HomeMy WebLinkAbout20161925.tiff?t b
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
June 13, 2016
Dear Sir or Madam:
RECEIVED
JUN 152016
WELD COUNTY
COMMISSIONERS
On June 15, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for Bill
Barrett Corporation - 18414_NE Rosenberg 6-61-30. 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
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govicdphe
John W. Hickenlooper. Governor Larry Wolk, MD. MSPH. Executive Director and Chief Medical Officer
CC, P t_ ecki,
Co -`a1- ao‘ CQ
2016-1925
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Bill Barrett Corporation - 18414_NE Rosenberg 6-61-30 - Weld County
Notice Period Begins: June 15, 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: Bill Barrett Corporation
Facility: 18414_NE Rosenberg 6-61-30
Exploration and Production Facility
NWNE Sec30 T6N R61W
Weld County
The proposed project or activity is as follows: The applicant proposed to permit a new exploration and
production facility including venting from VRT-1 and VRT-2 during Vapor Recovery Unit Downtime.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
IUI.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 14WE0805 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:
David Thompson
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 DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
14WE0805
Bill Barrett Corporation
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the 18414_NE Rosenberg 6-61-30, located in the NWNE
of Section 30, Township 6N, Range 61W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Description
Point
VRU
Bypass
Heated separator and VRTs to reduce flash emissions. Emissions
007 are a function of condensate throughput during VRU bypass.
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 THOSE 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 after issuance of this permit, by submitting a Notice of Startup form to
the Division. The Notice of Startup form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/other-air-permittinq-notices. Failure to notify the
Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) after 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.
(Reference: Regulation No. 3, Part B, 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
AIRS ID: 123/9C0C Page 1 of 8
Wellhead Version 2012-1
ado Department of Public Health and Environment
Air Pollution Control Division
erm" :. .n :" " ed '" ispermit;(ii) discontinues construction for a period
P =
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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
I I I. F.4. )
The operator shall"complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 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 (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
yp
NO,
VOC
CO
VRU Bypass
007
--
12.4
--
Point
See "Notes to Permit Ho der #4" for information on emission factors and methods used to
calculate limits.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
7. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Flare
007
Enclosed Combustion Device (ECD)
VOC, HAPs
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the throughput shall be maintained by the applicant and made
AIRS ID: 123/9C0C
Page 2 of 8
mrado Department of Public Health and Environment
Air Pollution Control Division
aVail25fe tNisfbn-for inset t'fion upon request. (Reference: Regulation 3, Part B,
II.A.4)
Process/Consumption Limits
Facility
Equipment, ID
AIRS
Point
Process Parameter
Annual Limit
VRU Bypass
007
Liquid Throughput through separator
while VRU is being bypassed
95,000 bbl/yr
The owner or operator shall calculate 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
9. The permit number and AIRS ID number shall be marked on the subject equipment
(heated flash separator and VRT) for ease of identification. (Reference: Regulation
Number 3, Part B, III.E.) (State only enforceable)
10. 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. (Reference: Regulation No. 1, Section II.A.1. & 4.)
11. No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30% opacity for a period or periods aggregating more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.)
12. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
13. Upon startup of these points, the applicant shall follow the 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&M plan are subject to Division approval prior to implementation. (Reference:
Regulation No. 3, Part B, Section III.G.7.)
14. Within 180 days after issuance of this permit, the owner or operator shall continuously
monitor and record VRU downtime while emissions are routed to the backup Enclosed
Control Devices using a SCADA (supervisory control and data acquisition)
system. The owner or operator shall use monthly VRU downtime records, monthly
condensate throughput records and calculation methods detailed in the O&M Plan to
demonstrate compliance with the process and emissions limits specified in this
permit. After issuance of this permit and prior to startup of the SCADA monitoring
system, the operator shall monitor and record VRU downtime manually through site
AIRS ID: 123/9C0C Page 3 of 8
ado Department of Public Health and Environment
Air Pollution Control Division
visits a minimum of once per week until the SCADA monitoring system
is continuously monitoring and recording VRU downtime, at which point the manual
checks for VRU downtime are no longer required. If the VRU is observed to not be
operating during a site visit, the operator must record downtime hours as the number of
hours elapsed since the last time the VRU was observed to be operating.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. The owner or operator shall demonstrate compliance with opacity standards using EPA
Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section
II.A.5).
