Kern Kings S T R Unified / htion : Central Kern County Oilfields San Joaquin Valley Air Pollution Control 2314 Mariposa Street Fremo, California 93721 (209) 488-3330 FAX (209) 488-3134 / ISSUEDATE: March 30. 1992 WTIFICATE NO 4013003 / 101 / 20 1 / 301/401/601 DATE:July 9. 1991 - EMISSION REDUCIlON CERTIFICATE 1s HEREBY G ACTUAL HISTORICAL mc : PolluIant : 10.06 283.57 61.32 0.81 330.26 71.42 0.94 154.80 33.47 0.44 Ist Qtr 4th Qtr 2.98 131.81 28.50 0.37 Amount: 2nd Qtr lbmlday 3rd Qtr CREDIT ACHIEVED BY : s-fired only of one oilfield steam generator. /
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San Joaquin Valley Unified Air Pollution Control · RESOURCE MANAGEMENT AGENCY RANDALL L ABBOlT DIRECTOR DAVID PRlCE 111 AsslsTANl CiRF-CroR AIR POLLUTION CONTROL DISTRICT February
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Kern Kings
S T R
Unified
/ h t i o n :
Central Kern County Oilfields
San Joaquin Valley Air Pollution Control
2314 Mariposa Street Fremo, California 93721
(209) 488-3330 FAX (209) 488-3134
/
ISSUEDATE: March 30. 1992 WTIFICATE NO 40 13003 / 101 / 20 1 / 301/401/601
DATE:July 9. 1991 - EMISSION REDUCIlON CERTIFICATE 1s HEREBY G
I am a citizen of the United States and a resident of the County aforesaid: I am over the age of 18 years, and not a party to or interested in the above entitled matter. I am the assistant principal clerk of the printer of The Bakersfield Californian, a newspaper of general circula- tion, printed and published daily in the City of Bakersfield, county of Kern, and which newspaper has been adjudged a newspaper of general circulation by the Superior Court of the County of Kern, State of California, under date of February 5, -_., 1952, Case Number 57610; that the notice, of which the annexed is a printed copy, has been published in each regular and entire issue of said newspaper and not in any supplement thereof on the following dates, to wit:
-
2/6
all in the year 1992
I certify (or declare) under penalty of perjury that the foregoing is true and corr- ect ..
P .,&. STgna tur e
Dated at Bakersfield, Ca FEBRUARY 4, 1992
ROSLYN T. WILLIAMS
Proof of Publication of:
5762
REQUEST FOR PUBLIC COMMENT
PROOF OF PUBLICATION
6AN JOAQUIN VALLEY UNlflED AIR POLLUTION CONTROL DISTRICT EMISSIONS REDUCTIONS FOR DEPOSr IN COMMUNITY BANK
Date: ~ 2. . .
To:- . KC4J 4 Zone, SJWAPCD
Ann: TLy From: 1L.s n Zone, SJVUAPCD
Zone Contact: L^ca c c Phone:$ (n.m
RE: EMISSIONS REDUCTIONS FOR DEPOSIT IN THE COMMUNITY BANK: .
I Descrlbe Action Generating Credits: ((%I - J O h
I ! I Company Name: % )a . . .
1 Date Reductlonr Occurred: Al&/Lz - I The above referenced actlon has generated emissions reduction credlte which are to be included in the Communlty Bank. Please include the following emounts, expressed In average daily credits for each calendar quener, in the Community Bank registry:
SJVUAPCD Form EN4
RESOURCE MANAGEMENT AGENCY
RANDALL L. ABBOTT DIRECTOR
DAVID PRICE m m A N r DIRECTOR
AIR POLLUTION CONTROL DISTRICT February 3. 1992
Mr. Raymond Menebroker. Chief California Air Resources Board Project Review Branch Stationary Source Division P. 0. Box 2815 Sacramento. CA 95812
SUBJECT: Preliminary Public Notice - Emissions Reduction Credits Project 1 ' s 4013 910703-910709
Dear Mr. Menebroker:
Enclosed for your review and comment is the analysis of Shell Western E&P's request for emissions reduction credits for Conversion of 11 Oilfield Steam Generators to Gas-Fired Only.
Also enclosed are the draft Banking Certificate documents and a copy of the preliminary public notice to be published on approximately February 7. 1992. This will start the 30-day public comment period.
Please submit your written comments on our analysis and draft documents as soon as possible to provide ample time for our review and consideration.
Thank you for your cooperation in this matter. please telephone Mr. Lance Ericksen of the Engineering Evaluation Section at
Should you have any questions
1805) 861-3682.
Sincerely,
WILLIAM J. RODDY AIR POLLUTION CONTROL OFFICER (SED)
(SJVUAPCD)
omas Paxson. P.E.
LE/cs Enclosures
2700 M" STREET, SUITE 275 BAKERSFIELD. CALIFORNIA 93301 -""_- ̂ .. ---..r.-- -."-"
(805) 861-3632
RANDALL L. ABBOTT DIRECTOR
DAVID PRICE m W T A N T DFIECTOR
RESOURCE MANAGEMENT AGENCY
AIR POLLUTION CONTROL DISTRICT February 3. 1992
Mr. Matt Haber. Chief U.S. E.P.A.- Region IX New Source Section 75 Hawthorne St. San Francisco. CA 94105
Enclosed for your review and comment is the analysis of Shell Western E&P's request for emissions reduction credits for Conversion of 11 Oilfield Steam Generators to Gas-Fired Only.
A l s o enclosed are the draft Banking Certificate documents and a copy of the preliminary public notice to be published on approximately February 7. 1992. This will start the 30-day public comment period.
Please submit your written comments on our analysis and draft documents as soon as possible to provide ample time for our review and consideration.
Thank you for your cooperation in this matter. Should you have any questions please telephone Mr. Lance Ericksen of the Engineering Evaluation Section at ( 8 0 5 ) 861-3682.
Sincerely,
WILLIAM J. RODDY AIR POLLUTION CONTROL OFFICER (SED) ASST,AIR POLLUTION CI)NTROL OFFICER (SJWAPCD)
homas Paxson. P.E. Manager. Engineering Division
LE/cs Enclosures
2700 " M STREET. S V m 275 BAKERSFIELD, CALIFORNIA 93301 -.. --̂ ..-.L- -._-_
(SOSY 861-3632
RESOURCE MANAGEMENT AGENCY
RANDALL L ABBOlT DIRECTOR
DAVID PRlCE 111 AsslsTANl CiRF-CroR
AIR POLLUTION CONTROL DISTRICT February 3. 1992
Mr. J.A. Ruhl. Manager Health. Safety & Environment Shell Western EQP. Inc. West Coast Production Division P.O. Box 11164 Bakersfield. CA 93389-1164
Enclosed for your review and comment is the analysis of your request for emissions reduction credits for Conversion of 11 Oilfield Steam Generators to Gas-Fired Only.
Also enclosed are the draft Banking Certificate documents and a copy of the preliminary public notice to be published on approximately February 7, 1992. This will start the 30-day public comment period.
Please submit your written comments on our analysis and draft documents as soon as possible to provide ample time for our review and consideration.
Thank you f o r your cooperation in this matter. please telephone Hr. Lance Ericksen of the Engineering Evaluation Section at
Should you have any questions
(805) 861-3682.
Sincerely,
WILLIAM J. RODDV AIR POLLUTION CONTROL OFFICER (SED)
(SJWAPCD)
LE/cs Enclosures
2700 "M" STREET, S V m 275 BAKERSFIELD, CAuFORNlA 93301
PRIPmD ON RECYCLED PAPER
(805) 861-3682
Date: Time:
kith: Title:
Company : ,CJ e c3 Phone :
APCD Representative: Lance Ericksen Title APE
Subject of Conversation:
Summary of Conversation:
March 13, 1992
Shell Western E&P Inc. @ P.O. Box 11164
Bakenlisld. CA 93389
Mr. Thomas Paxson, P.E. Manager, Engineering Eva1 uati on San Joaquin Valley Unified Air Pollution Control District Kern Zone 2700 "M" Street, Suite 275 Bakersfield, CA 93301
Dear Mr. Paxson:
SUBJECT: NOTIFICATION OF OIL FIRING EQUIPMENT REMOVAL ON STEAM GENERATORS ASSOCIATED WITH ERC APPLICATIONS
REQUEST FOR INSPECTION PROJECT NOS. 911202 & 910703 - 910709
This letter shall serve as official notification that oil firing equipment has been removed from all steam generators for which emission reduction credits are being sought (see attached listing). We request that an APCO inspection be completed as soon as possible so that PTO's can be issued and processing of the pending ERC applications can be completed.
Our Mr. Jeff Elliott will be happy to escort or accompany you to the various steam generator locations. make arrangements.
Should you have any questions or need further information, please contact Ms. Eileen Lindsay at 326-5442.
