DEPARTMENT OF ENVIRONMENT AND CONSERVATION TENNESSEE DIVISION OF AIR POLLUTION CONTROL, ANNUAL INSPECTION Reference No.: 84-0067 Environmental Specialist: BUG Route To: CMW State Class: Title V Pollutant(s): NOx Files Date Inspected: November 3, 2008 Company: Texas Gas Transmission LLC., Covington Compressor Station Location address: 3947 Charleston ~ Tabernacle Road City/State/Zip: Covington, TN 38019 Mailing Address, if different: Same Company Contact/Title: Andy Sullivan Phone: (901) 476-2847 ‘Does Company impact an additional control area? YES/NO: No. If Yes, pollutant type: N/A Does Company have: NSPS (Part 60)? GG PSD? No. NESHAPS (Part 61)? No. MACT (Part 63)? ZZZZ. IE YES, give subpart for NSPS, NESHAPS, MACT Sources If YES to any, indicate point number(s): Source 01 (All equipment permitted under source 01) Date of the last annual inspection: October 29, 2007 Time period covered by this inspection, from: October 29, 2007 — November 3, 2008 Is inspection partial or comprehensive? Comprehensive Total time required for this inspection (hours): 15.0 Was company in compliance during entire inspection time period? Yes, ENO, explain in final peragreph IfCM source: Date annual report received in EFO: N/A Date annual report review complete/acknowledged by EFO: N/A Did annual report have deviations from permit conditions (Y/N)? N/A EXECUTIVE SUMMARY: ‘The Covington Compressor Station is a natural gas pipeline link that compresses bulk gas for further transport and distribution through the pipeline network. This station consists of five Cooper-Bessemer GMW-6TF, two Cooper-Bessemer GMWA-6C, one Cooper-Bessemer GMWA-6 and two Cooper- Bessemer GMWA-10 natural gas fired reciprocating engines, and one Solar Mars T-14000 natural gas fired turbine engine, and associated emissions units that qualify as insignificant activities. There have been no equipment changes. Mr. David Goodwin has assumed the duties of V.P. of Operations. He replaced Mr. Alan Englehart, There have been no complaints recorded against this facility. (0.0544 (Rev. 9-06) RDA 1298Previous comprehensive site inspections were completed on November 2, 2006 and October 29, 2007. ‘The facility was found to be in compliance during each of these inspections. Title V renewal Perinit 557157, was issued December 5, 2005 with an expiration date of December 5, 2010. This permit was used to complete this inspection of the facility. The following is a condition by condition review of this permit, along with the corresponding notes and compliance calls: Permit Conditions — Title V Operating Permit 557157 (Renewal) — Issued December 5, 2005: Condition E] Fee payment: actual emissions basis, Emissions fees are based on the actual emissions analysis, The log required by Condition 33-1 is the method that the company uses to calculate their actual emission fees. Compliance call is deferred to the Fees Section. The log is retained as required. See notes related to Condition E3-1. Condition E2 (a) Semiannual reporting requirements: The report shall cover the period from July 1" to December 31" of each year. Each report shall be submitted within 60 days after the end of the 6-month period and shall include the recordkeeping and monitoring required by Condition E3-1. Compliance call is deferred to the West TN Permitting Program. Based on the February 19, 2008 letter (attached) from TAPCD to the company, the SAR for the period of July 1, 2007 — December 31, 2007 was received on February 11, 2008 and was found to be adequate. Based on the August 29, 2008 jetter (attached) from TAPCD to the company, the SAR for the period of January 1, 2008 ~ June 30, 2008 wes received on August 25, 2008 and was found to be adequate, Condition E2(b) Annual compliance certification reporting requirements: The permittee shall submit ‘annual compliance certifications (ACC) in accordance with Condition BS of this permit. The certifications shall cover the period of January 1" to December 31" and shall be submitted within 60 days after the end of each 12-month period. Compliance call is deferred to the West TN Permitting Program. Based on the February 11, 2008 letter (attached) from TAPCD to the company, the ACC that covered the period of January 1 ~ December 31, 2007 was received on February 11, 2008 and was noted to be adequate. Condition B3-1 For the purpose of calculating actual emission fees, the permittee shall maintain records of fuel usage and horsepower-hours of operation (the amount of attained horsepower summed over each hour of operation) for each of the compressor engines and the turbine. These records shall be kept for a petiod of no less than five years, In compliance, the required log is retained and was up to date. 1 cross-referenced the date in the log (Horsepower Hours & Fuel Use) with the back-up data in the company’s computer software for the months of September and October of 2007 and March and June of 2008. All of the Horsepower Hour values were accurate. Minor differences were noted in the Fuel Use values, Mr. Sullivan and I reviewed the data and determined that the differences were related to the Company's corporate method of calculating fuel usage. In the past a standard BTU value was used to caloulate fue] usage. Currently, the company samples the fuel hourly and then calculates a monthly ‘average BTU value, which is used to calculate the fuel usage values listed in the monthly log for each engine ot tmbine, The log is maintained and submitted by corporate environmental personnel. Mr, Sullivan is not provided the monthly average BTU value, So this data cannot be accurately spot- checked. The values fluctuate between 1025 and 1029 Btw/CF. As noted in the first sentence of this permit condition, these values are not related to a permit limit. They are used to calculate fees, which are based on actual emissions. (ON-0844 (Rev. 9:06) RDA 1298,VY Condition B3-2 limits the rated input capacity for