Loading...
HomeMy WebLinkAbout20170370.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 1150O St PO Box 758 Greeley, CO 80632 February 8, 2017 Dear Sir or Madam: RECEIVED FEB 16 2017 WELD COUNTY COMMISSIONERS On February 9, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Kerr-McGee Oil Et Gas Onshore LP - Battery 36221021. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: 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 Pc) G RA—Vi€LA CC '• PLCmm/-rP),FLcPN, va�aai�-1 PWCE Ur n oailcoi (-1 2017-0370 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Kerr-McGee Oil Et Gas Onshore LP - Battery 36221021 - Weld County Notice Period Begins: February 9, 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 Oil Et Gas Onshore LP Facility: Battery 36221021 Oil and gas production facility SESW Sec 13 T1 N R66W Weld County The proposed project or activity is as follows: Source is operating a low pressure separator (heater -treater) which vents emissions to an enclosed flare while emissions are unable to be recycled by a vapor recovery unit (VRU). 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 16WE0525 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 wilt 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 Aff?�� . " COLORADO ?.,K xn,,. Colorado Air Permitting Project Version No. 1.00 Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? yes If yes, for what pollutant? ❑ Carbon Monoxide (CO) 0 Particulate Matter (PM) Bradley Eades 344879 2/29/2016 12/15/2016 Kerr McGee Oil and Gas Onshore LP 123 9E71 Battery 36221021 (Lochbuie 4C 30C-13) SESW Sect. 13 T1N R66W Exploration & Production Weil Pad Oil & Natural'Gas Production & Processin Section 02 - Emissions Units In Permit Application 0 Ozone (NOx & VOC) AIRs Point # Emissions Source Type Emissions Control? Permit it Issuance # Self Cert Required? Action Engineering Remarks 003 002 Pro ed :er'Storage Tank Yes Yes L6WE0526.X1 16WE0525 XP 1 APEN Required /; Permit Exempt ,Initia <1% crude oil by venting during: VRU downtime Section 03 - Description of Project This application isrequesting a permit fora new "Generation 4" tank battery facility in Weld County (non -attainment): KMG is requesting permit coverage for one (1) vapor recovery tower (VRT). Hydrocarbon liquid produced at this faciltiy flows from a HIP separator to a VRT prior to storage in atmospheric tanks. During normal operation, gas vented fro mthe VRT is routed to a vapor recovery unit (VRU) which compresses the gas and directs it to the sales gas gathering pipeline: During periods of VRU downtime, the gas vented from the VRT is routed to enclosed corn bustors (ECDs). Emissions while VRT gas is routed to the ECDs (flare run-time) is a function of condensate throughput. Source is permitting condensate storage tanks under GP01 and produced water tanks will be issued an exemption based on <1% crude oil by volume. Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?' Requ het£c M1nor Pei Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 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, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD): Title V Operating Permits (OP) : VOC Non -Attainment New Source Review (NANSR): VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: No:;., Yes One (1) vapor recovery tower (VRT) that processes liquid from the second stage of separation to cree r third stage of liquid/gas separation. Overhead flash gas from the VRT,is routed to the vapor recovery uni (VRUs) in a closed loop process. When the VRUs are unable to capture the entire overhead gas stream, 002 flash gas is routed to an enclosed combustion device (ECU). The ECD has a minimum control efficiency of 95%. Emissions are a function of condensate throughput while overhead gas is routed to the ECD It is assumed that the flash gas is routed to the ECD 30% of the time. This'pemtit covers emissions when flash gas is routed to the ECDs. Equipment Description This source vents natural gas from: one 1) vapor recovtower Emissions from this source are: r. Natural gas venting from one (1) vapor recovery tower. Emissions from this source are routed to a flare. Calculations The site specific emission factors developed for this source were determined