BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
CITATION OIL & GAS CORPORATION
)
Bio Desulfurization Unit
)
)
PCB 09-
)
(Tax Certification)
PROPERTY IDENTIFICATION NUMBER
)
15-06-200-11 or portion thereof
)
NOTICE
TO:
[
Electronic filing
]
[
Service by mail
]
John Therriault, Assistant Clerk
Susette M. Harris
Illinois Pollution Control Board
Citation Oil & Gas
State of Illinois Center
8223 Willow Place Drive S
100 W. Randolph Street, Suite 11-500
Houston, Texas 77070-4631
Chicago, Illinois 60601
[
Service by mail
]
Steve Santarelli
Illinois Department of Revenue
101 West Jefferson
P.O. Box 19033
Springfield, Illinois 62794
PLEASE TAKE NOTICE that I have today electronically filed with the Office of
the Pollution Control Board the APPEARANCE and RECOMMENDATION
of the
Illinois Environmental Protection Agency, a copy of which is herewith served upon the
applicant and a representative of the Illinois Department of Revenue.
Respectfully submitted by,
Robb H. Layman
/s/
Robb H. Layman
Assistant Counsel
Date: March 12, 2009
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Telephone: 217/524-9137
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
CITATION OIL & GAS CORPORATION
)
Bio Desulfurization Unit
)
)
PCB 09-
)
(Tax Certification)
PROPERTY IDENTIFICATION NUMBER
)
15-06-200-11 or portion thereof
)
APPEARANCE
I hereby file my Appearance in this proceeding on behalf of the Illinois
Environmental Protection Agency.
Respectfully submitted by,
Robb H. Layman
/s/
Robb H. Layman
Assistant Counsel
Date: March 12, 2009
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
Telephone: 217/524-9137
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
CITATION OIL & GAS CORPORATION
)
Bio Desulfurization Unit
)
)
PCB 09-
)
(Tax Certification)
PROPERTY IDENTIFICATION NUMBER
)
15-06-200-11 or portion thereof
)
RECOMMENDATION
NOW COMES the ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
(“Illinois EPA”), through its attorneys, and pursuant to 35 Ill. Adm. Code 125.204 of the
ILLINOIS POLUTION CONTROL BOARD’S (“Board”) procedural regulations, files
the Illinois EPA’s Recommendation in the above-referenced request for tax certification
of pollution control facilities. The Illinois EPA recommends a
grant
of the applicant’s
request. In support thereof, the Illinois EPA states as follows:
1.
On December 26, 2006, the Illinois EPA received a request and supporting
information from CITATION OIL & GAS CORPORATION (“Citation Oil”) concerning
the proposed tax certification of certain air emission sources and/or equipment associated
with a natural gas liquids (“NGL”) manufacturing plant. The plant is located near Odin
in Marion County, Illinois. A copy of the relevant portions of the application is attached
hereto.
[Exhibit A]
.
2.
The registered address of Citation Oil is:
Citation Oil & Gas
8223 Willow Place Drive S
Houston, Texas 77070-4631
3.
The address of the NGL gas plant located in Illinois is:
Citation Oil & Gas Corporation
2302 Hoots Chapel Road
Odin, Illinois 62870
4.
The pollution control facilities involved in this request consist of the
construction and installation of a Bio Desulfurization Unit. As a part of the NGL
manufacturing plant, the Bio Desulfurization Unit employs an innovative control
technology to control process emissions, using absorbtion techniques in combination with
biological treatment (i.e., hydrogen sulfide-eating bugs). The control technology
removes and breaks down the highly-concentrated hydrogen sulfide that is found in the
sour casing head gas that is processed in NGL manufacturing. The process produces both
elemental sulfur, which will be sent to a landfill, and a sweet residue gas, which will be
flared. As a result of the project’s implementation, neither the acid gas from the NPL
manufacturing plant nor the existing well sites will need to be flared. Moreover, the
resulting reduction in hydrogen sulfide will reduce ambient sulfur dioxide emissions
within a five square mile area by an estimated 1,200 tons per year.
5.
Section 11-10 of the Property Tax Code, 35 ILCS 200/11-10 (2002),
defines “pollution control facilities” as:
“any system, method, construction, device or appliance appurtenant
thereto, or any portion of any building or equipment, that is designed,
constructed, installed or operated for the primary purpose of: (a)
eliminating, preventing, or reducing air or water pollution… or (b)
treating, pretreating, modifying or disposing of any potential solid, liquid,
gaseous pollutant which if released without treatment, pretreatment,
modification or disposal might be harmful, detrimental or offensive to
human, plant or animal life, or to property.”
6.
Pollution control facilities are entitled to preferential tax treatment, as
provided by 35 ILCS 200/11-5 (2002).
7.
Based on information in the application and the underlying purpose of the
Bio Desulfurization Unit to prevent, eliminate or reduce air pollution, it is the Illinois
EPA’s engineering judgment that the described project and/or equipment may be
considered “pollution control facilities” in accordance with the statutory definition and
consistent with the Board’s regulations at 35 Ill. Adm. Code 125.200.
[Exhibit B].
8.
Because the Bio Desulfurization Unit will satisfy the aforementioned
criteria, the Illinois EPA recommends that the Board
grant
the applicant’s requested tax
certification.
Respectfully submitted by,
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY
Robb H. Layman
/s/
Robb H. Layman
Assistant Counsel
DATED: March 12, 2009
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
Telephone: 217/524-9137
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
I hereby certify that on the 12th day of March 2009, I electronically filed the
following instruments entitled
NOTICE, APPEARANCE
and
RECOMMENDATION
with:
CERTIFICATE OF SERVICE
John Therriault, Assistant Clerk
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
and, further, that I did send a true and correct copy of the same foregoing instruments, by
First Class Mail with postage thereon fully paid and deposited into the possession of the
United States Postal Service, to:
Steve Santarelli
Susette M. Harris
Illinois Department of Revenue
Citation Oil & Gas Corporation
101 West Jefferson
8223 Willow Place Drive S
P.O. Box 19033
Houston, Texas 77070-4631
Springfield, Illinois 62794
Robb H. Layman
/s/
Robb H. Layman
Assistant Counsel
,
,
December 19, 2006
Illinois EPA
. Attn: Donald
E. Sutton, Manager
Permit Section
Division
of Air Pollution Control
PO Box 19276
Splingfield, IL 62794-9276
Re: Citation Oil
&
Gas Corp.'s Form APC 151 Application for Certification (Property Tax
Treatment), Pollution Control Facility
Dear Mr. Sutton:
Enclosed for filing with the Permit Section, Bureau
of Air is Citation Oil
&
Gas Corp.'s
("Citation") application for Certification (Property Tax Treatment) Pollution Control Facility.
Citation operates oil and gas wells located in Marion County, Raccoon Township.
,
InJuly 2005, Citation was granted a pennit (Application Number 05060022) to construct
a gas plant, the Salem Gas Plant, for the recovery natural gas liquids (NGLs) from casing head
gas collected
Ii-om existing crude oil pumping wells. The construction permit also includes three
existing gas production facilities: Water Injection Plant, South BattelY, and the North Battery.
The existing facilities operate under a lifetime operating penni! number 73030968.
The construction phase
of the gas plant was completed in July 2006. The facility is
cunently undergoing testing.
Please let me know
if you have any questions or need further infonnation in aid of
reviewing this application.
CMRRR# 7006 0810 0000 9574 2450
Enclosures
lL EPA App!k!l1ion for
T~~
Cenificl\!;on 12192006.dox
8223 Willow Place South
-1 -
Respectfully submitted,
)1wdL7l!
;ftvi/M
Susette M. Hanis, CPA
Senior Tax Accountant
JfC,
'!,
6 2006
tEPA DAPC SPFLD
Houston, TX
...................
77070-5623
F-
pC
It;
~
i-t A
281/517-7800
!
I
INDEX OF ATTACHEMENTS
1.
June
7,
2005
-Transmittal to Original ConstJUction Pennit Application
2.
June
2005-ConstJUction Pennit Application prepared by Kane Environmental
Engineering, Inc.
3.
June 8,
2005-Application for ConstJUction Pennit- Form 199-CAAPP
4.
July 20,
2005-Notice of Additional Construction Penni! Application Fees
5.
September 6,
2005-Construction Pennit granted
ILEPA
App\ic~!ion forTn~
Certification 12192006.dot
- 2-
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
r
,
APPLICATION FOR CERTIFICATION (PROPERTY TAX TREATMENT)
This Agency is authorized to request this
POLLUTION CONTROL FACILITY
illfonnation under Illinois Revised Statues, 1979,
AIR
Ii1I
WATER 0
Chapter, 120, Section 502a-5. Disclosureoflhis
information is voluntary. However, failure to
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
comply could prevent your appl ication from
P. O. Box 19276,
Springfield, IL
62794-9276
being processed
or could result in denial of your
application for certification.
FOR AGENCY USE
File No.
Date Received
Certification No.
Date
Sec. A
Company
Name
Cilation Oil & Gas Corp.
Person Authorized to Receive Certification
Person 10 Contact for Additional Details
Susette M. Harris
Le Ann Elsom
Street Address
Street Address
8223
Willow Place Drive S
8223
Willow Place Drive S
~
Municipality. State & Zip Code
Municipality, State & Zip Code
z
~
Houston, TX
77070-4631
Houston, TX
77070.4631
"
:::;
a.
Telephone Number
Telephone Number
a.
~
'281) 517.7513
(281) 517.7800
Location of Facility
Municipality
Township
Quarter Section
Township
Range
Racoon
Salem
Racoon
Street Address
County
Book Number
2302
Hoots Chapel Road
Marion County
Property Identification Number
Parcel Number
15.06.200.11
Sec. B
Nature of Operations Conducted at the Above Location
Gas gathering system and NGL sales project with bio.desulfurization. See Attached Construction Permit
prepared by Kane Environmental Engineering, Inc.
June
2005.
"
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~'"
Water Pollution Control Construction Permit No.
Date Issued
~-
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::>0.
~'"
NPDES PERMIT No.
Date Issued
I Expiration Dale
;::0
ILROO
05131108
"
Air Pollution Control Construction Permit No.
Date Issued
05060022
07120105
Air Pollution Control Operating Pemnit No.
Dale Issued
Pending
Sec. C
Describe Unit Process
See Attachment in Support of Tax Application.
"
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Materials Used in Process
,
;
.
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.
,
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See Attachment in Support of Tax Application.
.
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Sec. D
Describe Pollution Abatement Control Facility
~z
The pollution control facility includes a bio.desulfurization unit.
See Attached Construction Permit prepared
00
g:\i:
by Kane Environmental Engineering, Inc. June
2005,
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IL 532-0222
Tax Certification/or Pollution Control Facilities
APC 151
(Rev.
8100)
Page I 0/2
8100
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
f
Sec. E
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(1) Nature of Contaminants or Pollutants
sulfides
Material Retained, Captured
or Recovered
Contaminant
or Pollutant
DESCRIPTION
DISPOSAL OR USE
hydrogen sulfide
sutfide
bio-desulfurization
sulfer dioxide
sulfide
bio-desulfurization
(2)
Point(s)
of Waste Water Discharge
Plans and Specifications Attached
I Yes lEI
I NoD
131
Are contaminants (or residues) collected bv the control facilitv?
I Yes
lEI
I NoD
(4)
Date installation completed
07101/06
status of installation on date of application
(5)
a. FAIR CASH VALUE IF CONSIDERED REAL PROPERTY:
$
7,374,000.00
b. NET SALVAGE VALUE IF CONSIDERED REAL PROPERTY:
$
0.00
c. PRODUCTIVE GROSS ANNUAL INCOME OF CONTROL FACILITY:
$
0.00
d.
PRODUCTIVE NET ANNUAL INCOME OF CONTROL FACILITY:
$
0.00
e.
PERCENTAGE CONTROL FACILITY BEARS TO WHOLE FACILITY VALUE:
%
100
The following information is submitted in accordance with the Illinois Property Tax Code, as amended, and to the best of my
knowledge, [s true and
o~aC[I[t[es
claimed herein are "pollulion control fac[lit[es' as defined," Section 11-10 of the
IIlino[s Property T
ode
2
~
O.4..,-t/
Vice-President Taxalion
I"
.~
Signature
Title
INSTRUCTIONS FOR COMPILING AND FILING APPLICATION
General: Separate applications must be completed for each control fadlity claimed. Do not mix types (waler and air). Where both air and
water operations are related, file two applications. If attachments are needed, record them consecutively on an index sheet.
Sec. A
Sec. B
Sec.C
Sec. D
Sec. E
Sec. F
Information refers
to applicant as listed In the tax records and the person to be contacted lor further details orror inspection of
facilities. Define facility location
by street address or legal description. A pial map location is required for facilities located
outside of municipal boundaries.
