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Address Info: 1150 O Street, P.O. Box 758, Greeley, CO 80632 | Phone:
(970) 400-4225
| Fax: (970) 336-7233 | Email:
egesick@weld.gov
| Official: Esther Gesick -
Clerk to the Board
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20143500.tiff
41/4, CDPHE COLORADO CO A 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 1150O St RECEIVED PO Box 758 Greeley, CO 80632 NOV 0 7 2014 November 4, 2014 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On November 5, 2014, the Air Pollution Control Division will begin a 30-day public notice period for ONEOK Bakken Pipeline LLC - OPPL Interconnect Station. 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 date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Ft Environment APCD-SS-61 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, t A I ./alga_ ---- e,-Zaty Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure /pF Ot3• 4' �4 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ae z r:x2 li, 0 John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer k ,, x 18'6."I 7ubIAc. gtutRAdO !f— IZ ,q co- Pt, RC,, PLO l(j7 204- 3500 C E Public Notice Of A Proposed Project CO Or Activity Warranting Public Comment Website Title: ONEOK Bakken Pipeline LLC - OPPL Interconnect Station - Weld County Notice Period Begins: November 5, 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: ONEOK Bakken Pipeline LLC Facility: OPPL Interconnect Station Natural gas liquids pipeline SWSW Sec 3, T10N, R63W Weld County The proposed project or activity is as follows: The applicant proposes to install a control device to reduce emission associated with pipeline maintenance. 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 12WE1404 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: Stuart Siffring Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1 I AV -COLORADO STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION N< TELEPHONE: (303)692-3150 *1876* CONSTRUCTION PERMIT PERMIT NO: 12WE1404 Issuance 2 DATE ISSUED: ISSUED TO: ONEOK Bakken Pipeline, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas pipeline facility, known as the OPPL Interconnect Station, located in the SWSW S3 T10N R63W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Meter Maintenance blowdowns (meter skid and pigging operations) Station 001 and inlet filter changes. Maintenance Fugitive Equipment leaks (fugitive VOCs) from a natural gas liquids Equipment 003 pipeline interconnect station. Leaks 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 sect), 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. 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). 2. 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.) 3. 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. AIRS ID: 123/9758 Page 1 of 9 Fugitive TM Version 2012-2 ONEOK Bakken Pipeline, LLC Colorado Department of Public Health and Environment Air Pollution Control Division EMISSION LIMITATIONS AND RECORDS 4. 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: Tons per Year Facility Equipment ID AIRS Point Emission Type VOC Meter Station 001 16.6 Point Maintenance Fugitive Equipment 003 7.1 Fugitive Leaks See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Annual records of the actual emission rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. 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. 5. Point 003: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent liquids analysis, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. 6. Points 001: The operator shall calculate actual annual calendar year VOC emissions based on actual blowdown and actual pigging events and the results of the liquids analysis, as required in Condition 10, the Compliance Testing and Sampling section of this permit. 7. The emission points in the table below shall be operated and maintained with the control equipment as listed to reduce emissions to less than or equal to the limits established in this permit(Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Control Device Pollutants Equipment ID Point Controlled Meter Station 001 Open Flame Flare VOC Maintenance PROCESS LIMITATIONS AND RECORDS AIRS ID: 123/9758 Page 2 of 9 ONEOK Bakken Pipeline, LLC Colorado Department of Public Health and Environment Air Pollution Control Division 8. This source shall maintain annual records of the actual number of maintenance events which occur, and keep them for two years to be made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) 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 owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits AIRS Process Parameter Annual Limit Point 001 NGL Routed to Flare 3,514.8 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. 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. (Reference: Regulation No. 1, Section II.A.5.) 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.