through the use of two pressurized liquid samples, and two E&P Tanks simulations associated with the pressurized liquids samples. The pressurized liquid samples were obtained from two different wells at the facility on January 20, 201&. The wells from which the samples were taken are as follow: Lochbuie 4C-13HZ & Lochbuie 30C-13HZ. Two separate E&P Tanks simulations were. conducted using the two pressurized liquid samples. The results of the simulation were averaged to determine the site specific emission factors. The simulation uses a sales oil API gravity of 44 degrees. The following tables contain the information from the E&P Tanks simulations used to determine the emission factors: E&P Tanks Simulation 1 (Lochbuie 30C-13HZ) Throughput: 24 bbl/day Pollutant Emission Rate Emission Rate Uncontrolled Emission Factor VOC 12.027 lb/hr 105356.52 lb/year 12.03 lb/bbl Benzene 0.015 lb/hr 131.40lb/year 0.02 lb/bbl Toluene 0.012 lb/hr 105.12 lb/year 0.01 lb/bbl Ethylbenzene 0.001 lb/hr 8.76 lb/year 0.00 lb/bbl Xylenes 0.003 lb/hr 26.28 lb/year 0.00 lb/bbl n -Hexane 0.087 lb/hr 762.12 lb/year 0.09 lb/bbl 2,2,4-TMP 0.006 lb/hr 52.56 lb/year 0.01 lb/bbl Note: The E&P Tanks simulation was run on a basis of 24 bbUday (6780 from lb/hr to lb/bbl results in the same value. E&P Tanks Simulation 2 (Lochbuie 4C-13HZ) Throughput: 24 bbl/day Pollutant can Emission Rate Emission Rate Uncontrolled Emission VOC 14.419 lb/hr 126310.44 lb/year 14.42 lb/bbl Benzene 0.016 lb/hr 140.16 lb/year 0.02 lb/bbl Toluene 0.013 lb/hr 113.88 lb/year -1.01 lb/bbl Ethylbenzene 0.001 lb/hr 8.76 lb/year 0.00 lb/bbl Xylenes 0.003 lb/hr 26.28 lb/year 0.00 lb/bbl n -Hexane 0.096 lb/hr 840.96lb/year 0.10 lb/bbl 2,2,4-TMP 0,007 lb/hr 61.32 lb/year 0.01 th lb/bbl ersiorc Note: The. E&P Tanks simulation was run on a oasts of 24 bbl/day (8760 bbi/year}. Rs a resuH e v from lb/hr to lb/bbl results in the same value. Average of Simulation 1 and 2 Throughput: 24 bbl/day Pollutant Emission Rate Emission Rate Uncontrolled Emission VOC 13.223 lb/hr 115833.48 lb/year 13.223 lb/bbl Benzene 0.0155 lb/hr • 135.78 lb/year 0.016 lb/bbl Toluene 0.0125 lb/hr 109.50 lb/year 0.013 lb/bbl Ethylbenzene 0.001 lb/hr 8.76 lb/year 0.001 lb/bbl Xylenes 0.003 lb/hr 26.28 lb/year 0.003 lb/bbl n -Hexane 0-0915 lb/hr 801.54 lb/year 0.092 lb/bbl 2,2,4-TMP 0.0065 lb/hr 56.94lb/year 0.007 lb/bbl Iblh f Note: The overall emission rates (Ib/tu) were determined using a stmpie average of tine emtsscon rates ( r) ar each pollutant obtained from the Underhill 27C-17HZ and Underhill 28N-17NZ simulations. 16WE0525.CP1.xlsm One (1} vapor recovery tower (VRT)that processesliquid.from the second stage of separation to create a third stage of Iiquid/gas separation. Overhead flash gas from the VRT is muted to the vapor recovery units (VRUs} in a'closed loop process. When the VRlJs are unable td capture the entire overhead;gas stream, flash gas is routed to an enclosed combustion device (ECD}. The ECD has a minimum control efficiency of 95%. Emissions are a function of condensate throughput while overhead; gas is routed to control It is assumed that the flash gas is routed to the ECD 30% of the time- Tills Permit covers emissions when flash gas is rotated to the ECDs. Requested Throughput: Total throughput to VRT: VRU downtime: VRT Throughput during VRU downtime: Flaring Information Equipment Description Three (3) enclosed combus Manufacturer TBD r Model TBD Serial Number TBD Control Efficiency 95.00% 203,238 bbl/year 30% 60,972 bbl/year Combustion emission factor source: 0.0037 Ilb NOx/Ib VOC Emissions Summary Table CDPHE Inter -Office Communication (2005-03-22) 0.0094 III) CO/lb VOCI Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 13.223 lb/bbl 0.661 lb/bbl 403.12 tpy 20.16 tpy E&P Tanks NOx 0.0489 lb/bbl 0.0489 lb/bbl 1.49 tpy 1.49 tpy CDPHE CO 0.1243 lb/bbl 0.1243 lb/bbl 3.79 tpy 3.79 tpy CDPHE Benzene 0.0150 lb/bbl 7.50000E-04 lb/bbl 914.6 lb/yr 45.7 lb/yr E&P Tanks Toluene 0.0115 lb/bbl 5.75000E-04 lb/bbl 701.2 lb/yr 35.1 lb/yr E&P Tanks Ethylbenzene 0.0010 lb/bbl 5.00000E-05 Ib/bbl 61.0 lb/yr 3.0 lb/yr E&P Tanks Xylenes 0.0030 lb/bbl 1.50000E-04 lb/bbl 182.9 lb/yr 9.1 lb/yr E&P Tanks n -Hexane 0.0875 lb/bbl 4.37500E-03 lb/bbl 5335.1 lb/yr 