The property identification number is required.
Self -explanatory. Submit copies of
all pennits issued by local pollution control agencies.
(e.g. MSD Construction Permit)
Refers
to manufacturing processes or materials on which pollution control facility is used.
Narrative description of the pollution control facility, indicating that its primary purpose is to eliminate, prevent or reduce pollution.
State the type of
control facility. State permit number, date, and agency issuing permit. A narrative description and a process
flow diagram desaibing
the pollution control facility. Include a listing of each major piece of equipment included in the claimed
fair cash value for real property. Include
an average analysis of the influent and effluent of the control facility stating the
collection efficiency.
list air contaminants, or water pollution substances released as effluents to the manufacturing processes. list also the final
disposal of any contaminants removed from the manufacturing processes.
Item
(1) - Refers to pollutants and contaminants removed from the process by the pollution control faCility.
Item (2) - Refers to water pollution but can apply to water-carried wastes from air pollution control facilities. Submit drawings,
which clearly show
(a) Point(s) of discharge to receiving stream, and (b) Sewer.;. and process piping to and from the control
facility.
Item
(3) -If the collected contaminants are disposed of other than as wastes, slate the disposition of thl:; materials, and the value
in dollars reclaimed by sale or reuse of the colleced substances. State the cost of reclamation and related expense.
Item (4) - Stale the date which the pollution control facility was first placed in service and operated. If not, explain.
Item
(5) - This information is essential to the certification and assessment actions. This accounting data must be completed to
activate project review prior to certification by this Agency.
Self-explanatory.
Signature must
be a corporate authorized signature.
Submit
to:
Imnois EPA
p.o. Box 19276
Spnngfield, IL 62794-9276
Attention:
AI Keller
Permit
Section
Division of Water Pollution Control
Tat Certification/or Pollution Control Facilities
Page
2
of2
8100
Attention:
Donald
E.
Sutton
Permit Section
Division of Air Pollution Control
4
J 211912006
1:58 PM
ATTACHMENT IN SUPPORT OF TAX CERTIFICATION APPLICATION
Section C. Describe Unit Process. Unit.
Process described in attached Construction
Permit Application ID No. 121813AAA beginning at page 5.
The new Salem Gas Plant if located at 2302 Hoots Chapel Road, Marion
County, Illinois. The plant was constructed
to gather sour casing head
gas
to process into a saleable product: natural gas liquids (NGLs).
38
miles of pipelines were installed to gather casing head gas from existing
oil pW11ping wells. This gas has been flared at the well site since 1938.
The process consists
of six separate sub processes (See Attachment 2 for
more details):
I. Inlet gas heating and separation.
2. Gas treating/Sulfur Recovery.
3. Refrigeration Unit/Process Cooling
4. Liquids recovery from Process Gas
5. Liquids Stabilization
G ..
Hydrate Inhibition and Stabilizer Heat Medium Supply
Section C. Materials used in process.
Materials described in attached Construction
Pennit ApplicationlD No. 121813AAA.
Shell-Pacques/Thopaq® solvent for removal
of H2S. MRU unit and dual
purpose ethylene glycol heating
and injection unit. Thiopaq®
process
uses bacteria
of the genera Thiobacillus to oxidize the hydrogen sulfide.
Section D. Pollution Control Facility Description.
Pollution control facility described
in attached Construction Pennit Application
ID No. 121813AAA beginning at page 5.
Salem Gas Plant
The Salem Gas Plant pollution control facility consists of a bio-
desulfurization unit that removes entrained H2S for gathered casing head
gas.
There are three sections to the bio-desulfurization facility:
Absorption section, Reaction section, aerobic section, and the Sulfur
Recovery Section.
The absorption section washes the gas in
an absorption tower. The laden
washing liquid is led to the aerobic reactor in which the sulfides are
oxidized.
0506022
APe
lSI 12142006..doc
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
.p
12/1912006
1:58 PM
The reaction section, aerobic reactor contains micro-organism that
oxidizes the absorbed sulfides into elemental sulfur. Reactor intemals are
used
to ensure complete mixing and optimal mass transfer of the oxygen
in
to the liquid phase. Exhaust air fonn the reactor can be nonnally
emitted without further processing.
The produced sulfur is separated from the liquid by means
of a settling
unit. Solids content
of the settler underflow is typically between 10 and
20%. The sulfur slurry can be furthered dewatered by means
of a decanter
centrifuge or filter press
to obtain a dry solid concentration of about 60-
65%.
The sulfur product can use as a raw material for the production of sulfuric
acid at sulfuric acid plants for burning waste acid and slurries. Citation
plans
to dispose of the sulfur by truck to a nearby solid waste landfill.
South Battery
The South Battery had an existing non-assisted flare that was converted to
a vapor recovery unit that will route vapors into the gas gathering system.
A
21 O-BBL vertical fixed roof condensate tank will be installed that will
include a vapor recovery unit that will also route vapors back into the gas
gathering system.
0506022 APC 151 ! 2142006.doc
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
.'
)
---ll~G~SCORP'
~
June 7, 2005
Illinois Environmental Protection Agency
Division Of
Air
Pollution Control -- Permit Section
P.O. Box 19506
Springfield, Illinois 62794-9506
RE:
Air Permitting Construction Application
-
Salem Unit
-
Gas Gathering and NGL Sales Project
To v,'hom
It May Concern:
Citation Oil
&
Gas Corp. (Citation) is pleased to present this permit application for the Salem Unit - Gas Gathering
and NGL Sales Project This project will be classified as a synthetic minor source and will require a FESOP
(Federally Enforceable State Operating Permit) since the facility's uncontrolled emissions would be major without
the pollution control device.
Citation Oil
&
Gas Corp. (Citation) operates three oil and gas production facilities located southwest of Salem,
Illinois in Marion County, The facilities are the North Battery, South Battery and Water Injection Plant that operate
under a Lifetime Operating Permit (Permit No
.. 73030968) and are engaged in the separation of oil from water that is
extracted from the crude oil pumping wells in the surrounding area. With this application, Citation proposes to
construct a gas plant, the Salem Gas Plant, for the recovery of natural gas liquids (NGLs) from casing head gas
collected
from existing crude oil pumping wells. Due the existing Lifetime Operating Permits for the North and
South Batteries and Water Injection Plant, guidance from tbe !EPA was to include these facilities in this
construction application. For the purposes of creating consistent and accurate representation of these operations,
Citation is providing revised plot plans and emission calculations for these facilities.
BaCkground
Since approximately 1938, pumping wells in the Salem area have been producing crude
oiL These, wells are
currently owned and operated by Citation and produce crude from over 200 active well sites. Current operations
include the extraction
of a water and crude oil mixture from the wells, The mixture is sent to one of two locations,
the North Battery or the South Battery, depending on the geographic location
of the wells. At each respective tank
battery, water is separated from the crude oil after passing through a series of freewater knockout rnnks, gunbarrels
and crude' oil stock tanks. Crude oil
is transferred to sales via a lease automated custody transfer (LACT) unit.
Produced water is transported to a centralized location, the Water Injection Plant, which stores the water prior
to
pumping into water injection wells located throughout the field, Gas from the freewater knockouts and the
gunbarrel tanks are collected and sent
to a combustion flare. The sour casing head gas that is produced fTom the
extraction of the liquids is flared at the wellhead in small .flares. These flares are not regulated under the air rules of
the Illinois EPA and have operated in this mode throughout the life of the field.
'EPi~
'JAPe SPFLD
"'8223 Willow Place South
Houston, TX 77070-5623
281/517-7600
; .
Page 1
Gas Gathering and NGL Sales Project
Since 2000, Citation has been actively conducting a study to evaluate the technical and economical feasibility of
collecting~
processing and selling the casing head gas and the associated NGLs that can be extracted from the gas.
In 2001, Citation completed a Gas Gathering Pilot program to determine if the recovery of the casing head gas
would be feasible.
It
was determined that with the current economic conditions and the quantity of gas that is
currently produced at the well sites that the projectwas'feasible. Since that time, Citation has developed a plan, the
Salem Gas Gathering and NGL Sales Project, to collect the sour casing head gas to a central location and process the
gas for the collection ofnalural gas liquids (NGLs). The proposed location is the subject
of this construction permit
application, the Salem
Gas Plant, which is to be located adjacent to the existing South Battery, Note that the
processing
of the casing head gas is independcnt of the crude oil production operations, The operation of the
batteries
and water injection plallt is essentially unaffected by this proposed construction.
Citation
is proposing to use an innovative control techoology that is provided by NATCO called bio-desulfurization.
This technology has been permitted and operated in the United States and Canada and utilizes absorbtion technology
in combination with biological treatment in the form of H,S-eating bugs. The protess achieves over 99% reduction
in H,S with the by-product of elemental sulfur and a sweet residue gas instead of highly concentrated H,S gas. The
elemental snlfur is removed from the site
as a moist cake while the residue gas is flared. This techoology eliminates
the need
to flare acid gas at the plant and consequently eliminates the flaring of H,S at the existing well sites.
It
is
expected that the Salem Unit Gas Gathering and NGL Sales Project is one of the most significant environmentally
beneficial projects in the history
of Marion County, as it will contribute to the reduction of over 1,200 tons per year
of actual SO, emissions that have been emitted annually since 1938. Using innovative technology and vision,
Ciiation has proposes to construct this project that will:
•
Reduce ambient SO] emissions in a
5
square mile area by over 1,200 tons per year;.
•
Recover otherwise wasted natural resources to generate nearly 350 barrels per day of saleable NGLs;
•
Generate
-600 Mcflday of sweet, high-Btu residue gas that has the potential to be used for future power
generation, feedstock for ethanol production, or supply
of clean burning natural gas to the city of Salem;
and
•
Improve the ambient air quality in the Marion County by eliminating over, 200 ground flares located
throughout the area.
Enclosed is a fee check for $12,000 along with an original and two additional copies of the application for your
review. Thank you in advance for you consideration ofthis permit application.
If you have any questions about this
application, or need additional information please do not hesitate to contact me directly at (281) 517-7196, or Mr.
Paul DeCiutiis
of Kane Environmental at (512) 401-2444.
Lee Atm Elsom
Environmental Coordinator
cc:
Mr. Clyde Finch, Citation Oil
&
Gas, Corp. Oklahoma City, OK
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
Q
~
\ Citation Oil & Gas Corp.
i
itaiiott
,8223 WILLOW PLACE SOUTH
-: --
:;:~~
HOUSTON, TEXAS 77070-5623
VENDOR NO.
VENDOR NAME
10615
STATE OF ILLINOIS
... , VOUCHER
VENDOR
INV #
06-AP-18
IEPA060105
DP00001828
TOTAL INVOICES PAID
INV DATE
06/01/05
Wells Fargo Bank
115 Hospilal Drive
Van Wert,
OH 45891
Payable Account
Page 1 of i
CHECK DATE
CHECK NUMBER
AMOUNT
TOTAL
AMOUNT
12,000.00
Jun.01-200S
132291
.PRIOR PMTS
& DISCOUNTS
0.00
$12,000.00
NET
AMOUNT
12,000.00
12,000.00
PAYEE; DETACH THIS STATEMENT BEFORE DEPOSITING
Citation Oil 8," Gas Corp.
8223 WilLOW PLACE SOUTH
HOUSTON, TEXAS
77070-562~
EXAC~~~Q~12,OOOdo1s00cts
TWr;.LVE 'I'HOUSAND
DOLLARS AND
NO CENTS .
STATE OF ILLINOIS
OFFICE
OF STATE TREASURER.
ENVIRONMENTAL PROTECTION AGENCY
POBOX 19276
SPRINGFIELD, It. 62794-9276
Wells Fargo Bank
115 Hospital Drive
Van Wert,
OH 45891
412
Check No
132291
.
Payable Account
Do not aCC!ptin;s d\lCument
WARNING
unless you cansee a ghost
leatur~,wtleo
he:d aI
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4~ c~
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light
lhe
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documl.'l1l has 10 iln,f1Cla1 Ylilte:marl;.
VOID AFTER 90 DAYS
.
CHECK NO.
DATE
PAY EXACTLY
132291
Jun-01-i005
$12,000.00
COUNTER SIGNATURE REQUIRED IF AMOUNT GREATER THAN $50,000
By
~~--,,-.
-"......
.. t:..:....
c....:..=-_._'~
3y ________________________ _
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
Construction Permit Application
Salem Unit - Gas Gathering and NGL Sales Project
Salem, Marion
County
10 No. 121813AAA
Prepared for:
Citation Oil
&
Gas Corp.