Sincerely ,
You may contact him at 326-6045 to
* J."A. Ruhl k' Manager Health, Safety & Environment West Coast Production Division
E FL
Enclosure
cc: Mr. Steve Beyn Senior Specialist Kern Zone
CBCD9207203 - 0001.0.0
STEAM GENERATORS TO BE INSPECTED
KERN RIVER F IELD
SWEPI GENERATOR NAME
PRICEWELL #4 " #5 " #7 " #8 " #9 " T-2
BISHOP #69 RAMBLER # 1
" #5 " #6 " #13
MCMANUS #T-1 " #8
MIDWAY PREMIER #2
PTO NUMBER
40134231' 094K 096K 098K 099K 0045
002E OOlF ~~~
l l 0 C 0030
MT. POSO FIELD
SWEPI GENERATOR NAME PTO NUMBER
CLUSTER 0 iY1 " 112 " c 4 " # 5 " #6
CLUSTER A # 1 " #2 " # 3 " 84 " #6
CLUSTER C #2 " # 3 " #6
NPU #2 84 #5
CLUSTER B #2 " #3 " #4
,I
40130795 0805 082 I 0835 084 I 0405 0455 044L 043 I 041K 0295
Shell Western E&P Inc. @ P.O.Bo.11164 B a k e n f i . W 95389
October 30, 1991
HAND DELIVERED
M r . Thomas Paxson, P.E. Manager Engineer ing Eva lua t ion San Joaquin Va l ley U n i f i e d A i r P o l l u t i o n Contro l D i s t r i c t Kern Zone 2700 "M" S t ree t , Sui te 275 Bakers f ie ld , CA 93301
Dear Mr. Paxson:
SUBJECT: ADDITIONAL DATA FOR ERC APPLICATIONS FOR CONVERSION OF GENERATORS TO GAS FIRED ONLY - PROJECT # ' S 910703 - 910709, APPLICATION # ' S 4013094 E -096; -001; -026; -003; -002 E -072; -032 E -085; AND -028 E -081
Th is l e t t e r s h a l l a lso serve as formal n o t i f i c a t i o n t h a t t h e sub jec t She l l Western EEP Inc. (SWEPI) generators have ceased o i l f i r e d opera t ions and t h a t the emissions reduct ions app l i ed f o r have a c t u a l l y occurred.
Per your l e t t e r o f September 30, 1991, enclosed i s fuel use data f o r the years 1989 and 1990 w i t h corresponding q u a r t e r l y emissions f o r t h e sub jec t generators. A lso inc luded i s a summary of q u a r t e r l y emissions by app l i ca t i on . c a l c u l a t i o n s are based on t h e formula i n the c u r r e n t SJVUAPCD New Source Review Rule: AER = CE*HAE. Also note t h a t s ince we do not have o i l f i r e d source t e s t s f o r "20's" with which t o c a l c u l a t e H i s t o r i c a l Actual Emissions, those emissions are based on approved emission f a c t o r s , as discussed w i t h M r . Lance Er ickson. The proposed lb/MMBtu l i m i t s used i n the Contro l E f f i c i e n c y c a l c u l a t i o n s are t h e c u r r e n t l y approved SLC f a c t o r s .
As per our October 22, 1991 FAX t o you, t h e emission
Enclosed i s an a p p l i c a t i o n t o modify the au thor ized lbs/day l i m i t on our SLC Compliance Plan f o r each of the sub jec t generators and our check number 058362 f o r $60 t o cover the f i l i n g fee. surrender ing our o i l f i r i n g c a p a b i l i t y and app ly ing f o r ERC's, t h e au thor ized l i m i t s w i l l be reduced. Per telephone conversat ion between M r . Er ickson and our Mr . Steve Messner, these l i m i t s were determined by m u l t i p l y i n g the cu r ren t gas f i r e d SLC lb/MMBtu emissions fac to rs - genera tor ' s r a t i n g .
As a r e s u l t o f
CBCD9130202 - 0001.0.0
NOV 2 0 1991 ' KERN WUNTT AIR
POLLUTION CONTROC DISTRICT
Per your September 30th l e t t e r , a l so enclosed i s ou r check number 000204 f o r $2510 t o cover t h e a d d i t i o n a l fees requ i red under SJVUAPCD Rules f o r banking c e r t i f i c a t e app l i ca t i ons . Fees are broken as fo l l ows :
P r o j e c t 910703 = $350 P r o j e c t 910704 = 410 P r o j e c t 910705 = 350 P r o j e c t 910706 = 350 Pro jec t 910707 = 350 P r o j e c t 910708 = 350 Pro jec t 910709 = - 350
TOTAL $2510
Should you have any quest ions o r need f u r t h e r in fo rmat ion , please contac t Mr . S. D. (Steve) Messner a t 326-5982.
S incere ly ,
J. A. Ruhl Manager Health, Safety & Environment West Coast Product ion D i v i s i o n
EFL
Enclosure
CBCD9130202 - 0002.0.0
. . .“ - . .. .- RESOURCE MANAGEMENT AGENCY
RANDALL L. ABBOlT DIRECTOR
DAVID PRICE 111 ASSISTANl DIRECTOR
AIR POLLUTION CONTROL DISTRICT
December 6. 1991
’ Anr Pdlulm bnld hwnct W l W J. ROM)Y. APCO
tnvvomnlal H u h h I*p.nmPnl
STEVE M c C A U V . R M S . DIRECTOR
pLs””lng & De”e!oF.mnl SeNICes Deparlmmt
TED JAMES, NCP. DIRECTOR
Mr. J.A. Ruhl. Manager Health, Safety and Environment Shell Western E&P, Inc. West Coast Production Division P.O. BOX 11164 Bakersfield. CA 93389-1164
SUBJECT: Application t ‘ s 4013003/101/201/301/401/601 - Project t 910706 In reply refer to ATC t ’ 8 & Project t
Dear Mr. Ruhl: , .
This office has received your applications fo r Emission Reduction Credit Banking Certificates the following: For Conversion of Steam Generators to Gas-Fired Only: They have been reviewed by our staff, additional information has been requested, and you have submitted additional i’nformation. Based on your submittal, your applications have been found to be complete: i.e., you have submitted enough information to enable the District to initiate its review of your project.
Please be advised that during the course of review, the District may request additional information for the purpose of clarifying, amplifying, correcting or otherwise supplementing the information on file.
Thank you for your cooperation in filing the necessary applications. Should you have any questions please telephone Mr. Lance Ericksen of the Engineering Evaluation Section at ( 8 0 5 ) 861-3682.
Sincerely,
WILLIAM J. RODDY AIR POLLUTION CONTROL OFFICER (SED)
(SJWAPCD)
B omas Paxson, P.E.
Manager. Engineering Division
LE/cs
2700 “ M STREET, SUITE 275 BAKERSFIELD, CALlFORNlA 93301 (805) 861-3682
. __. - ,!
RESOURCE MANAGEMENT AGENCY ,:, -
RANDALL L. ABBOTT DIRECTOR
DAVID PRICE 111 ASSISTM DIRECTOR
AIR POLLUTION CONTROL DISTRICT
September 30, 1991
Air Pollution Control District W l u l A M J. RODDY. APCO
Environmentd Health Sowices Dewnmnt STEVE McCAUEY. REHS, DIRECTOR
Wnning & Development Services Domartmonl TED JAMES, AICP. DIRECTOR
Mr. J. A. Ruhl, Manager Health, Safety & Environment Shell Western E & P Inc. West Coast Production Division P.O. Box 11164 Bakersfield, CA 93389-1164
SUBJECT: ERC Application t’s 4013003/101/201/301/401/601 - Project t910706 In reply refer to ERC t’s EL Project t
Dear Mr. Ruhl:
Your applications for Emission Reduction Banking Certificates for the following project have been received by this office: Conversion of Generators to Gas Fired Only.
After reviewing this application, our office sent you a list of deficiencies which had to be corrected before processing could commence (see attached copy). These items are necessary to satisfy the requirements of Rule 210.3/230.1 of the District’s Rules and Regulations.
Because we have not received sufficient information from you, this office will have no choice but to deny your applications for ERC Banking Certificates within thirty.days should you still not supply the required information.
Because the requested information was not received prior to September 19. 1991. any further processing of the applications must be under the SJVUAPCD Banking and NSR rules adopted on that date. Therefore. in order to proceed with the applications, the District will required:
1. Actual historical fuel use and corresponding emissions ucalendar auarter for the two years preceding the date of application.
ERC Banking Credits for
2. Additional fees of $350. Under the SJVUAPCD Rules adopted September 19, 1991, fees for banking certificate applications are $650. This fee is for all air contaminants and additional fees may be requested by the District if the actual time and materials exceed the initial fee amount. Because you have previously paid $300, the balance due before processing can proceed is $350.
2700 “M” STREET, SUITE 275 BAKERSFIELD, CALIFORNIA 93301 (805) 861-3682
.Mr. J . A. Ruhl Shell Western E & P Inc. September 30, 1991
Page 2
Submission of the above information within 30 days will enable the District to proceed with processing of the applications.
