HomeMy WebLinkAbout20130342.tiffSTATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbina, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.co.us
January 25, 2013
Mr. Steve Moreno
Weld County Clerk
1402 N. 17th Ave.
Greeley, CO 80631
Dear Mr. Moreno:
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Colorado Department
of Public Health
and Environment
'The Air Pollution Control Division will publish a public notice for Encana Oil & Gas (USA) Inc. This
public notice will be published in the Greeley Tribune on January 30, 2013.
Thank you for assisting the Division by making the enclosed package (includes public notice,
preliminary analysis, Air Pollutant Emission Notice(s) and draft permit(s)) available for public review
and comment. It must be available for public inspection for a period of thirty (30) days from the date
the public notice is published.
Please forward any comment regarding this public notice to the address below.
Colorado Department of Public Health and Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Attention: Ellen Evans
Regards,
Ellen Evans
Public Notice Coordinator
Stationary Sources Program Air Pollution Control Division
( ti �eoteeiCJ
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2013-0342
STATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbino, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.co.us
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Website Title: Encana Oil & Gas (USA), Inc. — Gratton 1 20 — Weld County
Released to: The Greeley Tribune on January 25, 2013, published January 30, 2013
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
Colorado Department
of Public Health
and Environment
The Colorado Air Pollution Control Division declares the following proposed construction
activity warrants public comment. Therefore, the Air Pollution Control Division of the Colorado
Department of Public Health and Environment hereby gives NOTICE pursuant to Section 25-7-
114.5(5), C.R.S. of the Colorado Air Quality Control Act that the Division received an
application for an air pollution emission permit on the following proposed project and activity:
Encana Oil & Gas (USA), Inc. proposes to operate a wellhead site with condensate tanks and
truck loadout located at the SESE of Section 30, Township 2 North, Range 64 West in Weld
County. The company has submitted an application requesting issuance of a federally enforceable
synthetic minor source permit limiting the potential to emit. As a synthetic minor source the
permit is subject to public comment per Regulation 3, Part B, Section III.C.1.
The Division hereby solicits and requests submission of public comment from any interested
person concerning the aforesaid proposed project and activities to comply with the applicable
standards and regulations of the Commission for a period of thirty (30) days from the date of this
publication. Any such comment must be submitted in writing to the following addressee:
Stephanie Chaousy, P.E.
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B l
Denver, Colorado 80246-1530
Within thirty (30) days following the said thirty (30) -day period for public comment, the Division
shall consider comments and, pursuant to Section 25-7-114.5(7)(a), either grant, deny, or grant
with conditions, the emission permits. Said public comment is solicited to enable consideration of
approval of and objections to the proposed construction of the subject project and activity by
affected persons.
A copy of the applications for the emission permits, the preliminary analysis of said applications,
and accompanying data concerning the proposed project and activity are available for inspection
at the office of the Clerk and Recorder of Weld County during regular business hours and at the
office of the Air Pollution Control Division, Colorado Department of Public Health and
Environment, 4300 Cherry Creek Drive South, Denver, Colorado. A copy of the draft permit and
preliminary analysis are available on the Air Pollution Control Division's website at:
http://www.colorado.gov/cs/Satellite/C DPHE-AP/CBON/ 1251596498449
sir
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Encana Oil & Gas (USA) Inc.
Permit Number:
12WE2463
Source Location:
SESE Section 30, T2N, R64W, Weld County (non -attainment)
Equipment Description:
Point 001: Eleven condensate storagedanks
Point 003: truck loadout
AIRS ID:
123-99E9
Date:
December 18, 2012
Review Engineer
Stephanie Chaousy, PE
Control Engineer:
Chris Laplante
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
CP1
Transfer of Ownership
APEN Exempt/Permit Exempt
Section 3 — Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
X
Yes
No
Did the applicant submit all required paperwork?
X
Yes
No
Did the applicant provide ample information to determine emission rates?
