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Home My WebLink About20132249.tiffSTATE OF COLORADO John W. Hickenlooper, Governor Karin McGowan Interim Executive Director 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 Weld County Clerk & Recorder 1402 N 17th Ave Greeley, CO 80631 July 29, 2013 Dear Sir or Madam: Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Colorado Department of Public Health and Environment On August 1, 2013, the Air Pollution Control Division will publish a public notice for Rose Rock Midstream — Briggsdale OPF, in the The Greeley Tribune. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B I 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure Marc letuictu i/i21►3 H-11,1 2013-2249 STATE 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 Laboratory Services Division 6100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Website Title: Rose Rock Midstream — Briggsdale OPF — Weld County Released To: The Greeley Tribune On: July 29, 2013 Published: August 1, 2013 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT Colorado Department of Public Health and Environment Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Rose Rock Midstream Facility: Briggsdale OPF Crude oil polishing facility Section 25 of Township 8 north, Range 63 west Weld County The proposed project or activity is as follows: Crude oil polishing facility The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.I.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 12WE3121 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at www.colorado.gov/cdphe/AirPublicNotices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Michael Cleary Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: DATE ISSUED: ISSUED TO: 12WE3121 Rose Rock Midstream, L.P. Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Crude oil and condensate storage and transport facility, known as the Briggsdale Station, located at Section 25, Township 8N, Range 65W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description T-50-230 to T-150-231 004 Two (2) 100,000 BBL internal floating roof tanks used to store crude oil and condensate. T-5-230-1 to 1-5-230-4 005 Four (4) 5,000 BBL internal floating roof tanks used to store crude oil and condensate. These tanks are operated as constant level tanks. Fugitives 006 Equipment leaks (fugitive VOCs) from a condensate storage and transport facility. 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 commencement of operation, 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 on this permit shall be demonstrated to the Division. It is the permittee's responsibility to self -certify compliance with the conditions. Failure to AIRS ID: 123/6946 Page 1 of 16 Condensate Tank Version 2006-1 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division 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 application associated with this permit; (ii) discontinues construction for a 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. Points 004 & 005: Within ninety (90) days after issuance of this permit, the operator shall install and maintain operation of an automated supervisory control and data acquisition system to continuously monitor and record the tank levels. 5. 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 lll.E.) 6. The following information shall be provided to the Division within fifteen (15) days after commencement of operation. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 7. 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 8. 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) Quarterly Limits: Facility Equipment ID AIRS Point Pounds per Quarter Emission Type NO„ VOC CO T-50-230 to T-150-231 004 --- 5,600 --- Point T-5-230-1 to T-5-230-4 005 --- 2,990 --- Point Fugitives 006 --- 1,745 --- Fugitive (Note: Quarterly limits are based on a 93 -day period.) AIRS ID: 123/9946 Page 2 of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division The owner or operator shall calculate monthly emissions based on the calendar month. Facility -wide emissions of each individual hazardous air pollutant shall be less than 4,077 lb/quarter. Facility -wide emissions of total hazardous air pollutants shall be less than 10,194 lb/quarter. Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO, VOC CO T-50-230 to T-150.231 004 --- 11.2 --- Point T-5-230-1 to T-5-230-4 005 --- 6.0 --- Point Fugitives 006 --- 3.5 --- Fugitive See "Notes to Permit Holder #4" 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 tons per year. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tons per year. During the first twelve (12) months of operation, compliance with both the quarterly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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. Points 004: The operator shall continuously monitor the depth of liquid in the tanks using a Supervisory Control and Data Acquisition (SCADA) system. This control system shall maintain each tank level at an average monthly liquid depth between six (6) and thirteen (13) feet for each storage vessel identified as T-50-230 and T-150-231, The liquid level in each tank shall be monitored and recorded a minimum of once daily. The daily liquid levels recorded for each tank shall be averaged to determine a monthly average liquid level to demonstrate compliance with the requirement of this condition. Tank levels recorded during any of the permitted, roof landing events outlined in Condition #6 may be excluded from this calculation. AIRS ID: 123/9946 Page 3 of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division PROCESS LIMITATIONS AND RECORDS 10. 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 applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Quarterly Limit Annual Limit T-50-230 to T-150-231 004 Crude oil and condensate throughput 5,040,000 20,160,000 BBL Roof landing events 1 event 4 events T-50-230 to T-150-231 005 Crude oil and condensate throughput 5,040,000 20,160,000 BBL Roof landing events 2 event 8 events During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 12. 