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Home My WebLink About20151423.tiff A COPHE COLORADO Co ''..% Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St RECEIVED PO Box 758 Greeley, CO 80632 MAY 1 8 2015 May 14, 2015 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On May 20, 2015, the Air Pollution Control Division will begin a 30-day public notice period for Kerr- McGee Oil and Gas Onshore LP - 36128757. 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 8 Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, f 7,i r•Clara Gonzales f ..�Lrr Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure • ----PU-b)Lis,‘ TV,UitA-3 CC' PL;"PW 'L 1)� 2015-1423 -* (°r,-v 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692.2000 www.colorado.gov/cdphe . c: John W. Hickenlooper,Governor Larry Wolk, MD,MSPH,Executive Director and Chief Medical Officer %s7 +. CDPH Air Pollution Control Division c© ''-"Sr Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Kerr-McGee Oil and Gas Onshore LP - 36128757 - Weld County Notice Period Begins: May 20, 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 Oil and Gas Onshore LP Facility: 36128757 Oil and gas exploration and production facility SESW Section 36, Township 3N, Range 65W Weld County The proposed project or activity is as follows: The applicant is requesting permit coverage for loading of condensate from storage tanks to tank trucks at an exploration and production site. 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 14WE1754 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 :OLORz�C 1 I ir g t 1 5 ' a. STATE OF COLORADO zgicat-~/ ° COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 1of AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 '' + ' -4-1876% CONSTRUCTION PERMIT PERMIT NO: 14W E1754 1 754 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee Oil and Gas Onshore LP THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility, known as 36128757, located in the SESW of Section 36, Township 3N, Range 65W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID TL-01 007 Truck loadout of condensate. Emissions from the loadout are controlled by an enclosed flare. 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 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.gov/pacific/cdphe/other-air- permitting-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, 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: 123/9B49 Page 1 of 8 Condensate Loadout TM Version 2012-1 Co do . P e o Public Health and Environment Air Pollution Control Division 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, I I I.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 z TL-01 007 1.6 21.6 4.1 Point See "Notes to Permit Holder"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 Pollutants Equipment Point Control Device Controlled ID TL-01 007 Enclosed Flare VOC, HAPs PROCESS LIMITATIONS AND RECORDS 7. 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 owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) AIRS ID: 123/9B49 Page 2 of 8 g ., J� a Cold do D p etrhe. o Public Health and Environment 1/4446%, - Air Pollution Control Division ` 141 Process/Consumption Limits AIRS Process Parameter Annual Limit Point 007 Condensate Loading 3,650,000 BBL 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. 8. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 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 AIRS ID: 123/9B49 Page 3 of 8 OW Co T do • p e o Public Health and Environment Air Pollution Control Division 13. 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.) 14. Flare shall be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare, or by other convenient means approved by the Division, determine whether the flare is operating properly. 15. The owner or operator of a loadout at which an enclosed flare 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 16. This source is not required to comply with any testing and sampling requirements. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 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 AIRS ID: 123/9B49 Page 4 of 8 Co( r� do wartme of Public Health and Environment Air Pollution Control Division ��: Ag vatsm 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. 18. 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 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. AIRS ID: 123/9B49 Page 5 of 8 1 Co do l p e o Public Health and Environment li Air Pollution Control Division : r It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Kerr-McGee Oil and Gas Onshore LP AIRS ID: 123/9B49 Page 6 of 8 4 Col do Dprme # of Public Health and Environment Lir LP" Air Pollution Control Division i , jra 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 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: https.//www.cclorado.gov/pacific/cdphe/aqcc-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 Rate Point Pollutant CAS# (Ib/yr) reportable? (Ib/yr) n-Hexane 110543 13,140 Yes 657 007 Benzene 71432 1,497 Yes 75 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/BBL Source Lb/BBL Source loaded loaded VOC 0.236 PS Memo 14-02 0.0118 PS Memo 14-02 110543 n-Hexane 0.0036 CDPHE I 0.00018 CDPHE PS Memo 14-02 PS Memo 14-02 71432 Benzene 0.00041 PS Memo 14-02 0.0000205 PS Memo E4-02 NOx 0.0008732 Engineering N/A N/A lb/bbl Estimate CO 0.002218 Engineering N/A N/A lb/bbl Estimate The uncontrolled VOC and non-criteria reportable air pollutant (NCRP) emission factors represent state approved emission factors for condensate loadout found in CDPHE PS-Memo 14-02. 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 AIRS ID: 12319B49 Page 7 of 8 Co do p e o Public Health and Environment Air Pollution Control Division 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 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: 123/9649 Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Kerr-McGee Oil and Gas Onshore LP Permit Number: 14WE1754 Source Name: 36128757 Source Location: SESW Section 36, Township 3N, Range 65W Equipment Description: Truck loadout of condensate AIRS ID: 123-9649-007 Review Date: 03/19/2015 Review Engineer: Harrison Slaughter Control Engineer: Chris Laplante Section 2—Action Completed X CP1 Modification APEN Required/Permit Exempt Final Approval Transfer of Ownership APEN Exempt/Permit Exempt Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no" to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? November 4, 2014 Section 4—Source Description AIRS Point Equipment Description 007 Truck Condensate Loadout 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? PM10 CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source N/A PM10 N/A CO N/A 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) Is this source located at an oil and gas exploration X Yes No site? Page 1 If yes, does this source load less than 10,000 gallons of crude oil per day on an annual average, splash fill less than 6750 bbl of condensate(hydrocarbons that Yes X No have an API gravity of 40 degrees or greater) per year or submerged fill less than 16,308 bbl of condensate per year? Is this source located at a facility that is considered a major source of hazardous air pollutant(HAP) Yes X No emissions? Will this equipment be operated in any NAAQS X Yes No nonattainment area? Does this source load gasoline into transport vehicles? Yes X No Section 5—Emission Estimate Information AIRS Point Emission Factor Source State emission factors for condensate were utilized to calculate emissions from 007 loadout. 