HomeMy WebLinkAbout20203734.tiff X.C. COLORADO
=l Department Public RECEIVE D
�G� Health 8 Envirit onment
DEC 0 7 2020
WELD COUNTY
COMMISSIONERS
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
December 2, 2020
Dear Sir or Madam:
On December 3, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
Mountain TRAX Intermodal LLC - Mountain TRAX Terminal. 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
,FoF•Colds:
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I �f " :'h `.
}O'i
Jared Polls, Governor I Jill Hunsaker Ryan,MPH, Executive Director ` ,_I
Pu b I; C Re ':2(,) cc:P�(Tv) HC.(cs/re),pw(sn/eR/c++/c,K), 2020-3734
OG(SMi
12 /93/20 i2hs/2Q
C4 4:4 0 M Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
CDPHE
Comment
Website Title: Mountain TRAX Intermodal LLC - Mountain TRAX Terminal - Weld County
Notice Period Begins: December 3, 2020
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: Mountain TRAX Intermodal LLC
Facility: Mountain TRAX Terminal
Petroleum bulk stations and terminals
7300 47th Avenue, Evans, CO 80645
Weld County
The proposed project or activity is as follows: Mountain TRAX Terminal wishes to permit transloading of
hydrocarbon liquids from trucks to rail cars.
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 20WE0612 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.govtpacific/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.Rov/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:
Diego Chimendes
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
jejail COLORADO
1 I Department at Public
Hh&Etwironmertt
":,;- COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0612 Issuance: 1
Date issued: XX/XX/XXXX
Issued to: Mountain TRAX Intermodal, LLC.
Facility Name: Mountain TRAX Terminal
Plant AIRS ID: 123/9D6E
7300 47th Avernue
Physical Location: Evans, CO 80645
County: Weld County
Description: Petroleum bulk stations and terminals (SIC 5171)
Equipment or activity subject to this permit:
Equipment AIRS Emissions Control
ID Point Equipment Description Description
Truck loadout of hydrocarbon liquids -
Hydrocarbon condensate or crude oil - from tank
Liquids 006 trucks directly to rail cars. Emissions Vapor Balance System
Loadout are controlled using vapor balance
system.
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.aov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
Page 1 of 10
-r.Y COLORADO
_ Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
3. 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.
EMISSION LIMITATIONS AND RECORDS
4. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
Monthly Limits:
AIRS Pounds per Month Emission
Equipment ID
Point PM2.5 NO, VOC CO Type
Hydrocarbon
Liquids 006 --- --- 373 --- Point
Loadout
Note: Monthly limits are based on a 31-day month.
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.
5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
Annual Limits:
AIRS Tons per Year Emission
Equipment ID
Point PM2.5 NO,t VOC CO Type
Hydrocarbon Liquids 006 --- -- 2.2 --- Point
Loadout
Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Page 2 of 10
-r,•".I. COLORADO
il. 44011 Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
Compliance with the annual limits for criteria 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 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. (Regulation Number 3, Part B, Section III.E.)
Equipment ID AIRS Point Control Device Pollutants Controlled
Hydrocarbon Liquids 006 Vapor Balance System VOC and HAP
Loadout
PROCESS LIMITATIONS AND RECORDS
8. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rate must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, Section
II.A.4)
Process/Consumption Limits
Equipment AIRS Process Parameter Annual Limit Monthly Limit
ID Point (31 days)
Hydrocarbon Condensate or Crude
Liquids 006 Oil Loaded 1,000,000 barrels 84,932 barrels
Loadout
The owner or operator must calculate 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.
Page 3 of 10
.,.:,y COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
9. 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. (Regulation Number 1, Section II.A.1. Et 4.)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. 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:
§ IV.C.4.a. Rail cars shall be loaded only at facilities which allow for the following:
§ IV.C4.a.(i) A submerged fill pipe which reaches within 15.24 cm (6 in.) of the bottom
of the tank.
§ IV.C.4.a.(ii) Vapor collection and/or disposal equipment designated and operated to
recover vapors displaced during the loading of the rail car.
S IV.C.4.a.(iii) A vapor-tight seal around the tank car hatch and the loading equipment.
12. The petroleum transport trucks transferring products in° this site are subject to the
requirements contained in Regulation No. 7, Part B, Section IV. "Storage and Transfer of
Petroleum Liquid" including but not limited to:
S IV.C.4.b.(i) Dry-break loading and unloading nozzles are used and are compatible with
those required at loading facilities.
§ IV.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, transport and delivery.
S IV.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.
S IV.C.4.b.(v) Hoses, couplings, and valves are maintained to prevent dripping, leaking,
or other liquid or vapor loss during loading or unloading.
13. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division-approved report format. The information included in the annual
Page 4 of 10
:t:•, COLORADO
IP -446011 1140
Air Pollution Control Division
Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
14. 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 above in sections "Emissions Limitations and
Records", "Process Limitations and Records", and this section were determined to be RACT.
OPERATING 8 MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator must follow the most recent operating and
maintenance (0EM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to your O&M plan are subject to Division approval prior to implementation. (Regulation Number
3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. This permit replaces the following permits and/or points, which are cancelled upon issuance of
this permit.
Existing Permit Number Existing Emission Point New Emission Point
15WE0018 123/9D6E/001 123/9D6E/006
19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
Page 5 of 10
C ���»,- COLORADO
"4 Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t 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.
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.