X
Yes
No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
I sent Encana a question regarding
the number of tanks onsite. Please
refer to Section 14
On what date was this application complete?
August 3, 2012
Section 4 — Source Description
AIRS Point
Equipment Description
001
One (1) 100 BBL and ten (10) 330 BBL above ground atmospheric condensate
storage tanks. Emissions from these tanks are controlled by a combustor.
003
Truck condensate loadout.
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
X
Yes
No
If "yes", for what pollutant?
PM10
CO
X
Ozone
Is this location in an attainment maintenance area for
any criteria pollutant?
Yes
X
No
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT per Regulation 3, Part B, Section III.D.2)
PM10
CO
Ozone
Page 1
Alb
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
Regulation 7, Sections XII and XVII.C may apply)
X
Yes
X
No
Point 003: Is this source located at an oil and gas
exploration site?
X
Yes
No
Point 003: If yes, does this source load less than
10,000 gallons of crude oil per day on an annual
average, splash fill less than 6750 bbl of condensate
(hydrocarbons that have an API gravity of 40 degrees
or greater) per year or submerged fill less than 16,308
bbl of condensate per year?
Yes
X
No
Point 003: Is this source located at a facility that is
considered a major source of hazardous air pollutant
(HAP) emissions?
Yes
X
No
Point 003: Will this equipment be operated in any
NAAQS nonattainment area?
X
Yes
No
Point 003: Does this source load gasoline into
transport vehicles?
Yes
X
No
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
001
Operator provided site -specific emission factors using E&P Tanks. Refer to
Section 14 for calculations.
003
AP -42: Chapter 5.2, Equation 1
L = 12.46*S*P*M/T
L = loading losses in lb per 1000 gallons loaded
S = Saturation Factor
P = true vapor pressure of liquid loaded [psia]
M = molecular weight of vapors [lb/lb-mole]
T = temperature of bulk liquid loaded [deg. R]
Did the applicant provide actual process data for the emission inventory?
X
Yes
No
Basis for Potential to Emit (PTEI
AIRS Point
Process Consumption/Throughput/Production
001
91,781 BBL per year (76484 * 1.2)
003
91,781 BBL per year
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
001
76,484.2 BBL per year
2012
003
91,781 BBL per year
2012
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
001
91,781 BBL per year
003
91,781 BBL per year
Does this source use a control device?
X
Yes
No
AIRS Point
Process
Control Device Description
% Reduction
Granted
001
01
Combustor
95
Page 2
Section 6 — Emission Summa
(tons per year)
Point
NO,
VOC
CO
Single HAP
Total HAP
PTE:
001
2.0
1056.7
11.0
15.8 (Hexane)
21.1
(�U2)
---
8.8
---
0.7 (n -hexane)
1.0
003
---
15.3
0.4 (n -hexane)
0.9
Uncontrolled point
source emission rate:
001
2.0
1056.7
11.0
15.8 (Hexane)
21.1
GP5
(002)
__
8.8
---
0.7 (n -hexane)
1.0
003
---
15.3
---
0.4 (n -hexane)
0.9
TOTAL (TPY)
2.0
1080.8
11.0
16.9 (n -hexane)
23.0
Controlled point
source emission rate:
001
2.0
52.8
11.0
0.8 (Hexane)
1.1
GP5
(002)
_
10.0
---
0.7 (n -hexane)
1.0
003
---
15.3
0.4 (n -hexane)
0.9
TOTAL (TPY)
2.0
78.1
11.0
1.9 (n -hexane)
3.0
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(Ib/yr)
Are the
etabe
reportable?