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 007 3,650,000 BBL per year condensate loaded Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production 007 3,650,000 BBL per year condensate loaded Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 007 3,650,000 BBL per year condensate loaded Does this source use a control device? X Yes No Section 6— Emission Summar/ (tons per year) Point NO, VOC CO Single HAP HAP PTE: 007 1.6 431 4.1 6'57 7.33 (n-Hexane) Uncontrolled point 007 1.6 431 4.1 6.57 7.33 source emission rate: (n-Hexane) Permitted point source 007 1.6 21.6 4.1 0.33 0.37 emission rate: (n-Hexane) Total 1.6 21.6 4.1 0.33 0.37 (n-Hexane) Uncontrolled Are the Controlled Emission Rate Pollutant CAS # Emission Rate emissions(lb/yr) reportable? (lb/ r Y ) Benzene 71432 1497 Yes 75 n-Hexane 110543 13,140 Yes 657 Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? Page 2 Section 9—Source Classification Is this a new previously un-permitted X Yes No source? What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what X Title V PSD X NA NSR MACT programs? Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? N/A Minor N/A Synthetic N/A 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.iii (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)? AIRS Point Section 12— Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 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.) 007 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 007 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, Operatinq Permits, PSD 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 tons per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is non-attainment. 007 (Applicant is required to file an APEN since emissions exceed 1 tons 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 ll.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. 007 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, this source is considered "new or modified." (Year Tanks were placed in service 2013). Operator is using submerged fill (0.6 saturation factor), therefore, RACT requirements are satisfied. Regulation 6-New Source Performance Standards 007 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 007 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 007 None Section 13—Aerometric Information Retrieval System Coding Information Process/ Emission Process Emission Pollutant/ Fugitive Control Point Process Description throughput Factor CAS# (Y/N) Factor (ova) Limit Source 5.62 lb/1000 VOC No CDPHE PS 95 gallon Memo 14-02 throughput 0.00976 lb/1000 Benzene/ CDPHE PS gallon 71432 No Memo 14-02 95 01 Truck Condensate 3,650,000 throughput 007 Loadout BBL/yr 0.0857 lb/1000 n-Hexane/ CDPHE PS gallon 110543 No Memo 14-02 95 throughput 0.0008732 NOx No Engineering N/A lb/bbl Estimate 0.002218 CO No Engineering N/A lb/bbl Estimate SCC 40600132: Crude Oil: Submerged Loading (Normal Service) Page 4 Section 14—Miscellaneous Application Notes AIRS Point 007 Truck Condensate Loadout The emission factors used to calculate the loadout emissions were state emission factors found in the CDPHE PS-Memo 14-02. The emission factors utilized are as follow: Truck Loadout- PS Memo 14-02 Loadout Default Emission Factors (Ib/bbl) Hydrocarbon Type: VOC Benzene n-Hexane Condensate—API Gravity≥ 40 0.236 0.00041 0.0036 The emission factors used to calculate the NOx and CO emissions were determined with an engineering estimate using the NOx and CO EF from the CDPHE Inter-office communication from 2005-03-22 in conjunction with the state loadout emission factor for VOC. Permit Notes: 1. The flare that is controlling the emissions from the loadout is the same flare that controls emissions from the condensate tanks. As a result, condition #14 in the permit that states the "flare shall be enclosed, have no visible emissions, and be designed...."was left in the permit. This is due to the fact that the condensate tanks are subject to Reg 7 section XII and XVII. The requirements of this regulation are consistent with condition 14 in the permit. 2. The submitted O&M plan expresses that Method 22 readings will be conducted weekly for the flare in order to demonstrate compliance with Regulation 7 requirements. 3. The monitoring frequency displayed in the O&M plan for this point are based on permitted facility emissions < 80 tpy VOC. Although the facility wide emissions inventory form displays VOC emissions at 95.9 tpy, the operator expressed that a cancellation request for the permitted fugitives at the facility had been submitted. This brought the permitted VOC emissions below the 80 tpy threshold. As a result, the monitoring frequency expressed on the O&M Plan was deemed acceptable. A copy of the cancellation notice was obtained from the operator. 4. The uncontrolled NOx and CO emission factors represent approved values from the CDPHE Inter-Office Communication on 2005-03-22 multiplied by the VOC emission factor from the CDPHE PS Memo 14-02. The emission factor for and emissions of NOx and CO were determined through the following calculation: EF,lb EF,lbVOC Emission Factory = (lb VOC� bbl The calculation of the NOx and CO emission factors represented in the permit are as follow: 0.0037 lbs N0x 0.236 lb VOC 0.0008732 lb NOx NOxiblbbi = lb VOC ) * ( bbl ) = bbl 0.0094 lbs CO 0.236 lb VOC 0.002218 lb CO COib/btii = lb VOC ) ( bbl bbl The calculation of the NOx emission limit found in the permit is as follows: 0.0008732 lbs NOx 3,650,000 bbl) 1 ton 1.6 tons NOx NOxt,y = bbl / '. year \20001b51 year The calculation of the CO emission limit found in the permit is as follows: 0.002218 lb CO 3,650,000 bbl 1 ton 4.1 tons CO CO`py — bbl ) * year ) *�20001bs� year Page 5 5. A cancellation notice for the fugitives permitted at the facility was submitted to the Division by the operator. This dropped the uncontrolled emissions of n-Hexane to-8 tpy. As a result, the facility is not synthetic minor for n-Hexane as an individual HAP. 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