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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 3, P 0 o a T. 0 0. O' W U 0 R a y >_ V ' O oo V g 3 _ R ^ o E N C O o o a m c v '0 01 " U H , m ❑ u U O L C ❑ ❑ L u y m >, T i 'ik V ^ a r^_' V O O e0 G O 0 7 L �_ ate+ —r0 rL 0 W y O U pi i G E F V V j a L W 4 0 � 0.i r a- 5 d H F 4 = O N z e-,cu0 17.-a e U .0 vr0. ^ O .O+ Q r C. L g.' � N d N 0 0 0 = 0 U R V Z 0. U N 31. 0 U 0- 1099 18th St., Suite 2300 Mailing Address: N co 0 _ L_ (303) 291-0420 _ ` 4 .0 03 — General Information N N Ni C- 0 N Do O a w a o 0 0 0 U 0 _ O = O a'.^ G ? N 'O O o v "08 G 3c w Z 31 t` 0 a-7 • 0. Z O O L Of) co L C < J U J b.L U 2 G o on 0 r U 0 J 3 o o . o _= T U = 0 3 o . C j 4 = v w Dr 0 O G b 'a 7 o C N L-1 w .. v 0 a GG ✓ > -5 v° y a CJ S 1=. C J a y.o G 00 op u m0 J 0 p, = a o 3 a -5G J r u 5 0 . a .. C. a- V N — f. ". •F _ U W O U n - V T 0 ^ u 5'.° "O3 7.'V 8 _ _ 'w N = 2 q U 'w 0 _ .2 = 0U= ≥ a L Ll t. or, Cg p., o <U < < C O O O = z h C 0 U il N i O_ Cy O C < = z • CD a n ^ a 6 _L j o O > 0 0 meat Information 0 Section 04 — Processin T 0 m n 5 U v N 0 0, CA C N lV N 0. 0\ v 'O C. Een 05 0 0 00 C. °' o M 0 0 0 2 2 0 > V 0 -= '0 C O y y at m Blowdowns: O N O 0 AP A In > 0V S o o O - 0 O O n a • E 0 V -0 5 W C O > C C- o O o U 3 0 0 > 0 0 0 0 O C 27, 24 U U Z® Vented Gas Properties: Q Z Z a cc FORM APCD-211 Emission Source AIRS ID: & either Lat/Long o Section 05 — Stack Information (Combustion stacks must be listed here) r. 0 o� > • 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 ..i e� _ j(�,n, $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. Vl 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 Hello