Controlled Emission
r
RateIb/ ( y )
Point 001
Benzene
71432
A
5232
Yes
262
Toluene
108883
C
3671
Yes
184
Ethylbenzene
100414
C
367
No
18
Xylenes
1330207
C
1193
Yes
60
n -Hexane
110543
C
31664
Yes
1583
Point 003
Benzene
71432
A
287
Yes
287
Toluene
108883
C
506
No
506
Ethylbenzene
100414
C
21
No
21
Xylenes
1330207
C
223
No
223
n -Hexane
110543
C
711
Yes
711
Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non -criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
X
Yes
No
If "yes", complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
001
01
VOC/HAPs
State only requirement
peci
Site-specificp
sampling
Page 3
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
PSD
X
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why?
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?
X
Yes
No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
X
Yes
No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
Yes X No
AIRS Point
Section 12 — Regulatory Review
Requlation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
001, 003
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator
of a source shall allow or cause the emission into the atmosphere of any air pollutant which
is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings
taken at 15 -second intervals for six minutes. The approved reference test method for
visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July,
1992)) in all subsections of Section II. A and B of this regulation.
Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner
or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty
consecutive minutes.
Requlation 2 — Odor
001, 003
Section I.A - No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are
measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Re.ulation 3 - APENs, Construction Permits, O.eratinq Permits, PSD
001, 003
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in a non -attainment area with uncontrolled actual emissions
of one ton per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is nonattainment.
(Applicant is required to file an APEN since emissions from condensate production
are greater than 1 ton per year VOC)
001, 003
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section ll.D.2.a)
Re.ulation 6 - New Source Performance Standards
Page 4
001
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
Is this source greater than 19,800 gallons (471 bbl)? No
Is this source subject to NSPS Kb? No
WHY? Tanks at this facility are all less than the 471 BBL threshold. Therefore, not subject
to NSPS Kb.
003
No applicable subpart. This facility is not a bulk •asoline terminal.
Regulation 7 — Volatile Or. anic Compounds
001
XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
(Applicant is subject to the emission control requirements for condensate tanks
since it is located in a non -attainment area.)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
(Applicant is currently subject to this since actual uncontrolled emissions are
greater than 20 tpy of VOC.)
003
No sections apply. This facility is neither a terminal, nor a bulk plant per definitions in Reg
7, Section VI.C.
Regulation 8 — Hazardous Air Pollutants
001, 003
MACT EEEE: Organic Liquids Distribution
This source is not subject to MACT EEEE because it is not located at a major source of
HAP.
001
MACT HH
This source is not subject to MACT HH because it is not located at a major source of HAP.
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process
Description
Emission Factor
Pollutant/
CAS #
Fugitive
(YIN)
Emission Factor
Source
Control
(%)
001
01
E&P Condensate
Storage Tanks
548.268 lb/1000 gal
VOC
No
Engineering
Calculation
95
1.361
lb/1000 gal
Benzene
No
Engineering
Calculation
95
0.964
lb/1000 gal
Toluene
No
Engineering
Calculation
95
0.086
lb/1000 gal
Ethylbenzene
No
Engineering
Calculation
95
0.309
lb/1000 gal
X lenes
y
No
Engineering
Calculation
95
8.225
lb/1000 gal
n -hexane
No
Engineering
Calculation
95
SCC
40400311 — Fixed Roof Tank, Condensate, working+breathing+flashing
losses
003
01
Truck
Condensate
Loadout
91,781
BBLJyr
7.911b/1,000
gal
VOC
No
AP -42
0
0.0744
lb/1,000 gal
Benzene
No
Engineering
Calculation
0
0.1313
lb/1,000 gal
Toluene
No
Engineering
Calculation
0
0.0055
lb/1,000 gal
enylbenzene
No
Engineering
Calculation
0
0.0577
lb/1,000 gal
Xylenes
No
Engineering
Calculation
0
0.1843
lb/1,000 gal
n -hexane
No
Engineering
Calculation
0
SCC
40600132: Crude Oil: Submerged Loading (Normal Service
Page 5
Section 14 —Miscellaneous Application Notes
AIRS Point
001
Condensate Storage Tanks
I emailed Encana on 12/18/12: The APEN does not list the total tank capacity (bbl). I was hoping you
can help me with this piece of information. Paul Buck with Encana called back on 12/19/12 providing
information on the total tank capacity. He said that there was one 100 -BBL and ten 330 -BBL tanks
onsite. I quickly emailed him asking him to confirm the year the tanks were in place. These sources are
emitting a lot of emissions and I want to make sure before I grant them GF status, that they meet it.