20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
21. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in 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.
22. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation 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.
Page 6 of 10
COLORADO
iv., Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
23. 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.
24. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
25. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof 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 final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
Diego Chimendes
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Mountain TRAX Intermodal, LLC.
Page 7 of 10
•r,s”y 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
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 II.E.1 of the Common Provisions
Regulation. See.
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 Uncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
Benzene 71432 2017 26
Toluene 108883 14319 186
Ethylbenzene 100414 1553 20
006
Xylenes 1330207 20287 264
n-Hexane 110543 13807 179
224 TMP 540841 1267 16
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.
Page 8 of 10
c •4 COLORADO
t Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Uncontrolled Controlled Uncontrolled Controlled
Emission Emission Emission Emission
Pollutant CAS # Factors Factors Factors Factors Source
lb/bbl lb/bbl lb/Mgal lb/Mgal
AP-42 -
VOC 3.38x10-1 4.39x10-3 8.04 1.05 x10-1 Site
Specific
AP-42 -
Benzene 71432 2.02x10-3 2.62x10-5 4.80 x10"2 6.24 x10-4 Site
Specific
AP-42 -
Toluene 108883 1.43x10-2 1.86x10-4 3.41 x10"1 4.43E x10"3 Site
Specific
AP-42 -
Ethylbenzene 100414 1.55x10"3 2.02x10"5 3.70 x1O2 4.81 x10"4 Site
Specific
AP-42 -
Xylene 1330207 2.03x10-2 2.64x10"4 4.83 x10"1 6.28 x10-3 Site
Specific
AP-42 -
n-Hexane 110543 1.38x10-2 1.79x10-4 3.29 x10"1 4.27 x10-3 Site
Specific
AP-42 -
224 TMP 540841 1.27x10-3 1.65x1O5 3.02 x10-2 3.92 x10-4 Site
Specific
The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version
1/95) using the following values:
L = 12.46*S*P*M/T
S = 1.0 (Submerged Loading: Dedicated Vapor Balance Service)
P (true vapor pressure) = 6.59 psia
M (vapor molecular weight) = 50 lb/lb-mot
T (temperature of liquid loaded) = 510.39 °R
The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor.
Controlled emission factors are based on a vapor balance collection efficiency of 98.7%.
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
Page 9 of 10
r.Yy COLORADO
Air Pollution Control Division
Department of Public Health&Ervronment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, Xylene, and HAPs.
PSD True Minor Source of: CO a NOx.
NANSR Synthetic Minor Source of: VOC.
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
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 10 of 10
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details i For Division Use Only
Review Engineer: Diego Chimendes
Package#: 432499
Received Date: 6/19/2020
Review Start Date: 10/7/2020
Section 01-Facility Information
Company Name: Mountain TRAX I ntermodal,LLC Quadrant Section Township Range
County AIRS ID: 123
Plant AIRS ID: 9D6E
Facility Name: Mountain TRAX Terminal ,.
Physical
Address/Location: 7300 47th Avenue.Evans,CO 80645
County: Weld County
Type of Facility: Other(Describe facility type in Section 03)
What industry segment?Oil&Natural Gas Production&Processing
Is this facility located in a NAAQS non-attainment area? Yes
If yes,for what pollutant? Ozone(NOx&VOC)
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
Permit#
AIRS Point#
Emissions (Leave blank unless Issuance Self Cert
(Leave blank unless APCD Emissions Source Type Equipment Name Action Engineering
Control? APCD has already # Required? Remarks
has already assigned)
assigned)
Permit Initial Vapor Balance
006 Liquid Loading Not Provided Yes 20WE0612 1 Yes Issuance System
Section 03-Description of Project
Mountain TRAX Terminal submitted on 06/19/2020 APEN to permit transloading of hydrocarbon liquidsfrom trucks to rail cars.
Point source is APEN-required because uncontrolled VOC emissions are greater than 1 tpy and uncontrolled emissions of at least one non-criteria pollutant is greater
than 250 tpy.(Regulation 3 Part A Section 11.8.3.)Point source is permit-required because uncontrolled facility-wide VOC emissions are greater than 2 tpy.
(Regulation 3 Part B Section 11.8.2.).
This point source is subject to public comments because source is attempting to obtain a federally enforceable limit on the potential to emit of the source in order
to avoid other requirements.(Regulation 3 Part B Sections III.C.1.d.)
Point source is not subject to ambient air impact analysis.(Regulation 3 Part D Section II.A.44).
This facility is classified as a petroleum bulk stations and terminal(SIC 5171).
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? Requesting Synthetic Minor Permit
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-tMde Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(P50) —
Title V Operating Permits(OP) _ J �J
Non-Attainment New Source Review(NANSR) ✓
Colorado Air Permitting Project
...... .................. .........
Is this stationary source a major source? No
If yes,indicate programs and which pollutants: SO2 NOx CO VOC_PM2.5 PMS0 TSP HAPs
Prevention of Significant Deterioration(PSD) _ _ _ _
Title V Operating Permits(OP) Ei
Nan-Attainment New Source Review(NANSR) -
Hydrocarbon Loadout Erissions inventory
Section 01-Administrative Information
'Facility Allis ID: 123 906E 006,Coun[y Plant Point
Section 02-Equipment Description Details
Detaled Emissions Unit `Truck loadout of hydrocarbon liquids-condensate or crude oil from tank trucks directly to rail cars Emissions ontrolled using vapor
Description.
