The URL can be used to link to this page

Browse Search

Home My WebLink About20210475.tiffCOLORADO Department of Public Health 8 Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 February 8, 2021 Dear Sir or Madam: RECEIVED FEB 16 2021 WELD COUNTY COMMISSIONERS On February 9, 2021, the Air Pollution Control Division will begin a 30 -day public notice period for Musket Corporation - Windsor Loading Facility. 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 beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive 5., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director Pv61:c Rev:eG J 02/a4/2.1 CC: PL(TP), H LOs /TR), P(4311cR/c H/cK), ©G CsM) 2021-0475 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Musket Corporation - Windsor Loading Facility - Weld County Notice Period Begins: February 9, 2021 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: Musket Corporation Facility: Windsor Loading Facility This facility is a condensate and crude oil transloading facility. 2030 Howard Smith Ave. East; Windsor, CO 80550 Weld County The proposed project or activity is as follows: This project reduces throughput and emission limitations for the storage vessel, loadout and flaring points, as well as cancels the large internal floating roof storage vessels, as these units were never built. 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): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 12WE1016 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 https://www.colorado.gov/pacific/cdphe/air-permit-public-notices 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. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Elie Chavez Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public Health B Environment COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 12WE 1016 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County:, Description: Issuance: 4 Musket Corporation Windsor Loading Facility 123/9581 2030 Howard Smith Ave. East; Windsor, CO 80550 Weld County Condensate and Crude Oil .Transloading'Facility '` Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Description Emissions Control North IFR Tank Et South IFR Tank ` 002 Two (2) internal floating roof (IFR) storage tanks to receive crude oil/condensate from tank trucks. Tank capacity is 948,614 gallons each (Manufacturer: Chicago Bridge and Iron, model no. 73-6270U and 74- 2064U). None (internal floating roof) 8 - LACT tanks 003 Eight (8) fixed -roof LACT tanks to receive crude oil/condensate from tank trucks and discharge to internal floating roof tanks (AIRS 002). Tank capacity is 16,075 gallons each (Manufacturer: Tank and Vessel Builders LP, model no. 400 bbl, SN : 2012401-1 to 2012401-8). Open Flare (AIRS 005) Flare 005 John Zink flare, model LHT-3-24-30-X- 1 /10-1 /10-X, serial number 9123952, Rated at a maximum of 39 MMBtu/hr. Flare controls emissions from eight (8) LACT tanks (AIRS 003), and hydrocarbon liquid loadout to railcars (AIRS 008). Emissions associated with this emissions point are for combustion of flare pilot/assist gas N/A Page 1 of 20 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado (propane) and secondary emissions from combustion of waste gas. Railcar Loadout (Primary) 008 Crude oil/condensate loadout from IFR storage tanks (AIRS 002) to railcars. Open Flare (AIRS 005) Fugitive Component Leaks 011 Fugitive emissions from equipment leaks. None Alternate Railcar Loadout (tank truck to rail car) 013 Crude oil/condensate loadout from tank trucks directly to rail cars. Vapor Balance 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 the specific 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) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must 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. A self certification form and guidance on how to self - certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. The operator must 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. (Regulation Number 3, Part B, Section III.E.) 3. The owner or operator must develop an operating and maintenance pam) plan, along with a recordkeeping format, that outlines how the applicant will maintain compliance on an ongoing basis with the requirements of this permit. Compliance with the 0&tM plan must commence at startup. Within one hundred and eighty days (180) after issuance of this permit, the owner or operator must submit the OitM plan to the Division. Failure to submit an acceptable operating and maintenance plan could result in revocation of the permit. (Reference: Regulation No. 3, Part B, I I I. E. ) 4. The operator must 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. Page 2 of 20 COLORADO Air Pollution Control Division Department of Publtc Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Monthly Limits: Facility Equipment ID AIRS Point Pounds per Month Emission Type PM2.5 NOx VOC CO 8 - LACT tanks 003 --- --- 187 --- Point Flare 005 --- 616 538 1,540 Point Railcar Loadout (Primary) 008 6,312 --- Point Alternate Railcar . Loadout (tank truck to rail car) 013 Point Fugitive Component Leaks 011 --- --- 309 --- Fugitive TOTAL Point -- 616 7,037 1,540 - Fugitive --- ---- 309 ---- ---, Note: Monthly limits are based on a 31 -day month. Monthly emission limits in this table that are shared for two AIRS points are for the total combined emissions for both AIRS points. The owner or operator must calculate monthly emissions based on the calendar month. Facility -wide emissions of each individual hazardous air pollutant must not exceed 1,359 pounds per month. Facility -wide emissions of total hazardous air pollutants must not exceed 3,398 pounds per month. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOx VOC CO North IFR Tank Et South IFR Tank 002 --- --- 6.3 --- Point 8 - LACT tanks 003 --- --- 1.1 --- Point Page 3 of 20 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Flare 005 --- 3.6 3.2 9.1 Point , Railcar Loadout (Primary) 008 --- 37.2 Point Alternate Railcar Loadout (tank truck to rail car) 013 Point Fugitive Component Leaks 011 --- --- 1.8 --- Fugitive TOTAL Point --- 3.6 47.8 9.1 --- Fugitive --- ---- 1.8 ---- --- Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Annual emission limits in this table that are shared for two AIRS points are for the total combined emissions for both AIRS points. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. 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, for both criteria and hazardous air pollutants, must 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 must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The owner or operator must calculate the potential -to -emit (PTE) of VOC emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Regulation 3, Part C. II.E.) Page 4 of 20 COLORADO Air Pollution Control Division 1 Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of VOC 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. Operating parameters of the control equipment shall be identified in the operating and maintenance plan. The identified operating parameters will replace the control efficiency requirement in the final approval permit. (Regulation Number 3, Part B, Section I I I. E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled ('1Control Efficiency (%) 8 - LACT tanks 003 Flare VOC, HAPs 95 Flare 005 Flare VOC 95 Railcar Loadout (Primary) 008 Flare VOC, HAPs 95 Alternate Railcar Loadout (tank truck to rail car) 013 Vapor balance VOC, HAPs 98.7 (1)Control efficiency for flare based on 99% capture and 96% destruction of VOCs. PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4. ) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Monthly Limit (31 days) North IFR Tank Et South IFR Tank 002 Combined crude 5,119,048 barrels 434,768 barrels oil/condensate throughput Roof landing events 1 event --- Page 5 of 20 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8nkT tanks 003 Crude oil/condensate throughput 51,190 barrels 8 barrels Flare 005 (t)Crude oil/condensate processed to flare 5,170,238 barrels 439,116 barrels Propane throughput (assist gas) 30,000 gallons 2,548 gallons Railcar Loadout (Primary) 008 Combined crude 5,119,048 barrels 434,768 barrels Alternate Railcar Loadout (tank truck to rail car) 013 oil/condensate throughput ')Crude oil/condensate processed to flare represents the total volume of crude mt/condensate throughput for AIRS 008 plus the crude oil/condensate throughput to AIRS 003. Note: The monthly limits included in this permit were derived from the annual limits basedon a 31 -day month. The owner or operator must monitor monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits must 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 must calculate throughput each month and keep`a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. Point 002: These storage tanks are subject to the New Source Performance Standards requirements of Regulation No. 6, Part A Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Page 6 of 20 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Construction, Reconstruction, of Modification Commenced After July 23, 1984. including but not limited to, the following: a. b. c. d. $60.112b Standard for volatile organic compounds (VOC) $60.113b Testing and Procedures $60.115b Reporting and recordkeeping requirements $60.116b Monitoring of operations 14. Point 002: The following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply. a. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Divi ion, which may.inc[ud d but is not limited` to, monitoring results, opacity observations,' review of operating` and maintenance procedures, and inspection of the source.' (Reference: Regulation No. 6, Part A. General Provisions from 40 CFR 60.11 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere.: (§ 60.12) Writtennotification of construction and initial startup dates shall be submitted to the Division as required under S 60.7. Records of startups, shutdowns, and malfunctions shall be maintained, as required under 5 60.7. 15. Point 002: These storage tanks are subject to requirements to Control Emissions of Volatile Organic Compounds as contained in Regulation No. 7, Part B, Section IV.B.2 "Storage of petroleum liquid in tanks greater than 151,412 liters (40,000 gallons)" including but not limited to: SIV.B.2.a. Et b. Storage of petroleum liquid in fixed roof tanks a. b. SVI.B.2.a.(i)(A) The tank has been equipped with a pontoon -type, or double -deck type, floating roof or an internal floating cover which rests on the surface of the liquid contents and which is equipped with a closure seal or seals to close the space between the edge of the floating roof (or cover) and tank walls; §IV.B.2.a.(ii) No owner or operator of a fixed -roof tank equipped with an internal floating roof or cover shall permit the use of such tank unless: (i) SIV.B.2.a.(ii)(A) The tank is maintained such that there are no visible holes, tears, or other openings in the seal or any seal fabric or materials; and (ii) SIV.B.2.a.(ii)(B) All openings, except stub drains, are equipped with covers, lids, or seals such that: Page 7 of 20 COLORADO Air Pollution Control Division Department of Pubs c Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado SIV.B.2.a.(ii)(B)(1) The cover, lid, or seal is in the closed position at all times except when in actual use; SIV.B.2.a.(ii)(B)(2) Automatic bleeder vents are closed at all times except when the roof is floated off or landed on the roof leg supports; SIV.B.2.a.(ii)(B)(3) and Rim vents, if provided, are set to open when the roof is being floated off the roof leg supports or at the manufacturer's recommended setting. . c. SIV.B.2.a.(iii) The operator of a fixed -roof tank equipped with an internal floating roof shall: (i) SIV.B.2.a.(iii)(A) Perform a routine inspection through the tank roof hatches at least once every six months; SIV.B.2.a.(iii)(A)(1) During the routine inspection, the operator shall measure for detectable vapor loss inside the hatch. Detectable vapor loss means a V;OC concentration exceeding 10,000 ppm, using a portable hydrocarbon! analyzer. (ii) SIV.B.2.a (iii)(B) Perform a complete inspection of the cover and seal whenever the tank is out of service, whenever the routine inspection required in Section IV.B.2.a.(iii)(A) reveals detectable vapor loss, and at least once every ten years, and shall notify the Division in writing before such an inspection. (iii) SIV.B.2.a;(iii)(C)Ensure during inspections that there are no visible holes, tears, or other openings in the seal or any seal fabric or materials; that the cover is floating` uniformly on or above the liquid. surface; that there are no visible defects in the surface of the cover or liquid accumulated on the cover; and that the seal is uniformly in place around the circumference of the cover between the cover and the tank wall. If these items are not met, the owner or operator shall repair the items or empty and remove the storage vessel from service within 45 days. If a failure that is detected during inspections required in this section cannot be repaired within 45 days and if the vessel cannot be emptied within 45 days, a 30 -day extension may be requested from the Division in writing. Such a request must document that alternative storage capacity is unavailable and specify a schedule of actions the owner or operator will take that will assure that the items will be repaired or the vessel will be emptied as soon as possible; (iv) SIV.B.2.a.(iii)(D) Maintain records for at least two years of the results of all inspections. d. SIV.B.2.b. Above ground storage tanks used for the storage of petroleum liquid shall have all external surfaces coated with a material which has a reflectivity for solar radiation of 0.7 or more. Methods A or B of ASTM E424 shall be used to determine reflectivity. Alternatively, any untinted white paint may be used which is specified by the manufacturer for such use. Page 8 of 20 c. COLORADO Air Pollution Control Division Department of Public Health 9 Environment Dedicated to protecting and improving the health and environment of the people of Colorado This provision shall not apply to written symbols or logograms applied to the external surface of the container for purposes of identification provided such symbols do not cover more than 20% of the exposed top and side surface area of the container or more than 18.6 square meters (200 square feet), whichever is less. 16. Point 008 and 013: This source is subject to requirements to Control Emissions of Volatile Organic Compounds as contained in Regulation No. 7, Part B, Section IV. "Storage and Transfer of Petroleum Liquid" including but not limited to: a. SIV.C.4. Transport Vehicles (i) SIV.C.4.a Rail cars shall be loaded only at facilities which allow for the following: SIV.C.4.a(i) A submerged fill pipe which reaches within 15.24 com (6 in) of the bottom of the tank or tank cars equipped for bottom loading. SIV.C.4.a(ii) Vapor collection and/or disposal equipment designated and operated to recover vapors displaced during the loading of the rail car. SIV.C.4.a(iii) A vapor -tight seal around the tank car hatch and the loading equipment. 17. Point 008 and 013: The petroleum transport trucks transferring products at Musket's Windsor site are subject to the requirements contained in Regulation No. 7, Section IV. "Storage and Transfer of Petroleum Liquid" including but not limited to: SIV.C.4.b(i) Dry -break loading and unloading nozzles are used and are compatible with those required at Musket's Windsor facility. SIV.C.4.b(ii) Vapor recovery hoses are connected at all times during unloading or loading of petroleum distillate. §IV.C.4.b(iii) Transport trailers and vehicle tanks are operated and maintained to prevent detectable hydrocarbon vapor loss during loading and delivery at the Musket's Windsor Facility. d. SIV.C.4.b(iv) Compartment dome lids are closed and locked during transfers of petroleum liquid. Such lids may be opened for the purpose of certifying the accuracy of a delivery only prior to and after such delivery. e. SIV.C.4.b(v) Hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading or unloading. 18. This source is located in an ozone non -attainment or attainment -maintenance area and subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.b. Compliance with conditions 5, 8, 9, 13, 15, 16 and 17 were determined to be RACT. OPERATING Et MAINTENANCE REQUIREMENTS 19. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions Page 9 of 20 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado to the OftM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 20. Point 005: The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 9, 40 C.F.R. Part 60, Appendix A, to measure opacity from the flare for one continuous hour. (Regulation Number 1, Section II.A.5) Periodic Testing Requirements 21. Point 005: The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 9, 40 C.F.R. Part 60, Appendix A, on an annual basis to measure opacity from the flare for one continuous hour. (Regulation Number 1, Section II.A.5. ) ADDITIONAL REQUIREMENTS 22. All previous versions of this permit are cancelled upon issuance of this permit. 23. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually, by April 30th whenever a significant increase in -emissions occurs as follows: For any criteriapollutant: 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 (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, `a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. Page 10 of 20 COLORADO Air Pollution Control Division Department of Public Health B Environment Dedicated to protecting and improving the health and environment of the people of Colorado 24. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Facility Equipment ID AIRS Point Equipment Description P Pollutant Emissions - tons per year Threshold Current Permit Limit North IFR Tank Et South IFR Tank 002 Storage Vessels VOC 50 48.1 8 - LACT tanks 003 Storage Vessels Railcar Loadout (Primary) 008 Railcar Loadout Alternate Railcar Loadout (tank truck to rail car) 013 Flare 005 Flare _ __ Insignificant Sources Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. This facility, although considered a petroleum storage and transfer facility, does not have a total storage capacity exceeding 300,000 barrels and is therefore not a listed source for which fugitives must count toward the major stationary source determination. GENERAL TERMS AND CONDITIONS 25. 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 Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. Page 11 of 20 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 26. 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 Number 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. 27. 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. 28. 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. 29. 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 must' constitute a'rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and finial 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. 30. 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. 31. 