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 9 to measure opacity from the flare. This measurement shall consist of a AIRS ID: 123/9758 Page 3 of 9 ONEOK Bakken Pipeline, LLC Colorado Department of Public Health and Environment Air Pollution Control Division minimum twenty-four consecutive readings taken at fifteen second intervals over a six minute period. (Reference: Regulation No. 1, Section II.A.1 &4) Periodic Testing Requirements 15. On an annual basis, the owner or operator shall complete (or obtain from the NGL supplier) an extended analysis of natural gas liquids to determine volatile organic compounds (VOC) and hazardous air pollutants (HAP) content and liquid density representative of the NGL in the pipeline. This analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 16. All previous versions of this permit are cancelled upon issuance of this permit. 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 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. AIRS ID: 123/9758 Page 4 of 9 ONEOK Bakken Pipeline, LLC Colorado Department of Public Health and Environment Air Pollution Control Division 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. 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 or 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: , 6/11 /atm 'Li, , r Stuart Siffring Permit Engineer AIRS ID: 123/9758 Page 5 of 9 ONEOK Bakken Pipeline, LLC Colorado Department of Public Health and Environment Air Pollution Control Division Permit History Issuance Date Description Issuance 2 This Issuance Modification to allow control device to be used. Increase throughput to flare. Issuance 1 Final approval: 10/23/2013 Issued to ONEOK Bakken Pipeline, LLC • AIRS ID: 123/9758 Page 6 of 9 ONEOK Bakken Pipeline, LLC 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 pen-nit 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 emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.cdphe.state.co.us/requlations/aireqs/100102agcccommonprovisionsreq.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 Are the Controlled AIRS Emission Rate emissions Emission Rate Point Pollutant CAS# (Ib/yr) reportable? (Ib/yr) Benzene 71432 568 Yes 28 001 n-Hexane 110543 5488 Yes 274 Toluene 108883 140 No 7 Benzene 71432 11.8 No 11.8 003 Toluene 108883 2.9 No 2.9 n-Hexane 110543 113.6 No 113.6 5) The emission levels contained in this permit are based on the following emission factors: Estimated Annual Uncontrolled AIRS Events per year Emission Factor Point Process Description (lb VOC/event) 001 01 Inlet Filter 1 (-10%cloth) 11.09pB 001 02 Inlet Filter 2 (-10%cloth) 52 11.09pB 001 03 Inlet Filter 3 (-10% cloth) 11.09pB 001 04 Meter Skid Blowdowns 15 19.66pB 001 05 Pig Receiver Section 1 15 1.12pB 001 06 Pig Receiver Section 2 15 1.53pB AIRS ID: 123/9758 Page 7 of 9 ONEOK Bakken Pipeline, LLC Colorado Department of Public Health and Environment Air Pollution Control Division *Not a limit, but for informational purpose only. Where emission factor is equal to: E.F.(lb VOC/event)=Volume of emissions(bbl/event) 'liquid density(lb/bbl)*%VOC(fractional) Where p= Liquid Density(lb/bbl) B=%VOC(fractional) For the purpose of the emission factors included in this permit, B= 1.0 and p= 188.92 lb/bbl. Notes: a. Volume estimates shown above are based on pre-construction projections. Actual volumes are to be used in actual emission calculations. Actual volumes may be higher or lower than shown. Actual volumes will be calculated from actual dimensions of filters and pig traps in the"as-built condition or to be estimated based on pipe diameter and length of pipe between block valves. b. The liquid density and % VOC from the liquids analysis described in Condition 13 are to be used in the actual emissions calculations. c. Flare is shared with adjacent facility covered under permit 14WE1075. All emissions from each separate facility are accounted for under their individual permits. Point 003: Water/O0Component Gas Service Heavy Oil Light Oil Service Connectors 0 0 681 0 Flanges 0 0 102 0 Open-ended Lines 0 0 17 0 Pump Seals 0 0 0 0 Valves 0 0 218 0 Other" 0 0 2 0 VOC Content(wt. 0 0 100 0 fraction) Benzene Content(wt. 0 0 8.3E-2 0 fraction) Toluene Content(wt. 0 0 0.02 0 fraction) Ethylbenzene(wt. 0 0 0.001 0 fraction) Xylenes Content(Wt. 0 0 3.0E-3 0 fraction) n-hexane Content(wt. 0 0 0.797 0 fraction) 'Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 AIRS ID: 123/9758 Page 8 of 9 ONEOK Bakken Pipeline, LLC Colorado Department of Public Health and Environment Air Pollution Control Division Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA-453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas and liquids analyses. 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 PSD Minor Source MACT HH Area Source Requirements: Not Applicable NSPS KKK Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX AIRS ID: 123/9758 Page 9 of 9 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: ONEOK Bakken Pipeline, LLC Permit Number 12WE1404 Source Location: SWSW,S3,T10N, R63W,Weld County Equipment Description: Maintenance operations (blowdowns,filter changes) AIRS ID: 123-9758-001 Date: 10/03/2014 Review Engineer: Stuart Siffring Control Engineer: Stefanie Rucker Section 2—Action Completed Grandfathered X Modification APEN Required/Permit Exempt X CP2 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? 