HomeMy WebLinkAbout20162206.tiffCOPHE
-q
!COLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
July 6, 2016
Dear Sir or Madam:
11.is 1' )U116
On July 7, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for
Extraction Oil It Gas. LLC - Meader 5-N Tank Battery. 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 8 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
Pc>blrG Re.A./ P L, HL, C'w
-77t t/tCC
/l€7ICo
2016-2206
f CqI J.
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.sovicdphe e
John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
8
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Extraction Oil Et Gas, LLC - Meader 5-N Tank Battery - Weld County
Notice Period Begins: July 7, 2016
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: Extraction Oil Et Gas, LLC
Facility: Meader 5-N Tank Battery
Exploration and production facility
SESW Section 5, T11N. R63W
Weld County
The proposed project or activity is as follows: Exploration and production facility including four (4) crude
oil tanks.
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 16WE0519 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:
Stephanie Spector
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
co,..
co,.
16WE0519
CDPHE
Permit number:
Date issued:
Issued to:
Construction Permit
Air Pollution Control Division
Issuance: 1
Extraction Oil a Gas, LLC
Facility Name: Meader 5-N Tank Battery
Plant AIRS ID: 123/9E6F
Physical Location: SESW Section 5, T11N, R63W
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
Oil Storage
Tanks
002
Four (4) 500 barrel fixed roof storage vessels
used to store crude oil.
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 the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operators 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.Rov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B,
Section III.G.2.)
2. 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.)
�. _ _ Page 1 of 7
3. ra'=i, s '.11 pl e all i `; ial compliance testing and sampling as required in this
permiit ults he Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
4. 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
5. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
Oil Storage
Tanks
002
---
---
17.0
3.2
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
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.
6. 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
Oil Storage
Tanks
002
Enclosed Combustor
VOC and HAPs
PROCESS LIMITATIONS AND RECORDS
7. 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
Oil Storage
Tanks
002
Crude Oil throughput
128,138 barrels
The owner or operator shall monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
COLORADO
Air Pollution Control Division
DeoarlerrF.koim xeaih5Evi.onmrm
Page 2 of 7
at
'pet nif Lumber a 1 t digit A S ID number assigned by the Division (e.g. 123/4567/001)
shall ( `'"ha'r T on tfire" f lect anent for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
9. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
10. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed, have no visible emissions during normal operations, 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.
11. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate 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 except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to
the Division upon request. This control requirement must be met within 90 days of the date
that the storage tank commences operation.
12. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING & MAINTENANCE REQUIREMENTS
13. 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 OEM plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
14. 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 XII.C, XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
15. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, on a weekly basis 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 XII.C, XVII.B.2. and XVII.A.16)
COLORADO
Air Pollution Control Division
Page 3 of 7
ADD
16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (N0,) 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.
17. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source shall not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
18. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
19. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located in
the Requirements to Self -Certify for Final Authorization section of this permit.
COLORADO
Air Pollution Control Division
Depamm: rd'nIDACHeaLn @?nnronment
Page 4 of 7
20. LnT `pe ni s iy uecI re ance upon the accuracy and completeness of information supplied
by thrr`$wnei""ni opei,it 'rid is o ditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
21. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
22. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and 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.
23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Stephanie Spector, PE
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil & Gas, LLC. Newly permitted
crude oil tanks at a synthetic minor facility.
COLORADO
Air Pollution Control Division
Page 5 of 7
No
ththis -.-.= it issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or 'raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(Ib/yr)
002
Benzene
71432
852
43
Toluene
108883
746
37
Ethylbenzene
100414
48
2
Xylenes
1330207
182
9
n -Hexane
110543
5554
278
2,2,4-
Trimethylpentane
540841
823
41
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 002:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
0.0196
---
Engineering Calculation
CO
0.0499
---
Engineering Calculation
VOC
5.3034
0.2652
Engineering Calculation
71432
Benzene
0.0066
0.0003
Engineering Calculation
108883
Toluene
0.0058
0.0003
Engineering Calculation
110543
n -Hexane
0.0433
0.0022
Engineering Calculation
540841
2'2'4
Tnmethylpentane
0.0064
0.0003
Engineering Calculation
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
COLORADO
Air Pollution Control Division
•.,rtprtme%a• 5aFM1V Reich sa-.wonment
Page 6 of 7
F
6) I acc dar e h g.R.S: 5-71114.1, eath Air Pollutant Emission Notice (APEN) associated with
1 permit iCvafr to? a rgentrive yeas 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 permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A)
when applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
V0C
PSD
Synthetic Minor Source of:
V0C
MACT HH
Not Applicable
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
Page 7 of 7
Construction Permit Application
Preliminary Analysis Summary
Section 1 - Applicant Information
Company Name:
Extraction Oil & Gas, LLC
Permit Number:
16WE0519
Source Location.
