acenaphthene*
1.33E-06
Acenaphthylene*
3.17E-06
Anthracene*
7.18E-07
Benzo(a)anthracene*
3.36E-07
Benzo(a)pyrene*
5.68E-09
Benzo(b)fluoranthene*
8.51 E-09
Benzo(e)pyrene*
2.34E-08
Benzo(g,h,l)perylene*
2.48E-08
Benzo(k)fluoranthene*
4.26E-09
Chrysene*
6.72E-07
Fluoranthene*
3.61 E-07
Fluorene*
1.69E-06
lndeno(1,2,3-cd)pyrene*
9.93E-09
Naphthalene***
9.63E-05
Perylene
4.97E-09
Phenanthrene*
3.53E-06
Pyrene
5.84E-07
SUBTOTAL
3.23E-04
* designates a polycyclic aromatic hydrocarbon (PAH). PAHs are potent atmospheric pollutants that consist of fused aromatic rings and do not contain heteroatoms
or carry substituents. See http://en.wikipedia.Org/wiki/Polycyclic_aromatic_hydrocarbon#PAH_compounds
** designates a POM compound that is also an individual HAP.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 253 of 270
Page A-5 of A-18
-------
Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Emission Unit
Description
Control Device
Fuel
Installation Date
Design Maximum Output Capacity
Design Maximum Heat Input Capcity
Operation
NON-FUGITIVE EMISSIONS
EU-4
Clark TCV-10 Reciprocating IC Compressor Engines, two-stroke, lean-burn, spark ignition
none
natural gas
1969
3,400 horsepower at 300 rpm
21.743 MMBtu/hr
8760 hours per year
Criteria Pollutant Emissions
EF
(Ib/MMBtu)
PTE
(tPY)
EF Reference
Carbon Monoxide (CO)
0.346
33.0
1
Lead (Pb)
4.90E-07
0.00005
2
Nitrogen Oxides (NOx)
3.754
357.5
1
Particulate (PM)
0.0384
3.7
3
Inhalable Coarse Particulate (PM10)
0.0475
4.5
3
Fine Particulate (PM2 5)
0.0475
4.5
3
Sulfur Dioxide (S02)
0.0544
5.2
4
Volatile Organic Compounds (VOC)
0.112
10.7
1
NON-FUGITIVE EMISSIONS
Greenhouse Gas Emissions
(C02 Equivalent)
EF
(Ib/MMBtu)
PTE
(tpy)
EF Reference
Carbon Dioxide (C02)
116.977
11140.3
5
Methane (CFI4)
0.055
5.2
5
Nitrous Oxide (N20)
0.066
6.3
5
TOTAL
11,152
EF Reference
Description
1
EU-1 performance test conducted June 11, 1998 at full load (~100%) and reduced load (~85%). Emission factors employed in this PTE El are worst-case (i.e. NOx
and VOC at full load and CO at reduced load.
2
Table 1.4-2 of AP-42, July 1998. EF (Ib/MMBtu) = (0.0005 lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
3
Table 3.2-1 of AP-42, July 2000. Filterable PM (< 1nm) = 3.84x10"2 Ib/MMBtu. Condensible PM ~ 9.91x103 Ib/MMBtu. PM EF equal to filterable portion. PM10 and
PM2 5 EF equal to sum of both; 0.0483 Ib/MMBtu. EPA did not employ the applicable FARR PM limit to calculate potential emissions because the resultant 0.1871
Ib/MMBtu PM EF is unrealistic for a natural gas fired engine. The calculation to derive the 0.1871 Ib/MMBtu PM EF is as follows:
Basis: FARR combustion source stack PM emission limit of 0.1 gr/dscf corrected to 7% 02 at 40 CFR 49.125(d)(1)
EF (Ib/MMBtu) = FARR PM Limit (gr/dscf@7%02) X CF7_^%02 X Fd (dscf/MMBtu) / CFgr^lb (gr/lb)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR PM
Calculated EF
(Ib/MMBtu)
FARR PM
Emission Limit
(gr/dscf @7%02)
CF 7—>0%O2
(unitless)
Fd
(dscf/MMBtu)
CFgr^|b
(gr/lb)
0.1871
0.1
1.504
8,710
7,000
Option 1: 0.0544 Ib/MMBtu. This emission factor is employed to determine PTE as it limits emissions to less than Option 2 or 3 below.
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (Ib/MMBtu) = Pipeline tariff S Limit (gr/100 ft3) / CF100ft3^Btu X CFBtu^MMBtu / CFgr^,b X CFS^S02
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 105000 Btu/100 ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
Pipeline Tariff
Calculate S02 EF
(Ib/MMBtu)
Pipeline Tariff
Fuel Sulfur Limit
(qr/100 ft3)
CFft3^Btu
(Btu/100 ft3)
CFgtu->MMBtu
(Btu/MMBtu)
CFgr_>|b
(gr/lb)
CF S—»S02
(lb S02/lb S)
0.0544
20
105000
1.E+06
7000
2
Option 2: 0.1308 Ib/MMBtu.
Basis: FARR gaseous fuel sulfur limit of 1.1 g/dry standard cubic meter at 40 CFR 49.130(d)(8)
EF (Ib/MMBtu) = FARR Fuel S Limit (g/m ) / CFm3_»ft3 / CFft3_>Btu X CFBtu->MMBtu! CFg_,.ib X CFs->so2
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFft3^Btu = 1050 Btu/ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
4
FARR Fuel S
Calculate S02 EF
(Ib/MMBtu)
FARR
Fuel Sulfur Limit
(q/rri3)
CF m3_>ft3
(ft3/m3)
CFfo^etu
(Btu/ft3)
CF[3tu—>MMBtu
(Btu/MMBtu)
CFg^|b
(g/ib)
CFs^so2
(ju 0U2HU
C-N
0.1308
1.1
35.3147
1050
1.E+06
453.592
2
Option 3: 1.087 Ib/MMBtu.
Basis: FARR combustion source stack S02 emission limit of 500 parts per million by volume dry basis (ppmvd) corrected to 7% 02 at 40 CFR 49.129(d)(1)
EF (Ib/MMBtu) = FARR S02 Limit (ppmvd@7%02) X CF7^0%02 X CFpprTW|b/dscfSo2 X Fd (dscf/MMBtu)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
Xo2Fd = 0 ar|d X02farr = 7- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• CFpprTW|b/dscfSo2 = 1 -660 X 10"7 lb S02/dscf / ppm S02. See Table 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR 500 ppm
Calculate S02 EF
(Ib/MMBtu)
FARR
1— 1 1 1 I^OIWI 1
1 IfV* it
(ppmvd@7%02)
CF 7—»0%O2
(unitless)
C Fppm^i b/dscfS02
(lb/dscf / ppm)
Fd
(dscf/MMBtu)
1.087
500
1.504
1.66E-07
8710
EPA's March 2011 guidance document "PSD and Title V Permitting Guidance for Greenhouse Gases" states that the GFIG Report Rule (40 CFR 98), "should be
considered a primary reference for sources and permitting authorities in estimating GFIG emissions and establishing measurement techniques when preparing or
processing permit applications." Therefore, GFIG Reporting Rule emission factors will be employed to determine GFIG PTE.
Carbon Dioxide (CO-?)
EF (lb C02e/MMBtu) = EF (kg C02/MMBtu) X CFkg^lb (lb/kg) X GWPC02 (lb C02e/lb C02)
Calculated C02e
EF for C02
(lb C02e/MMBtu)
40 CFR 98
Table C-1 EF
(kg C02/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb C02)
116.977
53.06
2.20462262
1
5
Methane (CFL)
EF (lb C02e/MMBtu) = EF (kg CH4/MMBtu) X CFkg^lb (lb/kg) X GWPCH4 (lb C02e/lb CH4)
Calculated C02e
E F for C Fl4
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg CH4/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb CH4)
0.055
0.001
2.20462262
25
Nitrous Oxide (N?0)
EF (lb C02e/MMBtu) = EF (kg N20/MMBtu) X CFkg^lb (lb/kg) X GWPN20 (lb C02e/lb N20)
Calculated C02e
EFfor N20
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg N20/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb N20)
0.066
0.0001
2.20462262
298
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 254 of 270
Page A-6 of A-18
-------
Appendix A: Potential Emissions Inventory
HAP Potential to Emit
EU-4
Clark TCV-10 Reciprocating IC Compressor Engines, two-stroke, lean-burn, spark ignition
none
natural gas
1969
3,400 horsepower at 300 rpm
21.743 MMBtu/hr
8760 hours per year
NON-FUGITIVE EMISSIONS
Emission Unit:
Description:
Control Device:
Fuel:
Installation Date:
Design Maximum Output Capacity:
Design Maximum Heat Input Capcity:
Operation:
Criteria Pollutant Emissions
EF
(lb/1 x106 scf)
EF
(Ib/MMBtu)
PTE
(tpy)
Trace Metal Compounds
Arsenic Compounds
2.0E-04
2.0E-07
1.87E-05
Beryllium Compounds
1.2E-05
1.2E-08
1.12E-06
Cadmium Compounds
1.1 E-03
1.1E-06
1.03E-04
Chromium Compounds (including hexavalent)
1.4E-03
1.4E-06
1.31E-04
Cobalt Compounds
8.4E-05
8.2E-08
7.84E-06
Manganese Compounds
3.8E-04
3.7E-07
3.55E-05
Mercury Compounds
2.6E-04
2.5E-07
2.43E-05
Nickel Compounds
2.1 E-03
2.1E-06
1.96E-04
Selenium Compounds
2.4E-05
2.4E-08
2.24E-06
Organic Compounds
1,1,2,2-Tetrachlorethane
6.63E-05
6.31 E-03
1,1,2-Trichloroethane
5.27E-05
5.02E-03
1,3-Butadiene
8.20E-04
7.81 E-02
1,3-Dichloropropene
4.38E-04
4.17E-02
2,2,4-Trimethylpentane
8.46E-04
8.06E-02
Acetaldehyde
7.76E-03
7.39E-01
Acrolein
7.78E-03
7.41 E-01
Benzene
1.94E-03
1.85E-01
Biphenyl
3.95E-06
3.76E-04
Carbon Tetrachloride
6.07E-05
5.78E-03
Chlorobenzene
0)
4.44E-05
4.23E-03
Chloroform
CO
0
4.71 E-05
4.49E-03
Ethyl benzene
"q.