Periodic Testing Requirements
16. The operator shall complete a site specific extended liquids analysis of a pressurized
liquid sample from the low pressure outlet of the three-phase inlet separator. Results of
sampling shall be used to verify the emissions factor (lb VOC/bbl) for the VRT emissions
stream used in the permit application. The VOC site specific emission factor shall be
verified using ProMax modeling and the site specific extended liquids analysis.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, I I.C)
a. Annually 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 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.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
18. 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 No. 3 Part D).
GENERAL TERMS AND CONDITIONS
AIRS ID: 123/9C0C Page 4 of 8
trado Department of Public Health and Environment
Air Pollution Control Division
19. `"` `This g'ermit'Thtcf any°attaChmerfenust 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 No. 3, Part B, Section II.B upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
20. 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 No. 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.
21. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the applicant 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 applicant or applicant's agents. It is valid only for the
equipment and operations or activity specifically identified on the permit.
22. 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.
23. 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 applicant, or the Division
revokes a permit, the applicant or owner or operator of a source may request a hearing
before the AQCC for review of the Division's action.
24. 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.
25. 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:
David Thompson
Permit Engineer
AIRS ID: 123/9C0C Page 5 of 8
Permit Histo
rado Department of Public Health and Environment
Air Pollution Control Division
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Bill Barrett Corporation
AIRS ID: 123/9C0C Page 6 of 8
rado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder:
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 (Reference:
Regulation No. 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 permittee 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
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 permittee 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/aocc-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.
If a NCRP is listed as reportable in this table, then a corresponding emission factor needs to be included
in Notes to Permit Holder #4.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
007
Benzene
71432
3091
Yes
155
Toluene
108883
2166
Yes
108
Ethylbenzene
100414
84
Yes
14
Xylenes
1130207
569
No
28
n -Hexane
110543
20149
Yes
1007
2.2,4-
Trimethylpentane
1027
Yes
51
5) The emission levels contained in this permit are based on the following emission factors:
Point 007:
CAS #
Pollutant
Emission Factors
Uncontrolled
Emission Factors
Controlled
Source
NOx
0.068 Ib/MMBtu
0.068 lb/MMBtu
AP -42, Table 13.5-1
CO
0.37 Ib/MMBtu
0.37 Ib/MMBtu
AP -42, Table 13.5-1
VOC
5.1819 lb/bbl
0.2591 lb/bbl
Promax
71432
Benzene
0.0325 lb/bbl
0.0016 lb/bbl
Promax
108883
Toluene
0.02281b/bbl
0.0011 lb/bbl
Promax
110543
n -hexane
0.2121 lb/bbl
0.0106 lb/bbl I
Promax
AIRS ID: 123/9C0C
Page 7 of 8
rado Department of Public Health and Environment
Air Pollution Control Division
e I ions ' ".rs for point 001 are based on the combustor control
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 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:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor of:
VOC
PSD or NANSR
Synthetic Minor of:
VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
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
SubpartA— SubpartZ
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
9) A self certification form and guidance on how to self -certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123/9C0C
Page 8 of 8
Division Information
Engineer:
David Thompson
Control Engineer:
Chris Laplante
Review Date:
02/25/2015
Application Date:
03/03/2015
Facility Identifiers
Permit No.
14WE0805
AIRS
County#
123 Weld
Facility #
9C0C
Facility Type:
exploration and production facility
❑ Located in the 8 -hour non -attainment area?