APEN says that the source was in place in 2000, which is prior to December 30, 2002. He wrote back on
12/19/12: No, the 2000 is incorrect- the 10 330s were associated with the new wells were put in service
in 2012. The one tank associated with the 100 bbl tank is associated has been in service since 1985.
Therefore, this source has been modified and lost its grandfather status, therefore, will require a permit.
Operator provided site -specific emission factors using an extended gas analysis dated 7/11/12 and E&P
tanks. The emission factors are:
VOC = (1056.732 *2000)/91781 = 23.027 lb/bbl* 1000/42 = 548.268 lb/1000 gal
Benzene = (2.623*2000)/91781 = 0.057 lb/bbl * 1000/42 = 1.361 lb/1000 gal
Toluene = (1.858*2000)/91781 = 0.040 lb/bbl * 1000/42 = 0.964 lb/1000 gal
Ethylbenzene = (0.165*2000)/91781 = 0.004 lb/bbl * 1000/42 = 0.086 lb/1000 gal
Xylenes = (0.595*2000)/91781 = 0.013 lb/bbl * 1000/42 = 0.309 lb/1000 gal
n -hexane = (15.853*2000)/91781 = 0.345 lb/bbl * 1000/42 = 8.225 lb/1000 gal
12/19/12: I had a few questions for the operator regarding the O&M plan:
1. Section 2: Both boxes have been checked. I typically see only one box checked. Is this correct?
If not, which one should it be? Paul Buck called on 12/19/12 and said that the second box should
be checked, not the first. I redlined the O&M and made sure the correct information was added
in CACTIS.
2. Section 4: Backup method was checked for "Other" however there were no attachments to the
O&M plan. Should backup just be the tank level measurements? Paul Buck called on 12/19/12
and said to remove the "other." I redlined the O&M and made sure the correct information was
added in CACTIS.
Page 6
AIRS Point
003
Truck Condensate Loadout
Units
Basis
S
0.6
Submerged loading:
dedicated normal service
Pw
8.5
Psia
Based on extended natural
gas sample
M
109.18
Lb/lb-mole
Based on E&P TANKs run
T
530
Deg R
Based on source's
knowledge of bulk liquid
temperature
L
7.91
Lb/10^3 gal
This value is used to
calculate annual emissions
0.332
Lb/bbl
AP -42: Chapter 5.2
Equation 1
L = 12.46*S*P*M/T
L = loading losses in lb per 1000 gallons loaded
S = Saturation Factor
P = true vapor pressure of liquid loaded [psia]
M = molecular weight of vapors [lb/lb-mole]
T = temperature of bulk liquid loaded [deg. RI
L 7.911b/10^3 gal
3.32E-01lb/bbl
Annual requested Throughput 3854802ga1/yr
Annual requested VOC emissions 305041b/yr
15.25tpy
12/19/12: I emailed the operator how the wt% of VOC was
calculated for the HAPS. I tried several times,
and did not get what they calculated. Paul Buck called on 12/19/12 saying that those numbers are
assumed numbers that Encana has seen over several applications. However, he noticed that the
molecular weight should not be 109 Ib/Ib-mol (that is for the oil) and it should be 66 lb/lb-mol (for the
vapors). He provided me supporting documentation via email on 12/19/12. I reviewed it and made the
changes to the APEN, PA and permit.
