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Home My WebLink About20172669.tiffCOLORADO Department of Public Health & 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 July 24, 2017 Dear Sir or Madam: RECEIVED JUL 272017 WELD COUNTY COMMISSIONERS On July 27, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc. - Nakagawa T5N-R64W-S13 L01. 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 Pubttc gtai-1 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickentooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer cc PLCMMITO, NLC3T), pwc (CH-1iSMlch� —713i / t1 2017-2669 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - Nakagawa T5N-R64W-S13 L01 - Weld County Notice Period Begins: July 27, 2017 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: Noble Energy, Inc. Facility: Nakagawa T5N-R64W-S13 L01 Oil and gas exploration and production facility SWSW Sec 13 T5N R64W Weld County The proposed project or activity is as follows: Source is proposing to combust gas from a vapor recovery tower (VRT) at an existing oil and gas exploration and production facility. 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 17WE0394 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: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us � CC3CARADdY 1 Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Bradley Eades 361524 4/25/2017 6/22/2017 Company Name: Noble Energy Inc. County AIRS ID: 123 Plant AIRS ID: 9C30 Facility Name: Nakagawa T5N-1464W-S13 L01 Physical Address/Location: SWSW quadrant of Section 13, Township SN, Range 64W, in Weld County, Colorado Type of Facility: ExpioratiOn&Production Welt Pad What industry segment? C«iI& [aturatGas Production '& Processing;', Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? )Jarbon Monoxide (CO) Weld Quadrant Section Township Range SWS 13 SN Section 02 - Emissions Units In Permit Application [particulate Matter (PM) ❑Q Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 014 Vapor Recovery Tower(VRT} VRT Yes 17W E0394 1 Yes Permit Initia Issuance Section 03 - Description of Project New permit for an existing E&P facility in the non -attainment area of Weld County. Source has removed the Vapor Recovery Unit(s) (VRU) compressors from the facility and will route all (previously recycled) vapor recovery tower (VRT) vapors to the 'V0C Burner" (enclosed combustor). Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Sy etic Minor P Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification a 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) S02 ❑ No Yes NOx CO VOC PM2.5 PM10 TSP HAPs ❑ O ❑ O ❑ O ❑ O ❑ i] O Is this stationary source a major source? No If yes, explain what programs and which pollutants here: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits (OP) ❑ O O O O O O O Non -Attainment New Source Review (NANSR) ❑ ❑ Condensate Storage Tank(s) Emissions Inventory Section 01- Administrative Information Patlllty AIRs I0: 123 9090 014 -. County Plant Section 02 -Equipment Description Details Detated Emissions U. Description: ventlnpotgas frame vapor moven, tower(VR7). Emission Control Device Description: Emig Requested Overall VOC & HAP Control Efficiency %: Separator Equipment Type of separator n Wiilgasbemetered: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions - Separator Maximum vent rate Requested Permit Lint Throughput Potential to Erna (POE) Throughput = Gas Process Control (Recycling) VRU: VRU operation: 95 3678 scf/hr 129,940 Barrels (bbl( per year 129,940 Barrels (bbl( per year Secondary Emission -Combustion Device(s) for Air Pollution Control Control Efficiency% pass (annual( Separator Gas Heating Value: 2671.5:. Btu/scf Section 04 -Emissions Easton & Methodologies Potential Process Parameters: Gas Recycled: 0.0 MMsct/yr Gas Routed to Control: 3.2 MMscf/yr The Lapoerennet toWN iskated dowostrkkmof MihMt(Mes pensree) 3epasatdr andlow pllMore sepasator cettmp lle)iq u(rdegio 6is(6gYNseparatlonprfor to the VRT. A leessuemd liquidsample seas taken from the inletsepa.a rat 232ipsig; 66dej P(fampledo2/1/22017)and medeledsisWq l0P9V5 Vet 0.6, M.0080 she /D separator and subsequently the VRT. The maafractfons. molecular weight(MW), and Lent nee are derbed trom the modeled VET gas stream 'VRT Vaporsto eranor. Input Parameters Modeled Liquid Throughput 356'.0: Barrels (bbl) per day (8 applicable( EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.0.3) Ex=O'MW'to/C Ex =emissions of pollutant x O= Volumetric Row rate/volume of gas processed MW = Molecular weight of gas =SG of gas' MW of air )G = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol(at 60F and 1 