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Home My WebLink About20151695.tiff * CDPHE ; COLORADO Co 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 1150 0 St RECEIVED PO Box 758 Greeley, CO 80632 JUN 0 8 2015 June 1, 2015 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On June 3, 2015, the Air Pollution Control Division will begin a 30-day public notice period for Grand Mesa Pipeline, LLC - Lucerne Station. 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 RkIkAier :AllA3 2015-1695 ((016 : P+/)�� llY) (Olt F COI 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe :;:7! John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer CDPH Air Pollution Control Division Co Notice of a Proposed Project or Activity Warranting Public ' Comment Website Title: Grand Mesa Pipeline, LLC - Lucerne Station - Weld County Notice Period Begins: June 3, 2015 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: Grand Mesa Pipeline, LLC RECEIVED Facility: Lucerne Station JUN 0 8 2015 Crude oil and condensate storage and transport facility Section 27, T6N, R65W WELD COUNTY COMMISSIONERS Weld County The proposed project or activity is as follows: Crude oil and condensate storage and transport facility consisting of eight crude/condensate storage 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): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) 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 15WE0038 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 Chaousy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1 I Y COLORADO A STATE OF COLORADO of cozo COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ie '�� AIR POLLUTION CONTROL DIVISION ICCC,,,�� ° TELEPHONE: (303)692-3150 V'„��" ,Ct* ♦1876• CONSTRUCTION PERMIT PERMIT NO: 1 5WE0038 Issuance 1 DATE ISSUED: ISSUED TO: Grand Mesa Pipeline, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Crude oil and condensate storage and transport facility, known as the Lucerne Station, located at Section 27, Township 6N, Range 65W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment AIRS Description ID Point T-1501 thru T-1508 002 Eight (8) 150,000 BBL internal floating roof tanks used to store crude oil and condensate. 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 commencement of operation of new tanks, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. 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 commencement of operation of new tanks, 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 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 AIRS ID: 123/9D73 Page 1 of 12 Condensate Tank Version 2009-1 Col, •o D ; 'e o" 'ublic Health and Environment A Air Pollution Control Division time of the es ima ed comple ion da e. e Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 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 (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: AIRS Tons per Year Facility Equipment ID Point NO, VOC CO Emission Type T-1501 thru T-1508 002 --- 42.4 --- Point See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate limits. Annual records of the actual emission rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. PROCESS LIMITATIONS AND RECORDS 6. 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 applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Process Parameter Annual Limit Point Crude oil and 85,200,000 T-1501 thru T-1508 002 condensate throughput BBL/year Roof landing events 8 events/year STATE AND FEDERAL REGULATORY REQUIREMENTS 7. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 8. 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.) 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. This source is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart Kb, Standards of Performance for Volatile Organic AIRS ID: 123/9D73 Page 2 of 12 Col o D er o Public Health and Environment Air Pollution Control Division Liquid Storage essels or w ich cons ruction, reconstruction or modification commenced after July 23, 1984, including, but not limited to, the following: § 60.112b Standard for volatile organic compounds (VOC). (a) The owner or operator of each storage vessel either with a design capacity greater than or equal to 151 m3 containing a VOL that, as stored, has a maximum true vapor pressure equal to or greater than 5.2 kPa but less than 76.6 kPa [...] shall equip each storage vessel with: (1) A fixed roof in combination with an internal floating roof meeting the following specifications: (i) The internal floating roof shall rest or float on the liquid surface (but not necessarily in complete contact with it) inside a storage vessel that has a fixed roof. The internal floating roof shall