HomeMy WebLinkAbout20151422.tiff ,A COPHE ' COLORADO
CO Department of Public
Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632 RECEIVED
May 8, 2015 MAY 1 8 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 Kerr
McGee Gathering LLC - Fort Lupton Gas Plant. 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
Sly
LC;TOW. —905 2015-1422
4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.govicdphe
John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer 1.�:.:.:r•r ,...'r'.
CDPHE Air Pollution Control Division
CO �� Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Kerr McGee Gathering LLC - Fort Lupton Gas Plant - 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: Kerr McGee Gathering LLC
Facility: Fort Lupton Gas Plant
Natural gas processing plant
16116 Weld County Road 22, Fort Lupton, CO 80621
Weld County
The proposed project or activity is as follows: Newly permitted process flare at a natural gas processing
plant.
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 14WE0142 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Any such comment must be submitted in writing to the following addressee:
Stephanie Chaousy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
COLORADO
1 A ::1 .:,�r., ,
STATE OF COLORADO
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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT -` Pt
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AIR POLLUTION CONTROL DIVISION * "
TELEPHONE: (303) 692-3150 1876
CONSTRUCTION PERMIT
PERMIT NO: 14WE0142
E0142
Issuance 1
DATE ISSUED:
ISSUED TO: Kerr-McGee Gathering LLC
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Natural gas processing facility, known as the Ft. Lupton Gas Plant, located in 16116 WCR
22, Ft. Lupton, CO, 80621 in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS Description
Equipment ID Point
One (1)facility process flare to control emissions from
process equipment blowdowns associated with maintenance
activities, compressor blowdowns, and venting such as
pressure relieve valves or plant shutdowns. Activities are
F-4 070 controlled by an elevated open air-assisted process flare
(Make, Model, Serial Number to be submitted). Purge gas
prevents low flashback problems to the flare and keeps the
flame stable. The purge gas and pilot gas used is sales gas
and helps the flare maintain a minimum required positive
flow through the system.
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 APCD no later than fifteen days after commencement of the
permitted operation or activity by submitting a Notice of Startup (NOS) form to the
APCD. The Notice of Startup (NOS) form may be downloaded online at
http://www.colorado.gov/cs/Satellite/CDPHE-AP/CBON/1251596800297. Failure to
notify the APCD of startup of the permitted source is a violation of 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 issuance of this permit, compliance with
the conditions contained on this permit shall be demonstrated to the Division. It is the
permittee's responsibility to self-certify compliance with the conditions. Failure to
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Air Pollution Control Division
demonstrate compliance within 180 days may result in revocation of the permit.
(Reference: Regulation No. 3, Part B, III.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
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. As part of the self-certification process, the operator shall install a flow meter on the inlet
to emissions unit F-4 described above. The flowmeter shall be capable of continuously
measuring and recording the flowrate of the combined gas streams routed to the flare for
combustion.
5. 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.)
6. 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
7. 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)
Monthly' Limits:
Facility AIRS Pounds per Month Emission
Equipment ID Point NO, SO2 VOC CO PM2.5 H2S Type
F-4 070 1444 --- 2158 2888 51 --- Point
. Footnotes:
1: Monthly limits are based on a 31-day month.
Annual Limits:
Tons per Year Emission
Facility AIRS Type
Equipment ID Point
NO, SO2 VOC CO PM2.5 H2S
F-4 070 8.5 --- 12.7 17.0 0.3 --- Point
See "Notes to Permit Holder #4 for information on emission factors and methods used to
calculate limits.
During the first twelve (12) months of operation, compliance with both the monthly and
yearly emission limitations shall be required. After the first twelve (12) months of
operation, compliance with only the yearly limitation shall be required.
Compliance with the emission limits in this permit shall be determined by recording the
facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis
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olor Dep ent Public Health and Environment
Air Pollution Control Division
reporting level) from each emission unit, on a rolling (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 monthly emissions and keep a
compliance record on site or at a local field office with site responsibility, for Division
review. Rolling twelve-month total limitations shall apply to all emission units, requiring
an APEN, at this facility.