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. (Reference: Regulation No. 1, Section II.A.1. & 4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. Points 004 and 005: This source is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels for which construction, reconstruction or modification commenced after July 23, 1984, including, but not limited to, the following: § 60.112b Standard for volatile organic compounds (VOC). (a) The owner or operator of each storage vessel either with a design capacity greater than or equal to 151 m3 containing a VOL that, as stored, has a maximum true vapor pressure equal to or greater than 5.2 kPa but less than 76.6 kPa [...] shall equip each storage vessel with: AIRS ID: 123/9946 Page 4 of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division (1) A fixed roof in combination with an internal floating roof meeting the following specifications: (i) The internal floating roof shall rest or float on the liquid surface (but not necessarily in complete contact with it) inside a storage vessel that has a fixed roof. The internal floating roof shall be floating on the liquid surface at all times, except during initial fill and during those intervals when the storage vessel is completely emptied or subsequently emptied and refilled. When the roof is resting on the leg supports, the process of filling, emptying, or refilling shall be continuous and shall be accomplished as rapidly as possible. (ii) Each internal floating roof shall be equipped with a mechanical shoe seal between the wall of the storage vessel and the edge of the internal floating roof. (A mechanical shoe seal is a metal sheet held vertically against the wall of the storage vessel by springs or weighted levers and is connected by braces to the floating roof. A flexible coated fabric (envelope) spans the annular space between the metal sheet and the floating roof.) (iii) Each opening in a noncontact internal floating roof except for automatic bleeder vents (vacuum breaker vents) and the rim space vents is to provide a projection below the liquid surface. (iv) Each opening in the internal floating roof except for leg sleeves, automatic bleeder vents, rim space vents, column wells, ladder wells, sample wells, and stub drains is to be equipped with a cover or lid which is to be maintained in a closed position at all times (i.e., no visible gap) except when the device is in actual use. The cover or lid shall be equipped with a gasket. Covers on each access hatch and automatic gauge float well shall be bolted except when they are in use. (v) Automatic bleeder vents shall be equipped with a gasket and are to be closed at all times when the roof is floating except when the roof is being floated off or is being landed on the roof leg supports. (vi) Rim space vents shall be equipped with a gasket and are to be set to open only when the internal floating roof is not floating or at the manufacturer's recommended setting. (vii) Each penetration of the internal floating roof for the purpose of sampling shall be a sample well. The sample well shall have a slit fabric cover that covers at least 90 percent of the opening. (viii) Each penetration of the internal floating roof that allows for passage of a column supporting the fixed roof shall have a flexible fabric sleeve seal or a gasketed sliding cover. (ix) Each penetration of the internal floating roof that allows for passage of a ladder shall have a gasketed sliding cover. AIRS ID: 123/9946 Page 5 of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division § 60.113b Testing and procedures. The owner or operator of each storage vessel as specified in §60.112b(a) shall meet the requirements of paragraph (a), (b), or (c) of this section. The applicable paragraph for a particular storage vessel depends on the control equipment installed to meet the requirements of §60.112b. (a) After installing the control equipment required to meet §60.112b(a)(1) (permanently affixed roof and internal floating roof), each owner or operator shall: (1) Visually inspect the internal floating roof, the primary seal, and the secondary seal (if one is in service), prior to filling the storage vessel with VOL. If there are holes, tears, or other openings in the primary seal, the secondary seal, or the seal fabric or defects in the internal floating roof, or both, the owner or operator shall repair the items before filling the storage vessel. (2) For Vessels equipped with a liquid -mounted or mechanical shoe primary seal, visually inspect the internal floating roof and the primary seal or the secondary seal (if one is in service) through manholes and roof hatches on the fixed roof at least once every 12 months after initial fill. If the internal floating roof is not resting on the surface of the VOL inside the storage vessel, or there is liquid accumulated on the roof, or the seal is detached, or there are holes or tears in the seal fabric, the owner or operator shall repair the items or empty and remove the storage vessel from service within 45 days. If a failure that is detected during inspections required in this paragraph cannot be repaired within 45 days and if the vessel cannot be emptied within 45 days, a 30 -day extension may be requested from the Administrator in the inspection report required in §60.115b(a)(3). Such a request for an extension must document that alternate storage capacity is unavailable and specify a schedule of actions the company will take that will assure that the control equipment will be repaired or the vessel will be emptied as soon as possible. (4) Visually inspect the internal floating roof, the primary seal, the secondary seal (if one is in service), gaskets, slotted membranes and sleeve seals (if any) each time the storage vessel is emptied and degassed. If the internal floating roof has defects, the primary seal has holes, tears, or other openings in the seal or the seal fabric, or the secondary seal has holes, tears, or other openings in the seal or the seal fabric, or the gaskets no longer close off the liquid surfaces from the atmosphere, or the slotted membrane has more than 10 percent open area, the owner or operator shall repair the items as necessary so that none of the conditions specified in this paragraph exist before refilling the storage vessel with VOL. In no event shall inspections conducted in accordance with this provision occur at intervals greater than 10 years in the case of vessels conducting the annual visual inspection as specified in paragraphs (a)(2) and (a)(3)(ii) of this section and at intervals no greater than 5 years in the case of vessels specified in paragraph (a)(3)(i) of this section. (5) Notify the Administrator in writing at least 30 days prior to the filling or refilling of each storage vessel for which an inspection is required by paragraphs (a)(1) and (a)(4) of this section to afford the Administrator the opportunity to have an AIRS ID: 123/9946 Page 6 of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division observer present. If the inspection required by paragraph (a)(4) of this section is not planned and the owner or operator could not have known about the inspection 30 days in advance or refilling the tank, the owner or operator shall notify the Administrator at least 7 days prior to the refilling of the storage vessel. Notification shall be made by telephone immediately followed by written documentation demonstrating why the inspection was unplanned. Alternatively, this notification including the written documentation may be made in writing and sent by express mail so that it is received by the Administrator at least 7 days prior to the refilling. § 60.115b Reporting and recordkeeping requirements. The owner or operator of each storage vessel as specified in §60.112b(a) shall keep records and furnish reports as required by paragraphs (a), (b), or (c) of this section depending upon the control equipment installed to meet the requirements of §60.112b. The owner or operator shall keep