Thank you for your cooperation in this matter. Should you have any questions, please telephone Mr. Lance Ericksen of the Engineering Evaluation Section at (805) 861-3682.
Sincerely.
WILLIAM J. RODDY Air Pollution Control Officer (SED) Asst. bir Pollution Control Officer (SJVUAPCD)
omas Paxson, P.E. anager. Engineering Division
LE/bd Attachment
RESOURCE MANAGEMENT AGENCY
RANDALL L. ABBOlT DIRECT 0 R
DAVID PRICE ni ASSTANT DIRECTOR
AIR POLLUTION CONTROL DISTRICT
August 13, 1991
Air Pollutm Control Dslr lc l
WILLIAM J . RODDY. APCO
Envnomrntd Health hwlcor LXpanmnl STEVE McCAUTY. RFHS. DIRECTOR
Raminq & Dwobpmnl SorVhes Dopart- TED JAMES. AICP. DIRECTOR
Mr. J. A. Ruhl. Manager Health, Safety h Environment West Coast Production Division Shell Western E h P Inc. P.O. Box 11164 Bakersfield, CA 93389-1164
SUBJECT: Application #IS 4013003/101/201/301/401/601 - Project #910708 In reply refer to Application I ' s & Project #
Dear Mr. Ruhl:
Your applications for Emission Reduction Banking Certificates for the following project have been received by this office: ERC Banking Credits for conversion of generators to gas fired only.
A preliminary review of these applications revealed that they are incomplete and that the following information will be required before processing can commence:
1. Documentation that reductions have actually occurred. i.e.. that o i l firing has ceased.
2 . Fuel use data for two years preceding date of application and corresponding emissions.
Please be advised that failure to provide the necessary information within thirty days may result in denial of the requested Authority to Construct. Thank you for your cooperation in this matter. Should you have any questions, please telephone Mr. Lance Ericksen of the Engineering Evaluation Section at (805) 861-3682.
Sincerely,
WILLIAM J. RODDY Air Pollution Control Officer (SED)
r (SJVUAPCD)
LE/bd
2700 " M STREET, SUITE 275 BAKERSFIELD, CALIFORNIA 93301 (805) 861-3682
. ,,.,... ~, , . ~ , ,.,. .. ~ ..,. .: . .. . .... . .. ~. . . ; .. . . . ,: ,.. . .~ ...,. . . . ~ ~ .,,.., I ::.. , . . . ~. ... .. . . .~ . ~. ~.. ,... ,. .... . .. . K'fkN .CO'U.NTY'.AlR P O L L U T l O N C O N T R O L DISTRICT ,~....
2700 "M" Street. S u i t e 275 Bakersfield. Cal i fornia 93301 Telephone: ,...
5. Q T Y P i OR PRINT NAME OF SIGNER:
J . A . R u h l
APPLICATION FOR:
~. TITLE' OF .SIGNE3: tianager H e a l t h , S a f e t y 6 Environment West C o a s t P roduct ion D i v i s i o n
DATE: . PHONE NO.:
(805 ) 326-5900
0 Aurhoriry IO Construe: (ATCI 0 Permit to Operate IPTO) a Banking G r t i f i w i e
AN APPLICATION IS REQUIRED FOR EACH SOURCE OPERATION AS DEFINED iN RULE iaz, SECTION cc.
1 1. PERMIT T O BE ISSUED TO: Name of organization IO operate the following cquipmenr:
! . . S h e l l Westixn E6P Inc.
Validaribn (For APCO Use Only)
>
I . . ! 2. .MAILING ADDRESS:
JUl9 19911 K E R N COUNTY AIR
. 01 t ilTlON f.ONVlOI DISrRlr'
P.O. :Box' 11.164,' B a k e r s f i e l d , CA: ' 93389-1164 Zip Code:
1 i . .
j 3. LOCATION AT WHICH THE EQUIPMENT IS TO BE OPZRATED:
F I L I N G FEE: s&X%i i~ & RECEIPT NO.: O ? P L DATE: 7 ? g /
I
S e c t i o n 32 > T 27s 3. R 28s I POSO CREEK F i e l d , MIDWAY PREMIER Lease
1 4. GENERAL NATURE OF BUSINESS:
I C r u d e O i l and G a s . P r o d u c t i o n
5. EQUIPMENT FOR WHICH APPLICATION IS MADE:
PTO N u m b e r s 4013003 MIDWAY PREMIER #2. GENERATORS
R e q u e s t f o r . B a n k i n g C e r t i f i c a t e f o r E m i s s i o n - R e d u c t i o n C r e d i t s i n - c o n j u n c t i o n w i t h the surrender of o i l f i r e d ' c a p a b i l i t y . . .
I E m i s s i o n R e d u c t i o n C r e d i t s are requested i n ' the f o l l o w i n g a m o u n t as p e r a t tached calculat ions: 1 .
. . . T o t a l PM C r e d i t s : 10.02 lb /day
Provide additional information as required by Din r in "Insrructions".
6. T Y P E AND ESTIMATED COST OF AIR POLLUTION CONTROL EQUIPMENT:
7. TYPE AND ESTIMATED C O S T , O F BASIC PROCESS EQUIPMENT: .
. . . . . . . . , . . . . . . , : . . ~ . . . . . . . . . . . . . . . . . ~&N'.cuuN i ~ ' Y ' . i I R ' POLLUTION CONTROL DISTRICT
Bakersfield. California 03301 i . , . . .~.i.. . . .,. . .
2700 -M" Street. Suite 275 Telephone: (805) 861-3682 .'.
.. . I . .
APPLICATION FOR:
TITLE OF SIGNEk: , ' .. Manager Health, Safety & Environment West Coast Production Division
0 A T C - Modifierion 0 PTO - Modifletion 0 A T C - Renewal ' PTO -Transfer of Ownership
A N APPLICATION IS REQUIRE0 FOR EACH SOURCE OPERATION AS DEFINED iN RULE 102, SECTION cc.
1 1. PERMIT T O BE ISSUED TO:
I ..Shell Western ESP Inc.
1 2. .MAILING ADDRESS: '.
; ' 3. LOCATION A T WHICH T H E EQUIPMENT IS TO BE OPiAATED:
Name of organization IO opcnre rhe following equipment:
. . P.O. Box 11164, Bakersfield, CA ' . .
. ' 93389-1164 ' ' . .
Zip Code:. I ..
. . Section 32, T 27S..R28E, POSO CREEK Field, MIDWAY PREMIER Lease I i I 4.
1 GENERAL NATURE O F BUSINESS:
Crude Oil and Gas.Producrion
! 5. EQUIPMENT FOR WHICH APPLICATION IS MADE: I PTO Numbers 4013003 MIDWAY PREMIER #2 GENERATOR
. Request for.Banking Certificate for Emission.Reduction Credits in conjunction with the surrender of oil fired'capability.
Emmission Reduction Credits are requested calculations:
. . in the following amount as per attached
Total CO Credits: 7.22 lb/day
Provide additional information as required by District "lnnrur20ns".
6. TYPE A N D ESTIMATED COST OF AIR POLLCrrlON CONTROL EaUIPMENI:
7. TYPE AND ESTIMATED COST OF BASIC PROCESS EQUIPMENT: .
i \ i i L I \ LUJIYI HIH PULLUIIUN CONTROL DISTRICT 2700 "M" Street. Sui te 275 Bakersfield. California 93301 Telephone: (805) 86'1-3682
3. fi PE OR PRINT NAME O F SIGNER:
r J . A . Ruhl
.' - .
APPLICATION FOR:
TITLE OF SIGNER: . 34anager Heal th , S a f e t y ' & Environment West Coast Product ion D i v i s i o n
DATE: - P H O N E NO.:
6/,,,/q, (805) 326-5900
0 Author i ry to Conrrruc:'(ATC) 13 Permit to per are I P T O ~ a Banking G n i f i o t e
0 A T C - Modif ia r ion 0 PTO - Madifjstion 0 irans ier of ~ ~ a r i o n
0 ATC - Renewal ' 0 PTO -Transfer of Ownenhip
A N APPLICATION IS REOUlRED FOR EACH SOURCE OPERATION AS DEFINED i N RULE 102, SECTION cc.
1. P E R M I T TO BE ISSUED TO: Name of organization io operate the follom'ng cquipmenr:
. . S h e l l Western EhP Inc . . .
2. . M A I L I N G ADDRESS: P;O. Box 11164, Bakers f ie ld , CA . ' 9 3389- 1 1 64. . .
Zip Code:
3. LOCATION AT WHICH T H E EQUIPMENT IS TO 8 E OPERATED:
S e c t i o n 32 , T 27s , . R 28E , POSO CREEK Fie ld , MIDWAY PREMIER Lease
4. G E N E R A L NATURE O F BUSINESS: Crude O i l and Gas.Production
EQUIPMENT FOR WHICH APPLICATION IS MADE: 5.
