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Home My WebLink About20180432.tiffRevleu) ©a-ra -l8 COLORADO Department of Public Health f:~ Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 February 5, 2018 Dear Sir or Madam: RECEIVED FEB 0 8 2018 WELD COUNTY COMMISSIONERS On February 8, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Saddle Butte Rockies Storage E. Terminals, LLC - Lucerne Crude Oil 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 >:t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Cc• PLC MMITP);, NL CST), PW CER /CNIJ'M/CK) oa-Ia-r8 2018-0432 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Saddle Butte Rockies Storage Et Terminals, LLC Lucerne Crude Oil Terminal - Wetd-County Notice Period Begins: February 8, 2018 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: Saddle Butte Rockies Storage Et Terminals, LLC Facility: Lucerne Crude Oil Terminal Crude Oil Terminal NWSW Section 26 T6N R65W Weld County The proposed project or activity is as follows: change the size of the breakout tanks from 400 -bbl to 750- bbl each, and increase the maximum throughput of oil loaded out by truck. No changes to other points already on this permit. 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): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the 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 16WE0318 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. Any such comment must be submitted in writing to the following addressee: Andy Gruel Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us "Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package It: Received Date: Review Start Date: Section 01- Facility Information Company Name: Saddle: Eitte RocklesiStOrage &Terminals, LLC County AIRS ID: 123 Plant AIRS ID: 965E Facility Name: EucerneCrudeOil•Terrninai • Physical Address/Locatio NWSW quadrant of Section 26, Township 6N, Range 65W, in Weld County, Colorado Type of Facility: G*I'Stora astdE tpelicte[,ri)eetr What industry segments Ott&Aiet jsal6as.ffroduoosn&;Pr eg Is this facility located in a NAAQS non -attainment �area? [ If yes, for what pollutant? Don Monoxide (CO) Section 02- Emissions Units In Permit Application Weld Quadrant Section Township Range . NWSW culate Matter (PM) [3ne (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering - Remarks ['rank Breakout Tanks' 16WEO313 'CP2 0 Permit ' edifii.460n. • 7 CP2_ Section 03 - Description of Project Modify-16WE031&to -Charlgesizeoffled r©oftankslatpoint003.from400-bb€.tanksto-750- bbl tanks; - Increasing the Pt throughput 6foil loaded: out by truck, bringingthetruck loadout point into a permit required source: Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Reques g.Starthettol mar Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? At €_`• If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. 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) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants hers soz Nox co voc Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) PM2.5 PM10 CI El TSP HAPs ❑❑ Crude Oil Storage Tank(s) Emissions Inventory Section 01- Administrative Information !Facility AIRs ID: . fiEMEMSSItalilll County Plan RR Paint Section 02 - Equipment Description. Details Detailed Emissions.Unit Description: Emission Control Device. Description: Requested Overall VOC & HAP Control -Efficiency %: Section 03.- Processing Rate Information for EmissionStstimates- Primary Emissions _Storage Tank(s) Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) 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 = 9 Barrels (bbl) per year Actual Crude Oil Throughput While Emissions Controls Operating = 219;06d! Barrels (bbl)`per year 219,000: Barrels (bbl) per year 700 Btu/scf 944 scf/bbl 106.8 scfh from tank gas, 16.8 scfh from pilot gas, divided by liquid throughput 0 MMBTU per year 4,006 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 4,006 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant Control. Device Pollutant Uncontrolled Controlled (lb/bbl) (Ib/bbl) (Crude Oil Throughput) (Crude Oil Throughput) Uncontrolled (Ib/MMBtu) (waste heat combusted) Uncontrolled (lb/b60 0j3B8CEIK 0.3100 (Crude Oil Throughput) 0.0001 0.0001 0.0012 0.0057 Emission Factor Source Emission Factor Source 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) VOC 61.71 61.71 3.09 PM10 0.01 0.01 _ 0.01 PM2.5 0.01 0.01 0.01 NOx 0.14 0.14 0.14 CD 0.62 - 0.62 0.62 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) ' (lbs/year) (lbs/year) (lbs/year) Benzene 741 741 37 Toluene 1234 _ 1234 62 Ethylhenzene 494 - 494 25 Xylene 1728 1728 85 n -Hexane 494 494 25 224 TMP 123 123 6 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A,B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage Tank is not subject to Regulation 7, Section XVII Regulation 7, Section XVII.C.2 Storage Tank is not subjecttottegulaLion 7, Section XVII.C.2 Regulation 6, Part A, NIPS Subpart Kb Storage tank is subject to NIPS Kb Regulation 6, Part A, NIPS Subpart 0000a Not subject to NSPS 00000 Regulation B, Part E, MACT Subpart HH Storage Tank is not subject to MACT NH (See regulatory applicability worksheet for detailed analysis) 2af1 v K:\PA\2016\16 W E0318.CP2.xlsm Crude Oil Storage Tank(s) Emissions Inventory Section 07 - Initial. and PeriodicSampling and Testing Requirements Does the company use the state -default emissions factors to estimate emissions? If yes, are the uncontrolled actualor requested emissions estimated to be greater thanor equal to 20 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03 Doesthe company use -a site specific emissions factor to estimate'emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the facility being permitted? 