copies of all reports and records required by this section, except for the record required by (c)(1), for at least 2 years. The record required by (c)(1) will be kept for the life of the control equipment. (a) After installing control equipment in accordance with §60.112b(a)(1) (fixed roof and internal floating roof), the owner or operator shall meet the following requirements. (1) Furnish the Administrator with a report that describes the control equipment and certifies that the control equipment meets the specifications of §60.112b(a)(1) and §60.113b(a)(1). This report shall be an attachment to the notification required by §60.7(a)(3). (2) Keep a record of each inspection performed as required by §60.113b (a)(1), (a)(2), (a)(3), and (a)(4). Each record shall identify the storage vessel on which the inspection was performed and shall contain the date the vessel was inspected and the observed condition of each component of the control equipment (seals, internal floating roof, and fittings). (3) If any of the conditions described in §60.113b(a)(2) are detected during the annual visual inspection required by §60.113b(a)(2), a report shall be furnished to the Administrator within 30 days of the inspection. Each report shall identify the storage vessel, the nature of the defects, and the date the storage vessel was emptied or the nature of and date the repair was made. (4) After each inspection required by §60.113b(a)(3) that finds holes or tears in the seal or seal fabric, or defects in the internal floating roof, or other control equipment defects listed in §60.113b(a)(3)(ii), a report shall be furnished to the Administrator within 30 days of the inspection. The report shall identify the storage vessel and the reason it did not meet the specifications of §61.112b(a)(1) or §60.113b(a)(3) and list each repair made. § 60.116b Monitoring of operations. (a) The owner or operator shall keep copies of all records required by this section, except for the record required by paragraph (b) of this section, for at least 2 years. AIRS ID: 123/9946 Page 7 of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division The record required by paragraph (b) of this section will be kept for the life of the source. (c) Except as provided in paragraphs (f) and (g) of this section, the owner or operator of each storage vessel either with a design capacity greater than or equal to 151 m3 storing a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa or with a design capacity greater than or equal to 75 m3 but less than 151 m3 storing a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa shall maintain a record of the VOL stored, the period of storage, and the maximum true vapor pressure of that VOL during the respective storage period. (e) Available data on the storage temperature may be used to determine the maximum true vapor pressure as determined below. (1) For vessels operated above or below ambient temperatures, the maximum true vapor pressure is calculated based upon the highest expected calendar -month average of the storage temperature. For vessels operated at ambient temperatures, the maximum true vapor pressure is calculated based upon the maximum local monthly average ambient temperature as reported by the National Weather Service. (2) For crude oil or refined petroleum products the vapor pressure may be obtained by the following: (i) Available data on the Reid vapor pressure and the maximum expected storage temperature based on the highest expected calendar -month average temperature of the stored product may be used to determine the maximum true vapor pressure from nomographs contained in API Bulletin 2517 (incorporated by reference —see §60.17), unless the Administrator specifically requests that the liquid be sampled, the actual storage temperature determined, and the Reid vapor pressure determined from the sample(s). (ii) The true vapor pressure of each type of crude oil with a Reid vapor pressure less than 13.8 kPa or with physical properties that preclude determination by the recommended method is to be determined from available data and recorded if the estimated maximum true vapor pressure is greater than 3.5 kPa. In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply. a. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation No. 6, Part A. General Provisions from 40 CFR 60.11 b. No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based AIRS ID: 123/9946 Page 8 of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division on the concentration of a pollutant in the gases discharged to the atmosphere. (§ 60.12) c. Written notification of construction and initial startup dates shall be submitted to the Division as required under § 60.7. d. Records of startups, shutdowns, and malfunctions shall be maintained, as required under § 60.7. e. Excess Emission and Monitoring System Performance Reports shall be submitted as required under § 60.7. 15. Points 004 and 005: This source is subject to the requirements of Regulation No. 7, Section VI, Storage and Transfer of Petroleum Liquid including, but not limited to, the following: VI.B.2.a.(i) The owner or operator of a fixed -roof tank used for storage of petroleum liquids which have a true vapor pressure greater than 33.6 torr (0.65 psia) at 20°C (or, alternatively, a Reid vapor pressure greater than 1.30 pounds - (67.2 torr) but not greater than 570 torr (11.0 psia) at 20°C, and which are stored in any tank or other container of more than 151,412 liters (40,000 gallons) shall ensure that the tank at all times meets the following conditions: VI.B.2.a.(i)(A) The tank has been equipped with a pontoon -type, or double -deck type, floating roof or an internal floating cover which rests on the surface of the liquid contents and which is equipped with a closure seal or seals to close the space between the edge of the floating roof (or cover) and tank walls. VI.B.2.a.(i)(E) The owner or operator shall maintain records for at least two years of the type, average monthly storage temperature, and true vapor pressure of all petroleum liquids stored in tanks not equipped with an internal floating roof or cover or other control pursuant to Regulation 7.VI.B.2.a.(i)(A) or (B) or 7.II.D. VI.B.2.a.(ii) No owner or operator of a fixed -roof tank equipped with an internal floating roof or cover shall permit the use of such tank unless: VI.B.2.a.(ii)(A) The tank is maintained such that there are no visible holes, tears, or other openings in the seal or any seal fabric or materials; and VI.B.2.a.(ii)(B) All openings, except stub drains, are equipped with covers, lids, or seals such that: VI.B.2.a.(ii)(B)(1) The cover, lid, or seal is in the closed position at all times except when in actual use; Vl.B.2.a.(ii)(B)(2) Automatic bleeder vents are closed at all times except when the roof is floated off or landed on the roof leg supports; VI.B.2.a.(ii)(B)(3) and Rim vents, if provided, are set to open when the roof is being floated off the roof leg supports or at the manufacturer's recommended setting. VI.B.2.a.