Emission Control Device - ' +y- '� - 't+r' k.F *
Description: Vapor Balance System
Is this load out controlled? Yes
Requested Overall VOC&HAP Control Efficiency%, 96.7 _ _ .
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Hydrocarbon Loadout
Actual Volume Loaded= 163,733 Barrels(bbl)per year
Requested Permit Limit Throughput= 1,000,000 Barrels(bbl)per year - Requested Monthly Throughput= 84932 Barrels IbblI per month 23809.52
Potential to Emit(PTE)Volume Loaded= 1,000,000 Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= _ etu/scf
Actual Volume of waste gas emitted per year= 419301 scf/year
Requested Volume of waste gas emitted per year= 2560883 scf/year
Actual heat content of waste gas routed to combustion device= 0 MMBTU per year
Requested heat content of waste gas routed to combustion device= 0 MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= 0 MMBTU per year
Control Device I I I
Pilot Fuel Use Rate, t2 �scfh 0.0 MMscf/yr
Pilot Fuel Gas Heating Value: Btu/scf 0.0 MMBTU/yr
Section 04-Emissions Factors&Methodologies
Does the company use the state default emissions factors to estimate emissions? '"te-
Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being .
permitted? I ard:A site specific stabilized hydrocarbon liquid sample must be provided to develop a site specific emissions factor.
Loading Loss Equation
L=12.46°S°P•M/T
Factor Meaning Value Units Source
S Saturation Factor 1 j"r4'w5" i AP-42 Chapter 5.2 Table 5.2-1 Submerged Loading:Dedicated VaporBalance Service(5=1)
P True Vapor Pressure 6.59 psis AP-42 Chapter 7-Site-specific data.
M Molecular Weight of Vapors SO Ib/Ib-mol AP-42 Chapter 7
T Liquid Temperature 510.39 Rankine Site-specifc data
L Loading Losses 8.04 lb/3000 gallons AP-42 Chapter 5.2 Equation 1
0.33785 lb/bbl
Component Mass Fraction Emission Factor Units Emission Factor Units
Benzene 0.60% 2.017E-03 lb/bb 0.0480 b/Mga
Toluene 4.24% 1.432E-02 lb/bb 0.3409 b/Mga
Ethylbenzene 0.46% 1.553E-03 lb/bb 0.0370 b/Mga
Xylene 6-00% 2.029E-02 lb/bb 0.4830 b/Mga
n-Hexane 4.09% 1.381E-02 Ib/bb 0.3287 b/Mga
224TMP :0,38% 1.267E-03 lb/bb 0.0W2 b/Mga
Emission Factors Hydrocarbon Loadout Hydrocarbon Loadout
Uncontrolled Controlled Uncontrolled Controlled
Emission Factor Source
Pollutant
(lb/bbl) (lb/bb)) (Ib/Mgal) )Ib/Mgai)
(Volume Loaded) (Volume Loaded) (Volume Loaded) (Volume Loaded)
VOC 3.38E-01 4.39E-03 Site Specific-AP-42::Chapter 5.2,Equation). 8.04E+00 1.05E-01
Benzene 2.02E-03 2.62E-OS Site Specific•AP-42 Chapter 5.2,Equation 1 4.80E-02 6.24E-04
Toluene 1.43E-02 186E-04 Site Specific-UP-42:Chapter 5.2,Equation l 3.41E-01 4.43E-03
Ethylbenzene 1.55E-03 2.02E-05 Site Specific-AF-42,Chapter 3.2,Equation1 3.70E-02 4.81E-04
Xylene 2.03E-02 2.64E-04 500 Specific-AP-42:Chapter 5.2,Equation 1 4.83E-01 6.28E-03
n-Hexane 138E-02 1.79E-04 Site Specific-AP-42,Chapter 5.2,Equation 1 3.29E-01 4.27E-03
224TMP 1.27E-03 1.65E-05 Site Specific-AP-HZ:Chapter S.2,Equation.1 3.02E-02 3.92E-04
Control Device
Pollutant Uncontrolled Uncontrolled Emission Factor Source
)Ib/MMBtu) (lb/bbl)
(waste heat combusted) (Volume Loaded)
PM10 0.00E+00
PM2.5 - 0.00E+00
500 0.00E+00
NOx 0.00E+00 4
CO 0.00E+00 .€
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant )Ib/MMBtu) (lb/MMscf) Emission Factor Source
(Pilot Gas
(Waste Heat Combusted) Throughput)
PM10 0.0000
PM2.5 0.0000 }
sox o.000B
NOx 0.0000
VOC 0.0000
CO - 0.0000 ., .,
3 of 7 NAPA\2020\20W E0612.CP1
Hydrocarbon L oftdout Emissions Inventory
i
•
•
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits ♦.
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled -
(tons/yeatl (tans/year) Icons/year) (tons/year) (tons/year) (Ibs/month)
PM10 0.00 0.00 0.00 0.00 0.00 0
PM2.5 0.00 0.00 0.00 0.00 0.00 0
50x 0.00 0.00 0.00 0.00 0.00 0
NO5 0.00 0.00 0.00 0.00 0.00 0 .