' PTO Numbers 4013003 MIDWAY PREMIER #2 GENERATOR
KtkN COUNTY 'A IR POLLUTION C O N T R O L D I S T R I C T 2700 "M".Slreet. Suite 275 Bakersfield. California 93301 Telephone: (805) 861-3682
q O [ y q / g ) 1 . .
APPLICATION FOR:
0 Authority i o Consiruc: IATCI 0 Permit IO Operarc LPTO) 8anking Cenificart
0 ATC - Modi f ia t ion 0 PTO -. Modiflarion 0 Transier o f Locarion
0 ATC- Renewal 0 PTO -Transfer of Ownership
A N APPLICATION IS REQUIRED FOR EACH SOURCE OPERATION AS DEFINED IN RULE 102, SECTION cc.
1. PERMIT T O BE ISSUED TO: Name of organizarion i o operare the following equiprnenr:
.. S h e l l Western E&P Inc. . . 2. .MAIL ING ADDRESS:
93389-1164 . . Zip Code:
. . P . O . Box 1.1164.. Bake r s f i e ld , Ch;
3. LOCATION AT WHICH THE EQUIPMENT IS TO BE OPERATED:
S e c t i o n 32, T27S , .R28E , POSO CREEK Fie ld , MIDWAY PREMIER Lease
4. GENERAL NATURE OF BUSINESS: Crude O i l and Gas-Product ion
5. . EQUIPMENT FOR WHICH APPLICATION IS MADE:
MIDWAY PREMIER.#2 GENERATOR . .
PTO Numbers 4013003
.. Request for. Banking C e r t i f i c a t e f o r Emission- Reduction C r e d i t s i n conjunct ion w i t h t h e s u r r e n d e r of o i l f i r e d - capab i l i t y .
E m i s s i o n Reduction Cred i r s a r e requested c a l c u l a t i o n s :
. . . . i n the fo l lowing amount as pe r a t t a c h e d
T o t a l SO2 Cred i t s : 349.68 lb/day
Provide additional informarion as required by Dinrict "I~uucrions". .. . 6. TYPE AND ESTIMATED COST OF AIR POLLUTION CONTROL EQUIPMENT:
7. TYPE AN0 ESTIMATED COST,OF BASIC PROCESS EQUIPMENT: . . . . . . . .
TITLE OF SIGNER: 8. SIGNATURE . .
+tanager Heal th , S a f e t y & Environment West Coast Product ion Div is ion
9. @ Y P E OR P ~ I N T NAME OF SIGNER: p.3::E; .PHONE NO.:
J . A . Ruhl &//5/9, (805) 326-5900
,...,~ !$ D q & E @ q C W D Validarion (For APCO Use Only1
a A T C - Modification 0 PTO -. Modifletion 0 Transier of Location.
0 ATC- Renewal ' [7 PTO -Transfer of Ownership .
AN APPLICATION IS REQUIRED FOR EACH SOURCE OPERATION AS DEFINED IN RULE 102, SECTION cc.
1. PERMIT TO BE ISSUED TO: Name of organization to operate the following equipment:
..Shell Western E&P Inc. . .
93389-1164 2. .MAILING ADDRESS:
P.O. Box 11164, Bakersfield, CA Zip Code:
3. LOCATION'AT WHICH THE EQUIPMENT IS TO BE OPERATED:
section32 , T27S ,.R28E , POSO CREEK Field,MIDWAY PREMIER Lease
4. GENERAL NATURE OF BUSINESS: Crude Oil and Gas.Production
5. . EQUIPMENT FOR WHICH APPLICATION IS MADE:
PTO Numbers 4013003 MIDWAY PREMIER #2 GENERATOR
. Request for.Banking Certificate for Eiission-Reduction Credits in conjunction with the surrender of oil fired'capability.
Emission Reduction Credits are requested calculations :
. . . in 'the following amount as per attached
Total NOx Cr,edits: 46.39 lb/day
. .
Provide addirional information as required by Distrin "lnsuuaions".
TYPE AND ESTIMATED COST OF AIR POLLUTION CONTROL EOUIPMENT: 6.
7. TYPE AND ESTIMATED COST. OF BASIC PROCESS. EOUIPMENT:
. . . . . . . . .
~ 8 . SIGNATUZE O F A P P L W : . . .I TITLE OF SIGNER: . .
I I Nanager Health, Safety & Environment I / / I West Coast Production Division
9 . v T Y P E OR PRINT hAME OF SIGNER: I DATE: I .PHONE NO.:
b
Projects 910703-910709
Shell Western Bxploration and Production Inc. SJ Division
!hiling address: Phone :
P.O. Box 11164 Bakersfield, CA 93389
(805) 326-5442
Company Contact: Processing Engineer:
Eileen Lindsay Environmental Engineer
Project:
4013 910703-910709
Project Location:
Central Kern County Oilfields
INDEX Section
I. Proposed Emission Reduction Credit
11. Rules and Regulations
Rule 220.1 Requirements
Rule 230.1 Requirements
Other Applicable Rules and Regulations
111. ERC Validation
IV. Emission Calculations
Lance Ericksen Air Quality Engineer
Start date: 7/9/91 Finish date: 1/ 30/92 Deemed corp: 12/6/91 WP File 92LE004 Final Review Not Req.
V. Conclusions
VI. Recommendations
!%aLtt 2 z
It 70 7 0
<
Projects 910103-910109
I. Pr owsed E mission R eduction Cr e d u
Page Z '
The applicant is requesting emission reduction credits for the conversion of 11 steam generators from dual firing to gas fired only. Credits are requested for reductions in PM10, S02, S04, NO2 and CO.
11. Rules and Renulations
A. Rule 220.1 Requirements: (9-19-91 SJWAPCD)
1. Subsection I1 - Definitions A. Actual Emissions: measured or estimated emissions which
most accurately represent the emissions from an emissions unit.
B. b-: the reductions of Actual Emissions from an emissions unit selected for emission offsets or banking, from the baseline period. Actual emissions reductions shall be calculated pursuant to Section V of this rule and meet the following criteria:
1. shall be real, enforceable, quantifiable, and permanent; and
2. (considerations for early implementation of BARCT), and
3. shall be in excess of any emissions reduction which at the time the application for an Authority to Construct is deemed complete is:
a. required or encumbered 'by any laws, rules, regulations, agreements, orders, (This provision does not include controls required by this rule.); or
b. attributed to a control measure noticed for workshop, or proposed or contained in a state implementation plan, except for reductions outlined in Subsection II.B.2. (This provision does .not include controls required by this rule.); or
C. proposed in the district's adopted air quality plan for attaining the reductions required by the California Clean Air Act except for reductions outlined in Subsection II.B.2.
L
Projects 910703-910709
JI. ;1 Rules a t CO
A. Rule 220.1 Requirements: (9-19-91 SJVUAPCD) (Cont.)
1. Subsection I1 - Definitions (Cont.)
Page 3
F. Baseline Period shall be either 1) two consecutive years of operation immediately prior to the submission of the complete application; 2) another tim period of at least two consecutive years within five years immediately prior to the submission of the complete application determined by the Control Officer as more representative of normal source operation; 3) a shorter period of at least one year in cases where the emissions unit has not been in operation for two years so long as this represents the full operation history of the stationary source; 4) emission units which have been in operation for less than one year shall have no baseline period for determining actual emission reductions.
2. Subsection V - Calculations General
(calculation procedures) .... shall be performed separately for each pollutant, and for each emissions unit .... All calculations shall be performed on a quarterly basis, unless specified otherwise.
B. Terms
HAE = Historical Actual Emissions .... emissions which have actually occurred .... must be discounted for reductions required o r encumbered by laws, rules etc and ... control measures noticed for workshop or proposed in the AQIA
IPE = Increase in Permitted Emissions
PE = Potential to Emit from the new or modified emissions unit
HAPE = Historical Adjusted Potential Emissions shall be the potential to emit prior to modification adjusted for the proposed control efficiency.
HAPE = PEPM ( 1 - CE) PEPM = Potential to Emit from the emissions unit prior to modification
CE Control Efficiency of the proposed air pollution control technology.
IPE = PE (for modified unit) - HAPE (modified unit prior to modification)
Projects 910103-910109
11. R ules and R enula tions I Cont. 1
A. Rule 220.1 Requirements: (9-19-91 s J W A P C D ) (Cont.)
2. Subsection V - Calculations (Cont.) p p
Page 4
IPE = PE(for modified unit) - HAPE(modified unit prior to modification)
Subsection V.E. General
If the actual emissions reductions, after 10% deduction for community bank allowance, are greater than the increase in permitted emissions, the difference can be banked. Actual emission reductions are positive numbers. All negative numbers calculated using these procedures shall be set to zero.
Subsection V.E.l. Actual emission reductions solely due to reduction in oDeratina hours and/or throuRhDut rates.