266.8 lb/yr E&P Tanks 2,2,4-TMP 0.0065 lb/bbl 3.25000E-04 lb/bbl 396.3 lb/yr 19.8 lb/yr E&P Tanks Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'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.' AQCC Regulation 2 Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air." AQCC Regulation 7 Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014'? Yes This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, Section XV1I.B.2 Additional Notes: 1. The operator did not provide a sales oil analysis with this application. As a result, it was suggested to the applicant that a sales oil API gravity of 44 degrees be used based sales oil data from the COGCC . Operator agreed to re -run the model using this value and submitted revised calculations and APEN addendum on 1/23/2017. The original application assumed a post-VRT API gravity of 52 degrees. Initial sampling will not be required with this issuance since samples were taken from two producing wells at this facility within 1 year of application submittal. 2. This is a Anadarko Gen 4 Tank Battery and as such, emissions are estimated per discussions with Division staff on 12/16/14. Per this discussion, KMG uses a sample pulled downstream of the inlet HLP separator (upstream of the VRT) as input composition to E&P Tank. The E&P Tank model is run assuming the bottom of the HLP separator as the E&P Tank separator, and the VRT as the E&P Tank oil tank. 3. The amount of time that a valve is open allowin ggas to the ECED is monitored on a daily basis. The total monthly liquid throughput to the VRT is multiplied by the percentage of time the VRU is down (i.e. while valve is open allowing gas to the ECD) to obtain throughput to VRT during VRU downtime. For the purposes of establishing permit limits, a maximum VRU downtime of 30% is assumed. 4. Secondary emissions from combustion of the waste gas are calculated using emission factros from a 2005 APCD memo for use on storage tanks (Ib/IbVOC). I calculated emissions using the "GOR" (scf/bbl) and heating value of the waste gas calculated in the E&P tanks run (average of the two model runs). This resulted in a less conservative estimate of emissions of CO and NOx and therefore the calculations proposed with the original application are being used here. It was communicated that the Division prefers the use of AP -42 factors and calculated waste stream data to the lb/lb VOC factor referenced in the 2005 APCD Memo. 5. O&M plan outlines continous monitoring of VRU downtime and calcualtion methods used to demonstrate compliance with the liquid throughput limits in this permit. 16WE0525.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Issuance Date: December 30, 2015 Section 01- Adminstrative Information Facility AIRS ID: 123 County 9E71k Plant 003 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: One (1) 210 bbl produced water tank. Emisstonsfrom the produpi Emissions are routed to an enclosed combustor Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Requested Permit Umit Throughput = Potential to Emit (PTE) Produced Water Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas= NA" Btu/scf Volume of waste gas emitted per BBL of liquids'. produced = NA scf/bbl Actual heat content of waste gas routed to combustion device = Request heat content of waste gas routed to combustion device = 141,876 Barrels (bbl) per year 70,251. Barrels (bbl) per year 70,251.: Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = 141,8766 NA MMBTU per year NA MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = NA Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant Produced Water Storage Tanks Uncontrolled E.F. (Ibs/bbl Produced Water Throughput) Controlled E.F. (Ibs/bbl Produced Water Throughput) Uncontrolled E.F. (Ibs/Ib VOC) Control Device Uncontrolled E.F. (Ibs/bbl Produced Water Throughput) MMBTU per year PM10 VIIIIINI `NN XXX_WCZEIMILXXXVIO\�� � VOC `O.26 s6t W\X NX 0.0094'; 0.0025„ 0.007 0.000 1.A MIIEMMEMI 0.000 r: ,p 0.000 4III.V4faXIIIII.14NNW MIMSTEMMIll 0.000 VIVII0lIkVIIII XXXVI4IILVI6IXIIIIIN 74040467%., n -Hexane Section 05 - Emissions Inventory Emissions Factor Source Citation Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 NOx VOC CO #VALUE! #VALUE! #VALUE! #VALUE! #VALUE! #VALUE! #VALUEI #VALUE! #VALUE! #VALUE! 