8. Emissions from maintenance activities and purge gas shall be collected and controlled
by a flare in order to reduce the emissions of volatile organic compounds to the level
listed in this section, above. Operating parameters of the flare are identified in the
operation and maintenance plan for this unit. Flare combustion efficiency shall be a
minimum of 98%. (Reference: Regulation No.3, Part B, Section III.E.)
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate shall be maintained by the applicant and
made available to the Division for inspection upon request. (Reference: Regulation 3,
Part B, II.A.4)
Process/Consumption Limits
Facility AIRS Monthly
Equipment Point
ID days)
Parameter Annual Limit Limitss(31
)
F-4 070* Natural gas combustion - Process and 78.4 MMSCF/yr 6.7
Purge Gas MMSCF/month
*Note: The process flare is present to control emissions from process equipment blowdowns
associated with maintenance activities, compressor blowdowns, and venting such as pressure
relieve valves or plant shutdowns.
During the first twelve (12) months of operation, compliance with both the monthly and
yearly emission limitations shall be required. After the first twelve (12) months of
operation, compliance with only the yearly limitation shall be required.
Compliance with the yearly 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 monthly
consumption of natural gas and keep a compliance record on site or at a local field office
with site responsibility, for Division review.
10. The operator shall continuously monitor the process and upset flare to ensure the
presence of a pilot flame.
11. The operator shall continuously monitor and record the total volumetric flow rate of the
gas stream being routed to the flare. By the end of each month, the total volumetric flow
for the previous months' data shall be calculated, and a new twelve-month total shall be
calculated and recorded based on the previous twelve months' data.
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.:S olor Dep ent , Public Health and Environment
Air Pollution Control Division
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and AIRS ID number shall be marked on the subject equipment for
ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only
enforceable).
13. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation
of the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in
any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.)
14. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
15. The Division has determined this flare shall comply with the New Source Performance
Standards requirements of Subpart A Section §60.18, General Control Device and Work
Practice Requirements, including, but not limited to, the following:
a. §60.18(b) Flares. Paragraphs (c) through (f) apply to flares.
b. §60.18(c)(1) Flares shall be designed for and operated with no visible emissions
as determined by the methods specified in paragraph (f), except for periods not
to exceed a total of 5 minutes during any 2 consecutive hours.
c. §60.18(c)(2) Flares shall be operated with a flame present at all times, as
determined by the methods specified in paragraph (f).
d. §60.18(c)(3) An owner/operator has the choice of adhering to either the heat
content specifications in paragraph (c)(3)(ii) of this section and the maximum tip
velocity specifications in paragraph (c)(4) of this section, or adhering to the
requirements in paragraph (c)(3)(i) of this section.
• §60.18(c)(3)(i)(A) Flares shall be used that have a diameter of 3
inches or greater, are nonassisted, have a hydrogen content of 8.0
percent (by volume), or greater, and are designed for and operated
with an exit velocity less than 37.2 m/sec (122 ft/sec) and less than
the velocity, Vmax, as determined by the following equation:
Vmax = (XH2 K,)* K2
Where:
Vmax= Maximum permitted velocity, m/sec.
K1 = Constant, 6.0 volume-percent hydrogen.
K2 = Constant, 3.9(m/sec)/volume-percent hydrogen.
XH2 = The volume-percent of hydrogen, on a wet basis, as
calculated by using the American Society for Testing and
Materials (ASTM) Method D1946-77. (Incorporated by reference
as specified in §60.17).
• §60.18(c)(3)(i)(B) The actual exit velocity of a flare shall be
determined by the method specified in paragraph (f)(4) of this section.
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Air Pollution Control Division
• §60.18(c)(3)(ii) Flares shall be used only with the net heating value of
the gas being combusted being 11.2 MJ/scm (300 Btu/scf) or greater
if the flare is steam-assisted or air-assisted; or with the net heating
value of the gas being combusted being 7.45 MJ/scm (200 Btu/scf) or
greater if the flare is nonassisted. The net heating value of the gas
being combusted shall be determined by the methods specified in
paragraph (f)(3) of this section.
e. §60.18(c)(5)Air-assisted flares shall be designed and operated with an exit
velocity less than the velocity, Vmax, as determined by the method specified in
paragraph (f)(6).
f. §60.18(c)(6) Flares used to comply with this section shall be steam-assisted, air-
assisted, or nonassisted.
g. §60.18(d) Owners or operators of flares used to comply with the provisions of
this subpart shall monitor these control devices to ensure that they are operated
and maintained in conformance with their designs. Applicable subparts will
provide provisions stating how owners or operators of flares shall monitor these
control devices.
h. §60.18(e) Flares used to comply with provisions of this subpart shall be operated
at all times when emissions may be vented to them.