Meader 5-N Tank Battery
SESW Section 5, T11 N, R63W, Weld County (attainment)
Equipment Description:
Crude oil tanks
AIRS ID:
123-9E6F-002
Date:
June 2, 2016
Review Engineer:
Stephanie Spector, PE
Control Engineer:
Chris Laplante
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
CP1
Transfer of Ownership
APEN Exempt/Permit Exempt
Section 3 — Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
X
Yes
No
Did the applicant submit all required paperwork?
X
Yes
No
Did the applicant provide ample information to determine emission rates?
X
Yes
No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
On what date was this application complete?
February 26, 2016
Section 4 — Source Description
AIRS Point
Equipment Description
002
Four (4) above ground 500 bbl atmospheric crude oil storage tanks. Emissions
from these tanks are controlled by an enclosed combustor.
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
Yes
X
No
If "yes", for what pollutant?
PM,o
CO
Ozone
Is this location in an attainment maintenance area for
any criteria pollutant?
Yes
X
No
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT per Regulation 3, Part B, Section III.D.2)
PM10
CO
Ozone
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
Regulation 7, Sections XII and XVII.C may apply)
Yes
X
No
Page 1
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
002
Source provided site -specific emission factors using gas sample and E&P Tanks
for VOC and HAP emissions. Source used the state ratio for NOx and CO. Please
see Section 14 for calculations.
Did the applicant provide actual process data for the emission inventory?
X
Yes
No
Basis for Potential to Emit (PTE)
AIRS Point
Process Consumption/Throughput/Production
002
128,138 BBL per year (106,782 x 1.2)
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
002
106,782 BBL per year
2016
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process ConsumptionfThroughput/Production
002
128,138 BBL per year
Does this source use a control device?
X
Yes
No
AIRS Point
Process
Control Device Description
% Reduction
Granted
002
01
Enclosed combustor
95
Section 6 — Emission Summary (tons per year)
Point
NO,
VOC
CO
Single HAP
Total HAP
PTE:
002
1.3
339.8
3.2
2.8 (Hexane)
4.1
Uncontrolled point
source emission rate:
002
1.3
339.8
3.2
2.8 (Hexane)
4.1
Controlled point
source emission rate:
002
1.3
17.0
3.2
0.1 (Hexane)
0.2
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(lb/yr)
Are the
emissions
reportable?
Controlled Emission
Rate (Iblyr)
Benzene
71432
A
852
Yes
43
Toluene
108883
C
746
Yes
37
Ethylbenzene
100414
C
48
No
2
Xylenes
1330207
C
182
No
9
n -Hexane
110543
C
5554
Yes
270
2,2,4-TMP
540841
C
823
Yes
41
Note: Regulation 3, Part A, Section ll.B.3.b APEN emission reporting requirements for non -criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
X
Yes
No
If "yes", complete the information listed below
Page 2
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
002
01
Visible
emissions
Regulation Number 7, Sections XII.C,
XVII.B.2. and XVII.A.16
Method 22
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
What is this facility classification?
X
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
X
PSD
NA NSR•
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why?
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?
Yes
X
No
For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
X
Yes
No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
Yes
X
No
AIRS Point
Section 12 — Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
002
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator
of a source shall allow or cause the emission into the atmosphere of any air pollutant which
is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings
taken at 15 -second intervals for six minutes. The approved reference test method for
visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July,
1992)) in all subsections of Section II. A and B of this regulation.
Regulation 2 — Odor
002
Section I.A - 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.
Regulation 3 - APENs, Construction Permits, Operating Permits, PSD
002
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in an attainment area with uncontrolled actual emissions of
two tons per year or more of any individual criteria pollutant (pollutants are not summed) for
which the area is attainment.
(Applicant is required to file an APEN since emissions exceed 2 tons per year VOC)
002
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section II.D.3.a)
Regulation 6 - New Source Performance Standards
002
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
Is this source greater than 19,800 gallons (471 bbl)? Yes
Is this source subject to NSPS Kb? Yes or No
WHY?
Page 3
002
NSPS OOOO: Tanks with the potential to emission equal to or greater than 6 TPY.