0.1 0.1 0.1 0.1 0.1 22.3 22.3 1.1 18.6 0.9 0.2 0.2 0.2 0.2 0.2 Hazardous Air Pollutants Potential to Emit Uncontrolled (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 6.0E-01 6.0E-01 3.0E-02 5.0E-Ol 2.5E-02 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 1.9E+00 1.9E+00 9.4E-02 1.6E+00 7.8E-02 0.0E+00 0.0E+00 0.0E+0D 0.0E+00 0.0E+00 Section 06- Regulatory Summary Analysis _ Regulation 3, Parts A, B Regulation 7, Section XVII.B, C.1, C.3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart 0000 (See regulatory applicability worksheet for detailed analysis) Source requires APEN, is permit exempt Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3, a Storage tank is subject to Regulation 7, Section XVII.C.2, as provide Storage Tank is not subject to NSPS 0000 4 of 7 K:\PA\2016\16W E0525.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Issuance Date: December 30, 2015 section 07- Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emisions factor to estimate emissions? �- If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. SeP PSMemo14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and intial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section o8 - Technical Analysis Notes Source is claiming exemption for <1% oil by volume per Regulation 3, P Section 09 - Inventory SCC Coding and Emissions Factors rt I3, ion ll.D.1.M;:< AIRS Point # Process # SCC Code 003 01 4-04-003-15 Fixed Roof Tank, Produced Water, workingcbreathing+Flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 #VALUE! 0 lb/1,000 gallons liquid throughput PM2.5 #VALUE! 0 lb/1,000 gallons liquid throughput NOx 0.02 0 lb/1,000 gallons liquid throughput VOC 6.2 95 lb/1,000 gallons liquid throughput CO 0.06 0 lb/1,000 gallons liquid throughput Benzene 0.17 95 lb/1,000 gallons liquid throughput Toluene 0.00 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 lb/1,000 gallons liquid throughput n -Hexane 0.52 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput 5 of7 K:\PA\2016\16W E0525.CP1.xlsm Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Regulation 3 Parts Aand 0- APEN and Permit Requirements ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, MOO greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3(? (Not enough information NON ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M( 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)7 (Source requires APES. is permit exempt Colorado Regulation 7. Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation, well production facility', natural gas compressor station' or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC? 'Storage tank is subject to Regulation 7, Section 3011, B, Cl S C.3, as provided below Section X011.0 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions section XVII.C.3- Recordkeeping Requirements 5. Does the produced water storage tank contain only"stabilized" liquids? If no, the following additional provisions apply. 'Storage tank is subject to Regulation?, Section XVII.C.2, as provided below Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60. Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production. Transmission and Distribution 1. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after August 23, 2011? 2. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430? 3. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 'Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 -Testing and Procedures 460.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(cl - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] NA Yes;. Yet Source Rey Source is Al Source is Al Go to next i Go to then. Go to then Source is su Go to then Go to the n. Go to then Storage Tar AIRS (County/Plant) 123/9E71 Permit No. 16WE0525 & 16WE0526 Date 1/30/2017 Point # 002 SCC 31000205 Pollutant or CAS Uncontrolled Emission Factor Emission Factor Source Controlled Actual Emissions (tpy) Controlled Requested Emissions PTE Ctrl. Elf NCRP = reportable 002 31000205 VOC 13.223 lb/bbl Gas Analysis/ProMax (tpy) 20.2 (tpy) % ? 