(iii) The operator of a fixed -roof tank equipped with an internal floating roof shall: VI.B.2.a.(iii)(A) Perform a routine inspection through the tank roof hatches at least once every six months; VI.B.2.a.(iii)(A)(1) During the routine inspection, the operator shall measure for detectable vapor loss inside the hatch. Detectable vapor loss AIRS ID: 123/9946 Page 9 of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division means a VOC concentration exceeding 10,000 ppm, using a portable hydrocarbon analyzer. VI.B.2.a.(iii)(B) Perform a complete inspection of the cover and seal whenever the tank is out of service, whenever the routine inspection required in subclause (A) above reveals detectable vapor loss, and at least once every ten years, and shall notify the Division in writing before such an inspection. VI.B.2.a.(iii)(C) Ensure during inspections that there are no visible holes, tears, or other openings in the seal or any seal fabric or materials; that the cover is floating uniformly on or above the liquid surface; that there are no visible defects in the surface of the cover or liquid accumulated on the cover; and that the seal is uniformly in place around the circumference of the cover between the cover and the tank wall. If these items are not met, the owner or operator shall repair the items or empty and remove the storage vessel from service within 45 days. If a failure that is detected during inspections required in this paragraph cannot be repaired within 45 days and if the vessel cannot be emptied within 45 days, a 30 - day extension may be requested from the Division in writing. Such a request must document that alternative storage capacity is unavailable and specify a schedule of actions the owner or operator will take that will assure that the items will be repaired or the vessel will be emptied as soon as possible; VI.B.2.a.(iii)(D) Maintain records for at least two years of the results of all inspections. VI.B.2.b. Above ground storage tanks used for the storage of petroleum liquid shall have all external surfaces coated with a material which has a reflectivity for solar radiation of 0.7 or more. Methods A or B of ASTM E424 shall be used to determine reflectivity. Alternatively, any untinted white paint may be used which is specified by the manufacturer for such use. This provision shall not apply to written symbols or logograms applied to the external surface of the container for purposes of identification provided such symbols do not cover more than .20%of the exposed top and side surface area of the container or more than 18.6 square meters (200 square feet), whichever is less. 16. Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). This requirement to apply RACT shall be satisfied by implementing the following emission controls: a. Directed Inspection & Maintenance as described below shall satisfy the requirement to apply RACT. i. For leak screening, auditory/visual/olfactory inspection (AVO) will be performed on a monthly basis. H. For each leak found in the AVO inspection, a gas detector shall be used to determine the size of the leak. The gas detector shall be regularly calibrated. Component leaks greater than 10,000 ppm shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. For such component leaks that require a shutdown to be AIRS ID: 123/9946 Page 10 of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered. iii. For repair, valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. iv. Repaired components shall be re -screened to determine if the leak is repaired. v. The following records shall be maintained for a period of two years: • The name of the site screened via AVO inspection and the name of the inspector. • Components evaluated with the gas detector. • Repair methods applied. • . Dates of the AVO screenings, gas detector calibrations, attempted repairs, successful repairs, repair delays, and post - repair screenings. vi. Leaks shall be repaired as soon as practicable, but no later than 15 calendar days after detection, unless it is technically or operationally infeasible to make the repair within 15 calendar days. Records documenting the rationale shall be maintained if it is technically or operationally infeasible to make the repair within 15 calendar days. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. Point 006: Within one hundred and eighty days (180) after issuance of this permit, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service". The operator shall submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. 18. Point 006: Within one hundred and eighty days (180) after commencement of operation, the owner or operator shall complete the initial liquids analysis of gas samples that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the gas analysis and emission calculations to the Division as part of the self -certification process to ensure compliance with emissions limits. Periodic Testing Requirements 19. Point 006: On an annual basis, the owner or operator shall complete an extended liquids analysis of samples that are representative, of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. AIRS ID: 123/9946 Page 11, of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, I I.C) a. Annually 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 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. 21. 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 22. 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. 23. 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 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part 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. 24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with AIRS ID: 123/9946 Page 12 of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division representations made by the applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 25. 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. 26. 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 applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. 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. 28. 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: Michael Cleary Permit Engineer Air Pollution Control Division Permit Histo Issuance Date Description Issuance 1 This Issuance • Issued to Rose Rock Midstream for two 100,000 BBL and four 5,000 BBL crude oil and condensate tanks and facility fugitive equipment leaks, AIRS ID: 123/9946 Page 13 of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder: 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 permittee 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 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 permittee 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.cdphe.state.co.us/regulations/airreqs/100102aacccommonprovisionsreq.Ddf. 