HomeMy WebLinkAbout20131081.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
Weld County Clerk & Recorder
1402 N 17th Ave
Greeley, CO 80631
April 25, 2013
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
BEcovED
wino
COELD 0- M M1SSI 0NERS
Colorado Department
of Public Health
and Environment
Dear Sir or Madam:
On April 29, 2013, the Air Pollution Control Division will publish a public notice for Kerr-McGee Oil and
Gas Onshore LP — 35029745, 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-S S -B 1
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
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13
2013-1081
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.cdphastate.co.us
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Colorado Department
of Public Health
and Environment
Website Title: Kerr-McGee Oil and Gas Onshore LP — Natural gas wellhead site — Weld County
Released To: The Greeley Tribune
On: April 25, 2013
Published: April 29, 2013
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
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: Kerr-McGee Oil and Gas Onshore LP
Facility: 35029745
Natural gas wellhead site
SWSE Section 5, Township 3 North, Range 63 West
Weld County
The proposed project or activity is as follows: Oil and gas wellhead site permitting a truck loadout and associated
fugitive emissions
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 Division has made a preliminary determination of approval of the application.
A copy of the application, including supplemental information, the Division's analysis, and a draft of
Construction Permit 12WE1578 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:
Stephanie Chaousy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B 1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Kerr-McGee Oil and Gas Onshore LP
Permit Number:
12WE1578
Source Name:
35029745
Source Location:
SWSE Section 5, T3N, R63W, Weld County (non -attainment)
Equipment Description:
Point 008: Truck loadout
Point 009: Fugitives
AIRS ID:
123-9393
Review Date:
July 26, 2012
Review Engineer:
I Stephanie Chaousy, PE
Section 2 — Action Completed
X
CP1
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?
Please see Section 14
On what date was this application complete?
April 25, 2012
Section 4 — Source Description
AIRS Point
Equipment Description
008
Truck condensate loadout.
009
Fugitive emission leaks.
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?
PM1U
CO
X
Ozone
Is this location in an attainment maintenance area for
any criteria pollutant?
I
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
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
Pagc: l
Point 008: Is this source located at an oil and gas
exploration site?
X
Yes
No
Point 008: 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 008: Is this source located at a facility that is
considered a major source of hazardous air pollutant
(HAP) emissions?
Yes
X
No
Point 008: Does this source load gasoline into
transport vehicles?
Yes
X
No
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
008
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]
009
EPA -4531R-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
008
400,000 BBL per year condensate loaded
009
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
5580
---
1956
306
Flanges
54
---
13
0
Open -Ended Lines
2
---
8
3
Pump Seals
0
---
0
0
Valves
569
---
351
55
Other
84
---
20
5
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
008
400,000 BBL per year condensate loaded
009
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
5580
---
1956
306
Flanges
54
---
13
0
Open -Ended Lines
2
---
8
3
Pump Seals
0
---
0
0
Valves
569
---
351
55
Other
84
---
20
5
Does this source use a control device?
Yes
X
No
Section 6 — Emission Summary (tons per year)
Point
NO„
VOC
CO
Single HAP
HAP
Page 2
PTE:
008
---
22.3
---
0.5 (n -hexane)
0.6
009
---
30.2
---
1.3 (n -hexane)
2.7
Total
---
24.4
---
0.8 (n -hexane)
2.6
Uncontrolled point
source emission rate:
008
---
22.3
---
0.5 (n -hexane)
0.6
009
---
30.2
---
1.3 (n -hexane)
2.7
Permitted point source
emission rate:
GP01
---
39.0
---
8.0
20.0
008
---
22.3
---
0.5 (n -hexane)
0.6
009
---
30.2
---
1.3 (n -hexane)
2.7
Total
---
91.5
---
9.8 (n -hexane)
23.3
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled Emission
Rate (Ib/yr)
Point 008
Benzene
71432
A
153
Yes
N/A
n -Hexane
110543
C
944
No
N/A
Point 009
Benzene
71432
A
524
Yes
N/A
Toluene
108883
C
1026
Yes
N/A
Xylenes
1330207
C
1146
Yes
N/A
n -Hexane
110543
C
3134
Yes
N/A
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?
Yes
X
No
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
What is this point classification?
X
True
Minor
Synthetic
Minor
Major
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
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
If "yes", for which pollutants? Why?
For Reg. 3, Part B, III.C.1:a (emissions increase > 25/50 tpy)?
X
Yes
No
Page 3
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)?