Are uncontrolled VOC emissions greater than 6 TPY? Yes
Are controlled emissions greater than 6 TPY? Yes
Source is subject to NSPS OOOO requirements.
Regulation 7 —Volatile Organic Compounds
002
XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
(Applicant is not subject to the emission control requirements for condensate tanks
since it is located in an attainment area)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
(Applicant is currently subject to this since actual uncontrolled emissions are
greater than 6 tpy of VOC)
Regulation 8— Hazardous Air Pollutants
002
MACT EEEE: Organic Liquids Distribution
This source is not subject to MACT EEEE because it is not located at a major source of
HAP.
002
MACT HH
This source is not subject to MACT HH because it is not located at a major source of HAP.
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process
Description
Emission
Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor Source
Control
(%)
002
01
E&P Crude Oil
Storage Tanks
126.2706
lb/1000 gal
VOC
No
Engineering Calculation
(E&P Tanks)
95
0.4672
lb/1000 gal
NOx
No
Engineering Calculation
0
1.1870
lb/1000 gal
CO
No
Engineering Calculation
0
0.1583
lb/1000 gal
Benzene /
71432
No
Engineering Calculation
(E&P Tanks)
95
0.1387
lb/1000 gal
Toluene/
108883
No
Engineering Calculation
(E&P Tanks)
95
0.0089
lb/1000 gal
Ethylbenzene/
100414
No
Engineering Calculation
(E&P Tanks)
95
0.0339
lb/1000 gal
Xylenes/
1330207
No
Engineering Calculation
(E&P Tanks)
95
1.0319
lb/1000 gal
n -Hexane/
110543
No
Engineering Calculation
(E&P Tanks)
95
0.1530
lb/1000 gal
2,2,4-TMP/
540841
No
Engineering Calculation
(E&P Tanks)
95
SCC
404003121 — Fixed Roof Tank, Crude Oil, working+breathing+flashing losses
Page 4
Section 14 — Miscellaneous Application Notes
AIRS Point
002
Condensate Storage Tanks
A permit will be issued because the uncontrolled VOC emissions are greater than 5 TPY (permit threshold).
Operator provided site -specific emission factors using an extended gas analysis sampled on 5/16/2016 and
E&P Tanks model run. Emissions and emission factors were based on actual throughput of 106,782 bbl/yr.
Component Uncontrolled
Emissions
(TPY)-
Actual
Uncontrolled
Emissions
(TPY)-PTE
Uncontrolled
Emissions
(lb/yr)-PTE
Controlled
Emissions
(TPY)-
PTE
Controlled
Emissions
(Ib/yr)-
PTE
Emission
factor
(lb/bbl)
Emission
factor
(lb/1000
gal)
VOC 1283.152
339.782
---
17.0
---
5.3034
126.2706
Benzene 0.355
0.426
852
0.0213
43
0.0066
0.1583
Toluene 10.311
0.3732
746
0.0187
37
0.0058
0.1387
Ethylbenzene 0.020
0.024
48
0.0012
2
0.0004
0.0089
Xylenes 10.076
0.091
182
0.0046
9
0.0014
0.0339
n -hexane i 2.314
2.7768
5554
0.1388
278
0.0433
1.0319
2,2,4-TMP 0.343
0.4116
823
0.0206
41
0.0064
0.1530
NOx and CO were calculated using the state ratios approved by the division that originated from inventory.
NOx = (0.0037 lb/lb-VOC) * 339.8 TPY VOC = 1.2573 TPY NOx
CO = (0.0094 Ib/Ib-VOC) * 339.8 TPY VOC = 3.1941 TPY CO
Component
NOx
CO
Emissions
(TPY)
1.2573
3.1941
Emission factor
(lb/bbl)
0.0196
0.0499
Page 5
Emission factor
(lb/1000 gal)
0.4672
1.1870
n
[Leave blank wiles
ility Equipment ID k
G
O 6
L
Co
Y ❑ id
0 L
2 -
a C
_ G =_
1 V
C - A V V v
.c E c c.,z
d a c ` <
p' U a a tt
L F G r. v. 4
m G O ce it L L
n C > Li H :a!
a
V y O e c
m
a E < u❑❑ V d
a CL c
-4 a,y „ c L
V .] Z u E >
(J O V O E k C
c z C c
≥ a p _ E
O 0 [:. 'c a` c
`c -
Z C U 'c .2 -°
w > 4 a
E C .. ;
Z° x m5 E
V`` c c L L
g.. ., r ` ` Vi Ul
V V V Z Z el 0z`z`ce❑❑<`<
nested Action
Section 01 — Administrative Information
N
>W
" L
Cc
M
CJ
U T
-0 `
v
V
u _
z
O
J N
N
CO CO
Y
05
co
2
O
U
<0
co
c0
Lit
F
Z z
c
u v7
CD
z_
F-
U)
N
C,)
N
W
Source I meal ion'.