be floating on the liquid surface at all times, except during initial fill and during those intervals when the storage vessel is completely emptied or subsequently emptied and refilled. When the roof is resting on the leg supports, the process of filling, emptying, or refilling shall be continuous and shall be accomplished as rapidly as possible. (ii) Each internal floating roof shall be equipped with a mechanical shoe seal between the wall of the storage vessel and the edge of the internal floating roof. (A mechanical shoe seal is a metal sheet held vertically against the wall of the storage vessel by springs or weighted levers and is connected by braces to the floating roof. A flexible coated fabric (envelope) spans the annular space between the metal sheet and the floating roof.) (iii) Each opening in a noncontact internal floating roof except for automatic bleeder vents (vacuum breaker vents) and the rim space vents is to provide a projection below the liquid surface. (iv) Each opening in the internal floating roof except for leg sleeves, automatic bleeder vents, rim space vents, column wells, ladder wells, sample wells, and stub drains is to be equipped with a cover or lid which is to be maintained in a closed position at all times (i.e., no visible gap) except when the device is in actual use. The cover or lid shall be equipped with a gasket. Covers on each access hatch and automatic gauge float well shall be bolted except when they are in use. (v) Automatic bleeder vents shall be equipped with a gasket and are to be closed at all times when the roof is floating except when the roof is being floated off or is being landed on the roof leg supports. (vi) Rim space vents shall be equipped with a gasket and are to be set to open only when the internal floating roof is not floating or at the manufacturer's recommended setting. AIRS ID: 12319D73 Page 3 of 12 . Col K' .o D ;rii' `e o `-ublic Health and Environment Air Pollution Control Division (vii ach penetra ion of a in ernal f oa ing roof for the purpose of sampling shall be a sample well. The sample well shall have a slit fabric cover that covers at least 90 percent of the opening. (viii) Each penetration of the internal floating roof that allows for passage of a column supporting the fixed roof shall have a flexible fabric sleeve seal or a gasketed sliding cover. (ix) Each penetration of the internal floating roof that allows for passage of a ladder shall have a gasketed sliding cover. § 60.113b Testing and procedures. The owner or operator of each storage vessel as specified in §60.112b(a) shall meet the requirements of paragraph (a), (b), or (c) of this section. The applicable paragraph for a particular storage vessel depends on the control equipment installed to meet the requirements of§60.112b. (a) After installing the control equipment required to meet§60.112b(a)(1) (permanently affixed roof and internal floating roof), each owner or operator shall: (1) Visually inspect the intemal floating roof, the primary seal, and the secondary seal (if one is in service), prior to filling the storage vessel with VOL. If there are holes, tears, or other openings in the primary seal, the secondary seal, or the seal fabric or defects in the internal floating roof, or both, the owner or operator shall repair the items before filling the storage vessel. (2) For Vessels equipped with a liquid-mounted or mechanical shoe primary seal, visually inspect the internal floating roof and the primary seal or the secondary seal (if one is in service) through manholes and roof hatches on the fixed roof at least once every 12 months after initial fill. If the internal floating roof is not resting on the surface of the VOL inside the storage vessel, or there is liquid accumulated on the roof, or the seal is detached, or there are holes or tears in the seal fabric, the owner or operator shall repair the items or empty and remove the storage vessel from service within 45 days. If a failure that is detected during inspections required in this paragraph cannot be repaired within 45 days and if the vessel cannot be emptied within 45 days, a 30-day extension may be requested from the Administrator in the inspection report required in §60.115b(a)(3). Such a request for an extension must document that alternate storage capacity is unavailable and specify a schedule of actions the company will take that will assure that the control equipment will be repaired or the vessel will be emptied as soon as possible. (4) Visually inspect the internal floating roof, the primary seal, the secondary seal (if one is in service), gaskets, slotted membranes and sleeve seals (if any) each time the storage vessel is emptied and degassed. If