HomeMy WebLinkAbout20110903.tiff STATE OF COLORADO
John W.Hickenlooper,Governor
Christopher E.Urbina,MD, MPH - �, 40
Executive Director and Chief Medical Officer c 4644
Dedicated to protecting and improving the health and environment of the people of Colorado 1 * ' o.
4300 Cherry Creek Dr.S. Laboratory Services Division • ra7 •
"
Denver,Colorado 80246-1530 8100 Lowry Blvd. 6
Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department
Located in Glendale,Colorado (303)692-3090 of Public Health
http://www.cdphe.state.co.us and Environment
March 30, 2011
Mr. Steve Moreno
Weld County Clerk
1402 17th Ave.
Greeley, CO 80631
Dear Mr. Moreno:
The Air Pollution Control Division will publish a public notice for the Kerr-McGee. This public notice
will be published in the Windsor Beacon on April 7, 2011.
Thank you for assisting the Division by making the enclosed package (includes public notice,
preliminary analysis, Air Pollutant Emission Notice(s) and draft permit(s)) available for public review
and comment. It must be available for public inspection for a period of thirty (30) days from the date
the public notice is published.
Please forward any comment regarding this public notice to the address below.
Colorado Department of Public Health and Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Attention: Ellen Evans
Regards,
--.\
',./
Ellen Evans
Public Notice Coordinator
Stationary Sources Program Air Pollution Control Division
RU.\OC &J C Ll tAL P L_ 2011-0903
APPLICATION FOR ISSUANCE OF A MINOR SOURCE PERMIT
FOR LANDFARMING OF CONDENSATE CONTAMINATED SOIL
BY
Kerr-McGee Oil & Gas Onshore LP
CONTENTS
1. PUBLIC NOTICE
2. PRELIMINARY ANALYSIS
3. AIR POLLUTANT EMISSION NOTICE
4. DRAFT PERMIT
PREPARED BY:
Dennis M. Myers, P.E.
COLORADO DEPARTMENT OF PUBLIC HEALTH & ENVIRONMENT
4300 CHERRY CREEK DRIVE SOUTH, APCD-SS-B1
DENVER CO 80246-1530
STATE OF COLORADO
John W.Hickanlooper,Governor -
Christopher E.Urbina,MD,MPH
Executive Director and Chief Medical Officer o
Dedicated to protecting and improving the health and environment of the people of Colorado l*� pit; r n AOi
4300 Cherry Creek Dr.S. Laboratory Services Division
Denver,Colorado 80246-1530 8100 Lowry Blvd. -.(876_
Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department
Located in Glendale,Colorado (303)692-3090 of public Health
http:Uwww.cdphe.state.co.us and Environment
Released to: The Windsor Beacon on March 30, 2011 and published April 7, 2011
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
The Colorado Air Pollution Control Division declares the following proposed construction activity warrants public
comment. Therefore, the Air Pollution Control Division of the Colorado Department of Public Health and Environment
hereby gives NOTICE, pursuant to Section 25-7-114.5(5), C.R.S. of the Colorado Air Quality Control Act that the
Division received an application for an air pollution emission permit on the following proposed project and activity:
Kerr-McGee Oil &Gas Onshore LP is proposing to operate a landfarm for disposal of petroleum contaminated soils. The
landfarm is located at the Kerr-McGee Landfarm, SE1/4, SEl/4, Section 13, Township 3 North, Range 66 West, Weld
County, Colorado. For permitting purposes, this source is considered to be a true minor source, Public comment is
required, however, since controlled emissions from this source are greater than 25 tons per year in a non-attainment area.
Copies of the draft permit and preliminary analysis are available for review in the public comment package. The Division
has determined that the proposed source will comply with all applicable regulations and standards of the Colorado Air
Quality Control Commission and has made a preliminary determination of approval of the application.
The Division hereby solicits and requests submission of public comment from any interested person concerning the
aforesaid proposed project and activities to comply with the applicable standards and regulations of the Commission for a
period of thirty (30) days from the date of this publication. Any such comment must be submitted in writing to the
following addressee:
Dennis M. Myers, P.E.