CL
1.08E-04
1.03E-02
Ethylene Dibromide
<
7.34E-05
6.99E-03
Formaldehyde
-Z.
5.52E-02
5.26E+00
Methanol
2.48E-03
2.36E-01
Methylene Chloride
1.47E-04
1.40E-02
n-Hexane
4.45E-04
4.24E-02
Naphthalene1
9.63E-05
9.17E-03
Phenol
4.21 E-05
4.01 E-03
Polycyclic Organic Matter (POM)2
3.23E-04
3.07E-02
Styrene
5.48E-05
5.22E-03
Toluene
9.63E-04
9.17E-02
Vinyl Chloride
2.47E-05
2.35E-03
Xylene
2.68E-04
2.55E-02
TOTAL3 8.00E-02 7.6
1 Naphthalene is a HAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds
that, in aggregate, are subject to the same 10 tpy major source threshold.
2 See table below for list of individual polycyclic organic matter (POM) compounds. POM defines a broad class of compounds that generally includes all organic
structures having two or more fused aromatic rings (i.e., rings that share a common border), and that have a boiling point greater than or equal to 212°F (100°C).
See http://www.epa.g0v/ttn/atw/hlthef/polycycl.html#refl 1
3 Because naphthalene is accounted for individually and in the calculation of POM EF, its contribution here is discounted so as to avoid double-counting.
Trace Metal Compounds EF Basis: AP-42. Table 1.4-4. July 1998.
EF (Ib/MMBtu) = EF (Ib/1x106scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-4.
Onuinic Compounds TT B;isis: AP 42. T;il>lo 3.2 1. Inly 2000.
POM Compounds
I I
(Ib/MMI'lu)
2-Methylnaphthalene
2.14E-04
Acenaphthene*
1.33E-06
Acenaphthylene*
3.17E-06
Anthracene*
7.18E-07
Benzo(a)anthracene*
3.36E-07
Benzo(a)pyrene*
5.68E-09
Benzo(b)fluoranthene*
8.51 E-09
Benzo(e)pyrene*
2.34E-08
Benzo(g,h,l)perylene*
2.48E-08
Benzo(k)fluoranthene*
4.26E-09
Chrysene*
6.72E-07
Fluoranthene*
3.61 E-07
Fluorene*
1.69E-06
lndeno(1,2,3-cd)pyrene*
9.93E-09
Naphthalene***
9.63E-05
Perylene
4.97E-09
Phenanthrene*
3.53E-06
Pyrene
5.84E-07
SUBTOTAL
3.23E-04
EF Basis: AP-42, Table 3.2-1, July 2000.
* designates a polycyclic aromatic hydrocarbon (PAH). PAHs are potent atmospheric pollutants that consist of fused aromatic rings and do not contain heteroatoms
or carry substituents. See http://en.wikipedia.Org/wiki/Polycyclic_aromatic_hydrocarbon#PAH_compounds
** designates a POM compound that is also an individual HAP.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 255 of 270
Page A-7 of A-18
-------
Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Control Device
Fuel
Installation Date
Design Maximum Output Capacity
Design Maximum Heat Input Capcity
Operation
Emission Unit: EU-5
Description: Caterpillar 3408 Backup Electrical Power Generator
Reciprocating IC Compressor Engine, four-stroke, rich-burn, spark ignition
none
natural gas
1998
400 horsepower
3.76 MMBtu/hr
500 hours per year1
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(Ib/MMBtu)
PTE
(tPV)
EF Reference
Carbon Monoxide (CO)
3.72
3.5
1
Lead (Pb)
4.90E-07
4.61 E-07
2
Nitrogen Oxides (NOx)
2.27
2.1
1
Particulate (PM)
0.0095
0.01
3
Inhalable Coarse Particulate (PM10)
0.01941
0.02
3
Fine Particulate (PM2 5)
0.01941
0.02
3
Sulfur Dioxide (S02)
0.0544
0.1
4
Volatile Organic Compounds (VOC)
0.0296
0.03
1
NON-FUGITIVE EMISSIONS
Greenhouse Gas Emissions
(C02 Equivalent)
EF
(Ib/MMBtu)
PTE
(tpy)
EF Reference
Carbon Dioxide (C02)
116.977
110.0
5
Methane (CFI4)
0.055
0.1
5
Nitrous Oxide (N20)
0.066
0.1
5
TOTAL 110
1 September 6, 1995 EPA memorandum entitled, "Calculating Potential to Emit (PTE) for Emergency Generators"
EF Reference
Description
1
Table 3.2-3 of AP-42, July 2000.
2
Table 1.4-2 of AP-42, July 1998. EF (Ib/MMBtu) = (0.0005 lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
3
Table 3.2-3 of AP-42, July 2000. Filterable PM (< 1nm) = 9.50x103 Ib/MMBtu. Condensible PM ~ 9.91x103 Ib/MMBtu. PM EF equal to filterable portion. PM10 and
PM2 5 EF equal to sum of both; 0.01941 Ib/MMBtu. EPA did not employ the applicable FARR PM limit to calculate potential emissions because the resultant 0.1871
Ib/MMBtu PM EF is unrealistic for a natural gas fired engine. The calculation to derive the 0.1871 Ib/MMBtu PM EF is as follows:
Basis: FARR combustion source stack PM emission limit of 0.1 gr/dscf corrected to 7% 02 at 40 CFR 49.125(d)(1)
EF (Ib/MMBtu) = FARR PM Limit (gr/dscf@7%02) X CF7^0%02 X Fd (dscf/MMBtu) / CFgr^lb (gr/lb)
• CF7_>o%02 = (20.9 - X02Fd) / (20.9 - X02FARR). To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR PM
Calculated EF
(Ib/MMBtu)
FARR PM
Emission Limit
(gr/dscf @7%02)
CF 7—>0%O2
(unitless)
Fd
(dscf/MMBtu)
CF gr^|b
(gr/lb)
0.1871
0.1
1.504
8,710
7,000
4
Option 1: 0.0544 Ib/MMBtu. This emission factor is employed to determine PTE as it limits emissions to less than Option 2 or 3 below.
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (Ib/MMBtu) = Pipeline tariff S Limit (gr/100 ft3) / CF100ft3^Btu X CFBtu^MMBtu / CFgr^,b X CFS^S02
• CFS^S02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 105000 Btu/100 ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
Pipeline Tariff
Calculate S02 EF
(Ib/MMBtu)
Pipeline Tariff
Fuel Sulfur Limit
(qr/100 ft3)
CFft3^Btu
(Btu/100 ft3)
CF BtU_>MMBtu
(Btu/MMBtu)
CFgr^|b
(gr/lb)
CFs^so2
(lb S02/lb S)
0.0544
20
105000
1.E+06
7000
2
Option 2: 0.1308 Ib/MMBtu.
Basis: FARR gaseous fuel sulfur limit of 1.1 g/dry standard cubic meter at 40 CFR 49.130(d)(8)
EF (Ib/MMBtu) = FARR Fuel S Limit (g/m ) / CFm3_»ft3 / CFft3_>Btu X CFBtu->MMBtu! CFg_,.ib X CFs->so2
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 1050 Btu/ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
FARR Fuel S
Calculate S02 EF
(Ib/MMBtu)
FARR
Fuel Sulfur Limit
(g/rri3)
CF m3_>ft3
(ft3/m3)
CFft3^Btu
(Btu/ft3)
CFgtu—»MMBtu
(Btu/MMBtu)
CF g—b
(g/lb)
CF S—»S02
^iu JU2/IU
OA
0.1308
1.1
35.3147
1050
1.E+06
453.592
2
Option 3: 1.087 Ib/MMBtu.