3 AER = HAE
1 installation of a control device o r more efficient process or material.
AER = (HAE * CE) the potential to emit after modification shall be equal to potential to emit prior to modification times 1 minus the control efficiency; or
PE (after modification = PEPH * (1-CE) C. Subsection VI. - Community Bank Allowance
Subsection V1.B.
The community bank is funded by preserving a portion of all Actual Emission Reductions calculated in accordance with Subsection V.E. of this rule, and shall be funded by the following:
1. 10 percent of all onsite actual emissions reductions since August 22, 1989.
2. 10 percent of all onsite actual emissions reductions created after the date of adoption of this rule.
Projects 910703-910709
11. Rule s and Renula t ions ( Cont .)
B. Rule 230.1 Requirements: (9-19-91 SJWAPCD)
Page f
1. Subsection 111 - Definitions c. Bankable Emission Reductions - emission reductions of
pollutants and their precursors for which ambient air quality standards exist, and which meet the provisions of this Rule. Such reductions may be deposited in the District’s ERC Bank. Once banked and certified, the emission reductions become Emission Reduction Credits (ERCs).
g. Emission Reduction Credits (ERCs): reductions of actual emissions emission unit recognized by the District as available for use as tradeoffs or offsets in accordance with the requirements of this Rule. To be eligible for certification as ERCs, emissions reductions must be real, surplus, permanent, quantifiable and enforceable. All emission reduction meeting these requirements may be certified as ERCs.
2. Subsection IV. - Eligibility of Emission Reductions B. Emissions Reductions Occurring After September 19, 1991
For emission reductions occurring after the September 19, 1991, the following criteria must be met in order to deem such reductions eligible for banking:
1. The emission reduction are real, surplus, permanent, quantifiable, and enforceable.
2. Actual emission reductions are calculated in accordance with the calculation procedures of the District’s New Source Review Rule and comply with the definition of Actual Emission Reductions of the District’s New Source Review Rule. Adjustment to emissions reductions for the community bank shall be made at the time the reductions a quantified pursuant to the District’s New Source Review Rule.
3. An application for ERC has been filed no later than 180 days after the emission reductions occurred.
Projects 910703-910709
11. Rul es and Regulations (Cont. 1
B. Rule 230.1 Requirements: (9-19-91 SJWAF'CD) (Cont.)
2. Subsection IV. - Eligibility of Emission Reductions (Cont.) 4. For non-permitted emission units emissions must have
been included in the 1987 emissions inventory and the source creating ERCs shall apply for and acquire a Permit to Operate subject to enforceable permit conditions which ensures that the emission reductions will be provided in accordance with the provisions of this rule, and shall continue for the reasonably expected life of the proposed stationary source. If the district, pursuant to state laws, is prohibited to permit the emission unit, the stationary source creating ERC's shall execute a legal binding contract with the District which ensures that the emission reductions will be provided in accordance with the provisions of this rule, and shall continue for the reasonably expected life of the proposed source.
3. Subsection V - ERC Certificate Application Procedures: E. Applications for reduction certificates shall be
submitted within 180 days after the emission reduction occurs. For reductions covered under IV.A., ERC Certificate applications shall be submitted within 180 days of the adoption date of this rule (9-19-91).
4. Subsection VI - Registration of ERC Certificates: A . May only grant ERC Certificates after the emissions
reductions have occurred upon satisfaction of the following provisions:
1. A revised P to 0 has been issued if the emission reductions were created as a result of greater operating efficiencies or from application of more efficient control technology.
2. If the reductions were created due to shutdown of a permitted emissions unit, the relevant P to 0 has been surrendered and voided.
G. Delivery by the District of an ERC Certificate shall be accomplished by person or by registered mail.
Projects 910703-910709
11. Rul es an d Renula tione ( C ont. 1
C. Other Applicable Rules and Regulations
Rule 424 - Sulfur Compound Emissions - emissions from existing steam generator shall not exceed 0.11 lbm sulfur per million BTU of heat input on a field wide average basis - excluding small steam generators up to a total of 165 million BTU per hour of heat input operated by a small producer
Rule 425.1 - NOX Emissions from Steam Generators Used in TEOR Central Stationary Source - large existing NOX emissions from existing steam generators in NO per million BTU of heat input shall not exceed; 0.35 oil fire& 0.14 gas fired for large existing steam generators which operated by small producers, 0.20 oil fired 0.14 gas fired for large steam generators operated by producers other than small producers or 0.38 oil fired 0.18 gas fired for small steam generators
SLC plan requirements - These generators are subject to the SLC requirements of Rule 220.1 and must comply with the District policy referenced in Subsection II.GG. of Rule 220.1.
Projects 910703-910709
A . Rule 220.1 Requirements
1. These steam generators have been in operation under valid permit to operate, actual fuel use data and source test emission factors have been used provided to document emissions. This data has been used to calculate emissions pursuant to Rule 220.1 Subsection V. the reductions therefore satisfy the Requirements of Rule 220.1 Subsections 1I.a. and 1I.b.
2. The baseline period used in emission calculations is the two consecutive years preceding the date of complete application. Therefore the baseline period is consistent with Rule 220.1 Subsection 1I.F. and the reductions are based on historical actual emissions.
3. The calculations have been preformed on a quarterly basis for each air contaminant. The reductions are due to the addition of emissions controls and have been calculated according to Subsection V.E.3. Therefore calculations satisfy the requirements of Rule 220.1 Subsection V.
4. The emission reductions occurred after August 22, 1989 therefore 10% of reductions should be deposited to the community bank pursuant to Subsection VI.B.l. The amount of credit available to be banked by the source will be reduced by 10% for the community bank. The calculation of emission reductions is therefore consistent with the Requirements of Rule 220.1 subsection VI. community bank.
B. Rule 230.1 Requirements
Subsection IV. Requirements
1. These emissions reductions are authorized by authority to construct issued after September 19, 1991. The applicant has notified the District that these ATCs have been implemented and a new permit to operate may be issued. Therefore the reductions occurred after September 19, 1991 and may be banked subject to the requirements of Subsection 1V.B.
2. To be eligible for banking reductions Subsection V.B.1. requires such reductions be real, surplus, permanent, quantifiable and enforceable:
Projects 910703-910109
Lhk ERC Validation C ont B. Rule 230.1 Requirements Cont.
Real: The reductions have actually occurred as authorized by ATC oil firing has ceased and an new permit prohibiting oil firing is being prepared. Emissions have been calculated using representative source test emission factors and actual fuel use data. The applicant has submitted acural fuel use for each quarter and has indicated that the original records are available upon request. Therefore the reductions are real.
SurDlus: A review of District records shows the reductions have not previously been used as tradeoffs or offsets. No District, State or Federal law, regulation or agreement require these reductions. The SJVUAPCD draft AQIA plan includes proposed control measures that may impact oil fired fuel burning equipment. However, the AQIA plan was not adopted when these applications were deemed complete. Therefore the reductions are surplus.
Permanent: These reductions are the result of conversion to gas firing only. This type of reduction is not dependant on control efficiency of post combustion equipment and is not expected to change over time. The steam generators will continue to serve the same function and no emissions will be transferred to other equipment. Because these steam generators are included in the Rule 424 average compliance plan they must be maintained at there oil fired level to insure permanence. Therefore the reductions are permanent.
Quantifiable: The emission reductions have been calculated using representative source test emission factors for each steam generator when oil firing, the proposed gas firing factors have been documented by source tests of similar equipment. Historic actual emissions are based on actual fuel use for two years. The emissions reductions may therefore be quantified for theses specific emissions units. Therefore the reductions are quantifiable.
Enforceable: The steam generators will be issued new permits to operate which require gas firing only. Annual District inspection of this equipment, record keeping and compliance testing as required by District policy and permitting actions will insure the reductions are enforceable.
. Projects 910703-910709 Page [ O m Fm Val idat i on Cont, B. Rule 230.1 Requirements Cont.
2. Rule 230.1 subsection IV.B.2. requires the calculation of actual emission reductions be in accordance with Rule 220.1. The emission calculations have been preformed according to the procedures in Rule 220.1 subsections V. (see Rule 220.1 requirements). Therefore the reductions meet the requirements of Rule 230.1 subsection V.B.2.
3. Rule 230.1 Subsection IV.B.3. and Subsection V require an application for reductions be submitted no later than 180 days after the reduction occurs. ATCs to remove oil firing provisions were issued 1/13/92 and have now been implemented.' The application for emission reduction credits was therefore made in a timely manner.
4. Rule 230.1 subsection IV.B.4. requires that non-permitted emission units must have been included in the 1987 inventory. These steam generators are under District permit and is therefore not subject to this requirement.
5. Rule 230.1 Subsection VI requires a revised P to 0 be issued for reductions created as a result of greater operating efficiencies or from application of more efficient control technology. The applicant has notified the District that these ATCs have been implemented and new PTOs will be prepared. Therefore the reduction satisfy this requirement.