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-BI
Denver, Colorado 80246-1530
Within thirty(30)days following the said thirty(30)-day period for public comment, the Division shall consider
comments and, pursuant to Section 25-7-114.5(7)(a), either grant, deny, or grant with conditions, the emission permits.
Said public comment is solicited to enable consideration of approval of and objections to the proposed construction of the
subject project and activity by affected persons.
A copy of the applications for the emission permits, the preliminary analysis of said applications, and accompanying data
concerning the proposed project and activity are available for inspection at the office of the Clerk and Recorder of Weld
County during regular business hours and at the office of the Air Pollution Control Division, Colorado Department of
Public Health and Environment, 4300 Cherry Creek Drive South, Denver, Colorado, A copy of the draft permit, and the
preliminary analysis are available at: http://www.cdphe.state.co.us/ap/airpublicnotices.html
AIR POLLUTION CONTROL DIVISION - PRELIMINARY ANALYSIS
DATE: March 30, 2011
APPLICANT: Kerr-McGee Oil & Gas PERMIT NUMBER: 06WE0517
REVIEW ENGINEER: Dennis M. Myers, P.E. CONTROL ENGINEER:R.K. Hancock
III, P.E.
PROJECT DESCRIPTION
Kerr-McGee Oil & Gas Onshore LP is proposing to operate a landfarm for disposal of petroleum
contaminated soils. The landfarm is located at the Kerr-McGee Landfarm, SE1/4, SE1/4, Section 13, Township
3 North, Range 66 West, Weld County, Colorado. For permitting purposes, this source is considered to be a true
minor source. Public comment is required, however, since controlled emissions from this source are greater than
25 tons per year in a non-attainment area. This source is subject to the Requirements of Regulation No. 7,
Section V. which states that no person shall dispose of volatile organic compounds by evaporation or spillage
unless Reasonably Available Control Technology (RACT) is utilized. The Division has determined that RACT
for this landfarm is the use of Best Management Practices to maintain a high level of microbes in the soil that
will help degrade the organics in the soil, and minimize evaporation of volatiles. Air pollutant emissions from the
landfarm are as follows:
SUMMARY OF EMISSIONS {tons/year)
AIR CONTROLLED POTENTIAL TO REMARKS
POLLUTANT EMISSIONS EMIT
Source is subject to Regulation No. 7,
VOC 28.3 56.6 Part V.A.
PM 12.7 12.7
PMI0 6.4 6.4
SOURCE IMPACT
Impact modeling analysis is not required for volatile organic compounds.
Impact modeling analysis is not required for particulate emissions, since emissions of particulate matter are
below modeling threshold requirements.
SOURCE CLASSIFICATION
This facility has been determined to be a true minor Source for Operating Permit and Nonattainment Major New
Source Review applicability since the source's potential to emit (PTE) is less than the major source threshold of
100 tons per year.
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•
DRAFTCONSTRUCTION PERMIT
PERMIT NO: 06WE0517
DRAFT INITIAL APPROVAL
DATE ISSUED:
ISSUED TO: Kerr-McGee Oil & Gas Onshore LP
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Petroleum contaminated soil remediation located at the Kerr-McGee Landfarm, SE1/4,
SE1/4, Section 13, Township 3 North, Range 66 West, Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE
FOLLOWING:
Landfarm (land spreading of soil with occasional tilling).
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:
1. Within one hundred and eighty days (180) after commencement of operation, 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. (Information on how to certify compliance
was mailed with the permit.)
2. 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. Opacity shall be measured by EPA Method 9. (Reference: Regulation No. 1, Section
II.A.1.&4.)
3. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis): (Reference: Regulation No. 3, Part B, II.A.4)
Particulate Matter: 12.7 tons per year.
PM10 (Particulate Matter<10 µm): 6.4 tons per year.
Volatile Organic Compounds (VOC): 28.3 tons per year.
Compliance with the VOC emission limit shall be determined by the following formula, and shall
be based on the average concentration of samples taken pursuant to Condition 5 during a given
123/5683/001 ver. 2/00
Kerr-McGee Oil & Gas Onshore LP
Permit Number 06WE0517 DRAFT
Initial Approval DRAFT Colorado Department of ''ublic Health and Environment
page 2 Air Pollution Control Division
calendar year, multiplied by the total quantity of material received during that calendar year.
