HomeMy WebLinkAbout20151418.tiff A COPHE COLORADO
Co •
Department of Public
Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150OSt RECEIVED
PO Box 758
Greeley, CO 80632 MAY 1 4 2015
May 11, 2015 WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On May 13, 2015, the Air Pollution Control Division will begin a 30-day public notice period for
Encana Oil Et Gas (USA) Inc - Boyd 19H Battery. A copy of this public notice and the public comment
packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health f Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
ze
i
Ca
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
11- w; 57( 2015-1418
gap—l5
4300 Cherry Creek Drive S., Denver, CO 80246.1530 P 303.692.2000 www.colorado.govlcdphe /-
John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer
CDPPHE Air Pollution Control Division
Co Notice of a Proposed Project or Activity Warranting Public
' Comment
Website Title: Encana Oil a Gas (USA) Inc - Boyd 19H Battery - Weld County
Notice Period Begins: May 13, 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: Encana Oil £t Gas (USA) Inc
Facility: Boyd 19H Battery
Oil Et Gas Exploration and Production Facility
SWSW Sec 19 T3N R68W
Weld County
The proposed project or activity is as follows: The applicant proposes to operate one (1) tank used for
storage of condensate with an annual throughput limit of 374,400 BBL/yr of condensate. Storage tank
consists of 16 liquid manifold storage vessels.
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 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 15WE0252 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:
Bradley Eades
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
VCOLORe DO
• STATE OF COLORADO
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•LOR •O DE•ART •F PU: IC HEALTH AND ENVIRONMENT s .
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AIR POLLUTION CONTROL DIVISION F ''''e�
TELEPHONE: (303) 692-3150 . k> .�
*1876
CONSTRUCTION PERMIT
PERMIT NO: 15WE0252
Issuance 1
DATE ISSUED:
ISSUED TO: Encana Oil & Gas (USA) Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas exploration and production facility known as the Boyd 19H Battery , located
in the SWSW Sec 19 T3N R68W, Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
One (1) above ground 8,000 bbl atmospheric condensate storage
Condensate tank (sixteen (16) liquid manifold storage vessels). Emissions from
Tanks 002 the tanks are controlled by an enclosed combustor that achieves a
minimum destruction efficiency of 95%
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
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 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
AIRS ID: 123/9D91 Page 1 of 9
olor Depa en P di Health and Environment
it Pollution Control Division
c
on which suc <. ctia, '. 7 W. Ied to ,=mence as set forth in the
permit application associated with this permit; (H) discontinues construction for a period
of eighteen months or more; (Hi) 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, lll.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(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 AIRS Tons per Year
Equipment ID Point NO VOC CO Emission Type
Condensate 002 1.6 68.0 8.5 Point
Tanks
See "Notes to Permit Holder"for information on emission factors and methods used to calculate
limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
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.)
AIRS ID: 123/9D91 Page 2 of 9
,'taa. olor.A Depa en P .li Health and Environment
fir Pollution Control Division
•
Facility 'S� � •• � Pollutants
Equipment Point Control Device Controlled
ID
•
VOC, Benzene,
Condensate Toluene,
Tanks 002 Enclosed Flare Ethylbenzene,
Xylenes, n-Hexane,
2,2,4-TMP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility AIRS
Equipment Point Process Parameter Annual Limit
ID
Condensate 002 Condensate Throughput 374,400 BBL
Tanks
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 monitor and record
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 point number (e.g. 123/4567/890) shall be marked on
the subject equipment for ease of identification. (Reference: Regulation Number 3, Part
B, III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
11. This source is subject to the recordkeeping, monitoring, reporting and emission control
requirements of Regulation 7, Section XII. The operator shall comply with all applicable
requirements of Section XII.
12. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General
Provisions (State only enforceable). These requirements include, but are not limited to:
XVII.B.1.b If a flare or other combustion device is used to control emissions of volatile
organic compounds to comply with Section XVII, it shall be enclosed, have no
visible emissions during normal operations, and be designed so that an observer
can, by means of visual observation from the outside of the enclosed flare or
combustion device, or by other convenient means approved by the Division,
determine whether it is operating properly. The operator shall comply with all
applicable requirements of Section XVII.
AIRS ID: 123/9D91 Page 3 of 9
ii olor Depa en . P di Health" and Environment
A' it Pollution Control Division
. 5.
XVII.B.2.d.(i) A . > . 'stn °.v . --ta ) „-after v , 2014, must be equipped
with an operational auto-igniter upon installation of the combustion device
XVII.B.2.d.(ii) All combustion devices installed before May 1, 2014, must be equipped
with an operational auto-igniter by or before May 1, 2016, or after the next
combustion device planned shutdown, whichever comes first.
13. The storage tanks covered by this permit are subject to the emission control
requirements in Regulation No. 7, Section XVII.C.1.b. The owner/operator must install
and operate air pollution control equipment that achieves an average hydrocarbon
control efficiency of 95%. If a combustion device is used, it must have a design
destruction efficiency of at least 98% for hydrocarbons. The source shall follow the
inspection requirements of Regulation No. 7, Section XVII.C.1.d. and maintain records of
the inspections for a period of two years, made available to the Division upon request.
This control must be achieved according to the following schedule:
o If storage tank was constructed on/after May 1, 2014, within 90 days of the date
that the storage tank commences operation;
o If storage tank was constructed before May 1, 2014, by May 1, 2015.
14. The storage tanks covered by this permit are subject to the venting and Storage Tank
Emission Management System ("STEM") requirements of Regulation No. 7, Section
XVII.C.2. This storage tank shall be operated without venting hydrocarbon emissions
from the thief hatch (or other access point to the tank) or pressure relief device during
normal operation, unless venting is reasonably required for maintenance, gauging, or
safety of personnel and equipment. The owner/operator must develop, certify, and
implement a documented STEM plan to identify, evaluate, and employ appropriate
control technologies, monitoring practices, operational practices, and/or other strategies
designed to meet these requirements. Compliance is required on the following
schedule:
o A storage tank constructed on/after May 1, 2014 must comply and implement a
STEM Plan within 90 days of the storage tank commencing operation;
o A storage tank constructed before May 1, 2014, must comply and implement a
STEM Plan by May 1, 2015. Approved instrument monitoring method inspections
must begin within ninety (90) days of the Phase-In Schedule in Table 1, or within
thirty (30) days for storage tanks with uncontrolled actual VOC emissions greater
than 50 tons per year.
Following the first approved instrument monitoring method inspection, owners or
operators must continue conducting approved instrument monitoring method inspections
in accordance with the Inspection Frequency in Table 1.
AIRS ID: 123/9D91 Page 4 of 9
olor. Depa en, P li Health and Environment
it Pollution Control Division
4
Table 1 — Storage Tank Inspections
Threshold: Storage Tank Approved Instrument Phase-In
Uncontrolled Actual VOC Monitoring Method ("AIMM") Schedule
Emissions (tpy) Inspection Frequency
> 6 and < 12 Annually January 1, 2016
> 12 and < 50 Quarterly July 1, 2015
> 50 Monthly January 1, 2015
The owner/operator shall maintain records in accordance with Regulation No. 7, Section
XVII.C.3. and make them available to the Division upon request. The owner or operator
shall maintain records of STEM, including the plan, any updates, and the certification, for
the life of the storage tank. The owner/operator will maintain records of all required
inspections and monitoring for a period of two years.
OPERATING & MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall follow the most recent
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.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Method 22 to determine the presence or absence of visible emissions. "Visible
Emissions" means observations of smoke for any period or periods of duration greater
than or equal to one (1) minute in any fifteen (15) minute period during normal operation.