Yes
X
No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
Yes
X
No
AIRS Point
Section 12 — Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
008, 009
Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
the source. During periods of startup, process modification, oor 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.)
Regulation 2 - Odor
008, 009
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.
Regulation 3-APENs, Construction Permits, Operating Permits, PSD
008, 009
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 two tons per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is non -attainment.
(Applicant is required to file an APEN since emissions exceed 1 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 11.D.2.a)
009
Part B, III.D.2 - RACT requirements for new or modified minor sources
This section of Regulation 3 requires RACT for new or modified minor sources located in
nonattainment or attainment/maintenance areas. This source is located in the 8 -hour ozone
nonattainment area.
The date of interest for determining whether the source is new or modified is therefore
November 20, 2007 (the date of the 8 -hour ozone NA area designation). Since the tank
battery from which loadout is occurring has been in service after the date above, this
source is considered "new or modified." Operator is using 0.6 saturation factor (submerged
fill), therefore, RACT requirements are satisfied.
Regulation 6 - New Source Performance Standards
008
No applicable subpart. This facility is not a bulk gasoline terminal.
009
NSPS KKK: Equipment Leaks of VOC from onshore natural gas processing plants.
Affected facilities at onshore natural gas facilities (any processing site engaged in
the extraction of natural gas liquids from field gas, fractionation of mixed natural gas
liquids (NGLs) or both).
Is this source at a "natural gas processing plant?" No
Is this source subject to NSPS KKK? No
WHY? Facility is not a "natural gas processing plant," therefore, not meeting the criteria of
this regulation. Therefore, source not subject.
Regulation 7 -Volatile Organic Compounds
008
No sections apply. This facility is neither a terminal, nor a bulk plant per definitions in Reg
7, Section VI.C.
009
Section XII.G: If facility is a natural gas processing plant located in non -attainment
area, then subject to Section XII.G.
Facility not a natural gas processing plant, therefore, not subject.
Regulation 8 — Hazardous Air Pollutants
008
MACT EEEE:
Not subject because minor source of HAPs
Page 4
009
MACT HH: If facility is MAJOR source for HAP (summation of HAPS of dehydrators
and fugitives), then fugitive emissions are subject to MACT HH.
Is this facility considered MAJOR for HAPS? No
Is this source subject to MACT HH? No
WHY? Facility is considered area source MACT HH. Only TEG dehydrators are subject to
area source MACT HH (no dehydrators at this facility).
Section 13 — Aerometric.Information Retrieval System Coding Information
Point
Process
Process
Description
Process/
throughp
ut Limit
Emission
Factor
Pollutant /
CAS #
Fugitive
(YIN)
Emission
Factor
Source
Control
(%)
008
01
2.66 lb/1,000
gallon
throughput
VOC
No
AP -42
0
Truck Condensate
Loadout
200,000
BBL/yr
0.0091
lb/1, 000
gallon
throughput
benzene
No
AP -42
0
0.0562
lb/1,000
gallon
throughput
n -hexane
No
AP -42
0
SCC
40600132: Crude Oil: Submerged Loading (Normal Service)
009
01
Fugitive VOC
Leak Emissions
VOC
Yes
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
008
Truck Condensate Loadout
Units
Basis
S
0.6
Submerged loading:
dedicated normal service
P
4.6
Psia
Based on EPA TANK
M
41
Lb/lb-mole
Based on E&P TANK run
T
531
Deg R
Based on source's
knowledge of bulk liquid
temperature
L
2.66
Lb/10^3 gal
0.112
Lb/bbl
This value is used to
calculate annual emissions
AP -42: Chapter 5.2
Equation 1
L = 12.46*S*P*M/T
S 0.6 Submerged loading: dedicated normal service
P 4.6 Psia,
M 41 lb/lb-mole
T 531 deg. R
L 2.66Ib/10^3 gal
1.12E-01Ib/bbl
Annual requested Throughput 16800000gal/yr
Annual requested VOC emissions 446091b/yr
22.3tpy
Operator calculated HAPS by representative benzene and n -hexane loading emission composition
(mol%)
Benzene
n -hexane
W&S Gas Mol%
0.18
1.00
Lb/Ib-mol (M)
78.11
86.8
Benzene (152.98 Ib/yr) / (400000 bbl/yr) = 0.00038 lb/bbl = 0.009106 lb/1000 gal
n -hexane = (944.41 Ib/yr) / (400000 bbl/yr) = 0.00236 lb/bbl = 0.0562 lb/1000 gal
Page 6
AIRS Point
009
Fugitive VOC Leak Emissions
A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit
threshold).