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: Elie Chavez Permit Engineer Page 12 of 20 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 1 August 3, 2012 Issued to Musket Corporation Issuance 2 (IA Modification #1) May 8, 2013 Add 2 LACT tanks to AIRS 001, Add 2 LACT tanks to AIRS 003, add emergency transloading engine (AIRS 012), add Alternate transfer methods (AIRS 013 and 014), increase throughputs of crude and condensate and adjust emission limits Issuance 3 July 20, 2016 Decrease facility -wide throughput of hydrocarbon liquid., Emissions were conservatively calculated assuming all liquid handled as condensate, as'a result tracking of process limits as crude oil vs. condensate were removed in addition to AIRS points specific to crude oil handling. Increase capacity with addition of two (2) internal floating roof tanks (AIRS 016). Issuance ,4 This Issuance Decrease facility -wide throughput of hydrocarbon liquid to IFR storage tanks (AIRS 002), LACT storage tanks (AIRS 003), primary railcar loadout (AIRS008) and alternate railcar loadout (AIRS' 013). Decrease flare emission limitations (AIRS 005) as a result of hydrocarbon throughput decrease. Remove large IFR tanks (previously AIRS 016) as this point was never constructed. Page 13 of 20 COLORADO Air Pollution Control Division Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must 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 I1.E.1 of the Common Provisions Regulation. See:'https://www.colorado.gov/pacific/cdphe/aqcc-regs 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 # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 002 Benzene 71432 52 52 Toluene 108883 19 19 Ethylbenzene 100414 2 2 Xylenes 1330207 8 8 n -Hexane 110543 224 224 2,2,4- Trimethylpentane 540841 32 32 003 Benzene 71432 182 9 Toluene 108883 68 3 Ethylbenzene 100414 6 0 Xylenes 1330207 28 1 n -Hexane 110543 787 39 2,2,4- Trimethylpentane 540841 112 6 005 Benzene 71432 1 1 Page 14 of 20 011 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Toluene 108883 2 2 n -Hexane 110543 1,025 1,025 Formaldehyde 50000 43 43 008/ 013 Benzene 71432 6,151 308 Toluene 108883 2,291 115 Ethylbenzene 100414 214 11 Xylenes 1330207 953 48 n -Hexane 110543 26,593 1,330 2,2,4- Trimethylpentane 540841 3,789 189 Benzene 71432 15 15 Toluene 108883 6 Ethylbenzene 100414 0 0 Xylenes 1330207 2 2 n -Hexane 110543 65 65 2,2,4- Trimethylpentane 540841 9 9 Note: All non -criteria reportable; pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 002 (North IFR Tankand South IFR Tank) Process 01: Rim Seal, Withdrawl, Deck Fitting and Deck Seam Losses for IFR Tank CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 2.27E-03 2.27E-03 TANKS 4.0.9d / AP -42 Ch. 7.1 71432 Benzene 9.41E-06 9.41E-06 108883 Toluene 3.50E-06 3.50E-06 100414 Ethylbenzene 3.27E-07 3.27E-07 1330207 Xylene 1.46E-06 1.46E-06 110543 n -Hexane 4.07E-05 4.07E-05 540841 2'2'4-5.79E-06 Trimethylpentane 5.79E-06 Note: Emissions conservatively based on liquid properties of gasoline, RVP 15; therefore facility does not need to calculate "condensate" vs "crude oil" separately. A conversion factor of 42 gal/bbl was used. Page 15 of 20 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Process 02: Roof Landing Emission Calculations for IFR Tank w/ Partial Liquid Heel CAS # Pollutant Uncontrolled Emission Factors lb/event Controlled Emission Factors lb/event Source VOC 890.19 890.19 AP -42 Chapter 7.1 71432 Benzene 3.68 3.68 108883 Toluene 1.37 1.37 100414 Ethylbenzene 0.13 0.13 1330207 Xylene 0.57 0.57 110543 n -Hexane 15.93 15.93 540841 2'2'4-2.27 Trimethylpentane 2.27 Note: Emissions conservatively based on liquid properties of gasoline, RVP 15; therefore facility does not need to calculate "condensate" vs "crude oil" separately. A conversion factor of 42 gal/bbl was used. Point 003 (Eight Fixed Roof LACT Storage Tanks) CAS # Pollutant Uncontrolled Emission Factors lb/bbl ' , Controlled Emission Factors lb/bbl ` Source' " VOC 0.8589 0.0429 EPA TANKS 4.0.9d 71432 Benzene 3.55E -03 1.78E-04 108883 Toluene 1.32E-03 6.62E-05 100414 Ethylbenzene 1.24E-04 6.18E-06' 1330207 Xylene 5.51E-04 2.75E-05' 110543 n -Hexane 1.54E-02 7.68E-04 540841 2,2,4- Trimethylpentane 2.19E-03 1.09E-04 Note: Permit knits for this point were established assuming that 1% of that total permitted liquids throughput to the IFR storage tanks (Point 002) is routed through the LACT tanks. Emissions conservatively based on liquid properties of gasoline, RVP 15; therefore facility does not need to calculate "condensate" vs "crude oil" separately. A conversion factor of 42 gal/bbl was used. Working and breathing losses from the LACT tanks are routed to the facility flare (Point 005). The controlled emissions factors for this point are based on a control efficiency of 95% achieved at the facility flare (Point 005). Combustion emissions (i.e., NOx and CO) generated from the combustion of these vapors are accounted for at the facility flare (see Point 005). Point 005 (Facility Flare) CAS # Pollutant Uncontrolled Emission Factors lb/1000 gallons product loaded Controlled Emission Factors lb/1000 gallons product loaded Source NOx 0.0334 0.0334 John Zink Performance Guarantee developed for the Windsor Facility by Page 16 of 20 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/1000 gallons product loaded Controlled Emission Factors lb/1000 gallons product loaded Source John Zink Company per December 8, 2011 specification document CO 0.0835 0.0835 71432 Benzene 5.51E-06 5.51E-06 AP -42 Chapter 1.4 108883 Toluene 8.92E-06 8.92E-06 110543 n -Hexane 4.72E-03 4.72E-03 50000 Formaldehyde 1.97E-04 1.97E-04 Note: The total volume used for "product loaded" is assumed to be any process step where the transfer of crude oil/condensate results in emissions that are controlled by the flare. For the purpose of developing permit limits this was assumed to be the total crude oil/condensate throughput for AIRS point 003 tt AIRS point 008. A conversion factor of 42 galibbl was used. CAS # Pollutant Uncontrolled Emission Factors lb/gallon pilot/assist gas used Controlled Emission Factors lb/gallon pilot/assist gas used Source' VOC 4.220 0.211 Density of Propane at 60°F Note: Emissions of VOC resulting'; from incomplete combustion of the pilot/assist gas (propane) is assumed to be 5% of the total assist gas routed to the flare (based on 95% control). The VOC limit for the flare applies to only the VOC emitted due to incomplete combustion of propane. Emissions of VOC and HAP from the waste streams controlled by the flare are accounted for in each respective AIRS emissions points (i.e. AIRS point 003 and AIRS point 008). A conversion factor of 42 gaUbbl was used. Point 008 (Primary Railcar Loadout - IFR Tanks to Railcars) CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 2.90E-01 1.45E-02 AP -42 Chapter 5.2 71432 Benzene 1.20E-03 6.01E-05 108883 Toluene 4.47E-04 2.24E-05 100414 Ethylbenzene 4.18E-05 2.09E-06 1330207 Xylene 1.86E-04 9.31E-06 110543 n -Hexane 5.19E-03 2.60E-04 540841 2'2'4- Tnmethylpentane 7.40E-04 3.70E-05 Note: The principal method for crude/condensate loadout at this facility is from the IFR storage tanks (Point 002) to the railcars. The emission factors listed in the table above apply only when this primary method of condensate/crude loadout is being performed. Vapors displaced from the rail car loading is routed to the facility flare (Point 005). The Page 17 of 20 COLORADO Air Pollution Control Division Department or Mantic Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 06/08) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 7.88 psia M (vapor molecular weight) = 60 lb/lb-mot T (temperature of liquid loaded) = 511°R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the stable oil by the VOC emission factor (based on a generic HAP concentration in RVP 15 liquid per EPA TANKS). The controlled emissions factors for this point are based on a control efficiency of 95% achieved by the facility flare. A conversion factor of 42 gal/bbl was used. Combustion emissions (i.e., NOx and CO) generated from the combustion of these vapors are accounted for at the facility flare (see Point 005). Point 011 (Fugitive Emissions) Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 1,345 0 3,235 0 Flanges 291 0 1,125 0 Open-ended Lines 0 0 0 0 Pump Seals 0 0 40 0 Valves 189 0 689 0 Other* 42 0 - 63 0 Rail Hatch openings 4 0 0'! _0 VOC Content (wt. fraction) 1 1 1 1 Benzene Content (wt. fraction) 0.004138 0 0.004138 Q Toluene Content (wt. fraction) 0.001541 0 0.001541 0 Ethylbenzene (wt. fraction) 0.000144 0 0.000144 0 Xylenes Content (wt. fraction) 0.000641 0 0.000641 0 n -hexane Content (wt. fraction) 0.017891 0 0.017891 0 2,2,4-Trimethylpentane Content (wt. fraction) 0.002549 0 0.002549 0 *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 4.20E-05 --- 8.00E-06 --- Flanges 4.20E-05 --- 8.00E-06 --- Open-ended Lines 1.20E-04 --- 1.30E-04 --- Page 18 of 20 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Pump Seals 6.50E-05 --- 5.40E-04 --- Valves 1.30E-05 --- 4.30E-05 --- Other 1.20E-04 --- 1.30E-04 --- Hatch Openings 4.41E-03 --- --- --- Source: EPA -453/R95-017 Table 2-3 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 represented in the table above. Point 013 (Alternate Railcar Loadout - Tank Trucks to Railcars) CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 2.90E-01 3.77E-03 AP -42 Chapter 5.2 71432 Benzene 1.20E-03 1.56E-05 108883 Toluene 4.47E-04 5.82E-06 100414 Ethylbenzene 4.18E-05, 5.44E-07 1330207 Xylene 1.86E-04 2.42E-06 110543 n-Hexane 5.19E-03'' 6.75E-05' 540841 2,2,4-7.40E-04 Trimethylpentane _ 9.62E-06 Note: The backup method for crude/condensate loadout at this facility is vapor balanced loading from tanker trucks into the rail cars. The emission factors listed in the table above apply only when this backup method of condensate/crude loadout is being performed. The uncontrolled emissions factors were calculated in the same manner as Point 008 (AP -42 Chapter 5.2, Equation 1). Per AP -42 Chapter 5.2, a vapor balance collection efficiency of 98.7% may be assumed for trucks passing the NSPS - level annual leak test. As such, the controlled emissions factors for this point are based on a control efficiency of 98.7%. A conversion factor of 42 gal/bbl was used. 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 must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC Page 19 of 20 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecir.govi Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix 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 Page 20 of 20 Colorado Air Permit, g Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: For Division Use Only Elie Chavez 438980 12/29/2020 " 12/22/2020 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: What industry segment Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ;Musket Corporation " Weld County 2030 Howard Smith Ave. East; Windsor, CO 80550 Section 02 - Emissions Units In Permit Application Quadrant Section LM Township Range Petroleum bulk stations and terminals (SIC 5171) Leave Blank - For Division Use Only AIRS Point # (Leave blank unless APCD Emissions Source Type has already assigned) Equipment Name North iFfi & South iFR Tank 8-LACT Tanks Flare Ilcar"Loadout (Primary) Fugitive Compone. Leaks Alternate Railcar Loadout Fugitive Dust Emissions Control? ti Permit # (Leave blank unless APCD has already assignedi Section 03 - Description of Project 016 12WE1016 12WE1016 Issuance Self Cert # Required? 4 Action Engineering Remarks 1" PEN/ Permit Gahcel(ation<... Thresholds . Never Itanceilation Constructed Request to reduce throughput and emission limitations for the North and South IFR crude/condensate storage tanks (AIRS 002), LACT tanks (AIRS 003) , process flare (AIRS 005) and railcar loading (AIRS 008, 013), as well as to cancel the large IFR storage tanks (.AIRS 016) as this point was never constructed. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Section 05 - Ambient Air Impact Analysis Requiremeni Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. �z Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs LIL L LJ L L LJ L L LI L Ill! L I Colorado Air Permitting Project Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 El NOx MT CO VOC PM2.5 PM10 TSP HAPs © ❑ ❑ ❑ u u u u u u O Storage Tank(s) Emissions Inventory Section 01 Administrative Information IFaalny AIRS ID ,kaa. y 123 9581 TM 002 County Plant vi'Point Section 02 Equipment Description Details Storage Tank Liquid Detailed Emissions Unit Description Emission Control Device Description 2n7dOd and Condensate Two(2) internalfloatmgroof(IF R) storagetanksto recav'e audeoiUcondensate fromtank truiks Tank'capa'citq �s 448 614 gallons each (Manufacturer Chicago Bridge and Iron model no 73-6270U and 742064U) None Internal FloaLmg Roof �Yanki Requested Overall VOC & HAP Control Effiaenry .6 Limited Process Parameter Pistil Through Section 03 Processing Rate Information for Emissions Estimates Pnmary Emissions Storage Tank(s) Actual Throughput = Requested Permit Limit Throughput= i 5 119 048 Barrels (bbl) per year Requested Monthly Throughput= 434768 Barrels (bbl) per month 0 0 Barrels (bbl) per year ti s Actual Roof Landings = Potential to Emit (PTE) Condensate Throughput= Secondary Emissions Combustion Device(s) Heat content of waste gas = Volume of waste gas emitted per BBL of liquids produced = i';!'"<,‘ '45119,048 Barrels (bbl) per year t _ Actual heat content of waste gas muted to combustion device = Requested heat content of waste gas routed to combustion device = Btu/scf Potential to Emit (PTE) heat content of waste gas routed to combustion device = Control Device Pilot Fuel Use Rate Pilot Fuel Gas Heating Value 00 MMBTU per year 00 MMBTU per year 00 MMBTU per year }lscfh Btu/scf CO MMscf/yr O0 MMBTU/yr Section 04 Emissions Factors &_Methodologies Will this storage tank emit flash emissions, r w.. .y s. ..1 w., 'D ..�t-".'y._ "cc- r s_� � Process Ol Rim Seal Withdraw' Deck Fitting and Deck Seam lnssei forlFR Tank�� Parameters Value Units Source Rim Seal Loss s 27702' yI lb/year Tanks 409d Withdraw' Loss - 67582 � lb/year Tanks 409d Deck Fitting Loss ! / '365209_/,, lb/year Tanks 409d Deck Seam Loss 3155134 lb/year Tanks 409d Emissions a ' " " ,. 6156 dr 4', lb/year Tanks 4 0 9d total for 1 tank assuming 100.E throughput (to generate most conservative withdraw' loss) Total Emissions r 4, ^" 3 ' 11636 72 4 ' ' lb/year Tanks 409d total for 1tank assuming 100A throughput (to generate most conservative withdraw' loss) plus rim deck fitting and seam losses from second tank �Proce O2 Rooflandmg Emtssron Cap ula[Tons farlMemal Floating Roof Partial Llgmd Heel Tankr Parameters Operator Value Division Check Units Soume Ideal Gas Constant ( R ) 10 731„ .1" r , 10 731 f (psr•ft')/pb mol•R) Ideal Gas Law Constant Atmospheric Pressure (P) ''---t;12 12 12 12 ' psia TANKS 4 0 9d for Denver CO Ni Reid Vapor Pressure (RVP) r �;,y 15 15 / ` psis TANKS 409d for Gasoline RVP 15 Stock Vapor Molecular weight (M ) ?. 60 460�`� Ib/Ibmol TANKS 409d for Gasoline RVP 15 Saturation Factor (5) ( ) "05 � n 05 f� •".. 'k' k''.' �„�I;::.ax;, Equation 3 18 assuming Partial Liquid Heel g q Height of vapor space under floating roof (ft) 4' " 49 , ' i. ,,49 ft Operator estimated value assumed small heel for conservatism Tank Diameter (D) ' 60, '14, F 7,60 ' ft Operator provided value Days Standing Idle (rid) ,. 1 17' " j. , qty Operator provided value Average Daily Total Insolation Factor (I) -=i i."), a NR '- r 1491-° t Btu/ft' day Table 7 17 Denver CO Surface Solar Absorptance(a) NR ' _ 054 ti. '::II II=). §,.,t Table 716 Gray Good Light Average Temperature of vapor and liquid below floating roof (T) ' 519 67* ' 519 67. R Operator provided value per Equation 3 6 True Vapor Pressure (P) 816, .� F 8 16 psia Figure 71 14b Equation for True Vapor Pressure of Refined Petroleum Stocks(using T 5=3 RVP=15) Average Daily Maximum Ambient Temperature (T.)� , NR' ">,-s 379 R Table Denver Average Daily Minimum Ambient Temperature (T,w) µ c` - - ., NR 635 R Table 717 Denver CO Average Daily Ambient Temperature (Top) 1 NR 510 4 R AP 42 Chapter 7 Equation 130 3 of 23 K \PA\2012\12WE1016 CP4 Storage Tank(s) Emissions Inventory Average Daily Ambient Temperature Range (ATA) NR 'R AP -42 Chapter 7 Equation 1-11 Average Daily Vapor Temperature Range (ATv) 32.21 °R Equation 1-8; Operator chose largest difference from all Denver, CO values Liquid Bulk Temperature (TO NR °R AP -42 Chapter 7 Equation 1-31 Average Daily Liquid Surface Temperature (T A) 512.03 'R AP -42 Chapter 7 Equation 1-29 True Vapor Pressure at T (Pv,) 7.08 psia Figure 7.1-14b Equation for True Vapor Pressure of Refined Petroleum Stocks (using LA, 5=3, RVP=15) Daily Maximum Liquid Surface Temperature (TLx) 544.06 o R Figure 7.1-17 Equation for Average Caily Minimum and Maximum Surface Temperature Vapor Pressure at Tex (Pvx) 12.5 psia Figure 7.1-14b Equation for True Vapor Pressure of Refined Petroleum Stocks (using Tex, S=3, RVP=15) Daily Minimum Liquid Surfact Temperature (TAN) 528.1 °R Figure 7.1-17 Equation for Average Caily Minimum and Maximum Surface Temperature Vapor Pressure at TAN (PVN) 9.5 psia Figure 7.1-14b Equation for True Vapor Pressure of Refined Petroleum Stocks (using TN, 5=3, RVP=15) Daily Vapor Pressure Range (AN 3 psia AP -42 Chapter 7 Equation 1-9 Volume of Vapor Space (V,,) 4...iO..,-: •i _ .�;;.;.:.::f; ft3 AP -42 Chapter 7 Equation 1-3 Vapor Space Expansion Factor (KG) VN `�� \ ` ``' �' \1 AP 42 Chapter 7 Equation 1-5 Standing Idle Saturation Factor (Ks) _ - 7.5 :.t07 _ _ _ _ _ - .,\ ..\ �:•\:-:-•••,.;:.--:•:;•••;:,.. =� �.�42 AP Chapter 7 Equation 1-21 Event Standing Losses (1_,,L ) 282.011° ' " ° ' ''c="455 lb/roof landing _ event AP -42 Chapter 7 Equation 3-7 Event Filling Losses (L„) 608.1798604 608.1798604 lb/roof landing event AP -42 Chapter 7 Equation 3-18 Total Landing Loss Emissions (LT, = LFi+Lsi) 890.1918054 553.0085565 lb/roof landing event AP -42 Chapter 7 Equation 3-1 Total Number of Roof Landing events 1 Vapor Composition Pollutant wt% Source VOC Crude Oil Analysis (no change since previous issuance) Benzene Toluene Ethylbenzene Xylenes n -Hexane 2,2,4-TMP Process 01: Rim Seal, Withdraw), Deck Fitting and Deck Seam Losses for IFR Tank Emission Factors Working/Breathing Losses Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Crude Oil Throughput) (Crude Oil Throughput) VOC 2.27E-03 Site Specific EPA TANKS E.F. Working and Breath Benzene 9.41E-06 Site Specific EPA TANKS E.F. Working and Breath Toluene 3.50E-06 Site Specific EPA TANKS E.F. Working and Breath Ethylbenzene . 3.27E-07 Site Specific EPA TANKS E.F. Working and Breath Xylene 1.46E-06 Site Specific EPA TANKS E,F. Working and Breath n -Hexane 4.07E-05 Site Specific EPA TANKS E.F. Working and Breath 224 TMP 5.79E-06 Site Specific EPA TANKS E.F. Working and Breath Process 02: Roof Landing Emission Calculations for internal Floating Roof Partial Liquid Heel Tank Emission Factors Roof Land-ng Losses Uncontrolled Controlled Factor Source Pollutant lb/event lb/event Emission Event Event V O C 890.19 Benzene 3.68 Toluene 1.37 Ethylbenzene 0.13 Xylene 0.57 n -Hexane 15.93 224 TMP 2.27 Pollutant Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) Emission Factor Source (waste heat combusted) (Crude Oil Throughput) PM10 C PM2.5 0.0000 SOx NOx CO Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source (Pilot Gas Heat Combusted) (Pilot Gas Throughput) PM10 PM2.5 SOx NOx VOC CO AP -42 Chapter 7 AP -42 Chapter 7 AP -42 Chapter 7 AP -42 Chapter 7 AP -42 Chapter 7 AP -42 Chapter 7 AP -42 Chapter 7 4 of 23 K:\PA\2C12\12WE1016.CP4 Storage Tank(s) LftliSSIOFIS (lore tort' Section 05 - Emissions Inventory Criteria Pollutants PM10 PM2.5 SOx Max VOC CO Hazardous Air Pollutants Ben Toluene Ethylbenzene Xylene n -Hexane 224 TMP Process Or. RimSeal: Withdraw! Potential to Emit Uncontrolled (tons/year) Potential to Emit Uncontrolled (ibs/year) 7 Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Actual Emissions Uncontrolled Controlled (Ibs/year) fibs/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Monthly Limits Controlled (Ibs/month) PPo€Es's,OZi'.RoibBitriiliiikEriissioirtafculatiohsfor InterndIFloatinRROOf Partial Utah! Neel Tank `t Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 SOx NOx VO0 CO .7 G.0 DO 0.0 0.0 G0 u 0 _... 