002 31000205 NOx 0.049 lb/bbl AP -42 403.1 1.49 95% --- 002 31000205 CO1.49 0.124lb/bbl AP -42 3.79 0% -- 002 31000205 Benzene 0.015 lb/bbl Gas Analysis/ProMax 45.7 3.79 914.6 0% — 002 31000205 n -Hexane 0.088 lb/bbl Gas Analysis/ProMax 266.8 5335.1 95% Yes 002 31000205 Toluene 0.012 lb/bbl Gas Analysis/ProMax 35.1 95% Yes 002 31000205 Ethylbenzene 0.001 lb/bbl Gas Analysis/ProMax 3 701.2 61 95% Yes 003 40400315 Xylenes 0.003 Ib/bbl Gas Analysis/ProMax 9.1 95% No 003 40400315 VOC 6.238 lb/1000 gallons CDPHE 0.9 182.9 95% No 003 40400315 Benzene 0.167 lb/1000 gallons CDPHE 49.7 18.6 993.1 95% - n -Hexane 0.524 lb/1000 gallons CDPHE 156.1 3121.3 95% Yes 95% Yes Permit number: Date issued: Issued to: Co Air Po Depart CONSTRUCTION PERMIT 16WE0525 Issuance: 1 Kerr-McGee Oil and Gas Onshore LP Facility Name: Tank Battery #36221021 Plant AIRS ID: 123/9E71 Physical Location: SESW Sec 13 T1 N R66W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT 002 One (1) vapor recovery tower (VRT) that processes liquid from the second stage of separation to create a third stage of liquid/gas separation. Overhead flash gas from the VRT is routed to the vapor recovery units (VRUs) in a closed loop process. When the VRUs are unable to capture the entire overhead gas stream, flash gas is routed to an enclosed combustor. Emissions are a function of condensate throughput while overhead gas is routed to the ECD. Enclosed Combustor 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.cotorado.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. COLORADO Air Pollution Control Division Page 1 of 8 2. Within one hundred and -fight d . s 80) the t r of ommencement of operation or issuance of this permit, om • a e ith - on i ns c tained in this permit shall be demonstrated to the per 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.>yov/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 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.) 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 II.A.4.) Annual Limits: Facility Equipment ID C AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO VRT 002 --- 1.5 '__'__' 20.2 r_—__- __A 3.8 .....H...A.. ...ea Point *r. nlenlntc Note: See "Notes to Permit Holder" for informati 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. ;COLORADO Air Pollution Control Division Page 2 of 8 7. The emission points in t control equipment as lis established in this perm maintained with the emissions ess than or equal to the limits III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled VRT 002 Emissions from the VRT are routed to an Enclosed Combustor during Vapor Recovery Unit (VRU) downtime VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. 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 VRT 002 Condensate throughput while emissions are routed to enclosed combustor 60,972 bbl/yr omp lance wit 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 shall continuously monitor and record Vapor Recovery Unit (VRU) downtime while emissions are routed to the control device. 10. The owner or operator must use monthly VRU downtime records, monthly condensate throughput records, calculation methods detailed in the OfrM 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 11. 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) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) COLORADO Air Pollution Control Division TX"k':i v1 P .alt: i Ie tth k J.l" ;:± Page 3 of 8 13. The combustion device - pew is b'ect Regulation Number 7, Section XVII.B.2. General Provisi• to enf • ble I a fl or other combustion device is used to control emission. • at - -r• - o - - to c ly with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) 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 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. 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 NOX per year, a change in COLORADO Air Pollution Control Division • Page 4 of 8 annual actual em sion .f �nR 1) t� "�•er y r or m're or five percent, whichever is greater, above th leve e d o ast P N; or For sources emi a e, a.J►ange 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. 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 20. 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. 21. 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. 22. 