HomeMy WebLinkAbout20131138.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 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
RECEIVE
MAY 03 NO
WELD COUNTY
COMMISSIONERS
On May 2, 2013, the Air Pollution Control Division will publish a public notice for Kerr-McGee Oil and Gas
Onshore LP — 36022613, 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
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
Rao &vviti51e31,�
CC,'- 'Pk N s I
2013-1138
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-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:
12WE1253
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:
Natural gas exploration and production facility, known as 36022613, located in the SESE
of Section 13, Township 3 North, Range 68 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
FUG1
002
Equipment leaks (fugitive VOCs) from a natural gas exploration
and production facility.
TL1
003
Truck loadout of condensate.
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 sea), 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 on this permit shall be demonstrated to the Division. It is the
permittee'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; (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.)
AIRS ID: 123/8466/002, 003 Page 1 of 10
Fugitive Version 2009-2
Kerr-McGee Oil and GEC , O
Permit No. 12WE1253
Issuance 1
lidHealth and Environment
it 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
FUG1
002
25.1
Fugitive
TL1
003
16.8
Point
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
tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the synthetic minor status of this facility 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 (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 monthly emissions 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 emission units, requiring an
APEN, at this facility.
6. Point 002: 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 applicant and
made available to the Division for inspection upon request. (Reference: Regulation 3,
Part B, II.A.4)
AIRS ID: 123/8466/002, 003 Page 2 of 10
Kerr-McGee Oil and G
Permit No. 12WE1253
Issuance 1
Process/Consumption Limits
Health and Environment
it Pollution Control Division
AIRS
Point
Process Parameter
Annual Limit
003
Condensate Loading
300,000 BBL
Compliance with the yearly loading 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 the amount of
condensate loaded 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. (Reference: Regulation No. 1, Section II.A.1. & 4.)
9. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
10. Point 002: 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.
11. Point 002: 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 12 below were determined to be RACT
for this source.
12, Point 002: 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.
(i)
(ii)
For leak screening, auditory/visual/olfactory inspection (AVO) will be
performed twice a year.
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.
AIRS ID: 123/8466/002, 003
Page 3 of 10
Kerr-McGee Oil and G
Permit No. 12WE1253
Issuance 1
ern -6f POlidHealth and Environment
it Pollution Control Division
(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 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.
(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.
13. Point 003: This source is located in an ozone non -attainment or attainment -
maintenance area and is subject to the Reasonably Available Control Technology
(RACT) requirements of Regulation Number 3, Part B, III.D.2.a. The requirements of
condition number 14 below were determined to be RACT for this source.
14: Point 003: Condensate loading to truck tanks shall be conducted by submerged fill.
(Reference: Regulation 3, Part B, III.E)
OPERATING & MAINTENANCE REQUIREMENTS
15. Point 002: Upon startup of these points, the applicant shall follow the operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order
to demonstrate compliance on an ongoing basis with the requirements of this permit.
Revisions to your O&M plan shall be submitted to the Division for approval prior to
implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. Point 002: Within one hundred and eighty days (180) after issuance of this permit, the
permittee shall complete the initial extended gas analysis of gas samples that are
AIRS ID: 123/8466/002, 003 Page 4 of 10
Kerr-McGee Oil and G4 On
Permit No. 12WE1253 1
Issuance 1
Iic'Health and Environment
it Pollution Control Division
representative of volatile organic compound (VOC) 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
17. Point 002: On an annual basis, the permittee 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 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.
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).
20. 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 source at any such time that this 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:
21. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AIRS ID: 123/8466/002, 003 Page 5 of 10
Kerr-McGee Oil and Gq'
Permit No. 12WE1253
Issuance 1
enttRaf Pv .liclHealth and Environment
a
it Pollution Control Division
AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
22. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this construction
permit does not provide "final" authority for this activity or operation of this source. Final
authorization of the permit must be secured from the APCD in writing in accordance with
the provisions of 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.
23. 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
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.
24. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with
the provisions of Section 25-7-114.5(7)(a), C.R.S.
25. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self -certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the 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.
26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air. Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Stephanie Chaousy, P.E.
Permit Engineer
AIRS ID: 123/8466/002, 003 Page 6 of 10
Kerr-McGee Oil and G
Permit No. 12WE1253
Issuance 1
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Newly permitted facility. This permit consists of
fugitive emissions and condensate truck.
Facility is synthetic minor.