0.4 0.0 0.0 OD 0.0 0.0 0.4 CO 0.0 0.0 0.0 0.0 J9 00 0.0 0.0 0.4 0.0 0.4 0.4 a.., 0.0 E0.0 0.0 0,0 0.0 0.0 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Requested Permit Limits Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (Ibs/Year) (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 IMP 3.7 0.0 0.0 GO 0.0 0.0 0.0 3.7 1.4 0-1 O.6 155,3 2.3 3.7 1,4 0,1 0.5 159 2.3 15.4 2.3 ,Total Emrsstoits` Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 50x NOx VOC CO 0 0.0 0.0 0.0 0.0 n_0 0.O 00z,a 0<0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0. 0.0 0.0 0.0 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) )Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 51.8 0.0 0.0 0.0 30 0.0 52 is ,3 1.3 0,0 0.0 0.0 122 s 0.0 0.G 224 32 32 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires permit Regulation 7, Part D,Section LC, D; E, F Storage Tank is mat subject to Regulation 7, Parr .9, Seotiob Regulation 7, Part D,Section I.G, C Storage Tank is.. object to RegulatMn 7 Part C Section `s._ Regulation 7, Part D,Section ILB, C.1, C.3 Storajge Tank is not subject to Regulation r, Psim p, se,tio,,.. Regulation 7, Part D,Section II,C.2 Storage .rank is not subject to Regulatior Paw, G ....? .2 Regulation 7, Part D,Section II.C.4.a.)i) Storage. Tank is mat sultiort to Regulation art 1 Seetion 04.444) Regulation 7, Part 0,Section ll.C.4.a.(ii) Storage. Tank id not subject to Regulation 7„ Di,ir,. Section ii._. _ - , Regulation 6, Part A, NSPS Subpart Kti s'torag tank is subject to € SP_ 6s, including leut notlimited a. tim following'provisions Regulation 6, Part A, NSPS Subpart 0000 Storage Tanis is not subject to `ISPS 0000 NSPS Subpart 0000a Storage Tank is not subleut to NSPS 0000a Regulation B, Part E, MALT Subpart HH Storage Tank is not subject to*xiAO; HIT (See regulatory applicability worksheet for detailed analysis) Pilot/Combustion emissions included here 'Roof Landing emissions only Section 07 - Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks, does the company use the state default emissions factors to - estimate emissions? If yes, are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy? Bye's, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company use a site specific emissions factor to estimate emissions? Byes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted (for produced water tanks, a pressurtze liquid sample must he analyzed using flash liberation analysis)? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the fadlity has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-D3, Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 N/A- no flash emissions 5 of 23 KVA\2012\12WE1016.CP4 Storage Tank(s) Emissions Inventory Section 08 -Technical Analysis Notes 1. To calculate rim seal, withdraw', deck fitting and seam loses, the operator elected to consevatively assume that 100% of the requested throughput be routed through one storage vessel, as opposed to splitting the flow evenly between the two storage vessels.: This results in a conservative estimation of withdraw' losses Because the two storage vessels are structurally identical, the rim seal;: deck fitting and seam losses are equivalent for both storage vessels. To summarize, total emissions for this point are based on withdraw' losses from one storage vessel, (assuming 100% throughput to that vessel) plus rim seal, deck fitting and seam losses. from both storage vessels and one annual roof landing event. 2. To calculate roof landing losses, the operator elected to use the most conservative temperatures and temperature differentials set forth in AP -42. Chapter l's Table 7.1-7 for Meteorlogfcaldata for Denver, CO ' Assuming a tank color of light gray in "good" condition (as specified in the EPA TANKS 4.0.9d run attached to the 12/29/2020 application) and average temperature values in accordance with AP -42 Chapter 7, standing losses during periods of a landed roof were calculated by the Division (for comparison) to be 245 Ibs/landing event. Secause the conservative temperatures used in the operator's calculation result in a >:conservative emissions estimate of 2821hs/landing event, this method was accepted for use in this permitting action. 1 3. Monthly emission limits for AIRS 002 were not included in the permit due to complexities with accounting for roof landing events (the operator cannot reasonably foresee when the landing events will occur). -. A monthly limit will be included however for the process limit (434,768 bbl/month( Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only) AIRS Point p 002 Process ft SCC Code 01/02 U4-003-07. Infernal Floating"R Tank: Working and Breathing Losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 _ lb/1,000 gallons Crude Oil throughput PM2.5 G lb/1,000 gallons Crude Oil throughput 50x [ 0-0 4 lb/1,000 gallons Crude Oil throughput NOx 000 0 lb/1,000 gallons Crude Oil throughput VOC 4.83E-02 0 lb/1,000 gallons Crude Oil throughput CO 0.03 0 lb/1,000 gallons Crude Oil throughput Benzene 240G-0, 0 lb/1,000 gallons Crude Oil throughput Toluene 8._0005 0 lb/1,000 gallons Crude Oil throughput Ethylbenzene 0 lb/1,000 gallons Crude Oil throughput Xylene ...r.,..._ 0 16/1,000 gallons Crude Oil throughput n -Hexane _._,_-.,.. 0 lb/1,000 gallons Crude Oil throughput 224 TMP 1.499:6x7 0 lb/1,000 gallons Crude Oil throughput 6 of 23 KAPA\2012\12WE1016.CP4 Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and 0-APEN and Permit Requirements ATTAINMENT -This source Is located In the ozone non -attainment area. Since this source does not emit CO, all questions in this section are listed as N/A 1. Are uncontrolled actual emissions from any criteria. pollutants from this Individual source greater than 2TPY(Regulation 3, Part A,Section ll.D.l.a)7 T. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/20[12 (See PS Memo O3-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility unoMrolled VOC emissions greater than 5 TPY, NOx greater than to TPY or CO emissions greaterthan to TPY (Regulation 3, Part 0, Section 11.0.3)? 'NOS . aoglr lrtlarvu,stian NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual sourre greater than )TPY(Regulation 3, Part A, Section ll.0.1.a)7 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total faciltyy uncontrolled VOC emissions from the greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than S TPY (Regulation 3, Part B, Section ll.D.2)? Saurae r,,,ffO n a perofft Colorado Regulation], Section IV 1. Does this storage tank store "petroleum liquid" as defined by Regulation 7 Part B Section lV.A.2.g? 2. Does this storage tank meet any of the exemptions listed In Regulation 7 Part B Section lV.B.1? 3. Does the tank have a storage capacity greater than 40,000 gallons(952 barrels)? 4. Does the storage tank have a fixed roof? 5. Is the fixed roof tank used forthe storage of petroleum liquids which have a true vapor pressure between 0.65 psia and 11.0 psia at 20°C (6MF)? 6. Is the fled roof tank equipped with an internal floating roof? WOW wal *AM Stornget tuff<is xdr{ect fa Regulation !, Past E, Asmtign t`l.E.,7.rnY.b filorav tank' lo.eua{ecP, tp IteguIffthan '/, vrart 0,1rsNon 11r.[rz.t,u.d) Stcuusge ter,I., is snhiect-f,i,,,,fian /, Pars B. Sectisets 7. Is thetank equipped with an external floating roof AND Is larger than 953bb1 AND stores petroleum liquid AND is located In ozone nonattainment area? 8. Ooes the tank meet any of the exemptions of Section M.B.2.c.(i)(B)(1)? 9. Does the tank meet any of the exemptions of Section lV.B.2.c.(i)(B)(2)? 10. Does the tank store petroleum Ilquds with true vapor pressure (as stored) above 1.3 psia? fir orag,r Imnk rs root subfea to Kegrdution 3, Part S, be<.o.ion IV.S3.3c 11. Does the storage tank have a storage capacity less than 40,000 gallons (952 barrels)? 12. Does the storage tank stare liquids with a true vapor pressure between 1.5 psla and 11.0 psia at 20°C? 13. Is the stnragetank at a facility that receives and stores petroleum addressed by Regulation 7 Sections IV.C.2 or IV.C.37 Df WON Ifft,,,,f8 lash is not...4, t to ReY.ulution /, Purt fa, Sact,ov; Sternagv Wt& is rtllafact xu Becxulatfon 5, Purl tJ, hoct,un if! Colorado Regulation 7, Part D, Section I.C-F 1. Isthis storage tank located In the 8 -hr ozone control area or any ozone on -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation'', natural gas compressor station or natural gas drip station? 3. Is thisstorage tank located upstream of a natural gas processing plant? IfItnx onk fy nw't i5oNret ter dt.Igulnti5rri'7. Part Lf, Stwtioni Section I.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section I.C.2—Emission Estimation Procedures Section I.D—Emissions Control Requirements Section I.E—Monitoring Section I.F—Recordkeeping and Reporting Colorado Regulation]. Part D. Section I.G 1. Is this storage tank located In the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does thisstorage tank exhibit "Flash"(e.g. storing non-stabillzed liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tans per year VOC? IfAcmgu lank is not mr6Jert ter ftagutstion /, Part fi, swmoni rd Section %11.6.2- Emissions Control Requirements Section XII,C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section NII.C.2—Emission Estimation Procedures Colorado Regulation 7. Part D. Section II 1. Is this tank located at a transmission/storagefacliRy? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation, well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this condensate storagetanka fixed roof storage tank? 4. Are uncontrolled actual emissions" of this storage tank equal to or greater than 2 tons per year VOC? ISt a,Iff,f 1'xmi; ru nur sufrfan.t to Rogtilatiorr'7, Park kt, Set tfovf If Section 11.B —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section II.DS- Emissions Control and Monitoring Provisions Section II.C.3- Recordkeeping Requirements Does the condensate sorage tank contain only'stabllized' liquids? >¢urvrga Tank is nwt subizzi to idngutatwn 1, Purl (J, srrc tk,n Section II.C.2- Capture and Monitodngfor Storage Tanks fitted with Air Pollutlon Control Equipment Is the controlled storage tank located ai a well production facility, natural gascompressor station, or natural gas processing plant constructed on or after May 3, 2020 or located at afadlity that was modified on or after May 1, 2020, 6. such that an additional controlled storage vessel is constructed to receive an anticipated increase In throughput of hydrocarbon liquids or produced water (Regulation 7, part 0, section 11C4.a.(I)? Sfurtuw i ank Is rrut sukrieit.t to Rrrguletfon 7, Put D, bat twit Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after January 1, 2021 or located at a facility that was modified on or after January 7. 1, 2021, such that an additional controlled storage vessel is constructed to receive an anticipated Increase Inthroughput of hydrocarbon liquids or produced water (Regulation], Part D, Section II.C.4.a.(ii)7 �8turgge Tank 1s trot subjat to Regulation 7, Part O, Sat uon tE.C.4.a(lih b f W Source Requires an APEN. Go to the next question Go to next question Source Requires a permit Go to the next question Goto the next question Source Is subjectto Regulation 7, Part B, Section IV.B.2.6; Go to the next question Source is subject to Regulation 7, Part B, Section IV.B.2.a.; Go tothe next question Source Is subject to Regulation 7, Part B, Section IV.B.2.a.(1); Go tothe next question Source is subject to Regulation 7, Part B, Section IV.B.2.a.hh-(III); Go to the next question Storage Tank is not subject to Regulation 7, Part B, Section IV.B.2.c. Source is not subject to Regulation 7, Part B, Section IV.B.3. Go to the next question Storage Tank is not subject to Regulation 7, Part 0, Section I Go to the next question Storage Tank is not subject to Regulation 7, Part D, Section I.G Go to next question Storage Tank is not subject. Regulation 7, Part D, Section 11 NAii aNStorage Tanks nmsubject to Regulation 7, Part D, Section II.C.2 forage Tank is nm subject to Regulation 7, Part D, Section II.C.4 forage Tank is not subject to Regulation 7, Part D, Section II.CA 40 CFR, Part 60, Subpart Kb. Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (a) (-472 BBLsl7 2. Does the storage. vessel meet thefallowing exemption in 6D.1116(d)(4)7 a. Ooesthe vessel has a design capacity less than or equal to 1,589.874 m 1-10,000 BBLI used far petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.113b7 3. Was this condensate. storage tank constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) afterJuly 23,19847 4. Doesthetank meet the definition of"storage vessel' in 60.11367 5. Does the storage vessel store a"volatile organic liquid(VOL)'S as defined in 6o.111b7 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the. storage vessel. pre re vessel designed to operate in excess of 204.9 kPa r-29.7 psi] and without emissions to the atmosphere(60.110b(d)12)17; or b. The design capacity is greater than or equal to 1510I-950 BBL] and stores a liquid with a maximumtrue vapor pressure' less than 3.5 kPa (60.1106(b))7; or c. The design capacity is greater than or equal to 75 M' 1-472 BBLI. but less than 151 m' 1-950 BBL] and stores a liquid with a maximum true vapor pressure` lessthan 15.0 kPa(60.1106(61)? timre,ge tarok i5,,,,hlq.ct to NSPS NI , inth Ling but nest R,,, ted theio towing psouNioru Subpart A, General Provisions §6o.112b - Emissions Control Standards for VOC §60.113b -Testing and Procedures 460.115b -Reporting and Recordkeeping Requirements §60.3166- Monitoring of Operations 40 CFA, Part fio, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production. Transmission and Distdbution 1. Was this condensate storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after August 23, 2011 and prior to September 18, 20157 2. Does this condensate storage vessel meet the definition of "Storage vessel"' per 60.54307 3. Isthis condensate storage vessel located at afacility in the onshore oil and natural gas production segment, natural gas processing segment ornatural gas transmission and storage segment of the industry? 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6tons per year? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60Subpart Kb or 40 CFR Part 63 Subpart HH7 51Ir MPS 00(.10 SubpartA, General Provisions per §60.5425 Table 3 §60.5395- Emissions Control Standards for VOC 460.5413 -Testing and Procedures 560.5395(g)- Notification, Reporting and Recordkeeping Requirements §60.5416(4)- Cover and Closed Vent System Monitoring Requirements 460.5417 -Control Device Monitoring Requirements (Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) evr if potential VOC emissions drop below 6 tons pervert) 40 CFR. Part 60, Subpart 0000a, Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced After September 38, 2015 1. Was this condensate Sorage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 20157 2. Ores this condensate storage vessel meet the definition of "storage vessel"' per 60.5430a? 3. Is this condensate storage vessel located at a facility in the crude ail and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 4. Are potential VOCemissions' from the individual storage vessel greater than or equal to 6tons per year? 5. Is the storage vessel subject to and controlled in accordancewith requirements for storage vessels in 40 CFR Part 60Subpart Kb or 40 CFR Part 63 Subpart HH7 (§ 60.5395a1 NA No A NA 5[arnge Tank is mA aubpa to N6P60.00. 40 CFR, Part 63, Subpart MAR HH, OII and Gas Production Facilities 1. Is the tank located at a facility that Is major': for HAPs7 2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. Afacility that processes, upgrades or stores hydrocarbon liquids' (63,760(a)(2)1; OR b. A facility that processes, upgrades or stores natural gas prior tothe point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.76o(a)(3))7 3. Does thetank meet the definition of"storage vessel"' in 63.7617 4. Does thetank meet the definition of"storage vessel with the potential for flash emisslons. per 63.7617 5. Isthe tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 00007 �se,ao-nge Ittnk N notem4lart to MAI`t ltH Subpart A, General provisions per §63.764 (a) Table 2 463.766- Emissions Control Standards 463.773 -Monitoring §63.774-Recordkeeping §63.775 -Reporting PAR Review RACT review is required If Regulation 7 does not apply AND if thetank is in the non -attainment area. If the tank meets both criteria, then review RAR requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis if contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change orsubstitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict betweenthe language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such es'recommend,""may," "should, and 'can,' intended to describe APCD interpretations and recommendations. Mandatory terminologysuch as'must" and "required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Go to the next question Go to the next question Go to the next question Go to the next question Go to the next question Source IS subject to NSPS Kb Go lathe next question Go to the next question Storage Tank is not subject NSPS 0000. Storage Tank Is not subject NSPS 0000 -This tank was constructerfprior to the applicability date. N11947 Storage Tank Is not subject MARHH-There are no MAR HH requirements for tanks at area sources MUM NA `ti 1x351 En -05s Section 01 -Administrative Information 'Facility AIRS ID: County 9581 Plant 003 , Point Section 02- Equipment Description Details Storage Tank Liquid EYgfr (8 fixed-idof LACE tanks to ieceive crude oil/condensate from tank trucks and discharge to internal floating; roof. tanks (AIRS " 002), Tank capacity is 16,075 gallons ea ,F ``fNa 4fa t rer. Tank and Vessel Bu iders LP; model no. 400 bbl, SN: Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Operri lore. Section 03- Processine Rate Information for Emissions Estimates Primary Emissions -Storage Tank(s) Actual Throughput = Requested Permit Limit Throughput= 51,140 Barrels (bbl) per year Requested Monthly Throughput= 4348 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput= Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Barrels (bbl) per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Control Device 00 MMBTU per year C.0 MMBTU per year 0 0 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Standing & Withdrawal Losses Total Number of Vessels lb/year Vapor Composition Pollutant wt% Source VOC Benzene 0.413-9✓)§ Toluene _ 1541,`'() / w his 6 Ethylbenzene 0.0144Xylenes � rSrhuEt 'v ... -040541 t€�rn ssuanGe n -Hexane 1.9951 2,2,4-TMP 0.254.3 7ANKS4 D 9rl assuming gasoline RVP SS:4 ' Emission Factors Crude Oil Tank Pollutant Uncontrolled Controlled (M/bbl) pb/bbq (Crude Oil Throughput) (Crude Oil Throughput) Emission Factor Source VOC Benzene Toluene Ethylbenzene xylene n -Hexane 224 TMP Pollutant Control Device 0 5.51E-04 1.54E-02..'