Administrative Information
Company Name:
Bill Barrett Corporation
Source Name:
18414_NE Rosenberg 6-61-30
Source Location:
SIC:
NWNE Sec 30 T6N R61W
1311
Mailing
Address
Address 1:
Address 2:
City, State Zip:
Bill Barrett Corporation
1099 18th St, Suite 2300
Denver, CO 80202
Person To
Contact
Name:
Phone:
Fax:
Email:
Wes Hill
303-312-8546
000-000-0000
whill@billbarrettcorp.com
Potentially located in ozone nonattainment area
True Minor
O Synthetic Minor for:
f voc r NOx F CO
Requested Action
Self Certification Required?
Issuance Number:
Yes
1
Source Description:
Oil and gas exploration and production facility known as the 18414_NE Rosenberg 6-61-30, located in the NWNE Sec 30
T6N R61W, Weld County, Colorado.
Point
Name
Type
Control
Action
003
Condensate
Tanks
Condensate Tanks
Flare
Newly
reported
source
004
produced water
tanks
Water Tanks
Flare
Newly
reported
source
005
condensate
loadout
Loadout
None
Newly
reported
source
006
fugitive
Fugitives
None
Newly
reported
source
007
VRT/Separator
Separator Venting
Flare
Newly
reported
source
003 2 VRT's where emissions are controlled by a combustor during VRU downtime (50%)
Requsted Throughput
95000
bbl
Control
Efficiency
Flare
95.00%I
Emissions Summary Table
i
Pollutant
Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
VOC
5.1819
lb/bbl
246.1 tpy
12.3 tpy
E&P TANK
Benzene
0.0325
lb/bbl
3087.5 lb/yr
154.375 lb/yr
E&P TANK
n -Hexane
0.2121
lb/bbl
20149.5 lb/yr
1007.475 lb/yr
E&P TANK
Regulatory Review
Regulation 2 — Odor
Regulation 6 - New Source Performance Standards
V
n
VRT-1 and VRT-2
uested Action (check applicable request boxes)
Section 02 — Re
Section 01 —Administrative Information
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FORM APCD-211
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& either Lat/Long o
Section 05 — Stack Information (Combustion stacks must be listed here)
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> •
0.
F
er Diameter (inches) =
N
O
> ❑
❑ L
C
O
Y
V
o L
0 r
N
V N
a>
a
0
O
Y W
at = 0
O 0,
0 O
0
U
°'.
W
0
U
ction 07 — Control Device Inform
Manufacturer Guaranteed:
a
0.
.0
0
U
0 9
0
O
a
Ca
0
E
U
Waste gas heat content:
m
0
a
VRT-1 and VR
O b �
9 6
v G
U
o - O
U
N 0 _
cal U E
o
O O
y
O
E
O T O
ta
U c
C
Requested VOC & L
>
>
N
N
U
N
Describe Any Other:
of Informatio
ProMax
AP -42
I
0
0
aL
0
0
4
0£
0
a`
0
a`
w`
Requested Permitted Emissions
M
N
N
k
O,
O
0
ti
_
0
p
0
M
rN
0
0
_
?
6
g?
d
'
0
Actual Calendar Year
Emissions4
Controlled
(Tons/Year)
M
S'
nn
,,
N
M
O
t`fir
a
O
p
di
2:
O
o
O
0
d
Uncontrolled
(Tons/Year)
T
5
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e�
_
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$5
_
iti
p
A
O
k)
i
Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report p
I Vim will hp rlwiwiiA A num r__:r r ___.
Emission Factor
Units
t
r
S
u
!!L
t
u
u
Opt
^�
w
O
O'
N
6925 O.2t 7.1 I -lb/Mscf ib/bl
Uncontrolled
Basis
E
'-°
In
�
C'
c
m
C
O'
Rj'� Q
of.
C
4
4I;
Control
Efficiency
(% Reduction)
N
o.
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0
V)
O,
in
OC
Y1
O\
Vl
a
Overall
Collection
Efficiency
0
0
0
0
0
0
0
0
0
0
0
0
Secondary
Control Devi(
Primary
Pollutant
0
>
0
z
0 0
U
Benzene
O
F
Ethylbenzene I
N
x
0.
x
FORM APCD-211
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