Basis: FARR combustion source stack S02 emission limit of 500 parts per million by volume dry basis (ppmvd) corrected to 7% 02 at 40 CFR 49.129(d)(1)
EF (Ib/MMBtu) = FARR S02 Limit (ppmvd@7%02) X CF7^o»A02 X CFpprTW|b/dscfS02 X Fd (dscf/MMBtu)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• CFpprTW|b/dscfSo2 = 1 -660 X 10"7 lb S02/dscf / ppm S02. See Table 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR 500 ppm
Calculate S02 EF
(Ib/MMBtu)
FARR
JU2 L_l 1 IIS^IUI 1
1 im it
(ppmvd@7%02)
CF 7_>0%O2
(unitless)
C F ppm^| b/dscfS02
(lb/dscf / ppm)
Fd
(dscf/MMBtu)
1.087
500
1.504
1.66E-07
8710
5
EPA's March 2011 guidance document "PSD and Title V Permitting Guidance for Greenhouse Gases" states that the GFIG Report Rule (40 CFR 98), "should be
considered a primary reference for sources and permitting authorities in estimating GFIG emissions and establishing measurement techniques when preparing or
processing permit applications." Therefore, GFIG Reporting Rule emission factors will be employed to determine GFIG PTE.
Carbon Dioxide (CO?)
EF (lb C02e/MMBtu) = EF (kg C02/MMBtu) X CFkg^lb (lb/kg) X GWPC02 (lb C02e/lb C02)
Calculated C02e
EF for C02
(lb C02e/MMBtu)
40 CFR 98
Table C-1 EF
(kg C02/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb C02)
116.977
53.06
2.20462262
1
Methane (CFI„)
EF (lb C02e/MMBtu) = EF (kg CH4/MMBtu) X CFk£Mb (lb/kg) X GWPCH4 (lb C02e/lb CH4)
Calculated C02e
E F for C Fl4
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg CH4/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb CH4)
0.055
0.001
2.20462262
25
Nitrous Oxide (N?0)
EF (lb C02e/MMBtu) = EF (kg N20/MMBtu) X CFk£Mb (lb/kg) X GWPN20 (lb C02e/lb N20)
Calculated C02e
EFfor N20
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg N20/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb N20)
0.066
0.0001
2.20462262
298
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 256 of 270
Page A-8 of A-18
-------
HAP Potential to Emit
Appendix A: Potential Emissions Inventory
Control Device
Fuel
Installation Date
Design Maximum Output Capacity
Design Maximum Heat Input Capcity
Operation
Emission Unit: EU-5
Description: Caterpillar 3408 Backup Electrical Power Generator
Reciprocating IC Compressor Engine, four-stroke, rich-burn, spark ignition
none
natural gas
1998
400 horsepower
3.76 MMBtu/hr
500 hours per year1
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 xl 06 scf)
EF
(Ib/MMBtu)
PTE
(tpy)
Trace Metal Compounds
Arsenic Compounds
2.0E-04
2.0E-07
1.84E-07
Beryllium Compounds
1.2E-05
1.2E-08
1.11E-08
Cadmium Compounds
1.1E-03
1.1E-06
1.01E-06
Chromium Compounds (including hexavalent)
1.4E-03
1.4E-06
1.29E-06
Cobalt Compounds
8.4E-05
8.2E-08
7.74E-08
Manganese Compounds
3.8E-04
3.7E-07
3.50E-07
Mercury Compounds
2.6E-04
2.5E-07
2.40E-07
Nickel Compounds
2.1E-03
2.1E-06
1.94E-06
Selenium Compounds
2.4E-05
2.4E-08
2.21 E-08
Organic Compounds
1,1,2,2-Tetrachlorethane
2.53E-05
2.38E-05
1,1,2-T richloroethane
1.53E-04
1.44E-04
1,3-Butadiene
6.63E-04
6.23E-04
1,3-Dichloropropene
1.27E-05
1.19E-05
Acetaldehyde
2.79E-03
2.62E-03
Acrolein
2.63E-03
2.47E-03
Benzene
1.58E-03
1.49E-03
Carbon Tetrachloride
1.77E-05
1.66E-05
Chlorobenzene
0)
1.29E-05
1.21 E-05
Chloroform
cu
0
1.37E-05
1.29E-05
Ethylbenzene
Q_
Q_
2.48E-05
2.33E-05
Ethylene Dibromide
<
2.13E-05
2.00E-05
Formaldehyde
-z.
2.05E-02
1.93E-02
Methanol
3.06E-03
2.88E-03
Methylene Chloride
4.12E-05
3.87E-05
Naphthalene2
9.71 E-05
9.13E-05
Polycyclic Organic Matter (POM)3
1.41E-04
1.33E-04
Styrene
1.19E-05
1.12E-05
Toluene
5.58E-04
5.25E-04
Vinyl Chloride
7.18E-06
6.75E-06
Xylene
1.95E-04
1.83E-04
TOTAL4 3.25E-02 3.05E-02
1 September 6, 1995 EPA memorandum entitled, "Calculating Potential to Emit (PTE) for Emergency Generators"
2 Naphthalene is a HAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds
that, in aggregate, are subject to the same 10 tpy major source threshold.
3 POM defines a broad class of compounds that generally includes all organic structures having two or more fused aromatic rings (i.e., rings that share a common
border), and that have a boiling point greater than or equal to 212°F (100°C). See http://www.epa.gOv/ttn/atw/hlthef/polycycl.html#ref11
4 Because naphthalene is accounted for individually and in the calculation of POM EF, its contribution here is discounted so as to avoid double-counting.
Trace Metal Compounds EF Basis: AP-42. Table 1.4-4. July 1998.
EF (Ib/MMBtu) = EF (Ib/1x106scf) X(1x106 scf/1020 MMBtu). See footnote a to Table 1.4-4.
Organic Compounds EF Basis: AP-42. Table 3.2-3. July 2000.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 257 of 270
Page A-9 of A-18
-------
Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Control Device
Fuel
Installation Date
Design Maximum Heat Input Capcity
Operation
Emission Unit: EU-6
Description: Sellers Model C80W Boiler
Boiler provides glycol heat to keep compressor engines on warm standby
none
natural gas
1989
3.5154
8760
MMBtu/hr
hours per year
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 x105 scf)
EF
(Ib/MMBtu)
PTE
ftpy)
EF Reference
Carbon Monoxide (CO)
84
0.0824
1.3
1
Lead (Pb)
0.0005
4.9E-07
7.55E-06
2
Nitrogen Oxides (NOx)
100
0.0980
1.5
1
Particulate (PM)
1.9
0.0019
0.03
3
Inhalable Coarse Particulate (PM10)
7.6
0.0075
0.11
3
Fine Particulate (PM2 5)
7.6
0.0075
0.11
3
Sulfur Dioxide (S02)
Not Applicable
0.0544
0.8
4
Volatile Organic Compounds (VOC)
5.5
0.0054
0.08
2
NON-FUGITIVE EMISSIONS
Greenhouse Gas Emissions
EF
EF
PTE
EF Reference
(C02 Equivalent)
(lb/1 x105 scf)
(Ib/MMBtu)
(tpy)
Carbon Dioxide (C02)
116.977
1801.2
5
Methane (CFI4)
Not Applicable
0.055
0.8
5
Nitrous Oxide (N20)
0.066
1.0
5
TOTAL 1,803
EF Reference
Description
1
Table 1.4-1 of AP-42, July 1998. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-1.
2
Table 1.4-2 of AP-42, July 1998. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
3
Table 1.4-2 of AP-42, July 1998. Filterable PM (< 1nm) = 1.9 lb/1 xl06 scf. Condensible PM -5.7 lb/1 xl06 scf. PM EF equal to filterable portion. PM10 and PM2 5 EF
equal to sum of both; 7.6 lb/1 xl06 scf. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
EPA did not employ the applicable FARR PM limit to calculate potential emissions because the resultant 0.1871 Ib/MMBtu PM EF is unrealistic for a natural gas fired
boiler. The calculation to derive the 0.1871 Ib/MMBtu PM EF is as follows:
Basis: FARR combustion source stack PM emission limit of 0.1 gr/dscf corrected to 7% 02 at 40 CFR 49.125(d)(1)
EF (Ib/MMBtu) = FARR PM Limit (gr/dscf@7%02) X CF7_^%02 X Fd (dscf/MMBtu) / CFgr^lb (gr/lb)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR PM
Calculated EF
(Ib/MMBtu)
FARR PM
Emission Limit
(gr/dscf @7%02)
CF 7—>0%O2
(unitless)
Fd
(dscf/MMBtu)
CFgr^|b
(gr/lb)
0.1871
0.1
1.504
8,710
7,000
4
Option 1: 0.0544 Ib/MMBtu. This emission factor is employed to determine PTE as it limits emissions to less than Option 2 or 3 below.
