HomeMy WebLinkAbout20152878.tiff A CDPHE COLORADO
Co -0' Department of Public
Health ft Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632 RECEIVED
August 24, 2015 AUG 2 7 2015
WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On August 26, 2015, the Air Pollution Control Division will begin a 30-day public notice period for
Encana Oil a Gas (USA) Inc. - Vogl Geist McCoy 5H-E267 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,
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Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
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4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/capne o
John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer t,7,,,,,,v, .'
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CDPHE Air Pollution Control Division
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Notice of a Proposed Project or Activity Warranting Public
M` Comment
Website Title: Encana Oil E. Gas (USA) Inc. - Vogl Geist McCoy 5H-E267 Battery - Weld County
Notice Period Begins: August 26, 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 Et Gas (USA) Inc.
Facility: Vogl Geist McCoy 5H-E267 Battery
Oil and Gas Exploration and Production Facility
SWNW of Section 5, Township 2N, Range 67W
Weld County
The proposed project or activity is as follows: Applicant is requesting permit coverage for condensate
loadout from storage tanks to tank trucks at an exploration and production facility.
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):
• 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 15WE0423 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:
Harrison Slaughter
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 AA ?„7,.n., ,
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT F4 ,
AIR POLLUTION CONTROL DIVISION °i
TELEPHONE: (303)692-3150 `,t */'
CONSTRUCTION PERMIT
PERMIT NO: 155WE0423
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 Vogl Geist McCoy 5H-E267
Battery, located in the SWNW of Section 5, Township 2N, Range 67W, in Weld County,
Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
Condensate Truck loadout of condensate. Emissions from the loadout are
Loadout 009 controlled by an enclosed combustor.
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 sec{), 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 of the latter of commencement of operation or issuance of this permit,
by submitting a Notice of Startup form to the Division. The Notice of Startup form
may be downloaded online at https://www.colorado.ciov/pacific/cdphe/other-air-
permittinq-notices. Failure to notify the Division of startup of the permitted source is a
violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section
III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
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, I I I.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
AIRS ID: 123/9DA8 Page 1 of 8
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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
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 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:
Facility AIRS Tons per Year
Equipment ID Point NO. VOC CO Emission Type
Condensate 009 --- 3.9 --- Point
Loadout
See "Notes to Permit Holder #4" for information on emission factors and methods used to
calculate limits.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
6. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility AIRS Control Device Pollutants
Equipment ID Point Controlled
Condensate 009 Enclosed Combustor VOC, HAPs
Loadout
PROCESS LIMITATIONS AND RECORDS
7. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the throughput shall be maintained by the applicant and made
available to the Division for inspection upon request. (Reference: Regulation 3, Part B,
II.A.4)
Process/Consumption Limits
AIRS ID: 123/9DA8 Page 2 of 8
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Air Pollution Control Division
Facility AIRS Process Parameter Annual Limit
Equipment ID Point
Condensate 009 Condensate Loading 667,785 BBUyr
Loadout
The owner or operator shall calculate monthly process rates based on the calendar
month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
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. Emission control devices subject to Regulation 7,
Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation
No. 1, Section II.A.1. & 4.)
9. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
10. This source is located in an ozone non-attainment or attainment-maintenance area and
is subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be
conducted by submerged fill. (Reference: Regulation 3, Part B, III.E)
11. The owner or operator shall follow loading procedures that minimize the leakage of
VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B,
III.E):
a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or
other liquid or vapor loss during loading and unloading.
b. All compartment hatches (including thief hatches) shall be closed and latched at
all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
c. The owner or operator shall inspect loading equipment and operations onsite at
the time of inspections to monitor compliance with Condition 11 (a) and (b)
above. The inspections shall occur at least monthly. Each inspection shall be
documented in a log available to the Division on request.
12. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated
and maintained so as to minimize leakage of volatile organic compounds to the
atmosphere to the maximum extent practicable.
OPERATING & MAINTENANCE REQUIREMENTS
13. Upon startup of these points, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in order to demonstrate
compliance on an ongoing basis with the requirements of this permit. Revisions to your
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O&M plan are subject to Division approval prior to implementation. (Reference:
Regulation No. 3, Part B, Section III.G.7.)
14. The owner or operator of a loadout at which an enclosed combustor is used to control
emissions shall:
a. Install and operate the vapor collection and return equipment to collect vapors
during loading of tank compartments of outbound transport trucks.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in
use.
c. Use operating procedures to ensure that hydrocarbon liquid cannot be
transferred unless the vapor collection equipment is in use.
d. Operate all recovery and disposal equipment at a back pressure less than the
pressure relief valve setting of transport vehicles.
e. Inspect thief hatch seals annually for integrity and replace as necessary. Thief
hatch covers shall be weighted and properly seated.
f. Inspect pressure relief devices (PRD) annually for proper operation and replace
as necessary. PRDs shall be set to release at a pressure that will ensure
flashing, working and breathing losses are routed to the control device under
normal operating conditions.
g. Document annual inspections of thief hatch seals and PRD with an indication of
status, a description of any problems found, and their resolution.