the internal floating roof has defects, the primary seal has holes, tears, or other openings in the seal or the seal fabric, or the secondary seal has holes, tears, or other openings in the seal or the seal fabric, or the gaskets no longer close off the liquid surfaces from the atmosphere, or the slotted membrane has more than 10 percent open area, the AIRS ID: 123/9D73 Page 4 of 12 Col o D e o Public Health and Environment Air Pollution Control Division owner or operators all repair the i ems as necessary so that none of the conditions specified in this paragraph exist before refilling the storage vessel with VOL. In no event shall inspections conducted in accordance with this provision occur at intervals greater than 10 years in the case of vessels conducting the annual visual inspection as specified in paragraphs (a)(2) and (a)(3)(ii) of this section and at intervals no greater than 5 years in the case of vessels specified in paragraph (a)(3)(i) of this section. (5) Notify the Administrator in writing at least 30 days prior to the filling or refilling of each storage vessel for which an inspection is required by paragraphs (a)(1) and (a)(4) of this section to afford the Administrator the opportunity to have an observer present. If the inspection required by paragraph (a)(4) of this section is not planned and the owner or operator could not have known about the inspection 30 days in advance or refilling the tank, the owner or operator shall notify the Administrator at least 7 days prior to the refilling of the storage vessel. Notification shall be made by telephone immediately followed by written documentation demonstrating why the inspection was unplanned. Alternatively, this notification including the written documentation may be made in writing and sent by express mail so that it is received by the Administrator at least 7 days prior to the refilling. § 60.115b Reporting and recordkeeping requirements. The owner or operator of each storage vessel as specified in §60.112b(a) shall keep records and furnish reports as required by paragraphs (a), (b), or (c) of this section depending upon the control equipment installed to meet the requirements of§60.112b. The owner or operator shall keep copies of all reports and records required by this section, except for the record required by (c)(1), for at least 2 years. The record required by (c)(1) will be kept for the life of the control equipment. (a) After installing control equipment in accordance with §60.112b(a)(1) (fixed roof and internal floating roof), the owner or operator shall meet the following requirements. (1) Furnish the Administrator with a report that describes the control equipment and certifies that the control equipment meets the specifications of §60.112b(a)(1) and §60.113b(a)(1). This report shall be an attachment to the notification required by§60.7(a)(3). (2) Keep a record of each inspection performed as required by §60.113b (a)(1), (a)(2), (a)(3), and (a)(4). Each record shall identify the storage vessel on which the inspection was performed and shall contain the date the vessel was inspected and the observed condition of each component of the control equipment (seals, internal floating roof, and fittings). (3) If any of the conditions described in §60.113b(a)(2) are detected during the annual visual inspection required by §60.113b(a)(2), a report shall be furnished to the Administrator within 30 days of the inspection. Each report shall identify the storage vessel, the nature of the defects, and the date the storage vessel was emptied or the nature of and date the repair was made. AIRS ID: 123/9D73 Page 5 of 12 a'i Col .o D ? e o' 'ublic Health and Environment Air Pollution Control Division (4) After eac inspec ion require. ay ,.O.11 • a (3) that finds holes or tears in the seal or seal fabric, or defects in the internal floating roof, or other control equipment defects listed in §60.113b(a)(3)(ii), a report shall be furnished to the Administrator within 30 days of the inspection. The report shall identify the storage vessel and the reason it did not meet the specifications of§61.112b(a)(1) or§60.113b(a)(3) and list each repair made. § 60.116b Monitoring of operations. (a) The owner or operator shall keep copies of all records required by this section, except for the record required by paragraph (b) of this section, for at least 2 years. The record required by paragraph (b) of this section will be kept for the life of the source. (c) Except as provided in paragraphs (f) and (g) of this section, the owner or operator of each storage vessel either with a design capacity greater than or equal to 151 m3 storing a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa or with