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HomeMy WebLinkAbout20143583.tiff CDPHE 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 November 12, 2014 NOV 17 2014 COMMISSIONERS Dear Sir or Madam: On November 19, 2014, the Air Pollution Control Division will begin a 30-day public notice period for Encana Oil Et Gas (USA) Inc. - State 3H. 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 a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Ca tQ) Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer I * 3 ?Lib, kev le()) „ 2014-3583 /F/1-/4/ cc:-PC: w, µL 11? CDPHE Air Pollution Control Division CO 1Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Encana Oil 8 Gas (USA) Inc. - State 3H - Weld County Notice Period Begins: November 19, 2014 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 a Gas (USA) Inc. Facility: State 3H Oil and Gas Exploration and Production Facility NWSW SEC 16 T3N R68W Weld County The proposed project or activity is as follows: Applicant proposes the activity of loading out 410,520 BBL of condensate into tank trucks per year. 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 14WE1232 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:, Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us WU COLORADO NtaUnh F=„ STATE OF COLORADO .pF'C COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION e TELEPHONE: (303)692-3150 +� • 4-1876* " CONSTRUCTION PERMIT PERMIT NO: 14WE1232 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 facility, known as the State 3H facility, located in the NWSW of Section 16, Township 3N, Range 68W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Loadout 003 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 after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at 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) after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source AIRS ID: 123/9CFB Page 1 of 8 Condensate Loadout TM Version 2012-1 Colorado Department of Public Health and Environment Air Pollution Control Division 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 Point Emission Type ID VOC Loadout 003 2.1 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 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 Loadout 003 Enclosed Combustor VOC 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 AIRS ID: 123/9CFB Page 2 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits AAIR Process Parameter Annual Limit Point 003 Condensate Loading 410,520 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): II 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. AIRS ID: 123/9CFB Page 3 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division OPERATING & MAINTENANCE REQUIREMENTS 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 vapor balancing 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 and return these vapors to the stationary source storage tanks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Install dry-break loading couplings to prevent hydrocarbon liquid loss during uncoupling from vehicles. d. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. e. Operate all recovery and disposal equipment at a back pressure less than the pressure relief valve setting of transport vehicles. f. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. g. 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. h. 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) AIRS ID: 123/9CFB Page 4 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO() in ozone nonattainment areas emitting less than 100 tons of 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 AIRS ID: 123/9CFB Page 5 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas(USA) Inc. New syn minor facility. AIRS ID: 123/9CFB Page 6 of 8 Colorado Department of 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 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.colorado.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 Point Pollutant CAS# BIN (lb/yr) reportable? Rate(lb/yr) Benzene 71432 A 788 Yes 39 n-Hexane 110543 C 1953 Yes 98 003 Toluene 108883 C 1391 Yes 70 Xylenes 1130207 C 612 Yes 31 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 loaded Source Lb/BBL loaded Source VOC 0.2 0.01 71432 Benzene 0.046 HYSYS 0.0023 HYSYS and 110543 n-Hexane 0.11 and 0.0055 EPA 108883 Toluene 0.081 Tanks 0.004 Tanks 1130207 Xylenes 0.036 0.0018 The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L= 12.46*S*P`M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) =4.9 psia M (vapor molecular weight) =68 lb/lb-mol T (temperature of liquid loaded) = 512.12 °R AIRS ID: 123/9CFB Page 7 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by using Hysys to model the flashing losses and EPA Tanks to model the working and breathing losses. 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, n-hexane NANSR Synthetic Minor Source of: VOC, n-hexane 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 7777—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.coloradoxiov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9CFB Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Encana Oil &Gas (USA) Inc. Permit Number: 14WE1232 Source Name: State 3H Source Location: NWSW SEC16 T3N R68W Equipment Description: Hydrocarbon liquid loadout AIRS ID: 123/9CFB/003 Review Date: 9/15/2014 Review Engineer: Stuart Siffring 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? 