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.95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiencyofthe combustion device based,on inlet and outlet concentration sampling Section 09 -Inventory SCC Coding and Emissions Factors - AIRS Point it 003 Process# SCC.Code 01 Uncontrolled . Emissions Pollutant Factor Control % PM10 - 0.003 0 lb/1,000 gallons crude oil throughput PM2.5 0.003 0 lb/1,000gallons.crude oil throughput NOx 0.030 0 lb/1,000 gallons crude oil throughput VOC 13.418 95 lb/1,000 gallons crude oil throughput CO 0135 0 lb/1,000 gallons crude oil throughput Benzene 0.081 95 Ib/1,000 gallons crude -oil throughput Toluene - 0.134 95 Ib/1,000gallons crude oilthroughput' Ethylbenzene 0.054 95 Ib/1,000 gallons crude oil throughput' Xylene 0.188 95 lb/1,000 gallons crude oil throughput n -Hexane 0.054 95 Ib/1,000 gallons crude oil' throughput . 224 TMP 0.013- 95 lb/1,000 gallons crude oil throughput 3 of 5 - - K:\PA\2016\16WE0318.CP2.xlsm • Section 01- Administrative Information _Facility AIRs ID: Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device -Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Plant Requested Overall VOC & HAP Control Efficiency %: - 93.20 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Limit Throughput= Potential to Emit (PTE) VolumeLoaded =- Secondary Emissions - Combustion Device(s) Heat content of waste gas=. Hydrocarbon Loadout Emissions Inventory Pain Barrels (bbl) per year . Actual Volume Loaded While Emissions Cbntrols Operating= 1131i Barrels (bbl) per year Barrels (661) per year, Barrels (b61) per year Actual heat content of waste gas routed to combustion device = Requested heat content of waste gasrouted to combustion device = Potential to Emit (PTE) heat Content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emission Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facil being permitted? Loading Loss Equation L=12.46*5*P*M/T estimated by applicant:1334.7 scf/hr from tack,10.8 scfb for pilot gas 0 MMBTU per year 43,805 MMBTU per year 43,805. MMBTU per year. The stabilized hydrocarbon liquid sample is valid for devefoping site Specific emissions factors. Factor - Meaning Value Units Source 5 Saturation Factor 0.6 ' P True Vapor Pressure psia - M Molecular Weight of Vapors -' 50 „�-. Ib/lb-mol I'• ,, ,,, : l '' T Liquid Temperature ), '5238;;: .»Rankine L Loading Losses - 5.923516/1000 gallons 0.2488 lb/bbl Component - Mass Fraction Emission Factor Units - Source Benzene 010 -0001492723 lb/bbl F i $i /111 3yOf 11 t 2titd9'p1 ( - 1 33 1 Toluene °01#� 0.002487071 lb/bbl Ethylbenzene / a OLCtO4 }1:: 0.000995148 lb/bbl XYlene I (1 r :0 014 � � 11 U � 0.0034830?~° 16/661 n -Hexane 91 1jj 0004 0.000995148 lb/bbl 224 TMP f, --,70,4 0,0061W = = 0.000248787 lb/bbl Emission Fac 0.0000 Pollutant Benzene Toluene Hydrocarbon Loadout Uncontrolled Controlled (lb/bbl) (lb/bbl) (Volume Loaded) (Volume , Loaded) Ethylbenzene .:0y,V -•S 10108' �.+ t: 0.000 Xylene 0.000 n -Hexane 224 TMP 0.0 Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (waste heat combusted) PM10 PM2.5 Emission Factor Source (Ib/bbl) Emission Factor Source (Volume Loaded) 5.26E-05 536E-05 4.16E-06 4.80E-04 K:\PA\2016\16W E0318.CP2.xlsm Hydrocarbon Loadout Emissions 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) (tans/year) PM10 • PM2.0 SOX NOw VOC CO 0.16 • 0,16 0.16 ,_ 0.16 0:16 0,16 0.01 0.01 0.01 1.49 1.49 1,49 771.24 771.24 52.48 - 6.79 6.79 6.79 Hazardous. Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled • (lbs/year) (Ibs/year{ Requested Permit Limits Uncontrolled Controlled . Ps/year) _. (Ibs/year)- - Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 9255 9255 - 630 15425 11425 1050 6170 6170 420 21595 21595 1470 6170 6170 420 1542 1542 105 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit The !indent must operate with submerged fill and readout emissions must be routed to flare to satisfy RACE. RACi - Regulation 3, Part B, Section III.D.2.a (See regulatory applicability worksheetfor detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare combustion device? _ If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 007 Process # SCC Code 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.001 0.00 lb/1,000 gallons transferred PM2.5 0.001 0.00 16/1,000 gallons transferred 50x 0.0051 