C. Other Rule Requirements
- 1. Rule 424
Theses steam generators are currently included in the applicants Rule 424 plan (sulfur compounds from oilfield steam generators). To insure the reductions in SO2 are real and permanent the generators must stay in the plan at their oil fired levels. Because Rule 424 allows averaging to meet the Rule limits reductions if the level for these generators were allowed to be reduced for Rule 424 averaging increases could occur at other emissions units and the reductions will not be real and permanent. 2L peer \ \ A Q Cofy o. 8-h F 1 . z ~
Pule '425.1
The source test emission factors used to document actual emissions are below the rule 425.1 limit for NO2 of 0.2 lbm/MMBtu (see pages $6-5-h) . for NO2 when gas firing are below the Rule 425.1 limit of 0.14 lbm/MMBtu and will be validated by annual source testing. Therefore no adjustments are necessary for Rule 425.1.
The proposed emission factors
. Projects 910703-910709
III. ERC Validation Cont, C, Other Rule Reauirements
3. -
These steam generators are included in the applicants SLC plan for the central heavy oil production stationary source. Currently each steam generator has capacity and use factors of 80% (over all 8 0 / 8 0 or 64%). The actual average emissions for each generator does not exceed thepounds/day in the pre- project plan (see pages'&& and >7&3). adjustments to actual historical emissions are required. After the conversion to gas fired only the new potential to emit will replace the existing potential to emit for each generator in the plan (see pages u, for the post-project plan. The gas fired emission factors used to quantify credits for this banking action and current rating, capacity and use factors will be used to calculate the new potential to emit. Compliance with these limits will continue to be shown;for all units in the SLC plan on a daily basis.
Therefore no
& q I O m 3 - cl67cFj l o p / / A ELP INC., YEST COAST PRODUCTION DIVISION - RULE 424 PLAN, CENTRAL KERW CDUlllY [Propordl
%€PI UWCONT UNCONT 502 CONT. I PTO UNIT MBTUl FUEL PCT lb5021 SCRUBBER lb502 PCT lb502/ lb4041 lb504l I lbS02/ lb5041 TOTRL lb51
I I I t I I I I t I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I l I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I l NO. 8 FIELD LEASE HR TvPE s MBTU n i t 8 HR CONT HR MBN HR I HR As 5 HR LS 5 I~S/W MBI
0.594 I 0.390 1.615 I 1.059 1.615 I 1.059 1.615 I 1.059 1.615 1 1.059 1.118 I 12.430 1.377 I 12.995 0.300 I 0.610 1.219 I 1.166 1.108 I 10.452 1.377 I 12.995 0.568 I 0.373 1.615 I 1.059 1.615 I 1.059 1.615 I 1.059 1.615 I 1.059 1.615 I 1.059 1.377 I '12.995 1.497 I 14.125 1.497 I 14.125 1.509 I 14.238 1.497 I 1.412 1.497 I 1.412
1.254 I 0.900 1.254 l 0.900 1.254 I 0.900 1.254 I 0.900 1.035 I 0.900 1.055 I 0.900 1.035 I 0.900 1.035 I 0.900 1.740 I 1.013 1.740 I 1.015 1.140 I 1.013 1.740 I 22.500 1.740 I 1.011 1.140 I 22.300 1.441 I 0.900 1.441 I 0.900 1.441 I 22.500 1.441 I 0.900 1.441 I 0.900 1.441 I 0.900 2.901 I 22.500 2.901 I 0.900 2.901 I 0.900
Rule 220.1 subsection V.D.3.b. specifies for a modified emissions unit the increase in permitted emissions (IPE) is:
IPE = PE(for modified emissions unit) - HAPE(modified emissions unit prior to modification)
Subsection V.E.3. specifies that the potential to emit for modifications that are the installation of a more efficient process or material is:
PE(8fter modification) = PEPM(1-CE)
The definition of HAPE in subsection V.B. specifies it is:
HAPE = PEPM(1-CE)
Thus for this modification the IPE is zero i.e.
IPE = PEPM(1-CE) - PEPM(1-CE) = 0
Rule 220.1 subsection V.E.3. specifies that the Actual Emissions Reduction (AER) where the reduction is due to the installation of control equipment or due implementation of more efficient process or material is:
AER = HAE(CE)
HAE = Historic Actual Emissions CE = Control Efficiency
HAE for each generator for each quarter is calculated by the actual oil burned times the representative source test emission factor for oil firing. No calculation of HAE for gas firing is preformed because no controls that reduce emissions while gas firing are proposed and therefore the CE and reduction are zero.
The CE for the conversion from oil to gas firing can be represented by :
oil fired E F - lZ8S fr ied EF oil fired EF
To insure all creditable reductions are real an actual representative oil fired emission factor must be used not the permitted factor.
Calculation for each steam generator are shown on pages !de% . Creditable reductions are summarized on pages D-3\ .
. Projects 910703-910709
on Calc-tions Contr
c. c o w i t y Bank A d.iustmes t
Rule 220.1 subsection V.E. requires a 10% adjustment for the community bank of actual emission reductions for the community bank. Because this reduction occurred after 8/22/89 by district policy the adjustment is made at the time the reduction is uantified. Community bank adjustments are summarized on pages
qr4L. . . p. Emission Factors for Oil F i r m
1, Steam Generators 4013094 & '096
rn NO2 emi sion factor is based on source test conducted 2/21/90 see page A. PM10. SO4 & SOZ
The PM10, SO4 and SO2 emission factors are based on a series of test on generators in the same field, fired on oil with the same sulfur content and with the same control equipment. The Tests are shown on pages =?and summarized below:
Because these tests show an emission factor higher than the SLC limit for SO4 the factor used to quantify credits will be limited to the SLC factor.
- co The CO emission factor of 0.012 lbm/MMbtu is based on a test of generators in the same field, fired on oil with the same sulfur content and with the same control equipment. The Test is shown on page &. This emission factor is below the current SLC limit.
Projects 910103-910109
VI. Emission C a l culat ions Cont,
- 2. Steam Generators 4013001-’003 b ‘072
I .I
Emission factors from similar sized uncontrolled oil fired-steam generators (operated by Mobil Oil) are used to establish emission factors for these units. To account for fuel sulfur content the tested emission factors for PM10, SO4 and SO2 are adjusted by the ratio of the actual sulfur content to the sulfur content of the tested generators. summarized below:
For PMlO and SO4 the source test emission factor exceeds the SLC emission factor the factor used to quantify credits will be limited to the SLC factor.
3. Steam Generators 4013026,’028,’032.’081.’085
N02 NO2 emission factor is based on source tests see pages @s PM10. SO4 & SO2 Steam generator326
The PM10, SO4 and SO2 emission factors are based on a series of test on generators in the Same field, fired on oil with the same sulfur content and with the same control equipment. The Tests are shown on pages and summarized below:
Projects 910703-910709 page IS' VI. KB ission Cal culations Cont.
Because these tests show an emission factor higher than the SLC limit for PMlO & SO4 the factor used to quantify credits will be limited to the SLC factor.
These generators are unscrubbed. Emission factors for PM10, SO4 8 SO2 can be calculated based on the tests for shown above for unscrubbed generators 4013001-'003 & '072 corrected for sulfur content of 0.7 wtX.
The CO emission factor of 0.012 lbm/MMbtu is based on a test of a similar generators fired on oil with the similar sulfur content and with the same control equipment. This emission factor is below the current SLC limit.
E. Post Proiect Emission Factors and Pounds/Dav for SLC
The applicant has proposed emission factors the steam generators equal to their current gas fired emission factors in the SLC plan. Steam generators 4013026,'094 & '096 are currently permitted to burn gas with a high sulfur content (TEOR casing gas) and therefore have higher emission factors for PM10, SO2 and 504.
Each of these generators has is currently included in the SLC plan with throttle and use factors of 80% (overall capacity factor of .64). The emissions factors times the rating times the throttle and use factors result in pounds/day for the SLC.
The Test is shown on page 36.
pounds/day = rating(24)(.8)( .8)(EF)
Emission factors and resulting pounds to be included in the post project SLC plan are shown on pages w-72.
To insure the reductions are real and permanent i.e. provided by these emissions units annual limits on gas burned to reflect the 80/80 capacity factor will be included on each steam generator permit as a Rule 230.1 condition.
Annual compliance testing consistent with policy E1801 will be required to verify that the units continue to comply with these emission factors.
i . . . . . ~ . . . . . . . . . . . . . .
: m m : I.mw : 1.m : 1.m : 1.m : l.IuI( :l.lm : .
t + :n tf, l M L l : 1,nlw : 1.1m : 1.w : l.11111 : 1.w :1.*uI : t .
