Blackstone prepared an air quality construction permit application for a natural gas liquids fractionation facility in Kansas. The project included updates to existing equipment within the fractionation train plus the addition of new equipment, including a boiler, a cooling tower, and piping & equipment components. Blackstone was provided the engineering plans for the proposed new and modified equipment and utilized that information, as well as ongoing discussions with the project engineering design team, to determine affected emission sources and to develop a permitting strategy.
Blackstone developed emissions calculations for the project, including baseline and past actual emissions to determine applicability of Prevention of Significant Deterioration (PSD) permitting, and potential emissions to determine applicability of state construction permitting. Several iterations of emissions calculations were prepared as the project design progressed. The past ten years of emissions inventories and production information was collected and reviewed to determine an appropriate baseline period. Since this project included both new equipment and modifications to existing equipment, a hybrid approach was taken for the PSD applicability assessment, using an actual-to-potential test for the new emission units and a baseline-to-projected actual test for the modified emission units. Ultimately, the project did not exceed the threshold for PSD permitting and a state level permit was required.
Blackstone developed a permit application for the project that included the applicable state forms, a review of prior projects to determine if any projects were substantially related, a discussion of the PSD applicability review and emissions calculations, and a review of federal and state regulations applicable to the project. Equipment that was part of this project was determine to be subject to two New Source Performance Standards (Subpart Db and Subpart OOOOa). Potential hazardous air pollutant emissions were also estimated for the entire facility after the project to show that the facility would not become a major source of hazardous air pollutants after the project was complete.