VOC 168.92 27.66 0.36 168.92 2.20 373
CO 0.00 0.00 0.00 0.00 0.00 0
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
libs/year) (Ibs/year) (Ibs/year) (Ibs/year) (Ibs/year)
Benzene 2017 330 4 2017 26
Toluene 14319 2344 30 14319 186
Ethylbenzene 1553 254 3 1553 20
Xylene 20287 3322 43 20287 264
n-Hexane 13807 2261 29 13807 179
224 TMP 1267 207 3 1267 16.
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B - Source requires a permit
Regulation 7 Part 0 Section II.C.5. The hydrocarbon liquids loadoot source is not subject to Regulation 7 Part 0 Section II.C.5.
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Requirements
Does the company request a control deuce efficiency greater than 95%for a flare or combustion device? { t Ogf,'Y. *'.e
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08-Technical Analysis Notes
1 Emissions from the loading operations were estimated using Equation l from AP-42 Section 5.2.CIPHE PS Memo 14-2 defines products with an API gravity greater than or equatto 417.as condensate and products less than 40.as crude.Operator provided a hydrocarbon squids lab
re
sult from a liquid withAPI gravity 57.42 @ 60 F;however,transloading operations will handle both condensate and crude oil liquids Emission calculations where then carried with a"condensate sample"which is acceptable since it will result in more conservative numbers.
Equipment description will include both crude and condensate.
2.Operator applied a 1.2 factor to HAPs emissions.Although unusual,this is a conservative approach to emissions calculatio its,therefore acceptable"
3.Compliance with emission limits,process limits,control equipment included In the permit along with applicable provisions of Regulation 7,Part H Section IV wasdetermined to be fulfillment of RACE.
C.According tote operator,an electric motors used to drive the condensate transloader pump.
5 A copy of the permit draft was provided to the operator for review..Operator provided the following comments:(I)about se ction 4"Since the HAPs at the facility are all VOC,Im not sure this limit is mean ingful since V0Cs are limited to 373 pounds per mo nth.and(ii)about Notes
to Permit Holder 8 operator brought attention to a typo in the regulation.Explanation was provided to the operator about the needto provide limits to the OAPs emissions since this is a HAPs synthetic minor facility and to justify the absence of requirementsto track insignificant
sources.Typo was corrected.Operator approved changes on 11/24/2020.
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
Uncontrolled
AIRS Point It Process 0 SCC Code Pollutant Emissions Factor Control% Units
006 01 4-06-001-42 Crude Oil:Submerged Loading Balanced Service(S=1) PM20 0.00 0 6/1,000 gallons transferred
PM2.5 0.00 0 b/1,000 gallons transferred
SOx 0.00 0 b/1,000 gallons transferred
NOx 0.00 0 6/1,000 gallons transferred
VOC 8.0 99 b/1,000 gallons transferred
CO 0.00 0 6/1,000 gallons transferred
Benzene 0"05 99 6/1,1100 gallons transferred
Toluene 0.34 99 6/1,000 gallons transferred
Ethylbenzene 0.04 99 6/1,000 gallons transferred
Xylene 0.48 99 6/1,000 gallons transferred
n-Hexane 0.33 99 6/1,000 gallons transferred
224 TMP 0.03 99 b/1,000 gallons transferred
•
4 of 7 K:\PA\2020\20W E0612.CP1
Hydrocarbon loed7ut Regulatory Analysis Worksheet
The regulatory requirements below ore determined based on requested emissions and throughput. _
Colorado Regulation 3 Parts A and a•APEN and Permit Requirements
ISa _..:..on Alta,mm._.,inn
ATTAINMENT
1.Are antrdied actual emissions Iron ria polutanb from this individual sourreaTPY( Part h Secon 11.0.1.4?2. I80E:
uction site(e.g well pad)(Regulationartn ll.O.3. than 10,000 gallons(136 BMA orcrudl pean annasis?4. than 6,750 hbls per year of condensat spa s 611 pater than STPY,NO8 greater than lO TPY or CO emissions greaer than TOTPY(Regul.don 3,Part 6,section 6.0.31?
Iron 1 . n ,.ow m.d that 77 .rh.rm I7Inment woe
NON-ATTAINMENT
1.Are trolled emissions from any criteria pollutants from thisirdloldual source greater than 17Y(Regulafion 3,Pe00,Sec Son 11.2.5.8)? *kW*Go to next q 010 ues)
2. Is the loadout located at an exploration and p100uction site(e.g.,well pad)1Regula0003,0ar16,6.788 11.¢1.1)? 020';=2 10 Go to question 6
3. Is the lwdout operation loading less than 10,000 gallons 1238 BOW)of crude di per day an an annual average hasis?
a. Is the Iwdou t lanes tiw loading less.than 6,750 bb s per year of condensate via splash 6I?
5. Is the lwdout operation loading less than 16,308 bhis perm?of condensate Wa submerged fill procedure?
6 Are total facility uncontrolled VOC emissions from the greater Nan 2 TPY,505 greater than 5 TPY or CO emissions greater than 10 TM/IReguiatlon3 Part 3,Section 11.0.2)? rs .The lwdout requires a permit
Colorado Regulation 7 Part D Section 11.x5.
1.Isnds condenate storage lank hydrocarbonliquids loadyutloca0d at a well production facilFIY,natural gas compressor staobn or natural gas processing plant, is rotzubie 075 Regulation)Pare OSestion 111 5.