8223 Willow Place South, Suite 250
Houston, Texas 77070-5623
Prepared by:
JIRUljJ
Kane Environmental Engineering, Inc.
2801 Welton Cliff
Cedar Park, Texas 78613-4324
Project No. 04-035
June 2005
IEPA. DAPC.
. , . '
TABLE OF CONTENTS
1.0
INTRODUCTION
1
2.0
PROCESS DESCRIPTION
5
3.0
PROCESS FLOW
11
4.0
FACILITY DIAGRAMS
12
5.0
STATE REQUIREMENTS FOR PERMIT TO CONSTRUCT
20
6.0
FEDERAL REQUIREMENTS FOR PERMIT TO CONSTRUCT
24
7.0
EMISSION SOURCES AND CONTROLS
27
8.0
AIR DISPERSION MODELING
30
9.0
EMISSIONS FEE
31
Appendix A: Required IEPA Forms and Tables
Appendix
B: Emissions Calculations and Data
Appendix C: Supporting Documentation
Appendix
D: Supporting Data for Alternative Control Technology
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
1.0
INTRODUCTION
Citation Oil & Gas Corp. (Citation) operates three oil and gas production facilities located
southwest of Salem, Illinois
in Marion County. The facilities are the North Battery, South
Battery and Water Injection Plant that operate under a Lifetime Operating Permit (Permit
No. 73030968) and are engaged in the separation of oil from water that is extracted from
the crude oil pumping wells
in the surrounding area. With this application, Citation
proposes
to construct a gas plant, the Salem Gas Plant, for the recovery of natural gas
liquids (NGLs) from casing head gas collected from existing crude oil pumping wells.
Background
Since approximately 1938, pumping wells in the Salem area have been producing crude oil.
These wells are currently owned and operated
by Citation and produce crude from over
200 active well sites. Current operations include the extraction of a water and crude oil
mixture from the wells. The mixture is sent to one of two locations, the North Battery or the
South Battery, depending
on the geographic location of the wells. At each respective tank
battery, water is separated from the crude oil after passing through a series of freewater
knockout tanks, gunbarrels and crude oil stock tanks. Crude oil
is transferred to sales via a
lease automated custody transfer (LACT) unit.
Produced water
is transported to a
centralized location, the Water Injection Plant, which stores the water prior
to pumping into
water injection wells located throughout the field. Gas from the freewater knockouts and
the gunbarrel tanks are collected and sent to a combustion flare. The sour casing head
gas that
is produced from the extraction of the liquids is flared at the wellhead in small
flares. These flares are not regulated under the air rules of the Illinois EPA and have
operated
in this mode throughout the life of the field.
Gas Gathering and NGL
Sales
Project
Since 2000, Citation has been actively conducting a study to evaluate the technical and
economical feasibility of collecting, processing and selling the casing head gas and the
associated NGLs that can
be extracted from the gas. In 2001, Citation completed a Gas
Gathering Pilot program
to determine if the recovery of the casing head gas would be
feasible.
It was determined that with the current economic conditions and the quantity of
gas that
is currently produced at the well sites that the project was feasible. Since that
time, Citation has developed a plan, the Salem Gas Gathering and NGL Sales Project, to
collect the sour casing head gas
to a central location and process the gas for the collection
of natural gas liquids (NGLs). The proposed location
is the subject of this construction
permit application, the Salem Gas Plant, which
is to be located adjacent to the existing
South Battery. Note that the processing of the casing head gas
is independent of the crude
oil production operations, The operation of the batteries and water injection plant is
essentially unaffected by this proposed construction.
In evaluating the feasibility of this project, Citation has conducted studies of the production
and gas composition of the casing head gas. The analytical results of sampling conducted
in February 2004 is included
i~
Appendix C. Because of the sour composition of the casing
Citation Oil and Gas Corporation
Salem Unit
1
June 2005
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
•
head gas and need to remove the entrained hydrogen sulfide (H
2
S) for recovery of saleable
NGLs, a concentrated sour vent stream would be created and posed a complex air
pollution control issue. The casing head gas that
is currently flared at the wellheads
creates,
in aggregate, over 1,200 tons per year of sulfur dioxide (S02) by combusting the
H2S which ranges
in concentration from 2% to 5%, by volume. In order to flare this gas
collectively at the Salem Gas Plant, compliance with Illinois EPA Rule 214.301 could not be
demonstrated. Therefore, Citation explored
all options in controlling the acid gas created
from removing the H2S.
After significant review and analysis of control options, Citation is proposing to use an
innovative control technology that
is provided by NATCO called bio-desulfurization. This
technology has been permitted and operated
in the United States and Canada and utilized
absorbtion technology
in combination with biological treatment in the form of H2S-eating
bugs. The process achieves over 99% reduction in H2S with the by-product of elemental
sulfur and a sweet residue gas instead of highly concentrated H2S gas. The elemental
sulfur
is removed from the site as a moist cake while the residue gas is flared. This
technology eliminates the need to flare acid gas at the plant and consequently eliminates
the flaring of H2S
at the existing well sites. It is expected that the Salem Unit Gas
Gathering and NGL Sales Project
is one of the most significant environmentally beneficial
projects
in the history of Marion County, as it will contribute to the reduction of over 1,200
tons per year of actual S02 emissions that have been emitted annually since 1938. Using
innovative technology and vision, Citation has proposes
to construct this project that will:
•
Reduce ambient
SO,
emissions in a
5
square mile area by over
1,200
tons per year;
•
Recover otherwise wasted natural resources
to generate nearly
350
barrels per day of saleable
NGLs;
~
•
Generate
-600
Mcf/day of sweet, high-Btu residue gas that has the potential to be used for future
power generation, feedstock for ethanol production, or supply of clean burning natural gas to the city
of Salem; and
•
Improve the ambient air quality
in the Marion County area by eliminating over 200 ground flares
located throughout the area.
Due the eXisting Lifetime Operating Permits for the North and South Batteries and Water
Injection Plant, guidance from the IEPA was to include these facilities
in this construction
application. For the purposes of creating consistent and accurate representation of these
operations, Citation
is providing revised plot plans and emission calculatioris for these
facilities. A summary of the equipment at the existing and proposed Salem Gas Plant
is
provided below.
Equipment Summary
Existing equipment at the North Battery is listed below
• (2) 400-bbl vertical fixed-roof oil stock tanks;
• (2) 600-bbl vertical fixed-roof gunbarrel tanks;
•
(1) 3,300-bbl vertical open-roof overflow tank;
•
(6) 420-bbl freewater knockout tanks;
• (1) non-assisted flare;
• Equipment fugitive components
Citation Oil
&
Gas Corp.
Salem Unit
2
.fune 2005
Construction Permit Application
Existing equipment at the Water Injection Facility is listed below
• (2)
5,OOO-bbl vertical fixed-roof water tanks;
• (1) 5,000-bbl vertical open-roof overflow tank;
•
(1) 20,000-bbl vertical open-roof overflow tank;
•
(1) fluid separation pit*;
• Equipment fugitive components
'Note: This unit
was
previously authorized but has been closed and is no longer operational.
Existing equipment at the South Battery is listed below
• (2) 400-bbl vertical fixed-roof oil stock tanks;
• (2) 600-bbl vertical fixed-roof gunbarrel tanks;
• (1) 3,300-bbl vertical open-roof overflow tank;
• (6) 420-bbl free water knockout tanks;
• (1) non-assisted flare*;
• Equipment fugitive components
'Note: This flare will be eliminated and will be repiaced with a VRU that will route vapors into the
gas gathering system.
New equipment is proposed to construct the Salem Gas Plant and is listed below:
• (3) 30,000 gal pressurized NGL product tanks;
• (1) mechanical refrigeration unit
with gas-fired reboiler for glycol dehydration;
• (1) bio-desulfurization unit with ancillary equipment;
• (1) propane refrigeration compressor - electric motor drive
•
(1) chilled water skid;
• (1)
21 O-bbl vertical fixed-roof condensate tank*;
• (1) air-assisted flare (located
-1,600 feet north of the plant);
•
(1) 250 hp electric drive, 2-stage gas compressor;
• Equipment fugitive components
'Note: This tank will be located at the South Battery and equipped with
a
VRU that will route
vapors into
the gas gathering system.
Emissions Summary
The emissions generated at the Salem Gas Plant include carbon monoxide (CO), nitrogen
oxides (NO
x
),
particulate matter (PM
1O
),
sulfur dioxide (S02), hydrogen sulfide (H
2S),
and
volatile organic compounds (VOC). The sitewide emissions associated with the proposed
production increase will not trigger CAAPP (Title
V) applicability since the emissions of all
criteria pollutants are below 100 tpy. Single HAP emissions are not above 10 tons per year
(tpy) and the aggregate HAP emissions are below 25 tpy, so MACT will not apply to the
Salem Gas Plant. Since the Water Injection Plant and North Battery are located over '!.
mile from the Salem Gas Plant, the potential emissions from these facilities are not
included
in determining federal permit applicability. Since the South Battery
is
located
adjacent to the Salem Gas Plant, emissions from both locations will be evaluated together
to determine federal permit applicability.
This document includes the required IEPA forms, area maps, plot plans, emissions data,
permit fee, process flow diagrams, and process descriptions, to demonstrate compliance
Citation
Oil
&
Gas Corp.
Salem Unit
3
June 2005
Construction Permit Application
,
with all applicable state and federal air permitting requirements.
A
summary of the existing
and proposed emissions is summarized in Tables
1-1 - 1-5
below.
a
T bl
e
1
-
1 P
ro
pose
dE
missions -
SI
aem G as
PI
ant
.
'. NO
x
'
co
YOM
so,
H
2
S
.
PM
1
()
EPN
.
:' Equipment
. ' ..
Ib/hr
TPY
Ib/hr
TPY
Ib/hr
TPY
Ib/hr
TPY
Ib/hr
TPY
Ib/hr"
TPY .
PVl
Bioreactor Ven1 Emissions
0.00
0.00
0.00
0.00
0.002
0.007
0.000
0.000
0.01
0.01
0.00
0.00
PHl
300
MBtu/hr Dehy Reboiter
0.02
0.08
0.02
0.07
0.001
0.004
0.000
0.000
0.00
0.00
0.001
0.006
PFL 1
Facility Flare
4.55
8.36
39.04
71.64
51.61
59.10
307.28
75.46
3.34
0.80
0.000
0.000
PFl
Equipment FU!=Iitives
0.00
0.00
0.00
0.00
6.91
30.28
0.00
0.00
0.263
1.150
0.000
0.000
Totals:
4.57
8.43
39.05
71.71
58.52
89.40
307.28
75.46
3.61
1.96
0.001
0.006
a
T
bl
e
1
-
2 E
XIS
. f
mg
E
missions -
N
0
rth B
a
tt
ery
': .
.. . .
·.<,_-NO~
:
'- . co
.•
VOM
so,
H,S
PM
10'
.
',,"
EPN"
:Eq'u!p~_ent
""hr
TPY.
Ib/hr
.TPY.
Iblhr
TPY
Ib/hr
TPY
Iblhr
-TPY.
.iblhr.
TPY'
"
NTl
400
bbl Oil Slack Tank #1
0.00
0.00
0.00
0.00
0.57
2.49
0.00
0.00
0.021
0.09
0.00
0.00
NT2
400 bbl Oil Stock Tank #2
0.00
0.00
0.00
0.00
0.572
2.49
0.00
0.00
0.021
0.09
0.00
0.00
NFL1
Facility Flare
0.004
0.02
0.03
0.13
0.04
0.20
0.19
0.85
0.002
0.01
0.00
0.00
NFl
Eauipment Fuqitives
0.00
0.00
0.00
0.00
0,,79
3.44
0.00
0.00
0.046
0.201
0.00
0.00
Totals:
0.004
0.02
0.03
0.13
1.97
8.61
0.19
0.85
0.09
0.40
0.00
0.00
T
a
bl
e
1
-
3 E
XIS
. f
mg E miSSions -
W
a
t
er
I'
nJec
f
Ion
PI
an
t
:.-'
,/'
, . ".
,
.NO
x
' co
YOM
"
so,
H
2
S .
"PM~'~:r
..
EPN
Equipment
Iblhr
TPY
. .Ib/hr
TPY
Iblhr
TPY
Iblhr
TPY
Ib/hr
TPY
Ib/hi '
TPY'
WFL 1
Tank Vent
0.00
0.00
0.00
0.00
2.97
14.54
0.00
0.00
0.11
0.55
0.00
0.00
WL1
Loading Emissions
0.00
0.00
0.00
0.00
9.50
5.13
0.00
0.00
1.05
0.57
0.00
0.00
WFl
Equipment Fugitives
0.00
0.00
0.00
0.00
0.47
2,06
0.00
0.00
0.029
0.129
0.00
0.00
Totals:
0.00
0.00
0.00
0.00
12.94
21.74
0.00
0.00
1.19
1.24
0.00
0.00
T
a
bl
e
14
-
E
xlstmg
.