a design capacity greater than or equal to 75 m3 but less than 151 m3 storing a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa shall maintain a record of the VOL stored, the period of storage, and the maximum true vapor pressure of that VOL during the respective storage period. (e) Available data on the storage temperature may be used to determine the maximum true vapor pressure as determined below. (1) For vessels operated above or below ambient temperatures, the maximum true vapor pressure is calculated based upon the highest expected calendar-month average of the storage temperature. For vessels operated at ambient temperatures, the maximum true vapor pressure is calculated based upon the maximum local monthly average ambient temperature as reported by the National Weather Service. (2) For crude oil or refined petroleum products the vapor pressure may be obtained by the following: (i) Available data on the Reid vapor pressure and the maximum expected storage temperature based on the highest expected calendar-month average temperature of the stored product may be used to determine the maximum true vapor pressure from nomographs contained in API Bulletin 2517 (incorporated by reference—see §60.17), unless the Administrator specifically requests that the liquid be sampled, the actual storage temperature determined, and the Reid vapor pressure determined from the sample(s). (ii) The true vapor pressure of each type of crude oil with a Reid vapor pressure less than 13.8 kPa or with physical properties that preclude determination by the recommended method is to be determined from available data and recorded if the estimated maximum true vapor pressure is greater than 3.5 kPa. In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply. a. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and AIRS ID: 123/9D73 Page 6 of 12 Col o D ' e o Public Health and Environment 22 Air Pollution Control Division operate in a manner consisten wi goo air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation No. 6, Part A. General Provisions from 40 CFR 60.11 b. No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§ 60.12) c. Written notification of construction and initial startup dates shall be submitted to the Division as required under§ 60.7. d. Records of startups, shutdowns, and malfunctions shall be maintained, as required under§ 60.7. e. Excess Emission and Monitoring System Performance Reports shall be submitted as required under§ 60.7. 11. This source is subject to the requirements of Regulation No. 7, Section VI, Storage and Transfer of Petroleum Liquid including, but not limited to, the following: VI.B.2.a.(i) The owner or operator of a fixed-roof tank used for storage of petroleum liquids which have a true vapor pressure greater than 33.6 torr (0.65 psia) at 20°C (or, alternatively, a Reid vapor pressure greater than 1.30 pounds - (67.2 torr) but not greater than 570 torr (11.0 psia) at 20°C, and which are stored in any tank or other container of more than 151,412 liters (40,000 gallons) shall ensure that the tank at all times meets the following conditions: VI.B.2.a.(i)(A) The tank has been equipped with a pontoon-type, or double-deck type, floating roof or an internal floating cover which rests on the surface of the liquid contents and which is equipped with a closure seal or seals to close the space between the edge of the floating roof (or cover) and tank walls. VI.B.2.a.(i)(E) The owner or operator shall maintain records for at least two years of the type, average monthly storage temperature, and true vapor pressure of all petroleum liquids stored in tanks not equipped with an internal floating roof or cover or other control pursuant to Regulation 7.VI.B.2.a.(i)(A) or (B) or 7.II.D. VI.B.2.a.(ii) No owner or operator of a fixed-roof tank equipped with an internal floating roof or cover shall permit the use of such tank unless: VI.B.2.a.(ii)(A) The tank is maintained such that there are no visible holes, tears, or other openings in the seal or any seal fabric or materials; and VI.B.2.a.(ii)(B) All openings, except stub drains, are equipped with covers, lids, or seals such that: VI.B.2.a.(ii)(B)(1) The cover, lid, or seal is in the closed position at all times except when in actual use; VI.B.2.a.(ii)(B)(2) Automatic bleeder vents are closed at all times except when the roof is floated off or landed on the roof leg supports; AIRS ID: 12319D73 Page 7 of 12 Illsa colis..oDrire o ''ublic Health and Environment is Air Pollution Control Division .a.(ii e 3) an. Rim yen s, if provided, are set to open when the roof is being floated off the roof leg supports or at the manufacturer's recommended setting. VI.B.2.a.