2 Does facility h fhyd Idsotl transport vehicles tla equalto5,000 barrels? Source a subeRto 658311507 PdrtDSec60011.CS.
•
Disclaimer
This dxuncnt assists operator with determining applicability of certain tequrcvrants of the Clean A0 Act.its impknx.Mirg regulations.are Air Qualiy Combo!Commission r guletla5C This dxurantis not
rvkortegeletion,and the anraysis it contains may not apply to aparticuar satiation basedupon the individual facts and citremstaocu This&cumert dos rot chsrgem substitute l eny law,regulations
any other legally binding rs?u ement and is not Iega1N enforceable.In the evert ci any contact behveen the language of this dxumeu and the lerguege tithe Clean Air Act„its implementing reguletloos,
and Air Quality Control Commission regulations,the language d the statute or regulation wlll control The use non-mandatory language such as 5aoommarel,""mey,."should,"end"can,"Is intended to
describe APCD Interpretations and recommendatbas.Mandatary terminology such as"must"and"waited'are intended ts describe controlling requirements under the terra of the Clean Air Act and Air
Quality Coned Commission regulations,hut ths dxanont does not establish legally hinting requirements in sine/tldsetl.
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name Mountain TRAX Intermodal,LLC
County AIRS ID 123 History File Edit Date _ 11/2412020
Plant AIRS ID 9D6E Ozone Status Non-Attainment
Facility Name Mountain TRAX Terminal Last Modified By: Diego Chimendes
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS ID VOC HAPs VOC HAPs
Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 1,746.5 18.6 0.0 41.1 0.0 0.0 0.0 0.0 0.0 78.4 18.6 0.0 2.3
Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 1,746.5 18.6 0.0 41.1 0.0 0.0 0.0 0.0 0.0 78.4 18.6 0.0 2.3
051 1SWEOO18.ON Truck loadout = 0.0 d.0 Cancelled.
002 15WE0018.CN Truck loadouf 0:0 0 0 Cancellation recd 1/15/2020-removed.
003 15WE0018.CN.XA Fugitive emissions 0.2 0.0 0.2 0.0 No change.
004 15WE0018.CE 2-95,000 bbl condensate tanks. -0.0 , 0:0 Cancellation rec'd 1/15/2020-removed.
005 15WE0018:0N 2.95,000 bbd crude oil tanks 0.0 ' „�. s 0.0 Cancellation reed 1/15/2020-removed
006 20WE0612 Crude oil and/or condensate loadout from 168.9 26.6 2.2 0.3 Puinl added and updated on 10:07/2020.DC
tank trucks directly to rail cars.
70/07/'2020
0.0 _ 0.0
XA NGLs Transloading 0.5 0.0 0.5 0.0 Insignificant Source
0.0 0.0
0.0 0.0
0.0 0.0
0.0 0.0
FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 169.4 0.2 0.0 26.6 0.0 0.0 0.0 0.0 0.0 2.7 0.2 0.0 0.3 VOC: Syn Minor(NANSR and OP)
NOx:Minor(NANSR and OP)
CO: Minor(PSD and OP)
HAPS: Syn Minor Xylene and Total
HH: Syn Minor affected Area
7777; NA
Permitted Facility Total 0.0 0.0 0.0 0.0 0.0 168.9 0.0 0.0 26.6 0.0 0.0 0.0 0.0 0.0 2.2 0.0 0.0 0.3 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions 0.0 0.0 0.0 0.0 0.0 -76.2 -18.6 0.0 -2.0
Pubcom is required because because source is
attempting to obtain a federally enforceable limit on
the potential to emit of the source in order to avoid
other requirements(VOC<50 tpy).Modeling not
required because of change in emissions.
Total VOC Facility Emissions(point and fugitive) 2.9 Facility is eligible for GPO2 because<90 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) -94.8 Project emissions less than 25/50 tpy
Note 1
Note 2
Page 6 of 7 Printed 11/24/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs -
Company Name Mountain TRAX Intermodal,LLC
County AIRS ID 123
Plant AIRS ID 996E
Facility Name Mountain TRAX Terminal
Emissions-uncontrolled(lbs per year) _
POINT'PERMIT I Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy)
Previous FACILITY TOTAL 0.0 0.0 7.4 0.0 20.7 3.1 9.9 0.0 0.0 0.0 0.0 0.0 41.1
001 ;15WE0018.CN Truck loadout 0.0
002 15WE0018.CN Truck loadout 0:0'
003 15WE0018.CN XA Fugitive emissions 0.0
004 15WE0018.CN 2-95,000 bbl condensate tanks 0.0
005 15WE0018.CN 2-95,000 bbl crude oil tanks 0.0
006 20WE0612 Crude oil and/or condensate loadout from 2017.0 14319.0 1553.0 20287.0 13807.0 1267.0 26.6
tank trucks directly to rail cars. _
0.0
XA NGLs Transloading 0.0
0.0
0.0
0.0
0.0
TOTAL(tpy) 0.0 0.0 0.0 1.0 7.2 0.8 10.1 6.9 0.0 0.6 0.0 0.0 26.6
*Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Red Text: uncontrolled emissions<de r'nisimus
Emissions with controls(lbs per year)
POINT'PERMIT I Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy)
Previous FACILITY TOTAL 0.0 0.0 0.4 0.0 1.1 0.2 0.5 0.0 0.0 0.0 0.0 0.0 2.3
001 15WE0018.CN Truck loadout 0.0
002 15WE0018.CN Truck loadout 0.0
003 15WE0018.CN.XA Fugitive emissions 0.0
004 15WE0018.CN 2-95,000 bbl condensate tanks 0.0
005; 15WE0018.CN 2=95,000 bbl crude oil tanks 0.0
006 20WE0612 Crude oil and/or condensate loadout from 26.2 186.1 20.2 263.7 179.5 16.5 0.3
tank trucks directly to rail cars.