E
missions -
S
ou th
B
a
tt
ery
.
..
,:.:::.
. .
,
NO,
CO
YOM
so,
H,S
. ,"\.':::PM'. ...
..
EPN
..
Equipme-nt
. -
.
'.
' Ib/hr,
.'
'
TPY
Ib/hr
TPY
Ib/hr
TPY
Ib/hr
.TPY
Ib/hr
TPY
Ib/hr"
•
.
10-
;T~Y
..
STl
400 bbl Oil Stock Tank #1
0.00
0.00
0.00
0.00
0.57
2.49
0.00
0.00
0.021
0.09
0.00
0.00
ST2
400
bbl Oil Stock Tank #2
0.00
0.00
0.00
0.00
0.57
2.49
0.00
0.00
0.02
0.09
0.00
0.00
PFL1
Facility Flare
0.004
0.02
0.03
0.13
0.04
0.20
0.19
0.85
0.002
0.01
0.00
0.00
SL
1
Loadinq Emissions
0.00
0.00
0.00
0.00
9.50
1,60
0.00
0.00
11.62
0.06
0.00
0.00
SFl
Equipment Fugitives
0.00
0.00
0.00
0.00
0.79
3.44
0.00
0.00
0.046
0.20
0.00
0.00
Totals:
0.004
0.02
0.03
0.13
11.47
10.21
0.19
0.85
11.71
0.461
0.00
0.00
T
a bl
e
1
-
5 Ttl
oa
E missions
f
rom
th
e
S
aem
I
G as
PI
an
t
an
dS
ou
thT an
kB
a tt
ery
NO,
e .
. Ibihr' .'
'TPY
..
'" Ib/hr
4.57
8.45
39.08
Citation
Oil
&
Gas Corp.
Salem Unit
CO
YOM
"
.TPY
Ib/hi
TPY.
71.84
69.99
99.61
4
SO,
Ib/hr
TPY.
307.47
76.31
H,S
PM
10
'
,.
Ib/hr
TPY
"Ibfhr
TPY
15.32
2.42
0.001
0.006
June 2005
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
2.0
PROCESS DESCRIPTION
OVERVIEW OF THE PROCESS
The equipment supplied
by NATCO for this project will integrate with existing and new
equipment
to be supplied by Citation Oil and Gas to enable value to be captured from
casing head gas.
The following process description is taken from the design
documentation provided
by NATCO, Proposal No. 2M994181 Rev. 2.
1. Inlet
Gas
Heating and Separation
Associated (sour) process gas and liquids from field compression will enter the plant at
approximately
50 psig. It is expected that a primary gas-liquids separator will be supplied
by the client at this point of the system.
Gas from the primary separator will be routed to
the NATCO Shell-Paques
unit Free liquids are removed from the gas stream by a NATCO
vertical separator, followed
by a NATCO MistTrap coalescer.
These separators are vital
to the overall performance of the system
by preventing hydrocarbon liquids from entering
the H2S contactors / scrubbers. Because of the configuration of the system with first-stage
field compression and buried flow lines to the main plant, it
is expected that the gas will
enter the plant at a temperature value of between 60-70'F. Optimum process gas
temperature range for this Shell Paques design
is 60-85°F to allow for suitable temperature
difference between the process gas and Paques process solution. An in-line electric gas
heater
is supplied within the pre-treat system to provide suitable gas temperature
conditions to the Shell Paques
unit The PLC control panel will have the capabilities to
operate the heater if the gas temperature is lower than 60°F, and/or to maintain a constant
85°F gas temperature to the H
2
S Gas Scrubbers.
Wet (sour) liquids from the plant inlet gas separator and the two NATCO supplied
separators are recycled back into the process. Treated gas from the H
2
S Scrubbers is
routed to a conventional gas-liquid separator that uses a coarse vane pack demister (in lieu
of a wire mesh demister). A spray nozzle is provided in this separator to enable in-situ
water-washing of the demister section to scrub out any residual Paques solvent from the
treated gas.
2. Gas
Treating
I
Sulfur Recovery
Scrubbed process gas is routed to the two H
2
S Scrubber vessels (piped in series), where
the gas is allowed to contact the Paques solvent for removal of H
2
S from the process
stream, The Paques solvent
is discharged from the H
2
S Scrubbers to the Bio-regeneration
system, which regenerates the solvent and the bacteria produce elemental sulfur.
A slipstream of solvent is routed to a decanting centrifuge (supplied
by client) for collection
and removal of elemental sulfur in solid (paste) form. The sulfur is suitable for dumping into
a waste bin. Filtrate liquid from this process
is allowed to drain into a Filtrate Tank, where it
is pumped back to the regeneration system.
Cilalion Oil
&
Gas Corp.
Salem Unit
5
June 2005
Construclion Permit Application
3. Refrigeration Unit
I
Process Cooling
Process cooling for the MRU and process cooling for the NATCO Shell Paques Unit are
supplied
by a closed loop refrigerant compression / condensing unit. This unit is a two-
stage Arial compressor with a discharge cooler / condenser and a receiver / accumulator
vessel. Refrigerant liquid from the receiver / accumulator are discharged
in parallel to the
MRU Chiller (evaporator) and to the Chilled Water evaporator.
Refrigerant vapors from the MRU chiller are routed to the compressor first stage suction.
The refrigerant compressor controls the pressure
on the evaporator shell. This indirectly
controls the process temperature
in the Cold Separator, which essentially controls the
amount of liquids allowed to condense from the process gas stream.
Refrigerant vapors from the Chilled Water evaporator are routed to the compressor second
stage suction, thus acting somewhat
as an economizer. Routing to the second stage
suction is vital
to prevent over-cooling of the chilled water to prevent inadvertent freezing of
the Paques solvent. A back-pressure valve
is supplied on the refrigerant vapor line to
provide further means of controlling the refrigerant bath temperature.
4.
Liquids Recovery from Process Gas
The treated gas, with
an H
2
S concentration of 4-10 ppmv, is further compressed in two
stages to a pressure of 550 - 785 psig, which
is more suitable for recovery of LPG and
heavier fractions. At these pressures the process gas
is chilled to a temperature of -20°F
in a conventional Mechanical Refrigeration Unit (MRU). The outlet gas is combined from
the MRU, stabilizer overhead, and wet condensate feed drum. At this time it
is expected
that this gas stream will be flared or possibly used to generate electrical power
in the future.
5. Liquids Stabilization
Liquids from the Stabilizer Feed Drum, and liquids from the MRU Cold Separator are routed
to the Stabilizer Column. The Stabilizer
is a non-refluxed reboiled absorber. Depending on
the operating conditions of the stabilizer system, the product liquids may
be discharged to
LPG storage tanks, or they may be "spiked" into the crude oil storage tanks. Overhead gas
from the Stabilizer
is routed to the outlet gas system.
6. Hydrate Inhibition and Stabilizer Heat Medium Supply
The MRU unit is equipped with a dual-purpose Ethylene Glycol (EG) heating and injection
unit. The injection unit functions as a conventional reconcentrator to deliver a controlled
rate of lean (80%) EG to the MRU Gas-Gas Heat Exchanger and Chiller. The lean EG is
distributed as a thin film on the cold surfaces of the heat exchangers and piping, and
function to dissolve into solution any hydrates that form from the gas stream due to the
cooling processes. The rate is controlled to insure that the maximum dilution of EG is 10%
(thus minimum 70% rich EG). The diluted
EG solution is collected in the three-phase MRU
Cold Separator and returned to the
EG reconcentrator unit.
A separate closed-loop hot
EG stream is pumped through the Stabilizer Reboiler tube
bundle. This stream provides the energy required to condition the liquid product to the
Citation
Oil
&
Gas Corp.
Salem Unit
6
June 2005
Conslruciion Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
\
desired vapor pressure value. The return EG stream is returned directly to the EG reboiler
firetube section.
THE BIO-DESULFURIZATION PROCESS
The following is taken from the Paques document entitled,
REMOVAL
OF
H
2
SFROM GAS
STREAMS Using THIOPAQ® TECHNOLOGY,
dated March 2003.
The THIOPAO process can be summarized
in a simplified block diagram:
SCRUBBER
GAS
WITHOUT H
2S
~
1
AIR OUT
AIR
BIOREACTOR
SULFIDE
'I
OXIDATION
SULFUR
•
SEPARATOR
r--- BLEED
f-------.- s"
Figure 2-1 Block diagram of the THIOPAO® process.
The gas enters a wet scrubber, typically a packed column,
and is desulfurized with a slightly
alkaline fluid. A demister section prevents carry-over of fluid. The cleaned gases leave the
scrubber at the top.
The spent scrubber liquid
is collected in the bottom of the scrubber and directed to the
bioreactor.
In the reactor bacteria convert, under the consumption of oxygen, the dissolved
sulfide into solid elemental sulfur, thereby regenerating caustic soda. The sulfur is separated
as a solid and the sulfur slurry can optionally be pumped into a sulfur recovery unit. In this
unit the slurry can be dewatered
and discharged as a cake for further use. The liquor is
returned to the reactor. The bioreactor effluent is recycled to the scrubber for renewed
removal of H
2
S. From the system a small bleed stream is taken in order to prevent built up of
formed salts.
Process Chemistry
The THIOPAO® process for treatment of gas can be considered
as a caustic scrubber
combined with a bioreactor in which the spent caustic solution is regenerated. A flow
diagram of the process
is shown in Figure 2-1.
In a scrubber hydrogen sulfide is absorbed under alkaline conditions, i.e. at pH 8-9. The
absorption of H
2
S proceeds according to the following equation:
H
2
S
+
NaOH
->
NaHS
+
H
2
0
From this equation it follows that alkalinity is consumed.
Citation Oil
&
Gas COlp.
Sa/em Unit
7
June
200S
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
High H
2
S removal efficiencies are feasible, because the H
2
S concentration in the washing
liquid entering the scrubber will
be virtually zero due to the high activity in the bioreactor.
In the THIOPAO® process, the alkalinity consumption due to the absorption of H
2
S, is
completely compensated as a result of the oxidation of hydrogen sulfide to elemental sulfur
which proceeds under oxygen limited circumstances:
NaHS
+
y:'O,
-'t SO
+
NaOH
The THIOPAO® process uses bacteria of the genera
Thiobacillus
to oxidize the hydrogen
sulfide. Since there
is a significant biological overcapacity in the reactor, variations in the
H
2
S loading rate can easily be handled.
A small part
«5%) of the dissolved sulfide will be completely oxidized to sulfate according
to:
2NaHS
+
40, -'t 2NaHS0
4
~
Na,S04
+
H ,S04
As a result of this reaction, caustic soda is required to neutralize the formed sulfuric acid.
This leads
to the production of a small bleed stream. The bleed stream (containing sodium
salts and some sulfur)
is harmless and can in most cases easily be discharged.
Compared
to caustic scrubbers the bleed stream is negligible and expensive treatment of
spent caustic is not necessary. Obviously caustic consumption figures for THIOPAO@
technology are significantly lower as for caustic scrubbers (savings are greater than 94%).
After dewatering, the produced sulfur
can be used for the production of sulfuric acid or as a
fertilizer.
Process Configuration
The process of removing H
2
S from biogas consists of three main sections. These include
an absorber, an aerobic (biological) reactor and a sulfur separation step. A schematic
overview of the system
is shown in Figure 2-2.
Citation
Oil
&
Gas Corp.
Salem Unit
8
June 2005
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
ABSORPTION
SECTION
REACTOR
SECTION
GAS
NAOH
NUTRIENTS
WATER
!--+PURGE
'----+ SULFUR
SULFUR RECOVERY
SECTION
Figure 2-2 THIOPAQ® process for biogas desulfurization.
1. Absorption section
Hydrogen sulfide is absorbed in an absorption tower. The gas enters at the bottom of the
column and flows upwards. The washing liquid is sprayed downwards from the top by
means of nozzles. The laden washing liquid is led to the aerobic reactor in which the
sulfides are oxidized.
2. Reaction section, aerobic reactor
The aerobic reactor contains the micro-organisms that oxidize the absorbed sulfides into
elemental sulfur. Reactor internals are used to ensure complete mixing and optimal mass
transfer of oxygen into the liquid phase. The volume of
the aerobiC reactor is designed in
accordance with the optimal activity of the bacteria.
The exhaust air from the reactor can normally be emitted without further treatment. The
reactor effluent is recycled to the absorber column to serve as scrubbing liquid.