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (Ib/MMBtu) = Pipeline tariff S Limit (gr/100 ft3) / CF100ft3^Btu X CFBtu^MMBtu / CFgr^,b X CFS^S02
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 105000 Btu/100 ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
Pipeline Tariff
Calculate S02 EF
(Ib/MMBtu)
Pipeline Tariff
Fuel Sulfur Limit
(qr/100 ft3)
CFft3^Btu
(Btu/100 ft3)
CFgtu->MMBtu
(Btu/MMBtu)
CFgr_>|b
(gr/lb)
CF S—»S02
(lb S02/lb S)
0.0544
20
105000
1.E+06
7000
2
Option 2: 0.1308 Ib/MMBtu.
Basis: FARR gaseous fuel sulfur limit of 1.1 g/dry standard cubic meter at 40 CFR 49.130(d)(8)
EF (Ib/MMBtu) = FARR Fuel S Limit (g/m ) / CFm3_»ft3 / CFft3_>Btu X CFBtu->MMBtu! CFg_,.ib X CFs->so2
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFft3^Btu = 1050 Btu/ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
FARR Fuel S
Calculate S02 EF
(Ib/MMBtu)
FARR
Fuel Sulfur Limit
(q/rri3)
CF m3_>ft3
(ft3/m3)
CFfo^etu
(Btu/ft3)
CF[3tu—>MMBtu
(Btu/MMBtu)
CFg^|b
(g/ib)
CFs^so2
ON
0.1308
1.1
35.3147
1050
1.E+06
453.592
2
Option 3: 1.087 Ib/MMBtu.
Basis: FARR combustion source stack S02 emission limit of 500 parts per million by volume dry basis (ppmvd) corrected to 7% 02 at 40 CFR 49.129(d)(1)
EF (Ib/MMBtu) = FARR S02 Limit (ppmvd@7%02) X CF7^0%02 X CFpprTW|b/dscfSo2 X Fd (dscf/MMBtu)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
Xo2Fd = 0 ar|d X02farr = 7- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• CFpprTW|b/dscfSo2 = 1 -660 X 10"7 lb S02/dscf / ppm S02. See Table 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR 500 ppm
Calculate S02 EF
(Ib/MMBtu)
FARR
JW2 i_ 111 i^oiwi i
1 im it
(ppmvd@7%02)
CF 7—>0%O2
(unitless)
C Fppm^i b/dscfS02
(lb/dscf / ppm)
Fd
(dscf/MMBtu)
1.087
500
1.504
1.66E-07
8710
5
EPA's March 2011 guidance document "PSD and Title V Permitting Guidance for Greenhouse Gases" states that the GFIG Report Rule (40 CFR 98), "should be
considered a primary reference for sources and permitting authorities in estimating GFIG emissions and establishing measurement techniques when preparing or
processing permit applications." Therefore, GFIG Reporting Rule emission factors will be employed to determine GFIG PTE.
Carbon Dioxide (CO-?)
EF (lb C02e/MMBtu) = EF (kg C02/MMBtu) X CFkg^lb (lb/kg) X GWPC02 (lb C02e/lb C02)
Calculated C02e
EF for C02
(lb C02e/MMBtu)
40 CFR 98
Table C-1 EF
(kg C02/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb C02)
116.977
53.06
2.20462262
1
Methane (CFL)
EF (lb C02e/MMBtu) = EF (kg CH4/MMBtu) X CFkg^lb (lb/kg) X GWPCH4 (lb C02e/lb CH4)
Calculated C02e
E F for C Fl4
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg CH4/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb CH4)
0.055
0.001
2.20462262
25
Nitrous Oxide (N?0)
EF (lb C02e/MMBtu) = EF (kg N20/MMBtu) X CFkg^lb (lb/kg) X GWPN20 (lb C02e/lb N20)
Calculated C02e
EFfor N20
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg N20/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb N20)
0.066
0.0001
2.20462262
298
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 258 of 270
Page A-
10 of A-18
-------
HAP Potential to Emit
Appendix A: Potential Emissions Inventory
Control Device
Fuel
Installation Date
Design Maximum Heat Input Capcity
Operation
Emission Unit: EU-6
Description: Sellers Model C80W Boiler
Boiler provides glycol heat to keep compressor engines on warm standby
none
natural gas
1989
3.5154
8760
MMBtu/hr
hours per year
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 xl 06 scf)
EF
(Ib/MMBtu)
PTE
(tpy)
Trace Metal Compounds
Arsenic Compounds
2.0E-04
2.0E-07
3.02E-06
Beryllium Compounds
1.2E-05
1.2E-08
1.81E-07
Cadmium Compounds
1.1E-03
1.1E-06
1.66E-05
Chromium Compounds (including hexavalent)
1.4E-03
1.4E-06
2.11E-05
Cobalt Compounds
8.4E-05
8.2E-08
1.27E-06
Manganese Compounds
3.8E-04
3.7E-07
5.74E-06
Mercury Compounds
2.6E-04
2.5E-07
3.92E-06
Nickel Compounds
2.1E-03
2.1E-06
3.17E-05
Selenium Compounds
2.4E-05
2.4E-08
3.62E-07
Organic Compounds
Benzene
2.1E-03
2.1E-06
3.17E-05
Dichlorobenzene
1.2E-03
1.2E-06
1.81E-05
Formaldehyde
7.5E-02
7.4E-05
1.13E-03
Hexane
1.8E+00
1.8E-03
2.72E-02
Naphthalene1
6.1E-04
6.0E-07
9.21 E-06
Polycyclic Organic Matter (POM)2
7.0E-04
6.8E-07
1.05E-05
Toluene
3.4E-03
3.3E-06
5.13E-05
TOTAL3 1.89E+00 1.85E-03 2.85E-02
1 Naphthalene is a HAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds
that, in aggregate, are subject to the same 10 tpy major source threshold.
2 POM defines a broad class of compounds that generally includes all organic structures having two or more fused aromatic rings (i.e., rings that share a common
border), and that have a boiling point greater than or equal to 212°F (100°C). See http://www.epa.gOv/ttn/atw/hlthef/polycycl.html#ref11
3 Because naphthalene is accounted for individually and in the calculation of POM EF, its contribution here is discounted so as to avoid double-counting.
Trace Metal Compounds EF Basis: AP-42. Table 1.4-4. July 1998.
EF (Ib/MMBtu) = EF (Ib/1x106scf) X(1x106 scf/1020 MMBtu). See footnote a to Table 1.4-4.
Orc[ani£^om|30und=EF=Basis;=^P=42JableJ^4_3i=Jul^J=998i
POM Compounds
EF
(lb/105 scf)
EF
(Ib/MMBtu)
2-Methylnaphthalene
2.4E-05
2.4E-08
3-Methychloranthrene
1.8E-06
1.8E-09
7,12-Dimethylbenz(a)anthracene
1.6E-05
1.6E-08
Acenaphthene*
1.8E-06
1.8E-09
Acenaphthylene*
1.8E-06
1.8E-09
Anthracene*
2.4E-06
2.4E-09
Benzo(a)anthracene*
1.8E-06
1.8E-09
Benzo(a)pyrene*
1.2E-06
1.2E-09
Benzo(b)fluoranthene*
1.8E-06
1.8E-09
Benzo(g, h, I) perylene*
1.2E-06
1.2E-09
Benzo(k)fluoranthene*
1.8E-06
1.8E-09
Chrysene*
1.8E-06
1.8E-09
Dibenzo(a,h)anthracene
1.2E-06
1.2E-09
Fluoranthene*
3.0E-06
2.9E-09
Fluorene*
2.8E-06
2.7E-09
lndeno(1,2,3-cd)pyrene*
1.8E-06
1.8E-09
Naphthalene***
6.1E-04
6.0E-07
Phenanthrene*
1.7E-05
1.7E-08
Pyrene
5.0E-06
4.9E-09
SUBTOTAL
7.0E-04
6.8E-07
* designates a polycyclic aromatic hydrocarbon (PAH). PAHs are potent atmospheric pollutants that consist of fused aromatic rings and do not contain heteroatoms
** designates a POM compound that is also an individual HAP.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 259 of 270
Page A-11 of A-18
-------
Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Control Device
Fuel
Installation Date
Design Maximum Heat Input Capcity
Operation
Emission Unit: EU-7
Description: BS&B Model IH-3012-500M-T2 Heater (Refurbished)
Boiler provides glycol heat to keep compressor engines on warm standby
none
natural gas
?