§60.18(f)(1) Method 22 of appendix A to this part shall be used to determine the
compliance of flares with the visible emission provisions of this subpart. The
observation period is 2 hours and shall be used according to Method 22.
j. §60.18(f)(2) The presence of a flare pilot flame shall be monitored using a
thermocouple or any other equivalent device to detect the presence of a flame.
k. §60.18(f)(3) The net heating value of the gas being combusted in a flare shall be
calculated using the following equation:
a
M7 = K E Ci M1
1=1
Where:
HT = Net heating value of the sample, MJ/scm; where the net enthalpy per
mole of offgas is based on combustion at 25 °C and 760 mm Hg, but the
standard temperature for determining the volume corresponding to one mole
is 20 °C;
K = Constant, 7 1 d mole‘ MJ
1.740 x I0 'ppm/ t scm ' 11cal/
where the standard temperature for (g mole) is 20'Ci
scm
= Concentration of sample component i in ppm on a wet basis, as
measured for organics by Reference Method 18 and measured for hydrogen
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olor Dep ent Public Health and Environment
Air Pollution Control Division
and carbon monoxide by ASTM D1946-77 or 90 (Reapproved 1994)
(Incorporated by reference as specified in §60.17); and
H, = Net heat of combustion of sample component i, kcal/g mole at 25 °C and
760 mm Hg. The heats of combustion may be determined using ASTM
D2382-76 or 88 or D4809-95 (incorporated by reference as specified in
§60.17) if published values are not available or cannot be calculated.
I. §60.18(f)(4) The actual exit velocity of a flare shall be determined by dividing the
volumetric flowrate (in units of standard temperature and pressure), as
determined by Reference Methods 2, 2A, 2C, or 2D as appropriate; by the
unobstructed (free) cross sectional area of the flare tip.
m. §60.18(f)(5) The maximum permitted velocity, Vmax, for flares complying with
paragraph (c)(4)(iii) shall be determined by the following equation.
Login (Vmax)=(HT+28.8)/31.7
Vmax= Maximum permitted velocity, M/sec
28.8=Constant
31.7=Constant
HT = The net heating value as determined in paragraph (f)(3).
n. §60.18(f)(6) The maximum permitted velocity, Vmax, for air-assisted flares shall be
determined by the following equation.
Vmax= 8.706+0.7084 (HT)
Vmax= Maximum permitted velocity, m/sec
8.706=Constant
0.7084=Constant
HT = The net heating value as determined in paragraph (f)(3).
16. This facility is located in an ozone non-attainment or attainment-maintenance area and
subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, III.D.2.a.:
Facility AIRS
Equipment Point Meeting RACT Requirements by:
ID
F-4 070 Controlling process emissions by combustion using an
open flare
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olor DepT , ent Public Health and Environment
Air Pollution Control Division
OPERATING & MAINTENANCE REQUIREMENTS
17. Upon startup of these points, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in order to demonstrate
compliance on an ongoing basis with the requirements of this permit. Revisions to your
O&M plan are subject to Division approval prior to implementation. (Reference:
Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
18. The owner or operator shall demonstrate compliance with Condition 13 using EPA
Method 22 to measure opacity from the flare per Condition 15. (Reference: Regulation
No. 1, Section II.A.5).
Periodic Testing Requirements
19. The owner or operator shall sample the gas routed to the each of the flares to determine
the heat content on a semi-annual basis.
ADDITIONAL REQUIREMENTS
20. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a) Annually whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen 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.
21. This source is subject to the provisions of Regulation Number 3, Part C, Operating
Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this
construction permit must be incorporated into the operating permit. The application for
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olor Dep ent Public Health and Environment
Air Pollution Control Division
the modification to the Operating Permit is due within one year of commencement of
operation of the equipment or modification covered by this permit.
GENERAL TERMS AND CONDITIONS:
22. 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.
23. 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.