Operator requested a 20% safety factor for their fugitive emission limits.
Operator provided a gas analysis dated 7/30/11 with the application. This is within 1 year of the
application submittal and review, so I will not request a new gas analysis.
I worked with the operator to determine RACT for this facility. I emailed KMG a condition based on AVO
that might be sufficient for RACT on 7/19/12. Kerr-McGee did not think that the Division's condition was
applicable to their facility because KMG felt that if they were to follow this condition, they should receive
control credit since they felt it was a smaller version of a LDAR program. We had several back and forth
email conversations regarding this. Some suggestions KMG brought up to satisfy RACT were:
1. The O&M plan: The Division felt that the O&M did not fully meet all the criteria for RACT.
2. 2. Using screening factors: Chris emailed KMG on 3/14/13 saying that the Division will not
accept screening emission factors to represent uncontrolled fugitive emissions. KMG must use
the average emission factor approach to calculate uncontrolled emissions from fugitive sources.
Carissa Money emailed me on 3/20/13 (per meetings and emails with KMG): Please move forward with
processing the Kerr McGee E&P site applications that were on hold due to the minor source RACT
condition for fugitives. Kerr McGee has been notified that we are moving forward with existing
applications using our standard language for minor source RACT. For these applications, we will use our
standard emission calculation methodology for fugitives and we will not be assigning a control efficiency
for implementing the minor source RACT requirements. if Kerr McGee has not yet seen a draft of the
permits and requested to see a draft, please do send them the draft but we will not modify the minor
source RACT condition for fugitives. If you have any questions, let me know.
AIRS Point
Facility Notes
The Operator provided a NOS for the loadout and fugitives with the application (operations began June
29, 2011). Therefore, I am not going to require a NOS in the permit.
Page 7
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
12WE1578
Issuance 1
DATE ISSUED:
ISSUED TO: Kerr-McGee Oil and Gas Onshore LP
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as 35029745, located in the SWSE of Section 5, Township 3
North, Range 63 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
TL1
008
Truck loadout of condensate. Emissions from the loadout are
not controlled.
FUG1
009
Equipment leaks (fugitive VOCs) from a wellhead site.
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. 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).
2. 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; (Hi) 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.)
AIRS ID: 123/9393
Page 1 of 10
Condensate Loadout TM Version 2012-1
Collli'ido fpai4?ne a Public Health and Environment
#- Air Pollution Control Division
3. 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.)
4. 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
5. 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:
Facility
Equipment
ID
AIRS
Point
Tons per Year
Emission Type
VOC
TL1
008
22.3
Point
FUG1
009
30.2
Fugitive
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.
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.
6. Point 008: The operator shall calculate actual emissions from this emissions point
based on representative component counts for the facility with the most recent gas
analysis, as required in the Compliance Testing and Sampling section,of this permit.
The operator shall maintain records of the results of component counts and sampling
events used to calculate actual emissions and the dates that these counts and events
were completed. These records shall be provided to the Division Upon request.
PROCESS LIMITATIONS AND RECORDS
7. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
AIRS ID: 123/9393 Page 2 of 10
Process/Consumption Limits
oPPublic Health and Environment
Air Pollution Control Division
IRS
Point
Process Parameter
Annual Limit
008
Condensate Loading
400,000 BBL
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.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. 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 XVII.B.1.c shall have no visible emissions. (Reference: Regulation
No. 1, Section II.A.1. & 4.)
This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
10. Point 008: 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. The requirements of
condition number 10 below were determined to be RACT for this source.
11. Point 008: Condensate loading to truck tanks shall be conducted by submerged fill.
(Reference: Regulation 3, Part B, III.E)
12. Point 009: This source is subject to Regulation No. 7, Section XII.C General Provisions
(State only enforceable). All condensate collection, storage, processing and handling
operations, regardless of size, shall be designed, operated and maintained so as to
minimize leakage of volatile organic compounds to the atmosphere to the maximum
extent practicable. The operator shall comply with all applicable requirements of Section
XII.
13. Point 009: 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 for the pollutants for which the
area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B,
III.D.2.a). The requirements of condition number 13 below were determined to be RACT
for this source. The requirements of condition number 14 below were determined to be
RACT for this source.
AIRS ID: 123/9393 Page 3 of 10
rhe -i. or Public Health and Environment
Air Pollution Control Division
14. Point 009: 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
installing/implementing the following emission controls:
a. Directed Inspection & Maintenance as described below shall satisfy the
requirement to apply RACT.