.... . 62.19E-03'. -: 0.0429 .78E-04 1.58E-03 1.05E-04 Uncontrolled (Ib/MMBtu) (waste heat combusted) Uncontrolled (Ib/bbl) (Crude Oil Throughput) Emission Factor Source PM10 PM2.5 SOx NOx CO Pilot Light Emissions Pollutant 0.0000 Uncontrolled (Ib/MMBtu) (Ib/MMscf) Uncontrolled (Pilot Gas Heat I (Pilot Gas Combusted) Throughput) Emission Factor Source 9 of 23 I(:\PA\2012\12WE1016.CP4 age Tank(s) Emissions Inventory PM10 "ss`, 0,0-0G-0 . .. x¢ PM2.5 0.0000 SOx 0 C0 0 NOx 0.0000 VOC D.0002 CO 0.0000 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tans/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (H./month) PM10 PM2.5 SOx NOx VOC Co 0.0 0.0 ._ _... 0.0 OF 0.0 0.0 0.0 0.0 ir.0 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0._ 22,0 0.0 0.0 22.0 i._ 156.7 0.0 0.-0 0.0 0.0 .» 0.0 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ihs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ihs/year) (Ihs/year) Benzene Toluene Ethylhenzene Xylene n -Hexane 224 TMP 182.0 0.0 0.0 182 _ 67.8 0.0 0.0 68 s b.3 0.0 0.3 _ 0 28.2 MO 0:0 28 1 785.7 0.0 0.0 787 19 112.1 0.0. 0.0 112 6 10 of 23 KAPA\2012\12W E1016.CP4 Storage Tank(s) EmISSIOP lnvenfory i Section 06 Regulatory Summary Analysis Regulation 3 Parts A, B Sour a regress a perm t Regulation 7 Part D Section IC D E F Storage Tank is not subjec, to Regulation 7 Part D Seeior I Regulation 7 Part D Section I G C storage Tank is not subject to Regulation 7 Part D Section I G Regulation 7 Part D Section II B C 1 C 3 Storage Tank is not ubiect to Regulation 7 Part D Section II Regulation 7 Part D Section II C 2 Storage Tank s wt subject to Regina ion 7 Par D Section II C 2 Regulation 7 Part D Section II C 4 a (I) 5 orage Tank is -at_subject to Re3elatior 7 Parr D Section II C 4e(0 Regulation 7 Part D Section II C 4 a (n) Storage Tank is not subject to Pegula ion 7 Par D Section II C 4 alai b t Regulation 6 Part A NSPS Subpart Kb Storage Tank is lot subject to NSPS Kb Regulation Part NSPS Subpart 0000 / Storage Tank is not subjectto NSPS 0000 II NSPS Subpart 0000a i storage -rank is no subject o t oPS 0000a Regulation 8 Part E MAR Subpart HH storage -ar r is not _ub e•-• to MACT Ho (See regulatory applicability worksheet for detailed analysis) Section 07 Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks does the company use the state default emissions factors to""-� estimate emissions, O If yes are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy7 If yes the permit will contain an Initial Compliance testing requirement to develop a site specific emissions factor based on guidelines an PS Memo 14 03 Dues the company use a site specfic emissions factor to estimate emissions, If yes and if there are flash emissions are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted (for produced water tanks a pressurize liquid sample must be analyzed using flash liberation analysis), This sample should be considered representatrre which generally means site specific and collected within one year of the application received date However tithe facility has not been modified (e g no new wells brought on line) then it may be appropriate to use an older site specific sample If no the permit will contain an Initial Compliance testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14 03 Does the company request a control device efficiency greater than 954 for a flare or combustion device, If yes the permit will contain radial and periodic compliance testing in accordance with PS Memo 20 02 N/A No flash emissions Section 08 Technical Analysis Notes -',/7'-..->-..-�.n"StZTt=— "f ''a a.0.3.,.4-.eY3'..---,77-.. t ..-�-�— 3 -v+ -r--' -"7",^'t : µ k�-"" 1 tACT tanks are usefd tostoremcommg crude during upset conditions je g'poweroutagsifthecrude is suspected to be of loW quality The crude is then transferred m[o the lFR tanks (AIRS 002) For i permitting purposesirt is eisurne that lY of the total crude thatge sts[ rbu'ted tothe lFR tanks �KR5002)has been routed through the LAC, tanks ,v z`'s -rr' s ,,.y 'X <', i -- i Z IdO4 and CR emnsaons fromat4as�e gas combuston accounted for at pro ess fla� (AIRS 005)'"�y,..� � r� gems � A'�ti, .r ; ? ;,�'„ �'' s'1 ,. �;,y :r� `,� r, ` , s , � -j i 3 Thesestorag"e tanks wea determmed`not to be subject to Colored ion,o 7 Part B Sefton IV B 3 b for sforage of petroleum liquids m tanks <40 000 gallons because these storage vessels to not', , y store gasohrie`and by definition ln5ectlon`IVA2jr a vapor collection system is applicable togasoLne displacement only' Note however thatthe`ie storage vessels arerequired tebe cantrilled wrtAthe�facibry k fl:re (t)IRS 005)whmh was`previously d� rmieeed to a RACE fm�this rant -ter y +, i i , s` r p —�,� `sue» ��' k' r,.f a - —" .. e 6 p_� ; _a Section 09 SCC Coding and Emissions Factors (For Inventory Use Only) AIRS Point it 007 Process R SCC Cade Uncontrolled Emissions Pollutant Factor Control Units 01 ;gif-0003,02 Fixed Raooff7`an)C feldrking ✓# Breathingi:oasei, tet., r-. a ^'t�?'jy PM10 0 00 0 Ib/1000 gallons Crude Oil throughput PM2 5 0 00 0 Ib/1000 gallans Crude Oil throughput SOx 000 0 Ib/1000 gallons Crude Oil throughput NOx 0 09 0 113/1 000 gallons Crude Oil throughput VOC 1045 95 Ili/1000 gallons Crude Oil throughput CO 0 00 0 Ib/1000 gallons Crude Oil throughput Benzene 0 08 95 16/1000 gallons Crude Oil throughput Toluene 0 0, 95 Ib/1000 gallons Crude Oil throughput Ethylbenzene 0 00 95 Ib/1000 gallons Crude Oil throughput Xylene 0 01 95 Ib/1000 gallons Crude Oil throughput n Hexane 0 37 95 Ib/1000 gallons Crude Oil throughput 224 TMP 0 05 95 Ib/1000 gallons Crude Oil throughput 11 of 23 K \PA\2012\12W E3016 CP4 Condensate Tank Regulatory Analysis Worksheet Colorado Regulation% Parts Aand 8-APEN and Permit Requirements ATTAINMENT -This source is located in the ozone non -attainment area. Since this source does not emit CO, all questions in this section are listed as N/A 1. Are uncontrolled actual emissions from any criteria pollutants fromthis individual source greater than 2TPY(Regulation 3, Part A, Section 11.0.1.a)? 2. Is the construction date (service date) priori° 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greaterthan S TPY, NOx greater than to TPY or CO emissions greater than 10 TPY (Regulation 3, Part B; Section ll.D.3)? Not atone,,h 0tfoonatlon NON -ATTAINMENT 1 Are uncontrolled emissions from any criteria polluternsfrom this individual source greater than )TPY(Regulation 3, Part A, Section ll.D.S.a)7 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions from the greaterthan 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section ll.D.3)7 ISour<e reandraa aperme Colorado Regulation 7, Section IV 1. Does this storage tank store "petroleum liquid" as defined by Regulation 7 Part B Section lV.A.2.g7 2. Does this storage tank meet any of the exemptions listed in Regulation 7 Part B Section lV.B.17 3. Does the tank have a storage capacity greater than 40,000 gallons (952 barrels)? 4. Does the storage tank have a. fixed roof? 5. Is the faced roof tank used forthe. storage of petroleum liquids which have a true vapor pressure between 0.65 psia and 11.0 psia at 20, (WE)7 6. Is the fixed roof tank equipped with an Internal floating roof? ',rage' Tank is not sta,300-t Eo Regulaieo,t 7, Pao EM1. Settioo storage Tank Iona 54*.tix, Nmylulatiwt 7, Pert 0, Section 000.2000) ,t°rage.Ie„la;a,mzaubhu°t Reetatatinst?, Pmt x, 0,0,00, 000.5.o.(OH0q 7. Is the tank equipped with an external fldat ng roof AND Is larger than 952189 AND stores petroleum liquid AND Is located to ozone nonattalnment area? 8. Does the tank meet any of the exemptions of Section lV.B2c.(I)(B)(1)? 9. Does the tank meet any of the exemptions of Section lV.B:2.c(1)(B)(2)? 10. Does the tank store petroleum liquds with true vapor pressure (as stored) above 1.3 psia? IStornge'tint{ Ls nsOt sub act to keguletion d, Part B, Seettoo 101,20 11. Does the storage tank have storage capacity less than 40,000 gallons (952 barrels)? 12. Does the storage tank store liquids with a true vapor pressure between LS psia and 11.0 psia a[ 20°C? 13. Is the storagetank at a facility that receives and stores petroleum addressed by Regulation 7 Sections IV.C.2 or IV.C.3? 'stooge took 0,0yu tl 50000,0000Y,et'Y 0, 000,00,0.0 IStotege task is seitjeet Rege0-010,0 t Pert 07, Socoon Colorado Regulation 7. Part 0, Section I,C-F 1. Isthis storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oll and gas exploration and production operations, natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream o£ a natural gas processing plant? ISureoge lank isnot snbtecs Regulail,'sr, ]. Part 0,.5...un Section I.C.1 — General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section I.C.2—Emission Estimation Procedures Section I.0 —Emissions Control Requirements Section I.E—Monitoring Section I.F—Recordkeeping and Reporting Colorado Regulation ] Part 0, Section I.G 1. Is this storagetank located in the 8 -hr ozone control area or any ozone non-attalnment area or attalnment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit 'Flash" (e.g storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? ki.> _Took L nut subject ter Reputadon 7, pare O, Sennnn f.G Section I.G.2- Emissions Control Requirements Section I.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section I.C.2—Emission Estimation Procedures ' Colorado Regulation 7, Part 0, Section II 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation, well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 2 tons per year VOC? k sbiext to Reeetation I ewe Et, Seclio it Section II.B—General Provisions. for Air Pollution Control Equipment and Prevention of Emissions Section II.C.1- Emissions Control and Monitoring Provisions Section ll.C.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? ISterags Tank is rcr95 vub u4 Co Rmgutelfgn X, Path i'.1,5'sction0,0.a Section II.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment Is the controlled storagetank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on °rafter May 1, 2020 or located at a facility thaw. modified on or after May 1, 2020 6. such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Section ll.C,4.a.(I)? IStorage Tank is not sot,(estin Regetetioe 7, Pert D, 6act n,+00-104 is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after January 1, 2021 or located at a facility that was modified on or after -January 7. 1, 2021, such that an additional controlled storagevessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Section II.G4.a.(ii)? It:forage Tank is not5,-d*, to Regulation 7, Part D, Section B.C'.4.a90, b - f r!k NrMa* Yd'`s Ye P1A't`k."kk'. Source Requires an APEN. Go to the next quertlon Go to next question Source Requires a permit Go to the next question Go to the next question Storage Tank is not subjedta. Regulation 7, Part %Section IV.8.2.6 NdA aStorageTank is not subjectto Regulation 7, Part B,Secpon lV.B.1:c. NA '... ' NA Yes - - Na Nt f G $ N:a:a'iu`* NAS `,urAN RCN Go to next question Go to next question Source is subject to Reg 7, Part B, Sec IV.B.3. Go to the next question Storage Tank Is not subjectto Regulation 7, Part D, Section I Go to the next question Storage Tank is not subjectto Regulation 7, Part 0, Section I.G Go to next question Storage Tank Is not subject to Regulation 7, Part D, Section it Storage Tank is not subject to Regulation 7, Part D, Section II.C.2 Storage Tank is not subject to Regulation 7, Part D, Section II.C.4 Storage Tank is not subject to Regulation 7, Part D, Section II.C.4 40 CFR Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m) L-472 BBLs]7 2, Does the storage vessel meet the following exemption in 60.1116(d)(4)7 a. Does the vessel has a design capacity less than or equal to 1,589.874 rr][-mono BBL] used for petroleum" or ondensate stored,processed, or treated prior to custody transfer' as defined in 60.11Th? 3, Was this condensate storage tank constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23,19847 4. Does the tank meet the definition of "storage vessel"' in 60.11167 5. Does the storage vessel store a"volatile organic liquid(VOL)'Aas defined in 60.113b? B. Daps the storage vessel meet any one of the following additional exemptions; a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kna (-29.7 psi] and without emissions to the atmosphere (60,110b(d)(2)17; or b. The design capacty is greater than or equal to 151 m' (-950 BBL] and stores a liquid with a maximum true vapor pressures less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M' (^472 BBL] but less than 151 ms ['950 BBL] and stores a liquid with a maximum true vapor pressures lessthen 15.0 kPa(60.1106(b))7 Storage Tank is not subject NSPS Kb -The storage vessel capacity Is below the applicable threshold. NA ; N SW.ga lank is rtPY suhfek.t ¢e NSP6 KY Subpart A, General Provisions 460.1126- Emissions Control Standards for VOC 460.1136 -Testing and Procedures 460.1156 -Reporting and Remrdkeeping Requirements 460.1166 - Monitoring of Operations 40 CFR. Part., Subpart 0000. Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Was this condensate Sorage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after August 73,2011,and prior to September 18, 20157 2. Does this condensate storage vessel meet the definition of"storage vessel"' per 60.5430? 3. Is this condensate storage vessel located at a facility In the onshore ail and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry? 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6tens per year? 5. Is the storage vessel subject. and cantrolled'in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH7 Immmmnut,st „Moot 4a NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 460.5395- Emissions Control Standards for VOC 460.5413 -Testing and Procedures 460.5396(g)- Notification, Reporting and Remrdkeeping Requirements §60.5416(c)- Cover and Closed Vent System Monitoring Requirements 460.5412- Control Device Monitoring Requirements [Nate: If a storage vessel is previously determined to be subject. NSPS 0000 due to emissions above 6 tons per year VOL an the applicability determination date, It should remain subject to NSPS 0000 per 60.6366(0(2) evc if potential VOC emissions drop below 6 tons per year] 40 CFR. Part 60, subpart 00009. Standards of Performance for Crude OII and Natural Gas Facilities for which Construction. Modification, or Reconstruction Commenced After September IA, 2015 1. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 20157 2. Doesthls condensate storage vessel meet the definition of"storage vessel"' per 60.5430a7 3. Is this condensate storage vessel lasted at a facility In the crude oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry? 4. Are potential VOCemissions' fromthe individual storage vessel greater than or equal to 6tons per year? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 605ubpart Kb or 40 CFR Part 63 Subpart HH7 (4 60.5395a) 1500,0 Yani, to noi, mubje to NSP3O 40 CFR, Part 63, Subpart MACY HH, OII and Ges Production Facilities 1. Is the tank located at a facility that is major' for HAPs? 2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. Afacllity that processes, upgrades or stores hydrocarbon liquids' (63.?60(a)(2)); OR b. Afadlhythat processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gastransmission and storage source category or is delivered to a final end users (63.760(a)(3))7 3. Does the tank meet the definition of"storage vesselx°in 63.7617 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions°per 63.7617 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart DODO? Stnrat¢e faro fr„m¢041, ,t. to MAO rtti Subpart A, General provisions per 463.764 (a) Table 2 463.766- Emissions Control Standards 463.773 -Monitoring 463.774- Recrdkeeping 463.775 -Reporting RACE Review RACT review Is required If Regulation 7 does not apply AND if the tank Is In the nonattainment area. If the tank meets bath criteria, then review RACE requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis if contains may not apply toa particular situation based upon the individual facts and circumstances This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatary language such es "recommend,""may," "should," and "can," is intended to describe APCO Interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this. document does not establish legally binding requirements in and of itself fetiUte No N NA NA Go tothe nent question Go tothe neat question Storage Tank Is not subject NSP5 0000. Storage Tank is not subject NSPS 0000 -This tank was constructed prior to the applicability date. Storage Tank is not subject MAC[ HH-There are no MACr HH requirements for tanks at area sources Hydrocarbon Loaaout rr ssivns nv ntory Section 01 -Administrative Information Facility AIRS ID: County Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Controlled.? Joh ?ink flare, model 1H1` 3 24 -3G -;f-1/10-1/10 X, ser emissions from eight (8)(ACT tanks (AIRS 003); and hydrocarbon emissions point are for combustion of flare pilot/assist gas .(propane Open Flare Requested Overall VOC & HAP Control Efficiency %: Hours of Operation, hrs/year: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Pilot/Assist Gas (Propane) Actual Volume= 'Requested Permit Limit= Potential to Emit (PTE) Volume Loaded= ..yes 95.0 8760.0 3952, Ra#ed aYa maxhnam of 39 MtUIB sJtir. Flare controls lid �oadout to railcars (AIRS 008). Emissions satiated with thi and dart' missions from combustion of wale gas. "b. Pounds (lb) per year 3A,000. Gallons (gal) per year Requested Monthly Throughput= 254xo Gallons (gal) per month �,30 000. Gallons (gal) per year Secondary Emissions - Truck Loadout (AIRS 008) and TACT Tanks (AIRS 003) Actual Volume = 041330 Barrels (bbl) per year 1000 Gallons (gal) per hour Requested Permit Limit Throughput Loadout(AIRS 008)x,5-119 ➢48. Barrels (bbl) per year Requested Permit Limit Throughput LACTTanks (AIRS 003) 51,190, Barrels (bbl) per year Potential to Emit(PTE) Volume Loaded = Potential to Emit (PTE) Volume Loaded= 24 88}46}j 1000 Gallons (gal) per hour 5,170,23@': Barrels (bbl) per year Requested Monthly Throughput= 4'3911'8 Barrels (bbl) per month Secondary Emissions -Combustion Device(s) Flare Design Rating Heat content of waste gas = Actual Volume of waste gas emitted per year= Requested Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = !t,%1✓,,x f390MMBtu/hr Btu/scf scf/year 5894 00.9 scf/Year ,Potential to Emit (PTE) heat content of waste gas routed to combustion device = 0 MMBTU per year 341,840 MMBTU per year 341,040 MMBTU peryear Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: scfh Btu/scf 0.0 MMscf/yr 0.0 MMBTU/yr Section 04- Emissions Factors & Methodologies 'Pilot usage included with assist gas (both propane) 12WE1016.CP2 (density of propane) Mfg. Guarantee and 12WE1016.CP2 Mfg. Guarantee and 12WE1016.CP2 AP -42 Table 1A-3 AP -42 Table 1.4-3 AP -42 Table 1.4-3 AP -42 Table 1.4-3 14 of 23 KAPA\2012\12W E1016.CP4 Hydrocarbon Loadout Elms ons Inventory Section 05 Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Umrts Controlled fibs/month) PM10 PM2 5 sox NOx VOC CO 1 27 0 00 0 00 1 27 1 27 / 216 1 27 0 00 0 00 1 27 1 27 2116 0 10 0 00 0 CO 0 10 0 10 ` 17 3 63 0 00 0 00 3 63 3 63 616 63 30 0 00 'I 00 63 30 3 17 538 9 07 0 00 0 00 9 07 9 07 1540 Hazardous Air Pollutants Potential to Emit Uncontrolled fibs/year) Actual Emissions Requested Permit Umrts _ Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (Ibs/year) (Ibs/year) fibs/year) Benzene 1 0 0 Toluene 2 0 0 2 2 Ethylbenzene 0 0 0 0 a xylene 0 I 0 0 0 0 n Hexane 1025 0 0 1025 1025 224 TMP 0 0 0 0 0 Formaldehyde 43 0 0 43 43 Section 06 Regulatory Summary Analysis Regulation 3 Parts A B (See regulatory applicability worksheet for detailed analysis) 'Source requires a permit Section 07 Initial and Penochc Sampling and Testing Requirements 1 1 Does the company request a control device efficiency greater than 95/ for a flare or combustion device, If yes the permit will contain initial and penodic compliance testing in accordance with PS Memo 20 02 L 1 Section OB Technical Analysis Notes (7';' ^i✓' t,Y z a`k �s x:..