N
O
0
CJ
u
N
ailing Address: 370 17th Street, Suite 5300
Denver, Colorado
Person To Contact: Josh Carlisle
CO
C
Section 03 — General Information
For new or reconstructed
m
O
N
A
0
N
O
Normal Hours of So
Are Flash Emissions anticipated at these tanks
submit Form APCD-105.
V
V
z
ca
❑ C. U
T V
8I 20
L V
o
LY
.d4Fu
- 2
❑ ❑ i -
=
Z
o
o G
() O
C J r O
c a ou
a
k E.O
2 z o o
m
0 o a m
a
o a d'E S w
z< V v
0 iOJ U c o
C L� Z O -
c `u i=> e5 c,-,.
n
2
c
00
O ;
C
E 79
o Y E c
F, E
C 7
C
c' ,_V C c E
_6 G
>. 0
70. p.t L
c v cE. < 0. u E -"V
L J V � LV
EG
- ._ _ a L V, a - V\
L r K_ P e L,:,C
C H V..O It
V N `•V {1]
L Q^ " 'V •
'2 .t,..
ry L C
S"< .E.- c
.., s E a S
m
C 0 C J. L t V L V
L O n? V V '' a - =
=m< '�nmiE - c
≥ 8 _ ' . =L m d o
`o p :C4-
, T 9 y `e .Z 0 3
o `-2 c' giE W cc, OM .o
E C L : C E Y 3
0= r, cnaT, c E t i ea -
O` con • c...E C c O G "O o
z• v 3 E. Y. c 0 h a` U
o `C c- '5 E v Cs m O U E. QC. ≥.d n_y n Lp 6u c i
oL�0'7,�z oC=
r.
0
rg
E
C
C
C
F -
G
a
0
O
C
0
tat
h
CO
CO
N
Ct
n
c6 c7
o c
r �
Sr
- U
0 0
O
>
c
Li
V
00
Ia-
0
l")
0
O
u
0
CO
C
N
O
N
O
CO
0
N
r--
O
O
O
N
Welk Serviced by this Storage Tank or Tank Battery (P&P Sites Only)
Newly Reported Well
■❑.0
E 7
d
e D
E C)
z2
API Number
05- 123 - 42263
AP Fool- A Pt O-2 I 0-O mIcTankAIT N. doc
FORM APCD-210
Permit Number:
Section 06 -Stack (Source. if no combustion) Location (Datum & either Lar/Long or UTM)
a
V
C
in
O
u
z
Oy a
p Z
Cl cy
O
co
0
0
0
0
C,
m
0
a
N
O
n•
0
M
co
0
C
z
z
Other (Describe):
Width (inches) _
E&P Sites On
Information
oration Technolo
Cl)
9
Section 08 — Gas/L
C
CO
I —
w
0
E
L
L
e
0
U
O
E
W
C
C
O
E
a-
a-
0
E
C
O
u
h
et
O
v
C
.0
Y
O
C
C
0
C
G
Emission Factor
Data Source
APCD EF
E&P Tanks
APCD EF
E&P Tanks
E&P Tanks
Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. I
Requested Permitted Emissions
IControlled (Tons/Year)
lh
O
N
NO
?
r
�0
O
Uncontrolled (Tons/Year)
01.
m
N
C
co^
m
M
M
• O
N
Actual Calendar Year Emission
Controlled (Tons/Year)
C
•
cr
2.7
O
O
eN-
0
Uncontrolled (Tons/Year)
O
N
2.7
con
m
N
O
N
Emission Factor
Units
o
o
07
00.17
> on
Zi
n
—
a
a
n
Q
Uncontrolled Basis
f�
O
0
en
O
O
0
0
n
O
O •
O
L 0.043
Pollutant
V
0
Ethylbenzene
6
C)
t
2,2,4-Trirnethylpentanc
0
0
0
N
"
0
v
z>-5
C
T
OD
H
X
O
N_
E
L Q)
It a
o
.. CO
N
C
E
- C
1 n 4
any
E
U
C
n
-c
J C C 4 V
a C 0
C < c-
=
eo_r, <EC
tN
O
C
CO
FORM APCD-210
Hello