8/06/2014 Section 4—Source Description AIRS Point Equipment Description 001 Maintenance blowdowns Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria Yes X No pollutant? If"yes", for what pollutant? PM10 CO 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 PM,() 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 Yes No of Regulation 7, Sections XII and XVII.C may apply) Page 1 Section 5-Emission Estimate Information AIRS Point Emission Factor Source Mass Balance: Inlet Filter 1(-10%Cloth) 11.09pB Inlet Filter 2(-10%Cloth) 11.09pB Inlet Filter 3(-10%Cloth) 11.09pB Meter Skid Blowdowns 19.66pB 001 E.F.(lb VOC/event)=Volume of emissions(bbl/event) 'liquid density(lb/bbl)*%VOC (fractional) Where p= Liquid Density(lb/bbl) B=%VOC(fractional) For the purpose of the emission factors included in this permit, B = 1.0 and p= 188.92 lb/bbl Mass Balance: Pig Receiver Section 1 1.12p6 Pig Receiver Section 2 1.53pB E.F.(lb VOC/event) =Volume of emissions(bbl/event) *liquid density(lb/bbl) *%VOC (fractional) l Where p=Liquid Density(lb/bbl) B =%VOC (fractional) For the purpose of the emission factors included in this permit, B= 1.0 and p= 188.92 lb/bbl Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit(Mt AIRS Point Process Consumption/Throughput/Production 001 3,514.8 bbl/yr of NGL vented Basis for Permitted Emissions(Permit LimitsI AIRS Point Process Consumption/Throughput/Production 001 3,514.8 bbl/yr of NGL vented Does this source use a control device? X Yes, Flare No Section 6—Emission Summary(tons peryear) Point NO. VOC CO Single HAP Total HAP PTE: 001 — 332.0 -- 2.8(n-Hexane) 4.0 Uncontrolled 001 — 332.0 — 2.8(n-Hexane) 4.0 Controlled 001 0.2 16.6 0.4 0.03(n-Hexane) 0.03 Section 7—Non-Criteria/Hazardous Air Pollutants Point 001 Page 2 Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions Ib/ r (Ib/yr) reportable? Rate( Y) Benzene 71432 A 568 Yes 28 n-Hexane 110543 C 5488 Yes 274 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? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method Section 9—Source Classification Is this a new previously un-permitted source? Yes x No What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V PSD NA NSR MACT Is this a modification to an existing permit? x Yes No If"yes"what kind of modification? Minor X 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? VOC, new syn minor permit limits 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, 001 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 001 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. 001 each individual emission point in an attainment area with uncontrolled actual emissions of two tons per year or more of any individual criteria pollutant(pollutants are not summed)for which the area is nonattainment. (Applicant is required to file an APEN since emissions exceed 2 tons per year VOC) Part B—Construction Permit Exemptions 001 Applicant is required to file a permit since requested uncontrolled VOC emissions are greater than the 5.0 TPY threshold(Reg.3, Part B, Section ILD.2.a) Regulation 6-New Source Performance Standards 001 None Regulation 7—Volatile Ordanic Compounds 001 XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... Regulation 8—Hazardous Air Pollutants 001 None Section 13—Aerometric Information Retrieval System Coding Information Emission Pollutant/ Fugitive Control Point Process Process Description Emission Factor CAS# (Y/N) Factor (%) Source 188.92lblbbl VOC No Site 95°h throughput Specific 01 Maintenance Blowdown 0.138 Ib/MMbtu N0x No TNRCC 0 001 0.2755 lb/MMbtu CO No TNRCC 0 SCC 306004002—blowdown system w/o control Section 14—Miscellaneous Application Notes Modification of the permit to allow the flexibility to control emissions using an onsite flare. Site is co-located with an OPPL permit 14WE1075, and is considered a single source for aggregation purposes. NOx and CO emissions were calculated by assuming the flare pilot uses 2500 btu/scf propane for its fuel at 65 scf/hr.At 8760 hours/year this is 1427.9 MMbtu/year. A permit will be issued because the requested uncontrolled VOC emissions at the facility are greater than 5 TPY(permit threshold;APEN threshold >2 TPY for attainment areas). This source is for a meter station that is connected to pipelines that only are transferring natural gas liquid product(mostly hydrocarbons)to other companies to sell. There is no contact with the hydrocarbons between points of transfer. Pigs are launched throughout these pipes to maintain clean pipes. Pig launchers and receivers are located at the junctions of these pipeline systems. Page 4 O U y6. 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