24. 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 applicants agents. It is valid only for the
equipment and operations or activity specifically identified on the permit.
25. 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.
26. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self-certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the applicant, or the Division
revokes a permit, the applicant or owner or operator of a source may request a hearing
before the AQCC for review of the Division's action.
27. 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.
28. 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.
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olor Dep ent Public Health and Environment
Air Pollution Control Division
By:
Stephanie Chaousy, P.E.
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Addition of one (1) process flare. Source at a
major facility.
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polor a Dep r ent Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the permittee providing there is no exceedance of any specific emission control
regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and
application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as
soon as possible, but no later than noon of the next working day, followed by written notice to the
Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation.
See: http://www.cdphe.state.co.us/regulations/airregs/100102aacccommonprovisionsreq.pdf.
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# BIN (Ib/yr) reportable? Rate (Ib/yr)
Benzene 71432 A 3,853 Yes 77
Toluene 108883 C 3,881 Yes 78
070 Ethylbenzene 100414 C 174 No 4
Xylenes 1130207 C 1,347 Yes 27
n-hexane 110543 C 103,862 Yes 2,077
5) The emission levels contained in this permit are based on the following emission factors:
Point 070:
CAS Pollutant Emission Factors - Uncontrolled EF Source
Uncontrolled
NOx 218.56 Ibs/mmscf TCEQ
CO 436.31 lbs/mmscf TCEQ
VOC 16163.27 lbs/mmscf EPA Displacement Equation
71432 Benzene 49.15 lb/mmscf Mass Balance
108883 Toluene 49.50 lb/mmscf Mass Balance
100414 Ethylbenzene 2.221b/mmscf Mass Balance
1130207 Xylenes 17.18 lb/mmscf Mass Balance
110543 n-hexane 1324.77 lb/mmscf Mass Balance
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
AIRS ID: 123/0057 Page 10 of 11
tiogrkes
Fql olor Dep ent Public Health and Environment
�, I Air Pollution Control Division
?ea,
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 Major Source of NOX, VOC, CO, and HAP
PSD Major Source of NOx, VOC and CO
NANSR Major Source of NOX and VOC
MACT ZZZZ Major Source Requirements Apply
MACT HH Major Source: Applicable
NSPS Dc Applicable
NSPS OOOO 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 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: 123/0057 Page 11 of 11
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: Kerr-McGee Gathering LLC
Permit Number: 14WE0142
Source Location: Fort Lupton Gas Plant
16116 Weld County Road 22, Ft. Lupton, CO 80621, Weld County
Equipment Description: Process flare
AIRS ID: 123-0057-070
Date: January 7, 2015
Review Engineer: Stephanie Chaousy, PE
Control Engineer: Chris Laplante
Section 2—Action Completed
Grandfathered Modification APEN Required/Permit Exempt
X CP1 Transfer of Ownership APEN Exempt/Permit Exempt
Section 3—Applicant Completeness Review
Was the correct APEN submitted for this source type? X Yes No
Is the APEN signed with an original signature? X Yes No
Was the APEN filled out completely? X Yes No
Did the applicant submit all required paperwork? X Yes No
Did the applicant provide ample information to determine emission rates? Yes X No
If you answered "no" to any of the above, when VOC emissions were originally calculated using AP-
did you mail an Information Request letter to the 42 not a gas analysis and the displacement equation.
source? I talked with the operator and they provided me
revised calculations January 2015.
On what date was this application complete? December 13, 2013
Section 4—Source Description
AIRS Point Equipment Description
One (1)facility process flare to control emissions from process equipment blowdowns
associated with maintenance activities, compressor blowdowns, and venting such as
pressure relieve valves or plant shutdowns. Activities are controlled by an elevated open
070 air-assisted process flare (Make, Model, Serial Number to be submitted). Purge gas
prevents low flashback problems to the flare and keeps the flame stable. The purge gas
and pilot gas used is sales gas and helps the flare maintain a minimum required positive
flow through the system.
Is this a portable source? Yes X No
Is this location in a non-attainment area for any criteria Yes No
pollutant?
If"yes", for what pollutant? PM,o CO X Ozone
Is this location in an attainment maintenance area for Yes X No
any criteria pollutant?