0.00 16/1,000 gallons transferred NOx 0.011 0.00 lb/1,000 gallons transferred'. VOC 5.924 93.20 16/1,000 gallons transferred CO 0.052 0-00- lb/1,000 gallons transferred Benzene 0.036 93.20 16/1,000 gallons transferred Toluene 0.059 93.20 16/1,000 gallons transferred Ethylbenzene 0.024 93.20 lb/1,000 gallons transferred Xylene 0.983 93.20 lb/1,000 gallons transferred n -Hexane 0.024 93.20 lb/1,000 gallons transferred 224TMP 0.006 93.20 lb/1,000 gallons transferred 5 of5- - - K:\PA\2016\ 16WE0318.CP2.xlsm COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Saddle Butte Rockies Storage & Terminals 123 9E5E Lucerne Crude Oil Terminal tic History File Edit Date Ozone Status 1/16/2018 Non -Attainment EMISSIONS -Uncontrolled (tons pervear EMISSIONS With Controls (tons pervear POINT AIRS ID PERMIT Description PM10 PM2.5 H2S - S02 NOx - VOC - Fug VOC CO - Total HAPs PM10 . PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.3 0.3 -0.0 0.0. 3.6 . 50.2 25.1 3.3 3.3 0.3 0.3 0.0 0.0 3.6 19.7 25.1 - 3.3 1.7 Previous taken from Jan 2016 tab Previous. Permitted Facility total - 0.0: 0.0 0.0 0.0 0.1 49:1 25.1 a4 : 3 2 _ 0 0 0.0- 0.0"'. 0.0 09. 18.6 25.f - 0:4 -.1.6 001 16WE0318 Fugitives - 25.1 -- 1.0 25.1 1.0 nochange,-'- 002 16WE0318 ` IFR Crude Tanks (440000 bbltotal) 17.0 0.6 17.0 0.6 no change 003 16WE0318 Crude Oil Tanks (8 x 750 -bbl) - 0.0 0.0 `- 0.1 61.7 0.6 _ 2.5 0.0 0.0 _- 0.1 3.1 0.6 0.1 Nov 2017: change tank size, EFs, throughput 004 - 16WE0318 IFR Crude Tank (30000 bbl) - 0.0 8.3 - 0.1 0.3 0.0 -0.4 0.1 = 0.0 no change "polishing. tank" 005 16WE0318 Produced Water Tanks (1500 bbl total) -.' 0.0 8.7 0.1 0.7 DM 0.4 - 0.1 D.0 no change 006 16WE0651.XP Heaters for Separators (10 MMBtu/hr each) 0:3 0.3 3.5 0.2 2.9 " 0.1 0.3 0.3 _ 3.5 0.2 2.9 0,1 no change 007 16W56318 Truck Loadout 0.2 0.2 1.5 771.2 - - 6:8 30.1 0.2 0.2 1.5 52.5 6:8 - 2.0 Nov2017 no covet -required (previously XA) APEN-Exempt / Insionificants - - - - - Pig Blowdown 0:05 0.0 0:05 0.0 no change FACILITY TOTAL - 0.4 0.4 0.0 0.0 5.2 007.1 - 25.1 - 10.5 '. 35:4 -0A 0:4 0.0 ` 0.0 5.2 73:6 ' 25.1 :10.5 3.9 VOC: Syr, MIndt (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (POD and OP) HAPS: Syr, Minor (total and xylenes) HH: Syn Minor ZZ.ZZ: Syn Minor Permitted Facility Total - - - - 0.2 0.2 - 0:0 0.0 -- 1.7 866.9 25.1 7.5 35.3 ` 0.2 0.2 0.0 0.0 1.7 73.4 ` 25.1 "7.5 :3.8 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions -' - - - - - b.2 0.2 - 0:0 a0 1.6 54.8 0.0 - 7 2 - j - .- Pubcorn, required based on A change in emissions and new syn minor limit for 007 Nbte 1... - - - Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point end fugi ive) 98.7 - e , 54.8 N)ste 2 1 Printed 2/1/2018. Page 1' of 2 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Saddle Butte Rockies Storage & Terminals, LLC 123 9E5E Lucerne Crude Oil Terminal Emissions - uncontrolled (Ibs per year) POINT PERMIT. Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 IMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 16WE0318 Fugitives 301 501 201 702 201 1.0 002 16WE0318 IFR Crude Tanks (440000 bbl total) 204 339 136 475 136 0.6 003 16WE0318 Crude Oil Tanks (8 x 750 -bbl) 741 1234 494 1728 494 407 2.5 004 16WE0318 IFR Crude Tank (30000 bbl) 100 166 67 233 67 0.3 005 16WE0318 Produced Water Tanks (1500 bbl total) 14 84 4 66 1258 69 0.7 006 16WE0651.XP Heaters for Separators (10 MMBtu/hr ea 5 126 0.1 007 16WE0318 Truck Loadout 9255 15425 6170 21595 6170 1542 30.1 APEN-Exempt / Insignificants Pig Blowdown 0.0 TOTAL (tpy) 0.0 0.0 0.0 5.3 _ 8.9 3.5 12.4 4.2 0.0 1.0 0.0 0.0 35.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 r 001 16WE0318 Fugitives 301 501 201 702 201 1.0 002 16WE0318 IFR Crude Tanks (440000 bbl total) 204 339 136 475 136 0.6 003 16WE0318 Crude Oil Tanks (8 x 750 -bbl) 37 62 25 86 25 20 0.1 , 004 16WE0318 IFR Crude Tank (30000 bbl 5 8 3 12 3 0.0 005 16WE0318 Produced Water Tanks (1500 bbl total) 1 4 0 3 63 3 0.0 006 16WE0651.XP Heaters for Separators (10 MMBtu/hr ea 5 126 0.1. 007 16WE0318 Truck Loadout 630 1050 420 1470 420 105 2.0 APEN-Exempt / Insignificants Pig Blowdown 0.0... TOTAL (tpy) 0.0 0.0 0.0 0.6 1.0 ,0.4 1.4 0.5 0.0 0.1 0.0 0.0 , 3.9 .; 2 1239E5E.xlsx 2/1/2018 DRAFT Permit number: Date issued: Issued to: Construction Permit Air Pollution. Control Division 16WE03-1$ Saddle Butte Rockies Storage and Terminals, LLC Facility Name: Lucerne Crude Oil Terminal Plant AIRS ID: 123/9E5E Physical Location: NWSW SEC 26 T6N R65W County: Weld County General Description: Crude Oil Terminal Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description FUG 001 Fugitive component leak emissions. None CRDTK-1 002 Eight (8) 30,000 barrel and two (2) 100,000 barrel internal floating roof crude oil storage vessels. Internal Floating Roof CRDTK-2 003 Eight (8) 750 barrel fixed roof crude oil storage vessels. Enclosed Flare CRDTK-3 004 One (1) 30,000 barrel internal floating roof crude oil storage vessel. Internal Floating Roof and Enclosed Flare PWTNK 005 Two (2) 750 barrel fixed roof produced water storage vessels. Enclosed Flare TL 007 Truck loadout of crude oil by submerged fill. Enclosed Flare 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 specificgeneral terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL:AUTHORIZATION 1. Points 003, 004, 005, and 007: YOU MUST notify the Air Pollution Control. Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of Page 1 of 13 DRAFT this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 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 shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. 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/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section IILG.2.p This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I. F.4. ) The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with -the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point ; Tons per Year Emission Type PM2.5 NOX VOC CO FUG 001 --- --- 25.1 --- Fugitive CRDTK-1 002 --- --- 17.0 --- Point CRDTK-2 003 --- --- 3.1 --- Point CRDTK-3 004 --- --- 0.5 --- Point PWTNK 005 --- --- 0.5 --- Point TL 007 --- 1.5 52.5 6.8 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 year. AiContra DRAFT Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with, site responsibility for Division review. Point 001: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas and liquids analyses. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. The emission points in the table below shall 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.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled CRDTK-1 002 Internal Floating Roof VOC and HAP CRDTK-2 003 Enclosed Flare VOC and HAP CRDTK-3 004 Internal Floating Roof and Enclosed Flare VOC and HAP PWTNK 005 Enclosed Flare VOC and HAP TL 007 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall 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 CRDTK-1 002 Crude Oil Throughput 21,900,000 barrels CRDTK-2 003 Crude Oil Throughput 219,000 barrels CRDTK-3 004 Crude Oil Throughput 21,900,000 barrels PWTNK 005 Produced Water Throughput 2,190,000 barrels TL 007 Crude oil Loaded 6,200,000 barrels DRAFT The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate 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: Points 002, 003, 004, and 005: The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. Points 003, 004, 005, and 007: 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 001: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). The requirement to apply RACT shall be satisfied by installing/implementing the following emission controls: a Directed Inspection Et Maintenance as described below shall satisfy the requirement to apply RACT. i. Auditory/visual/olfactory. inspection (AVO) will be performed on a semi- annual basis. ii. For each leak found in the AVO inspection, a gas detector may be used to determine the size of the leak. The gas detector shall be regularly calibrated. Component teaks greater than 10,000 ppm shall be managed in accordance with item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. Component leaks less than 10,000 ppm shall not require repair. For such component leaks that require a shutdown to be repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered. iii. For repair, valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. iv. Repaired components shall be re -screened using g' AVO to determine if the leak is repaired. v. The following records shall be maintained for a period of two years: • The name of the site screened via AVO inspection and the name of the inspector. • Components evaluated with the gas detector. • Repair methods applied. • Dates of the AVO inspections, gas detector calibrations, attempted repairs, successful repairs, repair delays, and post -repair screenings. COLORADO i2 Pollution Control Division Vr- *ra Pilbti etOt.h v Er irnrrmnt Page 4 of 13 DRAFT vi. Leaks shall be repaired as soon as practicable, but no later than 15 calendar days after detection, unless it is technically or operationally infeasible to make the repair within 15 calendar days. Records documenting the rationale shall be maintained if it is technically or operationally infeasible to make the repair within 15 calendar days. 14. Point 001: The owner or operator shall follow the Directed Inspection and Maintenance (DIttM) program and record keeping format as approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your DI&M plan are subject to Division approval. 15. Points 002, 003, 004, and 005: Minor sources in designated nonattainment or attainment/maintenance areas that areotherwise not exempt pursuant to, Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology for the pollutants for, which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). The requirement to apply RACT shall be satisfied by installing either an internal floating roof or closed vent system and enclosed combustion device on all crude oil and produced water storage tanks registered under these points. 