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Home My WebLink About20173451.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 September 28, 2017 Dear Sir or Madam: RECEIVED OCT 022017 WELD COUNTY COMMISSIONERS On October 5, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Kerr-McGee Gathering LLC - Platte Valley Gas Plant/Ft. Lupton complex. 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 a 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 �ibliG �1 P.tJL� 0/9/F7 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer cc (mil.Cfl1(f(--p)r Ft(_C.IT,) PwCERfCHfsmfC,c j 10/ 3/(7 2017-3451 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Kerr-McGee Gathering LLC - Platte Valley Gas Plant/Ft. Lupton complex - Weld County Notice Period Begins: October 5, 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: Kerr-McGee Gathering LLC Facility: Platte Valley Gas Plant/Ft. Lupton complex Natural gas processing plant 16157 Weld County Rd 22 Weld County The proposed project or activity is as follows: The applicant is requesting to permit an existing natural gasoline loadout. 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 Divisipn 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 17WE0053 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: Carissa Money 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 1 I Aftff E st, Hydrocarbon Loadout Emissions Inventory Section 01- Administrative information (Facility Allis ID: 123 0057 County Plain 073 Point Section 02 - Equipment Description Details Loadout of natural gesoifne to. Detailed Emissions U. Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficwncy: Requested Overall VOC & HAP Control Efficiency %: 95.00 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Lima Throughput = Potential to Emit (PTE) Volume Loaded = Secondary Emissions- Combustion Device(s) Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year Heat content of waste gas= 1400 Btu/set Volume of waste gas emitted per year = 48805714.29 scf/year Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Heat content of supplemental fuel and pilot gas = Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Erna (PTE) heat content of waste gas routed to combustion device = 1080'. Btu/scf 5562600 set/year Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facil being permtsed2 Loading loss Equation L = 12.46'5'P'M/T Actual Volume Loaded While Emissions Controls Operating = 38750 SWIG estimated combustion emissions based on maximum Flare design of 2.8 MMBtu/hr_ I back -calculated waste gas emitted from assuming 2.8 MMBtu/hr. Using model values, waste gas flow would be 0.6 MMBtu/hr so using 7.8 MMBtu/hr is highest potential emissions. o MMBTU per year 68.328 MMBTU per year 68,328 MMBTU per year 0 MMBTU per year 6.008 MMBTU per year 6,008 MMBTU per year Barrels (bbl) per year Waste gas flow 292 scf/hr, EMS assumed this flow for displaced vapors from 119.695 scf/hr for flash emissions which is based on Promax 411.695 scf/hr, total 0.526323 Mmbtu/hr for estimated gas flow The stabilized hydrocarbon quid sample is valid for developing site specific emissions factors. The sample used to estimate emissions is based on a site -specific sample of the natural gasoline collected 12/23/2015. Factor Meaning Velue Units Source Saturation Factor 06 P True Vapor Pressure :'pzia M Molecular Weight of Vapors 72.0543 Ib/Ib-moo T Liquid Temperature 534.67 ' Rankine L Loading Losses 0 lb/1000 gallons 0 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0 lb/bbl Toluene 0 lb/bbl Ethylbenzene 0 lb/bbl Kylene 0 lb/bbl n-Hexene 0 lb/bbl 224 IMP 0 lb/bbl Pollutant Pollutant MIINMEC Hydrocarbon Loadeas (M/bbl) (lb/bbl) (Volume Loaded) 0.0260 0.000 0.0000 0 0000 0.0000 (Volume Loaded) 0.0011 0.0002 0.0000 0.0000 085 0.0002 0.00000 Control Device Uncontrolled lib/MMetul Uncontrolled (16/661) (Volume Loaded) (waste heat combusted) 0.0015 0,1500 Emission Factor Source Emission Factor Source ®£ 0.000 Section 05 - Emissions Inventory Criteria Pollutants Potential to Erne Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/tear) (44s/tear) Requested Permit Limits Uncontrolled Controlled (,..../1.) (tons/rear) PM10 PM2.5 SOx HOx ' VOC CO 0.28 0.00 0..) 0.3 0.3 0.28 0.00 0.00 0.3 0.3 0.02 0.00 000 0.02 00 5.58 0.00 0.00 5.6 5.6 118.59 0.00 0.00 118.6 5.9 7.43 0.00 0.00 7.4 7.4 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Uncontrolled (Ibs/year) Emissions Controlled (Ibs/year) Requested Permit Limns Uncontrolled Controlled /bs/year) (Ibs/year) Benzene Toluene Ethylbeeeene xylene n.Hexane 224 TMP 505 0 0 505 25 108 0 0 108 5 0 0 0 0 0 2 0 0 2 0.0 3898 0 0 3898 195 82 0 0 02 0 Emission rates from Promax Model lb/hr 13.811394 13.2643 lb/month 947 1007 1263 tpy Stream name 60.4939 Truck Flashing Losses 58.0926 Loading losses 1 of 2 K:\PA\2017\12WEO053.CP1.xlsm Hydrocarbon Loadout Emissions Inventory Section 06 - Reeulaton Summery Ana Regulat Pa A, B Source The loadout must operate with submerged flit and loadout zsrons must be routed to Mare xo satisfy RACT. eqm RACE - Regulation 3, Part B, Section III.D.2.a ?See regulatory applicability worksheet for detailed analysisl Section 01 - Initial and Periodic Sampling and Testing Requirements t is subject to RACT per Reg 7, Section ll.C.1.a(i). See Section 8 far additional discussion. Does the company request a control device efficiency greater than 95% for a flare or combustion deuce? 