COMPLIANCE TESTING AND SAMPLING
15. This source is not required to comply with any testing and sampling requirements.
ADDITIONAL REQUIREMENTS
16. 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 (NOx) in
ozone nonattainment areas emitting less than 100 tons of VOC or NOx 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.
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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.
17. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at
any such time that this source becomes major solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the applicable
Federal program threshold will require a full review of the source as though construction
had not yet commenced on the source. The source shall not exceed the Federal
program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
18. 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.
19. 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.
20. 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.
21. 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.
22. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self-certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the applicant, or the Division
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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.
23. 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.
24. 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:
Harrison Slaughter
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc.
AIRS ID: 123/9DA8 Page 6 of 8
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Notes to Permit Holder:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the permittee providing there is no exceedance of any specific emission control
regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and
application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as
soon as possible, but no later than noon of the next working day, followed by written notice to the
Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/agcc-reps
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# BIN (lb/yr) reportable? Rate(Ib/yr)
Benzene 71432 A 1,465 Yes 74
Toluene 108883 C 2,587 Yes 130
Ethylbenzene 100414 C 110 No 6
009 Xylenes 1130207 C 1,138 Yes 57
n-Hexane 110543 C 3,631 Yes 182
2,2,4-
540841 C 110 No 6
Trimethylpentane
5) The emission levels contained in this permit are based on the following emission factors:
Emission Factors - Emission Factors—
Uncontrolled Controlled
CAS Pollutant Ib/BBL loaded Source Lb/BBL Source
loaded
VOC 0.233 AP-42 0.0117 AP-42
71432 Benzene 2.2E-3 Mass Balance 1.1E-4 Mass Balance
108883 Toluene 3.9E-3 Mass Balance 1.95E-4 Mass Balance
100414 Ethylbenzene 2.0E-4 Mass Balance 1.0E-5 Mass Balance
1130207 Xylenes 1.7E-3 Mass Balance 8.5E-5 Mass Balance
110543 n-Hexane 5.4E-3 Mass Balance 2.7E-4 Mass Balance
540841 2'2'4 2.0E-4 Mass Balance 1.0E-5 Mass Balance
Trimethylpentane
The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
AIRS ID: 123/9DA8 Page 7 of 8
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S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) =5.6 psia
M (vapor molecular weight) =68 Ib/Ib-mol
T(temperature of liquid loaded) = 512.45 °R
The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor.
Controlled emission factors are based on a flare 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
NANSR Synthetic Minor Source of: VOC
MACT HH Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60,Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 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 XXXXX(
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: 123/9DA8 Page 8 of 8
Division Information
Engineer: Harrison Slaughter
Control Engineer: Chris Laplante
Review Date: 06/11/2015
Application Date: 02/20/2015
Facility Identifiers
Permit No. 15WE0423 Potentially located in ozone nonattainment area
AIRs County# 123 Weld
Facility# 9DA8
Facility Type: exploration and production facility
❑� Located in the 8-hour non-attainment area? O True Minor
® Synthetic Minor for: P VOC rNOx rCO
Administrative Information
Company Name: Encana Oil and Gas (USA) Inc.
Source Name: Vogl Geist McCoy 5H-E267 Battery
Source Location: SWNW Section 5, Township 2N, Range 67W
SIC: 1311
Address 1: Encana Oil and Gas(USA)Inc.
Mailing
Address Address 2: Republic Plaza 370 17th St.,Suite 1700
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 Vogl Geist McCoy 5H-E267 Battery, located in the SWNW
Section 5,Township 2N, Range 67W,Weld County, Colorado.
Point Name Type Control Action
Newly
Condensate
009 Loadout Flare reported
Loadout
source
009 Hydrocarbon Loadout to Tanker Trucks
The table of inputs below enables you to
calculate the loading loss emissions factor"L".