9 . t
:nwmn : aw : 101 : IUI : ~ua : ~ua ; IUI : 10 Ylmn : W1: 111: 110: I I W : 111; l(1: c.--c---t---+---+---.cI(----1 ;aulmtn : nn : nu : nu : nu : nu : nu :
:a! .3Wl : 21.50 I 410.39 : 10.61 : 21.01 LPP: 1.11: ................... 1 ........................................................ 1 ......... 1~ ~. . ~ ~~~~~. :O! C1 r l lar : 1.06 : 51.44 : 1.19 : 1 . 5 6 : E M : 0.82 :
1 ...................................... t ..............................................
IO1 LEI : 9.11 I 169.91 ; 1.11 : 1.11 I e a I t .61 :
,____________._____,_________I ........................................................ . ~ . :PI CI d l o i : 0.91 I 11.00 : 0.11 I 8.11 : tu : 0.16 I I...... . ............................... (.......... t ............,.. .......... (........ ) , .................. t ......... 1 ........................................................
. ~ . :PI CI d l o i : 0.91 I 11.00 : 0.11 I 8.11 : tu : 0.16 I I...... . ............................... (.......... t ............,.. .......... (........ ) , .................. t ......... 1 ........................................................ :PI ID : 11.91 : 111.41 I 1.95 : 14.91 I Kll I 4.81 I (.................. +.. ...... + .................... t ........... .I.- ..... .....I........ , 188 .iw I 18.11 ! I l . l O I 6 .26 I1.43 I U P : 4.11 I
Projects 910703-910709 Page 21
:A10 :MI :lo1 Irn :roc :m I +..... '.."'...""+-'.~.~...,.........+...~.~....,............,............,....... .+
:PI bblllqtrs I IIOIO I 11010 I 1lOlO I llO20 I 11020 I 11110 I + ........................................ ....+ ............,... . ..."( . ......., : P l bblllqtri I 11111 : 11111 I 21114 I 11119 : 11119 I 11111 : ,...... '...........,.........,.........,..........I.. . ............................... + :O1 bblllqtn : 1411 I 1111 I 1411 I 1114 I 1111 I 1411 I ,..... . ...................... , ....................................................... + IO1 Lblllqtr: : 11151 I 11151 I 11251 I 11152 I Ill51 : 11152 I + ............................................. 4 ............ + ............ + ........ + : I I B t d b b l I 6.11000 I 1.11000 I 8.11000 I 6.11000 I 6.11000 :6.111#0 I
I . . . ............... , ......... , ......... , .......... ,. ........... , ............ , ........ , :ST El. Ib I lOh I 0.01100 : 0.11000 : 0.01190 : 0.11000 : 0.00000 :0.1IlOO I +.... .............I.........,.........,.......... , ............I.....................,
:prop t i . Iba!OltiI 0.01000 : 0.00100 : 0.00100 O.IlOO0 : 0.00000 :O.OOIOO , ........................................................................... + ........, ICE : 0.10112 I 0.99511 : 0.91081 0.29111 : e11 :0.11661 : ,...... ........................ + ......... ............................................... , ........................................................................... ~ ........, :PI drv!lqlr I I10 I 110 : 110 I 180 : 110 : 110 : I O 1 d.ls!1qlt : 111 I 112 : IIf : i ez : 182 I l 8 f : : O S d w ! ? q : r I 111 : 111 : 181 I 181 : 114 ~ la4 I
:p1 c1 rllor I 1.15 : 55.01 : 1.11 : 1.11 : $11 : 0.15 I
, ....... .................................................................... + ........, IO1 IU i 10.51 : 111.11 : 1.09 I 11.11 : 611 I 1.11 : IPI .1uu I 1.41 I 115.11 : 1.11 I 11.51 I 811 I 1.51 I
IO1 c11110. I 1.15 I 11.11 I 1.41 I 1.11 I 111 : 1.11 I
8 . ................................................................................... IO1 111 i 15.15 : 111.11 I 1.11 I 11.11 : ill I 4.15 : :p1 .1*111 I 11.16 : 141.10 I 5.51 I 11.11 I 811 I 1.11 I 4 ..................I......... .. .......I..........,....... . ..................... .....,
IO1 C1 i l l o r : 1.51 I 21.11 : 0.61 1.91 : 811 I 1.41 : , .................................................................................... 4
,. . . . . .~ ... . . . . . , . . ~
:a 0 Ill. : 1.u : 1t.U : ' 1.u : 1.11 : ra : 1.u :
Projects 910703-910109 Page 23
I V Ictril h i r i i a I r d u c t i o n Cdco la t ioas
MI 4011011 1 l .S Bbtilhr t t ru leierator rrmr&kkd
l a i t 210.1 *r 11. 1. CIlcokItion for in fOt t k i d 6 i t i o n of control e q l i p m l l t or change to #ore e f f i c i e a t protrsm
CB: (1011W ( t S l ff . )ro)OId fFl/SQurct t i i t lV
1 ..................,.........I......... 1 ........................... ......... ........ I .......... -,..-- ....,. 1 ..........I............ t
:PI bblllqtrr : 11490 : 12490 : 11490 : 11490 ~ 11490 11190 : , ................. - t ..I.........,........ . I . ....................... ....... . ........... .............. : P I bblllqtts : 19151 : 19151 I 19111 I 19151 : 19151 : 19111 I f ................. -,----.- ...,......... 1 ................................... , :P I b b l l l q t t i I 1119 I 6119 : 6119 : 1119 I I l l 9 I 1111 : 1 ...................................... 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ........ 1
:P4 bblllqtrs I 11441 : 11441 I 11441 : 11441 : 11441 I 1 1 4 4 1 I I.................. I-.... .... 1 ......... 1 ....................... 1 1 ' :UUlltrlbbl : 1.11100 : 6.IlSOO 1.IROO : 1 . I I i M : 1.11600 I6 ,I l iOQ f ................. -1 t f ..........I...... t ..................... (
:PI bbl l lq t rs : 11661 : ll111 : 11661 : 11661 : 11661 I l l 6 I S : +..." ~............~...~.~.~.~.........(..........(............,.......~....,... . .-.., :Q2 b b l l l q t n : 11014 I 11014 : 21014 : 21014 : 11014 : 11014 I
:MI0 :UI1 Is04 ;Io: : voc :a .:
:PI bbl l lgtrn : lK14 1654 I 1614 I 1654 : 1614 : 1614 : ..................... ....... + ......... + ..........I............,............,........,
:Q4 bbl l lqtrs 11138 : 11191 : 11631 : 12631 : 11698 : 12698 : :88BtdbbI : 6.11000 I 1.11001 : 1.11000 I 6.12000 : 6.llOOO :1.11000 I
:It Ki. I b i l l l B t u : O.QSIO0 : 0.11100 : 0.01690 : 0.11100 : 0.00000 :0 .01100 :'
:prop I i . I b i l l l l l a : 0.OIPOO ; 0.00180 : 0.00100 : 0.00000 :O.OOIOO : , .................. ............................................ ...................... 0.I1000 : : C I : 0.80191 ! 0.99581 : 0.94011 : 0.10516 ; 611 :0.91611 : , .................. , ......... ,. ....... ., .......... , ............ , ............ , ........ ,
A. Because these emiss Emission Reductions that may be used in 220.1.
on reductions can be validated as Actual they qualify for ERC banking certificates accordance with the requirements of Rule
B. Because these reductions occurred after 1/1/88 the 10% adjustment for the community bank shall be made at the time the reductions are quantified and shall not be included in the amount of the ERC Banking Certificate.
VIII. Recommendations
After public notice and review issue ERC Banking Certificates in the amounts shown on p a g e s T m totaling the following:
Pounds/day PMlO SO4 so2 NO2 co
1st Qtr 191.20 74.88 3409.40 506.70 77.69
2nd Qtr 142.80 58.97 2735.90 385.60 47.22
3rd Qtr 50.12 21.79 1015.10 184.30 22.40
4th Qtr 72.72 29.21 1343.50 214.90 30.78
Upon issuance of ERC Banking Certificates deposit to the community bank the following amounts
Pounds/day PMlO SO4 so 2 NO2 co
1st Qtr 21.25 8.31 378.83 56.29 8.64
2nd Qtr 15.87 6.57 303.99 42.86 5.25
3rd Qtr 5.55 2.42 109.80 20.48 2.48
4th Qtr 8.07 3.23 149.28 23.07 3.52 !
SulDlARY OF PROBLEMS ENCOUNTERED DURING APPLICATION PROCESSING
BRIEF DESCRIPTION OF PROBLEMS ENCOUNTERED:
3.
4 .
5 .
6.
I .
8 .
9.
10.