�+.—_.. s�3- _ T t- .r �,"� ' .. s -4 ,r T x. „r t 1 NOx and CO emisssic fac4ms obtained from 12WE1o16 CP2 (based onflare manufacfurei certification) and were unchanged with tha permit modification Overall emissions decreased due to the decrease m throughput to the flare �, ` a_z s r 2�The VOC limit and emission facto`rswere unchanged with this permit modification �VOCemissions from the flare arefbased solely on propane combustion which is mhoduied asan assist gas to boost'heat cootentof thewaste gas steam asviellas used for pdotgas'It should be Noted thatt4eoperator rtatedin their application that verylittle if any assist gas is expected to beregmred basedn the heatcontent of thenude/Condensate vapors routed to the openiflare Re`gaMlessr 30000 gallons of -propane was permittedfo%[Nis point as a conservativahstimation/with a 95% Control efficiencyapplied '1* i1 "- / / ' y ,-, n. .j. -r o.y � '4, �, ss> x ` f e ^"-_m ik ,,' ;/ r �� ' 7',4' s 'y.^ ,, 3'Though not included Ztl the previous Issuance of 12WE1016 the operator requestedahat HAP emissions from propane cmnbusbon (due to possible imp�u`nties m the propane stream, approximated ai natural gas)be included in the construction p`ermd These emissions were calculated usingAP.t2 Chapter 14 emission factorafornatural gapyco'''''' n"'.�;^ `-e �"`�-y `>r»t� -v yr. .'s=°jr ' �` '';r lr ' 5..Tl, `. 5�, . _ _ .--� "�. Gyx'u ^._,— �-f .. -;a�, nd>?vz' F e'?r .� L"�sS_ss -,,' �'" t, art ".�J.." / P Section 09 SCC Coding and Emissions Factors (For Inventory Use Only) AIRS Point p 005 Process # 01 SCC Code 3 10 002 16 Flares Combusting Gases x 1000 BTU/scf L f) J Uncontrolled Emissions Pollutant Factor Control A Units PM10 447 0 Ib/MMscf burned PM25 447 0 Ib/MMscf burned SOx 035 0 Ib/MMscf burned NOx 127. 0 Ib/MMscf burned VOC 222.34 95 Ib/MMscf burned CO 3184 0 Ib/MMscf burned Benzene 2 a0E 03 0 Ib/MMscf burned Toluene 340E 03 0 Ib/MMscf burned Ethylbenzene C00 0 Ib/MMscf burned Xylene 000 0 Ib/MMscf burned n Hexane 1800 0 Ib/MMscf burned 224 TMP 000 0 Ib/MMscf burned 15 of 23 K \PA\2012\12W E1016 CP4 Hydrocarbon i-oadaut Emissions inventory Section 01 -Administrative information Facility AIRS ID: 123 County Plant r 008 Point Section 02- Equipment Description Details Detailed Emissions Unit Crude oiifc:5nd Description: Emission Control Device Open Hare (AIRS 005)„ Description: Is this loadout controlled? Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded=„y-✓*,e`' (Requested Permit Limit Throughput= Potential to Emit (PTE) Volume Loaded = Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= Actual Volume of waste gas emitted per year= Requested Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = COS/ F, 9 y4a;Barrels (bbl) per year 1' Potential to Emit (PTE) heat content of waste gas routed to combustion device = Barrels (bbll per year i Btu/scr 0 scf/year 0 scf/year Requested Monthly Throughput= 43-764 Barrels(bbl) per month 0 MMBTU per year 0 MMBTU per year 0 MMBTU per year Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: scfh - Btu/scf D.0 MMscf/yr 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate. emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at thefacility being permitted? Loading Loss Equation L=12.46*S*P*M/T d g sr e spec?fi Factor Meaning Value Units Source 5 Saturation Factor ��2, ° AP -42 Chapter 5.2 Table 5.2-1 Submerged Loading: Dedicated No, Servica{S= P True Vapor Pressure 7.8777 -. psia AP -42 Chapter 7 for Gasoline(RVP 15.0)'' M Molecular Weight of Vapors 60 --Ih/Ib-mol AP-42 Chapter for Gasoline(RVP 15.0); T Liquid Temperature .:511:12 ;:Rankine AP -42 Chapter 7 for Gasoline:(RVP 15.0)- L Loading Losses .:b_-. ::i lb/1000 gallons ::AP -42 Chapter 5.2 Table 52-1 Submerged Loading:. Dedicated Normal Service (S=0.6) 0.29_1111 :'lb/bbl Component Mass Fraction Emission Factor Units Source Benzene '0.004138 0. C312 -alb/bbl °%;-:'- .Stable Sales Oil Analysis (unchanged from previous CP issuance) Toluene '0.001541 .1 slb/bbl : Stable Sales Oil Analysis (unchanged from previous CP issuance) Ethylbenzene :.O.tl00144 ..�' I=1b/bbl Stable Sales Oil .Analysis (unchanged from previous CPissuance) Xylene '0.060641 -=1,' .?5 lb/bbl Stable Sales Oil Analysis (unchanged from. previous CP issuance) n -Hexane .0.017891 lb/bbl sv'; Stable Sales Oil Analysis (unchanged from previous CP issuance) 224 TMP :0.002549 .., -':: Ib/bhl":' -:Stable Sales Oil Analysis (unchanged from previous CP issuance) 16 of 23 KAPA\2012\12W E1016:CP4 Hydrocarbon Loaacut Emissions Inventory Section 09 SCC Coding and Emissions Factors (For Inventory Use Only) Section 05 Emissions Inventory Cntena Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limns Controlled (Ibs/_month_( PM10 PM25 SOx J NO4 VOC CO 000 0 C 000 C00 000 0 000 0C0 000 000 000 0 0 00 0 00 0 00 0 00 0 03 0 0 C 000 000 0 0 000 0 743 20 0 00 0 00 743 20 37 16 6312 0 CO 0 C0 0 00 0 00 0 00 0 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/yead (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n Hexane 224 TMP 6151 0 0 6151 308 2253 0 0 2291 175 214 0 0 214 L 953 0 0 953 48 26593 C 0 26593 1330 3789 0 0 3789 189 Section 06 Regulatory Summary Analysis Regulation 3 Parts A B Source equires a pe 'nit Regulation 7 Part D Section II C 5 (See regulatory applicability worksheet for detailed analysis) The Hydrocarbon homes loagnur source is not s_h)sc to Regulat on 7 P>tt C Section II C 5 Section 07 Inmal and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95/ for a flare or combustion device? If yes the permit will contain initial and periodic compliance testing in accordance with PS Memo 20 02 Section 08 Technical Analysis Notes _ w d , N..-5,4- . -1 -" ••�-^-^Yc„---- - - -- - • _ - ,t>r- „ A, ---^,— .-,-. , -e--;,,,,,,A.-----,- > -7 ".--",-----1,r- � r -_ - ,-,4 _ _...._... - 4, - -1-F,,,,-.37,_4;,-,-, ii NOx andCO emissions from waste gas combustion accounted for at process flare(AIR5005) 4-,6. d:' - �i 1' .„ „ �-, zi ,5i'� E` �-%chaneed slightly from previous pefmR issuance dueto an updated bq'uid'temperature (previously 5838 F based on field data now 5145 Fbased on AP�2 Chapte�l) Noe that the lowertemperatdre requested m this appl� ban r } rvatgve estimation of emissions asliquidtemperature is m the_denoommatorofthe AP'42cChapter 52 emission factor calculation Asaresult this lower Lempe.ature yields a higher loading loss emission factor ., 4� l., `"ta v t ss�X>r'` r ifi#y. 0�2-.` 4 v r > 'r s_ nl r'a5V �'.`� "* , e + i : i AIRS Point p 008 Process ft O1 SCC Code 4 06-001 32 Crude Oil Si.Smerged Loading No coal Sennoe (5=0 B Uncontrolled Emissions Pollutant Factor Control .G Unrts PM10 000 0 lb/1000 gallons transferred PM25 DGO 0 lb/1000 gallons transferred SOx 000 0 Ib/1000 gallons transferred NOx 0 CO 0 lb/1000 gallons transferred VOC 3 9 95 Ib/1000 gallons transferred CO 0 00 0 lb/1000 gallons transferred Benzene 2 86E 02 95 Ib/1000 gallons transferred Toluene a 07E 02 95 lb/1000 gallons transferred Ethylbenzene 996E 04 95 Ib/1000 gallons transferred Xylene 4 43E 03 9b Ib/1000 gallons transferred n Hexane 1 2"—E 0, 95 Ib/1000 gallons transferred 224 TMP 1 76E-02 95 Ib/1000 gallons transferred 17 of 23 K \PA\2012\12W E1016 CP4 Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions and throughput. Colorado Regulation 3 Parts A and B - APEN-and Permit Requirements Source is in the Non-=.tta€nment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the Ioadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)? 3. Is the Ioadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the Ioadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the Ioadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.3)? IYou have Indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section II.D.l.a)7 2. Is the Ioadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part 8, Section II.D.1.1)? 3. Is the Ioadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the Ioadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the Ioadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)7 ISource requires a permit Colorado Regulation 7 Part D Section II.C.5. 1. Is this condensate storage tank hydrocarbon liquids Ioadout located at a well production facility, natural gas compressor station or natural gas processing plant? 2. Does the facility have a throughput of hydrocarbon liquids Ioadout to transport vehicles greater than or equal to 5,000 barrels? 'The hydrocarbon liquids Ioadout source is not sublect `_c Regulation 7 Part D Section. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for regulation, or any otherlegally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act, it; regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,""may," "should," intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and required" are intended to describe controlling requirements under the terms of El Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Facility AIR 123- 4581 011: County Plant Point Operation (hrs/yr) 6760 SCC Code: 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Emission Factors: Vary by component type Fuaitive Component Counts & Emissions Service Component Type Count TOC EF Iblhr- source TOC EF kglhr- source Control (%) VOC Benzene Toluene Ethylbenzene Xylene n -Hexane 2,2,4-TMP Uncontrolled (tpy) Controlled (tpy) Uncontrolled (Ib/yr) Controlled (Ib/yr) Uncontrolled (Ib/yr) Controlled (Ib/yr) Uncontrolled (Ib/yr) Controlled (Ib/yr) Uncontrolled (Ib/yr) Controlled (Ib/yr) Uncontrolled (Ib/yr) Controlled (Ib/yr) Uncontrolled (Ib/yr) Controlled (Ib/yr) Gas Valves 189 2.87E-05 1.30E-05 0.0% 0.02 0.0 0.2 0.2 0.1 0.1 0.0 0.0 0,0 0.0 0.8 0.8 0.1 0.1 Pump Seals 0 1.43E-04 6.50E-05 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 • 0.0 0.0 0.0 0.0 Others 42 2.65E-04 1.20E-04 0.0% 0.05 0.0 0:4 0.4 0.1 0.1 0.0 0.0 0.1 0.1 1.7 1.7 0.2 0.2 Connectors 1345 9.26E-05 4.20E-05 0.0% 0.55 0.5 4.5 4.5 1.7 1.7 0.2 0.2 0.7 0.7 19.5 19.5 2.8 2.8 Flanges 291 9.26E-05 4.20E-05 0.0% 0.12 0.1 1.0 1.0 0.4 0.4 0.0 0.0 0.2 0.2 4.2 4.2 0.6 0.6 Open-ended lines 0 2.65E-04 1.20E-04 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Rail Hatch Openin 4 9.72E-03 4.41E-03 0.0% 0.17 0.2 1.4 1.4 0.5 0.5 0.0 0.0 0.2 0.2 6.1 6.1 0.9 0.9 Light Oil Valves 689 9.48E-05 4.30E-05 0.0% 0.29 0.3 2.3 2.3 0.9 0.9 0.1 0.1 0.3 0.3 10.2 10.2 1.5 1.5 Pump Seals 40 1.19E-03 5.40E-04 0.0% 0.21 0.2 1.7 1.7 0.6 0.6 0.0 0.0 0.3 0.3 7.5 7,5 1.1 1.1 Others 63 2.87E-04 1.30E-04 0.0% 0.08 0.1 0.6 0.6 0.2 0.2 0.0 0.0 0.1 0.1 2.8 2.8 0.4 0.4 Connectors 3235 1.76E-05 8.00E-06 0.0% 0.25 0.2 2.0 2.0 0.7 0.7 0.0 0.0 0.3 0.3 8.9 8.9 1.3 1.3 Flanges 1125 1.76E-05 8.00E-06 0.0% 0.09 0.1 0.7 0.7 0.3 0.3 0.0 0.0 0.1 0.1 3.1 3.1 0.4 0.4 Open-ended lines 0 2.87E-04 1.30E-04 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTALS(tpy) 1,• 2 1..- 0.01 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.03 0.03 0.0 0.00 TOTALS lb/ Colorado Department of Public Health Environment Air Pollution Control Division Preliminary Analysis - Emissions from Fugitive Components With safet factor: TOTALS (tpy) TOTALS Ibl 0.01 Emission Factor Source: EPA -453/R-95-017, Table 2-4 Stream VOC Fraction (wt) Gas 1.0000 1,0000 1,0000 1.0000 Light Oil Heavy Oil Water/Oil Regulatory Considerations Reg, 3 Is this source located in an ozone non -attainment area or attainment maintenance area? Yes If yes, is this source subject to leak detection and repair (LDAR) requirements per Regulation 7, Part D, Section II.E or I.G or 40 CFR, Part 60, Subparts KKK or 0000? No If you repond "yes" to the first question and "no" to the second, this source is subject to Regulation 3, Part B, Section 111.0.2, Reasonably Available Control Technology (RACT) requirements and must implement a leak detection and repair program. The engineer should work with the supervisor to craft an LDAR requirement that mirrors the provisions of Regulation 7, Part D, Section II.E. Reg. 6 Is this source at an onshore "natural gas processing plant" as defined in 40 CFR, Part 60.631? No Did this source commences construction, reconstruction, or modification after January 20, 1984, and on or before August 23, 2011? If you answer "yes" to both questions above, this source is subject to the provisions of 40 CFR, Part 60, Subpart KKK "Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants" contained in Regulation 6, Part A. Did this source commences construction, reconstruction, or modification after August 23, 2011? If you answer "yes" to question #1 and #3 this source is subject to the provisions of 40 CFR, Part 60, Subpart 0000 "Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution". Specifically, review subpar 60.5400 for fugitive component leaks and 60.5380 and 60.5385 if the operator reports compressors. Reg. 7 Is this source located in an ozone non -attainment area or attainment maintenance area? Yes Is this source at an onshore "natural gas processing plant" as defined in 40 CFR, Part 60.631? No If you answer "yes" to both questions above, this source is subject to the provisions of Regulation 7, Part D, Section I.G regardless of the date of construction Reg. 8 Is this source at a "natural gas processing plant" as defined in 40 CFR, Part 63.761? No Is this facility considered a "major source" of HAP as specifically defined in 40 CFR, Part 63.761 for sites that are not produution field facilities? No If you repond "yes" to both questions above, further review if the provisions of 40 CFR, Part 63.769 "Equipment Leak Standards" apply? Stream HAP Comconents (wt fraction HAP Gas Light Oil Heavy Oil Water/Oil Benzene 0.0041 0.0041 0.00 0.00 Toluene 0.0015 0.0015 0.00 0.00 Ethylbenzene 0.0001 0.0001 0.00 0.00 Xylene 0.0006 0.0006 0.00 0.00 n -Hexane 0.0179 0.0179 0.00 0.00 2,2,4-TMP 0.0025 0.0025 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.03 0.03 Technical Analysis Notes t 1.. Opera3or initially requested decrease in railcar hatch opening events from 4 to 1 to account for decreased throughput,with the 12/29/2020 construction permit application, However, in operator correspondence received 1/1.1/2021, it was communicated that the request to decrease rail car hatch opening events was withdrawn. As a result, this point was not modified with this permit action. This PA worksheet is being included for informational purposes only. ' 2.Allemission factorsareidentical to those permitted with previous construction permit issuance, - ` 3. Removed initial compliance requirement to conduct component hard count after installation of "large" IFR tanks covered by AIRS tag.These tanks were never constructed, Further, the component counts permitted with the previous (third) issuance of this construction permit ale -identical to the actual count submitted with the self -certification package received for the second issuance of this construction permit. As such, anew physical hard count3s not required, Printed 2/3/2021 Page 19 of 23 Hydrocarbon Loadout Emissions Inventory Section 01 -Administrative Information Facility AIRS ID: 123 County 9581" Plant 013 . Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Crude oli/condensate oadot om tank4rucks d'rectly to rail a (Alternate Fla car Loadout) Requested Overall VOC & HAP Control Efficiency /: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions- Hydrocarbon Loadout Actual Volume Loaded= 'Requested Permit Limit Throughput= Potential to Emit (PTE) Volume Loaded e Barrels (bbl) per year r;wfas4 04-t Barrels (bbl) per year ./i�, eapamgp f Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= Actual Volume of waste gas emitted per year = Requested Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Lf Btu/scf scf/year 0 scf/year Requested Monthly Throughput= 4347$. Barrels (bbl) per month J 0 MMBTU per year 0 MMBTU per year 0 MMBTU per year Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: 0.0 MMscf/yr 0.0 MMBTU/yr . Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the: facility being permitted? Loading Loss Equation L= 12.46'S'P'M/T carbon liquid sample Is valid for developing site specific emission_ fa^_ters. Factor Meaning Value Units Source S Saturation Factor 0,t; � "` P' Y rY' pr ,'d.faWe5 2-Y 5ubrnzrgod1:cladfng bi,it&I ed'Nidifi ai:'Service (S.0.63 P True Vapor Pressure to,1)8777 - Asia AP -42 Chapter 7;for Gasoline (RVP 15,0) M Molecular Weight of Vapors ✓„r,-„`Ib/Ihmol AP -42 Chapter 7 for Gasoline(RVP 15.0) T Liquid Temperature , °°4511.124 Rankine AP -42 Chapter 7: for Gasoline(RVP 15.0) L Loading Losses S.9S348*1239 lb/1000 gallons AP -42 Chapter 5.2 Table 5.2-1 Submerged Loading: Dedicated Normal Service (S=0.6) lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.004138 0.001201389 lb/bbl :Stable Sales Oil Analysis (unchanged from previous CP issuance) Toluene :O.Q01541'_�<;n%4551b/bbl 'Stable Sales Oil Analysis (unchanged from. previous CP issuance) Ethylbenzene :0.000144 ;,:'05 Ib/bbl ' Stable Sales Oil Analysis (unchanged from. previous CP issuance) Xylene 0.000641 _.:;'3='_-:h1251b/bbl Stable Sales Oil Analysis (unchanged from previous CP issuance) n -Hexane 0.017891 0.0051`•434'8 lb/bbl Se able Sales Oil Analysis (unchanged from previous CP issuance) 224 IMP 0.002544 ', 0.0007431.44 lb/bbl SYable Sales Oil Analysis (unchanged from previous CP issuance) , Emission Factor Pollutant VOC Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Pollutant CO Pollutant PM10 Hydrocarbon Loadou Uncontrolled (Volume. Loaded) Control Device Co. strolled Emission Factor Source (Volume Loaded) Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) Pilot Light Emissions Uncontrolled Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) Emission Factor Source (Ib/MMscf) Emission Factor Source (Pilot Gas Throughput) 20 of 23 K:\PA\2012\12W E1016.CP4 Hydiocarbon Loadou* Emissions Inventory Section OS Emissions Inventory Potential to Emit Actual Emissions Requested Permit Umus _ Requested Monthly Umds Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) PM10 000 000 000 000 000 0 PM25 000 000 009 000 0 G 0 sox 0 00 0 00 0 00 G CO 0 00 0 NOx 0 CO 0 00 0 00 0 00 0 00 0 VOC 743 n 0 00 0 00 743 20 5 60 1641 CO 0 0C 0 00 0 CO 0 90 0 00 0 Potential to Emrt Actual Emissions Requested Permit Limits Hazardous Au Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (Ibs/year) (Ibs/year) (Ibs/year) (Ibs/year) Benzene 6431 0 0 6151 80 Toluene 2291 0 0 2291 30 Ethylbenzene 214 G 0 214 Xylene 953 0 C 953 12 n Hexane 265.3 0 0 25553 346 224 TMP 3789 0 0 3789 e9 Section 06 Regulatory Summary Analysis Regulation 3 Parts A B Sour a requ res a Perm. Regulation 7 Part D Section II C 5 (See regulatory applIcabdrty worksheet for detailed analysis) The hydro_a bon Gqu ds loadout so_ cc is rot subject to 4egulation 7 Par D Sec 10P I G5 Section 07 Ingle! and Periodic Sampling and Testing Requirements Does the company request a control device effinency greater than 95,6 for a flare or combustion device, If yes the permit will contain initial and periodic compliance testing in accordance with P5 Memo 20 02 Section 08 Technical Analysis Notes 7.. �r tTa` o ..3cFa.