16. Point 004: This storage tank is subject to the requirements of Regulation Number 7, Section IV. To demonstrate compliance with these requirements, the source shall comply with all applicable requirements for this tank under New Source Performance Standards, Standards of Performance for Volatile Organic Liquid Storage Vessels for which construction, reconstruction or modification commenced after July 23, 1984, Subpart Kb. 17. Points 002 and 004: These sources are subject to the applicable requirements of Regulation Number 7, Section VI.B.2. 18. Points 002, 003, and 004: This source is subject to the New Source Performance Standards, Standards of Performance for Volatile Organic Liquid Storage Vessels for which construction, reconstruction or modification commenced after July 23, 1984, Subpart Kb. This facility shall comply with all applicable provisions of this regulation, as stated in 40 C.F.R Part 60, Subparts A and Kb. (Regulation Number 6, Part A, Subparts A and Kb) 19. Point 007: This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill and emissions shall be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) 20. Point 007: All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 21. Point 007: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): The owner or operator shall inspect onsite loading equipment during loading operations to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least quarterly. Each inspection shall be documented in a log available to the Division on request. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. Points 003 and 007: The owner or operator shall: COLORADO a it PoU tion Control Division k.�r�e�t ut �eiiilts e n.'ty �;rlbnrrreilt DRAFT a. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. b. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are routed to the control device under normal operating conditions. c. Document annual inspections of thief hatch seats and. PRD with an indication of status, a description of any problems found, and their resolution. 23. Point 007: The owner or operator shall: a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING Et MAINTENANCE REQUIREMENTS 24. Points 003, 004, 005 and 007: The owner or operator shall follow the most recent operating and maintenance (OEtM) 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 the. OEtM 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 25. Point 001: Within one hundred and eighty days (180) after commencement of operation, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service and "gas service". The operator shall submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. Periodic Testing Requirements 26. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 27. Alt previous versions of this permit are cancelled upon issuance of this permit. 28. A revised. Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, 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 For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO), per year, a change in COLORADO PollutionPollution Control Division tor Pub4e: s}t n & E:�uor:rne;t Page 6 of 13 DRAFT 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. 29. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 30. 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. 31. 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. 32. 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. 33. 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. 34. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and 'COLORADO Air Pollution: Control Divi$lon Intent DRAFT 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. 35. 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. 36. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 August 1, 2016 Issued to Saddle Butte Rockies Storage and Terminals, LLC Issuance 2 This Issuance Issued to Saddle Butte Rockies Storage and Terminals, LLC. Point 003: changed tank size, emission factors, and permit limits. Point 007:. added as new point. Facility is now synthetic minor. No changes to other points. Issued as Initial Approval. DRAFT 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 shall 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 shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphefagcc-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 (Ib/yr) 001 Benzene 71432 301 301 Toluene 108883 501 501 Ethylbenzene 10041.4 201 201 Xylenes 1330207 702 702 n -Hexane 110543 201 201 002 Benzene 71432 203 203 Toluene 108883 339 339 Xylenes - 1330207 136 136 Ethylbenzene 100414 474 474 n -Hexane 110543 136 136 003 Benzene 71432 741 37 Toluene 108883 1234 62 Ethylbenzene 100414 494 25 Xylenes 1330207 1728 86 n -Hexane 110543 494 25 2,2,4-Trtmethylpentane 540841 123 6 - 004 Benzene 71432 100 5 Toluene 108883 166 8 Pollution Control Division E aw r,mee:t DRAFT Ethylbenzene 100414 66 3 Xylenes 1330207 233 12 n -Hexane 110543 66 3 005 Benzene 71432 14 1 Toluene 108883 84 4 Ethylbenzene 100414 4 < 1 Xylenes 1330207 66 3 n -Hexane 110543 1258 