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 W-TechMcal Anahsis Notes This Ioadqutk unique becauseriisnatoralgasa\bofcsol and Ifrstrored ma bWMftank . gaselinearideoedtitisspewted sampioce ebeptamasmodelta¢af taemboloos These requested tM1a sauna toahoeNimeteer�efomifmmttte"tlashrgg" frumthe Bu1MT.iankee rnadmum doSlgneotloe oftfze./IafooedflarelrfemzfoRutererrr ssbn f4Crorzfor N4k artG cc Thas,thisapproachis more coeservatote KMG dtd e0r fdepGFY wtiwkRENwhenihs kodour been.pperucom KMG p4 aflgMaily bulk and operatedthe plate Thecartent TAIeV LarMltli 9900WE20 bat ntate 2990s.Ar0kObfg189TThe only piece of equlpmertlhrtsasbeoepe 01mtUle pkiit was bunter 1947• 1. 1447. the thee wwncmlderedln atfammeeO farazarre. Sactien ICC. l:.clb7, nnofl gsoafeea coot potenSattSC emgsmls gfeatertben ar eg0af to anairsi0.. and 0000rlt modlflgadoe appb54000h by4J$0/Z009. Anek6{mgsaatsewete thenr Watts exbthlgsoo 4es with potential to emit lotltpyof V0C oe more shalfueifze RACE For PSO/NAHSR, kevaluated what 78.'4180009 wnuldkaye applied attbetime the loadoutveas b an armament area;dips,PSffterreshotds aroald fare applied.Besed oft thepeeththedvalaesf eett4 0.eymw Aomment for 99oPW's107, Addingin 1SB-5?pq VUCfeotnfhe loadout„ ttteru0000lalfaaBRq V/1 Facility did noto¢umveMi£3 ectew and/or .enetraisforths. storm ceobowoutd haee..been sublet to Tiiileii for UdC:Bemb rmee morethan95Ycgntroletficlanet lam requtra tbissaurce. Section 09 - Inventory SCC Codine and Emissions Factors AIRS Point 003 Process', 01 SCC Code 4-06-001-31 Gasoline: Submerged loading (normal service) ',25- hus. ton fprtirlero elate wnif.c.B.A31l/ Pollutant PM10 PM2.5 505 NOn VOC CO Benzene Toluene Ethylbenzene %ylene n-ileaane 224 -OAP estimme-anziaolonsbutf Sion anoagor tee based the aalmumdesgrr ratingofllie Tare Uncontrolled Emissions Factor 0.03 0.03 0.00 0.58 12.4 0.28 0.03 0.01 0.00 0.00 0.20 0.00 Control% Units 0 95 0 95 95 95 95 95 95 b/1,000 gallonstransferred b/1,000 gallons transferred b/1,000 gallons transferred b/1,000 gallons transferred b/1,000 gallons transferred b/1,000 gallons transferred b/S,INJO gallons transferred b/1,000 gallons transferred b/1,000 gallons transferred b/1,000 gallons transferred b/1,000 gallons transferred b/1,000 gallons transferred 2 oft K:\PA\2017\17 W Eoo53.CP1.alsm Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: Kerr-McGee Gathering LLC County AIRS ID: 123 Plant AIRS ID: 0057 Facility Name: Platte Valley Gas Plant /Ft Lupton/ Lancaster Complex. Physical Address/Location: 16157 Weld County Rd 22 Type of Facility: Natural Gas Processing Plant What industry segment? Oil & Natural Gas Production & P Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) Carissa Money 357435 1/18/2017 7/6/2017 Weld Section 02 - Emissions Units In Permit Application Quadrant Section Township Range ❑� Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 073 Hydrocarbon Liquid Loading NG-TL-01 Yes 17WE0053 1 Yes Permit Initial - Issuance s Section 03 - Description of Project This application is for an existing, pressurized natural gasoline liquids loading operation at the Platte Valley Gas Plant. The unreported emissions source was discovered during an audit and was submitted through the voluntary self -disclosure process. This loadout is unique because it is loading out of natural gasoline (NOT condensate or crude oil); the material -is essentially C5+and is used as a denaturant in. alcohols Also, this loadout is unique because the natural gasoline is stored in a bullet tank at —15 psig and then is loaded out into an atmospheric tank truck. See discusion in Section 8 of Loadout tab for regulatory discussion and analysis. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Perr Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? No Colorado Air Permitting Project If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ 0 0 0 Title V Operating Permits (OP) 0 0 0 0 0 0 0 0 Non -Attainment New Source Review (NANSR) 0 0 Is this stationary source a major source? yes If yes, explain what programs and which pollutants here: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) 0 0 0 0 0 0 Title V Operating Permits (OP) 0 0 0 0 0 0 0 0 Non -Attainment New Source Review (NANSR) 0 0 DO Control Division Department of Public Health & Environment Permit number: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: General Description: STRUCTION PERMIT Issuance: 1 Kerr-McGee Gathering LLC Platte Valley/Ft. Lupton/Lancaster Complex 123/0057 16157 Weld County Rd 22 Weld County Natural Gas Processing Plant Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description NG-TL-01 01 073 Truck loadout of pressurized natural gasoline liquids (located at Platte Valley) 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 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.) 