An important process parameter is the amount of air being pumped into the reactor. This is
controlled accurately in order to minimize the formation of sulfate. The air dosage is therefore
automated based
on the oxygen content. This, and all other controls are controlled by a
PLC.
3. Sulfur recovery section
The produced sulfur is separated from the liquid by means of a settling unit. Part of the
reactor contents is circulated over the settler to maintain the desired dry solid content in the
system. The dry solids content of the settler underflow
is typically between 10 and 20%.
Citation Gil
&
Gas Corp.
Salem Unit
9
June 2005
Constructlon Permit Application
The sulfur slurry can be dewatered further by means of a decanter centrifuge or filter press
to obtain a dry-solid concentration of about 60-65%.
The sulfur will have a purity of about 95-98% on dry basis, the remainder is biomass. The
sulfur product
can be used as a raw material for the production of sulfuric acid at sulfuric
acid plants with facilities for burning waste acid and slurries.
In some countries the
biological produced sulfur
can be applied as a fertilizer. At this time, Citation proposes to
remove the sulfur
by truck for disposal in a nearby solid waste landfill.
Citation Oil
&
Gas Corp.
Salem Unit
10
June 2005
Cons/ruction Permit Application
3.0
PROCESS FLOW
,
1------------------------------------------------------------------------------------
. ,
,
1,000 MCFD
(4% H
2
S) from Gas
Gathering System
Electric Inline
heater
I
I
I
Bio-Desulfurization
Plant
Bioreactor
Vent
t
J
Flare Stack
,
"~~
...
I
Plant Fuel
I
I
I
2-Stage
Reciprocating
Electric Compressor
1
Refrigeration
Unit
Field Drip Trap
Condensate
(120 BOPD)
Fugitive Component Emissions
loading
Emissions
t
r
I
I
600 MCFD Residue Gas
----
Pressurized
NGL Storage
t
Vapor Recovery into
Gas Gathering System
I
Condensate
Tank
Pressurized NGL
Product Loading
Oil Sales
Figure 3-1 Simplified Process Flow Diagram of the
Salem Gas Plant
Citation
Oil
&
Gas Corp.
Salem Unit
J1
June 2005
Construction Permit Application
4.0
FACILITY DIAGRAMS
• Plot Pia n - North Battery
• Plot Plan - Water Injection Facility
• Plot Plan - South Battery
• Plot Plan - Salem Gas Plant
• Aerial Photo - North Battery
• Aerial Photo - South Battery and Proposed Flare and Gas Plant Locations
• USGS Topographic Map
Citation Oil
&
Gas Corp.
Salem Unit
12
June 2005
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
o
0
F acih\y Flare
NFl1
Oil Siock Tank Oil Sieck Tank
LACT Unit
North Battery
Shop
Equipment Leak Fugitives
NF1
N
NW
!
N[
~?
VI-/~."~~-E
SW"
'1
!X.
s
NTl
NT2
NT1
NT2
NFL1
NF1
Gunbarrel Tanks (2)
oR,""'"
n,,,,,
NFL
1 0
o 000
Freewater Kno,:kou\ Tanks (6)
0 0
EQUIPMENT LEGEND
OIL STOCK TANK
400 bbl
OIL STOCK TANK
400 bbl
NORTH BATIERY FLARE
OVERFLOW TANK
3,300
bbl
GUNBARREL TANK #1
600 bbl
GUNBARREL TANK #2
600 bbl
FREEWATER KNOCKOUT TANK #1
420 bbl
FREEWATER KNOCKOUT TANK #2
420 bbl
FREEWATER KNOCKOUT TANK '#3
420 bbl
FREEWATER KNOCKOUT TANK #4
420 bbl
FREEWATER KNOCKOUT TANK #5
420 bbl
FREEWATER KNOCKOUT TANK #6
420 bbl
NORTH BATIERY FUGITIVES
Meier
Building
-
~
OIL
& GAS
CORP_
North Battery Plot Plan
Marion County, Illinois
N 38" 34' 49.3" W 89' 0' 32.1"
Environmental Engineering, Inc.
ORA,WN BY: PED
PROJECT:
04-035
DATE:
05116/05
APPROVED" PEO
REVISED:
NOT TO SCALE
Vent
WV1
Pipeline Drl1in<lge
TanK
Tanks are rOlllcd
10
vent, W\!1
Lime Supply
Tank
o
o
o
o
o
Saild Supply
Tank
Waler InjecHon Plant
EQUIPMENT LEGEND
LIME SUPPLY TANK
5,000
bbl
SAND
SUPPl YTANK
5,000 bbl
SAND
QVERlfOW TANK
5,000
bbl
LIME
OVERFLOW TANK
20,000
bbl
PIPELINE DRAINAGE
TANK
2,000
bbl
WVl WATER INJECTION PLANT VENT
WF1
WATER INJECTION PLANT FUGITIVES
EQuipment Leak Fugilives
WF1
Water
-~
Injection Plant Plot Plan
Marion County, Illinois
N 38" 33' 58.8" W 89" l' 25.2"
Em'iroomental Engineering,
Inc.
DRAWN BY: PED
PROJECT:
04.035
DATE:
05/16105
APPROVED: PED
REVISED,
NOT TO SCALE
LAC1
o
Unit
Storage BlJildings
D
Equipment Leak Fugitives
SF1
N
s
Oil
o
Stock
lank
sn
Oil
o
Stock
T~nk
ST2
Vapor Recovery
Unit (VRU)
Condensate
o
lank
ST3
Gunbarrel Tanks (2)
Roured /0
flare,
PFL 1
00
000000
EQUIPMENT LEGEND
S11 OIL STOCK TANK
812 OIL STOCK TANK
513 CONDENSATE TANK
QVERFLOWTANK
GUNBARREL TANK # 1
GUNBARREL TANK #2
FREEWATER KNOCKOUT TANK #1
FREEWATER
KNOCKOUT TANK #2
FREEWATER KNOCKOUT TANK #3
FREI:WATER KNOCKOUT TANK #4
FREEWATER KNOCKOUT TANK #5
FREEWATER KNOCKOUT TANK #6
SFt SOUTH BATTERY FUGITIVES
Freewater Knockout Tanks (6)
400 bbl
400 bbl
210 bbl
3,300
bbl
600 bbl
600
bbl
420 bbl
420 bbl
420 bbl
420 bbl
420 bbl
420 bbl
Meier
Building
OIL
& GAS
CORP.
South Battery Plot Plan
Marion County, Illinois
N 38" 33' 19.9" W 89"
O' 50.2"
Environmental Engineering, Inc.
DRAWN BY: PED
PROJECT:
04-035
DATE:
05116105
APPROVED: PEn
REVISED:
NOT TO SCALE
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
0
Located
~1600'
North.Northwesr
N
38° 33' 37.6"
0 0 0
W
89°
O' 52.0'
Facil~Y
+
Flare
PFl1
NGL Product Tanks (3)
Mechanical
Control Building
Refligeration Plant
with Switch
Gem
I
I
Glycol DehydratOf
---------------
---------
Compressor
Propane
Refrig.
Reboller
PH'
I I
D
Chilled Water Skid
Transformer
l:lecllic Plant
Compression
D
,
Bio-Desulfurization Plant
Bioreactor Venl
PV,
EQuipment Leak Fugitives
PF1
EQUIPMENT LEGEND
r:r
JO
PHi
GL yeOL DEHYDRATOR REBOILER
300 MBlulhr
NGL PRODUCT TANK#1
30,000 gal
j
HD.lIf,"-,
NGL PRODUCT TANK#2
30,000 gal
-... O<L ,
GAS CORP.
N
NGL PRODUCT TANK#3
30,000 gal
Salem Gas Plant Plot Plan
NW
J,
NE
PV'
BIOREACTQR VENT
PFl1 GAS PLANT FLARE
Marion County, llIinois
PF1 GAS PLANT FUGITIVES
N 38" 33' 21.8" W 89" 0' 52.0"
~~
,
~"
W-~.-E
sw
lr.~'
1 SE
l~f!'~1
I
Environmental Engineering, Inc.
S
DRA.WN BY: PED
PROJECT:
04.035
DATE:
0:1/16105
APPROVED:
PEO
REVISED:
NOT TO SCALE
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
Aerial Photo - North Battery
Aerial Photo - South Battery and Proposed Salem Gas Plant Site
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
Name: CENTRALIA EAST
Dale:
6/4/2005
Scale: 1 inch equals 2000 feel
Location: 038
0
34' 05.96" N 089
0
00' 55.46" W
Caplion: Cilalion Oil and
Gas Corp.
Salem Unil Area Map
Marion Counly, Illinois
5.0
STATE REQUIREMENTS FOR PERMIT TO CONSTRUCT
In reviewing the potential applicability of state emissions standards, Citation has
summarized the pertinent Subparts and Sections that are included below.
TITLE
35,
SUBTITLE B: AIR POLLUTION, CHAPTER I: POLLUTION CONTROL BOARD
SUBCHAPTER
a: PERMITS AND GENERAL PROVISIONS
SUBPART
C: PROHIBITIONS
Section 201.146
Exemptions from State Permit Requirements
c) Each fuel burning emission unit for indirect systems and for heating and
reheating furnace systems used exclusively for residential, or commercial
establishments using gas and/or fuel oil exclusively with a design heat input
capacity of less than 14.6 MW (50 MMBtu/hr) , except that a permit shall be
required for any such emission unit with a design heat input capacity of at least
10 MMBtu/hr that was constructed, reconstructed or modified after June 9, 1989
and that is subject to 40 CFR 60, Subpart 0;
Citation will be operating
a
gas-fired glycol dehydrator reboiler (PH
1 )
rated at 300 MBtu/hr.
Therefore, this unit
is
exempt from state permitting requirements.
k) Safety devices designed to protect life and limb, provided that a permit is not
otherwise required for the emission unit with which the safety device
is
associated;
Citation
is proposing to operate the proposed air-assisted flare during times that the plant
experiences mechanical malfunction, power outages,
or other causes that are beyond their
operational control. The operation of the flare in these scenarios will be required to prevent
the release
of highly concentrated H
2
S gas to the atmosphere.
n)
Storage tanks of:
1)
Organic liquids with a capacity of less than 37,850 I (10,000 gal),
provided the storage tank is not used to store any material listed as a
hazardous air pollutant pursuant to Section 112(b) of the Clean Air Act,
and provided the storage tank
is not subject to the requirements of 35
III. Adm. Code 215.583(a)(2), 218.583(a)(2) or 219.583(a)(2);
2)
Any size containing exclusively soaps, detergents, surfactants, waxes,
glycerin, vegetable oils, greases, animal fats, sweetener, corn syrup,
aqueous salt solutions or aqueous caustic solutions, provided an
organic solvent has not been mixed with such materials; or
3)
Any size containing virgin or re-refined distillate oil, hydrocarbon
condensate from natural gas pipeline or storage systems, lubricating
oil or residual fuel oils.
Citation
Oil
and Gas Co/paratian
Salem Unit
20
June 2005
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
0)
Threaded pipe connections, vessel manways, flanges, valves, pump seals,
pressure relief valves, pressure relief devices and pumps;
p)
Sampling connections used exclusively to withdraw materials for testing and
analyses;
q)
All storage tanks of Illinois crude oil with capacity of less than 151,400 I
(40,000 gal) located
on oil field sites;
r)
All organic material-water single or multiple compartment effluent water
separator facilities for Illinois crude oil of vapor pressure of less than 34.5 kPa
absolute
(5 psia);
uu)
Piping and storage systems for natural gas, propane and liquefied petroleum
gas;
Citation
is
proposing
a
210-bbl (8,820 gallon) condensate tank (ST3) for collecting
condensate produced from
the collection of casing head gas in the field. In addition,
ancillary equipment associated with the bio-desulfurization unit, separators, fugitive
components, and
NGL product tanks are exempt from state permitting requirements.
TITLE
35,
SUBTITLE B: AIR POLLUTION, CHAPTER I: POLLUTION CONTROL BOARD
SUBCHAPTER
c: EMISSION STANDARDS AND LIMITATIONS FOR STATIONARY
SOURCES
PART 212 VISIBLE AND PARTICULATE MATTER EMISSIONS
Subpart B Visible Emissions
Section 212.123 Visible Emissions Limitations for All Other Emission Units
Citation will be operating
a
gas-fired glycol dehydrator reboiler (PH1) and air-assisted flare
(PH 1)
that will comply with the requirements
of
this Section.
PART 214 SULFUR LIMITATIONS
SUBPART K:PROCESS EMISSION SOURCES
Section 214.301 General Limitation
Citation will be operating
a
biovent (PV1) with trace amounts
of
H
2
S and air-assisted flare
that will combust
sweet
residue
gas
during normal operations. These units will comply with
the requirements
ofthis Section.