0.0
XA NGLs Transloading 0.0
0.0
0.0
0.0
0.0
TOTAL(tpy) 0.0 0.0 0.0 0.0 0.1 0.0 0.1 0.1 0.0 0.0 0.0 0.0 0.3
7 20 W E0612.CPI 11/24/2020
Superseded -See attached addendum received on 10/20/2020. DC 10/20/2020.
•
84,
/
Hydrocarbon Liquid Loading APtN,r„ . ""'
Form APCD-208
CDPHE 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 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: fi00-48 3 JEO(i 2. AIRS ID Number: 123 / 9D6E
A _i:l a .._1 i. v_..
Section 1 - Administrative Information
Company Name': MountainTRAX Intermodal LLC
Site Name: Mountain TRAX Terminal
Site Location
Site Location:
7300 47th Avenue County: Weld
Evans, CO 80645
NAICS or SIC Code: 5171
Mailing Address:
(Include Zip Code) 800 8th Ave, Ste 122
Greeley, CO 80631 Contact Person: Trevin Hogg
Phone Number: 303-656-8260
E-Mail Address2: thogg@mountaintraxrail.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 e-mail to the address provided.
432497
® A COLOR00
t (fil APCD-208 —s`{,�{:�ct11 fJl _fit 7 ;�li APE'4 :'�.Jfl lam;ZU1 �umoaniwe
armOrH.ua.e.rt
Permit Number: 15WE0018 AIRS ID Number: 123 /9D6E/001
_.._.0 i,l s �AP:;i: J.,,I Flt .,_ti.r t AIRS i
Section 2 - Requested Action
O NEW permit OR newly-reported emission source
O Request coverage under construction permit O 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-
Q MODIFICATION to existing permit (check each box below that applies)
r❑ Change fuel or equipment O Change company name3
❑ Change permit limit O Transfer of ownership' ❑ Other(describe below)
-OR-
0 APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
E] Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info Et Notes: Loading operations began at this site on December 30, 2019.
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: Transloading of crude from truck to rail by manifest process.
Emissions are controlled by a vapor balance system.
Company equipment Identification No. (optional):
For existing sources, operation began on: 2019-12-30
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area? El Yes O No
Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes D No
emissions?
Does this source load gasoline into transport vehicles? O Yes 0 No
Is this source located at an oil and gas exploration and production site? ❑ Yes 0 No
If yes:
Does this source toad less than 10,000 gallons of crude oil per day on an annual ❑ Yes O No
average?
Does this source splash fill less than 6,750 bbl of condensate per year? O Yes ❑ No
Does this source submerge fill less than 16,308 bbl of condensate per year? O Yes O No
'COLORADO
Form APC�° 20v iF?it=,3f ben .4{F LU2d i 1 eauem.+ e
Permit Number: 15W E0018 AIRS ID Number: 123 /9D6E/001
Section 4 - Process Equipment Information
Product Loaded: 0 Condensate ❑✓ Crude Oil D Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5: 1,000,000 bbl/year Actual Volume Loaded: 0 bbl/year
This product is loaded from tanks at this facility into: tank trucks into rail cars
(e.g. "rail tank cars"or"tank trucks")
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor: 1 0 Average temperature of 50 °F
bulk liquid loading:
True Vapor Pressure: 6.59 Psia @ 60 `F Molecular weight of 50 lb/lb-mol
displaced vapors:
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5: NA bbl/year Actual Volume Loaded: NA bbl/year
•
Product Density: NA lb/ft3
Load Line Volume: NA ft3/truckload Vapor Recovery Line Volume: NA 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 APEN5,including APEN updates.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.331861/-104.751677
I]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.
Operator Discharge Height Above Temp. Flow Rate Velocity
Stack ID No. Ground Level(Feet) ('F) (ACFM) (ft/sec)
NA NA NA NA NA
Indicate the direction of the stack outlet: (check one)
❑Upward ❑ Downward ❑Upward with obstructing raincap
❑Horizontal I]Other(describe): Fugitive
Indicate the stack opening and size: (check one)
❑Circular Interior stack diameter(inches):
0 Square/rectangle Interior stack width (inches): Interior stack depth(inches):
❑Other(describe):
COLORADO
Form APCD-2O8 "3y`eroca"r r L::i.id Loading APEN Re,'�.S�nl 12 2319 3 I S® • .• "um„i°ma
O
Permit Number: 15WE0018 AIRS ID Number: 123 /906E/001
�u_*,,,,ntess Al.D asSigned 3p,frr7t ,r7;u_
Section 6 -Control Device Information
0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
0 Loading occurs using a vapor balance system: Requested Control Efficiency: 98.7
Used for control of:
Rating: MMBtu/hr
Combustion Type: Make/Model:
❑ Device: Requested Control Efficiency: %
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature: 'F Waste Gas Heat Content: Btu/scf
Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: MMBtu/hr
Pollutants Controlled:
❑ Other: 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? 0 Yes 0 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):
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured
by control equipment) emissions)
PM
SOX
NOx
CO
VOC
HAPs
Other:
❑ Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane
❑Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.O036 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? N/A
Use the following table to report the criteria pollutant emissions from source:
Requested Annual Permit
Emission Factor Actual Annual Emissions
Emission Limit(s)s
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (4'42, Emissions Emissions6 Emissions Emissions
Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
PM
SOX
NO.