0.50
8760
MMBtu/hr
hours per year
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 x105 scf)
EF
(Ib/MMBtu)
PTE
ftpy)
EF Reference
Carbon Monoxide (CO)
84
0.0824
0.2
1
Lead (Pb)
0.0005
4.9E-07
1.07E-06
2
Nitrogen Oxides (NOx)
100
0.0980
0.2
1
Particulate (PM)
1.9
0.0019
0.00
3
Inhalable Coarse Particulate (PM10)
7.6
0.0075
0.02
3
Fine Particulate (PM2 5)
7.6
0.0075
0.02
3
Sulfur Dioxide (S02)
Not Applicable
0.0544
0.1
4
Volatile Organic Compounds (VOC)
5.5
0.0054
0.01
2
NON-FUGITIVE EMISSIONS
Greenhouse Gas Emissions
EF
EF
PTE
EF Reference
(C02 Equivalent)
(lb/1 x105 scf)
(Ib/MMBtu)
(tpy)
Carbon Dioxide (C02)
116.977
256.2
5
Methane (CH4)
Not Applicable
0.055
0.1
5
Nitrous Oxide (N20)
0.066
0.1
5
TOTAL 256
EF Reference
Description
1
Table 1.4-1 of AP-42, July 1998. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-1.
2
Table 1.4-2 of AP-42, July 1998. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
3
Table 1.4-2 of AP-42, July 1998. Filterable PM (< 1nm) = 1.9 lb/1 xl06 scf. Condensible PM -5.7 lb/1 xl06 scf. PM EF equal to filterable portion. PM10 and PM2 5 EF
equal to sum of both; 7.6 lb/1 xl06 scf. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
EPA did not employ the applicable FARR PM limit to calculate potential emissions because the resultant 0.1871 Ib/MMBtu PM EF is unrealistic for a natural gas fired
boiler. The calculation to derive the 0.1871 Ib/MMBtu PM EF is as follows:
Basis: FARR combustion source stack PM emission limit of 0.1 gr/dscf corrected to 7% 02 at 40 CFR 49.125(d)(1)
EF (Ib/MMBtu) = FARR PM Limit (gr/dscf@7%02) X CF7_^%02 X Fd (dscf/MMBtu) / CFgr^lb (gr/lb)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
X02Fd = 0 and X02farr = 1- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR PM
Calculated EF
(Ib/MMBtu)
FARR PM
Emission Limit
(gr/dscf @7%02)
CF 7—>0%O2
(unitless)
Fd
(dscf/MMBtu)
CFgr^|b
(gr/lb)
0.1871
0.1
1.504
8,710
7,000
4
Option 1: 0.0544 Ib/MMBtu. This emission factor is employed to determine PTE as it limits emissions to less than Option 2 or 3 below.
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (Ib/MMBtu) = Pipeline tariff S Limit (gr/100 ft3) / CF100ft3^Btu X CFBtu^MMBtu / CFgr^,b X CFS^S02
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 105000 Btu/100 ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
Pipeline Tariff
Calculate S02 EF
(Ib/MMBtu)
Pipeline Tariff
Fuel Sulfur Limit
(qr/100 ft3)
CFft3^Btu
(Btu/100 ft3)
CFgtu->MMBtu
(Btu/MMBtu)
CFgr_>|b
(gr/lb)
CF S—»S02
(lb S02/lb S)
0.0544
20
105000
1.E+06
7000
2
Option 2: 0.1308 Ib/MMBtu.
Basis: FARR gaseous fuel sulfur limit of 1.1 g/dry standard cubic meter at 40 CFR 49.130(d)(8)
EF (Ib/MMBtu) = FARR Fuel S Limit (g/m ) / CFm3_»ft3 / CFft3_>Btu X CFBtu->MMBtu! CFg_,.ib X CFs->so2
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFft3^Btu = 1050 Btu/ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
FARR Fuel S
Calculate S02 EF
(Ib/MMBtu)
FARR
Fuel Sulfur Limit
(q/rri3)
CF m3_>ft3
(ft3/m3)
CFfo^etu
(Btu/ft3)
CF[3tu—>MMBtu
(Btu/MMBtu)
CFg^|b
(g/ib)
CFs^so2
ON
0.1308
1.1
35.3147
1050
1.E+06
453.592
2
Option 3: 1.087 Ib/MMBtu.
Basis: FARR combustion source stack S02 emission limit of 500 parts per million by volume dry basis (ppmvd) corrected to 7% 02 at 40 CFR 49.129(d)(1)
EF (Ib/MMBtu) = FARR S02 Limit (ppmvd@7%02) X CF7^0%02 X CFpprTW|b/dscfSo2 X Fd (dscf/MMBtu)
• CF7_>o%o2 = (20.9 - X02Fd) / (20.9 - X02Farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
Xo2Fd = 0 ar|d X02farr = 7- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• CFpprTW|b/dscfSo2 = 1 -660 X 10"7 lb S02/dscf / ppm S02. See Table 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR 500 ppm
Calculate S02 EF
(Ib/MMBtu)
FARR
JW2 i_ 111 i^oiwi i
1 im it
(ppmvd@7%02)
CF 7—>0%O2
(unitless)
C Fppm^i b/dscfS02
(lb/dscf / ppm)
Fd
(dscf/MMBtu)
1.087
500
1.504
1.66E-07
8710
5
EPA's March 2011 guidance document "PSD and Title V Permitting Guidance for Greenhouse Gases" states that the GHG Report Rule (40 CFR 98), "should be
considered a primary reference for sources and permitting authorities in estimating GHG emissions and establishing measurement techniques when preparing or
processing permit applications." Therefore, GHG Reporting Rule emission factors will be employed to determine GHG PTE.
Carbon Dioxide (CO-?)
EF (lb C02e/MMBtu) = EF (kg C02/MMBtu) X CFkg^lb (lb/kg) X GWPC02 (lb C02e/lb C02)
Calculated C02e
EF for C02
(lb C02e/MMBtu)
40 CFR 98
Table C-1 EF
(kg C02/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb C02)
116.977
53.06
2.20462262
1
Methane (CH„)
EF (lb C02e/MMBtu) = EF (kg CH4/MMBtu) X CFkg^lb (lb/kg) X GWPCH4 (lb C02e/lb CH4)
Calculated C02e
E F for C H4
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg CH4/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb CH4)
0.055
0.001
2.20462262
25
Nitrous Oxide (N?0)
EF (lb C02e/MMBtu) = EF (kg N20/MMBtu) X CFkg^lb (lb/kg) X GWPN20 (lb C02e/lb N20)
Calculated C02e
EFfor N20
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg N20/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb N20)
0.066
0.0001
2.20462262
298
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 260 of 270
Page A-
12 of A-18
-------
HAP Potential to Emit
Appendix A: Potential Emissions Inventory
Emission Unit: EU-7
Description: BS&B Model IH-3012-500M-T2 Heater (Refurbished)
Boiler provides glycol heat to keep compressor engines on warm standby
Control Device
Fuel
Installation Date
Design Maximum Heat Input Capcity
Operation
none
natural gas
?
0.50
8760
MMBtu/hr
hours per year
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 xl 06 scf)
EF
(Ib/MMBtu)
PTE
(tpy)
Trace Metal Compounds
Arsenic Compounds
2.0E-04
2.0E-07
4.29E-07
Beryllium Compounds
1.2E-05
1.2E-08
2.58E-08
Cadmium Compounds
1.1E-03
1.1 E-06
2.36E-06
Chromium Compounds (including hexavalent)
1.4E-03
1.4E-06
3.01 E-06
Cobalt Compounds
8.4E-05
8.2E-08
1.80E-07
Manganese Compounds
3.8E-04
3.7E-07
8.16E-07
Mercury Compounds
2.6E-04
2.5E-07
5.58E-07
Nickel Compounds
2.1E-03
2.1 E-06
4.51 E-06
Selenium Compounds
2.4E-05
2.4E-08
5.15E-08
Organic Compounds
Benzene
2.1E-03
2.1 E-06
4.51 E-06
Dichlorobenzene
1.2E-03
1.2E-06
2.58E-06
Formaldehyde
7.5E-02
7.4E-05
1.61E-04
Hexane
1.8E+00
1.8E-03
3.86E-03
Naphthalene1
6.1E-04
6.0E-07
1.31E-06
Polycyclic Organic Matter (POM)2
7.0E-04
6.8E-07
1.50E-06
Toluene
3.4E-03
3.3E-06
7.30E-06
TOTAL3 1.89E+00 1.85E-03 4.05E-03
1 Naphthalene is a HAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds
that, in aggregate, are subject to the same 10 tpy major source threshold.
2 POM defines a broad class of compounds that generally includes all organic structures having two or more fused aromatic rings (i.e., rings that share a common
border), and that have a boiling point greater than or equal to 212°F (100°C). See http://www.epa.gOv/ttn/atw/hlthef/polycycl.html#ref11
3 Because naphthalene is accounted for individually and in the calculation of POM EF, its contribution here is discounted so as to avoid double-counting.
Trace Metal Compounds EF Basis: AP-42. Table 1.4-4. July 1998.
EF (Ib/MMBtu) = EF (Ib/1x106scf) X(1x106 scf/1020 MMBtu). See footnote a to Table 1.4-4.