PART 216 CARBON MONOXIDE EMISSIONS
SUBPART B: FUEL COMBUSTION EMISSION SOURCES
Section 216.121
Fuel Combustion Emission Sources
This section does not apply to the fuel combustion sources at the Salem
Gas
Plant.
Citation Oil
&
Gas CO/po
Salem Unit
21
June 2005
Construction Permit Application
PART 217 NITROGEN OXIDES EMISSIONS
SUBPART
B: NEW FUEL COMBUSTION EMISSION SOURCES
Section 217.121
New Emission Sources
This section does not apply
to the fuel combustion sources at the Salem
Gas
Plant
as
they
are rated
< 250
MMBtulhr.
PART 232 TOXIC AIR CONTAMINANTS
SUBPART
D: SOURCE IDENTIFICATION AND REPORTING REQUIREMENTS
Section 232.430
Emissions Report
This section does not apply
to the emission sources at the Salem Gas Plant
as
they are
deminimis.
PART 243 AIR QUALITY STANDARDS
SUBPARTB:STANDARDSANDMEASUREMENTMETHODS
Section 243.120
PM-10
a)
Standards. The ambient air quality standards for PM-10 are:
1)
An annual arithmetic mean concentration of 50 micrograms per cubic
meter; and
2)
A maximum 24-hour concentration of 150 micrograms per cubic meter,
not to
be exceeded more than once per year
The emissions sources at the Salem Gas Plant will comply with these standards.
Section 243.122
Sulfur Oxides (Sulfur Dioxide)
a)
Primary Standards. The primary ambient air quality standards for sulfur
oxides measured as sulfur dioxide are:
1)
An annual arithmetic mean concentration of 80 micrograms per cubic
meter (0.03 ppm); and,
2)
A maximum 24-hour concentration not to be exceeded more than once
per year of 365 micrograms per cubic meter (0.14 ppm).
b)
Secondary Standard. The secondary ambient air quality standard for sulfur
oxides measured as sulfur dioxide is a maximum 3-hour concentration not to
be exceeded more than once per year of 1,300 micrograms per cubic meter
(0.5 ppm).
The emissions sources at the Salem Gas Plant will comply with these standards. In
particular, the operation
of
the air-assisted flare (PFL
1)
for safety purposes during times of
plant shutdowns or mechanical failure have been modeled to demonstrate compliance with
the S02 standards.
The resulting predicted impacts are included in Section
8.0
of this
document.
Citation Oil
&
Gas Corp.
Salem Unit
22
June 2005
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
Section 243.123
Carbon Monoxide
a)
Standards. The ambient air quality standards for carbon monoxide are:
1)
A maximum 8-hour concentration
not
to be exceeded more than once
per year of
10 milligrams per cubic meter (9 ppm); and,
2)
A maximum i-hour concentration not to be exceeded more
than
once
per year of 40 milligrams per cubic meter (35 ppm).
The emissions sources at the Salem Gas Plant will comply with these standards.
Section 243.124
Nitrogen Dioxide
a) Standard. The ambient air quality standard for nitrogen dioxide is an annual
arithmetic mean concentration of 100 micrograms per cubic meter (0.05 ppm).
The emissions sources at the Salem Gas Plant will comply with these standards.
Section 243.125
Ozone
a) Standard.
The ambient air quality standard for ozone is 0.12 ppm (235
micrograms per cubic meter) maximum
i-hour concentration not to be exceeded
on more than one day per year.
.
The emissions sources at the Salem Gas Plant will comply with these standards.
Section 243.126
Lead
a) Standard. The ambient air quality standards for lead and its compounds are 1.5
micrograms per cubic meter, maximum arithmetic mean average over a calendar
quarter.
The emissions sources at the Salem Gas Plant will comply with these standards.
Citation Oil
&
Gas Corp.
Salem Unit
23
June 2005
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
6.0
FEDERAL REQUIREMENTS FOR A PERMIT TO CONSTRUCT
New Source Performance Standards (NSPS)
The emissions from the proposed facility will meet the requirements of any applicable
NSPS as listed under Title
40 Code of Federal Regulations (CFR) Part 60, promulgated by
the EPA under FCAA,
§
111,
as amended.
Subpart Dc--STANDARDS OF PERFORMANCE FOR SMALL INDUSTRIAL-
COMMERCIAL-INSTITUTIONAL STEAM GENERATING UNITS
Citation will be operating
a
gas-fired glycol dehydrator reboiler (PH
1 )
rated
at
300
MBtulhr.
Therefore, this section does not apply per 60.40c(a) since it
is
rated <10MMBtulhr.
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
Citation
is
proposing
a
210-bbl
(8,820
gallon) condensate tank (ST3) for collecting
condensate produced from the collection
of casing head
gas
in the field and pressurized
NGL product tanks. These tanks are exempt from Kb standards under
60.
630b
(d) This subpart does not apply to the following:
(2) Pressure vessels designed to operate in excess of
204.9
kPa and without emissions to the
atmosphere.
(4) Vessels with
a
design capacity less than or equal to
1,589.874
m
3
used for petroleum or
condensate stored, processed, or treated prior to custody transfer.
Subpart KKK-Standards of Performance for Equipment Leaks of VOC From
Onshore Natural Gas Processing Plants.
Citation will be extracting natural
gas
liquids from the casing head
gas
and will therefore be
required to comply with the requirements of this section. However, since the Salem
Gas
Plant has
a
maximum production rate of
1.0
MMscfd, it will qualify for an exemption of
some
monitoring and recordkeeping pursuant to 60.633(d):
(d) Pumps in light liquid service, valves in gas/vapor and light liquid service, and pressure relief
devices in gas/vapor service that are located at
a
non fractionating plant that does not have the design
capacity
to process
283,200
standard cubic meters per day (scmd) (10 million standard cubic feet per
day) or more of field
gas
are exempt from the routine monitoring requirements
of
§§60.482-2(a)(1)
and 60.482-7(a), and paragraph (b)(1)
of this section.
Citation
Oil
&
Gas Corp.
. Salem Unit
24
June 2005
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
Since the air-assist flare will be used to control certain components applicable to NSPS
KKK standards, the flare will comply with the applicable requirements
of 40
CFR 60,
Subpart A, Section
60.18
regarding exit velocity and heating value.
Subpart LLL-Standards of Performance for Onshore Natural Gas Processing: S02
Emissions
NSPS Subpart LLL is applicable to the gas sweetening operations at the Salem Gas Plant.
Citation will certify that the facility
is exempt from the control requirements of the LLL
standards because it has a design capacity less that
2.0 L TID of H2S in the acid gas
(expressed as sulfur). Therefore, Citation shall keep, for the life of the facility, an analysis
demonstrating that the facility's design capacity
is less than 2.0 L TID of H2S expressed as
sulfur pursuant
to § 60.640(b):
(b) Facilities that have
a
design capacity
less
than
2
long tons per day (L TID) of hydrogen sulfide
(H
2
S) in the acid
gas
(expressed
as
sulfur) are required to comply with §60.647(c) but are not
required
to comply with §§60.642 through 60646.
40 CFR Part 61, National Emission Standards for Hazardous Air Pollutants
(NESHAP).
The emissions from the proposed facility will meet the requirements of any applicable
NESHAP,
as listed under 40 CFR Part 61, promulgated by EPA under FCAA, §112, as
amended.
There are no NESHAPs under 40 CFR
61
applicable to the Salem Gas Plant.
40 CFR Part 63, NESHAP for source categories. The emissions from the proposed
facility will meet the requirements of any applicable maximum achievable control
technology standard as listed under 40 CFR Part 63, promulgated by the EPA under FCAA,
§ 112 or
as listed under Chapter 113, Subchapter C of this title (relating to National
Emissions Standards for Hazardous Air Pollutants for Source Categories (FCAA §112, 40
CFR 63)).
The Salem
Gas
Plant will not constitute
a
major source
of hazardous air pollutants
as
defined
by 40 CFR.63 or FCAA
§112.
Therefore, the plant will not be subject to any
emission standards under Subpart HH
of 40 CFR 63.
40 CFR Part 51.165, Nonattainment Review
If the proposed facility
is located in a nonattainment area. it shall comply with all applicable
requirements
in this chapter concerning nonattainment review.
The Salem Gas Plant
is located in Marion County which is not
a
designated nonattainment
area.
Citation Oil
&
Gas Corp.
Salem Unit
25
June 2005
Construction Permit Application
40 CFR Part 52.21, Prevention of Significant Deterioration (PSD) Review
If the proposed facility is located in an attainment area, it shall comply with all applicable
requirements
in this chapter concerning PSD review.
This facility is
a
new source that will not exceed the major source threshold of 250 tons per
year. Therefore, PSD is not applicable to this project.
Citation Oil
&
Gas Corp.
Salem Unit
26
June 2005
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
7.0
EMISSION SOURCES AND CONTROLS
Emission sources from the Salem Gas Plant will include truck loading, gas flare, glycol
dehydrator reboiler, glycol dehydrator, bioreactor
and equipment fugitive components. The
proposed controls and the emissions bases for the affected sources are listed below.
Compression
Citation will operate one 250
hp, 2-stage electric driven compressor for inlet compression.
.1.
There will be no emissions associated with the operation of this unit.
Line Heater
An
electric line heater will be used to provide heat to the inlet gas at the plant. There will
X
be no emissions associated with the operation of this unit.
Combustion Units (Glycol Dehydrator Reboilerl
Citation will operate a gas fired reboiler to supply heat
to the glycol dehydration unit. The
reboiler is rated at 300 MBtu/hr and will burn sweet residue gas. NO
x
and CO emissions
from these units will
be quantified using current emission factors from AP-42, Fifth Edition,
Tables 1.4-1
(NOx & CO) and 1.4-2 (VOC, S02, & PM), NOx
emissions will be controlled
to
100 Ib-NOx/MMscf of natural gas burned and 84 Ib-CO/MMscf of natural gas burned.
T
a
bl
e
7
-
1 C
om
us Ion
m
'pera IOn
b f
U't 0
f
'Pollutant
Controls
Controll Emission
Basis
.
rate
NO
x
Good combustion and
100lb/MMscf
AP-42 factor
sweet gaseous fuels
CO
Good combustion and
84lb/MMscf
AP-42 factor
sweet gaseous fuels
VOC
Good combustion and
5.5 Ib/MMscf
AP-42 factor
sweet gaseous fuels
PM
10
Good combustion and
7.6Ib/MMscf
AP-42 factor
sweet gaseous fuels
S02
Good combustion and
0.6 Ib/MMscf
AP-42 factor
sweet gaseous fuels
Flare System
The flare at the Salem Gas Plant will
be designed and operated according NSPS 60.18
Q
requirements. Streams that will be vented to the facility flare will qualify as high Btu
streams. Typical Btu content for vent streams will range between 1,100 and 1,250 Btu/scf,
Composition of flared streams
is listed in Appendix B. The flare calculation worksheet in
Appendix B demonstrates compliance with the maximum tip velocity and minimum heating
value requirements of 60.18. Air-assist will be employed
to maintain smokeless operation.
Citation Oil
&
Gas CO/po
Salem Unit
27
June 2005
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
Citation is proposing to operate the proposed air-assisted flare during times that the plant
experiences mechanical malfunction, power outages, or other causes that are beyond their
. control. The operation of the flare
in these scenarios will be required to prevent the release
of highly concentrated
H2S gas. Emissions are based on a maximum production of 1.0
MMscfd inlet gas and are estimated using gas volume and composition data provided
by
NATCO process simulation software and mass balance of all contributing vent sources.
Two scenarios were
run for the flare including the flaring of residue gas during normal
operation and the worst-case S02 emissions that will occur during the flaring of sour inlet
gas during plant downtime. The worst-case emissions from each scenario are listed in the
emissions summary with the maximum allowed operation of the flare while burning sour
gas of 480 hours per year, or the equivalent of approximately
20 days of continuous flaring.
'[
a
bl
e
7
.
2 FI
are
o
Ipera
f
Ion
Pollutant
Controls
Controll Emission
Basis
rate
NO,
Good combustion,
0.0641 Ib/MMBtu
TCEO Flare
compliance with NSPS
Guidance,
10/2000
60.18
CO
Good combustion,
0.54961b/MMBtu
TCEO Flare
compliance with NSPS
Guidance,
10/2000
60.18
VOC
Good combustion,
98 % DRE
TCEO Flare
compliance with NSPS
Guidance,
10/2000
60.18
H2S and
Good combustion,
98 % DRE
TCEO Flare
S02
compliance with NSPS
Guidance,
10/2000
60.18
Bioreactor Vent - Bioreactor vent will emit trace quantities of hydrocarbon emissions
and
(j)
H2S. Because of the relatively insignificant quantities of these pollutants, the vent will emit
uncontrolled to the atmosphere. Emissions are based on a maximum production of 1.0
MMscfd inlet gas and are estimated using gas volume and composition data provided by
NA TCO process simulation software.