(Reference: Regulation No. 7, Section XVII.A.II)
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually by April 30`" 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
AIRS ID: 123/9D91 Page 5 of 9
olor Depa en .Ii Health and Environment
•it Pollution Control Division
pja y
For vs Da • r^=I • -s (. -• nitr s oxides sources (NO,) in
ozone nonattainment areas emitting less than 100 tons of VOC or NO, per
year, a change in annual actual emissions of one (1) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
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 or Title V Operating Permit)
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
19. 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.
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 owner or operator and is conditioned upon conduct of the activity, or
construction, installation and operation of the source, in accordance with this information
and with representations made by the owner or operator or owner or operator's agents.
AIRS ID: 123/9D91 Page 6 of 9
olor Depa en P li Health and Environment
it Pollution Control Division
It is valid onl : eq • p activi ecifically 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 owner or operator, or the
Division revokes a permit, the owner or operator of a source may request a hearing
before the AQCC for review of the Division's action.
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:
Bradley Eades
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc.
AIRS ID: 12319D91 Page 7 of 9
•
olor Depa en li Health and Environment
it Pollution Control Division
Notes to Permit Holder me o e a .
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 owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper
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
Emission Are the Controlled
AIRS Rate emissions Emission Rate
Point Pollutant CAS# (Ib/yr) reportable? (Ib/yr)
Benzene 71432 8611 Yes 431
n-Hexane 110543 157248 Yes 7862
Toluene 108883 15351 Yes 768
002
Xylenes 1330207 3744 Yes 187
224-TMP 540841 4867 Yes 243
Ethylbenzene 100414 674 Yes 34
5) The emission levels contained in this permit are based on the following emission factors:
Point 002:
Emission Factors
Uncontrolled
Pollutant lb/BBL Source
Condensate
Throughput
VOC 7.259
n-Hexane 0.420
Benzene 0.023
Toluene 0.041 Hysys/EPA Tanks
Xylenes 0.010
224-TMP 0.013
Ethylbenzene 0.002
AIRS ID: 123/9D91 Page 8 of 9
-E m
.1 I% * olora, DeparIen' P •lid Health and Environment
it Pollution Control Division
Atirr
y a: j
Note: The co pi . is . ;fori ,.int ateklga ;on the-ft; 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 Status
Requirement
Operating Permit Synthetic Minor Source of:
VOC, n-Hexane, HAPs
NANSR Synthetic Minor Source of:
VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
h ttp://ecfr.q p o access.ci ov/
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.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 12319D91 Page 9 of 9
Division Information
Engineer: Bradley Eades
Control Engineer: Chris Laplante
Review Date: 04/20/2015
Application Date: 01/15/2015
Facility Identifiers
Permit No. 15WE0252
AIRS County f; 123 Weld
Facility It 9D91
Facility Type: exploration and production facility
2 Located in the 8-hour non-attainment area? O True Minor
Synthetic Minor for: r VOC r NOx r CO
Administrative Information
Company Name: Encana Oil & Gas (USA) Inc.
Source Name: Boyd 19H Battery
Source Location: SWSW Sec 19 T3N R68W
SIC: 1311
Address 1: Encana Oil &Gas (USA) Inc.
Mailing Address 2: Republic Plaza 370 17th Street Suite 1700
Address
ty,State Zip: Denver, CO
Name: Adam Berig
Person To Phone: 720-876-3884
Contact Fax: 720-876-4884
Email: Adam.Berig@encana.com
Requested Action
Self Certification Required? Yes
Issuance Number: 1
Source Description:
Oil and gas exploration and production facility known as the Boyd 19H Battery, located in the SWSW Sec 19 T3N
R68W,Weld County, Colorado,
Point Name Type Control Action
Newly
Condensate
002 Condensate Tanks Flare reported
Tanks
source
002 8,000 bbl condensate storage tank consisting of sixteen(16)above ground liquid manifold vessels.