Volume of PCS (yd3/yr) x (Inlet GRO concentration (mg/kg) + (0.6 x Inlet DRO concentration
(mg/kg)) x Soil Density (kg/yd3) x 2.2 lb/kg x kg/1,000,000 mg x ton/2000 lb = tons VOC per year
(uncontrolled).
A control efficiency of 34.90% shall be assumed for application of Best Management Practices
per Attachment A.
Applicant shall maintain records of volumes of petroleum contaminated soils received,
contaminant concentration measurements, and emission calculations. These records shall be
made available to the Division for inspection upon request.
4. Within one hundred and eighty days (180) after permit issuance, the applicant shall submit to the
Division for approval an operating and maintenance plan for all control equipment and control
practices, and a proposed record keeping format that will outline how the applicant will maintain
compliance on an ongoing basis with the requirements of this permit. The operating and
maintenance plan shall commence at permit issuance. (Reference: Regulation No. 3, Part B,
Section III.G.7.)
5. One load shall be sampled for every day that material is received at the site, in order to determine
total petroleum hydrocarbon (TPH) concentration, diesel range organics (DRO) concentration,
and gasoline range organics (GRO) concentration. Applicant shall maintain a log onsite to
demonstrate that one load is sampled for every day material is received. All sampling conducted
shall be representative of the petroleum contaminated soils received. Applicant shall complete
sampling as follows:
a. Each sample taken shall be a composite sample taken from a minimum of five different
locations in the load received.
b. Sampling and analysis shall be conducted in accordance with ASTM methods and
procedures.
6. A Revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, Section 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
tons per year or more, above the level reported on the last APEN submitted; or
For VOC and nitrogen oxide sources in an ozone non-attainment area emitting less than
100 tons of VOC or nitrogen oxide per year, a change in actual emissions of one ton per
year or more or five percent, whichever is greater, above the level reported on the last
APEN submitted; 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
A change in actual emissions, above the level reported on the last APEN submitted, of 50
pounds of lead
123/5683/001 ver. 2/00
Kerr-McGee Oil & Gas Onshore LP
Permit Number 06WE0517 DRAFT
Initial Approval DRAFT Colorado Department of Public Health and Environment
page 3 Air Pollution Control Division
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.
7. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable).
8. This source is subject to the RACT requirements to Control Emissions of Volatile Organic
Compounds as contained in Regulation No. 7, Part, Subpart V.A., Disposal of Volatile Organic
Compounds. In order to meet this requirement, the permit holder shall follow the Best
Management Practices Plan in Attachment A. .
9. Records of all sampling required by this permit shall be maintained by the applicant and made
available to the Division for inspection if so requested.
10. All previous versions of this permit are canceled upon issuance of this permit.
Dennis M. Myers, P.E. R.K. Hancock III, P.E.
Permit Reviewer Unit Leader
Permit History:
Initial Approval: This Issuance.
123/5683/001 ver. 2/00
Kerr-McGee Oil & Gas Onshore LP
Permit Number 06WE0517 DRAFT
Initial Approval DRAFT Colorado Department of Public Health and Environment
page 4 Air Pollution Control Division
Notes to Permit Holder:
1) The production or raw material processing limits and emission limits contained in this permit are
based on the production/processing rates requested in the permit application. These limits may
be revised upon request of the permittee providing there is no exceedence of any specific
emission control regulation or any ambient air quality standard. A revised air pollution emission
notice (APEN) and application form must be submitted with a request for a permit revision.
2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the
Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the
Common Provisions Regulation. See:
http://www.cd phe.state.co.us/regulations/airregs/100102agcccommonprovisionsreg.pdf.
3) This source is classified as a: Minor Source at a Minor Facility
4) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years. The five year term for the APEN received with this
permit application expires on January 6, 2013. A revised APEN shall be submitted no later than
30 days before the five year term expires
5) The following controlled emissions of non-criteria reportable air pollutants are established based
upon the information submitted with the application. This information is listed to inform the
operator of the Division's analysis of the specific compounds. This information is listed on the
Division's emission inventory system.