7/17/2014 Section 4—Source Description AIRS Point Equipment Description 003 Truck Condensate Loadout Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PKo 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 PKo 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) Is this source located at an oil and gas exploration site? Yes No (Section 03 on APEN) 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 have Yes X No an API gravity of 40 degrees or greater) per year or submerged fill less than 16,308 bbl of condensate per year? (Section 03 on APEN) Is this source located at a facility that is considered a major source of hazardous air pollutant(HAP) emissions? (Section 03 on APEN) If yes, source might Yes X No be subject to Subparts EEEE, CC, R. Please review these rules and determine applicability. Will this equipment be operated in any NAAQS nonattainment area? (Section 03 on APEN) If yes, source might be subject to Reg. 3, Part B, Section X Yes No III.D.2, Please review these rules and determine applicability. Does this source load gasoline into transport vehicles? (Section 03 on APEN). If yes, source might be subject Yes X No to Reg. 7, Section VI.C, subpart BBBBBB orXX. Please review these rules and determine applicability. Section 5—Emission Estimate Information AIRS Point Emission Factor Source AP-42: Chapter 5.2, Equation 1 L= 12.46*S*P*M/T 003 L=loading losses in lb per 1000 gallons loaded S =Saturation Factor P =true vapor pressure of liquid loaded [psia] M =molecular weight of vapors [lb/lb-mole] T=temperature of bulk liquid loaded [deg. R] Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potentia l to Emit(PTE2 AIRS Point Process Consumption/Throughput/Production 003 410,520 BBL per year condensate loaded Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 003 410,520 BBL per year condensate loaded Does this source use a control device? X Yes No Section 6—Emission Summary(tons per year) Point NO. VOC CO Single HAP HAP PTE: 003 41.91 0.98 (n-hexane) 2.3 Uncontrolled point 003 41.91 0.98(n-hexane) 2.3 source emission rate: Permitted point source 003 2.1 0.05(n-hexane) 0.13 emission rate: Total See history file for facility totals Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions (iblyr) reportable? Rate(lb/yr) Page 2 Benzene 71432 A 788 Yes 39 n-Hexane 110543 C 1953 Yes 98 Toluene 108883 C 1391 Yes 70 Xylenes 1130207 C 612 Yes 31 Note: Regulation 3, Part A, Section ll.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. Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? Section 9—Source Classification Is this a new previously un-permitted source? X Yes No True Synthetic What is this facility classification? Minor X Minor Major Classification relates to what programs? X Title V PSD X NA NSR MACT Is this a modification to an existing permit? Yes X No 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)? X Yes 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 Re•ulation 1 -Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of 003 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.) 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 003 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.Coen ing'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 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 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.3.a) 003 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 has not been in service since before the date above,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. 003 No applicable subpart. This facility is not a bulk gasoline terminal. Reputation 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 003 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 PolkRants 4 003 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 (%) Limit Source 4.76 01 Truck Condensate 410,520 Ib/1,000 V0C No Hysys and 95 003 Loadout BBL/yr gallon EPA Tanks throughput SCC 40600132: Crude Oil: Submerged Loading (Normal Service) Page 4 Section 14—Miscellaneous Application Notes AIRS Point 002 Truck Condensate Loadout Units Basis S 0.6 Submerged loading: dedicated normal service based on sources description/drawings P 4.9 Psia Based on extended natural gas sample OR based on EPA TANKs run M 68 Lb/lb-mole Based on extended natural gas sample OR based on EPA TANKs run T 512.12 Deg R Based on source's knowledge of bulk liquid temperature OR based on EPA TANKs run L 4.76 Lb/10^3 gal Clarify if this value is used to calculate annual emissions or if methane/ethane are removed to represent VOC vs TOC or if a safety factor is applied OR any other relevant notes 0.2 Lb/bbl AP-42: Chapter 5.2 Equation 1 L= 12.46*S*P*MIT L= loading losses in lb per 1000 gallons loaded S = Saturation Factor P =true vapor pressure of liquid loaded [psia] M = molecular weight of vapors [lb/lb-mole] T=temperature of bulk liquid loaded [deg. R] Use the loadout PA spreadsheet to calculate emission factor and emissions L 4.761b/10^3 gal 0.2Ib/bbl Annual requested Throughput 17241840ga1/yr Annual requested VOC emissions 838201b/yr 41.9tpy Page 5 0 0 0 0 01 s 0 0 0 0 0 0 E 0 E a - 0 .� 5 3r 3r .a c a y CD s 2 4 a C C C G C c W 00 v r % \N N N € - p 0 O 0 0 0 0 pQ.�, C /9 N O, N W O O c ❑ 0 0 0 0 0 0 . Q A 0 ' :a ry 'O .o 'O 0 4, q+ O en vi 0 o a ❑ ❑ ODD W U y 0 :pg a 4-..., 0 o c e 'O m m 44 x ❑ y P. C ` 0 0 0 0 0 `° c m .C cSI c. w° a 3 eq IL N a U .0 i r c 3 .co, a .o .E Z Z '.Z Z Z. y .�° .. a�,.. a_ en v u 0 0 'E € u q C .-0 F co 'n ti ai ra '3 C O v v v d r v d et a i 0 L c s r� s '0 S O py N 'E v .C ca AG y ti. v N 0 0 v v vi. 0 >` 0 0. .C � = v .. 00 ',..2: m O •G a - m c E W E 0. 0.` 0 3 u° L " 0 ° > u u gx e °m o > E 0 .C 0 " 00 ro CA o `o a ❑ ❑ v a E o ® ❑ ❑ ® ❑ E o v; 0 R .- L. eon o 0 m c a a, o O `A c c q O M ea a6i c m m �. �, w 0.0.. 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