Emission factors are calculated as multiplying the VOC emission factor (generated from AP -42) with the
wt % of VOC (which is an assumed engineering calculation done by Encana):
VOC E.F. = 7.91 lb/1000 gal
Benzene = (7.91 lb/1000 gal) * .0094 = 0.0744 lb/1000 gal
Toluene = (7.91 lb/1000 gal) * .0166 = 0.1313 lb/1000 gal
Ethylbenzene = (7.91 lb/1000 gal) * .0007 = 0.0055 lb/1000 gal
Xylenes = (7.91 lb/1000 gal) * .0073 = 0.0577 lb/1000 gal
n -hexane = (7.91 lb/1000 gal) * .0094 = 0.1843 lb/1000 gal
Page 7
123-99E9-001-APEN-2012-08-03-01
Pollutant'°
VOC [tons/year]
NOx [tons/year]
CO [tons/year]
Benzene [lbs/year]
n -Hexane [lbs/year]
Air Pollutant Emission Notice (APEN) — and — Application for Construction Permit
OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY
Current Status (Check all that apply) [ 23RgEq I0D
AIRS ID #1:
® New or previously unreported battery
,
❑ Previously grandfathered battery'
❑ Synthetic minor facility
® Located in the 8 -hr Ozone Control Area3 I'
❑ Registered under general permit no. GPOI 12WEZy6 2 J
❑ Permitted under individual permit:
Reason for APEN Submittal (Check all that apply) _
❑ APEN update only° 4< / 1
/ ❑ Modification to existing source' \
❑ Registration for coverage under general permit no. GP01\ ; ,
& cancellation request for individual permits: N
® Application for or Modification of an individual permit
❑ Administrative permit amendment?
❑ Other:
For individual permit applications, check if you wants:
❑ A copy of the preliminary analysis conducted by the Division
❑ To review a draft of the permit prior to issuance
Company Name9:
Mailing Address 1e
City:
Contact Name: Adam Berig
Encana Oil & Gas (USA) Inc.
Republic Plaza 370 17th St. Suite 1700
Denver
Tank Battery Name 11: GRATTAN 1 20
Location" (QQ Sec. Twp. Range.): SESE Sec 30 T2N R64W
Calendar year for which "Actual" data applies13: Projected
Control Description": Combustor
Condensate Throughput1° [bbl/year] Requestedis:
Other equipment at facility":
Comments:
a1 X81
OGCC Operator #: 100185
State: CO Zip: 80202 E-mail: adamberig@encana Dom
Phone: 720-876-3884 Fax: 720-876-4884
Number of tanks: 1" I 1
County: Weld Total tank capacity [bbl]: t51,;,.; -
Year(s) tank(s) were placed in service14: 2000' 20 t 2 -
Control Efficiencyl6: 6: 95
Maximum for PTE calculation19: 91781
While Controls Operational"
C5t—
Actual20: 7r(•i `j`S`l,
Estimated emissions at throughputs listed above. Use N/A for requested throughput/emission values unless requesting an individual permit
❑ Check if site -specific emission factors provided to calculate emissions'.
❑ Check if the Division is to calculate emissions.
Emission Factor
[Ib/bbl]
23.027
Battery
PTE"s
52.84
Requested Emissions
Uncontrolled's Controlled" Uncontrolled Controlled
1056.72
Actual Emissions
52.84 880.60
44.03
0.068 lb/MMbtu 2.03
1.69
0.37 lb/MMbtu 11.03
9.19
0.057
0.096
5231.52
261.58
4359.60
217.98
0.3540.3-] 11i - 0.84
31664.46
1583.22
26387.05
1319.35
API#:
API#:
API 4:
API #:
API 4:
API#:
API 0:
The signature below indicates that I have knowledge of the facts herein set forth and that the same are true, accurate, and complete to the best of
my knowledge and belief. If this is a registration for coverage under general permit GPOI, I further certify that this source is and will be operated
in full compliance with each condition of general permit GPOI.