Glycol Dehydrator Vent -
T~e
glycol dehydrator vent. is routed to the facility flare. The
flare~
will control the trace organics In the vent stream with at least 98% destruction effiCiency.
Emissions are based
on a maximum production of 1.0 MMscfd inlet gas and are estimated
:{oYh'
using gas volume and composition data provided by NATCO process simulation software.
']V
.V
Tank Working and Breathing Losses
A 210-bbl condensate storage tank
is used for collection of drip trap condensate in the field.
Vapors from the tank are collected with a vapor recovery unit and routed back into the Gas
. Gathering System. Therefore, there are no emissions from the tank released to the
atmosphere. Annual working
and breathing losses from the tanks are estimated using the
EPA Tanks 4.09b emissions model. Short-term emissions from the tanks (Lmax) are
calculated using TCEO Storage Tank Technical Guidance by multiplying the working losses
Citation Oil
&
Gas Corp.
Salem Unit
28
June 2005
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
by the maximum fill rate and dividing by the tank capacity and number of tank turnovers.
Potential emissions are based
on a maximum production of 120 BOPD.
Condensate Loading Losses
r.:;}
Condensate loading will be accomplished using submerged fill-pipe to atmospheric trucks. 0
Uncontrolled emissions are estimated using current AP-42 emission factors from Chapter
5, Section 5.2.2.1.1 and site-specific data. Since loading of the collected drip trap
condensate will occur
at this location, loading emissions are based on a maximum loading
rate of 120 BOPD.
Equipment Fuqitives
Equipment fugitive emissions were estimated using facility component counts
and the
/Ii\
emissions factors derived for oil and gas production facilities from SOCMI
wlo
ethylenelJ)
factors. Emissions from fugitives are estimated usi ng a laboratory analysis of the inlet gas
and estimated compositions of the tank vapors.
Since the Salem Gas Plant will trigger NSPS KKK applicability, Citation will implement a
Leak Detection and Repair program pursuant to the referenced section with a 10,000 ppm
leak definition and daily walkthroughs to visually inspect for leaks
.. The proposed fugitive
emission counts for the plant are very conservative and will be refined after construction.
Ta b Ie 7-3
.
Pollutant
Controls
VOC
NSPS KKK, daily
walkthrough
H
2
S
Daily walkthrough
Citation Oil
&
Gas Corp.
Salem Unit
E
:quipment Lea
kF
ugitives
29
Controll
Emission
Basis
rate
Component
emission factors
Component
emission factors
TCEQ Fugitive
Guidance,
10/2000
TCEQ Fugitive
Guidance,
10/2000
June 2005
Construction Permit Application
8.0
AIR DISPERSION MODELING
Upon request, Citation will conduct refined air dispersion modeling to demonstrate that the
emissions of
all pollutants from the Salem Gas Plant are in compliance with applicable
state and federal standards. Citation has run preliminary dispersion modeling to determine
with impact of the proposed worst-case S02 emissions associated with the flaring of sour
gas during times that the plant experiences downtimes due
to mechanical failure, electrical
outages, or other conditions beyond their control. The results of the initial modeling are
included
in the table below. The maximum predicted ground level concentrations (GLCs) of
S02 that occur from the flare stack are less than 5% of the 3-hr standard of 1 ,300
~g/m3
Model Conditions: Flare stack modeled
@
40.0 feet and emission rate = 307 Ib/hr.
National Ambient Air Quality Standards (NAAQS) Analysis
"1 Hour
1 Hour
' 3
H~ur3-H~~r.,
24'Houf
',..
\High~,1't
<r.~-,c:"
"'Hi~~,2n~.
'~AA~~'
.,.: Hihh'2'"
Pollutant> High,
Limit
' High"" ',.,
c',
"High.,'
Predicted
'
Predicted' -
Li;:';i~'
", ' : Predicted'
:. -.
Limit
.
, , Arin(ial
'High_2
nd
"
. "'High' ';.:'
PredictE;",j"
GLC ".'
'~rinu~L,
~'~";\.{.'
':'.'.
'Limit,:
,
,
.:Tllgirrh;
[Ilg
im
']
,'G,L':C
GLC
,GLC.
Illg{rn'] :.
[Ilg
lm
']
<
[Ilg
/
m.'].>
1',\
[~g}n\']
[Ilg
im
']
so,
58.03
, 1,300
20,78
365
2.31
Notes:
[1] SO, GLCs compared to federal SO, NAAQS 3-hour, 24-hour and annual limits.
[2]. Background concentrations not considered in this analysis but expected to be insignificant.
[3], GLCs do not include "nearby" retrieval source contributions,
80
Citation Oil
&
Gas Corp,
Salem Unit
30
June 2005
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
9.0
PERMIT FEE
Citation has completed a 197-FEE Form - Fee Determination for Construction Permit
Application which
is included in Appendix A of this document. The amount submitted
includes a fee of $5,000
for the synthetic minor construction permit application with an
additional $4,000 for the first emission unit (flare, PFL-1) and an additional $3,000 for the
other proposed emission units (glycol dehydrator reboiler PH-1, bioreactor vent
PV-1 and
210-bbl condensate tank ST-3). Thus, the fee submitted with this application
is $12,000.
Citation
Oil
&
Gas Corp.
Salem Unit
31
June 2005
Construction Permit Application
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
J
Illinois Environmental Protection Agency
Division
Of Air Pollution Control -- Permit Section
P.O. Box
19506
Springfield. Illinois 62794-9506
Application Page
33
of
218
Application For
For Illinois EPA use only
10 number:
Construction Permit
Permit number:
(For CAAPP & FESOP Sources only)
Date received:
This form IS to be used
by
CAAPP and FESOP sources to supply Information necessary to obtain a construction permit. Please
attach other necessary information and completed CAAPP forms regarding this construction/modification project
1.
2.
3.
5.
6.
9.
10.
11.
14.
15.
16.
19.
21.
22.
Source Information
Source name:
Salem Unit - Gas Gathering and NGL Sales Project
Source street address:
2302 Hoots Chanel Road Odin IL 62870
City:
4.
Zip code:
Salem
62870
Is the source located within city limits?
0
Yes
X
No
Township name:
7.
County:
8.
10 number:
Marion
121813AAA
Owner Information
Name:
Citation Oil & Gas Com.
Address:
8223 Willow Place South
Suite
250
City:
12.
State:
13.
Zip code:
Houston
Texas
77070-5623
Operator Information
~if
different from owner)
Name:
Address:
City:
17.
State:
18.
Zip code:
Applicant Information
Who is the applicant?
20.
All correspondence to: (check one)
X
Owner
0
Operator.
X
Owner
Attenflon name and/or title for written correspondence:
Lee Ann Eisom, Environmental Coordinator
Technical contact person for application:
23.
Lee Ann
EI som
0
Operator
0
Source
Contact person's tele'PhoAe number:
(281) 517-7196
t.ilJlt:tr::~/I~
-.
,
Dtc
2 ..
lY
Je{bJ
/£P/J,
6?
.006
D"IPC
Sp,:
ThiS Agency IS authOriZed 10 require and you must disclose thiS Information under 415lLCS 5/39. Failure to do so could result In the
apPlical,onLD
being denied and penalties under 415 lLCS 5 el seq. It is not necessary to use this form in providing this information. Thisformhasbeen
approved by the forms monagemeni center.
Rev.
6/6/2003
Printed on Recycled Paper
199-CAAPP
Page 1 of 2
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
I
Application Page
34
of 218
Summary Of Application Contents
24.
Does the application address whether the proposed project would
X
Yes
No
constitute a new major source or major modification under each of the
0
following programs:
a) Non-attainment New Source Review - 35 lAC Part 203;
b) Prevention
of Significant Deterioration (PSD) - 40 CFR 52.21;
c) Hazardous Air Pollutants: Regulations Governing Constructed or
Reconstructed Maior Sources - 40 CFR Part 63?
25.
Does the application identify and address all applicable emissions
X
Yes
No
standards, including those found in the following:
0
a) Board Emission Standards - 35 lAC Chapter I, Subtitle B;
b) Federal New Source Performance Standards -
40 CFR Part 60;
c) Federal Standards for Hazardous Air Pollutants - 40 CFR Parts 61
and 63?
26.
Does the application include a process flow diagram(s) showing all
emission units and control equipment,
and their relationship, for which a
oermit is beinq sought?
X
Yes
0
No
27.
Does the application include a complete process description for the
emission units and control equipment for which a permit is being sought?
X
Yes
0
No
28.
Does the application include the information as contained in completed
X
Yes
No
CAAPP forms for all appropriate emission units and air pollution control
0
equipment, listing all applicable requirements and proposed exemptions
from otherwise applicable requirements,
and identifying and describing
any outstanding legal actions by either the
USEPA or the Illinois EPA?
Note:
The use of "APC" application forms is not appropriate for
applications for CAAPP sources.
CAAPP forms should be used to
supply information.
29.
If the application contains TRADE SECRET information, has such
Yes
No
information been properly marked and claimed, and have two separate
0
0
copies of the application suitable for public inspection and notice been
submitted, in accordance with applicable rules and regulations?
X
Not Applicable,
NoTRADE
SECRET
information in this
application
30.
Does the application include a complete form 197-FEE, "FEE
X
Yes
No
DETERMINATION FOR CONSTRUCTION PERMIT APPLICATION" for
0
the emission units and control equipment for which a permit for
construction or modification is being sought?
Note1: Answering "No" to any of the above may result in the application being deemed Incomplete.
Signature Block
This certification must be signed by a responsible official. Applications without a signed
certification will
be deemed incomplete.
31.
I certify under penalty of law that, based on information and belief formed after reasonable
inquiry, the statements and information contained in this application are true, accurate and
complete.
Autho~natu
BY,
~
r/~
Environmental Coordinator
/
AUTHORIZED SIGNATURE
TITLE OF SIGNATORY
Lee Ann Eisom
06
1
08
1
2005
TYPED OR PRINTED NAME OF SIGNATORY
DATE
Note 2: An operating permit for the construction/modification
..
permitted In a construction permit must be
obtained by applying for the appropriate revision to the source's CAAPP permit, ifnecessary.
Rev.
616/2003
Printed on Recycled Paper
199.CAAPP
Page 2
of 2
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
!
•
,
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
2171782-2113.
P.O. Box 19506,
SPRINGFIELD, ILLINOIS
62794-9506
Douglas
P.
Scott, Director
CERTIFIED MAIL
7002 3150 0000 1106 7193
NOTICE OF ADDITIONAL CONSTRUCTION PERMIT APPLICATION FEES
July 20, 2005
Citation Oil & Gas Corp
Attn:
Lee Ann Elsom
8223 Willow place South, Suite 250
Houston, Texas 77070-5623
Application
No.
:
1. D.
No.:
Applicant's Designation:
Received:
Construction of:
Location:
Additional Fee Now Due:
05060022
121813AAA
June 10, 2005
Gas
Gathering and NGL Sales
2302 Hoots Chapel Road, Odin
$1,000.00
This letter provides written notice that the Illinois EPA has determined that
the application for construction permit referenced above is subject to
additional application fees under Section 9.12 of Illinois' Environmental
Protection Act (Act).
Based on its initial review of the application for purposes of fees, the
Illinois EPA has determined that an additional fee of $1,000.00 is due.
You have £Q days to remit the assessed fee and revised Form 197-FEE to the
Illinois EPA. Please submit payment to the Illinois EPA at the following
address. Make either a check or money order payable to: "Illinois
Environmental Protection Agency" and reference both the application and 1. D.
numbers assigned above. The Illinois EPA will not accept cash payments.
Illinois Environmental Protection Agency
Division of Air Pollution Control
Permit Section (MC 11)
P.O. Box 19506
Springfield, Illinois 62794-9506
If the
additio~al
fee is not submitted within 60 days, the Illinois EPA is
not required to further review or process this application and the statutory
deadlines in Section 39(a) of the Act cease to apply to the application until
such time as the proper fee is submitted. The Illinois EPA may also deny the
application for failure to pay the appropriate fees. Also, please be aware
that the Illinois EPA's continuing review of the application during this 60-
day period may identify additional fees that are due or deficiencies in the
technical information that has been submitted in "the application.
The following explains the Illinois EPA's determination with respect to the
fees that are due for this application.
ROD R. BLAGOJEVICH, GOVERNOR
PRINTED ON RECYCLED PAPER
:
Page 2
1.