63 007 Benzene 71432 9255 630 Toluene 108883 15425 1050 Ethylbenzene 100414 6170 420 Xylenes 1330207 21595 1470 n -Hexane 110543 6170 420 2,2,4-Trimethylpentane 540841 5090 346 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/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 001: Component Gas Heavy Oil Light Oil Water/Oil Connectors 0 0 542 0 Flanges 0 0 1422 0 Open-ended Lines 0 0 2 0 Pump Seals 0 0 7 0 Valves 0 0 431 0 Other 0 0 154 0 VOC Content (wt. fraction) 0 0 Benzene Content (wt. fraction) 0 0 0.006 0 Toluene Content (wt. fraction) 0 0 0.01 0 Ethylbenzene (wt. fraction) 0 0 0.004 0 Xylenes Content (wt. fraction) 0 0 0.014 0 n -hexane Content (wt. fraction) 0 0 0.004 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): COLORADO Air P Control Division DRAFT Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E -05 - Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: Standard EFs - EPA -453/R-95-017 Table 2-4 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas and liquids analyses. Point 002: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.001549 0.001549 EPA Tanks- Working and Breathing Emissions only 71432 Benzene 0.0000093 0.000009 108883 Toluene 0.0000155 0.000015 100414 Ethylbenzene 0.0000062 0.000006 1330207 Xylene 0.0000217 0.000022 110543 n -Hexane 0.0000062 0.000006 Note: The uncontrolled and controlled emissions factors for this point are based on the use of an internal floating roof tank in the EPA Tanks simulation. Point 003: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.0012 0.0012 AP -42 Ch. 13.5 CO 0.0057 0.0057 AP -42 Ch. 13.5 VOC 0.564 0.0282 EPA Tanks Working and Breathing Emissions only 71432 Benzene 0.003 0.0002 108883 Toluene 0.006 0.0003 100414 Ethylbenzene 0.002 0.0001 1330207 Xylene 0.008 0.0004 110543 n -Hexane 0.002 0.0001 540841 2,2,4-iMP 0.002 0.0001 Note: The uncontrolled and controlled emissions factors for this point are based on a fixed roof tank in the EPA Tanks 4,09d simulation and a flare control efficiency of 95%. NOx and CO emission factors are based on an estimated gas heat value of 3700 Btu/scf and a gas volume of 4.944 scf/bbl. Point 004: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.00075886 0.00003794 EPA Tanks - DRAFT CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source Working and Breathing Emissions only 71432 Benzene 0.00000455 0.00000023 108883 Toluene 0.00000759 0.00000038.. 100414 Ethylbenzene 0.00000304 0.00000015 1330207 Xylene 0.00001062 0.00000053 110543 n -Hexane 0.00000304 0.00000015 Note: The uncontrolled and controlled emissions factors for this point are based on the use of an internal floating roof tank in the EPA Tanks simulation and a flare control efficiency of 95%. CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source V0C 0.007910 0.000395 Promax Flashing, Working and Breathing Emissions with pressurized water sample as input 71432 Benzene 0.000007 0.0000003 108883 Toluene 0.000038 0.0000019 100414 Ethylbenzene 0.000002 0.0000001 1330207 Xylene 0.000030 0.0000015 110543 n -Hexane 0.000574 0.0000287 . Point 007: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 4.80E-04 4.80E-04 AP -42 Ch.13-5 CO 2.19E-03 2.19E-03 AP -42 Ch.13-5 V0C 0.2488 0.0169 AP -42 Ch. 5.2 71432 Benzene 0,0015 0.0001 108883 Toluene 0.0025 0.0002 100414 Ethylbenzene 0.0010 0.0001 1330207 Xylene 0.0035 0.0002 110543 n -Hexane 0.0010 0.0001 540841 2,2,4-TMP 0.0008 0.0001 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 = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 8.3 psia M (vapor molecular weight) = 50 lb/lb-mol T (temperature of liquid loaded) = 523.8 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the crude oil by the VOC emission factor. NOx and CO emission factors were calculated based on an estimated heat content of 3700 Btu/scf and a gas volume of 11.84 MMscf/yr. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to COLORADO ix PoUutio t Control Division DRAFT 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 permit fulfills the requirement to hold a valid permit reflecting the storage tank, and associated control device per the Colorado Oil and Gas Conservation. Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs (total, and xylenes) NANSR Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air PoU ttiori Control Diva i :pns �r'aens -r 3'u .i�6 klati,'v EmAronrrent Page 13 of 13 Condensate Storage Tank(s) Form APCD-205 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, 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 and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. 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: 16WE0318 AIRS ID Number: 123 / 9E5E / 00 ao [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name1: Saddle Butte Rockies Storage & Terminals, LLC Site Name: Lucerne Crude Oil Terminal Site Location: NW/SW Sec 26 T6N R65W Mailing Address: (Include Zip Code) 858 Main Avenue, Suite 301 Durango, CO 81301 Site Location • County: Weld NAICS or SIC Code: 1311 Permit Contact: Trent Miller Phone Number: 303-446-7532 E -Mail Address2: TMiller@sbpipeline.com 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 APCD via e-mail to the address provided. 