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Home My WebLink About20151151.tiff ,* CAE COLORADO CO ,I 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 RECEIVED Greeley, CO 80632 APR 2 0 2.015 April 15, 2015 WELD COUNTY COMMISSIONER Dear Sir or Madam: On April 22, 2015, the Air Pollution Control Division will begin a 30-day public notice period for Encana Oil Et Gas (USA) Inc. - McConahay P266 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 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 • --PUJO i.4) .eel AA) C /Al 2015-1151 14-a-7—,20/5 4300 Cherry Creek Drive S.. Denver, CO 80246.1530 P 303-642-2000 www.colorado.govicdphe � c John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer CDPHE Air Pollution Control Division co Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Encana Oil a Gas (USA) Inc. - McConahay P266 Battery - Weld County Notice Period Begins: April 22, 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 Ft Gas (USA) Inc. Facility: McConahay P266 Battery Oil&Gas Production Facility SESE Sec. 34, T2N, R66W Weld County, CO Weld County The proposed project or activity is as follows: The applicant proposes to operate one twelve (12) vessel 6,000 BBL condensate storage tank with an annual throughput limit of 273,720 bbi/yr of condensate 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 14WE1674 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 A GOLgNaDa 1 I STATE OF COLORADO NCO LO RA•• DEPARTME *FP n C HEALTH AND ENVIRONMENT of �o 0 �� o AIR POLLUTION CONTROL DIVISION . ;., TELEPHONE: (303) 692-3150 .\.1 6 . i/876 µ CONSTRUCTION PERMIT PERMIT NO: 14WE1674 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 McConahay P266 Battery , located in the SESE Sec. 34, T2N, R66W, in 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 6,000 bbl atmospheric condensate storage Condensate 001 tank (twelve (12) liquid manifold 500 bbl storage vessels). Tanks Emissions from 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: 123/9D41 Page 1 of 9 olor. ji Depa en . .Ii Health and Environment it Pollution Control Division on which suc cti- _ -' w. - ed to mence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.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 Emission Type Equipment ID Point NO, VOC CO Condensate 001 1.4 52.3 7.4 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: 123/9D41 Page 2 of 9 r ' ' olora, Deparrv`7ten f P li Health and Environment 1 %11 it Pollution Control Division Facility S Pollutants Equipment Point Control Device Controlled ID VOC. Benzene, Toluene, Condensate 001 Enclosed Flare Ethylbenzene, Tanks Xylenes, n- Hexane, 2,2,4- Trimethylpentane 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 001 Condensate Throughput 273.720 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. 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. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 5.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. 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. 13. 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: AIRS ID: 123/9D41 Page 3 of 9 olor.11 Depa en - •Ii Health' and Environment it Pollution Control Division XVII.B.1.b If .. a i ot - : .o '•n * - used - -ntrol 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. XVII.B.2.d.(i) All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device 14. 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. 15. 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. Table 1 — Storage Tank Inspections Threshold: Storage Tank Approved Instrument Phase-In Uncontrolled Actual VOC Monitoring Method ("AIMM") Schedule Emissions (tpy) Inspection Frequency AIRS ID: 123/9D41 Page 4 of 9 9 E; x olora Depa 4men o P IicaHealth and Environment f 1,.,x..'4— fir Pollution Control Division `s`'` hd< `�1�2 mo r ally ` 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 16. 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 17. 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 18. 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: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of V0C 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 AIRS ID: 123/9D41 Page 5 of 9 II olor- Depa en • P •Ii Health and Environment •it Pollution Control Division Fora it - 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. 19. 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 20. 