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) 004 Benzene 71432 A 76 Yes NA n -Hexane 110543 C 714 No NA 005 Benzene 71432 A 48 No NA n -Hexane 110543 C 455 No NA 006 n -Hexane 110543 C 329 No NA 4) The emission levels contained in this permit are based on the following emission factors: Points 004: CAS # Pollutant Emission Factors Ib/BBL Crude Oil and Condensate Throughput Source VOC 7.619e-04 EPA Tank 4.0.9d 71432 Benzene 2.597e-06 CAS # Pollutant Lb/Roof Landing Event Source VOC 1759.0 AP -42, Section 7.1.3.2.2 110543 n -Hexane 56.074 Engineering Estimate 71432 Benzene 5.994 Points 005: CAS # Pollutant Emission Factors lb/BBL Crude Oil and Condensate Throughput Source VOC 5.159 x 10-4 EPA Tank 4.0.9d CAS # Pollutant Lb/Roof Landing Event Source VOC 195.43 AP -42, Section 7.1.3.2.2 110543 n -Hexane 7.44 Engineering Estimate 71432 Benzene 0.78 AIRS ID: 123/9946 Page 14 of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division Note: EPA Tank was run for this emission point assuming that these tanks are operated as constant level tanks as discussed in AP -42, Section 7.1.3.5. Points 006: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors -- -- 20 -- Flanges -- -- 158 -- Open-ended Lines -- -- 5 -- Pump Seals -- -- 3 -- Valves -- -- 63 -- Other* -- -- 5 -- VOC Content (wt%) -- -- 100% -- *Other equipment type 'ncludes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 • 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA -453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent liquids analysis. 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: VOC, n -Hexane, total HAPS NA NSR Synthetic Minor Source: VOC MACT HH Major Source Requirements: Not Applicable 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: 123/9946 Page 15 of 16 Rose Rock Midstream, L.P. Colorado Department of Public Health and Environment Air Pollution Control Division http://ecfr.gpoaccess.gov/ 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 YYYY 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/oilgaspermitting.html AIRS ID: 123/9946 Page 16 of 16 Construction Permit Application Preliminary Analysis Summary Section 1 — Applicant Information Company Name: Rose Rock Midstream, L.P. Permit Number: 12WE3121 Source Name: Briggsdale Station Source Location: Section 25, Township 8N, Range 65W Equipment Description: Two (2) 50,000 BBL condensate storage tanks Four (4) 5,000 BBL condensate storage tanks Fugitive VOC from equipment leaks AIRS ID: 123/9964/004, 005, 006 Date: 3/17/2012 Review Engineer: Michael Cleary Control Engineer: Chris Laplante Permit Draft Location: K:\PERMiTS12012\12WE31211.CPI Section 2 — Action Completed X Initial Approval Modification APEN Required/Permit Exempt Final Approval 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? On what date was this application complete? July 2, 2012 Section 4 — Source Description AIRS Point Equipment Description 004 Two (2) 50,000 BBL internal floating roof condensate storage tanks 005 Four (4) 5,000 BBL internal floating roof condensate storage tanks These tanks are operated at a constant level. 006 Fugitive VOC from equipment leaks Is this a portable source? Yes X No Is this location in a non -attainment area for any criteria pollutant? X Yes i No If "yes", for what pollutant? PKo CO X Ozone Is this location in an attainment maintenance area for any criteria pollutant? Yes I X No Page 1 If "yes", for what pollutant? (Note: These pollutants are subject to minor source RACT per Regulation 3, Part B, Section III.D.2) PM,o CO Ozone 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 No Section 5 — Emission Estimate Information AIRS Point Emission Factor Source 004 EPA Tanks 4.0.9d and AP -42, Chapter 7, Equation 2-24 & 2-26 005 EPA Tanks 4.0.9d and AP -42, Chapter 7, Equation 2-24 & 2-26 • Rose Rock used a variation of the standard emission estimation procedure discussed in AP -42, Section 7.1.3.5 to reduce the throughput used in EPA Tanks. The throughput was reduced by multiplying the PTE throughput by the average change in liquid height and dividing by the total shell height (the PTE throughput was multiplied by 0.375). Further discussion can be found in Section 14. 006 EPA -453/R-95-017, Table 2-4 Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit (PTE) AIRS Point Process Consumption/Throughput/Production 004 20,200,000 BBL condensate throughput, 4 roof landings 005 20,200,000 BBL condensate throughput, 8 roof landings 006 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors 90 Flanges 180 Open -Ended Lines 15 Pump Seals 6 Valves 72 Other 2 _ Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 004 20,160,000 BBL condensate throughput, 4 roof landings 005 20,160,000 BBL condensate throughput, 8 roof landings 006 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors 90 Flanges 180 Open -Ended Lines 15 Pump Seals 6 Valves 72 Other 2 Does this source use a control device? Yes X No AIRS Point Process Control Device Description % Reduction Granted 001 01 Section 6 — Emission Summary (tons per year) Point 11 NO, VOC CO Single HAP Total HAP Page 2 PTE: 004 11.20 0.04 (Benzene) 0.04 005 5.98 --- --- 006 3.49 --- --- Total 20.67 0.04 (Benzene) 0.04 Uncontrolled point source emission rate: 004 11.20 0.04 (Benzene) 0.04 005 5.98 --- -- 006 3.5 --- --- Total 20.67 0.04 (Benzene) 0.04 Note: Points 001-003 are owned by Noble. See Division history file (k:/history/1239946.xls) for facility emission totals. Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (lblyr) Are the I Controlled Emission emissions reportable? I Rate (Ib/yr) Point 004 Benzene 71432 A 76 Yes NA n -Hexane 110543 C 714 No NA 2w Point 005 Benzene 71432 A 48 No NA n -Hexane 110543 C 455 No NA Point 006 n -Hexane I 110543 T C 329 No NA Note: Regulation 3, Part A, Section 1I.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? Yes X i No If "yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method Section 9 — Source Classification Is this a new previously un-permitted source? Yes X No What is this facility classification? True Minor X Synthetic Minor Major Classification relates to what programs? I X Title V PSD X NA NSR 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 Page 3 If "yes", for which pollutants? Why? For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? Yes No For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes 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 Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide All Points 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. Regulation 2 — Odor All Points 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 Operating Permits PSD 004, 005, 006 Part A-APEN Requirements Applicant is required to file an APEN since emissions exceed one ton per year VOC. 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 II.D.3.a). 