1. DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISIONMEMORANDUM February 1, 2005TO: Dawson Lasseter, P.E., Chief Engineer, Air QualityTHROUGH:Richard Kienlen, P.E., Engr. Mgr. II, New Source Permits SectionTHROUGH:Peer Review, Judy CupplesFROM: Herb Neumann, Regional Office at TulsaSUBJECT:Evaluation of Permit No. 2004-004-O BP America Production Company Red Oak Compressor Station West (SIC #1311) Section 17, T6N, R21E, Latimer County, Oklahoma Driving Directions: Travel on US 270 east into Red Oak. Take first available paved road to north (not OK 82), mile to T, mile west, then approximately 3 miles north and west (this becomes N4455), turn west again at E1395, mile to Section 17, look for site. INTRODUCTIONApplicant submitted an operating permit application for the Red Oak Station West, received by DEQ on April 19, 2004. Red Oak West was constructed in 1994 and has been operating without a permit. The current permit effort satisfies conditions of Consent Order 04-393 and will serve as the first operating permit for the facility. PROCESS DESCRIPTION AND EQUIPMENTThe facility is a natural gas gathering compressor station consisting of two compressors, seven tanks, and a fuel gas heater. Fugitive emissions from piping components are treated as an emission unit for this analysis. An inlet scrubber separates produced water from the natural gas. Natural gas from the producing wells is lean and there is no measurable condensate production, thus no flash emissions or condensate loading. The facility operates on a continuous basis (8,760 hours per year). Emission sources are grouped as follows.I. Internal Combustion EnginesUnit IDHP Make/Model/Serial No. TypeConst. DateCOMP1 1,232 Waukesha L7042GSI/244670Turbocharged 4SRBFeb 1999COMP2 1,232 Waukesha L7042GSI/316341Turbocharged 4SRBJune 1998 Both units are fitted with catalytic converters and air/fuel ratio controllers.

2. PERMIT MEMORANDUM 2004-004-O DRAFT2 II.Tanks Unit ID Capacity Contents Const. Date PWTK1300 barrels Produced water3/94LUBETK1 300 gallonsLube oil 3/94LUBETK2 300 gallonsLube oil 3/94 ANTIFRZTK1 300 gallons Antifreeze (Ambitrol) 3/94 ANTIFRZTK2 300 gallons Antifreeze (Ambitrol) 3/94 USEDOILTK1 300 gallonsUsed oil 3/94 USEDOILTK2 300 gallonsUsed oil 3/94III.Fugitives Various piping components, including valves, flanges and others, are considered. A list is found in the Facility Emissions section below.IV.Fuel gas heater This natural gas-fired unit is rated at 0.5 MMBTUH.FACILITY EMISSIONSI. Internal Combustion Engines Emission estimates for the two engines are based on continuous operations (8,760 hours per year) and manufacturers data for NOx, CO, and NMHC. PM and SO 2 factors are taken from Table 3.2-3 of AP-42 (7/00). Brake-specific fuel consumption is listed at 7,577 BTU/hp-hr and the heat content of the fuel stream is 1,002 BTU/CF, so fuel consumption is 9,321 SCFH at 1,000 RPM. Air emissions from the engine are discharged through a stack ten inches in diameter and 14.5 feet above grade at a rate of 5,377 ACFM and 1,055 F. Emission FactorsNOXCO NMHCPM10SO2 2.6 g/hp-hr 2.25 g/hp-hr 0.3 g/hp-hr0.0194 lb/MMBTU0.000588 lb/MMBTUPollutantEmissions (each engine) Total Emissions Lb/hr TPY TPY NOX7.06 30.9 61.9 CO 6.11 26.8 53.6 NMHC 0.81 3.57 7.14 PM10 0.18 0.79 1.59 SO20.01 0.02 0.05II. Tanks The production company applies an arbitrary non-zero condensate factor to all produced water in the formations under consideration. Use of this factor (925 lb of VOC/MMCF) for the produced water tanks yields only 0.0058 lbs/hr or 0.026 TPY of VOC. Loading losses and flash emissions are not calculated because the produced water is very close to fresh, with no sheen or indications of hydrocarbon content. 3. PERMIT MEMORANDUM 2004-004-O DRAFT3 III. Fugitives Fugitive emissions are estimated using Table 2-4 of EPAs Protocol for Equipment Leak Emission Estimates (11/95, EPA-453/R-95-017). Gas analysis shows the mol wt% of C3+ to be 0.90%. The following table shows estimated numbers of components and calculation results. Source Number Leak Factors (kg/hr)VOC Emissions (TPY)Compressors Seals12 0.008800.0092Flanges 238 0.000390.0081Open Ended Lines 16 0.002000.0028Pump Seals8 0.002400.0017Valves248 0.004500.0969Total VOC Emissions 0.12IV.Fuel gas heater Emission factors from Tables 1.4-1 and 2 of AP-42 (7/98) yield negligible results, as follow.Pollutant EmissionsLb/hrTPY NOX 0.050.22 CO0.040.18 NMHC