Requsted Throughput 374400 bbl
Control Flare
Efficiency 95.00%I
Heat Content Calculation
HHV(Btu/scf) Volume(Mscfd) Volume(MMscf/yr) Total(MMetu/yr)
Tanks Vapor 2098 59.8 21.839994 45820.30741
Total(MMBtu/yr) 45820.30741
HHV re-calculated using Mass Density and HHV from Hysys sim.Page 42(Tank Flash to
Combustor)Stream properties per correspondence w/5.Wagner 4/23/15
Emissions Summary Table
Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source
VOC 7.259 lb/bbl 1358.88 tpy 67.94 tpy
Benzene 0.023 lb/bbl 8611.20 lb/yr 430.56 lb/yr
n-Hexane 0.42 lb/bbl 157248.00 lb/yr 7862.40 lb/yr
Toluene 0.041 lb/bbl 15350.40 lb/yr 767.52 lb/yr Hysys/EPA Tanks
Xylene 0.01 lb/bbl 3744.00 lb/yr 187.20 lb/yr
Ethylbenzene 0.0018 lb/bbl 673.92 lb/yr 33.70 lb/yr
224-TMP 0.013 lb/bbl 4867.20 lb/yr 243.36 lb/yr
NOx 0.068 lb/MMbtu 1.55789 tpy AP 42
CO 0.37 lb/MMbtu 8.476757 tpy
Regulatory Review
Section II.A.1 -Except as provided in paragraphs 2 through 6 below,no owner or operator of a source shall allow or cause the emission into the
atmosphere of any air pollutant which is in excess of 20%opacity.This standard is based on 24 consecutive opacity readings taken at 15-second
intervals for six minutes.The approved reference test method for visible emissions measurement is EPA Method 9(40 CFR,Part 60,Appendix A
(July,1992))in all subsections of Section II.A and B of this regulation.
Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases 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.
Regulation 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 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 6-New Source Performance Standards
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
Each tank is greater than 19,800 gallons(471 bbl),however stores less than 420,000 gallons(10,000 bbl)condensate prior to custody transfer.
NSPS OOOO:for storage vessels in the natural gas production,transmission,and processing segments.
This source is not subject to this subpart because each"storage vessel"has federally enforceable emissions less than 6 tpy based on the
definition of"storage vessel"in 40 CFR Part 60 at the time of startup
Regulation 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.)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
Applicant is currently subject to this since actual uncontrolled emissions are greater than 20 tpy of VOC.
Public comment is required new syn minor source for tank.
AIRS(County/Plant) 123/9D91
Permit No. 15WE0252
Date 4/20/2015
Controlle Controlled
d Actual Requested NCRP=
Uncontrolled Emission Emisison Factor Emissio Emissions PTE Ctrl. reportable
Point# SCC Pollutant or CAS Factor Source ns(tpy)* (tpy)* (tpy)" Eff% ?
002 40400311 VOC 172.834 lb/1000 gallon Hysys/EPA Tanks 67.94424 1359 95% Yes
002 40400311 NOx 0.068 lb/MMBtu AP-42
002 40400311 CO 0.37 lb/MMBtu AP-42
002 40400311 Benzene 0.548 lb/1000 gallon Hysys/EPA Tanks 430.56 8611 95% Yes
002 40400311 n-Hexane 10 lb/1000 gallon Hysys/EPA Tanks 7862.4 157248 95% Yes
002 40400311 Toluene 0.976 lb/1000 gallon Hysys/EPA Tanks 767.52 15351 95% Yes
002 40400311 Xylenes 0.238 lb/1000 gallon Hysys/EPA Tanks 187.2 3744 95% Yes
002 40400311 Ethylbenzene 0.042857143 lb/1000 gallon Hysys/EPA Tanks 33.696 674 95% Yes
002 40400311 224-TMP 0.30952381 lb/1000 gallon Hysys/EPA Tanks 243.36 4867 95% Yes
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