004, 005 Part B — Minor Source RACT These tanks meet the requirements of NSPS Kb as internal floating roof tanks. Since the NSPS-level emissions control requirements are more stringent than RACT-level controls, no additional emissions controls will be required pursuant to Section III.D.2 of Regulation 3, Part B. 006 Part B — Minor Source RACT This source will begin operation after November 20, 2004 and is subject to the minor source RACT requirements of Part B, Section III.D.2. Reasonably available control technology for fugitive equipment leaks shall consist of a LDAR program with semi-annual AVO inspections. Re. ulation 6 - New Source Performance Standards 004, 005 NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. These tanks are subject to NSPS Kb because they have capacities greater than 75 m3 (491 BBL) (§ 60.110b(a)). These tanks also have capacities greater than 151 m3 and store VOL with a vapor pressure greater than 3.5kPa (0.51 psi) (§ 60.110b(b)). 004 NSPS OOOO: These tanks will be installed after the applicability date of 8/23/2011. However, these tanks are subject to 40 CFR Part 60 - Subpart Kb and, thus, exempt from the control requirements in Subpart OOOO. 005 NSPS OOOO: These tanks will be installed after the applicability date of 8/23/2011. However, these tanks are subject to 40 CFR Part 60 - Subpart Kb and, thus, exempt from the control requirements in Subpart OOOO. Page 4 Regulation 7 — Volatile Organic Compounds 004, 005 Sections XII and XVII These tanks are not subject to Section XII because they are not located at a natural gas exploration and production facility, compressor station, or natural gas drip station. These tanks are not subject to Section XVII because they are subject to a federal NSPS under Subpart 60. 006 Section XII Fugitives emitted from this facility are not subject to Section XII because the facility is not a natural gas processing plant. Regulation 8 — Hazardous Air`Pollutants § 1. p All Points MACT EEEE This source is not subject to MACT EEEE because it is not located at a major source of HAP. All Points 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 (Y/N) Emission Factor Source Control (%) Two 50,000 BBL IFR 2.646 x10-2 lb/1000 gal throughput VOC No EPA Tank 4.0.9d And AP -42 NA 004 01 Condensate Tanks 9,016 x10_5 lb/1000 gal throughput Benzene No Engineering Calculation NA SCC 40400331 — Internal Floating losses Roof Tank, Condensate, working+breathing+flashing 005 01 Four 5000 BBL Condensate Tanks 1.413 x10-2 lb/1000 gal throughput V0C No EPA Tank 4.0.9d And AP -42 NA SCC 40400331 — Internal Floating Roof Tank, Condensate, working+breathing+flashing losses 006 01 Fugitive emissions from equipment leaks VOC No EPA -453/R-95-017, Table 2-4 NA SCC 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Page 5 Section 14 — Miscellaneous Application Notes AIRS Point General Single Source Determination The Division evaluated whether or not an oil polishing train operated by Noble, and tanks operated by Rose Rock as part of the Briggsdale Station should be considered part of a single stationary source. Summary Description of Source Operations Tank trucks carry and deliver stable oil for Noble Energy to the truck unloading facility owned and operated by Rose Rock located at the Briggsdale Station. The stable oil is analyzed in the truck unloading facility to determine if it meets specifications for basic sediment and water (BS&W) content. If the oil meets BS&W specifications required by Rose Rock, the oil is transferred via pipe to oil storage tanks owned and operated by Rose Rock and eventually into the White Cliffs Pipeline to be delivered to Cushing, Oklahoma. If oil does not meet the required BS&W specifications it is transferred via pipe to one of the oil polishing trains owned and operated by Noble to bring it into specification before being transferred to the oil storage tanks owned and operated by Rose Rock. Meeting the BS&W specification is required by Rose Rock to minimize impurities such as sediment which may partially block the flow in the pipeline or contribute to the erosion of the pipeline's interior surface. In addition, excess water in the oil contributes to corrosion of the pipeline. Therefore, Noble Energy's oil polishing operations have been deemed integral to each company being able to deliver their oil to the Rose Rock pipeline injection operations. Using the 3 -Part Test, the following emissions sources evaluated in this stationary source determination include the Noble Energy oil polishing operations and the Rose Rock oil unloading, storage and pipeline injection operations. 1. Are the operations located on contiguous or adjacent properties? The Noble Energy operation and the Rose Rock operations are located on contiguous properties and are connected by a road and piping. 2. Are these facilities all classified under the same major two -digit Standard Industrial Classification (SIC)? Absent the same two- digit major SIC Code, activities may belong to the same industrial grouping if one activity is characterized as a support activity for the primary activity. The Division determined the Noble Energy oil polishing activities do have a support facility relationship with Rose Rock's primary operations. Thus, these operations are considered to be under the same major SIC code 4612 for the purpose of this source determination analysis. 3. Are these facilities under common ownership or common control? Rose Rock and Noble Energy are all separate corporate entities (i.e. no common ownership). Absent common ownership, common control may still exist. The Division may determine common control by looking at relevant factors such as if a support/dependency relationship exists. The Division determined a support/dependency relationship exists between each oil polishing and the oil storage and pipeline transfer operation since the pollutant emitting activities have significant operational ties to one another. Noble Energy maintains a contractual relationship with Rose Rock. Including an elements that stipulates Noble must meet minimum monthly volumes of deliverable oil to Rose Rock. Noble Energy also uses the oil loading rack owned by Rose Rock to offload their product from tanker trucks in order to move their product on site and, as needed, to their respective oil polishing facilities. Each of these facts was influential in the Division's decision. The Division has concluded that these facilities satisfy the requirements and should be considered part of a single stationary source. Page 6 Section 14 — Miscellaneous Application Notes AIRS Point 004 50,000 BBL Condensate Storage Tanks An APEN was submitted two 50,000 bbl tanks at this location. Tank emissions were estimated using a combination of EPA Tanks 4.0 and AP -42, Chapter 7, Equation 2-26 Rose Rock applied an estimation adjustment procedure, outilined in AP -42, Section 7.1.3.5, to reduce the throughput used in EPA Tanks. These tanks are to be controlled such that the floating roofing will be maintained within a limited range of liquid depth. This range (or variability), deemed to be 7 feet by the operator, as a fraction of the useable sidewall height is the ratio by which the estimated throughput is reduced for application in EPA tanks. The 5000 barrel tanks are 25 feet tall, but only have about 18.5 feet of usable sidewall (so you don't land the roof). Thus the estimated turnovers (1005), based on total requested throughput, is reduced by the ration of . The result, 134 turnovers, was used in EPA tanks run. The tanks are monitored and controlled by a SCADA system and levels are recorded at least daily. Operational controls are such that tank levels are maintained between a depth of 6 and approximately 13 feet. As tanks are filled and tank levels rise, product may be pumped out to the larger tanks. When tank levels return to a level of nine feet, pumping will stop. The operator has estimated that, depending upon the rate at which product is pumped in; the tank levels may rise as high as 16 feet. While the working height of the tank is said to be 18.5 feet, the operator maintains that historical data indicates that levels rarely rise above 13 feet. The emissions reduction from this adjustment is significant. Permit conditions outlining a demonstration that these operational parameters are maintained will be required. 