0512312696
0512334369
0512334362
Name:
Name:
Name:
Name:
Name
Name:
Name:
Wells serviced by this tank or tank battery's
0512312696 GRATTON I
0512334369 GRATTAN 4A -30H
0512334362 GRATTAN 4B -30H
❑ Newly Reported Well
Z Newly Reported Well
® Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Resorted Well
Signature of Legally Authorized Person (not a vendor or consultant)
Adam Berl:
Type or Print Name of Person Signing Above
8/2/2012
Date
Air Quality Lead
Official Title
Submit this form, along with $152.90 for each
filing of up to 5 tank battery APENS. Include
$250 General Permit fee for each new GP
registration to:
FORM APCD-205
Colorado Department of Public Health and Environment
Air Pollution Control Division, APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
277080
For information call:
(303) 692-3150
Page 1 of 2 02_APEN - EP Condensate Storage Tank eatery 2012-01-02 11-21-Ot.doc
N
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nested Action (Check applicable request boxes)
Section 02 — Re
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L
E
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0
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or newly reported emission source
Ch
a
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Permit Number:
Section 06 Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM)
Section 05 — Stack Information (Combustion stacks must be listed here)
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Estimation
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Emission
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Please use the APCD Non -Criteria Rportable Air iRollutant Addenduhi form to report pollutants not listed above.
Requested Permitted
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Control Device Description
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Signature of Person Legally Authorized to Supply Data
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CC
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
12WE2463
Issuance 1
DATE ISSUED:
ISSUED TO: Encana Oil & Gas (USA), Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as Grattan 1 20, located in the SESE of Section 30, Township 2
North, Range 64 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
AIRS
Point
Description
001
One (1) 100 BBL and ten (10) 330 BBL above ground atmospheric
condensate storage tanks. Emissions from these tanks are controlled by a
combustor.
003
Truck condensate loadout. Emissions from the loadout are not controlled.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of
the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No.
3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after issuance of this permit, compliance with the
conditions contained in this permit shall be demonstrated to the Division. It is the owner or
operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate
compliance within 180 days may result in revocation of the permit. (Reference: Regulation
No. 3, Part B, II.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
AIRS ID: 123/99E9 Page 1 of 10
Condensate Tank SM/M Version 2012-1
lic'Health and Environment
r Air Pollution Control Division
application assp jte•' ithh to pa+_a Qi) di- e , :q ; s constZ.:,lction fora period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
AIRS
Point
Tons per Year
Emission Type
NO.
VOC
CO
001
2.0
52.9
11.0
Point
003
---
15.3
---
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
7. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS
Point
Control Device
Pollutants
Controlled
001
Combustor
VOC and HAPS
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or operator
AIRS ID: 123199E9
Page 2 of 10
and made aval -.te`"he Is
Part B, II A.4)
Process/Consumption Limits
AIRS
Point
Process Parameter
Annual Limit
001
Condensate throughput
91,781 BBL/yr
003
Condensate Loading
91,781 BBL/yr
The owner or operator shall calculate monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
Health and Environment
it Pollution Control Division
n req - (Reference: Regulation 3,
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the
subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.)
(State only enforceable)
10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections
XII.C.1.d or XVI1.B.1.c shall have no visible emissions. (Reference: Regulation No. 1,
Section II.A.1. & 4.)
11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
12. Point 001: The flare covered by this permit is subject to Regulation No. 7, Section XII.C
General Provisions (State only enforceable). If a combustion device is used to control
emissions of volatile organic compounds to comply with Section XII.D, it shall be enclosed,
have no visible emissions, and be designed so that an observer can, by means of visual
observation from the outside of the enclosed combustion device, or by other means
approved by the Division, determine whether it is operating properly. The operator shall
comply with all applicable requirements of Section XII.
13. Point 001: This source is subject to the recordkeeping, monitoring, reporting and emission
control requirements of Regulation 7, Section XII. The operator shall comply with all
applicable requirements of Section XII.