Orc[ani£^om|30und=EF=Basis;=^P=42JableJ^4_3i=Jul^J=998i
POM Compounds
EF
(lb/105 scf)
EF
(Ib/MMBtu)
2-Methylnaphthalene
2.4E-05
2.4E-08
3-Methychloranthrene
1.8E-06
1.8E-09
7,12-Dimethylbenz(a)anthracene
1.6E-05
1.6E-08
Acenaphthene*
1.8E-06
1.8E-09
Acenaphthylene*
1.8E-06
1.8E-09
Anthracene*
2.4E-06
2.4E-09
Benzo(a)anthracene*
1.8E-06
1.8E-09
Benzo(a)pyrene*
1.2E-06
1.2E-09
Benzo(b)fluoranthene*
1.8E-06
1.8E-09
Benzo(g, h, I) perylene*
1.2E-06
1.2E-09
Benzo(k)fluoranthene*
1.8E-06
1.8E-09
Chrysene*
1.8E-06
1.8E-09
Dibenzo(a,h)anthracene
1.2E-06
1.2E-09
Fluoranthene*
3.0E-06
2.9E-09
Fluorene*
2.8E-06
2.7E-09
lndeno(1,2,3-cd)pyrene*
1.8E-06
1.8E-09
Naphthalene***
6.1E-04
6.0E-07
Phenanthrene*
1.7E-05
1.7E-08
Pyrene
5.0E-06
4.9E-09
SUBTOTAL
7.0E-04
6.8E-07
* designates a polycyclic aromatic hydrocarbon (PAH). PAHs are potent atmospheric pollutants that consist of fused aromatic rings and do not contain heteroatoms
** designates a POM compound that is also an individual HAP.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 261 of 270
Page A-13 of A-18
-------
Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Emission Unit:
Description:
Control Device:
Fuel:
Equipment List
EU-8
Heaters and Furnaces
none
natural gas
Rated Capacity (MMBtu/hr)
Shop Heater
0.25
Shop Heater
0.25
Breakroom Furnace
0.08
Old Office Furnace
0.07
Warehouse Shop Heater
0.16
Auxilary Room Heater
0.3691
Total 1.1791 MMBtu/hr
Operation: 8760 hours per year
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 xl 06 scf)
EF
(Ib/MMBtu)
PTE
(tpy)
EF Reference
Carbon Monoxide (CO)
40
0.0824
0.4
1
Lead (Pb)
0.0005
4.90E-07
2.5E-06
2
Nitrogen Oxides (NOx)
94
0.0980
0.5
1
Particulate (PM)
1.9
0.00186
0.01
3
Inhalable Coarse Particulate (PM10)
7.6
0.00745
0.04
3
Fine Particulate (PM2 5)
7.6
0.00745
0.04
3
Sulfur Dioxide (S02)
Not Applicable
0.0544
0.3
4
Volatile Organic Compounds (VOC)
5.5
0.0054
0.03
2
NON-FUGITIVE EMISSIONS
Greenhouse Gas Emissions
EF
EF
PTE
EF Reference
(C02 Equivalent)
(lb/1 x105 scf)
(Ib/MMBtu)
(tpy)
Carbon Dioxide (C02)
116.977
604.1
5
Methane (CH4)
Not Applicable
0.055
0.3
5
Nitrous Oxide (N20)
0.066
0.3
5
TOTAL 605
EF Reference
Description
1
Table 1.4-1 of AP-42, July 1998. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-1.
2
Table 1.4-2 of AP-42, July 1998. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
3
Table 1.4-2 of AP-42, July 1998. Filterable PM (< 1|im) = 1.9 lb/1 xl06 scf. Condensible PM ~ 5.7 lb/1 xl06 scf. PM EF equal to filterable portion. PM10 and PM25 EF
equal to sum of both; 7.6 lb/1 xl06 scf. EF (Ib/MMBtu) = EF (lb/1 xl06 scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-2.
EPA did not employ the applicable FARR PM limit to calculate potential emissions because the resultant 0.1871 Ib/MMBtu PM EF is unrealistic for a natural gas
fired boiler. The calculation to derive the 0.1871 Ib/MMBtu PM EF is as follows:
Basis: FARR combustion source stack PM emission limit of 0.1 gr/dscf corrected to 7% 02 at 40 CFR 49.125(d)(1)
EF (Ib/MMBtu) = FARR PM Limit (gr/dscf@7%02) X CF7^0%02 X Fd (dscf/MMBtu) / CFgr^lb (gr/lb)
• CF7—>0%o2 = (20.9 - X02pd) / (20.9 - X02farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
Xo2Fd = 0 ar|d X02farr = 7- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR PM
Calculated EF
(Ib/MMBtu)
FARR PM
Emission Limit
(gr/dscf @7%02)
CF 7_>0%O2
(unitless)
Fd
(dscf/MMBtu)
CF gr^|b
(gr/lb)
0.1871
0.1
1.504
8,710
7,000
4
Option 1: 0.0544 Ib/MMBtu. This emission factor is employed to determine PTE as it limits emissions to less than Option 2 or 3 below.
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (Ib/MMBtu) = Pipeline tariff S Limit (gr/100 ft3) / CF-ioo^Btu X CFBtu^MMBtu / CFgr^b X CFs^So2
• CFs—»so2 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFft3—>Btu = 105000 Btu/100 ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
Pipeline Tariff
Calculate S02 EF
(Ib/MMBtu)
Pipeline Tariff
Fuel Sulfur Limit
(qr/100 ft3)
CF ft3—>Btu
(Btu/100 ft3)
CF Btu—>MMBtu
(Btu/MMBtu)
CFgr_>|b
(gr/lb)
CF S—»S02
(lb S02/lb S)
0.0544
20
105000
1.E+06
7000
2
ODtion 2: 0.1308 Ib/MMBtu.
Basis: FARR gaseous fuel sulfur limit of 1.1 g/dry standard cubic meter at 40 CFR 49.130(d)(8)
EF (Ib/MMBtu) = FARR Fuel S Limit (g/m3) / CFm3_»ft3 / CFft3_>etu X CFetu-»MMBtu / CFg_,|b X CFs->so2
• CFs^s02 = 2 lb S02/lb S. S + 02 —> S02. For every 1 mol S (16 Ib/lb-mol) reactant, there is 1 mol S02 (32 Ib/lb-mol) product. 32 /16 = 2.
• CFfo—^Btu = 1050 Btu/ft3 fuel. See heating value of natural gas on page A-5 of Appendix A to AP-42, September 1985.
FARR Fuel S
Calculate S02 EF
(Ib/MMBtu)
FARR
Fuel Sulfur Limit
(q/rri3)
CF m3—>ft3
(ft3/rn3)
CF ft3—>Btu
(Btu/ft3)
CF(3tu—»MMBtu
(Btu/MMBtu)
CF g—b
(g/ib)
CF S—>S02
(lb S02/lb S)
0.1308
1.1
35.3147
1050
1.E+06
453.592
2
Option 3: 1.087 Ib/MMBtu.
Basis: FARR combustion source stack S02 emission limit of 500 parts per million by volume dry basis (ppmvd) corrected to 7% 02 at 40 CFR 49.129(d)(1)
EF (Ib/MMBtu) = FARR S02 Limit (ppmvd@7%02) X CF7^0%02 X CFpprTW|b/dsCfso2 X Fd (dscf/MMBtu)
• CF7—>0%o2 = (20.9 - X02Fd) / (20.9 - X02farr)- To create a correction factor that adjusts the basis of the FARR emission limit from 7% 02 to 0% 02 (the basis for Fd),
Xo2Fd = 0 ar|d X02farr = 7- The value 20.9 is the percent by volume of the ambient air that is 02. Decreasing the 02 from the FARR baseline increases the pollutant
concentration. See Equation 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• CFpprTW|b/dsCfso2 = 1 -660 X 10"7 lb S02/dscf / ppm S02. See Table 19-1 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
• Fd = 8,710 dscf/MMBtu for combustion of natural gas. See Table 19-2 of EPA Method 19 at Appendix A-7 to 40 CFR Part 60.
FARR 500 ppm
Calculate S02 EF
(Ib/MMBtu)
FARR
OU2 Ql I llbblUI I
(ppmvd@7%02)
CF 7_>0%O2
(unitless)
CF ppm^|b/dscfS02
(lb/dscf / ppm)
Fd
(dscf/MMBtu)
1.087
500
1.504
1.66E-07
8710
5
EPA's March 2011 guidance document "PSD and Title V Permitting Guidance for Greenhouse Gases" states that the GHG Report Rule (40 CFR 98), "should be
Carbon Dioxide (CO?)
