HomeMy WebLinkAbout20132621.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
September 5, 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 September 9, 2013, the Air Pollution Control Division will publish a public notice for Kerr McGee
Gathering, LLC. — Vollmar Compressor St., 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 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
RECEIVED
SEP 1 1 2013
WELD COUNTY
COMMISSIONERS
C'. ku1epo A
iv
2O13-2621
STATE 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 60246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.co.us
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Website Title: Kerr McGee Gathering LLC - Vollmar Compressor St. — Weld County
Released To: The Greeley Tribune
On: September 5, 2013
Published: September 9, 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: Kerr McGee Gathering LLC
Facility: Vollmar Compressor Station
Natural gas compressor station
Section 14, Township 2 north, Range 67 west
Weld County
The proposed project or activity is as follows: Natural gas compressor station
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):
• permittedemissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.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, the Division's analysis, and a draft of Construction Permit 12WE2413 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-B 1
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:
12W E2413
Kerr-McGee Gathering LLC
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Vollmar Compressor Station, located in the Section 14,
T2N R67W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point
Description
Fugitive
Components
007
Equipment leaks (fugitive VOCs) from a natural gas
compressor station.
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 equipment start-up, 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 equipment start up, 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, III.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; (Hi) does not complete construction within a reasonable
AIRS ID: 123/0058 Page 1 of 10
Fugitive SM/M Version 2012-2
IicPHealth and Environment
it Pollution Control Division
time of the e -tom ccu j et e. ®"vision gala'y grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
4. The operator shall 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)
Monthly Limits:
Facility
Equipment ID
AIRS
Point
Pounds per Month
Emission Type
VOC
Fugitive
Components
007
6163
Fugitive
(Note: Monthly limits are based on a 31 -day month.)
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
1,359 lb/month.
Facility -wide emissions of total hazardous air pollutants shall be less than 3,398
lb/month.
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
VOC
Fugitive
Components
007
36.4
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.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
During the first twelve (12) months of operation, compliance with both the monthly 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
AIRS ID: 123/0058 Page 2 of 10
i Health and Environment
it Pollution Control Division
twelve-month
facility.
6. The operator shall calculate actual emissions from this emissions point based on
representative component counts for the facility with the most recent gas analyses, 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.
STATE AND FEDERAL REGULATORY REQUIREMENTS
7. 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.
8. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
9. 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, section III.D.2.a.
a. RACT for fugitive equipment leaks from gas compressor stations will be the
inspection and repair requirements as set forth below conducted on a monthly
basis:
4t;drequiring an APEN, at this
i. 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.
it Screen all pumps, valves, connectors, and pressure relief devices on
a monthly basis to determine if leaks are present.
iii. Tag all leaking components with date of leak detected, date of repair
and date of rescreening. Once leak is repaired, the tag may be
removed.
iv. If a VOC measurement device is utilized, a component shall be
considered to be leaking if a concentration greater than 10,000 ppm is
monitored. If optical gas imaging is utilized, a component shall be
considered leaking if any visible emissions are noted.
v. Component leaks shall be repaired as set forth below:
o A first repair attempt shall be made within five days, with the
leak repaired as soon as practicable, but no later than 15
days. Repaired components shall be re -screened within five
days of repair to determine if the leak is repaired. If the
rescreening shows a leak, then attempt another repair as soon
as practicable, but no later than 15 days. Repeat the process
until the rescreening shows no leak.
AIRS ID: 123/0058 Page 3 of 10
li&Health and Environment
it Pollution Control Division
�. -; is •etec.a�,,a �s tec ly infeasible to make the
repair without a process unit shutdown, repair of this
equipment shall occur before the end of the next process unit
shutdown. Records documenting the rationale shall be
maintained, the component placed on the Delay of Repair list,
the ID number recorded, and an estimated date for repairing
the component included in the facility records. Monitoring to
verify the repair must occur within 15 days after startup of the
process unit.
vi. The following records shall be maintained and kept onsite for five
years and shall be made available to the Division upon request:
o List of leaking components
o List of repaired components along with the repair method and
associated dates
o List of successful repairs, repair delays, and post -repair
screenings and associated dates
o Dates of monitoring equipment calibration
OPERATING & MAINTENANCE REQUIREMENTS
10. This source is not required to follow a Division -approved operating and maintenance
plan.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
11. Within one hundred and eighty days (180) after issuance of this permit, the owner or
operator shall complete the initial extended gas 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.
12. 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.
Periodic Testing Requirements
13. 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.
AIRS ID: 123/0058 Page 4 of 10
ADDITIONAL REQ
Health and Environment
it Pollution Control Division
14. 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 NOx per
year, a change in annual actual emissions of one (1) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
15. 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).
16. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil
and Natural Gas Production Facilities major stationary source requirements shall apply
to this stationary source at any such time that this stationary source becomes major
solely by virtue of a relaxation in any permit limitation and shall be subject to all
appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part
E)
GENERAL TERMS AND CONDITIONS:
17. 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.