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. 21. 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. 22. 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. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. 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. 24. 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 at) initio. This AIRS ID: 123/9D41 Page 6 of 9 r,. 9r,TA ;!! u, f Taw:. PBt! r a olor. LDepar, ,nen P licHealth and Environment ` a a• g, it Pollution Control Division permit may beleMolidgatatiL r t. ,_z,atificafi. . ',. 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. 25. 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. 26. 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: 123/9D41 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&childpaoename=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? (lb/yr) Benzene 71432 6570 Yes 329 n-Hexane 110543 82116 Yes 4106 Toluene 108883 9307 Yes 466 001 Xylenes 1330207 4106 Yes 206 224-TMP 540841 2190 Yes 110 Ethylbenzene 100414 274 Yes 14 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Emission Factors Uncontrolled Pollutant Ib/BBL Source Condensate Throughput VOC 7.632 Hysys/EPA Tanks n-Hexane 0.300 Hysys Benzene 0.024 Hysys Toluene 0.034 Hysys Xylenes 0.015 Hysys 224-TMP 0.008 Hysys Ethylbenzene 0.001 Hysys AIRS ID: 123/9D41 Page 8 of 9 Y o „yolor dhipepar en of P3' lice Health and Environment ;.. x it Pollution Control Division 3 r tt nI Note: The con#r,tlerrmissi rts,for°#3 mount 5.•a4slon the, ,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: http://ecfr.q poacces s.o 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: 123/9D41 Page 9 of 9 Division Information Engineer: Bradley Eades Control Engineer: Christopher Laplante Review Date: 03/10/2015 Application Date: 10/20/2014 Facility Identifiers Permit No. 14WE1674 AIRS County# 123 Weld Facility# 9D41 Facility Type: exploration and production facility ❑' Located in the 8-hour non-attainment area? 0 True Minor 0 Synthetic Minor for: P VOC 1— NOx r CO Administrative Information Company Name: Encana Oil &Gas (USA) Inc. Source Name: McConahay P266 Battery Source Location: SESE Sec. 34, T2N, R66W SIC: 1311 Address 1: Encana Oil &Gas(USA) Inc. Mailing Address 2: Republic Plaza 370 17th St., Suite 1700 Address ty, state Zip: Denver, CO 80202 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 McConahay P266 Battery , located in the SESE Sec. 34, T2N, R66W, Weld County, Colorado. Point Name Type Control Action Condensate Newly 001 Tanks Condensate Tanks Flare reported source 001 One(1)above ground 6000 bbl atmospheric condensate storage tank(12 vessels) Requsted Throughput 273720 bbl Control Flare Efficiency 95.00%I Heat Content Calculation HHV(Btu/scf) Volume(Mscfd) Volume(MMscf/yr) Total(MMBtu/yr) Tanks Vapor 2108 51.9 18.95445 39955.9806 Total(MMBtu/yr) 39955.9806 HHV re-calculated using Mass Density and HHV from Hysys sim.Page 42(Tank Flash to Combustor)Stream properties per correspondence w/S.Wagner 3/16/15 Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 7.632 lb/bbl 1044.52 tpy 52.23 tpy Benzene 0.024 lb/bbl 6569.28 lb/yr 328.46 lb/yr n-Hexane 0.3 lb/bbl 82116.00 lb/yr 4105.80 lb/yr Toluene 0.034 lb/bbl 9306.48 lb/yr 465.32 lb/yr Hysys/EPA Tanks Xylene 0.015 lb/bbl 4105.80 lb/yr 205.29 lb/yr 224-TMP 0.008 lb/bbl 2189.76 lb/yr 109.49 lb/yr Ethylbenzene 0.001 lb/bbl 273.72 lb/yr 13.69 lb/yr NOx 0.068 lb/MMbtu 1.358503 tpy AP 42 CO 0.37 lb/MMbtu 7.391856 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) 123/9D41 Permit No. 14WE1674 Date 3/10/2015 Controlled Controlled Actual Requested NCRP= Uncontrolled Emission Emisison Emissions Emissions PTE Ctrl. reportable Point# SCC Pollutant or CAS Factor Factor Source (tpy)` (tpy)* (tpy)* Eft°/ ? Hysys/EPA 001 40400311 VOC 181.715 lb/1000 gall Tanks 52.2 1044.5 95% Yes Hysys/EPA 001 40400311 Benzene 0.572 lb/1000 gall Tanks 328.5 6569.3 95% Yes Hysys/EPA 001 40400311 n-Hexane 7.143 lb/1000 gall Tanks 4105.8 82116 95% Yes Hysys/EPA 001 40400311 Toluene 0.81 lb/1000 gall Tanks 465.3 9306.5 95% Yes Hysys/EPA 001 40400311 Ethylbenzene 0.024 lb/1000 gall Tanks 13.7 273.7 95% Yes — a' i o v Z. Z 7 L y c .: `m o m ,n ,. a , - ya v = - ' o N � — -- x ❑ v: d et t=. = a Lo aa a a a .c. .0 N - E > o y o o.e ek,c o z .o _ C. O p '� y G m_ O Hi C .e 2' C 2 - 2yNC , U } } rL iNNO. _ i.z ❑ G _ o = - t �Il E +. Q.) z.C E11 ti r r .F. 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