atm Maximum Vent Rate 367.8 scf/hr 24.8 scf/bbl Throughput (O) 3.2 MMscf/yr 36782192 scf/hr MW 47.73 Ib/Ib-mol 0008827726 MMscf/d mass fraction (%( lb/hr Ib/or toy Helium 0.0000 0.00 0.00 CO2 0.74 0.3428 3002.79 1.50 N2 0:090.0417 365.20 0.18 methane 3:08 1.426] 12498.12 6.25 ethane 1168 5.5031 4820703 24.10 propane 29:16 13.5076 11832635 59.16 isobutane 7.06 3.2796 28729.44 14.36 n -butane 20.75 9.6119 84199.99 42.10 isopentane 7.02 3.2518 28485.97 14.24 n -pentane 9.03 4.1829 36642.21 18.32 cyclopentane 5.11 2.3671 20735.52 10.37 n -Hexane 2.996086634 1.3879 12157.61 6.08 ryclohexane 0.0000 0.00 0.00 Other hexane: 0.0000 0.00 0.00 hepanes 1:93 0.8940 7831.60 392 methylcyclohexane 0.0000 0.00 0.00 224-TMP : '- 007276084 0.0337 295.29 0.05 Benzene 0,4340284W 0.2011 1761.20 0.88 Toluene <: 0.213358402 0.0988 865.77 043 Ethylbenzene 0.015762806 0.0073 63.96 0.03 %ylenes 0.065751016 0.0305 26681 0.13 C3o Heavies 0:33: 0.1529 1339.08 067 Total 100.0 Total VOC (Uncontrolled) VOC wR % 84.21 Operator Calculated Value: Variance: Note: lb/hr emission rates in the table above are based on 8]60 hr/yr venting and requested gas volume 70 8 0.05 2013 K:\PA\2017\17 W E0394.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 05 -Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Perm it Limits Uncontrolled Controlled (tons/t'ea'l (tons/Year) VOC PM10 PM2.5 900 CO 170.9 170.94 8.55 0.0 0.03 003 0.0 0.03 0.03 0.3 0.29 0.29 1.3 1.33 133 Hazardous Air Pollutants Potential to Emit Uncontrolled (tons/Year) Act al Emissions Uncontrolled Controlled (tons/yearl (tom/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limos Uncontrolled Controlled llus/yearl (Ibe/year) Benzene Toluene Ethylbemene gylene n -Neon 224 TMP 0.8606 0.88 0.04 176120 86 0.4329 0.43 0.02 865.77 43 0.0320 0.03 0.00 63.96 3 0.1334 0.13 0.01 266.81 13 6.0788 6.08 0.30 12158 608 0.1476 0.15 0.01 295.29 15 Section 06 -Re ulatory Summary Analysis Regulation 3, Parts 0n B Regulation 7, Section 10011 0, Regulation 7, Section XVII.8.2.e (See regulatory epplkabillty worksheet for detailed analysis) APES Required, Permit Required Source is not subject to KVII.G. Source is not subject to alternative emission control requirements Section 07 - Initial and Periodic Semolina and Testing Requirements Does the company use site specific emission factors based on a gas sample to estimate emissions? If yes, are the emissions factors based on an gas sample drawn at the facility and from the equipment being permitted? Thu sample should be considered representative which generally means We -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Inhul Compliance" testing requirement to collect a site -specific sample and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Does the company use site specific emission factors based on a pressurized liquid sample and process simulation to estimate emissions? If yes, are the emissions factors based on an pressurized liquid sample drawn at the facility and from equipment located upstream of the permitted equipment? This sample should be considered representative which generally means espectic and collected within one year or We application received date. However, if the facility has not been modified (e.g., no new wells brought on- line), then it may be appropriate to we an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to collect a site -specific liquid sample and conduct an emission factor analyse to demonstrate that the emission factors are less than or equal to the emiwions factors established with this application. Does the company request a control deuce efficiency greater than 95% for a flare or comblaton device?T, 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 08 - Technical Analysis Not. `Source has provided emission estimation based on a site -specific pressurized liquid sample analysis As such, there will be no initial sampling requtrementswith this permit. "Source indicated that the date of firstproduction from the most recently completed or recompleted well is 9/7/13 therefore, this source is not subject to Reg 7 Section %VII.G. "Draft permit permit. was sent to applicant on luly 13, 2017. Received response On 7/20/17 indicating that the source had reviewed the draft permit and did not have any comments. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Pointd 014 Process!! SOC Code Pollutant PM10 PM2.5 NOx VCC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Uncontrolled Emissions Factor Control % Units 0.01 0 0.01 0 0.11 0 62.64 95 0.49 0 0.32 95 0.16 95 001 95 0.05 95 2.23 95 0.05 95 b/1000gal liquid throughput b/SOODgal liquid throughput b/1000gal liquid throughput b/1000gal liquid throughput b/1000gal liquid throughput b/1000gal liquid throughput b/1000gal liquid throughput b/1000gal liquid throughput b/1000gal liquid throughput b/1000gal liquid throughput b/1000gal liquid throughput 3 of K:\PA\2017/17 W E0394.CPl.xlum Permit number: Date issued: Issued to: A D O n Contro lic Heal CONSTRUCTION PERMIT 17WE0394 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Noble Energy, Inc. Nakagawa T5N-R64W-S13 L-01 123/9C30 SWSW SEC 13 T5N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT 014 Venting of gas from one (1) Vapor Recovery Tower (VRT) Enclosed Combustor ("VOC Burner") 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 this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. 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 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. 2. 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 III.G.2.) COLORADO Air Pollution Control Division Page 1 of 7 3.er or oper or • e source this perms L, -.s issued: tion/modif' peration isource withi 8 months ce of t constr on per , or the date on ich such uled • commen m s set th in the permi ;; • •lication with thi . (ii) • -s cons • :- iod of eigh the 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.) 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.) 5. 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 I I .A.4. ) Annual Limits: s permit s does not c er either, stru • Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO VRT 014 --- --- 8.6 --- 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 tons per year. 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. 7. 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 VRT 014 Emissions from the VRT are routed to an enclosed combustor VOC and HAP COLORADO Air Pollution Control Division Page 2 of 7 8. e followi cessi .« tes sh1' be main he Di inspsfi eque Process Limits ate listed be Monthly owner or operate `.nd made ber 3, Par .) Facility Equipment ID AIRS Point Process Parameter Annual Limit VRT 014 Liquid Throughput 129,940 bbl/yr 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. 9. The owner or operator must use monthly condensate/crude oil throughput records, calculation methods detailed in the O&M Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. 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. 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) OPERATING Et MAINTENANCE REQUIREMENTS 13. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (0EtM) 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 0EtM 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 14. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 15. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 16. 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 COLORADO Air Pollution Control Division Page 3 of 7 mpounds ( nitrogen esources (N• in ozone nmeneas ting les an 10. ins of V or NO„ per year, change in actual ! ission one ton per or moor five percent chever is greater, ab • = - evel= • • - • • the la 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. 17. 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 18. 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. 19. 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. 20. 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. 21. 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. 22. 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 COLORADO Air Pollution Control Division Page 4 of 7 n such oc any time p CD) on gr alit shall be d- • nied ab in . permit ma e revoked tion and fi ation by - lr ollution Co •l Division e Color • Air Qu y Contrfj.ct and regulation •f the Air (Ai inching failur- meet express term or dition of enie :' onditi o . . " a permit a - ted 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. 23. 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. 24. 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: Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. COLORADO Air Pollution Control Division Page 5 of 7 Notes t• •-rmit Hold't the permit iss 1) The rmit holde requi to. ees for th.: ""= time fo s pe it. An invo ® for these fee ll be issu e-fter t •ermi issued. A e permi ,elder sh. .ay the invoice w n 30 days e invure invoi►Se , evocation ermit. (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/cdphe/aqcc-reps 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. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (lb/yr) VRT 014 Benzene 71432 1761 88 Toluene 108883 866 43 Ethylbenzene 100414 64 3 Xylenes 1330207 267 13 n -Hexane 110543 12158 608 2,2,4- Trimethylpentane 540841 295 15 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportab e 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 014: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source V0C 2.631 0.132 HYSYS Version 8.6 71432 Benzene 0.014 0.001 108883 Toluene 0.007 0.0003 110543 n -Hexane 0.094 0.005 1330207 Xylenes 0.002 0.0001 540841 224-TMP 0.002 0.0001 Note: The controlled emissions factors for this point are based on the combustor control efficiency of 95%. COLORADO Air Pollution Control Division Page 6 of 7 6) In a this APE the ass • rdance wit .R.S. rmit is vail Gr a t hall be suted n st re nual fe 'with this pe e each Air P years fro ter 30 days voice eter a any at (303)-692-3150. 7) This facility is classified as follows: -fore th` e the APE gardin Emission t was rec ve-year irati EN) associ • with the Divisio revised m expires. Pleas fer to ate for each em.ns point tion date c. P ` ision Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Total HAPs 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://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 Pollution Control Division Page 7 of 7 44, Emission. Source [Leave blank unless APCD has already assigned a permit # & AIRS ID] 0 4. 44. G C sue, 2 0 0 C b 0 E a c L[7 C) V..0.2 G Section 02 — Requested Action (check applicable request boxes) Section 01— Administrative Information 4 0 v ._ C. Q a ❑ a O u °3 W H- F se a _n 0, h Ca 00 >. aC..) C U L C 4 03 C p Ti. cr) 6.1 0i - c� c7 O o u 0 .0 .y U to C CO CI it CS ro a! O °) y .0 F v o n To I. C Y. s a as O .O O. a. b Q. ❑- >' '61 61 g u aa a C Gzs u c,, M .. z = a 0 Co., 9 11 E F < Ca y d Q. A W GUS. = C. a = Z O aoo i W s. O C ❑ G. VI C) U H w C G' 0' 0' a0 Cl g❑❑a�❑❑ N❑ DO O 10 o UU Z 3 0) u. co b O o o a° 0 a) Fl N C O° 0 C U a: N T C 0 O P. C 1.1 p C O 0 .-' N Tom' N N O. 0 w� C a O 0 En Ua 0 0 >, 3 I- P CO 0 „9 0 0 W G C ''r 0 r 0 cn C �. o v o N '0 o 0 O.R. 2 Oa N C m Phone Number: 303-228-4286 Fax Number: Section 03 — General Information 0 C O L N U, 0 t4. 0 C 04 C 'C 0 0 0 .-. od 0 o c) a o. a 7 Oa. O N 7 O ui 0 a a o 0 O 0 U a . 0 I 17 CO r L G 00 0 0 a) w Z. 0 C 4r Ci c Q a 1 h W C) C C O •$ U a-. C E CO C. a. N AQ 0 'U L 0 O U a) a -a. a. 61 > CC 0 A in 61 o A L N E �Uaaoo 0 y o n m U - TS Et 0 U a7 T. U C r. O co co ul- m _! `-� M. M M C '`Els� 1 N N N CO r ---... M C7 Kl- a -C Q Q 0 w o - a. > O 17 07 U t -q o v E to a ° on 00 0 O O O ., o -8'-8 ili cCS- 3 3 N ca ,� 0 O C C 7 U O X CO 7. a 4-1 ' Qa� Q C O Q z O O L CO N c O CO 0 C a^ zE co y C ,O a) O 0 00 -0 o a) m R U 0 � 3 3 Section 04 — Processing Eauinment Information C 0 0. O o. '3 ) 1 X cd a 0 a a.. `aJ C .a U ' y CCO P O 0 U cn a 4. in '48 ?'"^- O O C Cs C x .2' E P. V E ( c. A ❑❑❑❑❑ y d B C 0 V O Slowdowns: C 0 C. .C) U H 0 O > M IZI 1) 0 -0 0 C) N C c Cn 0 Ci N L C >. E 2 ) 1.0 10 F T:O X C C C .o- J 6 3 'G. 1.1 0 C) ei a U C C C) Cc • 0 .0 a. C O 4. 0 O :0 .0 a a. o a a. .0 -0 O o a a. O U 77 777 2 2 CO o .4 0 c.> V U U IE E U 2i C N 0 J C N 4.2 G U CI h N w a E W CC col CJ 0 Vented Gas Properties: -p- 0 U 0 VRT-Natural-Gas-Venting-APEN (2) FORM APCD-211 z Emission Source Permit Number: Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Section 05 — Stack Information (Combustion stacks must be listed here) b c7 CT C7 ft E cz N C U Z Vertical 0 Vertical with obstructing raincap 0 Circular: Inner Diameter (inches) = d C a d s CJ N UJ CJ C3 b0 .a a. O w C CJ W Section 07 — Control Device Information Section 08 — Emissions Inventory Information & Emission Control Information r- ('0 a a C C. 00 7 c 0 L e a 0 O z W a u C M O � OC u C C C) i11 C b C C O 'C .0 C +a+ O c a U u Cam) = 0 u ) •� O C) Cy dj U d Estimation Method or Emission Factor Source VI a, CDPHE CDPHE Hysys It >.. V VI >. Hysys II Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) n 00 Zr L M M 0.04 0.02 C. 0 ra . 0 '0....... ti a }+' o F 170.94 Cr (IN O M J t0 00 00 0 r 0 CO . vc Actual Calendar Year Emissionsa Controlled (Tons/Year) Uncontrolled (Tons/Year) Emission Factor i A a .:, 4b/l4H-VOc—1131 .a as a .n ..0 a Uncontrolled Basis o (-4 V O © o Vc 1-1 o O- N 0 O I..4 0 O 0 O Control Efficiency (% Reduction) I CT ( C\ O in CT O IA C O In Cr, Overall Collection Efficiency Control Device Description Secondary O 9 C VOC Burner I VOC Burner VOC Burner VOC Burner VOC Burner Pollutant VOC xON OD Oci, O CO C) N u .0 LE) Xylene 0 ca u X C) C) b K a 0 •,- o 'C Y u CC) CZ CI a 0 a y W 4-1 • a a � 1 0 Fri Q 0 70. ect tt p C5 c 0) ,) d G 0 O O O w Z 0 0 y w E Z R C H O -8- C2o b v F U U G a CZ L n a+ O .h CZ -a'a 17.1 N 7 C N a. to z a. C CO v a C). z N O N 00 rJ APCD-211 Hello