Page 1
If"yes", for what pollutant?
(Note: These pollutants are subject to minor source PM10 CO Ozone
RACT per Regulation 3, Part B, Section III.D.2)
Is this source located in the 8-hour ozone non-
attainment region?(Note: If"yes" the provisions of X Yes No
Regulation 7, Sections XII and XVII.C may apply)
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
070 TCEQ for NOx and CO
Displacement Equation (AP-42, Equation 10.4-3)for VOC and HAPS (Mass Balance)
Did the applicant provide actual process data for the emission inventory? Yes X No
Basis for Potential to Emit(PTE)
AIRS Point Process Consumption/Throughput/Production
070 78.4 MMSCF per year
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point Process Consumption/Throughput/Production Data Year
070 78.4 MMSCF per year 2014
Basis for Permitted Emissions(Permit Limits)
AIRS Point Process Consumption/Throughput/Production
070 78.4 MMSCF per year
Does this source use a control device? X Yes No
%Reduction
AIRS Point Process Control Device Description
Granted
VOC070 01 Process flare HAP and
HAPS: 98
Section 6—Emission Summary (tons per year)
Point NO, VOC CO Single HAP Total HAP
PTE: 070 8.5 633.6 17.0 51.9 (Hexane) 56.6
Uncontrolled point 070 8.5 633.6 17.0 51.9 (Hexane) 56.6
source emission rate:
Controlled point 070 8.5 12.7 17.0 1.0 (Hexane) 1.1
source emission rate:
Section 7—Non-Criteria/ Hazardous Air Pollutants
Uncontrolled Aral
ne Controlled Emission
Pollutant CAS# BIN Emission Rate emissions
(lb/yr) reportable? Rate(Ib/yr)
Benzene 71432 A 3853 Yes 77
Toluene 108883 C 3881 Yes 78
Ethylbenzene 100414 C 174 No 4
Xylenes 1330207 C 1347 Yes 27
n-Hexane 110543 C 103862 Yes 2077
Note: Regulation 3, Part A, Section Il.B.3.b APEN emission reporting requirements for non-criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Page 2
Section 8—Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory X Yes No
standard?
If"yes", complete the information listed below
AIRS Point Process Pollutant Regulatory Basis Test Method
070 01 VOC, State only requirement Extended gas
HAPS analysis
070 01 VOC, Regulation No. 1, Section II.A.5 Method 22
HAPS
Section 9—Source Classification
Are this a new previously un-permitted X Yes No
source?
What is this facility classification? True Synthetic X Major
Minor Minor
Classification relates to what X Title V X PSD X NA NSR X MACT
programs?
Is this a modification to an existing stationary Yes X No
source?
If "yes"what kind of modification? Minor Synthetic Major
Minor
Section 10—Public Comment
Does this permit require public comment per CAQCC Regulation 3? X Yes No
If "yes", for which pollutants?Why?
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? Yes X No
For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes X No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient Yes X No
Air Quality Standards (NAAQS)?
If"yes", for which pollutants?Why?
AIRS Point Section 12— Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or operator
of a source shall allow or cause the emission into the atmosphere of any air pollutant which
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,
070 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
070 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.
Page 3
Regulation 3-APENs Construction Permits Operating Permits, PSD
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for
070 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
070 Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold(Reg.3, Part B, Section Il.D.3.a)
Regulation 6- New Source Performance Standards
070 New Source Performance Standards requirements of Subpart A Section §60.18,
General Control Device and Work Practice Requirements for air-assisted flares.
Regulation 7—Volatile Organic Compounds
070 None
Regulation 8—Hazardous Air Pollutants
070 None
Section 13—Aerometric Information Retrieval System Coding Information
Process Emission Pollutant/ Fugitive Control
Point Process Description Factor CAS# (Y/N) Emission Factor Source (%)
16163.2653 VOC No Mass Balance 98
lb/mmscf (Engineering Calculation)
0.138 NOx No TCEQ 0
Ib/mmbtu
0.28 CO No TCEQ 0
Ib/mmbtu
49.1454 Benzene/ No Mass Balance 98
Ib/mmscf 71432 (Engineering Calculation)
01 Flare
070 49.5026 Toluene/ No Mass Balance 98
Ib/mmscf 108883 (Engineering Calculation)
2.2194 Ethylbenzene/ No Mass Balance 98
lb/mmscf 100414 (Engineering Calculation)
17.1811 Xylenes/ No Mass Balance 98
Ib/mmscf 1330207 (Engineering Calculation)
1324.7704 n-Hexane/ No Mass Balance 98
Ib/mmscf 110543 (Engineering Calculation)
SCC 31000205-Flares
Page 4
Section 14—Miscellaneous Application Notes
AIRS Point 070 Process flare
A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY(permit threshold). This
modification is the installation of a new process flare at an existing major source in the non-attainment area.