6/07/13: Upon review, the operator noted that these tanks are to be operated in series with the 5,000 bbl tanks and should have been submitted using the same throughput Revised estimates were provided. The APEN had not been signed so the existing APEN was redlined accordingly. Page 7 Section 14 — Miscellaneous Application Notes AIRS Point 004 5000 BBL Condensate Storage Tanks Working and Breathing emissions were estimated using, EPA Tanks 4.0 with '/ of the total throughput (10,079,850 bbls) being run through each of the two tanks. Roof landing losses were calculated using Equations 2-24 and 2-26 found in AP 42, Chapter 7. Standing losses: LsL=0.6Wit (BT°)M,, where: LSD = Standing loss during roof landing, lb Wt = density of liquid, lb/gal D = Tank diameter, ft 3.96 x 561101 Ls!,= 0.6 (10.731 x 512) x 58 = 1407.2 lbs per event Filling losses: PV, LFL — (-TT) M S where: LFL = filling loss during roof landing, lb P = true vapor pressure of the liquid within the tank, psia Vv = volume of the vapor space, ft3 R = ideal gas constant, 10.731 psia-ft3/(lb-mole-°R) T = average temperature of the vapor and liquid below the floating roof, °R My = stock vapor molecular weight, lb/lb-mole S = filling saturation factor, dimension less ((0.15 for a drain -dry tank)). (3.96 x 561101 LFL \10.731 x 512/ x 58 x (x 0.15) = 351.8 lbs per event Total 1407.2lbs + 351.8 lbs 1759 lbs 4 landings events ton => % landing event event year *HAPs were estimated utilizing ratios found in the Tanks output HAP Per event TOTAL Benzene 5.994 lbs 23.98 lb n -Hexane 56.074 lbs 224.30 lbs Emission Factors: 7.68 2000 lbs Yr VOCW+B = year x ton x 20,160,000 bbl = 7.619 x10-4 lbs/bbl 489.8+Yr Hexanew+B = x = 2.430 x10-5 lbs/bbl year 20,16 000 bbl 52.36 Yr Benzenew+B — year x 20,16 000 bbl = 2.597 x10-6 lbs/bbl 2000lbs — 3.52 tons per year *NOTE: Emission factors in Section 13 reflect the combined emission of working, breathing and landing losses expressed relative to annual throughput. 7.68 + 3.58 tons 2000 lbs yr a VOCTOTAL = year x ton x 20,160,000 bbl = 1.111x10 lbs/bbl 52.36 + 23.98 yr 6 BenzeneTOTAL — year x 20,160,000 bbl — 3.787 x10- lbs/bbl Page 8 Section 14 — Miscellaneous Application Notes AIRS Point 005 5000 BBL Condensate Storage Tanks Roof landing losses ...were calculated using Equations 2-24 and 2-26 found in AP 42, Chapter 7. Standing losses: LsL=0.6w,(Rr)M„ where: L5 = Standing loss during roof landing, lb Wt = density of liquid, lb/gal D = Tank diameter, ft 3.96x62341 Lst = 0.6 (10.731 x 512/ x 58 = 156.34 lbs per event Filling losses: LFL Rr M S where: LEL = filling loss during roof landing, lb P = true vapor pressure of the liquid within the tank, psia Vv = volume of the vapor space, ft3 R = ideal gas constant, 10.731 psia-ft3/(lb-mole-°R) T = average temperature of the vapor and liquid below the floating roof, °R My = stock vapor molecular weight, lb/lb-mole S = filling saturation factor, dimension less ((0.15 for a drain -dry tank)). Total = ( 3.96 x 6234 l LFL 10.731 x 5121 x 58 x (x 0.15) = 39.09 lbs per event 156.341bs + 39.09 lbs 195.431bs 8 landings events ton —> x event landing event year *HAPs were estimated utilizing ratios found in the Tanks output. — 0.78 tons per year x 20001bs HAP Per event Annual TOTAL Benzene 0.78 lbs 6.24 lb n -Hexane 7.44 61.92 Emission Factors: 5.20 2000 lbs yr V0CW+B = year x ton x 20,160,000 bbl = 5.159.x10-4 lbs/bbl NOTE: Emission factors in Section 13 reflect the combined emission of working, breathing and landing losses expressed relative to annual throughput. 5.20 + 0.78 tons 2000 lbs yr VOCroraL — year x ton x 20,160,000 bbl = 5.933 x10-5 lbs/bbl Page 9 Section 14 — Miscellaneous Application Notes AIRS Point A permit will be issued because the uncontrolled VOC emissions are greater than 1 TPY (APEN threshold) and TOTAL FACILITY is greater than 2 TPY (permit threshold). Calculations were based on a liquid sample not provided. An initial liquids analysis will be required. The APEN did not indicate an estimated or hard component count. This is a new facility and it is assumed that emissions are based on an estimated count so this permit will include an initial hard count requirement. 006 Fugitives As was the case with Rose Rock's Platteville station operation, only liquid service was indicated. As reported, "The liquid is stable when it reaches the facility because it is flashed at the wellhead separator and again in the wellhead tank. The liquid is then loaded onto a tank truck where is travels several miles over county roads to this facility. With three opportunities to flash prior to this facility, the liquid is definitely stable." As such, gaseous leaks would be unlikely and anything more than AVO inspections would not be necessary. Therefore, the minor source RACT requirement to reduce emissions focuses on completing AVO inspections. Page 10 ces pa at � M a, NI .b C) at Cld E W9 O G at Co" W w A O cC `V r� W 4 4 coo FA Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit # & AIRS ID] M 3 0 N 00 0 O 0 2 '0 U U w .u. at G a 0 S 0 E 0 v 7 F. 0. T-50-230 and T-50-231 0 a E .5" W if nested Action (Check applicable request boxes) Section 02 — R Request for NEW individual permit or newly reported emission source O a) L a CI y 0 O 0 a .0 G 8 a .0 ca a o a v ea 0 w0 E a 0 4.1 v� w 0 g + U F E WW OL bn 0 W 0 0 0 y o ° c O .., F a 0 u U 0 1 m o y O 0 00 b0 b. g F A a U A O' or a ❑ ❑ ®❑ ❑❑ O m 000 0 0) U O U a O o Co) W NN N U N Expressway, Suite 1100 Ofra M 405-945-6325 Phone Number: 0 Y 0 O0 W F s° 2 `y o F O 4 Person To Conta E-mail Address: (king@semgroupcorp.com landing) events. Inclues SSM Section 03 — General Informati to) N For new or reconstructed sources, the projected startup date is: 1 S bD p 0 0 0, O N s0. En • a) O w z al Hours of Source Operation: 3 3 0 0 ❑ ❑ zzzz ❑ ® Z ❑ Q [0 0 u 0 c 0. acs - 0 A a O O n. 2 v 0,an 3 c 2 0 A 0 N ^ p N O 000'1) G CID E_ f^ o 0 N M M et; r W bl1 N 'Z N N N O L+y L 6g. w d vS lO b b F Q b O �. a E M M M O W (� L C 00 O �5 0 y 0 V 9 a F U d q v O F Q b .S F N `^ E a La Cii 0. V at H E 'an 00C fl Z PC.yy. V A. 0 o A .. s CQ v 4 F F o 0 L i r1) rTi Y N E '� G N E y W C 1. 0 td W o T O A t u' .y00 .. O co V 'E u co) F O a y 0 o v v .