(iii) The operator of a fixed-roof tank equipped with an internal floating roof shall: VI.B.2.a.(iii)(A) Perform a routine inspection through the tank roof hatches at least once every six months; VI.B.2.a.(iii)(A)(1) During the routine inspection, the operator shall measure for detectable vapor loss inside the hatch. Detectable vapor loss means a VOC concentration exceeding 10,000 ppm, using a portable hydrocarbon analyzer. VI.B.2.a.(iii)(B) Perform a complete inspection of the cover and seal whenever the tank is out of service, whenever the routine inspection required in subclause (A) above reveals detectable vapor loss, and at least once every ten years, and shall notify the Division in writing before such an inspection. VI.B.2.a.(iii)(C) Ensure during inspections that there are no visible holes, tears, or other openings in the seal or any seal fabric or materials; that the cover is floating uniformly on or above the liquid surface; that there are no visible defects in the surface of the cover or liquid accumulated on the cover; and that the seal is uniformly in place around the circumference of the cover between the cover and the tank wall. If these items are not met, the owner or operator shall repair the items or empty and remove the storage vessel from service within 45 days. If a failure that is detected during inspections required in this paragraph cannot be repaired within 45 days and if the vessel cannot be emptied within 45 days, a 30- day extension may be requested from the Division in writing. Such a request must document that alternative storage capacity is unavailable and specify a schedule of actions the owner or operator will take that will assure that the items will be repaired or the vessel will be emptied as soon as possible; VI.B.2.a.(iii)(D) Maintain records for at least two years of the results of all inspections. VI.B.2.b. Above ground storage tanks used for the storage of petroleum liquid shall have all external surfaces coated with a material which has a reflectivity for solar radiation of 0.7 or more. Methods A or B of ASTM E424 shall be used to determine reflectivity. Alternatively, any untinted white paint may be used which is specified by the manufacturer for such use. This provision shall not apply to written symbols or logograms applied to the external surface of the container for purposes of identification provided such symbols do not cover more than 20% of the exposed top and side surface area of the container or more than 18.6 square meters (200 square feet), whichever is less. ADDITIONAL REQUIREMENTS 12. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: AIRS ID: 123/9D73 Page 8 of 12 Col o D . o Public Health and Environment Air Pollution Control Division For any cn eria po utan 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 V0C or N0x 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. 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. GENERAL TERMS AND CONDITIONS 13. 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 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. 14. 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. 15. 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. 16. 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. AIRS ID: 12319D73 Page 9 of 12 � ' Coto D :f.' ' 'e a nubile Health and Environment ll Air Pollution Control Division 17. Each and every condition o this permi is a matena 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. 18. 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. 19. 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 Chaousy, PE Permit Engineer Air Pollution Control Division Permit History Issuance Date Description Issuance 1 This Issuance Newly permitted IFR storage tanks at a true minor facility. AIRS ID: 12319D73 Page 10 of 12 Col o D e ;!Public Health and Environment si 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: http://www.cdphe.state.co.us/regulations/airregs/100102agcccommonprovisionsreg.pdf. 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. Uncontrolled Controlled Emission Are the Emission AIRS Rate emissions Rate Point Pollutant CAS # BIN (Ib/yr) reportable? (lb/yr) Benzene 71432 A 466 Yes 466 Toluene 108883 C 1175 Yes 1175 002 Ethylbenzene 100414 C 241 No 241 Xylenes 1330207 C 1250 Yes 1250 n-Hexane 110543 C 2883 Yes 2883 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Emission Factors CAS # Pollutant lb/1000 gal Crude Oil and Source Condensate Throughput VOC 0.0119 71432 Benzene 0.000065 108883 Toluene 0.00016 EPA Tank 4.0.9d plus roof 100414 Ethylbenzene 0.000034 landing emissions 1330207 Xylenes 0.00017 110543 n-Hexane 0.0004 AIRS ID: 123/9D73 Page 11 of 12 Col, •o D • ' e 0''ublic Health and Environment Air Pollution Control Division Note: EPA Tank was run for this emission point assuming that these tanks are operated as constant level tanks as discussed in AP-42, Section 7.1.3.5. 