Calculations If you choose to use a state default emissions
factor,you may enter is directly into cell B14
L= 12.46*S*P*M/T(AP-42:Chapter 5.2, Equation 1) in units lb/1,000 gallons which will overwrite
L= loading losses in lb per 1000 gallons loaded
Factor Meaning Value Units Source
S Saturation Factor 0.6 AP-42
P True Vapor Pressure 5.6 psia AP-42 (Figure 7.1-13a)
Molecular Weight of AP-42 (Table 7.1-2) RVP 8.6 from sales oil
M Vapors 68 lb/lb-mole analysis
T Liquid Temperature 512.45 deg. R Field Data
L 5.56 lb/10^3 gal
2.33E-01 lb/bbl
Annual requested Throughput 667785 BBL/yr
28046970 gal/yr
Annual requested VOC emissions 155812 lb/yr
77.91 tpy
Control: Flare
Efficiency: 95.00%
NCRPs
Component Mass Fraction If the operator provides HAP speciation from a stable "sales oil"
Benzene 0.0094 analysis,enter the mass fraction from this data. Alternatively,if
n-hexane 0.0233 the operator modeled a pressurized oil to develop a site specific
Toluene 0.0166 emissions factor,enter the modeled mass fraction for the
Xylenes 0.0073
E-Benzene 0.0007
2,2,4-TMP 0.0007
Source: Company specific estimated weight%values
Emissions Summary Table
Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source
VOC 0.2333 lb/bbl 77.9 tpy 3.9 tpy AP-42
Benzene 0.0022 lb/bbl 1464.6 lb/yr 73.2 lb/yr AP-42
n-Hexane 0.0054 lb/bbl 3630.42 lb/yr 181.52 lb/yr AP-42
Toluene 0.0039 lb/bbl 2586.48 lb/yr 129.32 lb/yr AP-42
Xylenes 0.0017 lb/bbl 1137.43 lb/yr 56.87 lb/yr AP-42
E-Benzene 0.0002 lb/bbl 109.07 lb/yr 5.45 lb/yr AP-43
2,2,4-TMP 0.0002 lb/bbl 109.07 lb/yr 5.45 lb/yr AP-44
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 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.
'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 3-APEN and Permitting Requirements
Is this site considered an exploration and production location (e.g.well pad)? Yes
If yes, review the following two exemptions for applicability:
Does the operator unload less than 10,000 gallons(238 BBLs)per day of crude oil on an annual average basis? No
If yes,this emissions point is categorically exempt from permit requirements per Regulation 3,Part B,Section II.D.1.1
Does this operator unload less than 6,750 bbls per year of condensate via splash fill or
16,308 bbls per year of condensate via submerged fill procedure? No
If yes,this emissions point is categorically exempt from permit requirements per Regulation 3,Part B,Section II.D.1.1
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 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
Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the
2.0 TPY threshold (Reg. 3, Part B, Section II.D.2.a)
Part B, III.D.2-RACT requirements for new or modified minor sources
This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or
attainment/maintenance areas. This source is located in the 8-hour ozone nonattainment area, but not the 1-hour
ozone area.
If source is in non-attainment: The date of interest for determining whether the source is new or modified is
therefore November 20, 2007(the date of the 8-hour ozone NA area designation). Since the tank battery from
which loadout is occurring came into service after the date above(reported as 11/2014 on condensate tank
APEN), this source is considered "new or modified." Operator is using submerged fill (0.6 saturation factor),
therefore, RACT requirements are satisfied.
'Regulation 6-New Source Performance Standards
No applicable subpart.This facility is not a bulk gasoline terminal.
'Regulation 7-Volatile Organic Compounds
No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum liquid storage and
distribution facility that has a daily average throughput of more than 76,000 liters of gasoline(20,000 gallons),
which is loaded directly into transport vehicles.
This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C.
'Regulation 8-Hazardous Air Pollutants
MACT EEEE:
Not subject because this facility is a synthetic minor source of HAPs. It should also be noted that this facility
would not be subject because the loadout is located at a production field facility and is thus exempt per 40CFR
60.2334(c).(1)
t Notes:
1. The weight%values used to calculate the HAP emissions associated with the loadout are company
specific. The operator expressed these specific values are utilized because determining the composition of
emissions for the displaced vapors from the tank truck is difficult to predict. This is due to the fact that
some of the associated vapors from the tank trucks will have the composition of previous loads contained
in the trucks from different facilities. It was determined that the company specific values were a
conservative estimate of the HAP emissions. As a result,they were approved and used in the analysis.
2. The weight%value for 2,2,4-TMP was determined by comparing the emission factors determined for
the condensate tanks from HYSYS. Since 2,2,4-TMP resulted in a similar emission factor as ethylbenzene,
the company specific weight%value for ethlybenzene was also used for 2,2,4-TMP.This again resulted in a
conservative estimate and therefore was accepted.
3. The operator was provided with a draft permit for review. They reviewed the draft and expressed they
did not have any comments.
4. The enclosed combustor used for loadout is a common control device. It also controls the condensate
storage tanks. As a result,the control device is subject to Regulation 7 and shall have no visible emissions.
This fact is reflected in the O&M plan submitted for the loadout operation(describes method 22 readings
will be conducted weekly)and is covered by condition 8 in the permit.
5.This permit will require public comment because the source is at a new synthetic minor facility.
Additionally,they are requesting an enforceable permit limit for the loadout that, if relaxed,would change
the facility classification from synthetic minor to major.
6. The NOx and CO emissions were calculated for this point by the operator and were determined to be
below APEN reporting thresholds. As a result,the NOx and CO emission factors and resulting emissions
are not reported on the APEN or in this PA.
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