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. 23. 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. 24. 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 Division hlean v L'. ;YCDIirr_'1C Page 5 of 8 regulations of the Air Qu- tr l mi .i (A C , inc ding failure to meet any express term or condition of the • - - Di • de e a p it, conditions imposed upon a permit are contested by - n. • - - or Divis evokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. 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. 26. 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 Kerr-McGee Oil and Gas Onshore LP "COLORADO Air Pollution Control Division ;f Putiss tieit°r: Page 6 of 8 Notes to Permit Holder at the tim 1) The permit holder is requir- _ ' ay-Lesng ti 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/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) 002 Note All Benzene 71432 915 46 Toluene 108883 701 35 Ethylbenzene 100414 61 3 Xylenes 1130207 183 9 n -Hexane 110543 5335 267 2,2,4- Trimethylpentane n t 540841 396 20 on cn erla reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 002: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source NOx 0.0489 0.0489 2005-03-22 APCD Memo CO 0.1243 0.1243 VOC 13.223 0.661 EEtP Tanks 71432 Benzene 0.015 7.5E-04 108883 Toluene 0.012 5.75E-04 110543 n -Hexane 0.088 4.4E-03 540841 2, Trimethylpentane 0.007 0.007 3.25E-04 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. COLORADO Air Pollution Control Division De nert cfPublic kfaE;^s io•irrrne Page 7 of 8 The emission factors listed separator pressure 6) In accordance with C.R.S. 2`- - .1, -. h -•ll . t" flissiorr tice (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 with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: (VRT) temperature of 50 °F and Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC 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 8 of 8 �tA.k.a I /OLA General APEN - Form APCD-200 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. 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. There may be a more specific APEN for your source (e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available 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: )(2 JJE Dias i a.3 /95?i/c o. AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Kerr-McGee Oil and Gas Onshore LP Site Name: 36221021 Site Location: SESW Sect. 13 TIN R66W Mailing Address: PO Box 173779 (Include Zip Code) Portable Source Home Base: Denver,CO 80217.3779 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Krey, Carissa Phone Number: (720) 929-6916 E -Mail Address: carissa.krey@anadarko.com 'Please 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. Form APCD-200 - General APEN - Revision 7/2015 1 I COLORADO N.vllp6f4whotunoul Permit Number: AIRS ID Number: 123/ / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ® NEW permit OR newly -reported emission source (check one below) • STATIONARY source 0 PORTABLE source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name ❑ Add point to existing permit O Change permit limit 0 Transfer of ownership2 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: Requesting individual permit for vapor recovery tower (VRT) 2For 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: Provide 3rd stage of gas/liquid separation Manufacturer: Model No.: Serial No.: Company equipment Identification No. (optional): 2 3 3 5 4 4 For existing sources, operation began: / / For new or reconstructed sources, the projected start-up date is: / / ® Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Seasonal use percentage: Dec -Feb: Mar -May: days/week weeks/year June -Aug: Sept -Nov: Form APCD-200 - General APEN - Revision 7/2015 2 IcOLoaaho Depa.tmentelhb,c Hiill114Enultenit nl Permit Number: AIRS ID Number: 1 23 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Processing/Manufacturing Information ft Material Use ❑ Check box if this information is not applicable to source or process From what year is the actual annual amount? 3 Condensate throughput in 60972 bbl/yr Flash gas Requested values will become permit limitations. Requested limit(s) should consider future process growth. Section 5 - Stack Information 40.044530 / -104.727760 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. ter, ` Pf z_ a O erator ` tack ID No vw .3z',yuzs 2 :i5 .x, t...,, �?