311728 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 it AV COLORADO n.adwwie 1{N9.6ExMiannani Permit Number: 16WE0318 AIRS ID Number: 123 / 9E5E / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit O Request coverage under a General Permit O GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) ✓❑ Change in equipment ❑ Change company name O Change permit limit O Transfer of ownership3 ❑ Other (describe below) - OR • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source O Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 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: Condensate Storage Tanks For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week ❑ Exploration & Production (E&P) site 365 weeks/year ❑✓ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ■ No Are Flash Emissions anticipated from these storage tanks? ■ Yes Fl No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? 151 Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 1.34 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • II Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 • Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 21 AV I COLORADO x wwn.m r.� AIRS ID Number: 123 / 9E5E / 002 0>,3 Permit Number: 16WE0318 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl%yea's) Requested Annual Permit Limit4' (bbl/year) Condensate Throughput: 219,000 From what year is the actual annual amount? Average API gravity of sales oil: Tank design: ❑✓ Fixed roof degrees ❑ Internal floating roof RVP of sales oil: 10.225 O External floating roof Storage; Tank ID : # of Liquid Manifold Storage . Vessels in Storage Tank"ge Total Volume of : Storage Tank (bbl)': `: Installation Date of Most " Recent Storage Vessel in Storage Tank ' (month/yeaar) . Date of First Production : - .. (month/year); , 8 6,000 November 2017 TBD API Number;` Wells Serviced by this Storage Tank or Tank Battery5 (EftP Sites Only) ." Name of Well Newly Reported Well O O O 4 Requested values will become permit limitations. Requested Limit(s) should consider future growth. 5 The EUP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40°27'02.3"N 104°38'15.0"W Operator Stack - ID No. Discharge Height Above Ground Level (feet) Temp . (°F) Flow Rate - (ACFM) = _ Velocity (ft/sec) 0 Indicate the direction of the stack outlet: (check one) ❑� Upward ❑ Downward O Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) ❑� Circular ❑ Square/rectangle O Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 31 COLORADO xeO`pari `sEtofPublic ue.et :N Permit Number: 16WE0318 AIRS ID Number: 123 / 9E5E / 2 00 3 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor El Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOC and HAPs Rating: 1 MMBtu/hr Type: Enclosed Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: Make/Model: Zeeco VCU 5-40 Flare System 95 99 Waste Gas Heat Content: 3700 Btu/scf Constant Pilot Light: El Yes D No Pilot Burner Rating: MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 -Gas/Liquids Separation Technology Information (EFtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 4 I COLORADO xdnasFn.m Benzene Permit Number: 16WE0318 AIRS ID Number: 123 I 9E5E / 9k72c.)o3 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): VOC Enclosed Combuster Overall Requested Control Efficiency;. (% reduction in emissions 95% NOx CO HAPs Enclosed Combuster 95% Other: From what year is the following reported actual annual emissions data? 0.564 Ib/bbl Tanks 4.0 Uncontrolled;- Basis - VOC riteria Pollutant Emissions Invento Source (AP 42, Mfg.etc) ctual Annual Emissions -- Uncontrolled Emissions (Tons/year), ontrolled Emissions? (Tons/year)' Uncontrolled: Emissions; (Tons/year) 61.71 3.09 NOx 0.068 Ib/MMBtu AP42 Tbl 13.5-1 0.14 CO 0.310 lb/MMBtu AP42 Tbl 13.5-1 0.62 on Criteria Reportable Pollutant Emissions Invent-` of emica Abstract Service (CAS) Number Emission Factor6 ncontrolled Basis Units Source Mfg. etc) Actual Annual Emissions ncontrolled Emissions (Pounds/year) ontrolle� missions, ou ids/year) 71432 0.003 Ib/bbl Tanks 4.0 741 37 Toluene 108883 0.006 Ib/bbl Tanks 4.0 1234 62 Ethylbenzene Xylene 100414 0.002 Ib/bbl Tanks 4.0 494 25 1330207 0.0079 Ib/bbl Tanks 4.0 1728 86 n -Hexane 110543 0.002 Ib/bbl Tanks 4.0 494 25 2,2,4- Trimethylpentane 540841 .001 Ib/bbl Tanks 4.0 123 6 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 5' AY Department of "IAA. COLORADO Permit Number: 16WE0318 AIRS ID Number: 123 / 9E5E / 0 00 3 [Leave blank unless APCD has already assigned a permit II 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. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Jam`''_'-` Signature of Legally Adthorized Person (not a vendor or consultant) (, g4117‘1 Citees 5 Name (print) 111)? ► 7 ate VP OF beEge°etloN S Title Check the appropriate box to request a copy of the: QQ 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, !LC. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250, 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 Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 COLORADO 6 I .y 'Nw`�'v r1 �P3 NUv 2� 6• Hydrocarbon Liquid Loading APEN - Form APCD-208 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. 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. 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 at: www.colorado.gov/cdphe/apcd. 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: 16W E0318 AIRS ID Number: 123 /9E5E /007 - [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Saddle Butte Rockies Storage and Terminals, LLC Site Name: Lucerne Crude Oil Terminal Site Location: NW/SW Sec 26 T6N R65W Mailing Address: (Include Zip Code) 858 Main Avenue, Suite 301 Durango, CO 81301 E -Mail Address2: TMiller@sbpipeline.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Trent Miller Phone Number: 303-446-7532 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 APCD via e-mail to the address provided. 37 729 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017 Q COLORADO 1I • , Permit Number: 16W E0318 AIRS ID Number: 123 /9E5E/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ▪ NEW permit OR newly -reported emission source r❑ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $250 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 name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) - OR ❑ APEN submittal for update only (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 Et Notes: 3 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: Loadout Of Condensate Into Trucks For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: I I I Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? I] Yes ❑ No El Yes El No El Yes ❑✓ No ❑ Yes El No ❑ Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 A;COLORADO Permit Number: 16W E0318 AIRS ID Number: 123 /9E5E/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: E Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded4: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth 6,200,000 Bbl/yr Actual Volume Loaded: Bbl/yr This product is loaded from tanks at this facility into: (eg, "rail tank cars" or "tank trucks") If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 64 °F True Vapor Pressure 10.225 Psia @ 60 °F Molecular weight of displaced vapors 50 Lb/lb mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: Bbl/yr Actual Volume Loaded: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Product Density: Lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume ft3/truckload Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 AV !COLORADO 3 1 m , °`"'�` .bo' HYW bFhuMnl Permit Number: 16WE0318 AIRS ID Number: 123 i9E5Ei [Leave blank unless APCD has already assigned a permit # and AIRS ID] 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 overall control efficiency (% reduction): • � � CContro Equipment Desct iption Ftr. Req ested Centro E#Foamy (% red C ,,PkInbemisstons) PM SOX NO), CO VOC Vapor Tight Trucks and Combusters 93.2 HAPs Vapor Tight Trucks and Combusters 93.2 Other: ❑ Using State Emission Factors (Required for GP07) VOC ❑ Condensate ❑ Crude 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene 0.00041 Lbs/BBL 0.00018 Lbs/BBL n -Hexane 0.0036 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 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.) neon rolled Einrssi.n l= ct ` ° Emission Factor Units Emission Factor . Source '' (AP -42, t9fg. etc) - Re. tlestedgAnn a F?e mi - r d u �� Emissi•ns .1 ut n � �Jn nt olled an�/year) Controlle'd53 _. (Tons/year) .; Uncontrollea (Tons/year) .. O ntrolled `(To!ye nsarn PM 40 pg / L AP -42 TbI 3.5-1 & 2 0.2 SOX 0.00015 Ib/MMBtu AP -42 <0.1 NO„ 0.068 Ib/MMBtu AP42TbI13.5-1 1.5 VOC 5.92 lb/1,000 gal AP 42 Chap 5.2 771.24 52.29 CO 0.310 Ib/MMBtu AP42Tb113.5-1 6.8 Benzene 0.0355 lb/1,000 gal AP 42 Chap 52 4.63 0.31 Toluene 0.0592 lb/1,000 gal AP 42 Chap 5.2 7.71 0.52 Ethylbenzene 0.0237 lb/1,000 gal AP 42 Chap 5.2 3.08 0.21 Xylenes 0.0829 Ib/1,000 gal AP 42 Chap 5.2 10.80 0.73 n -Hexane 0.0237 lb/1,000 gal AP 42 Chap 5.2 3.08 0.21 2,2,4- Trimethylpentane 0.0195 lb/1,000 gal AP 42 Chap 5.2 (} /' } 7 j ,15 ®- Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 5 'AV 5 2-1(1(6 tr OLORADO� `LMm 6Mmimmsom. \ v Permit Number: 16WE0318 AIRS ID Number: 123 /9E5E/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - 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 full compliance with each condition of the applicable General Permit. 11)rt `t i Signature of Legally Au orized Person (not a vendor or consultant) C Name (print) Title Date VP e r 'EMT) to' Check the appropriate box to request a copy of the: 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 in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250 as 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 Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 61 COLORADO u hon• tment al l H6iemimml • Hello