� °sue' P. A o h 0 E 0 AI bra y N '; Y L A O ••>i U adj •O as .o o G.. aa) .may, F a N Q . > O N R I. L N O Q 0 a y M E 0 G �.y T W a� U 0 y O o P. A m 0 a O F, OS y b0 C �'� -' • $ 0 .C u R U N E '"Q \ ), - 0 `o Q o > 00 a Td �'-R G O L O W M Y O .4. E "- , ` .n ..E Z a U Q R Q 2 a. :/hinvw. cdolre.state.co.us/ APEN forms: htt i 1 Go 0 o 0 0 =.0 o °u° E .a x F i a ¢ 8' No v 2 E a -, a. O O � a 053 Za O V ,p .. avi n NN a 0' 0 0 3 w o hl 0 f. m 5 Drp o b t, -I.: O 3 0.' .o. E- t, c 9 x > a a) ooi O < ^ I l t> o s ) v�x u u E. m o 0C .O d 0 A N.711 u O o 0 N E o,. 2 g O o o y O O o 'U t`Oi F u Al 5 9 ti r1) t-4 at o O .o o Z Z o O O an t at. 00' • 0 • i m m Q �° m No. F 'EE v. z 00 a .G'.,x v F ,0 0 0 P U m 0 0 m� o b ? g O 0 N C. O IS N 0 0:1G .o % A A II) v o v m m R o c o E E ',G N 0 0 Co' .� o ' 0 Al 0 .`0 w0 G ti b ' m G o' 9 9 E d o o o 0 0 .P. Y a o z z y r r '0 5C O N a L 0 > 2 = ¢ m to-�3 c7♦ Section 04 — Tank Battery Information' ro H H 0 9 O Al z E a 0 . o rz 0 O O d 0 D-0 0 y em b 02 .0. 2 0 O 0. a) A OA 0 iA 0 0 0 0 o `d y v c ..3,td .v5 0 7 0 0 Y O 0 N ZU., E 0 v True Vapor Pressure: 5.64 psia @ 60 °F ng and identification of parameters used to calculate emissions. a) a) 000 .o o. e N 0 0 u ~ .E 0 A O O 00 A0. v A a ro '0 2 A w O O 0 0 YA AA d O AO P U --Xcn 0 m 0' O 9, H 0 o 4 r= O 0 Y 0 °� O T d C a . POP 0 G N d a. 0 0. 0 a] O G ' O O O T C o v 0 0't 0.0 E v 0 0 'o o .., 0 A y k v v ,0 •0at y U .- 0 0 ' .- 0 cC2 9 e�gyo ill 5 E 0. a v o an OFs GO c0 0 0 0 ezl Q Q ndens ateTankAPEN-00l . d FormAPCD-204-MidstreamC N O Si 0, FORM APCD-204 G�2 I � at rn cla Pas too O E ca 00 CI u /. I z R POLL,UT Emission Source Permit Number: (Datum & either Lat/Long.or Section 06 —Stack (Source, if no combustion) Locat E42 Th 2 0 Q o uj of d bA O C7 00 00 00 o a ~en O rl 5o 00 0 .ti E 00 CT 1• 0 O 0 0 C b U O N ti 0 O C) Ckl Cn C) C) q. O os W Section 07 — Control Device Information aL 0 u 00 0 C • I- 0 s 0 • Estimation Method or Emission Factor Source Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) Uncontrolled (Tons/Year) J© Q ' Actual Calendar Year Emissions4 Controlled (Tons/Year) 1 ...V— Uncontrolled (Tons/Year) Emission Factor Uncontrolled Basis Control. Efficiency (% Reduction) identify in Section • • Please use the APCD Control Device Description Secondary i Y j ? Pr x O Z U O J `O U Benzene Toluene co R N W Xylene n -Hexane 03 ai 0 U 'O N op O 0 0 U. as O U (QCs U e U i l 3.a I U Q` O L+ ele. as .7 s•N o a) 14 cad � .0. ivy — y • Qa) rg g•Easb o U ) . �= al 8 0 2Q� Vl o a 4- u0 a) 4.0 ° M' 0 g .4 5 T U" cg o�— N Spa 0 .o o 4) :4 o6 •G12 c) U a) a) O en as LD FomiAPCD-204-MidstreamCondensateTani:APEN-001. doc LI Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Supplement to Air Pollutant Emission Notice (APEN) for Storage Tanks Note: Please complete one supplement for each tank containing liquids. Permit Number Company Name: Tank Location: Person to Contact: Contact Title: IzwC312r Rose Rock Midstream, LP AIRS Number —00i— Briggsdale Station Lance King Enviromnental Manager Page 1 of 3 Iz3/9q q6/00 q County: Weld Phone Number: 405-945-6325 Fax Number: 405-945-6425 6/25/2012 Signature Responsible (not a vendor or consultant) Peter Schwiering Name of Responsible Official (Please Print) Section 1 Tank Information Tank Identification: T-50-230, T-50-231 Tank Installation Date 1-1-2013 Tank Type: (Check all that apply) Pressurized Open Top Roofed Horizontal Vertical Tank Dimensions Shell Length / Height: 48 Shell Diameter: 114 Maximum Liquid Height: 45 Average Liquid Height: 23 Tank Capacity: 2,310,000 Tank Turnovers Per Year: 134 Tank Throughput: 309,540,000 Is the Tank Heated? No Is the Tank Underground? No Breather Vent Settings Vacuum Setting N/A Pressure Setting N/A Tank Emissions Vent To ® Atmosphere psig psig Date Chief Operating Officer Roof Type: (Check one) A Title Fixed Roof Internal Floating Roof External Floating Roof Domed External Floating Roof Feet Feet Feet (Vertical Tanks Only) Feet (Vertical Tanks Only) Gallons Gallons Per Year (Equal To Capacity x Turnovers) RECEIVED APCD A sieurces ❑ Flare ❑ Condenser ❑ Other: Revised July 2001 http://www.cdphe.state.co.us/ap/stationary.html 2 Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 2 Fixed Roof Characteristics Page 2 of 3 Tank ID T-50-220, T-50-221 Shell Color / Shade (Check one) Roof Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ® Other: Tan Shell Condition: Good Roof Paint Condition: Good Roof Type: Supported Cone / Dome Height: 0.06 Feet Section 3 Floating Roof Characteristics External Shell Color / Shade (Check one) • White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ® Other: External Shell Condition Roof Paint Condition: ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ® Other: . Tan Roof Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) • ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ® Other: Tan (used Med Gray) Good Internal Shell Condition: (Check one) Good Rim Seal System: Primary Seal (Check one) ® Mechanical Shoe ❑ Liquid -Mounted ❑ Vapor -Mounted Deck Type: Welded ® Light Rust ❑ Dense Rust ❑ Gunite Lining Secondary Seal (Check one) ❑ Weather Shield. ❑ Rim -Mounted ® None Revised July 2001 http://www.cdphe.state.co.us/ap/stationary.html Colorado Depai fluent of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 2 Fixed Roof Characteristics Shell Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ® Other: Tan Shell Condition: Good Roof Paint Condition: Good Roof Type: Supported Cone / Dome Height: 0.06 Feet Section 3 Floating Roof Characteristics External Shell Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ❑ Other: Page 2 of 3 Tank ID T-50-220, T-50-221 Roof Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ❑ Other: Tan Roof Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ® Other: Tan (used Med Gray) External Shell Condition Good Internal Shell Condition: (Check one) Roof Paint Condition: Good Rim Seal System: Primary Seal (Check one) Z Mechanical Shoe ❑ Liquid -Mounted ❑ Vapor -Mounted Deck Type: Welded ® Light Rust ❑ Dense Rust ❑ Gunite Lining Secondary Seal (Check one) ❑ Weather Shield ❑ Rim -Mounted ® None Revised July 2001 http://www.cdphe.state.co.us/ap/stationary.html .� . 4 Colorado Department. of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 4 Meteorological Data Nearest City (Check one) ❑ Colorado — Alamosa El Colorado - Colorado Springs ❑ Colorado — Denver ❑ Colorado - Grand Junction ❑ Colorado —Pueblo ❑ Kansas — Goodland ❑ Nebraska — Scotts Bluff ❑ Wyoming - Cheyenne Section 5 Tank Contents Product Type: • ® Single Component Liquid ❑ Multi -Component Liquid Product Stored*: Product Density: Product Vapor Pressure: For Solutions: Name of Solvent*: Name of Solute Dissolved*: Concentration of Material Dissolved Condensate 5.6 9.0 Page 3 of 3 Tank ID T-50-220, T -50-22l Pounds per Gallon RVP, or psia at % By Weight, or % By Volume * Note: Please attach Material Safety Data Sheets (MSDS) for the uncommon materials. Additional Comments TANKS 4.09d output attached. OF Revised July 2001 http://www.cdphe.state.co.us/ap/stationary.html Hello