��...f,..� ,,.-,.r ,.r -7-.r __ T-7 E1'Vapor balance collection eKaencyof 987,4 based Oil NSPS level annual leaktest(allowed per�APr42 Chapter 52/Pa`ge526 version 06/08) j�N�r `a T-' 1'; �''�'� ^-v_`�a t h 1,2 Emission factors cfjanged sbghtfyfrrom pievioui permd Issuance due to an updated. , temperature (previously 58 38 F bas`edaon field data now 51'A5 F based on AP -42, Chapter 7) Note that the lower temperature requested in this application j C results in a more Conservatly e'stimati000femissionsas llquld tempeature is in the denominator of the AP 42 Chapter ertussion faotor ealc`rilat nAs a tesult tins lower temperatureyields a higher lgadmglosssemission factor ` a 4-r<�7sr.-3Qi',�a ,a.�+ sa r d p Secton 09 SCC Coding and Emissions Factors (For Inventory Use Only) AIRS Point H Process it SCC Code 013 01 4-06-00 -32 Crude Oil Submerged Loading Normal Scr ce IS=O 5j ( Uncontrolled Emissions Pollutant Factor Control A Units PM30 .D 00 0 Ib/1000 gallons transferred PM25 900 0 Ib/3000 gallons transferred 50x 0 00 9 lb/1 000 gallons transferred NOx C00 0 Ib/1000 gallons transferred VOC 6 9 43 Ib/1000 gallons transferred CO 000 0 Ib/1000 gallons transferred Benzene 2 86E 02 99 Ib/1000 gallons transferred Toluene 107;02 99 Ib/1000 gallons transferred Ethylbenzene 9 96E 04 99 lb/1 000 gallons transferred Xylene 443E 03 99 Ib/1000 gallons transferred n Hexane 124E 01 \ 99 Ib/1000 gallons transferred 224 TMP 1 76E 02 99 lb/1 000 gallons transferred 21 of 23 K \PA\2012\12WE1016 CP4 Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions and throughput. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source's in the hio€ -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3,.Part B, Section II.D.1.0? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions, greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? IYou have indicated that source Is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollhtants from this individual source greater than 1TPY (Regulation 3, Part A, Section II,D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.2)? ISource requires a permit Colorado Regulation 7 Part DSection II.C.5. 1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility, natural gas compressor station or natural gas processing plant? 2. Does the facility have a throughput of hydrocarbon liquids loadout to transport vehicles greater than or equal to 5,000 barrels? [The hydrocarbon liquids loadout source is not subject to Regulation 7 Part Section DC -5 - Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act its implementing regulations, and Air Quality Control Commission regulations. This not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act, regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," 'may," "should," intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of tl Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. 015 Fugitive particulate emissions from Haul Road traffic E _ [k(sL)^0.91*(W)^1.02] (1-P/4N) AP -42 13.2.2, Equation 2 E = emission factor (Ib/VMT (VMT=Vehicle Miles Travelled)) k = constant from table 13.2.1-1 sL = road surface silt loading (g/m^2) W = mean vehicle weight (tons) P = number of "wet" days with at least 0.01" precipitation during the averaging period N = number of days in the averaging period (e.g. 365 for annual, 91 for seasonal, 30 for monthly) Constants W (tons sL (g/m^2) E (Ib/VMT) Pollutant k W, Empty W, Loaded W, Avg TSP (PM) 0.011 15 40 30.48 1 0.34 PM -10 0.0022 15 40 30.48 1 0.07 PM -2.5 0.00054 15 40 30.48 1 0.02 *CDOT 2011 Standard Specification Book Table 703-3 Class 6 Aggregate Base Course [Total Estimated VMT: 11,402 miles/yr —1 Emissions Summary Table Pollutant E (Ib/VMT) Uncontrolled Emissions TSP (PM) 0.34 1.93 tpy PM -10 0.07 0.39 tpy PM -2.5 0.02 0.09 tpy **Natural mitigation from precipitation per EPA AP -42 Volume 1 Fifth Edition - November 2006 Table 13.2.2-2 Equation 2; number of days with natural preciptiation from figure AP -42 Figure 13.2.2-1 Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 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.) Regulation 3-APENs, Construction Permits, Operating Permits, PSD Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission point in an 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. Notes: 1 This point is both APEN and permit exempt. This PA worksheet is being included for informational purposes only and to support the exempt determination for this source of emissions. - SCC 31088801: Fugitive Haul Road Emissions Pollutant Uncontrolled EF TSP (PM) PM -10 PM -2.5 0.34 Ib/VMT (vehicle mile traveled) 0.07 Ib/VMT (vehicle mile traveled) 0.02 Ib/VMT (vehicle mile traveled) DEC 2 9 2020 Hydrocarbon Liquid Loading APEN Form APCD-2O8 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or tacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 12WE1016 AIRS ID Number: 123 ! 9581 /008 [Leave blank unless APCD has already assigned a permit k and AIRS ID] Section 1 - Administrative Information Company Namei: Musket Corporation Site Name: Windsor Loading Facility Site Location: 2030 Howard Smith Ave. East Windsor, CO 80550 Mailing Address: 2929 Alien Parkwa , Suite 4100 (Include Zip Code) y Houston, TX 77019 Site Location County: Weld NAICS or SIC Code: 5171 Contact Person: Kevin Sokolowskl Phone Number: (346) 397-7792 E -Mail Address2: Kevin.Sokolowski@Loves.com t Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 12/2019 1 I 438977 _.__. CCOLORADO =mro= Permit Number: 12WE1016 AIRS ID Number: 123 /9581/008 [Leave blank unless APCD has already assigned a permit # and AIRS ICI Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional info Et Notes: Lower annual throughput to limit the facility -wide PTE emissions to below the major source threshold. Please refer to application text and attachments. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-i04) must be submitted. Section 3 - General Information General description of equipment and purpose: controlled by flare. Emissions from crude / condensate loadout from iFR tanks to railcars Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Yes No O IN Is this equipment Located at a stationary source that is considered a Major Source of (HAP) emissions? ❑ Yes No Q Does this source load gasoline into transport vehicles? Yes No ■ n Is this source located at an oil and gas exploration and production site? ❑ Yes No 19 If yes: Does this source load less than 10,000 gallons of crude oil per day on an annuat average? ❑ Yes ❑ No Does this source splash fill less than 6,750 bbl of condensate per year? ❑ Yes No ■ Does this source submerge fill less than 16,308 blot of condensate per year? Yes No ■ IS Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 12/2019 2jI COLORADO a.wm. el Rade Redd Yt.Weluneal Permit Number: 12WE1016 AIRS ID Number: 123 /9581/008 [Leave blank unless APCD has already assigned a permit 11 and AIRS ID] Section 4 - Process Equipment Information Product Loaded: 0 Condensate El Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded': 5,119, 048 bbUyear = Actual Volume Loaded: This product is loaded from tanks at this facility into: rail tank Gars (e.g. "rail tank cars" or "tank trucks") bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 52.45 °F True Vapor Pressure: 7.88 Psia ® 60 °F Molecular weight of displaced vapors: 60 ib / lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded': bbl/year Actual Volume Loaded: bb[/year Product Density: lb/ft3 Load Line Volume: ft'/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. Section 5 - Geographical/Stack Information Geographical Coordinates (LatftudelLongrtude:or UTM) UTM Zone 13: Easting - 511,280. Northing - 4,478,258 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. era NA 008 Ambient NA NA Indicate the direction of the stack outlet: (check one) ❑ Upward El Downward ❑ Horizontal El Other (describe): Fugitive Indicate the stack opening and size: (check one) ❑ Circular interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack depth (inches): Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 12/2019 COLORADO � N"""uE ° vIron�ni PM Permit Number: 12WE1016 AIRS ID Number: 123 /9581/008 [Leave blank unless APCD has already assigned a permit a and AIRS ID] Section 6 - Control Device Information ❑✓ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: ❑ Combustion Device: Used for control of: Rail lank car loading Rating: 39 Type: Flares MMBtu/hr Make/Model: Requested Control Efficiency: 95 % John 2ink/LHT 3 -24 -30 -X -1/10-1/10-X Manufacturer Guaranteed Control Efficiency: 99 % Minimum Temperature: 400 ° F Waste Gas Heat Content: 600 Btu/scf Constant Pilot Light: I] Yes Q No Pilot Burner Rating: NA MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. is any emission control equipment or practice used to reduce emissions? ❑r Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant PA SO. NO, CO VOC HAPs Other: Control Eg00,Ment Description::. Collection Efficiency (%nf total emrssrons'captured by caritrv! equrprient} Control Efficiency (%g rerhrctron of cQpfured , `:elriissiorts} Flare Rare 99 99 96 96 Using State Emission Factors (Required for GP02) VOC Benzene n -Hexane ❑ Condensate 0,236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0,104 Lbs/BBL 0,00018 Lbs/BBL 0,0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Emission Factor;! Units :? Source (AF 42, Mfg�etc) Actual. Anhual.Emissiens Uncontrolled misslons':'. _(tons/year),'_ Coitrolled Emissions° (tonslyear) Reguested;Annual Permit k %Emission Limit{s.)5 tlncontroited Emrasions (tonslyenr} Controlled '- Emi sons {tgnslye4r} _ SOX NO. CO VOC 6.91 1619000 gal AP -42 5,2.2 a 0 743.20 37.16 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 Annual emission fees wilt be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 12/2019 -AlmfoRAo-o 4 H«°< „t Permit Number: 12WE1016 AIRS ID Number: 123 /9581/008 (Leave blank unless APCD has already assigned a permit II and AIRS ID) Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? ❑ Yes El No If yes, use the foltowing table to report the non -criteria potlutant (HAP) emissions from source: Chemical Name Cherriica! :. Abstract Service CAS ( ) S:Iiumber :.Emissiori'Factor ActualAnnuaCEtriissions °: Uncontrolled , Basis Units Source (AA42,.: Mfg ;etc.j Uncontrolled Emissions :lifts/year) ..- Contrplied i Emissions6 ` {tbslyear) Benzene 71432 o.at%voc % Crude Analysis o 0 Toluene 108883 0.1s%voC % Crude Analysts o a Ethylbenzene 100414 o.ot%voc % Crude Analysis o 0 Xylene 1330207 0.06%voc % crudeAnarysia o 0 n -Hexane 110543 1.79%vac % Crude Ana lys o 0 2,2,4-Trimethylpentane 540841 0.25%voc % Crude Analysis s o 0is Other: 6 Annual emission fees wilt be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in futt compliance with each condition of Generat Permit GP07. - /--S ZA-y Signature of legally Authorized Person (not a vendor or consuttant) Date Michael Key Senior Environmental Advisor Name (print) Title Check the appropriate box to request a copy of the: [✓ Draft permit prior to issuance �jr Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised ADEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 OR (303) 6923148 APCD Main Phone Number (303) 692-3150 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 12/2019 ishcoLosAao 5l I;F�.� DEC , c 9 2020 Hydrocarbon Liquid Loading APEN Form APCD-208 � Air Pollutant Emission Notice (APEN) and Application for Construction Permit AU sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, Ii.C. for revised APEN requirements. Permit Number. 12WE1016 AIRS ID Number: 123 / 9581 /013 (Leave blank unless APCD has already assigned a permit # and AIRS ID) Section 1 - Adm�nzstrative Information Company Hamel: Musket Corporation Site Name: Windsor Loading Facility Site Location: 2030 Howard Smith Ave. East Windsor, CO 80550 Mailing Address: (lnciudeZip Code) 2929 Allen Parkway, Suite 4100 Houston, TX 77019 Site Location County: Weld NAICS or SIC Code: 5171 Contact Person: Kevin Sokolowski Phone Number: (346) 397-7792 E -Mail Address2: Kevin.Sokolowski@Loves.com i Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes wilt require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be 'issued by the APCD via a -mail to the address provided. 438978 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 12/2019 Permit Number: 12WE1©16 AIRS ID Number: 123 /9581/013 [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 0 Change permit Limit ❑ Transfer of ownership4 [] Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: Lower annual throughput to limit the facility -wide PTE emissions to below the major source threshold. Please refer to application text and attachments. 3 For company name change, a completed Company Name Change Certification Fonn (Form APCD-106) must be submitted. a For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Mornate seenarlo: Emissions from crude I condensate loadoul from lank bucks to railcar using vapor balance. Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Wilt this equipment be operated in any NAAQS nonattainment area? Yes No 12 ■ Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes ❑✓ No ■ Does this source load gasoline into transport vehicles? Yes 0 No ■ Is this source located at an oil and gas exploration and production site? Yes No ■ P If yes: No Does this source toad less than 10,000 gallons of crude oit per day on an annual average? Yes ■ IN Does this source splash fill less than 6,750 bbl of condensate per year? ❑ Yes No ■ Does this source submerge fill less than 16,308 bbl of condensate per year? Yes No ■ ■ Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 12/2019 t "acotoitADo 2 as ama°raa°UNIC Permit Number: 12`dVE1016 AIRS ID Number: (Leave blank unless APCD has already assigned a permit N and AIRS ID) Section 4 - Process Equipment Information Product Loaded: ® Condensate [✓J Crude Oil [] Other: 123 /9581/013 If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loadeds: 5,119,048 bbl/year This product is loaded from tanks at this facility into: rail tank CBrS (e.g. "rail tank cars" or "tank trucks") Actual Volume Loaded: 0 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 52.45 F True Vapor Pressure: 7'88 Psia 60 'F Molecular weight of displaced vapors: 60 Ib/lb mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loadeds: bbl/year Actual Volume Loaded: bbllyear Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. Section 5 - Geographical/Stack Information Geographical Coordinates ;' r{Latftude/Longrtude aY.UTi�f) '. UTM Zone 13: Easting - 511,280. Northing 4,478,258 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Opo atoX Ttack_fD Na• _. _ , _, .w Discharge leit Above z GP.P. ,Level (Fear) _ - .__. ��p :... 1rr 1 T Flow Rate 4. , Velgcity (ft/sec) 013 NA Ambient . = NA NA ...._._...._ cate the direction of the stack outlet: (check nne) Upward ❑ Horizontal ❑ Downward 0 Other (describe): Fugitive Indicate the stack opening and size (check one) ® Circular ❑ Square/rectangle ❑ Other (describe): Interior stack diameter (inches): Interior stack width (inches): ❑ Upward with obstructing raincap Interior stack depth (inches); Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 12/2019 a�oRa�o iiih NLnvaovrtlp5 PM Permit Number: 12WE1016 AIRS ID Number: 123 /9581/013 [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 6 - Control Device Information ❑✓ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. d Loading occurs using a vapor balance system: Requested Control Efficiency: 98.7% % Combustion Device: Used for control of: Rating: MMBtu/hr Type: Make/Model: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: "F Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑ Yes © No Pilot Burner Rating: MMBtu/hr `y ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ® Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Callectton Efficterzcy ; {%of totgi:emrssrans captured_ by coiierot equipment) ': Control Bquiptnent Description Gontro! Efficiency `: (% reductwn.of `captured;;;: SO. NO. CO VOC HAPs Other: Vapor Balance 100 98.7% Vapor Balance 100 98.7% ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: eollutanE; PM SO. NO. CO £missran Fact®r Ilncontralled Basis:P. IbM000 gal Source {AP 42 Mfg,Qec) ::::Actual Annual Emtsstons. ,'Uncontrohed EmisslQns {tonsiyear) ;Controlled; Elmssiansb ft4tasdyear). Requested: Annua(Permit,' Erriisson Lirriati(s)s Urpcontrol€e�_ -�fT1155iOn5 Goritrofled . Eniiss�ons {toris/yeat) VOC 8.95 AP -42 5.2.2 0 a 743.20 9.66 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Form APCD•208 - Hydrocarbon Liquid Loading APEN - Revision 12/2019 COLORADO C...61=1%,1=. 4 I Benzene Permit Number: 12WE1016 AIRS ID Number: 123 /9581/013 [Leave blank unless APCD has atready assigned a permit # and AIRS ID] Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbslyear2 If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: ❑ Yes Chem(cal _: Abstract `Service s(CAS) Number . . Emission Factor . Uncontrolled ? 8azls`: Toluene Ethylbenzene Xylene n -Hexane 2,2,4-Trimethylpentane Other: 71432 108883 100414 1330207 0.41% VOC 0.16% VOC 0.01% VOC 0.06% VOC % % % Source (AP 42, Mfg,, etc j (] No Actuai;Annual:Frtiissions `:. Uricontroiled �missigns Crude Analysis Crude Analysis Crude Analysis 110543 540841 1.79% VOC x Crude Analysis Crude Analysis 0 0 0 a Coni:rolled Emissionsb '7►bs/yeerj f: 0 0 0 0 a a 025% VOC 76 084&8 0.01% VOC 76 Crude Analysis Crude Analysis v a 0 0 6 Annual emission fees wilt be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operate,indull compliance wit ach condition of General Permit GP07. I212{.�-z z� Signature of Legally Authorized Pe�1 sonl(not a vendor or consultant) Date Michael Key Senior Environmental Advisor Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change 1n fuel type, etc.). See Regulation No. 3, Part A, ILC. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more Information or assistance call: Small Business Assistance Program (303) 692-3175 OR (303) 692-3148 APCD Main Phone Number (303) 692-3150 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 12/2019 5 I coioliiuo• P.Mronmt•A�pas aaMkWMrxurat BEC 2 9 2020 C General APEN - Form APCD-200 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All seLtionb of this APCN grid application must be completed for both new and existing facilities, including APEN updates. incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. There may be a more specific APEN for your source (e.g. boiler, mining operations, engines, etc.). A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 12WE1016 AIRS ID Number: 123 / 9581 /002 [Leave blank unless APCD has already assigned a permit a and AIRS ID] Section 1 - Administrative Information Company Name': Musket Corporation Site Name: Windsor Loading Facility Site Location: 2030 Howard Smith Ave. East Windsor, CO 80550 Site Location Weld County: NAICS or SIC Code: 5171 Mailing Address: 2929 Allen Parkway, Suite 4100 (include Zip Code) Houston, TX 77019 Portable Source NA Home Base: Contact Person: Kevin Sokolowski Phone Number: (346) 397-7792 E -Mail Address2: Kevin.Sokolowski@Lovescom 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. Z Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-200 - General APEN - Revision 12/2019 4;8914 ®�tOLORA00 Permit Number: 12WE1018 AIRS ID Number: 123 /9581/002 [Leave blank unless APCD has already assigned a permit N and AIRS ID) Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source (check one below) ❑ STATIONARY source ❑ PORTABLE source -OR - O MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment D Change company name3 ❑ Add point to existing permit Q Change permit limit ❑ Transfer of ownership4 , ❑ Other (describe below) - OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional info & Notes: Lower annual throughput to limit the facility -wide PTE emissions to below the major source threshold. Permit includes a combined limit for AIRS 002. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-906) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD•104) must be submitted. Section 3 - Genera! Information General description of equipment and purpose: Emissions from two 22,588 bbl crude / condensate IFR storage tanks Manufacturer: Chicago Bridge & Iron Model No.: 23,700 bb! Company equipment Identification No. (optional): For existing sources, operation began on: Serial No.: 73-627ou(N), 74-2064U(S) North 1FR & South IFR Tanks 12/18/2012 For new or reconstructed sources, the projected start-up date is: I] Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Seasonal use percentage: Dec -Feb: hours/day Form APCD-200 General APEN - Revision 12/2019 Mar -May: days/week weeks/year Jun -Aug: Sep -Nov: COLORADO rteseitsahtle Crude / Condensate Roof Landings Permit Number: 12WE1016 AIRS ID Number: 123 /9581/002 [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 4 - Processing/Manufacturing Information Et Material Use ❑ Check box if this information is not applicable to source or process From what year is the actual annual amount? Design Prgcess !; hate (Spsetfy Unrts) Actual Anraual.l Amount (Specefy Unrts) Requestied Annual ': Perrriit.t�mtt5 ' ': (Specgfy Unrts) Material Consumption,:` finished Product(s); 22,586 bbls/tank event/year 215,000,000 gal/yr (all tanks) 1 event/year 5 Requested values w it become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. Section 5 - Geographical/Stack Information Pe®graphical Coordinates' (Let i'ttudeli.ongrtude or UThi)'r: UTM Zone 13: Easting - 511,280. Northing - 4,478,258 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. �p rator Stack li] Flo Fisch rgO He9ht Akspye AM, Level (fee- re p �} Flow Rate fAOF i) t Ueipcity s (ft/see} r 002 N & 002 S 48 ambient 0 0 Indicate the direction of the stack outlet: (check one) El Upward © Horizontal Q Downward ❑ other (describe): Indicate the stack opening and size: (check one) El Circular ❑ Square/rectangle Interior stack width (inches): ❑ Other (describe): Interior stack diameter (inches): D Upward with obstructing raincap 24 Interior stack depth (inches): Form APCD-200 - General APEN - Revision 12/2019 3 I COLORADO firheneeiwene HeallhlavMwivnent EJC per email rcvd 2/3/2021 TSP (PM) Permit Number: 12WE1016 AIRS ID Number: 123 /9581/002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Combustion Equipment &t Fuel Consumption Information ❑✓ Check box if this information is not applicable to the source (e.g. there is no fuel -burning equipment associated with this emission source) Design Input Rate`: (MMBTUIhr) Actual Annual Fuel Use (9pec ffy Units} ` Requested Annual Permit Llmit5 (Specify Units) } From what year is the actual annual fuel use data? Indicate the type of fuel usedb: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) ❑ Field Natural Gas Heating value: BTU/SCF Ultra Law Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑ Coal Heating value: BTU/lb Ash content: ❑ Other (describe): Heating value (give units): Sulfur content: 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 if fuel heating value is different than the listed assumed value, provide this information in the "other" field. Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies: Contol Equipment.:'_ Description ::' Callect�on Effreiehcy ` (% a f tatal em.issians captured by �ontro[:egarpme{it) 'control;Efficiency (% reduction o f captured enirssions) PN+ra PM2.s SO. NO. CO VOC Internal Floating Roof NA NA Other: Form APCD-2(l0 - General APEN - Revision 12/2019 4 l co taiA00 TSP (PM) Permit Number: 1 2WE1010 AIRS ID Number: 123 /9581/002 [Leave blank unless APCD has already assigned a permit it and AIRS ID] From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled .. Emission Factor (Spec►fy Urirts) °Emission;:;; Factor ; _. Source Controlled (tarlsJyear) Controlled (tons/year) Uncontrolled {tons/year)'.: Uncontrolled (tons%year) PA o PM2.5 SOX NOx Co VOC 1.32-Ib/hr TANKs 4.0.9d 0 0 5.82(all IFRs) 6:82(all IFRs) Other: 2.27E-3 lb/bbl 890 lb/event 6.3 6.3 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on ail APENs, including APEN updates. 7 Annual emission fees will be based on actual controlled emissions reported. if source has not yet started operating, provide projected emissions. EJC per email rcvd 2/3/2021 Section 8 - Non -Criteria Pollutant Emissions information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? ❑ Yes No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Use the data reported in Sections 4 and 6 to calculate these emissions. CAS dumber Chemical Name Overall:+ Control, ) ffictency Uncontrolled. Eti�ssion Factor jSpecrfyiiiik0_ Emission Factor Source iAP 42, Mfg , etc) Uncontrolled Actual emissions (Ibsiyear) Controiled Actual ' Emissions (Ibiii4.4) .... 110-54-3 Hexane 0% 1.79% of VOC Crude Analysis 0 0 108-88-3 Toluene 0% 0.15% of VOC Crude Analysis 0 0 71-43-2 Benzene 0% 0.41% of vOC Crude Analysis 0 0 1330-20-7 Xylenes 0% 0.06% of voC Crude Analysis 0 0 540-84-1 22,4-Tdmeihylpentane 0% 0.25% of voc Crude Analysis 0 0 100-41-4 Ethylbenzene 0% 0.01% of VOC Crude Analysis 0 0 7 Annual emission fees will be based on actual controlled emissions reported. if source has not yet started operating, provide projected emissions. Form APCD-200 - General APEN - Revision 12/2019 I ico�osAoo ImpuweeolVTIYAle Permit Number: 12WE 1016 AIRS ID Number: 123 /9581/002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that ail information contained herein and information submitted with this application is complete, true, and correct. 7 1,21,1119,2, Signature of Legally Authorized Persgiovendor or consultant) Date Michael Key Senior Environmental Advisor Name (print) Title Check the appropriate box to request a copy of the: i] Draft permit prior to issuance C7✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, !LC. for revised APEN requirements. Send this form along with $191,13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, Co 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 OR (303) 692.3148 APCD Main Phone Number (303) 692-3150 Form APCD-200 • General APEN - Revision 12/2019 6I COLORADO nap �lowironount ..w Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Page 1 of 3 Supplement to Air Pollutant Emission Notice (APEN) for Storage Tanks Note: Please complete one supplement for each tank containing liquids. Permit Number 12WE1016 Company Name: Tank Location: Person to Contact: Contact Title: AIRS Number 123/9581/002 Musket Corporation 2030 Howard Smith Ave. East, Windsor Kevin Sokolowski Environmental Compliance Analyst 'YtA3--7,L r,A I # .7 — $— " tc , z.l Weld (346) 397-7792 County: Phone Number: Fax Number: Signature of Responsibleficial (not a vendor or consultant) Date Michael Key Senior Environmental Advisor Name of Responsible Official (Please Print) Section 1 Tank Information Tank Identification: 002 N & S OFR Crude Storage Tank) Tank Installation Date: 1973-1974 Tank Type: (Check all that apply) ❑ Pressurized Open Top Roofed Horizontal Vertical Tank Dimensions Shell Length / Height: Shell Diameter: Maximum Liquid Height: Average Liquid Height: Tank Capacity: Tank Turnovers Per Year: Tank Throughput: Is the Tank Heated? Is the Tank Underground? Breather Vent Settings Vacuum Setting Pressure Setting Tank Emissions Vent To 48 60 47 24 948,614 226.65 215,000,000 No No NA NA Atmosphere Title Roof Type: (Check one) ❑ Fixed Roof NI Internal Floating Roof ❑ External Floating Roof ❑ Domed External Floating Roof Feet Feet Feet (Vertical Tanks Only) Feet (Vertical Tanks Only) G allons Gallons Per Year (Equal To Capacity x Turnovers) psig pst`g ❑ Flare ❑ Condenser ❑ Other: Revised July 2001 httn://www.edphe.state.co.us/auistationa►y.html Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 2 Fixed Roof Characteristics Shell Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ❑ Other: Shell Condition: Roof Paint Condition: Roof Type: Cone / Dome Height: Feet Section 3 Floating; Roof Characteristics $xternal Shell Color / Shade (Check one) White Aluminum Specular (Shiny Finish) Aluminum Diffuse (Flat Finish) Light Gray Medium Gray Red Other: nesart Sand External Shell Condition Good Roof Paint Condition: Good Rim Seal System: Primacy Seal (Check one) ❑ Mechanical Shoe Ni Liquid -Mounted ❑ Vapor;Mounted Deck Type: Bolted Page 2of3 Tank ID _002 N & S_ )roof Color / Shade (Check one) White Aluminum Specular (Shiny Finish) Aluminum Diffuse (Flat Finish) Light Gray Medium Gray Red Other: Roof Color / Shade (Check one) White Aluminum Specular (Shiny Finish) Aluminum Diffuse (Flat Finish) Light Gray Medium Gray Red other: Desert Sand Internal Shell Condition: (Check one) ® Light Rust ❑ Dense Rust ❑ Gunite Lining Secondary Seal (Check one) ❑ Weather Shield ® Rim -Mounted ❑ None Revised July 2001 ht p://www.cdphe,state,co.us/ap/stationary.html Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 4 Meteorological Data Nearest City (Check one) ❑ Colorado— Alamosa ❑ Colorado— Colorado Springs ® Colorado— Denver ❑ Colorado— Grand Junction ❑ Colorado— Pueblo ❑ Kansas —Goodland ❑ Nebraska— Scotts Bluff ❑ Wyoming - Cheyenne Section 5 Tank Contents Product Type: ® Single Component Liquid ❑ Multi -Component Liquid Product Stored*: Crude Oil Product Density: ?,8 Product Vapor Pressure: 15 For Solutions: Name of Solvent*: Name of Solute Dissolved*: Concentration of Material Dissolved Page 3 of 3 Tank ID 002 N & S Pounds per Gallon RVP, or psia at % By Weight, or %By Volume * Note: Please attach Material Safety Data Sheets (MSDS) for the uncommon materials. Additional Comments Two IFR Tanks storing Crude Oil Please see emission calculations and TANKS 4.0.9d results OF Revised July 2001 http://www.cdphe,state.co.us/ao/stationary,html 2/3/2021 State.co.us Executive Branch Mail - CP 12WE1016 for Review STATE OF COLORADO CP 12WE1016 for Review Chavez - CDPHE, Elie <elie.chavez@state.co.us> Kevin Sokolowski <Kevin.Sokolowski@loves.com> To: "Chavez - CDPHE, Elie" <elie.chavez@state.co.us> Cc: Andrew Parisi <aparisi@spiritenv.com>, Nicki Neyrey <nneyrey@spiritenv.com>, Michael Key <Michael.Key@loves.com> Wed, Feb 3', 2021 at 10:21 AM Elie, I have no additional comments or questions on the draft or APEN redlines, everything looks good to me. Please proceed with public notice. Thank you again for your help with this. Kevin Sokolowski From: Chavez - CDPHE, Elie <elie.chavez@state.co.us> Sent: Tuesday, February 2, 2021 11:05 AM To: Kevin Sokolowski <Kevin.Sokolowski@loves.com> Cc: Andrew Parisi <aparisi@spiritenv.com>; Nicki Neyrey <nneyrey@spiritenv.com>; Michael Key <Michael.Key@loves.com> Subject: Re: [EXT] CP 12WE1016 for Review Hi Kevin, Thank you so much for the attached spreadsheet - I have updated all HAPs to match the APCD form 102 with two exceptions: • AIRS 002 - It doesn't look like the HAPs listed on the form APCD-102 include the (very small) roof landing loss contribution. Therefore, the HAPs on the updated draft permit (attached) are slightly higher, but have been adjusted to reflect the more correct HAP speciation profile. • AIRS 003 - This is a very minor issue, but the HAPs listed on form APCD-102 were determined by dividing the controlled emissions (which match my calculations exactly) by 0.0496 (corresponding to a 99% capture efficiency and a 96% control efficiency = 95.04% CCE) instead of 0.05 (corresponding to a 95% CCE). Because we've used 95% for the other points in this application, I retained the 95% CCE for consistency. I did update the HAP speciation profile, but our numbers are still a little different. With the changes in HAP to the flare, I have updated the APEN redline previously provided - please find attached. Please confirm that this redline, along with the redlines previously provided for AIRS 002 and 003, look ok to you and I'll get these finalized and the permit off to public notice. Thanks again so much for all your help, Elie Chavez Permit Engineer Title V Operating Permit Unit Stationary Sources Program Air Pollution Control Division [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] https://mail.google.com/mail/u/0?ik=85031 f40e8&view=pt&search=all&permmsgid=msg-f%3A1690695527154876004&simpl=msg-f%3A16906955271... 1/1 DEC 2 9 2020 General APEN -- Form APCD-200 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and wilt require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or locks payment for the filing fee. The re -submittal will require payment for a new filing fee. There may be a more specific APEN for your source (e.g. boiler, mining operations, engines, etc.). A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 12WE1016 AIRS ID Number: 123 / 9581 /003 [leave blank unless APCD has already assigned a permit # and AIRS ID) Section 1 - Administrative information Company Name': Musket Corporation Site Name: Windsor Loading Facility Site location: 2030 Howard Smith Ave. East Windsor, CO 80550 M(Include Zipode, 2929 Allen Parkway, Suite 4100 Houston, TX 77019 Portable Source NA Home Base: Site Location Weid County: NAICS or SIC code: 5171 Contact Person: Kevin Sokolowski Phone Number: (346) 3977792 E -Mail Addressz: Kevin.Sokolowski@Loves,com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on al( documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-200 - General APEN - Revision 12/2019 1 I 438975 COLORADO [ Permit Number: 12WE1016 AIRS ID Number: 123 /9581/003 [Leave blank unless APCD has already assigned a permit rt and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source (check one below) ❑ STATIONARY source [] PORTABLE source -Oa - O MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name; ❑ Add point to existing permit El Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIoNAL PERMIT AcnoNs - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info & Notes: Lower annual throughput to limit the facility -wide PTE emissions to below the major source threshold. Please refer to application text and attachments. 3 For company name change, a completed Company Name Change Certification Form (Form APCp-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Emissions from 8 crude / condensate fixed roof LACT storage tanks Emissions from combustion of supplemental fuel are accounted for in AIRS 005. Manufacturer: Tank & Vessel Builders LP Model No.: 400 bbi Company equipment Identification No. (optional): For existing sources, operation began on: LACT Tanks Serial No.; 2042401-1 to 2012401-8 02/04/2014 For new or reconstructed sources, the projected start-up date is: Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Seasonal use percentage: Dec -Feb: Mar -May: Jun -Aug: Farm APCD-200 - General APEN - Revision 12/2019 2 I Sep -Nov: COLORADO o,a(Polils Permit Number: 12WE 1016 AIRS ID Number: 123 /9581/003 [Leave blank unless APCO has already assigned a permit b and AIRS ID] Section 4 - Processing/Manufacturing Information Et Material Use ❑ Check box if this information is not applicable to source or process From what year is the actual annual amount? 2019 'Material; Consumption: Crude / Condensate Design Process '. .(SE}2Cify. un}f5) . Acttiai ARRUdI ASTIOU , (Specify Units ;Requested Annual -: Permit �i-3m1t5 ,.: Dfie.Dfy;Units) 400 bbl/tank 0 2,150,000 gal/yr (all tanks) Flare Discharge 39 MMbtuihr NA 5 Requested values wil become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENS, including ADEN updates. Section 5 - Geographicat/Stack Information Geographical Coordinates (Latitude/Longitude or UTM).. UTM Zone 13: Easting - 511,280. Northing - 4,478,258 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. t3pferatar Stacklfl NaFset) DiseharRe Height Above C�ound Leya[ _ Temp { F) Flow Rate (�3�Plrl)- U�idt fftlsQc) 003A -H 48 Ambient 0 0 Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal O Downward Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): © Other (describe): ❑ Upward with obstructing raincap Emitted at Flare, see AIRS 005 APEN Interior stack depth finches): Form APCD-200 - General APEN - Revision 12/2019 3 I cal.®RAba edi&&&t. llI eaaravl i TSP (PM) Permit Number: 1 2WE1016 AIRS ID Number: 123 /9581/003 [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 6 - Combustion Equipment £t Fuel Consumption Information �] Check box if this information is not applicable to the source (e.g. there is no fuel -burning equipment associated with this emission source) Design input Rafie. =,{I�Mft7dllhr) 39 Actual ArinUal Poet Use .....................................'