EF (lb C02e/MMBtu) = EF (kg C02/MMBtu) X CFk£Mb (lb/kg) X GWPC02 (lb C02e/lb C02)
Calculated C02e
EFfor C02
(lb C02e/MMBtu)
40 CFR 98
Table C-1 EF
(kg C02/MMBtu)
CFkg^lh
(lb/kg)
40 CFR 98 Table
A-1 GWPco2
(lb C02e/lb C02)
116.977
53.06
2.20462262
1
Methane (CH/i)
EF (lb C02e/MMBtu) = EF (kg CH4/MMBtu) X CFk£Mb (Ib/kc
]) X GWPCh4 (lb C02e/lb CH4)
Calculated C02e
EF for CH4
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg CH4/MMBtu)
CFkg^lb
(lb/kg)
40 CFR 98 Table
A-1 GWPC02
(lb C02e/lb CH4)
0.055
0.001
2.20462262
25
Nitrous Oxide (N?0)
EF (lb C02e/MMBtu) = EF (kg N20/MMBtu) X CFkg^lb (lb/kg) X GWPN20 (lb C02e/lb N20)
Calculated C02e
EF for N20
(lb C02e/hp-hr)
40 CFR 98
Table C-2 EF
(kg N20/MMBtu)
CF kg^|b
(lb/kg)
40 CFR 98 Table
A-1 GWPc02
(lb C02e/lb N20)
0.066
0.0001
2.20462262
298
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 262 of 270
Page A-14 of A-18
-------
Appendix A: Potential Emissions Inventory
HAP Potential to Emit
Emission Unit
Description
Control Device
Fuel
EU-8
Heaters and Furnaces
none
natural gas
Equipment List
Rated Capacity (MMBtu/hr)
Shop Fleater
0.25
Shop Fleater
0.25
Breakroom Furnace
0.08
Old Office Furnace
0.07
Warehouse Shop Fleater
0.16
Auxilary Room Fleater
0.3691
Total 1.1791 MMBtu/hr
Operation: 8760 hours per year
NON-FUGITIVE EMISSIONS
Criteria Pollutant Emissions
EF
(lb/1 x105 scf)
EF
(Ib/MMBtu)
PTE
(tpy)
Trace Metal Compounds
Arsenic Compounds
2.0E-04
2.0E-07
1.01 E-06
Beryllium Compounds
1.2E-05
1.2E-08
6.08E-08
Cadmium Compounds
1.1E-03
1.1E-06
5.57E-06
Chromium Compounds (including hexavalent)
1.4E-03
1.4E-06
7.09E-06
Cobalt Compounds
8.4E-05
8.2E-08
4.25E-07
Manganese Compounds
3.8E-04
3.7E-07
1.92E-06
Mercury Compounds
2.6E-04
2.5E-07
1.32E-06
Nickel Compounds
2.1E-03
2.1E-06
1.06E-05
Selenium Compounds
2.4E-05
2.4E-08
1.22E-07
Organic Compounds
Benzene
2.1E-03
2.1E-06
1.06E-05
Dichlorobenzene
1.2E-03
1.2E-06
6.08E-06
Formaldehyde
7.5E-02
7.4E-05
3.80E-04
Flexane
1.8E+00
1.8E-03
9.11E-03
Naphthalene1
6.1E-04
6.0E-07
3.09E-06
Polycyclic Organic Matter (POM)2
7.0E-04
6.8E-07
3.54E-06
Toluene
3.4E-03
3.3E-06
1.72E-05
TOTAL3 1.89E+00 1.85E-03 9.56E-03
1 Naphthalene is a FIAP that is subject individually to the 10 tpy major source threshold, but that is also one of several polycyclic organic matter (POM) compounds that,
in aggregate, are subject to the same 10 tpy major source threshold.
2 POM defines a broad class of compounds that generally includes all organic structures having two or more fused aromatic rings (i.e., rings that share a common
border), and that have a boiling point greater than or equal to 212°F (100°C). See http://www.epa.g0v/ttn/atw/hlthef/polycycl.html#refl 1
3 Because naphthalene is accounted for individually and in the calculation of POM EF, its contribution here is discounted so as to avoid double-counting.
Trace Metal Compounds EF Basis: AP-42. Table 1.4-4. July 1998.
EF (Ib/MMBtu) = EF (Ib/1x106scf) X (1x106 scf/1020 MMBtu). See footnote a to Table 1.4-4.
Or2anic=Comgound=EF=Basis^Pi42feTab|eJi4;3feJu|^J=998i
POM Compounds
EF
(lb/105 scf)
EF
(Ib/MMBtu)
2-Methylnaphthalene
2.4E-05
2.4E-08
3-Methychloranthrene
1.8E-06
1.8E-09
7,12-Dimethylbenz(a)anthracene
1.6E-05
1.6E-08
Acenaphthene*
1.8E-06
1.8E-09
Acenaphthylene*
1.8E-06
1.8E-09
Anthracene*
2.4E-06
2.4E-09
Benzo(a)anthracene*
1.8E-06
1.8E-09
Benzo(a)pyrene*
1.2E-06
1.2E-09
Benzo(b)fluoranthene*
1.8E-06
1.8E-09
Benzo(g,h,l)perylene*
1.2E-06
1.2E-09
Benzo(k)fluoranthene*
1.8E-06
1.8E-09
Chrysene*
1.8E-06
1.8E-09
Dibenzo(a,h)anthracene
1.2E-06
1.2E-09
Fluoranthene*
3.0E-06
2.9E-09
Fluorene*
2.8E-06
2.7E-09
lndeno(1,2,3-cd)pyrene*
1.8E-06
1.8E-09
Naphthalene*'**
6.1E-04
6.0E-07
Phenanthrene*
1.7E-05
1.7E-08
Pyrene
5.0E-06
4.9E-09
SUBTOTAL
7.0E-04
6.8E-07
* designates a polycyclic aromatic hydrocarbon (PAFI). PAFIs are potent atmospheric pollutants that consist of fused aromatic rings and do not contain heteroatoms or
** designates a POM compound that is also an individual FIAP.
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 263 of 270
Page A-15 of A-18
-------
Appendix A: Potential Emissions Inventory
HAP & Non-HAP Potential to Emit
Emission Unit: EU-9
Description: System Blowdown Gas
Once per year the source conducts an annual Emergency Shutdown Test where the source is isolated from the natural gas line and the system is purged venting
natural gas to the atmosphere.
Control Device: none
Natural Gas Purged: 0.35 1x106scf
NON-FUGITIVE EMISSIONS
HAP & Non-HAP Emissions
EF
(lb/1 x105 scf)
PTE
(tpy)
EF Reference
Hexane (HAP)
3.19E+01 |
0.01
1
Hydrogen Sulfide (H2S)
3.21 E+01
0.01
2
Lead (Pb)
5.00E-04
8.8E-08
3
Volatile Organic Compounds (VOC)
1.02E+03
0.2
4
NON-FUGITIVE EMISSIONS
Greenhouse Gas Emissions
(C02 Equivalent)
EF
(lb/1 x105 scf)
PTE
(tpy)
EF Reference
Methane (CH4)
1.02E+06
177.8
5
EF Reference
Description
EF (lb Hexane/1x10° scf) = (MWgas) X (wt. % Hexane/100) / (Densitygas) X CF100scf.
-~MMscf
Values for variables provided by applicant.
1
Hexane EF for CH4
MWgas
wt. % VOC/100
Densitygas
(lb/1 x105 scf)
(Ib/lb-mol)
(unitless)
(scf/lb rriol)
(scf/1x10° scf)
3.19E+01
19.25
0.000628
379
1.0E+06
Basis: FERC natural gas pipeline tariff sulfur limit of 20 gr/100 standard cubic feet.
EF (lb/1 x10° scf) = Pipeline tariff S Limit (gr/100 ft3) X CF100scf_^
MMscf! CFg^it, X CFc
—»H2S
• CFs^h2s = 1-125 lb H2S/lb S. The MW S is 16 Ib/lb-mol, and the MW H2S is 18 Ib/lb-mol. The ratio of H2S to S = 18/16; 1.125.
2
Pipeline Tariff
Pipeline Tariff
Calculate H2S EF
Fuel Sulfur Limit
CF "lOOscf—>MMscf
' ^gr—>lb
CF S—»H2S
(lb/1 x105 scf)
(gr/100 ft3)
(100 scf/1x105 scf)
(gr/lb)
(lb H2S/lb S)
3.21 E+01
20
10000
7000
1.125
3
Table 1.4-2 of AP-42, July 1998. Lead is a
"pass through" pollutant.
EF (lb VOC/1x106 scf)
= (MWgas) X (wt. % VOC/100) / (Density
gas) X C Fi ooscf—~ MMSCf
Values for variables provided by applicant.
4
VOC EF for CH4
MWgas
wt. % VOC/100
Densitygas
scf—»M Mscf
(lb/1 xl 06 scf)
(Ib/lb-mol)
(unitless)
(scf/lb mol)
(scf/1x10° scf)
1.02E+03
19.25
0.019993
379
1.0E+06
EF (lb CO2e/1x105 scf)
= (MWqas) X (wt. % CH4/100) / (Density
qas) X C F-| 00SCf—>M MSCf
X GWPCh4 (lb C02e/lb CH4)
Estimate that wt. % CH
4 in natural gas is 80%.