FRACTION OF TOTAL PROCESSING TIME SPENT ON CORRECTING THE ABOVE:
PROCESSING:
Initial Contact: - telephone - in person Project Entry into System 36:
Preliminary Review:
Organization/Familiarization:
Project Description/Schemaric/Equipment Listing:
Listing of Applicable Rules:
Design Review of Air Pollution Control Equipment:
Calculation of Expected t?missions&c&h
Air Quality Impact Assessment Revieu (Modeling):
Preparation of Emission Profiles:
CEQA Reviev:
Health Risk Assessment Review:
Reworking of Application Due to Changes:
Preparation of Rough Draft- m Preparation of Written Requests for Information:
Telephone and Verbal Requests for Information:
General Meetings with Applicant:
System 36 Data Entry (Including Emissions):
m:
r \ PROJECT EVALUATION STATUS REPORT PROJECT t 4!7f 3 -: h702
DATES SUBMITTED:
PROJECT ENGINEER: k 6 . V : i e-2 k.l-TC'*& ASSIGNMENT DATE: / / -
n COMPANY: c,' b..q- \ \ )q;k.:fi c-+PROjECT: ~ e . c - 5 * 2 .
RECEIPT DATE: 'iT / /% EVC, -NUMBERIS): hi?/,
DATE PACKAGE DEEMED COMPLETE :a h / 4) I
EVALUATION STATUS SUMMARY:
Project proposal familiarization completed
proposal description complete
of applicable Rules and Regulations completed
d+Project proposal schematic(s) completed
&%$Design review of emissions control system(s) completed
&%Preparation of emission profiles completed
alculation of expected air contaminant emissions completed
{h;/f&Applicanf notified of A to C requirements different than proposed
, + f q ~ Project evaluation 1 complete
8. Applicant notified of pen'ding denial on / /
8 Request for 90 day extension received on / /
Waiting for additional information requested by: p h o n e l e t t e r
PROJECT EVALUATION STATUS REPORT
DATES SUBMITTED:
PROJECT ENGINEER: b - U L C C l (.-*( lCc-s-C& ASSIGNUENT DATE: / / <
k9 . -
COMPANY: c J b<L\ (,) 4 5 k t n m R O J E C T :
e NmER(SI : / DATE PACKAGE DEEMED COMPLETE : / z/ 6 / 4 /
Lr a\ K r \ E \
0 - RECEIPT DATE: -?/ l / ' I 1 180th DAY: c/Ls'7
EWJ I I
mdw 2 / Y / 4 Z EVALUATION STATUS S U " : L__c__
l$/6& Project proposal familiarization completed
(/Z< Project proposal description complete
I' Llsting of applicable Rules and Regulations completed
/Id /<?-Project proposal schematic(s) completed I ,
Design review of emissions control system(s) completed
1/30 Calculation of expected alr contaminant emisslons completed
&&u3reparation of emission profiles completed
(/= Comprehensive listing of conclusions 6 recommendations completed Rough draft a completed Applicant notified of A to C requirements different than proposed
oject evaluation Q complete % Waiting for additional information requested by: L h o n e l e t t e r
Applicant notified of pending denial on / /
Request for 80 day extenslon received on / /
PROJECT EVALUATION STATUS REPORT
DATES SUBMITTED:
PROJECT ENGINEER: k b w \ . C C : c[ k-h-T&& ASSIGNUENT DATE: ' / /
PROJECT t & 3 / 3 9h370c
c
Mz COMPANY: c > b t . L \ 145krn W R O J E C T : Lr TA\ .C; i \c, qa ~5
RECEIPT DATE: 717 71
h4ys . q c / / P z
EEL - N w m R ( s 1 :YO( < c ; c ~ / 10 [ I-3.r DATE PACKAGE DEEMED COUPLETE~L 6 l8Otb DAY: h/ r/?z
kwz . - COMPANY: c > he-L\ ) 4 5 k r n W R O J E C T : w Lr a\ t r \ E ,
E e c -NUUBER(S): ~~L;I,~~c31ro~/2u,/i,j/T~,[~~'r)j RECEIPT DATE: T/y / ?[ DATE PACKAGE DEEMED COMPLETE: J? A 180th DAY: .d&
60 3a2.5 EVALUATION STATUS SUMMARY:
6 Project proposal familiarization completed
Project proposal description complete /2/ + ],/k Listing of applicable Rules and Regulations completed
Project proposal schematic(8) completed
Design review of emissions control system(s) completed I /
!/.* Calculation of expected air contaminant emissions completed
hdf /Cureparation of emission profiles completed 1/30 Comprehensive listing of conclusions & recommendations completed
JIY) Rough draft completed
,"Applicant notified of A to C requirements different than proposed
1/31 Project evaluation 1 complete
Waiting for additional information requested by: A h o n e l e t t e r
8 Applicant notified of pending denial on / /
8 Request for 90 day extension received on / /
EVALUATION STATUS SUMMARY:
J& Project proposal Camlllarlzation completed
I/&/ Project proposal description complete
,/h< Listing of applicable Rules and Regulations completed
&/'vW/Project proposal sche@atic(s) completed
Design review of emissions control system(8) completed
Calculation of expected air contaminant emissions completed -+- h
/dLz,+eparatJon of emlsslon profiles completed
v3d Comprehensive listlng of conclusions 6 recommendations completed - ' ' Rough draft - completed Applicant notified of A to C requirements dlfferent than proposed / /
complete ' 1 Project evaluation 8 8
Waiting for addftlonal lnformatlon requested by: A h o n e l e t t e r
Applicant notified of pendlng denial on / /
Request for 90 day extension received on / /
.̂ * ' i'
PROJECT EVALUATION STATUS REPORT
DATES SUBMITTED:
PROJECT ENGINEER: k&: Ce: (L-6 d - 5 - C 7 - , &
PROJECT t &>I3 9&70,i,'
Y
ASSIGNMENT DATE: 7 3 7 i . - \ r , edZ
@fA+ 2 / w
COMPANY: c > b .L\ )45krn GPP~~OJECT: &r a\ 4 r -CO EPC I .
-NUMBER($): ~ c ! ~ c > - . ~ ~ . / [ o 1 /$?( j % ) h < I / 'RECEIPT DATE: 7/ 7 / 7 1 I I
11 Listing of applicable Rules and Regulations completed .
&lczrProject proposal schematic(s) completed
~ / ~ k ~ ~ C a l c u l a t i o n of expected alr contamlnant emissions completed
&d {YPreparatlon of emission prof iles completed
Design review of emisslons control system(s) completed
Comprehensive listing of conclusions 6 recommendations completed
1 3 Rough draft completed
Applicant notified of A to C requirements 'different than proposed
Project evaluation complete
Waiting for additional information requested by: L h o n e l e t t e r
.i4e L A -
I
Applicant notified of pending denial on / /
Request for 90 day extension received on / /
FINAL CHECKLIST
Engineering analysis includes all items described in uidelines, all items appear in correct order, and all parts of analysis read logical 9 y and are legible. Rule '210.1 Certificate of compliance, if required, has been received and i s of proper content and form.
4 Package is divided into sections (each one in a folder) as described in guidelines and each folder has a Correctly prepared label. . . . e. G Rough draft &have been prepared in accordance with guidelines and in'correct format with correct punctuation. Drafts read loaicallv and are leaible. Each Desian
~~
and Operational condition is followed by number-of rule requiring-the condition o i ~ ~ providing basis for the condition.
L/ Applicant has been notified by telephone of all conditions appearing in A'S to c but not proposed in application.
n&-issions summary sheets (one for whole project and one System 36 printout for each A to C) have been prepared including net emissions change for whole stationary source. NSPS status has been marked.
A O b E m i s s i o n profiles have been prepared according to guidelines, a maximum daily emission rate has been set, and compliance (on a "moving" yearly average) has been required.
' ? d a N S P S / N E S H A P S , BACT/LAER, and/or NSR report has been prepared, with three copies o f
d-APCD Grant Objectives report has been prepared for approval of source emitting each.
over 82 lbm/day PH,, and for sources "netting out" of NSR requirements for any criteria air contaminant.
Source test regulrements sumnary has been repared (don't specify emission limits, 4 u s t mark "inlet , outlet", "units", etc.7, and one copy has been made.
' d&%%rmit fee billing edit has been prepared which includes all A ' s to C involved in
I/ Problems encountered summary sheet has been prepared which includes all items project, even if there is no fee due for one or more A's to C.
(understandably and clearly described) which resulted in unnecessar time; unnecessar meaning that the time would not have been spent i f the application midstream", etc. Engineering evaluation time sheet has been prepared which incudes all time spent in processing the applications. This includes time spent discussing the application with others, time spent,revising, etc.
expenditure of had been correct Z y submitted, the data was all correct, no changes were made in
Signed: Project Evaluation Engineer
Initialed: , Reviewing Engineer
'.* b
?
PROJECT EVALUATION STATUS REPORT PROJECT t &If3 7 70) DATES SUBMITTED:
PROJECT ENGINEER: b - d CC: k/ (Lk-FcA ASSIGNMENT DATE: / / c
COMPANY: c J b - L \
DATE PACKAGE DEEMED COMPLETE:^^ L I'? [
)q>krn CMROJECT: a~-s Lr GI & i \ E , - l ~ ks c 4 EFL