For leak screening, auditory/visual/olfactory inspection (AVO) will be
performed twice a year.
H. For each leak found in the AVO inspection, use either optical gas imaging
(i.e. IR camera) or portable VOC measurement instrument (i.e. a Method 21
instrument) calibrated and maintained per the manufacturer's
recommendations to monitor for leaks.
Hi. If Method 21 is used, 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 repaired, repair shall
occur during the first shutdown of the affected operation after the leak is
discovered. If optical gas imaging is used, a component shall be
considered leaking if any visible emissions are monitored and 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 repaired, repair shall
occur during the first shutdown of the affected operation after the leak is
discovered."
iv. For repair, valves adjacent to the equipment to be repaired will be closed if
practicable, minimizing the volume released.
v. Repaired components shall be re -screened to determine if the leak is
repaired.
vi. The following records shall be maintained fora 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.
vii. 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.
OPERATING & MAINTENANCE REQUIREMENTS
15. Point 009: 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
AIRS ID: 123/9393 Page 4 of 10
o Public Health and Environment
Air Pollution Control Division
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
16. Point 009: Within one hundred and eighty days (180) after commencement of
operation, 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.
Periodic Testing Requirements
17. Point 009: On an annual basis, the owner or operator shall complete an extended gas
analysis of gas 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.
ADDITIONAL REQUIREMENTS
18, A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually by April 30th 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
AIRS ID: 123/9393 Page 5 of 10
oYPublic Health and Environment
Air Pollution Control Division
e. No later than 30 days before the existing APEN expires.
19. 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:
20. 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.
21. 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.
22. 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.
23. 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.
24. 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.
AIRS ID: 123/9393 Page 6 of 10
Public Health and Environment
Air Pollution Control Division
25. 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.
26. 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 Kerr-McGee Oil and Gas Onshore LP.
Newly permitted loadout and fugitives at a
synthetic minor facility.
AIRS ID: 123/9393 Page 7 of 10
Cori' do
e
or Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) 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.
3) 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. cdphe.state. co. us/requ lations/ai rregs/100102agcccom monprov isi onsreq. pdf.
4) 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)
008
Benzene
71432
A
153
Yes
N/A
n -Hexane
110543
C
944
No
N/A
009
Benzene
71432
A
524
Yes
N/A
Toluene
108883
C
1026
Yes
N/A
Xylenes
1330207
C
1146
Yes
N/A
n -Hexane
110543
C
3134
Yes
N/A
5) The emission levels contained in this permit are based on the following emission factors:
Point 008:
CAS
Pollutant
Emission Factors
Ib/BBL loaded
- Uncontrolled
Source
VOC
0.112
AP -42
71432
Benzene
0.00038
Engineering Calculation
110543
n -hexane
0.0024
Engineering Calculation
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)
AIRS ID: 123/9393
Page 8 of 10
f
P (true vapor pressure) = 4.6 psis
Public Health and Environment
Air Pollution Control Division
M (vapor molecular weight) = 41 Ib/Ib-mol
T (temperature of liquid loaded) = 531 °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.
Point 009:
Component
Gas Service
Heavy Oil
Light Oil
SWater/Oil
ervi
Service
Connectors
5580
---
1956
306
Flanges
54
---
13
0
Open-ended Lines
2
---
8
3
Pump Seals
0
---
0
0
Valves
569
---
351
55
Other*
84
---
20
5
VOC Content (wt.
fraction)
23.6
---
100
100
Benzene Content (wt.
fraction)
0.0716
---
1.2453
1.2453
Toluene Content (wt.
fraction)
0.0782
--
2.6146
2.6146
Ethylbenzene (wt.
fraction)
- __
_
___
___
Xylenes Content (wt.
fraction)
0.0268
---
3.0912
3.0912
n -hexane Content (wt.
fraction)
0.3822
---
7.5781
7.5781
*Other equipment type includes 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
Note that the emission limits included in this permit are derived by multiplying the equipment counts in
the table above by a factor of 1.2 to accommodate other minor changes to the facility and to provide a
conservative estimate of facility -wide emissions.
AIRS ID: 123/9393
Page 9 of 10
of Public Health and Environment
Air Pollution Control Division
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 gas analysis.
6) 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.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
VOC, n -hexane
NANSR
Synthetic Minor Source of:
VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
SubpartA— 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
9) 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://wvvw.cdphe.state.co.us/ap/oilgaspermittind.html
AIRS ID: 123/9393
Page 10 of 10
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Zip Code: 80217-3779
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