AIRS ID: 123/0058 Page 5 of 10
Iic Health and Environment
it Pollution Control Division
18. If this permits®. ;'fftally a#es)athfin
al a�rttslizatio 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.
19. 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.
20. 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.
21. 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 of a source may request a hearing
before the AQCC for review of the Division's action.
22. 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.
23. 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.
AIRS ID: 123/0058 Page 6 of 10
Michael Cleary
Permit Engineer
IicHealth and Environment
it Pollution Control Division
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Kerr-McGee Gathering LLC
AIRS ID: 123/0058
Page 7 of 10
Notes to Permit Holder &itretime of this
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 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 ll.E.1. of the Common Provisions
Regulation. See:
http://www.cdphe.state. co. us/regulations/airregs/100102aocccommonprovisionsred. 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.
IidHealth and Environment
it Pollution Control Division
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(lb/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate
(lb/yr)
004
Benzene
71432
A
1309
Yes
1309
Toluene
108883
C
1950
Yes
1950
Ethylbenzene
100414
C
274
No
274
Xylenes
1330207
C
1342
Yes
1342
n -Hexane
110543
C
4448
Yes
4448
5) The emission levels contained in this permit are based on the following emission factors:
Component
Gas Service
Heavy Oil
Light Oil
Water/Oil
Service
Inlet Gas
Fuel Gas
Connectors
2607
483
955
1978
10
Flanges
856
106
19
188
0
Open-ended Lines
0
0
0
0
0
Pump Seals
0
4
0
18
0
Valves
675
57
97
333
0
Other*
171
1
1
74
0
VOC Content (wt.
fraction)
0.2500
0.0600
1.0000
0.9960
1.0000
Benzene Content
(wt. fraction)
0.0020
0.0000
0.0000
0.0250
0.0000
Toluene Content
(wt. fraction)
0.0020
0.0000
0.0000
0.0400
0.0000
Efhylbenzene (wt.
fraction)
0.0005
0.0000
0.0000
0.0050
0.0000
Xylenes Content (wt.
0.0005
0.0000
0.0000
0.0300
0.0000
AIRS ID: 123/0058
Page 8 of 10
Deparnen
lid'Health and Environment
it Pollution Control Division
fraction)
n -hexane Content
(wt. fraction)
0.0050
0.0000
0.0900
0.0000
`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 7.5% to accommodate other minor changes to the facility and to provide
a conservative estimate of facility -wide emissions.
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 of: CO and HAPs
NANSR
Not Applicable
MACT HH
Area Source Requirements: Not Applicable
NSPS KKK
Not Applicable
NSPS OOOO
Not Applicable
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/
AIRS ID: 123/0058
Page 9 of 10
jHealth and Environment
it Pollution Control Division
Part 60: Standards of-Perforrriattce or edlr Station'aryources.-.
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
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:
www.colorado.gov/cdphe/oilgaspermits
AIRS ID: 123/0058 Page 10 of 10
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Kerr McGee Gathering LLC
Permit Number:
12WE2413
Source Location:
Section 14, T2N, R67W
Equipment Description:
Point 004: Backup/Emergency power generator
Point 007: Fugitive emissions
AIRS ID:
123/0058
Date:
July 2, 2013
Review Engineer:
Michael Cleary
Control Engineer:
Chris Laplante
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?
On what date was this application complete?
07/2/2013
ISection 4 -- Source Description
AIRS Point
Equipment Description
004
Backup/Emergency power generator. Cummins, Model GTA38G3, SN#: TBD
007
Fugitive VOC leak emissions
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?
PM,o
CO
X
Ozone
Is this location in an attainment maintenance area for
any criteria pollutant?
Yes
X
No
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT per Regulation 3, Part B, Section III.D.2)
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
Page 1
Section 5 — Emission Estimate Information
AIRS
Point
Emission Factor Source
004
Manufacturer specifications/ AP -42
007
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
007
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
3090
955
1978
10
Flanges
962
19
188
0
Open -Ended Lines
0
0
0
0
Pump Seals
4
0
18
0
Valves
732
97
333
0
Other
172
1
74
0
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS
Point
Process Consumption/Throughput/Production
007
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
3090
955
1978
10
Flanges
962
19
188
0
Open -Ended Lines
0
0
0
0
Pump Seals
4
0
18
0
Valves
732
97
333
0
Other
172
1
74
0
Basis for Permitted Emissions (Permit Limits)
AIRS
Point
Process Consumption/Throughpu/Production
_
007
Equipment Type
Gas
Heavy Oil (or
Heavy
Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
3090 .
955
1978
10
Flanges
962
19
188
0
Open -Ended Lines
0
0
0
0
Pump Seals
4
0
18
0
Valves
732
97
333
0
Other
172
1
74
0
Does this source use a control
device?