A construction permit for..a new synthetic minor ($5,000.00) plus first
new emission unit ($4,000.00) plus additional four units (4 x $1,000.00
= $4,000.00) for a fee total of $13,000.00. The $12,000.00 payment,
submitted by you, will be applied asa credit toward the $13,000.00
total construction permit application fee.
If you do not agree with the Illinois EPA's fee determination for this
application, you-may ask for reconsideration. A request for fee
reconsideration must include a new certified estimate (e.g., Form 197-FEE) of
the fees that are due and payment for any additional fees that are due based
on your new estimate.
TwO copies of this fee reconsideration request must be
submitted and must include any supporting material used in the new -estimate.
On all submittals, please reference both the application and
I.D ..
numbers
assigned above.
If you have any questions on this fee determination, please call George Kennedy
.'7JJj(~
ld
Dona
E. Sutton, P.E.
.
Cup
Manager of Permit Section
Division of Air Pollution Control
DES: GMK : jar
cc:
Illinois EPA, FOS Region 3
Paulette Blakes
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 NORTH GRAND AVENUE EAST,
P.O.
Box 19506, SPRINGfIELD, ILLINOIS 62794-9506 - ( 217) 782-2113
217/782-2113
PERMITTEE
ROD R. BLAGOJEVICH, GOVERNOR
CONSTRUCTION
DOUGlAS P.
SCOT
'IDJE~ ~ ~W~
rn\
,~"
lnl I
SEP I 111lTI51
~
A.E.G.
Citation Oil and Gas Corporation
Attn: Lee Ann Elsom
8223 Willow Place South, Suite
250
Houston, Texas
77070-5623
Application No.:
05060022
I.D. No.: 121813AAA
Applicant's Designation:
Date Received: June 9, 2005
Subject: Gas Gathering and NGL Sales Project
Date Issued: September 6,
2005
Expiration Date: See
Location: 2302 Hoots Chapel Road, Odin
JE-L
'1,
6
/::1::"
This permit is hereby granted to the above-designated Permittee to CONSTRUCT
emission unit(s) and/or air pollution control equipment consisting of:
II=PA OAPC SPFLD
Bioreactor Vent Emissions (PV1)
0.3 mmBtu/Hour Dehydrator Reboiler (PH1)
Facility Flares (PFL1)
Equipment Fugitives (PF1)
8,820 Gallon Condensate Storage Tank (ST-3)
pursuant to the above-referenced application. This permit is subject to
standard conditions attached hereto and the following special condition(s)
1.
No person shall cause or allow any visible emissions of fugitive
particulate matter from any process, including any material handling or
storage activity beyond the property line of the emission source,
pursuant to 35 Ill. Adm. Code 212.301.
2.
This permit is issued based upon emissions of photochemically
reactive
organic materials, as defined under 35 Ill. Adm. Code 211.4690, from
any
emission
source or operation using organic material, being less'
than 8 pounds per hour, pursuant to 35 Ill. Adm. Code 218.301.
3.
No person shall cause or allow the emission of sulfur dioxide in the
atmosphere from any process emission source to exceed 2000 ppm pursuant
to 35 Ill. Adm. Code 214.301.
4.
Equipment Fugitive Emissions shall not exceed the following limits:
VOM
(Tons/Mo)
(Tons/Yr)
3.03
30.29
E MIS S ION S
H,S
(Tons/Mo)
(Tons/Yr)
0.12
1.16
PRINTED ON RECYCLED PAPER
HAPs
(Tons/Mo)
(Tons/Yr)
0.15
1.42
Electronic Filing - Received, Clerk's Office, March 12, 2009
* * * * * PCB 2009-068 * * * * *
.,
Page 2
These limits are based on number of sources i.e. valves, flanges etc.,
Texas Commission on Environmental Quality (TCEQ), American Petroleum
Institute. and 8760 hours/year of operation. Compliance with the
annual limits shall be determined from a running total of 12 months of
data.
5.
Emissions form the facility flares shall not exceed the following
limits:
Emissions
Pollutant
(Tons/Month)
(Tons/Year)
VO~1
.5.91
59.1
NO,
0.84
8.4
CO
7.16
71.6
SO,
7.55
75.5
H,S
0.08
0.8
These limits are based on 227 mmscf/yr residue and sour plus 0.13
mmscf/year pilot gas, and gas analysis provided in application.
Compliance with annual limits shall be determined from running total of
12 months of data
6.
Emissions and operation of the dehydrator reboiler emissions shall not
exceed the following limits,
Pollutant
NO,
CO
PM
Emission Rate
(Lb/l0' scf)
100.0
84. a
7.6
Emissions
(Tons/Month)
(Tons/Year)
0.008
0.007
0.001
0.08
0.07
0.01
These limits are based on maximum reboiler operations, standard
emission factors AP-42, and 8,760 hours/year of operation. Compliance
with the annual limits shall be determined from a running total of 12
months of data.
7.
This permit is issued based on negligible emissions of volatile organic
materials (VOM) from the condensate storage tank.
For this purpose,
emissions shall not exceed nomirtal emissions rate of 0.1 Ib/hour and
0.44 tons/year.
8.
The flares shall have a heat sensing device, such as an ultraviolet
beam sensor or thermocouple, at the pilot light to indicate continuous
presence of a flame.
9a.
The Permi ttee shall maintain monthly records of the following items,
i.
Amount of gas burned in the facility flares (mmBtu/month,
'sef/month, scf/year and mmBtu/year) ;
Page 3
ii.
Amount of gas burned in the dehydrator reboiler (mmBtu/month.,
scf/month, scf/year and mmBtu/year); and
iii.
Monthly and annual
~OM,
NO
xl
H
2
S, and CO emissions with supporting
calculations (tons/month, tons/year).
b.
All records and logs required by this permit shall be retained
at a readily accessible location at the source for at least
three years from the date of entry and shall be made available
for inspection and copying by the Illinois EPA upon request.
Any records retained in an electronic format (e.g., computer)
shall be capable of being retrieved and printed on paper
during normal source office hours so as to be able to respond
to an Illinois EPA request for records during the course of a
source inspection.
10.
If there is an exceedance of the requirements of this permit as
determined by the records required by this permit, the Permittee shall
submit a report to the Illinois EPA's Compliance Section in
Springfield, Illinois within 30 days after the exceedance. The report
shall include the emissions released in accordance with the
recordkeeping requirements, a copy of the relevant records, and a
description of the exceedance or violation and efforts' to reduce
emissions and future occurrences.
11.
Two (2) copies of required reports and notifications concerning
equipment ope'ration or repairs, performance testing or a continuous
monitoring system shall be sent to:
Illinois Environmental Protection Agency
Division of Air Pollution Control
Compliance Section (#40)
P.O. Box 19276
Springfield, Illinois 62794-9276
and one (1) copy shall be sent to the Illinois EPA's regional office at
the following address unless otherwise indicated:
Iliinois'Environmental Protection Agency
Division of Air pollution Control
9511 West Harrison
Des Plaines, Illinois 60016
It should be noted that during the analysis of this permit application, it
was determined that your facility has the potential to emit more than 100 tpy
of VOM and will be classified as a major source under the Clean Air Act
Permit Program (CAAPP).
To avoid the CAAPP permitting requirements, you may
want to consider immediately applying for a Federally Enforceable State
Operating Permit (FESOP). A FESOP is an operating permit which contains
Federally enforceable limits in the form of permit conditions which
effectively restrict the potential emissions of a source to below major
source thresholds, thereby excluding the source from the CAAPP.
Please
I
Page 4
contact the Permit Section at 217/782-2113 to request the necessary
application forms.
Please note that this permit will expire one year from
the initial date of issuance.
If
you
have any questions on this permit, please contact George Kennedy at
217/782-2113.
Donald
~Efdi;~~
E. Sutton, P.E.
Manager, Permit Section
Division of Air Pollution Control
DES,GMK,psj
CC:
Region 3
J
STATE OF ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY
DIVISION OF AIR POLLUTION CONTROL
P. O. BOX 19506
SPRINGFIELD, ILLINOIS 62794-9506
STANDARD CONDITIONS FOR CONSTRUCTION/DEVELOPMENT PERMITS
ISSUED BY THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
July 1, 1985
The Illinois Environmental Protection Act (Illinois Revised Statutes, Chapter
111-1/2,
Section 1039) authorizes the
Environmental Protection Agency to impose conditions on permits which it issues.
The following conditions are applicable unless susperseded by special condition(s).
1. Unless this permit has been extended or it has been voided by a newly issued permit, this permit will expire one
year from the date of issuance, unless a continuous program of construction or development on this project has
started by such time.
.
2.
The construction or development covered by this permit shall be done in compliance with applicable provisions of
the Illinois Environmental Protection Act and Regulations adopted by the Illinois Pollution Control Board.
3. There shall be no deviations from the approved plans and specifications unless a written request for modification,
along with plans and specifications as required, shall have been submitted to the Agency and a supplemental
written permit issued.
4. The permittee shall allow any duly authorized agent of the Agency upon the presentation of credentials, at
reasonable times:
a. to enter the permittee's property where actual or potential effluent, emission or noise sources are located or
where any activity is to be conducted pursuant to this permit,
b. to have access to and to copy any records required to be kept under the terms and conditions of this permit,
c. to inspect, including during any hours of operation of equipment constructed or operated under this permit,
such equipment and any equipment required to be kept, used, operated, calibrated and maintained under this
permit,
d. to obtain and remove samples of any discharge or emissions of pollutants, and
e. to enter and utilize any photographic, recording, testing, monitoring or other equipment for the purpose of
preserving, testing, monitoring, or
~ecording
any activity, discharge, or emission authorized by this permit.
5. The issuance of this permit:
a.
b.
c.
d.
shall not be considered as in any manner affecting the title of the premises upon which the permitted
facilities are to be located,
does
not release the permittee from any liability for damage to person or property caused by or resulting from
the construction, maintenance, or operation of the proposed facilities,
does not release the permittee from compliance with other applicable statutes and regulations of the United
States, of the State of Illinois, or with applicable local laws, ordinances and regulations,
does not take into consideration or attest to the structural stability of any units or parts of the project, and
!L 532-0226
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09().005
APe 166
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\by 22,2003
Dll'~c~G:;-Y
Environmental Protection Agency
Bureau of
Air
For assistance
in
preparing a permit
Ipplication,
contad the Permit Section:
llIiuois
EPA
Divisiou of Air Pollution Control
Permit SectioD
1021
N.
Grand Ave
E.
P.O. Box 19506
Springfield, Illinois 62794-9506
217ns2-2113
.
'Or contact a regional office of the Field
Operations Sectwn. The regicnlll
~ffius
and their areas of responsibairy
lire shown on the map. The addresses
lind telephone numbers
of the regional
offices are as follows:
IDinolsEPA
Region 1
Bureau
of Air, FOS
9511 West Harrison
Des Plaiues, Illinois 60016
84712944000
lUiDol5 EPA
Region 2
5415 North Univiversity
Peoria, Illinois
61614
309/693-5461
IlIiuois EPA
Region 3
2009 Mall Street
Collinsville, Illinois 62234
618/346-5120.
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 NORTH GRAND AVENUE EAST,
P.O.
Box 19506, SPRINGFIELD, ILLINOIS 62794-9506 - ( 217) 782-2113
ROD R. BLAGOIEVICH, GOVERNOR
DOUGLAS P.
Scon,
DIRECTOR
Memorandum
Technical Recommendation for Tax Certification Approval
Date:
December 05, 2007
To:
Robb Layman
From:
Edwin
C. Bakowski'\;'
Subject: Citation Oil
& Gas Corporation TC-06-12-26
This Agency received a request on December 26, 2006 from Citation Oil & Gas Corporation for an
Illinois EPA recommendation regarding tax certification of air pollution control facilities pursuant to
35 III.
Adm. Code 125.204. I offer the following recommendation.
The air pollution control facilities
in this request include the following:
Bio Desulfurization Unit which reduces
S02 emissions by removing sulfur while
the residue gas
is flared. Because the primary purpose of this unit is to reduce or
eliminate air pollution, it is certified as a pollution control facility.
This facility
is located at 2302 Hoots Chapel Road, Odin, Marion County
The property identification number is 15-06-200-011
Based on the information included
in this submittal, it is my engineering Judgement that
the proposed facility may be considered "Pollution Control Facilities" under 35 lAC
125.200(a), with the primary purpose of eliminating, preventing, or reducing air pollution,
or as otherwise provided
in this section, and therefore eligible for tax certification from
the Illinois Pollution Control Board. Therefore, it is my recommendation that the Board
issue the requested tax Certification for this facility .
....................
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