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 Status Requirement Operating Permit Minor Source PSD Minor Source NA NSR Minor Source MACT EEEE 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.poaccess.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 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.00v/oacific/cdohe/air-permit-self-certification AIRS ID: 12319D73 Page 12 of 12 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Grand Mesa Pipeline, LLC Permit Number: 15WE0038 Source Location: Lucerne Station Section 27, T6N, R65W, Weld County (Non-attainment) Point 001: internal floating roof storage tanks (point cancelled by operator 5/1/15) _ Point 002: internal floating roof storage tanks Equipment Description: Point 003: internal floating roof storage tanks (point cancelled by operator 5/1/15) Point 004: internal floating roof storage tanks (point cancelled by operator 5/1/15) Point 005: Fugitives (point cancelled by operator 5/11/15) AIRS ID: 123-9D73 Date: April 30, 2015 Review Engineer: Stephanie Chaousy, 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? December 8, 2014 Section 4—Source Description AIRS Point Equipment Description 002 Eight (8) above ground 150,000 bbl internal floating roof(IFR) storage tanks used to store crude oil and condensate. Emissions are controlled with the IFR. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? Page 1 If"yes", for what pollutant? (Note: These pollutants are subject to minor source PMto CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region?(Note: If"yes" the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Section 5—Emission Estimate Information AIRS Point Emission Factor Source 002 Source provided site-specific emission factors using EPA Tanks4.09d. Flash emissions are not anticipated from these tanks. See Section 14 for calculations. Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit(PTEI AIRS Point Process Consumption/Throughput/Production 002 85,200,000 BBL per year Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 002 85,200,000 BBL per year Does this source use a control device? X Yes No AIRS Point Process Control Device Description %Reduction Granted 002 01 Internal floating roof Part of equipment Section 6—Emission Summary (tons per year) Point NO, VOC CO Single HAP Total HAP PTE: 002 --- 42.4 --- 1.4 (Hexane) 3.0 Controlled point 002 --- 42.4 --- 1.4 (Hexane) 3.0 source emission rate: Section 7—Non-Criteria/ Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions (Ib/yr) reportable? Rate(Ib/yr) Point 002 Benzene 71432 A 466 Yes 466 Toluene 108883 C 1175 Yes 1175 Ethylbenzene 100414 C 241 No 241 Xylenes 1330207 C 1250 Yes 1250 n-Hexane 110543 C 2883 Yes 2883 Note: Regulation 3, Part A, Section II.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 Yes X No standard? Page 2 Section 9—Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? X True Synthetic Major Minor Minor Classification relates to what programs? X Title V PSD X NA NSR X MACT Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? Minor Synthetic Major Minor 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)? X Yes 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)? Yes X No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If'yes", for which pollutants?Why? AIRS Point Section 12— Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 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 002 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. Re.ulation 2—Odor 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 002 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 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 002 each individual emission point in a non-attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is non-attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) Part B—Construction Permit Exemptions 002 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 20 TPY threshold(Reg. 3, Part B, Section II.D.2.a) Re•ulation 6- New Source Performance Standards 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 002 Is this source subject to NSPS Kb?Yes WHY? Point meets all criteria for this subpart. Tanks have IFR which satisfies Kb requirements. Page 3 NSPS OOOO: Tanks with the potential to emission equal to or greater than 6 TPY. Are uncontrolled VOC emissions greater than 6 TPY?Yes 002 Are controlled emissions greater than 6 TPY?Yes Is the operator requesting a permitted limit less than 6 TPY? No Source is not subject to NSPS OOOO requirements because they are subject to