Yes
X
No
Section 6 — Emission Summary
(tons per year)
Point
NOx
VOC
CO
Single HAP
Total HAP
PTE:
007
---
36.4
---
2.3 (Hexane)
4.8
Uncontrolled point
source emission rate:
007
---
36.4
---
2.3 (Hexane)
4.8
Page 2
Permitted point source
emission rate:
007
---
36.4
j 2.3 (Hexane)
4.8
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
r
BIN
Uncontrolled
Emission Rate
(Iblyr)
Are the
emissions
reportable?
Controlled Emission
Ib! r
Rate ( Y )
Benzene
71432
A
1309
Yes
NA
Toluene
108883
C
1950
Yes
NA
Ethylbenzene
100414
C
274
No
NA
Xylenes
1330207
C
1342
Yes
NA
n -Hexane
110543
C
4448
Yes
NA
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?
If "yes", complete the information listed below
Yes
X
No
i
AIRS Point
Process Pollutant
Regulatory Basis
Test Method
Section 9 — Source Classification
Is this a new previously un-permitted source?
004
X
Yes
No
007
X
Yes
No
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
MACT
Classification relates to what programs?
X I Title V
PSD
X
NA NSR
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 VOC emissions increase
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?
X
r
Yes
No
For Reg. 3, Part B, III.C.1,c.iii (subject to MACT)?
Yes
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
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 ,
No
AIRS Point
Section 12 — Regulatory Review
Ret'wlation 9 —Particulate. Smoke, Carbon Monoxide and Sulfur Dioxide
Page 3
007
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
007
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.
Requlation 3-APENs, Construction Permits, 0.eratin. Permits, PSD
007
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in an 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 attainment.
(Applicant is required to file an APEN since emissions exceed 1 tons per year VOC)
004
Part B — Construction Permit Exemptions
Applicant is not required to obtain a permit because the source will be used for
emergency power generation and operated less than 250 hrs/yr. (Reg. 3, Part B,
Section II.D.3.a)
007
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold (Reg. 3, Part 8, Section Il.D.3.a)
007
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 fugitives
have not been in service since before the date above, this source is considered "new or
modified." Operator has agreed on the Division's standard conditions for fugitive
component equipment leak monitoring for RACT.
Re•ulation 6 - New Source Performance Standards
007
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
007
NSPS 0000: Standards of Performance for Crude Oil and Natural Gas Production,
Transmission and Distribution. For fugitive emissions at natural gas processing
plants subject to NSPS 0000. This subpart establishes emission standards and
compliance schedules for the control of volatile organic compounds (VOC) and
sulfur dioxide (SO2) emissions from affected facilities that commence construction,
modification or reconstruction after August 23, 2011.
Is this source at a "natural gas processing plant?" No
Is this source subject to NSPS 0000? No
Regulation 7 — Volatile Organic Compounds
007
Section XII.G: If facility is a natural gas processing plant located in non -attainment
area, then subject to Section XII.G.
Re elation 8 — Hazardous Air Pollutants
Page 4
MACT HH: If facility is MAJOR source for HAP at a natural gas processing plant
ONLY (summation of HAPS of dehydrators and fugitives), then fugitive emissions
are subject to MACT HH.
007
Is this facility considered MAJOR for HAPS? No
Is this source subject to MACT HH? No
Section 13 — Aerometric Information Retrieval System Coding Information
Point.
Process
Process Description
Pollutant /
CAS #
Fugitive
(YIN)
Emission Factor
Source
Control
(%)
007
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)
Section 14— Miscellaneous Application Notes
AIRS Point
004
Emergency Generator
A permit exempt, APEN required letter will be issued because the source has potential emissions greater
than 1 TPY in a non -attainment area, but will be used as an emergency generator, operated less than
250 hours. Therefore, this source qualifies for the categorical emergency generator permit exemption
contained in Regulation 3, Part B, Section II.D.
Section 14 —Miscellaneous Application Notes
AIRS Point
007
Fugitive VOC Leak Emissions
A permit, will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit
threshold).
Updated APEN, provided on July 2, indicates additional equipment and a higher emission estimate. The
change in emissions from this project now exceed 25TPY in a non -attainment area so this permit will
require a public comment period.
Emissions Calculations:
In estimating, KMG has identified gas service components as being in one of two categories, inlet gas
and fuel gas, and used VOC weight fractions of 25% and 6% respectively. These figures were
determined based upon the average of several samples of product they deemed representative. Initial
and annual sampling, once operational, will be required within the permit.
Permitted emission limit reflects a 'buffer' requested to allow for variability in gas/liquids composition and
variations in as-builts due to use of an estimated component count.
RACT:
Part B, •III.D.2 of Regulation 3 requires RACT for new or modified minor sources located in nonattainment
or attainment/maintenance areas. This source is considered new and is located in the 8 -hour ozone
nonattainment area.
The Division deems has proposed leak detection and repair (LDAR) program requirements, within the
permit, to satisfy this requirement. KMG has reviewed and accepted these requirements, which include
monthly screening and a leak repair protocol.
Page 5
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