-"_-.. -� s Ran f zRlschanrge Heights �':j 0, Above Ground Leve4 armFee t ..<"" _� _ a�`,. �,�_ ''H>r i„ c �x �F r�,_#.�)�a� t � y emp t� r p �z� .. -, . t.s.,.� > T .�". � Flow Rateyelocrty a `ACF1) W r' ;��'-a3 _x f ,t { t w , i �k f: s , -ifE/sec�x -,s'' ' ,.. .�,.�va VRT ECD 20 Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): ® Upward ❑ Horizontal Indicate the stack opening and size: (check one) ® Circular n Square/rectangle ❑ Other (describe): Interior stack diameter (inches): 48 ❑ Upward with obstructing raincap Interior stack width (inches): Interior stack depth (inches): Form APCD-200 - General APEN - Revision 7/2015 3 I COLORADO onni:m;e or maim E. EIMIEMmint TSP (PM) Permit Number: AIRS ID Number: 123/ / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Combustion Equipment Et Fuel Consumption Information ® Check box if this information is not applicable to the source (e.g. there is no fuel -burning equipment associated with this emission source) Design Input Rate t'MMBTU/hr) Actual:Annual Fuel Use ; (Specify Unttsl Renested Annual Permit Limit' s`q � - (Spec�fy Unrts) From what year is the actual annual fuel use data? Indicate the type of fuel used4: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) ❑ Field Natural Gas Heating value: BTU/SCF ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑ Coal Heating value: BTU/lb Ash Content: Sulfur Content: ❑ Other (describe): Heating value (give units): 3 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 4 If fuel heating value is different than the listed assumed value, please provide this information in the "Other" field. Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ® Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): ontrol Equipment verall;Control Efficierc reduction o missions)" PMi o PM2.5 SOx NOx CO VOC ECD 95 Other: Form APCD-200 - General APEN - Revision 7/2015 4I ICOL0 RADO 1,116En o, nm,c HNn1�6EnvnPnmmY Permit Number: MRS ID Number: 123/ / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 (continued) 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. Pollutant Uncontrolled Emission k Factor S'eci { fy Units) ` c Emission Factor Source (AP 92 Mfq ;.efc r r 5'''.61'4, Actual Annual r , N3 Ermssions�='� - �Reqte Annual Permit E 3x Erfiissro irr Uncontrolled_ Tons/ ear C ontrolled5 Tons/ ear Uncontrolled 0701.0 4e),',- Controlled Tons/ eat TSP (PM) PMio PM2.5 SOX NOX 0.0037 Ib/IbVOC APCD 2005 1.49 CO 0.0094 Ib/IbVOC APCD 2005 3.79 VOC 11.9021b/bbl E&PTank 403.11 20.16 Other: 3 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. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP- hazardous air pollutant) emissions equal to or greater than 250 lbs/year? ® Yes ❑ No If yes, use the following table to report the non -criteria pollutant (HAP i emissions from source• CAS Number Chemical Name '. Overall Control Efficiency Uncontrolled Emission Factor . ,. ,{specifyunrts) Emission Factor Source (�P 42:.Mfg etc) _.,; _ ,.. • Uncontrolled Actual missions .,€ ,(ibs/year) Controlled Actual Emissions (l13.0S44).' Benzene 95% 0.015 ib/bbl E&P Tank 914.57 45.73 Toluene 95% 0.0115 lb/bbl E&P Tank 701.17 35.06 Ethylbenzene 95% 0.001 Ib/bbl E&P Tank 60.97 3.05 Xylenes 95% 0.003 lb/bbl E&P Tank 182.91 9.15 n-Hexan 95% 0.0875 lb/bbl E&P Tank 5335.01 266.75 224-TMP 95% 0.0065 lb/bbl E&P Tank 396.31 19.82 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-200 - General APEN - Revision 7/2015 5I (COLORADO Uepimnent of nm., • Hold, 4Envltonre.11 Permit Number: AIRS 1D Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. re of�e Signat�Legally Authorized Person (not a vendor or consultant) (la -3 / 17 Date Krey, Carissa HSE Representative Name (please print) Title Check the appropriate box to request a copy of the: ❑ Engineer's Preliminary Analysis conducted ® 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 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 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: www.colorado.gov/pacific/cdphe/air-permits Form APCD-200 - General APEN - Revision 7/2015 6 �-HwCOLORADO nsistic 6Fnvt' h«mew Hello