5
C02e EF for CH4
MWgas
wt. % CH4/100
Densitygas
C FSCf_>M Mscf
40 CFR 98 Table
A-1 GWPC02
(lb CO2e/1x105 scf)
(Ib/lb-mol)
(unitless)
(scf/lb mol)
(scf/1x10° scf)
(lb C02e/lb CH4)
1.02E+06
19.25
0.8
379
1.0E+06
25
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 264 of 270
Page A-16 of A-18
-------
Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Emission Unit
Description
Control Device
FUGITIVE EMISSIONS
EU-10
Equipment Leaks
none
Type of Component
Quantity3
Emission Factor'3
kg/hr/source
TOC Emissions
VOC Emissions0
kg/hr
Ib/hr
tpy
Ib/hr
tpy
Valves
196
4.50E-03
8.82E-01
1.944
8.517
0.039
0.170
Flanges
245
3.90E-04
9.56E-02
0.211
0.923
0.004
0.018
Open-Ended Lines
27
2.00E-03
5.40E-02
0.119
0.521
0.002
0.010
Compressor
4
8.80E-03
3.52E-02
0.078
0.340
0.002
0.007
TOTAL
0.21
a Quantity of the components are estimated based on an inventory performed at the Green River compressor station, which is similar to the Pocatello compressor station in equipment and size.
b Emission factors are obtained from the document "Protocol for Equipment Leak Estimates," Emission Standards Division, U.S. Environmental Protection Agency, November 1995 Table 2.4.
c Average weight fraction of VOC in the stream is estimated as 2.00%. VOC is calculated as Total Organic Carbon (TOC) excluding methane and ethane.
Because VOC for EU-10 approximately equal to VOC for EU-9, and given the similar nature of the emission generating activities, estimate that EU-10 PTE approximately equal to that of EU-9 for
hexane, H2S, lead and methane. A summary of EU-9 potential emissions is transposed here and assumed equal to EU-10 PTE, except that EU-10 emissions are fugitive.
FUGITIVE EMISSIONS
FIAP & Non-HAP Emissions
EF
(lb/1 xl 06 scf)
PTE
(tpy)
Hexane (HAP)
3.19E+01
0.01
Hydrogen Sulfide (H2S)
3.21 E+01
0.01
Lead (Pb)
5.00E-04
8.8E-08
Volatile Organic Compounds (VOC)
1.02E+03
0.2
FUGITIVE EMISSIONS
Greenhouse Gas Emissions
(C02 Equivalent)
EF
(lb/1 xl 06 scf)
PTE
(tpy)
Methane (CH4)
1.02E+06
177.8
Northwest Pipeline - Pocatello Compressor Station
Title V Operating Permit R10T5110200 Statement of Basis
Page 265 of 270
Page A-17 of A-18
-------
Appendix A: Potential Emissions Inventory
Non-HAP Potential to Emit
Emission Unit: EU-11
Description: Liquid Storage Tanks
Control Device: none
NON-FUGITIVE EMISSIONS
Liquid in Tank
Type of Tank
Capacity
(gallons)
VOC PTE
(tPY)
Scrubber Oil
Fixed Roof
310
0.1
Scrubber Oil
Fixed Roof
310
0.1
Lube Oil
Florizontal Fixed Roof
11,760
0.1
Used Lube Oil
Vertical Fixed Roof
2,940
0.1
Total
0.4
EPA TANKS 4.0.9d employed to estimate emissions resulting from storage of lube oil and used lube
oil. Engineering judgement employed to estimate emissions resulting from storage of scrubber oil.
Northwest Pipeline - Pocatello Compressor Station Page 2qq 0f 270
Title V Operating Permit R10T5110200 Statement of Basis Page A-18 of A-18
-------
From: Lori Howell
To: Familiare. Christopher S.
Subject: RE: Williams Corporation Northwest Pipeline Pocatello Compressor Station Pre-Draft Review
Date: Thursday, February 27, 2020 9:06:14 AM
Ok thanks. I will pass this along to our attorney. Appreciate it.
Lori
From: Familiare, Christopher S.
Sent: Thursday, February 27, 2020 9:12 AM
To: Lori Howell
Subject: RE: Williams Corporation Northwest Pipeline Pocatello Compressor Station Pre-Draft
Review
Hi Lori,
Thanks for your comment. EPA does not have authority under the Clean Air Act to require a
permittee to consent to the Tribe's jurisdiction as a condition of getting a Clean Air Act permit from
EPA.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
/i* .iir'tsii *?\
U.S. EPA Region 10
( W "I
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(7061-553-1 750 I familiare.christooher@eDa.Bov
From: Lori Howell
Sent: Tuesday, February 18, 2020 12:45 PM
To: Familiare, Christopher S.
Subject: RE: Williams Corporation Northwest Pipeline Pocatello Compressor Station Pre-Draft
Review
I apologize for taking so long for a response. We only request that the permit includes language that
the permittee consent to the Jurisdiction and law of the Shoshone-Bannock Tribes in regard to air
quality. Something to consider if not too late. Thank you for the opportunity to comment.
Lori
From: Familiare, Christopher S.
Sent: Friday, February 14, 2020 9:49 AM
To: Lori Howell
Cc: Jeff Carpenter : Shayna McCrary-Martin :
Page 267 of 270
-------
McFadden, Kellv
Subject: Williams Corporation Northwest Pipeline Pocatello Compressor Station Pre-Draft Review
Hi Lori,
I tried contacting you yesterday regarding the attached pre-draft Title V permit, statement of basis
and appendices to the statement of basis for the Williams Pocatello compressor station. I will be
sharing the materials with the company later today, but I wanted to contact you first. If you have
questions or comments on the attached materials, it would be great if you could share those with us
by COB February 28th.
I am hoping to begin the 30-day public comment process around the beginning of March. I will be
providing public notice of Region 10's proposed permitting action via our website. The public will
have access to the administrative record (permit, statement of basis, and all supporting materials)
over that same website. I am not intending to provide public notice through newspaper, and I am
not intending to provide the public access to a hardcopy of the administrative record. Please let me
know if the tribe is okay with that approach.
Looking forward to hearing back from you.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christopherOepa.eov
Page 268 of 270
-------
From: Forshprn. Derek
To: Familiare. Christophers.
Cc: McFadden. Kellv: lhowell@sbtribes.com: Forsbera. Derek
Subject: RE: Williams Corporation Northwest Pipeline Pocatello Compressor Station Pre-Draft Review
Date: Thursday, February 27, 2020 9:58:17 AM
Mr. Familiare,
On page 5, Table 1, Unit 11 -The Used Lube Oil Tank is listed twice. There is only one 2,940gallon (70 BBL) Used Lube
Oil Tank.
compressors associated wills the source.
Unit 11*
t sod I.uhc Oil Tank, 2^)40 gallons (?() HBI ); Used I.nbe
C >tl lank. 2.940 gallons (70 BBIJ; Scrubber Oil lank,
1.250 gallons (2l).S BBIJ - Scrubber lank stores oil thai is
removal (knockout) from the natural gas prior to
compression.
None
* Insignificant Emission Units (IBU).
w* Ptpelitw Pfcnfcl So Compressor Station
* No RHf IJ1 HJ '(in J>42c 5 ol
That is the only issue we found in the pre-draft review.
Thanks,
Derek Forsberg
From: Familiare, Christopher S.
Sent: Friday, February 14, 2020 9:57 AM
To: Forsberg, Derek
Cc: McFadden, Kelly ; lhowell@sbtribes.com
Subject: [EXTERNAL] Will iams Corporation Northwest Pipeline Pocatello Compressor Station Pre-Draft Review
Mr. Forsberg,
Attached is the pre-draft Title V permit, statement of basis and appendices to the statement of basis for the Williams
Corporation, Northwest Pipeline LLC - Pocatello Compressor Station facility. While the upcoming public comment period
is your opportunity to comment on the draft permit and supporting documents, we are making a pre-draft version
available to make sure we did not make any errors regarding your equipment and operations.
Please review the documents and let me know whetheryou identify any errors. I am hoping to begin the 30-day public
comment process around the beginning of March. If you can send me any questions or comments you have by COB
February 28th, that would be very much appreciated.
I am open to receiving your input and questions via email, phone, letter, etc. Feel free to call if you need me to explain
anything. I look forward to hearing from you.
Christopher Familiare
Environmental Engineer | Air Permits and Toxics Branch
U.S. EPA Region 10
1200 6th Ave, Suite 155, 15-H13
Seattle, WA 98101
(206)-553-1250 | familiare.christopher@eDa.gov
Page 269 of 270
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This email originates outside of Williams. Use caution if this message contains attachments, links or requests for
information.
Page 270 of 270
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