?.... Requested Annual Permit {Speedy Units) From what year is the actual annual fuel use data? Indicate the type of fuel used6: Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) ❑ Field Natural Gas Heating value: BTU/SCF ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,090 BTU/gallon) ® Propane (assumed fuel heating value of 2,300 BTU/SCF) [ Coal Heating value: BTU/lb Ash content: Sulfur content: D Other (describe): Heating value (give units): 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ® Yes EI No if yes, describe the control equipment AND state the collection and control efficiencies: Control Equipment Description Collection Efficiency �.of total emissions cdpture4.6y. control. equipment) Control Efficiency (% reduction of captured amissron4 PMi o PMz.s SO,, NOx CO VOC FLARE 95°/a Other: HAPS Form APCD-240 - General APEN - Revision 12/2619 4I 95% COLORADO avarrAMAMM Nc.W 6LhNranunml TSP (PM) Permit Number: 12WE1016 AIRS ID Number: 123 /9581/003 [Leave blank unless APCD has already assigned a permit 1f and AIRS ID] From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source; (Use the data reported in Sections 4 and 6 to calculate these emissions. Uncontrolled= Emission Factor (SpecifyUnits) . Emisston Factor. Source 1-92. MI3 , Uncontrollesi (togs/year) Controiled�' (tonyyear) UnconErotled {tons(gear) _:Controlled PMia PM2.s SOX NO. CO VOC 5,01-8 Ib/hK TANKs 4.0.9d Other: 10.8589 lb/bbl 0 0 21.98 (all S tanks) 1.10 (all 8 tanks) s Requested values wilt become permit limitations or wit! be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 7 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 Ws/year? ❑ Yes D No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions } CAS Number Cl.errilcai Name Cryerall Contro[ Effidenc Y Uncontrolled Emission Factor (SP.e�ijy tMrts) : Emission Factor Source f� 42; MfS , etcj Uncontrolled Actual Emissions : ,.: ((bs/year). , Controlled .t.i:w Emissions? ,:,t{tbs/year) 110-54-3 Hexane 95% 1.79% of VOC Crude Analysis 0 0 108-88-3 Toluene 95% 0.15% of voC Crude Analysis 0 0 71-43-2 Benzene 95% 0.41% of VOC Crude Analysis 0 0 1330-20-7 Xylenes 95% 0.06% of VOC Crude Analysis 0 0 540-84-1 2,2,4-Tdmethylpentane 95% 0.25% of Voc Crude Analysis 0 0 100-41-4 Ethylbenzene 95% 0.01% of VOC Crude Analysis 0 0 7 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions, EJC per email rcvd 2/3/2021 Form APCD-200 - General APEN - Revision 12/2019 5 (COLORADO Permit Number: 12WE 1016 AIRS ID Number: 123 /9581/003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. rt ./ MANS j r U N -1 -4;:lv Signature of Legally Authoriz t a vendor or consultant) Date Michael Key Senior Environmental Advisor Name (print) Title Check the appropriate box to request a copy of the: ❑r Draft permit prior to issuance ❑r Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division. APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 OR (303) 692-3148 APCD Main Phone Number (303) 692-3150 Form APCD-200 - General APEN - Revision 12/2019 6i COLORADO 4pmkMeflupue Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Page t of 3 Supplement to Air Pollutant Emission Notice (APEN) for Storage Tanks Note: Please complete one supplement for each tank containing liquids. Permit Number 12WE1016 9581 AIRS Number 123/9548/003 Company Name: Musket Corporation Tank Location: 2030 Howard Smith Ave. East, Windsor Person to Contact: Kevin Sokolowski Contact Title: Environmental Compliance Analyst a•7 County: Phone Number: Fax Number: EJC per email rcvd 2/3/2021 Weld (346) 397-7792 c ~ s—�1,1 Signature of Responsible (not a vendor or consultant) Date Michael Key Senior Environmental Advisor Name of Responsible Official (Please Print) Title Section 1 Tank Information Tank Identification: 003 A -H (LACT Tanks) Tank Installation Date: 2O14 Tank Type: (Check all that apply) Pressurized Open Top Roofed Horizontal Vertical Roof Type: (Check one) ® Fixed Roof ❑ Internal Floating Roof ❑ External Floating Roof ❑ Domed External Floating Roof Tank Dimensions Shell Length / Height: 20 Feet Shell Diameter: 12 Feet Maximum Liquid Height: 19 Feet (Vertical Tanks Only) Average Liquid Height: 18 Feet (Vertical Tanks Only) Tank Capacity: 16,075 Gallons Tank Turnovers Per Year: 16.72 Tank Throughput: 268,750 Gallons Per Year (Equal To Capacity x Turnovers) Is the Tank Heated? No Is the Tank Underground? No Breather Vent Settings Vacuum Setting -0.03 psig Pressure Setting 0,03 psig Tank Emissions Vent To ❑ Atmosphere Ni Flare ❑ Condenser ❑ Other: Revised July 2001 http://www.cdnhe.state.co.us/ap/stationarv.html Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 2 Fixed Roof Characteristics Shell Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ❑ Other: Shell Condition: nesprt Sand Good Roof Paint Condition: Good Roof Type: Cone Cone / Dome Height: Feet Section 3 Floating Roof Characteristics External Shell Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ❑ Other: External Shell Condition Roof Paint Condition: Rim Seal System: Primary Seal (Check one) ❑ Mechanical Shoe ❑ Liquid -Mounted ❑ Vapor -Mounted Deck Type: Page 2 of 3 Tank ID _003 A -H Roof Color / Shade (Check one) White Aluminum Specular (Shiny Finish) Aluminum Diffuse (Flat Finish) Light Gray Medium Gray Red Other: Desert Sand Roof Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) Light Gray Medium Gray Red Other: Internal Shell Condition: (Check one) ❑ Light Rust ❑ Dense Rust ❑ Gunite Lining Secondary Seal (Check one) ❑ Weather Shield ❑ Rim -Mounted ❑ None Revised July 2001 httn:/Avww,cdnhe.state.co.us/an/stationarv,html Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 4 Meteorological Data Nearest City (Check one) ❑ Colorado— Alamosa ❑ Colorado— Colorado Springs ❑ Colorado— Denver ❑ Colorado— Grand Junction ❑ Colorado— Pueblo ❑ Kansas —Goodland ❑ Nebraska — Scotts Bluff ❑ Wyoming - Cheyenne Section 5 Tank Contents Product Type: ® Single Component Liquid ❑ Multi -Component Liquid Product Stored*: Crude Gil/Condensate Product Density: 7.9 Pounds per Gallon Product Vapor Pressure: 15 RVP, or psis at For Solutions: Name of Solvent*: Name of Solute Dissolved*: Concentration of Material Dissolved Page 3 of 3 Tank ID 003 A -H % By Weight, or %By Volume °r• * Note: Please attach Material Safety Data Sheets (MSDS) for the uncommon materials. Additional Comments Eight LACT Tanks storing Crude Oil/Condensate. Throughput distributed evenly. Please see emission calculations and TANKS 4.0.9d results Revised July 2001 http://www.cdphe.state.co.us/ap/stationary.html 2/3/2021 State.co.us Executive Branch Mail - CP 12WE1016 for Review STATE OF COLORADO CP 12WE1016 for Review Chavez - CDPHE, Elie <elie.chavez@state.co.us> Kevin Sokolowski <Kevin.Sokolowski@loves.com> To: "Chavez - CDPHE, Elie" <elie.chavez@state.co.us> Cc: Andrew Parisi <aparisi@spiritenv.com>, Nicki Neyrey <nneyrey@spiritenv.com>, Michael Key <Michael.Key@loves.com> Wed, Feb 3, 2021 at 10:21 AM Elie, I have no additional comments or questions on the draft or APEN redlines, everything looks good to me. Please proceed with public notice. Thank you again for your help with this. Kevin Sokolowski From: Chavez - CDPHE, Elie <elie.chavez@state.co.us> Sent: Tuesday, February 2, 2021 11:05 AM To: Kevin Sokolowski <Kevin.Sokolowski@loves.com> Cc: Andrew Parisi <aparisi@spiritenv.com>; Nicki Neyrey <nneyrey@spiritenvcom>; Michael Key <Michael.Key@loves.com> Subject: Re: [EXT] CP 12WE1016 for Review Hi Kevin, Thank you so much for the attached spreadsheet - I have updated all HAPs to match the APCD form 102 with two exceptions: • AIRS 002 - It doesn't look like the HAPs listed on the form APCD-102 include the (very small) roof landing loss contribution. Therefore, the HAPs on the updated draft permit (attached) are slightly higher, but have been adjusted to reflect the more correct HAP speciation profile. • AIRS 003 - This is a very minor issue, but the HAPs listed on form APCD-102 were determined by dividing the controlled emissions (which match my calculations exactly) by 0.0496 (corresponding to a 99% capture efficiency and a 96% control efficiency = 95.04% CCE) instead of 0.05 (corresponding to a 95% CCE). Because we've used 95% for the other points in this application, I retained the 95% CCE for consistency. I did update the HAP speciation profile, but our numbers are still a little different. With the changes in HAP to the flare, I have updated the APEN redline previously provided - please find attached. Please confirm that this redline, along with the redlines previously provided for AIRS 002 and 003, look ok to you and I'll get these finalized and the permit off to public notice. Thanks again so much for all your help, Elie Chavez Permit Engineer Title V Operating Permit Unit Stationary Sources Program Air Pollution Control Division [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] https://mail.google.com/mail/u/0?ik=85031 f40e8&view=pt&search=all&permmsgid=msg-f%3A1690695527154876004&simpl=msg-f%3A16906955271... 1/1 DEC 2 9 2020 General APEN - Form APCD-200 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or locks payment for the filing fee. The re -submittal will require payment for a new filing fee. There may be a more specific APEN for your source (e.g. boiler, mining operations, engines, etc.). A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 34 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 12WE1016 AIRS ID Number: 123 / 9581 /005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Musket Corporation Site Name: Windsor Loading Facility Site Location: 2030 Howard Smith Ave, East Windsor, CO 80550 Malting Address: ap Code, 2929 Allen Parkway, Suite 4100 Houston, TX 77019 Portable Source NA Home Base: Site Location Weld County: NAICS or SIC Code: 5171 Contact Person: Kevin Sokolowski Phone Number: (346) 397-7792 E -Mail Addressz: Kevin.Sokoiowski@Loves.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via a -mail to the address provided. Form APCD-200 General APEN - Revision 12/2019 43897G I COlkeg* Zanos aw�.aanm� Permit Number: 12WE1 016 AIRS ID Number: 123 /9581/005 [leave btank unless APCD has already assigned a permit H and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source (check one below) ❑ STATIONARY source ❑ PORTABLE source -OR - ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑✓ Change permit limit ❑ Change company name3 ❑ Add point to existing permit ❑ Transfer of ownership4 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info £t Notes: Lower annual throughput to limit the facility -wide PTE emissions to below the major source threshold. Please refer to application text and attachments. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Emissions from B crude / condensate fixed roof LACT storage tanks Emissions of non -criteria pollutants due to combustion of waste gas is accounted for in respective AIRS Points 003 & 008. Manufacturer: John Zink Model No.: LHT-3-24-30-X-1/10-1/10-X Company equipment Identification No. (optional): For existing sources, operation began on: Flare Serial No.: 9123952 10/11/2012 For new or reconstructed sources, the projected start-up date is: El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Seasonal use percentage: Dec -Feb: Mar -May: Jun -Aug: Sep -Nov: Form APCD-200 - General APEN - Revision 12/2014 2 co1,ORAoo rairetruwe Npi*iiaHenwant Permit Number: 12WE1016 AIRS ID Number: [Leave blank unless APCD has already assigned a permit l and AIRS IDi Section 4 - Processing/Manufacturing Information £t Material Use ❑ Check box if this information is not applicable to source or process From what year is the actual annual amount? 2019 Material _. Consumption.• 123 /9581/O05 Design Process . Rate (Specify;iln�ts) Propane & VOC vapors 39 MMbtu/hr Actual Annuai Amount '_ (Specify Units), 0 ;Requested Annual's Permif`Umtt5 (Specify Units) 30,000 gal/yr propane Controlled VOC emissions 39 MMbtu/hr 5 Requested values wil become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including ADEN updates. Sections - Geographical/Stack Information Geographical Caordi.nates.: (LgtkiidelLangltude o t..,7MJ< uTM Zone 13: Easting - 511,271. Northing - 4,478,409 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. J o eratar Stacpk 1l7 blo Discharge Height oe o AbXGruntl Level %mp () flow Rafe {AGF�ls�`; Ye[octt {ftlecj _ - __.400 ._. ., ..:,8,401) 3 005 30 - .., r ..1 . Indicate the direction of the stack outlet: (check one) {]✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): indicate the stack opening and size: (check one) 0 Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): l] Other (describe): ❑ Upward with obstructing raincap 24 Interior stack depth (inches): Form APCD-200 - General APEN - Revision 12/2019 31 COLORADO 4,6 Permit Number: 12WE 1 0 1 6 AIRS ID Number: 123 [9581/005 (Leave blank unless APCD has already assigned a permit tt and AIRS ID] Section 6 - Combustion Equipment tfi Fuel Consumption information ID Check box if this information is not applicable to the source (e,g, there is no fuel -burning equipment associated with this emission source) Design Inpufi Rate ?. Immaru/hr} `Actual annual Fuel Use :` (Specify Units) - , .. tetl Annual hermit Limrt5.; (Specify Units) , 39 0 30,000 gal/yr propane From what year is the actual annua fuel use data? indicate the type of fuel used': I] Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCP) ❑ Field Natural Gas Heating value: BTU/SCF ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑✓ Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑ Coal Heating value: BTU/lb Ash content: Sulfur content: ❑ Other (describe): Heating value (give units): 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Section T - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? iI Yes El No If yes, describe the control equipment AND state the coilection and control efficiencies Pollutant ,. Control Equtpinen•t--,...,..,...„.„-,..,...........,.:„.:,..................,•,...ollecti .:pes • --- - on Efficiency (% f total eissions ctured by control equipment} Control Efficiency (% reductroir of captured em(s;ions} .,,. _ _ ...........:. TSP (PM) PMIQ PM2.s SO. NO. CO VOC John Zink Flare 95% Other: Form APCD-200 - General APEN - Revision 12/2019 4 4 AlsocoLoRADo n« ni`m m�°�eu TSP (PM) Permit Number: 12WE 101 G AIRS ID Number: 123 /9581/005 [Leave blank unless APCD has already assigned a permit ;' and AIRS ID] From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled `. Emission POCtOC ;,`(Specify elntts)...,, Emission Factor:: l?; Source` (AP 42, Aifs , Controlledt:s (tonslyenr) Uncontrolled . (tonsfyear) Controlled (tons/ year) Uncontrolled. (tgr)Or ar); PMia PM2.s SOX 0.6 I b/MMscf AP -42, Table IA -2 0 0 0.17 0.17 NOx 0,0334 lb/1000 gal Manufacturer 0 0 3.63 3.63 CO VOC 0.0835 lb/1000 gal X07-lbi Manufacturer 0 Propane slip 0 0 0 9.07 9.07 Other: 4.22 lb/gal 3.17 3.17 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on ail APENs, including APEN updates. 7 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? X If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) NLimher 110543 n -hexane Overall._ Uncon₹ratted. Controfi. �niission is IEfficrency factor (Speer fy Unrts):: 0% 1.8 lb/MMscf misS)Ori Factor Source (AP X622, Mfg , eti ) AP -42 Uncontrolled Actual :. Emissions (lbslyear)' Yes -g-No Controlled i Actual �missioo l (ibslyeai:) . 7 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. EJC per email rcvd 2/3/2021 EJC per email rcvd 2/3/2021 Form APCD-200 - General APEN - Revision 12/2019 COLORADO NmthtrCrtafeonmy:! Permit Number: 12WE 1016 AIRS ID Number: 123 /9581/ 005 [Leave blank unless APCD has already assigned a permit H and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. a E✓ 7 Signature of Legally Authorized Person (no dor or consultant) Date L2/2/ 2? -m Michael Key Senior Environmental Advisor Name (print) Title Check the appropriate box to request a copy of the: d Draft permit prior to issuance Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, ILC. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-61 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 OR (303) 692-3148 APCD Main Phone Number (303) 692-3150 Form APCD-200 - General APEN - Revision 12/2019 61 I ICOLORADO UtµkiFlntel Wbhe xoalih»zn i,enn en! Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Supplement to Air Pollutant Emission Notice (APED for Air Pollution Control Equipment SEE INSf'RUCTIONS ON RE 1. Facility Name and Location: For APCA use only Permit Number: 12WE1016 Windsor Loading Facility - 2030 Howard Smith Ave E. AIRS Point ID: 123/9581/005 2. Control Device: Type Make Model Serial Flare John Zink LHT-3-24-30-X-1/10-1/10-X 9123952 3. Date placed in service or last modified: 10/11/2012 4. Describe the control device. Attach a diagram of the system. Also attach copies of Operation and Maintenance Instructions supplied by the manufacturer. Sec attached Process Flow Diagram and Section 2.0 of the application. The O&M Plan is approved and on file with CDPHE 5. List the pollutants this equipment controls and the control efficiency foi• each pollutant on the table below. Attach documents to support the information. Pollutant Estimated / actual inlet pollutant concentration (Give Units) Emission capture efficiency, % Outlet pollutant p concentration (Give Units) Control Efficiency, o VOCs 743.20 tpy 99% 37.16 tpy 96% HAPS 20.05 tpy 99% 1.0 tpy 96% 6. Description of method of handling the collected material for reuse or disposal. No waste is collected or disposed of from the Flare. All materials are combusted. 7. Prepare a malfunction prevention and abatement plan for this pollution control system. Submit this plan with the application. This will be incorporated as a permit condition. The plan may include, but not limited to, the following: a. Operation variables such as temperature, flow rates, differential pressures, concentrations, and other vital parameters that will be monitored in order to detect a malfunction or breaktiuough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. b. Monitoring equipment used (temperature sensors, pressure sensors, GEMS). c. An inspection schedule and items or conditions that will be inspected. Inspection records will be maintained at the site. d. A maiptgnance plan to assure c�us compliance. Signature of Responsible Q tat (not a vendor or consultant) Michael Key Name of Responsible Official (Please Print) Revised July 2001 1,?/.211A)2-t, Date Senior Environmental Advisor Title httn://www.ednhe.state.co.us/an/stationary.ndf 2/3/2021 State.co.us Executive Branch Mail - CP 12WE1016 for Review STATE OF COLORADO CP 12WE1016 for Review Chavez - CDPHE, Elie <elie.chavez@state.co.us> Kevin Sokolowski <Kevin.Sokolowski@loves.com> To: "Chavez - CDPHE, Elie" <elie.chavez@state.co.us> Cc: Andrew Parisi <aparisi@spiritenv.com>, Nicki Neyrey <nneyrey@spiritenv.com>, Michael Key <Michael.Key@loves.com> Wed, Feb 3, 2021 at 10:21 AM Elie, I have no additional comments or questions on the draft or APEN redlines, everything looks good to me. Please proceed with public notipe. Thank you again for your help with this. Kevin Sokolowski From: Chavez - CDPHE, Elie <elie.chavez@state.co.us> Sent: Tuesday, February 2, 2021 11:05 AM To: Kevin Sokolowski <Kevin.Sokolowski@loves.com> Cc: Andrew Parisi <aparisi@spiritenv.com>; Nicki Neyrey <nneyrey@spiritenv.com>; Michael Key <Michael.Key@loves.com> Subject: Re: [EXT] CP 12WE1016 for Review Hi Kevin, Thank you so much for the attached spreadsheet - I have updated all HAPs to match the APCD form 102 with two exceptions: AIRS 002 - It doesn't look like the HAPs listed on the form APCD-102 include the (very small) roof landing loss contribution. Therefore, the HAPs on the updated draft permit (attached) are slightly higher, but have been adjusted to reflect the more correct HAP speciation profile. AIRS 003 - This is a very minor issue, but the HAPs listed on form APCD-102 were determined by dividing the controlled emissions (which match my calculations exactly) by 0.0496 (corresponding to a 99% capture efficiency and a 96% control efficiency = 95.04% CCE) instead of 0.05 (corresponding to a 95% CCE). Because we've used 95% for the other points in this application, I retained the 95% CCE for consistency. I did update the HAP speciation profile, but our numbers are still a little different. With the changes in HAP to the flare, I have updated the APEN redline previously provided - please find attached. Please confirm that this redline, along with the redlines previously provided for AIRS 002 and 003, look ok to you and I'll get these finalized and the permit off to public notice. Thanks again so much for all your help, Elie Chavez Permit Engineer Title V Operating Permit Unit Stationary Sources Program Air Pollution Control Division [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] https://mail.google.com/mail/u/0?ik=85031 f40e8&view=pt&search=all&permmsgid=msg-f%3A1690695527154876004&simpl=msg-f%3A16906955271... 1/1 Hello