C.A.S.# SUBSTANCE EMISSIONS ILB/YRj
1330-20-7 Xylenes (isomers and mixture) 1,520.2
•
123/5683/001 ver. 2/00
Kerr-McGee Oil & Gas Onshore LP
Permit Number 06WE0517 DRAFT
Initial Approval DRAFT Colorado Department of Public Health and Environment
page 5 Air Pollution Control Division
Attachment A
Best Management Practices Plan
RACT (Best Management Practices)
Landfarm shall be watered as needed to maintain moisture content within the range listed below.
Frequency of watering shall be adjusted as necessary per results of weekly moisture testing. If weekly
moisture testing can not be conducted due to weather and/or site conditions, then the testing shall be
conducted on the first day when weather and/or site conditions would allow testing.
Landfarm will be operated using Best Management Practices along with quarterly sampling for all
parameters to determine what parameters need to be adjusted.
Parameter Range
Heterotrophic Plate Counts > 1,000 CFUs per gram.
Soil Moisture Content 12%to 30% by weight
Soil pH Range of 6 to 8
Total Nitrogen > 10% of hydrocarbon mass
Total Phosphorous > 1% of hydrocarbon mass
TPH < 10,000 mg/kg
If any sampling result deviates from the above range, mitigation will be conducted to re-establish ranges
to promote biological activity. Any parameter(s) that sample outside of the above range(s) shall be
retested within 30 days. Mitigation procedures for parameters outside of the above effective ranges are
listed below:
Heterotrophic plate counts—adjusting the other parameters, or addition of petroleum degrading
microbes.
Soil moisture content— increased by increasing the frequency or volume of onsite watering operations.
Decreased through additional site grading and installation of drainage controls. Frequent watering shall
be employed until such time that soil moisture testing demonstrates that proper moisture content, as
described above, is being maintained.
Soil pH —amended through addition of a variety of pH control materials, including lime and elemental
sulfur.
Nutrients (Nitrogen and Phosphorus)— increased through fertilizer addition.
Soil TPH — lowered through more aggressive soil mixing operations, to reduce TPH values to non-toxic
levels.
Other Procedures— Beneficial soil amendments or soil technologies may also be used as a means of
reestablishing the above parameter ranges. These amendments or technologies may include, but are not
limited to, roducts such as BioSolve, Micro-Blaze, or Terramend.
123/5683/001 ver. 2/00
Kerr-McGee Oil & Gas Onshore LP
Permit Number 06WE0517 DRAFT
Initial Approval DRAFT Colorado Department of Public Health and Environment
page 6 Air Pollution Control Division
GENERAL TERMS AND CONDITIONS: (IMPORTANT! READ ITEMS 5,6,7 AND 8)
1. 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.
2. 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.
3. 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 final approval 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.
4. This permit and any required attachments must be retained and made available for inspection upon request
at the location set forth herein. With respect to a portable source that is moved to a new location, a copy of
the Relocation Notice (required by law to be submitted to the APCD whenever a portable source is
relocated) should be attached to this permit. 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.
5. Issuance (initial approval)of an emission permit does not provide"final" authority for this activity or operation
of this source. Final approval 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 approval
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. If the APCD so determines, it will provide written
documentation of such final approval, which does constitute "final" authority to operate. Compliance with
the permit conditions must be demonstrated within 180 days after commencement of operation.
6. THIS PERMIT AUTOMATICALLY EXPIRES IF you (1) do not commence construction or operation within
18 months after either the date of issuance of this permit or the date on which such construction or activity
was scheduled to commence as set forth in the permit, whichever is later; (2) discontinue construction for a
period of 18 months or more; or (3) do not complete construction within a reasonable time of the estimated
completion date. Extensions of the expiration date may be granted by the APCD upon a showing of good
cause by the permittee prior to the expiration date.
7. YOU MUST notify the APCD no later than fifteen days after commencement of the permitted
operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of
Startup (NOS) form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to do so is a violation of AQCC Regulation No.
3, Part B, Section III.G.1., and can result in the revocation of the permit. You must demonstrate compliance
with the permit conditions within 180 days after commencement of operation as stated in condition 5.
8. 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.
9. 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.
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123/5683/001 ver. 2/00
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