CO
VOC 8.04 Ib/Mgal AP.42 Chap 5 16673 220
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.
4�Form ' Ise COLORADO
t,.Fir✓-�l:ti� - :G?CiCc1(t'it,.i Liquid I.J�CI'1Q APEN �'. � ;!,� � ��CUi`r
Permit Number: 15W E0018 AIRS ID Number: 123 /9D6E/001
Section 8 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteriaEl yes ❑ No
pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year?
If yes,use the following table to report the non-criteria pollutant(HAP)emissions from source:
Chemical Emission Factor Actual Annual Emissions
Abstract Source Uncontrolled Controlled
Chemical Name Uncontrolled
Service(CAS) Basis Units (AP-42, Emissions Emissions6
Number Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 0.05 Ib/Mgal AP-42/Mass Bat 1.987 26
Toluene 108883 0 34 Ib/Mgai AP-42/Mass Bat 14.311 186
Ethylbenzene 100414 0.04 tb/Mgal AP-42/Mass Ba• 1.541 20
Xylene 1330207 046 Ib/Mgat AP-42/Mass Bat 20,271 264
n-Hexane 110543 0 33 Ib/Mgal AP-42/Mass Bat • 13,784 179
2,2,4-Trimethylpentane 540841 003 Ib/Mgal AP-42/Mass Bat 1.257 16
Other:
6 Annual emission fees will 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 ' fullRompliance with each condition of General Permit GP07.
`— - moo_ 11 Jun 2020
Signature of Legally Auth6rized Person(not a vendor or consultant) Date
Trevin Hogg General Manager
Name(print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
0 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 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175
Air Pollution Control Division OR
APCD-SS-B1 (303)692-3148
4300 Cherry Creek Drive South
Denver,CO 80246-1530 APCD Main Phone Number
(303)692-3150
Make check payable to:
Colorado Department of Public Health and Environment
5 I taw COLORADO
June 11,2020
MOUNTAIN
TRAX
Colorado Department of Public Health and Environment
Air Pollution Control Division, APCD-SS-B1 ,,t..
4300 Cherry Creek Drive South N(1t
Denver,CO 80246-1530 QZt1 ,
Ref MountainTRAX Intermodal LLC
Mountain TRAX Terminal
Formerly ARB Midstream Permit No. 15WE0018,Airs ID No. 123/9D6E
APEN Application
Dear Sir or Madam:
MountainTRAX Intermodal LLC (MTI) is pleased to present this APEN Renewal application package
for the Mountain TRAX Terminal (Formerly ARB Midstream's Niobrara Connector). MTI has made
the following changes to the facility in this application:
• The only APEN being renewed at this time is 001. The fugitive emissions are permit exempt.
• APEN 001 (Crude Oil Transloading) has updated for throughput, emissions calculations and
Hazardous air pollutant(HAP) speciation data.
• Emissions for the fugitive emissions and NGL butane transloading have been included to
demonstrate that these sources are APEN exempt. The previous permit indicates that the
facility is subject to Regulation 7,Sec XVII.F,but it is neither a natural gas compressor station
nor a well production facility.
The following items are attached to this letter: Process Description,Site Map,Emissions Calculations,
Representative Crude Sample, Regulatory Analysis,APEN Forms,and Fees.
If you should have any questions regarding this information,please contact me at 303-656-8260 or
thogg@mountaintraxrail.com.
Sincerely,
l
Mr.Trevin Hogg
General Manager
MountainTRAX
Attachments as Listed Above
MOUNTAIN-----TRAX--- 7300 47th Ave, Evans,CO 80645 • 800 8th Ave, Ste 122,Greeley,CO 80631
Received on 10/20/2020. DC 10/20/2020.
Hydrocarbon Liquid Loading APEN
-411 Form APCD-208
COME 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 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: 20WE0612 AIRS ID Number: 123 / 9D6E /006
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 1 - Administrative Information
Company Hamel: MountainTRAX Intermodal LLC
Site Name: Mountain TRAX Terminal
Site Location
Site Location: 7300 47th Avenue County: Weld
Evans, CO 80645
NAICS or SIC Code: 5171
Mailing Address:
(Include Zip Code) P.O. Box 2067
Fort Collins, CO 80522 Contact Person: Trevin Hogg
Phone Number: 303-656-8260
E-Mail Address2: thogg@mountaintraxrail.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 e-mail to the address provided.
qI (COLORADO
Form APCD-208 Hydrocarbon Li uid Loading APEN - Revision 12/2019 1 . n
Permit Number: 20WE0612 AIRS ID Number: 123 /9D6E/006
[Leave blank unless APCD has already assigned a permit#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
❑ Change permit limit ❑✓ Transfer of ownership' ❑ 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 at Notes: Loading operations began at this site on December 30, 2019.
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: Transloading of crude from truck to rail by manifest process.
Emissions are controlled by a vapor balance system.
Company equipment Identification No. (optional):
For existing sources, operation began on: 2019-12-30
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No
Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes ❑✓ No
emissions?