Health and Environment
it Pollution Control Division
AIRS ID: 123/8466/002, 003 Page 7 of 10
Kerr-McGee Oil and G
Permit No. 12WE1253
Issuance 1
Iict Health and Environment
it Pollution Control Division
Notes to Permit Holder:
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 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.
3) 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/requlations/airrees/100102agcccommonprovisionsreq.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
(lb/yr)
002
Benzene
71432
A
423
YES
N/A
Toluene
108883
C
934
NO
N/A
Xylene
1330207
C
1119
YES
N/A
Hexane
110543
C
2610
YES
N/A
003
Benzene
71432
A
115
YES
115
n -Hexane
110543
C
709
NO
709
5) The emission levels contained in this permit are based on the following emission factors:
Point 002:
Component
Gas Service
Heavy Oil
Light Oil
Water/Oil
Service
Connectors
4464
---
1956
245
Flanges
43
---
10
0
Open-ended Lines
1
---
6
2
Pump Seals
0
---
0
0
Valves
455
---
281
44
Other*
67
---
16
4
VOC Content (wt%)
23.6%
---
100%
100%
Benzene Content (wt%)
a 0716%
---
1.1795%
1.1795%
Toulene Content (wt%)
0.0782%
---
28184%
2.8184%
Xylenes Content (wt%)
0.0268%
---
3.5572%
3.5572%
n -hexane Content
0.3822%.
---
7.4454%
7.4454%
AIRS ID: 123/8466/002, 003
Page 8 of 10
Kerr-McGee Oil and G
Permit No. 12WE1253
Issuance 1
(wt%)
Health and Environment
rir Pollution Control Division
tti
*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.
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.
Point 003:
CAS
Pollutant
Emission Factors
Uncontrolled
lb/BBL loaded
-
Source
VOC
0.112
AP -42
71432
Benzene
0.00038
AP -42
110543
n -hexane
0.0024
AP -42
The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 4.6 psia
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.
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:
AIRS ID: 123/8466/002, 003
Page 9 of 10
Kerr-McGee Oil and Gr`
Permit No. 12WE1253
Issuance 1
recAPVi3olor
ic'Health and Environment
it Pollution Control Division
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source
VOC, n -hexane
NANSR
Synthetic Minor Source
VOC
MACT HH
Area Source Requirements: 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/
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
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://www.cdph e.state.co.us/alloilgasperm ittina html
AIRS ID: 123/8466/002, 003 Page 10 of 10
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Kerr-McGee Oil and Gas Onshore LP
Permit Number:
12WE1253
Source Location:
SESE Section 13, T3N, R68W, Weld County (non -attainment)
Equipment Description:
Point 002: Fugitive emission leaks
Point 003: Condensate truck loadout
AIRS ID:
123-8466
Date:
April 19, 2012
Review Engineer:
Stephanie Chaousy, PE
Control Engineer:
Chris Laplante
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
CP1
Transfer of Ownership
APEN Exempt/Permit Exempt
Section 3 — Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
X
Yes
No
Did the applicant submit all required paperwork?
X
Yes
No
Did the applicant provide ample information to determine emission rates?
X
Yes
No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
Please refer to Section 14
On what date was this application complete?
February 29, 2012
Section 4 — Source Description
AIRS Point
Equipment Description
002
Fugitive VOC leak emissions
003
Truck Condensate Loadout
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
X
Yes
No
If "yes", for what pollutant?
PM10
CO
X
Ozone
Is this location in an attainment maintenance area for
any criteria pollutant?
Yes
X
No
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT per Regulation 3, Part B, Section III.D.2)
PM10
CO
Ozone
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
Point 003: Is this source located at an oil and gas
exploration site?
X
Yes
No
Point 003: If yes, does this source load less than
10,000 gallons of crude oil per day on an annual
average, splash fill less than 6750 bbl of condensate
(hydrocarbons that have an APl gravity of 40 degrees
or greater) per year or submerged fill less than 16,308
bbl of condensate per year?
Yes
X
No
Point 003: Is this source located at a facility that is
considered a major source of hazardous air pollutant
(HAP) emissions?
Yes
X
No
Point 003: Will this equipment be operated in any
NAAQS nonattainment area?
X
Yes
No
Point 003: Does this source load gasoline into
transport vehicles?