14. Point 001: The flare covered by this permit is subject to Regulation No. 7, Section XVII.B
General Provisions (State only enforceable). If a flare or other combustion device is used to
control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed, have no visible emissions during normal operations, and be designed so that an
observer can, by means of visual observation from the outside of the enclosed flare or
combustion device, or by other convenient means approved by the Division, determine
whether it is operating properly. The operator shall comply with all applicable requirements
of Section XVII.
AIRS ID: 123/99E9 Page 3 of 10
Iic'Health and Environment
it Pollution Control Division
15. Point 001: T e"(isa fora ks e _er.t'4 oy this la it are subject to Regulation
7, Section XVII emission control requirements. These requirements include, but are not
limited to:
Section XVII.C. - Emission reduction from condensate storage tanks at oil and gas
exploration and production operations, natural gas compressor stations,
natural gas drip stations and natural gas processing plants.
XVII.C.1. Beginning May 1, 2008, owners or operators of all atmospheric condensate
storage tanks with uncontrolled actual emissions of volatile organic compounds
equal to or greater than 20 tons per year based on a rolling twelve-month total
shall operate air pollution control equipment that has an average control
efficiency of at least 95% for VOCs on such tanks.
XVII.C.3. Monitoring: The owner or operator of any condensate storage tank that is
required to control volatile organic compound emissions pursuant to this section
XVII.C. shall visually inspect or monitor the Air Pollution Control Equipment to
ensure that it is operating at least as often as condensate is loaded out from the
tank, unless a more frequent inspection or monitoring schedule is followed. In
addition, if a flare or other combustion device is used, the owner or operator shall
visually inspect the device for visible emissions at least as often as condensate
is loaded out from the tank.
XVII.C.4. Recordkeeping: The owner or operator of each condensate storage tank shall
maintain the following records for a period of five years:
XVII.C.4.a. Monthly condensate production from the tank.
XVII.C.4.b For any condensate storage tank required to be controlled pursuant
to this section XVII.C., the date, time and duration of any period where
the air pollution control equipment is not operating. The duration of a
period of non -operation shall be from the time that the air pollution control
equipment was last observed to be operating until the time the equipment
recommences operation.
XVII.C.4.c. For tanks where a flare or other combustion device is being used, the
date and time of any instances where visible emissions are observed from
the device.
16. Point 003: This source is located in an ozone non -attainment or attainment -maintenance
area and is subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be
conducted by submerged fill. (Reference: Regulation 3, Part B, III.E)
OPERATING & MAINTENANCE REQUIREMENTS
17. Point 001: Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (O&M) plan and record keeping format approved by the Division,
in order to demonstrate compliance on an ongoing basis with the requirements of this
permit. Revisions to your O&M plan are subject to Division approval prior to implementation.
(Reference: Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
AIRS ID: 123199E9 Page 4 of 10
li Health and Environment
kir Pollution Control Division
18. Point 001: Th. m=' or at -at-a de roc como ?r ewith Condition 10, using
EPA Method 22 to measure opacity from the flare. The observation period shall be a
minimum of fifteen consecutive minutes.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually by April 30`h whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO„ per year, a
change in annual actual emissions of one (1) ton per year or more or five percent,
whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level reported
on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
20. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
21. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
22. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
AIRS ID: 123199E9 Page 5 of 10
Health and Environment
it Pollution Control Division
25-7-114.5(12 '".S.,;=as •'a:.,:.Re• gt!.?,,,.No. 3 B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
23. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the owner or operator and is conditioned upon conduct of the activity, or
construction, installation and operation of the source, in accordance with this information and
with representations made by the owner or operator or owner or operator's agents. It is valid
only for the equipment and operations or activity specifically identified on the permit.
24. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
25. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator or owner or operator of a source may request a hearing before the AQCC
for review of the Division's action.