Operator requested 98% control efficiency. Typically the division has granted 95%for flares. KMG insisted that this
air-assisted flare is much more hi-tech than the typical process flares found at gas plants. The cost of this flare is
twice as much as typical flares. Because it is an open flare, it is impossible to test it to confirm 98% destruction.
KMG provided the operation and maintenance manual developed by the manufacturer for our review. The cover
letter stated that"It's difficult to predict the combustion efficiency in an air-assisted flare tip, since the overall
efficiency depends not only in the design but also on the way the flare is operated...The industry standards for
determination of destruction or combustion efficiency of elevated flares are based on the testing conducted by the US
EPA and Chemical Manufacturers from 1983 to 1985 and published in EPA document. Based on these studies the
US EPA concluded that properly designed and operated flares achieve greater than 98% combustion
efficiency...Flares designed with these guidelines [listed in letter] have been assumed to provide minimum DRE of
98%." KMG will follow the operation and maintenance manual provided by the manufacturer in order to operate the
flare within the correct guidelines. This flare shall comply with the New Source Performance Standards requirements
of Subpart A Section§60.18, General Control Device and Work Practice Requirements to ensure performance of the
flare in order to grant the 98% DRE. The Fort Lupton flare is present to control emissions from process equipment
blowdowns associated with maintenance activities, compressor blowdowns, and venting such as pressure relieve
valves or plant shutdowns.
Operator used TCEQ to calculate NOx and CO emissions.
Average heating value was used.
NG Ratio=(0.396)/(0.396+13.7) =0.02809
Process ratio= (13.7)/(0.396+13.7) =0.97191
Avg =(1020'0.02809) + (1600"0.97191) = 1583.7060 btu/scf
NOx= 0.138 lb 1583.7060 btu 78.4 mmscf 1 T =8.56 TPY
MMBtu scf year 2000 lb
Operator calculated 8.5 TPY. This could be due to rounding with the throughput or heating value; I will accept 8.5
TPY NOx.
CO = 0.28 lb 1583.7060 btu 78.4 mmscf 1 T = 17.38 TPY
MMBtu scf year 2000 lb
Operator calculated 17.0 TPY. This could be due to rounding with the throughput or heating value: I will accept 17.0
TPY CO.
I used the displacement equation (wellhead separator spreadsheet) to calculate emissions from this point source
(reference K:\PA\2014\14WE0142.CP1.xlsm)and calculated emission factors using what was calculated in the
spreadsheet.
Throughput(Q) 78.4 MMscf/yr 8949.8 scf/hr
MW 22.900 Ib/Ib-mol 0.002 MMscf/d
Mass°/ci Uncontrolled Operator Controlled Emission
in flared Emissions Uncontrolled Emissions factor
Component gas (see xcel) Emissions (Ib/yr) (lb/mmscf)
VOC 634.1 TPY 633.6 TPY 12.7 TPY 16163.2653
Benzene 0.0821% 3852 lb/yr 3853 lb/yr 77 lb/yr 49.1454
Toluene 0.0827% 3881 lb/yr 3881 lb/yr 78 lb/yr 49.5026
Ethylbenzene 0.0037% 174 lb/yr 174 lb/yr 4 lb/yr 2.2194
Xylenes 0.0287% 1347 lb/yr 1347 lb/yr 27 lb/yr 17.1811
n-Hexane 0.0000% 105181 lb/yr 103862 lb/yr 2077 lb/yr 1324.7704
224-TMP 0.0000% 0 0 0 0
Discrepancies between my calculations and the operators are probably due to rounding. I am comfortable with
operator's calculations for permitting.
Page 5
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