Yes
X
No
Section 5 — Emission Estimate Information
AIRS
Point
Emission Factor Source
002
EPA -453/R-95-017, Table 2-4
003
AP -42: Chapter 5.2, Equation 1
L = 12.46*S*P*M/T
L = loading losses in lb per 1000 gallons loaded
S = Saturation Factor
P = true vapor pressure of liquid loaded [psia]
M = molecular weight of vapors [lb/lb-mole]
T = temperature of bulk liquid loaded [deg. R]
Did the applicant provide actual process data for the emission inventory?
X
Yes
No
Basis for Potential to Emit (PTE)
AIRS
Point
Process Consumption/Throughput/Production
_
002
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
4464
---
1956
245
Flanges
43
---
10
0
Open -Ended Lines
1
---
6
2
Pump Seals
0
---
0
0
Valves
455
---
281
44
Other
67
---
16
4
003
300,000 BBL per year condensate loaded
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventor)
AIRS
Point
Process Consumption/Throughput/Production
002
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
4464
---
1956
245
Flanges
43
---
10
0
Open -Ended Lines
1
---
6
2
Pump Seals
0
---
0
0
Valves
455
---
281
44
Other
67
---
16
4
003
107,846 BBL per year condensate loaded
Basis for Permitted Emissions (Permit Limits)
Page 2
AIRS
Point
Process Consumption/Throughput/Production
002
Equipment Type
Gas
Heavy Oil (or
Heavy
Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
4464
---
1956
245
Flanges
43
---
10
0
Open -Ended Lines
1
---
6
0
2
0
Pump Seals
0
---
Valves
455
---
281
44
Other 67
---
16
4
003
300,000 BBL per year condensate loaded
Does this source use a control
device?
Yes X
No
Section 6 — Emission Summary
Point
(tons per year)
NO),
VOC
CO
I
Single HAP Total HAP
PTE:
002
---
25.1
---
1.3 (Hexane) 2.6
003
---
16.7
---
---
--
Uncontrolled point
source emission rate:
002
---
25.1
---
1.3 (Hexane)
2.6
003
---
16.7
---
---
---
Total APEN Reported
emissions:
41.8
1.3 (Hexane)
2.6
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant I CAS #
I
BIN
Uncontrolled
Emission Rate
(lb/yr)
Are the
emissions
reportable?
Controlled Emission
Rate (Ib/yr)
Point 002
Benzene
71432
A 423
Yes
423
Toluene
108883
C i 934
No
934
Ethylbenzene
100414
C 0 No
0
Xylenes
1330207
C
1119
Yes
1119
n -Hexane
110543 C
2610
Yes
2610
Point 003
Benzene
71432
A
115
Yes
115
n -Hexane 1110543
C
709
No
709
Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non -criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
X
Yes
No
If "yes", complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
002
01
VOC/HAPs
State only
Extended gas
analysis
Page 3
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
What is this point classification?
True Minor
Synthetic
Minor
Major
Point 002: Fugitive Emissions
X
Point 003: Condensate truck loadout
X
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
PSD
X
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
Yes
X
No
If "yes", for which pollutants? Why? Point 001 already going to PC because it is a GP01 (and the reason
why this facility is a synthetic minor). I will not request PC for these 2 points.
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?
X
Yes
No
For Reg. 3, Part B, III.C.1,c.iii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
Yes
X
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
002, 003
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator
of a source shall allow or cause the emission into the atmosphere of any air pollutant which
is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings
taken at 15 -second intervals for six minutes. The approved reference test method for
visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July,
1992)) in all subsections of Section II. A and B of this regulation.
Regulation 2 — Odor
002, 003
Section I.A - No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are
measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Regulation 3 - APENs, Construction Permits, Operating Permits, PSD
002, 003
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in a non -attainment area with uncontrolled actual emissions
of one ton per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is non -attainment.
(Applicant is required to file an APEN since emissions exceed 1 ton per year VOC)
002
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section ll.D.2.a)
Page 4
003
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). Operator provided
a commencement start date of 7/29/2002. Since the tank battery from which loadout is
occurring has been in service since before the date above, this source is not considered
"new or modified." However, operator is using 0.6 saturation factor (submerged fill),
therefore, RACT requirements are satisfied.
Regulation 6 - New Source Performance Standards
002
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? Source is located at an E&P site, not a "natural gas processing plant," so source
not subject to NSPS KKK.
003
No applicable subpart. This facility is not a bulk gasoline terminal.
Regulation 7 — Volatile Organic Compounds
002
Section XII.G: If facility is a natural gas processing plant located in non -attainment
area, then subject to Section X11.G.