26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Stephanie Chaousy, P.E.
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Encana Oil & Gas (USA), Inc.
AIRS ID: 123199E9
Page 6 of 10
Health and Environment
it Pollution Control Division
Nett(=: '`'tted w= "` =d site. Condensate tanks
and loadout at synthetic minor facility.
AIRS ID: 123199E9 Page 7 of 10
olor % Depa , en .f .li Health and Environment
a � Air Pollution Control Division
Notes to Permit Holder a '` "me o"` '.ef17 an
1) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the owner or operator providing there is no exceedance of any specific emission control regulation or any
ambient air quality standard. A revised air pollution emission notice (APEN) and complete application
form must be submitted with a request for a permit revision.
2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
http://www.cdph e. state. co. us/req ulations/ai rregs/ 100102aq cccom mon provisionsreq. pdf.
3) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
BIN '
Uncontrolled
Emission
Rate
(lb/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
001
Benzene
71432
A
5232
Yes
262
Toluene
108883
C
3671
Yes
184
Ethylbenzene
100414
C
367
No
18
Xylenes
1330207
C
1193
Yes
60
n -Hexane
110543
C
31664
Yes
1583
002
Benzene
71432
A
287
Yes
287
Toluene
108883
C
506
No
506
Ethylbenzene
100414
C
21
No
21
Xylenes
1330207
C
223
No
223
n -Hexane
110543
C
711
Yes
711
4) The emission levels contained in this permit are based on the following emission factors:
Point 001:
CAS #
Pollutant
Emission Factors
Uncontrolled
Ib/BBL
Condensate
Throughput
Emission Factors
Controlled
lb/BBL
Condensate
Throughput
Source
NOx
0.068 Ib/MMBtu
---
AP -42, Table 13.5-1
CO
0.37 lb/MMBtu
---
AP -42, Table 13.5-1
VOC
23.027
1.151
E&P Tanks
110543
n -Hexane
0.345
0.017
E&P Tanks
71432
Benzene
0.057
0.003
E&P Tanks
108883
Toluene
0.040
0.002
E&P Tanks
AIRS ID: 123199E9
Page 8 of 10
Health and Environment
Air Pollution Control Division
CAS #
Pollutant
ni actq s
Uncontrolled
lb/BBL
Condensate
Throughput
issio gtors
Controlled
lb/BBL
Condensate
Throughput
Source
100414
Ethylbenzene
0.004
0.0002
E&P Tanks
1330207
Xylene
0.013
0.001
E&P Tanks
Note: The controlled emissions factors for point 001 are based on the combustor control efficiency
of 95%.
Point 003:
CAS
Pollutant
Emission Factors
lb/1000 gal loaded
- Uncontrolled
Source
VOC
7.91
AP -42
71432
Benzene
0.0744
AP -42
108883
Toluene
0.1313
AP -42
100414
Ethylbenzene
0.0055
AP -42
1330207
Xylene
0.0577
AP -42
110543
n -Hexane
0.1843
AP -42
The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version
1/95) using the following values:
L = 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 8.5 psia
M (vapor molecular weight) = 66 lb/lb-mol
T (temperature of liquid loaded) = 530 °R
The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor.
5) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall
be submitted no later than 30 days before the five-year term expires. Please refer to the most recent
annual fee invoice to determine the APEN expiration date for each emissions point associated with this
permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150.
6) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
VOC, n -hexane
NANSR
Synthetic Minor Source of:
VOC
MACT HH
Area Source Requirements: Not Applicable
7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
AIRS ID: 123/99E9
Page 9 of 10
Health and Environment
it Pollution Control Division
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart WW
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
8) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit packet.
Please use this form to complete the self -certification requirements as specified in the permit conditions.
Further guidance on self -certification can be found on our website at:
http://www.cdphe.state.co.us/ap/oiloaspermittinghtml
AIRS ID: 123199E9 Page 10 of 10
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