3. 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 COLORADO Air Pollution Control Division rrapartrnent of Pahf, Health & i:r.aronrrent Page 1 of 9 c of this construction permit or the date on which such ity su -duled to commence as set forth in the permit application associate: with is perms (n • scontinues 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.) 4. The operato '°• " plete all initial compliance testing and sampling as required in this permit and submit t e a-su is to the Division as part of the self -certification process. (Regulation Number 3, Part Section III.E.) 5. The operator s retain the permit final authorization letter issued by the Division, after completion of sel -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 (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility Equipment ID AIRS Point Pounds per Month Emission Type PM2.5 NO. VOC CO NG-TL-01 073 --- 947 1,007 1,263 Point Note: Monthly limits are based on a 31 -day month. The owner or operator shall calculate monthly emissions based on the calendar month. Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO NG-TL-01 073 --- 5.6 5.9 7.4 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. During the first twelve (12) months after issuance of this permit, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months after permit issuance, compliance with only the annual limitation is required. 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 NG-TL-01 073 Enclosed Flare VOC and HAP COLORADO Air Pollution Control Division D'partrnent of RAI,E,- Ffeat, 6'nv,ronment. Page 2 of 9 8. our aitollowing maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consum•tion Limits Facilit SRS Equipment ID Point Process Parameter Annual Limit Monthly Limit (31 days) NG-TL-01 073 Natural gasoline liquids loaded 456,250 barrels 38,750 barrels The owner or operator shalt calculate monthly process rates based on the calendar month. During the first twelve (12) months after issuance of this permit, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months after permit issuance, compliance with only the annual limitation is required. 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 9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. Et 4.) 10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. This source is an existing source located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 7,II.C.1.a. RACT for this source shall be utilizing submerged fill during loadout of natural gasoline to truck tanks and routing emissions from the natural gasoline loadout to an enclosed flare. (Reference: Regulation 7, II.C.1.a(i)) 13. 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): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. 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. c. The owner or operator shall inspect onsite loading equipment during loading operations to monitor compliance with above conditions. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 14. All natural gasoline 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. COLORADO Air Pollution Control Division Deparimer.t of PAhr Heaitr & F.r irnnrnen?. Page 3 of 9 OPE 15. stpo - wner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O£tM plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) 16. The owner o =°op ate' of a loadout that is controlled shall: a. Install a '';; operate the vapor collection and return equipment to collect vapors during loading .', 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 natural gasoline 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. e. 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. f. Document annual inspections of PRD with an indication of status, a description of any problems found, and their resolution. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. A source initial compliance test shall be conducted on this emissions point to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits specified in this permit. The operator shall also measure inlet VOC, benzene, toluene, ethylbenzene, xylene, n -hexane, and 2,2,4-trimethylpentane emission rate prior to the control device. Results of the inlet testing for VOC, benzene, toluene, ethylbenzene, xylene, n - hexane, and 2,2,4-trimethylpentane shall also be used to calculate emission factors for this unit for the pollutants listed in this permit (in units of lb/bbl) using Division approved methods. Results of the analysis shall be submitted to the division as part of the self -certification process and must demonstrate the emission factors established through the analysis are less than or equal to the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If an emissions factor developed through this analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder," the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies) unless the pollutant is below APEN-reporting thresholds. The operator shall measure and record, using EPA approved methods, VOC mass emission rates at the enclosed flare inlet and outlet to determine the destruction efficiency of the enclosed flare (ProMax models shall not be used to determine the flow rate or composition of the waste gas sent to the enclosed flare for the purposes of this test) and demonstrate the enclosed flare achieves a minimum destruction and removal efficiency (DRE) of 95.0% for VOC. The natural gasoline liquids throughput and pressure of the natural gasoline storage tank shall be measured and recorded during this test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly COLORADO Air Pollution Control Division Department tai Heal«, b Emata:, mens. Page 4 of 9 have the results projected up to the monthly or annual test results by the allowable number of operating hours for at averaging time eference"'ommon Provisions Section II.C and Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods Volatile Organic Compounds using EPA Reference Method 18 and 25A Monoxide using EPA approved methods nzene, toluene, ethylbenzene, xylene, n -hexane, and 2,2,4-trimethylpentane ng EPA approved methods. ADDITIONAL REQUIREM TS 18. 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 (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the Operating Permit. The application for the modification to the Operating Permit is due within one year of the issuance of this permit. 20. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: COLORADO Air Pollution Control Division Department of P}bhc Ffeaitn & .rmrcnrnenr. Page 5 of 9 Equipment ID Point • ent Description Pollutant Emissions - tons per year Significant Modification Threshold Current Permit Limit Truck loadout of natural gasoline liquids CO 100 7.4 NOx 40 5.6 VOC 40 5.9 GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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 regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. COLORADO Air Pollution Control Division bepariment of P icl c lieaE;P: 6 awir;nrnen Page 6 of 9 By: Carissa Money Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Kerr-McGee Gathering LLC for natural gasoline liquids loadout COLORADO Air Pollution Control Division Dfpar'men3l {eat;h 8 Ersrcrnrren. Page 7 of 9 Notes rmit issuance: 1) Ts 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 based on the co u upon request of the control regulation or and complete appli terial processing limits and emission limits contained in this permit are tirates requested in the permit application. These limits may be revised wner or operator providing there is no exceedance of any specific emission y ambient air quality standard. A revised air pollution emission notice (APEN) on 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. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 073 Benzene 71432 505 25 Toluene 108883 108 5 n -Hexane 110543 3,898 195 2,2,4- Trimethylpentane 540841 82 4 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 073: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 0.0244 0.0244 Flare manufacturer CO 0.0326 0.0326 Flare manufacturer V0C 0.5199 0.0260 Promax 71432 Benzene 0.0011 0.0001 Promax 108883 Toluene 0.0002 0.00001 Promax 110543 n -Hexane 0.0085 0.0004 Promax 540841 2'2'4 Trimethylpentane 0.0002 0.00001 Promax Controlled emission factors are based on a flare efficiency of 95%. 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 the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated COLORADO Air Pollution Control Division Department }{eats & Enirnnrnent Page 8 of 9 ng a specific expiration date call the Division at (303)-692- 31 7) is permit u �„ s t e requiremen o old 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 Operating Permi Status Major Source of NOX, VOC, CO, and HAP PSD Major Source of CO NANSR Major Source of NOX and 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 Pollution Control Division Deparrtnent of P_i A c Health & 'nvironr .en?. Page 9 of 9 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: I� WEO057) AIRS ID Number: 123 / 0057 / 011D [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Site Name: Site Location: Kerr-McGee Gathering LLC Platte Valley Gas Plant/Ft. Lupton Complex Site Location 16157 Weld County Rd. 22 County: Weld County Mailing Address: (Include Zip Code) P.O. Box 173779 Denver, CO 80217 E -Mail Address2: jillian.yamartino@anadarko.com NAICS or SIC Code: 1311 Permit Contact: Jillian Yamartino Phone Number: 720-929-4374 '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. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 12/2016 357433 ©� COLORADO 1 I L31`ry IDepartmentofPublic { MULh6Eavtmanm¢nl Permit Number: AIRS ID Number: 123 /0057 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action 0 NEW permit OR newly -reported emission source Request coverage under traditional construction permit ✓❑ -OR - ❑ Request coverage under General Permit GP073 O MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR • APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: loading operations. 3 In addition to the APEN filing fee ($152.90), a General Permit fee of $250.00 must be paid with the : plication. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Construction permit application for natural gasoline Section 3 - General Information General description of equipment and purpose: Tank truck loadout of natural gasoline. Facility equipment Identification: NG-TL-01 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / Will this equipment be operated in any NAAQS nonattainment area? 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? Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 2 I ❑✓ Yes ❑ No ❑ Yes 0 No ❑✓ Yes ❑ No ❑ Yes ❑✓ No ❑ Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No PCOLORADO --tiepimnemd Wauc Permit Number: r -T -Thy AIRS ID Number: 123 / 0057 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑ Condensate ❑ Crude Oil 0 Other: Natural Gasoline If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth Bbl/yr 456,250 Bbl/yr This product is loaded from tanks at this facility into: (eg, "rail tank cars" or "tank trucks") Actual Volume Loaded: 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: 75 °F True Vapor Pressure: 5.96 Psia ® 60 ° F Molecular weight of displaced vapors: 72 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 5 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 12/2016 3 COLOR ADO Departmenea}Punue Permit Number: AIRS ID Number: 123 /0057 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM)i 40.1469,-104.7502 Operator a Stack-ID:Noy.„(ACFM) Discharge Height Above Ground Level g ; (Feet) x4u_..� Temper Flory Rafe ? F �, V .c�ty p=' NG-TL-01 30 Indicate the direction of the stack outlet: (check one) ✓❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Section 6 - Control Device Information ❑ Loading occurs using a vapor balance system Requested Control Efficiency ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC and HAPs 7.8 MMBtu/hr TBD Make/Model: TBD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: 400 95 95 % Waste Gas Heat Content: 1400 Btu/scf Constant Pilot Light: ✓❑ Yes ❑ No Pilot burner Rating: 0.06 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: 0 Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 4 CQL0RADO .m.�Jou iuc IF IpilNOMMlommni Permit Number: AIRS ID Number: 123 /0057 / PM [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): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO CO VOC ECD 95% HAPs ECD 95% Other: ❑ Using State Emission Factors (Required for GP07) VOC ❑ Condensate 0.236 Lbs/BBL ❑ Crude 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0u16 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.) Uncontrolled Emission Factor Emission Factor Units Emission" Factor Source (AP -42, Mfg. etc) Controlled° (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year)' Uncontrolled (Tons/year) 0.007 lb/MMbtu AP -42 Table 1.4-2 0.3 0.3 SOx 0.001 Ib/MMbtu AP -42 Table 1.4-2 0 0 NO„ 0.15 Ib/MMbtu Manufacturer 5.6 CO VOC 0.20 93 Ib/MMbtu lb/bbl Manufacturer ProMax + AP -42 l i .y 7.4 ( Benzene 0.02 lb/bbl ProMax ce:ld6 flirt. 2� ill) Toluene 0.008 lb/bbl ProMax de rlin. Ethylbenzene 1.8E-05 lb/bbl ProMax elemffi. Xylenes n -Hexane 0.0021 0.192 lb/bbl lb/bbl ProMax ProMax demin. -3Y �linli. 1415 .Q26 2,2,4- Trimethylpentane 0.031 lb/bbl ProMax demin. Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. c i771 Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 5 ,COLORADO_ b.p mten«nwk Home, 6r .:one,o Permit Number: AIRS ID Number: 123 /0057 / [Leave blank unless APCD has already assigned a permit # and MRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is com kite; ->:r and correct. nature of LegallyL/Authorized Person (not a vendor or consultant) Jillian Yamartino Date Sr. HSE Representative Name (print) Title 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 (add an additional $250 if applying for a General Permit) 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 12/2016 6 COLORADO bupIttmeetefhWtinn HnIN NTiMMIDIRAt Hello