Facility is not a natural gas processing plant, therefore, not subject to Section XII.G.
003
No sections apply. This facility is neither a terminal, nor a bulk plant per definitions in Reg
7, Section VI.C.
.''-
Regulation 8 — Hazardous Air Pollutants
002
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 (Facility is synthetic minor for HAPS;
therefore, area source MACT HH).
Is this source subject to MACT HH? No
WHY? Because facility is considered area source for MACT HH, and area source MACT
HH only applies to TEG dehydrators (there are no TEG dehydrators at this facility).
003 MACT EEEE: Not subject because minor source of HAPs
Section 13 —Aerometric Information Retrieval System Coding Information
Point
Process
Process Descri tion
p
Pollutant /
CAS #
Fugitive
(YIN)
Emission Factor
Source
Control
(%)
002
01
Fugitive V0C Leak
Emissions
VOC
Yes
EPA -453/R-95-017,
Table 2-4
NA
SCC
31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains)
003
01
0.112
lb/1,000
gallon
throughput
VOC
No
AP -42
0
Truck Condensate
Loadout
300,000
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)
Page 5
Section 14 — Miscellaneous Application Notes
AIRS Point
A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit
threshold).
002
Fugitive VOC Leak Emissions
A NOS was provided with the application (dated 2/21/2012), therefore, will not require a NOS in the
permit.
Provided an actual component count on the APEN (count date of 12/9/2011). Since count is within 6
months, I will not require an initial hard component count.
I emailed the operator a few questions regarding the fugitive emission calculations:
1. Fugitives: is there a safety factor applied to the emission limits? The calculation sheet is showing
20.91 TPY (which is what I calculated), but the APEN is showing 25.1 TPY. It looks like it's a
20% increase. KMG responded 5/25/12: Yes, there is a "safety factor" of 1.2 times the 12 -month
rolling value.
2. Fugitives: do you have a gas analysis to support the stream wt %for the light oil and water?
KMG responded on 5/25/12: as indicated in the original package "a representative gas analysis
from Kerr-McGee Gathering LLC's Hudson Compressor Station was used to estimate fugitive
emissions. As the sampled inlet gas line to the contactor at the compressor station is gathered
gas from numerous wellsites, the analysis provides a good, average representation of VOC and
HAP concentrations, typical for tank battery facilities."
3. Fugitives: The fugitives are subject to RACT. An O&M plan does not fully meet the requirements
of RACT. Do you have a RACT analysis for the fugitives? KMG responded 5/25/12: KMG will
need to meet with the Division to discuss. As non -KKK LDAR Method 21 and welded fittings are
two very expensive options, KMG would like to discuss further. I emailed them an example
RACT for fugitives on 6/19/12.
4. Fugitives: Facility inventory form (APCD 102) is showing controlled fugitive emissions. However,
the APEN does not reflect any control or how. Could you please explain? Might have to modify
the APEN. KMG responded 5/25/12: There are not any "controlled" fugitive emissions, the same
way there are not any "controlled" VRU emissions or heater treater emissions. I've included 1
facility -wide emission inventory forms: one for 2011 and one for the forcasted 12 -month rolling
total.
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.
Page 6
AIRS Point
003
Truck Condensate Loadout
Units
Basis
S
0.6
Submerged loading:
dedicated normal service
P
4.6
Psia
EPA
M
41
Lb/lb-mole
E&P Tanks
T
531
Deg R
Average sales Oil
Temperature
L
2.66
Lb/10^ 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
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]
S 0.6 Submerged loading: dedicated normal service
P 4.6 Psia,
M 41 lb/lb-mole
T 531 deg. R
L 2.661b/10^3 gal
1.12E-011b/bbl
Annual requested Throughput 12600000ga1/yr
Annual requested VOC emissions 334571b/yr
16.73tpy
I emailed the operator with some questions regarding the truck loadout:
1. Truck loadout: I was wondering if you could verify where you got the TVP and molecular weight
values (4.6 psia and 41 lb/lb-mol). KMG responded 5/25/12: Please refer to the attached revised
truck loadout emissions.
Emission factors for HAPS
Benzene = 114.73 / 300000 = 0.00038 lb/bbl (matches APEN) * 1000/42 = 0.0091 lb/1000 gal
n -hexane = 708.31 / 300000 = 0.0024 lb/bbl (matches APEN) * 1000/42 = 0.0562 lb/1000 gal
Page 7
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