Does this source load gasoline into transport vehicles? 0 Yes ❑✓ No
Is this source located at an oil and gas exploration and production site? 0 Yes ❑✓ No
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual ❑ Yes 0 No
average?
Does this source splash fill less than 6,750 bbl of condensate per year? ❑ Yes 0 No
Does this source submerge fill less than 16,308 bbl of condensate per year? ❑ Yes 0 No
COLORADO
Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 12/2019 2 I sliV.MY.Health n,r"n' ",
Permit Number: 20WE0612 AIRS ID Number: 123 /9D6E/006
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: 0 Condensate 0 Crude Oil ❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5: 1,000,000 bbl/year Actual Volume Loaded: 163733 bbl/year
This product is loaded from tanks at this facility into: tank trucks into rail cars
(e.g. "rail tank cars"or "tank trucks")
If site specific emission factor is used to calculate emissions, complete the following:
Average temperature of
Saturation Factor: 1 .0 50.72 °F
bulk liquid loading:
True Vapor Pressure: 6 59 Psia @ 60 °F Molecular weight of 50 lb/lb-mol
displaced vapors:
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5: NA bbl/year Actual Volume Loaded: NA bbl/year
Product Density: NA lb/ft3
Load Line Volume: NA ft3/truckload Vapor Recovery Line Volume: NA 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 APEN5,including APEN updates.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.331861/-104.751677
0 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.
Operator Discharge Height Above Temp. Flow Rate- -Velocity
:Stack ID_No Grourtcit.evel(Feet) (`F) (ACFM) (ftlsec)
NA NA NA NA NA
Indicate the direction of the stack outlet: (check one)
❑ Upward 0 Downward 0 Upward with obstructing raincap
❑ Horizontal ❑✓ Other(describe): Fugitive
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter (inches):
❑Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑ Other(describe):
gurkICOLORAoO
Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 12/2019 3 I E: `r,
Permit Number: 20WE0612 AIRS ID Number: 123 /9D6E/006
[Leave btank untess APCD has already assigned a permit-and A;PS'.0
Section 6 - Control Device Information
0 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: 98.7
Used for control of:
Rating: MMBtu/hr
Combustion Type: Make/Model:
❑ Device: Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature: °F Waste Gas Heat Content: Btu/scf
Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: MMBtu/hr
Pollutants Controlled:
❑ Other: 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 0 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):
Collection Efficiency. Control Efficiency:
Pollutant Control Equipment Description (%of,total emIssions captured , (%reduction of captured
by control equipment) ` emissions)
PM
SOX
NO.
CO
VOC Vapor Balance System 98.7
HAPs Vapor Balance System 98.7
Other:
❑ 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? 2020
Use the following table to report the criteria pollutant emissions from source:
Emisston'Factor Actual Annual Emissions` Requested Annual Permit
Emission Limit(s)s
Pollutant Source Uncontrolled cControllec Uncontrolled Controlled
Uncontrolled Units (AP-42, Emissions Em ssions Emission's Emissions
asfs Mfg.,etc.)
(Eons/year)' (tonslyearr} F(fons/year') ¢tonslyear)
PM
SOX
DC 11/05/2020.Per
NOX a,tached email.
CO
VOC 8 04 0 338 k5 m.0.ih/ht' AP-42 Chap 5 27.66 0.36 168.92 2.20
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.
._. .. _.. ._. .. _. _... _.. _.__ COLORADO
Form APCD-208- Hydrocarbon Liquid Loading APEN- Revision 12/2019 4 l i l+eahh E E�rzonm6nt
Permit Number: 20WE0612 AIRS ID Number: 123 1906E1 006
[Leave blank U^less APC0 h:i;already...,-.;;;red a permit a alld AIRS IDl
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:
Chemical Emission Factor Actual Annual Emissions
Abstract Source Uncontrolled Controlled
Chemical Name Uncontrolled
Service(CAS) Units (AP-42, Emissions Emissions6
Number Basis Mfg.,etc.) (lbs/year) DC 11/09/2020 Per attached
y ) ((bs/year) email
Benzene 71432 064800.00202 Ib4Mgallb/bbl AP-42/Mass Bal I 2.017 26
Toluene 108883 834090 0143 lb/Mga{Ib/bbl AP-42/Mass Bal 14,319 186
Ethylbenzene 100414 0-03700 c0155 le+Mgal'b/bbl AP-42/Mass Hal 1.553 20
Xylene 1330207 0-0880 0 0203 Ie gal lb/bbl AP-42/Mass Bal 20,287 264
n-Hexane 110543 03288 0.01381 lb/Mgallb/bbl AP-42/Mass Bal I 13.808 180
2,2,4-Trimethylpentane 540841 e0302o 001271 ISIMgaylb/bbl AP.42/Mass Bal 1.267 16
Other:
6 Annual emission fees will 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 ' full compliance with each condition of General Permit GP07.
Rev. 10/20/2020
Signature of Ley Authorized Person(not a vendor or consultant) Date
Trevin Hogg General Manager
Name(print) Title
Check the appropriate box to request a copy of the:
Q Draft permit prior to issuance
I]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 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175
Air Pollution Control Division OR
APCD-SS-B1 (303)692-3148
4300 Cherry Creek Drive South
Denver, CO 80246-1530 APCD Main Phone Number
(303)692-3150
Make check payable to:
Colorado Department of Public Health and Environment
COLORADO
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 12/1019 5 I .�I :>s ,
Hello