the Solar-Mars Turbine to no more the 96.3 MM BTU per hour based on firing natural gas with an LHV of 919.4 BTU/SCF. The Cooper-Bessemer GMWA- 6C engines #6 and #7 are limited to 1550 HP each. There is an allowance for ambient conditions. Compliance call is deferred to the West TN Permitting Program. There has been no change in the ‘equipment and the Technical Secretary has required no additional proof of compliance. Condition E3-3 places limits on the particulate matter emissions from the turbine (TBO2) and the Cooper-Bessemer GMWA-6C engines (RC06 and RCO7) to less than 0.144 pounds per million BTUs of heat input (18.8 Ibs./hr.). Particulate matter emitted from the remainder of this source shall not exceed 0.316 pounds per million BTUs of heat input (37.6 Ibs /ar.). Compliance is to be determined by the annual certification of compliance. Therefore, the total particulate matter emitted from this source shal] not exceed 56.4 pounds per hour. The potential emissions from each piece of fuel bumning equipment that constitutes this source are less than 5 tons per year. By certification of compliance, the permittee shall be considered to meet the monitoring and related recordkeeping and reporting requirements of the rules listed in this permit condition, Compliance call is deferred to the West TN Permitting Program. Based on the company’s records and the data in the company file, the most recent ACC appears to have ‘been submitted to the West TN Permitting Program within the required timeframe. Condition E3-4 limits the emissions of sulfur dioxide from the Solar Mars T-1400 turbine (TBO2) to less than 0.015 percent by volume at 15 percent oxygen on a dry basis. Sulfur dioxide emitted from the Cooper-Bessemer engines shall not exceed 5 pounds per million BTU heat input. The potential sulfur dioxide emissions are less than 5 tons per year. By certification of compliance, the permittee shall be considered to meet the monitoring and related recordieeping and reporting requirements of the rules listed in this permit condition. Compliance call is deferred to the West TN Permitting Program. Based on the company's records and the data in the company file, the most recent ACC appears to have been submitted to the West TN Permitting Program within the required timeframe. Condition E3-5 limits the emissions of nitrogen oxides from the Solar Mars T-1400 turbine (TBO2) to less than 0.020 percent by volume at 15 percent oxygen on a dry basis and 75.6 pounds per hour, Nitrogen oxides emitted from the Cooper-Bessemer GMWA-6C engines (RCO6 and RCO7) engines shall not exceed 26.5 pounds per hour. Compliance with these emission standards is based on the source tests conducted on April 22, 1992 and on February 23, 1993. No compliance call. Condition E3-6 limits visible emissions to no greater than 20% opacity, except for one (1) six-minute period in any one (1) hour period, and for no more than four (4) six-minute periods in any twenty-four (24) hour period. Visible emissions from this source shall be determined by EPA Method 9. Compliance with the opacity standard is assured by the procedures of the Division’s Opacity Matrix. In compliance, three engines (#2, #8 and #9) along with the Solar Mars Turbine (TBO2) were operating during the site inspection, No visible emissions were noted from any of these units. I conducted a VEE on Engine #9 during the inspection, 0.0% opacity was noted during the observation period. A copy of the VEE is attached, No visible emissions evaluations are required by the Opacity Matrix. Condition E3-7 the Solar Mars T-14000 turbine (TBO2) is subject to all applicable requirements of 40 CFR Part 60, Subpart GG, Standards of Performance for Stationary Ges Turbines (NSPS). In compliance, this turbine does not use steam or water injection to control NOx emissions; therefore, a continuous monitoring system is not required by this subpart. The facility demonstrates compliance with this subpart by certifying the gas quality characteristics vie a tariff sheet. This taviff sheet certifies compliance with this condition as well as Condition E3-8. A copy is retained on file by the facility and a copy is also attached to this report. N-0844 (Rev. 9-06) RDA 1298Condition E3-§ only pipeline natural gas with a sulfur content of twenty (20) grains or less of total sulfur per 100 cubic feet shall be used as fuel for this source. Sampling is unnecessary for fuels that qualify as natural gas. In compliance, the facility completed sulfur content analyses of the natural gas fuel until the issuance of this permit (December 2005). The attached tariff sheet certifies compliance with the requirements of this permit condition, Condition E3-9 one or more of the engines/turbines or engine/turbine components may be removed or replaced with new, repaired or refurbished equivalent capacity engines/turbines of in-kind components, in order to maintain gas delivery capacity. In compliance, no such changes have been necessary during this inspection period. Condition £3-10 portable compressor engines, such as Allison KV501, Solar Centaur or Solar Saturn, ‘may be used on an interim basis (up to three months) to temporarily replace the existing unit (or units) under maintenance of repair. In compliance, no such changes have been necessary during this, inspection period. Conclusion: Texas Gas Transmission LLC., Covington Compressor Station was found to be in compliance in that no compliance problems were found with any issue under the purview of this inspector. Rural Dono Taspector's Name ‘VEE Certification Numiber: 1553, Certification Expiration Date: 3/19/09 | verify that the format and content of this report conforms to established TN Division of Air Pollution Control annual inspection standard operational procedures guidance and that the compliance determination made in this report is correct. dt Ahlen Ut (0. 08 Use| fanager Date an (Cw.084a (Rev. 9-06) RDA 1298