NSPS Kb requirements. gulation 7—Volatile Organic Compounds XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks since it is located in a non-attainment area.) 002 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 MACT EEEE: Organic Liquids Distribution 002 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 Process Emission Pollutant/ Fugitive Control Point Process Description Factor CAS# (Y/N) Emission Factor Source (%) 0.0119 Engineering calculation lb/1000 gal V0C No (EPA Tanks 4.0.9d) 0 0.000065 Benzene/ Engineering calculation lb/1000 gal 71432 N° (EPA Tanks 4.0.9d) 0 0.00016 Toluene/ Engineering calculation No 0 01 E&P Condensate lb/1000 gal 108883 (EPA Tanks 4.0.9d) 002 Storage Tanks 0.000034 Ethyibenzene No Engineering calculation 0 lb/1000 gal / 100414 (EPA Tanks 4.0.9d) 0.00017 Xylenes/ Engineering calculation lb/1000 gal 1330207 No (EPA Tanks 4.0.9d) 0 0.0004 n-Hexane/ Engineering calculation lb/1000 gal 110543 No (EPA Tanks 4.0.9d) 0 SCC 40400331 —Internal Floating Roof Tank, Condensate, working+breathing+flashing losses Section 14—Miscellaneous Application Notes Facility comments Application originally came in with 5 APENS submitted 12/8/2014: 1. Up to 6-250,000 bbl internal floating roof storage tanks 2. Up to 4-150,000 bbl internal floating roof storage tanks 3. Up to 4-100,000 bbl internal floating roof storage tanks 4. Up to 6-5,000 bbl internal floating roof storage tanks Operator did not know how it was going to configure the site, but knew the facility would have a maximum throughput of 127,750,000 bbl/yr. For the purpose of the application, calculations were based on "worst-case" assumption that all 6-250,000 bbl tanks would be constructed, but allowing for other tank sizes to be built as long as the total facility emissions stayed under the permitted total. On May 1, 2015, I got an email from the consultant saying that the operator decided on their configuration of 8- 150,000 bbl internal floating roof storage tanks. They wanted to cancel the APENs for the 250,000 bbl, 100,000 bbl and 5,000 bbl tanks. I requested a cancellation notice for the 3 points. They provided a revised APEN for the 150,000 bbl tanks so that I could use that to redline the original APEN and supporting documentation via email on 5/1/2015. Operator referred me to permit 07WE0329. Page 4 AIRS Point 002 Condensate Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit threshold). Operator used EPA Tanks 4.0.9d to calculate working and breathing emissions from the tanks. Flash emissions are not anticipated from these tanks(indicated on the APEN). Landing loss emissions were also calculated and included with the total VOC emissions. When determining HAP emissions from the landing losses, the operator took the ratio of the HAPNOC from EPA Tanks and multiplied it to the total VOC emissions from the landing losses. There are 8 tanks and the EPA Tanks modeled 1 tank. Working and breathing Estimated using EPA Tanks 4.0 as: Ls= 9446.40 lb VOC 1 Ton 8 tanks = 37.79 TPY Tank/year 2000 lb Roof landing losses Calculated using Equations 2-22 and 2-26 found in AP 42, Chapter 7. Standing losses: L =0.0063Fi7r,.� where: LsL = Standing loss during roof landing, lb Wt= density of liquid, lb/gal D =Tank diameter, ft Ls= 0.0063 5.6 3.14...x1492 = 615.16 lb per event 4 Filling losses: Lam:. = (gT)3fd 5 where: LEA = filling loss during roof landing, lb P = true vapor pressure of the liquid within the tank, psia Vv = volume of the vapor space, ft3 R = ideal gas constant, 10.731 psia-ft3/(lb-mole-°R) T = average temperature of the vapor and liquid below the floating roof, °R My= stock vapor molecular weight, lb/lb-mole S = filling saturation factor, dimension less ((0.15 for a drain-dry tank)). LEL= 6.49`47773 65 0.15 = 541.74 lb per event 10.731`520 Total = 615.16+541.74 lb 8 landing events 1 Ton = 4.63 TPY Landing event year 2000 lb Component Emissions Total Landing Emissions Total Total Emission Emission from EPA emissions Loss ratio for HAPS Emissions HAPS factor factor (for 1 tank) (W+B) (TPY) (TPY) (Ib/yr) (lb/bbl) (lb/1000 lb/yr TPY gal) VOC 9446.40 37.79 4.63 --- 42.42 --- 0.000996 0.02371 Benzene 51.92 0.20768 --- 0.005496274 0.233128 466.26 0.000005 0.00013 Toluene 130.81 0.52324 --- 0.013847603 0.587354 1174.71 0.000014 0.00033 Ethylbenzene 26.88 0.10752 --- 0.002845528 0.120695 241.39 0.000003 0.00007 Xylenes 139.18 0.55672 --- 0.014733655 0.624937 1249.87 0.000015 0.00035 n-hexane 321.03 _ 1.28412 --- 0.033984375 1.441468 2882.94 0.000034 0.00081 Page 5 p o u v C F O -_ N O_' - rry c 0 Oc r .,. u c : n e rkr C T •• E z v v m m nn t 6 - a R To - O O C W 00 N a_ N N N - Pj O \ ..' en C e V 6 E . M M cr. 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