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1.02 Application
BURIED PIPING EXCEPTION REPORT FORM BU: Operation Center: General Information Location: Well -site ID: Line Description: This Report is ❑ New 0 Revised Inspection Data Flow Gathering Well -site Plant State County Month Day Year Feet Excavated Are Multiple Lines Exposed ❑ Yes 0 No Soil Condition ❑ Crumbly ❑ Sandy 0 Rocky ❑ Clay ❑ Dry ❑ Wet Coating Condition 0 No Visible Damage ❑ Poorly Bonded U MechanicalDamage ❑ Visible discoloration 0 Damage ❑ Soil / Air Interface Insulation Condition ❑ No Insulation ❑ Insulation / Jacketing Intact and Sealed ❑ Mechanical Damage Pipe Condition If Not Coated or Coating Damaged/Re moved ❑ No External Corrosion ❑ No Exceptions Noted ❑ Pipe was not exposed or coating is well bonded ❑ Visible Leaks ❑ ❑ Minor Pitting 0 Clamps Visible Misalignment Or Bending Extensive Pitting 0 Existing Pipe Casing Condition {If A linable ❑ No External Corrosion ❑ No Casing in Place ❑ Visible Leaks ❑ 0 Minor Pitting U Visible Misalignment or bending Extensive Pitting General Information C}ther Inspection Findings, Remarks: (Attach Field Sketch) Prepared by (Signature) (Title) Date `nxylspcc pladaxy spcc\axy rmat spcc,dac Page 28 EXTERNAL INSPECTION CHECKLIST FOR PROCESS PIPING Leaks Process Steam/Heat Tracing Existing Clamps/Sleeves 2. Misalignment Piping Misalignment/Restricted Movement Expansion Joint Misalignment 3. Vibration Excessive Overhung Weight Inadequate Support Thin, Small -Bore, or Alloy Piping Threaded Connections Loose Supports Causing Metal Wear 4. Supports Shoes Off Support Hanger Distortion or Breakage Bottomed -Out Spring Brace Distortion/Breakage Loose Brackets Slide Plates/Rollers Counter -Balance Condition Support Corrosion 5. Corrosion Bolting Support Points Under Clamps Coating/Painting Deterioration Soil -to -Air Interfaces Insulation Interfaces Biological Growth Corrosion Under TML Ports Insulation Damage/Penetrations Missing Jacketing/Insulation Sealing Deterioration Bulging Banding (broken or missing) TML Ports (missing plugs/cover tape) p1pw j tsbxylspcc plan Oxy spcc'oxy mat spec dnc Page 29 • • • PERSONNEL TRAINING/DISCHARGE PREVENTION BRIEFING LOG TOPIC(S): (Note: Required topics must include SPCC Plan.) SIGN IN SHEET NAME (PLEASE PRINT) COMPANYIPOSITION TELEPHONE 1. 2. 3. 4. 5. 6. 7. 8. 9 10, 11. 12. Instructor. Subjectllssue Identified Date: Required Action Implementation Date: p.lprojects'oxy\spoc planbxy spec oxy meat spa dux Page 30 • • • CONTAINER/CONTAINMENT EXAMINATION LOG DRAINAGE EVENT LOG Examiner: Examination Frequency: Date: (Retain record three (3) years.) Container/ Containment Comments Drainage Event (Vol.) Check containers for:. • Leaks, drip marks and discoloration puddles containing spilled or leaked material • Corrosion • Cracks • Localized dead vegetation Check foundation for: • Cracks • Cis col oration • puddles containing spilled or leaked material • Settling • Gaps between tank and foundation • Damage caused by vegetation roots Check piping for: • Droplets of stored material • Discoloration • Corrosion • Bowing of pipe between supports • Evidence of stored material seepage from valves or seals • Localized dead vegetation Check containment for: • Cracks • Discoloration • Presence of spilled material • Corrosion (if applicable) • Erosion (if applicable) • Valve conditions (if applicable) Record drainage event: • Appearance of stormwater discharged • Volume of water and volume or oil, if any removed discharged • Other details (i.e. testing) p:*rojects'oxy''apee plaa nxy spceoxy mot we.doc Page 31 • • POLLUTION PREVENTION EQUIPMENT AND YSTEMS LOG Pollution Prevention Equipment: INSPECTION/ TEST DATE CONDITION ACTION TAKE SUPERVISOR OR INSPECTOR'S SIGNATURE I p--: projectskoxy\sinc plariwxy spccbxy rmat spu:. doc Page 32 • • • APPENDIX C SITE-SPECIFIC INFORMATION FOR EAC SITE CONTAINER TABLE POTENTIAL SPILLS TABLE FACILITY DIAGRAM(S) WITH FLOW DIRECTION SECONDARY CONTAINMENT CALCULATIONS 40 CFR PART 112 — APPENDIX C - Substantial H SITE IN THIS PLAN: arm Certification p;tiprojectsbxyspcc plan o y spec xy rmai spot. doc Page 33 • Site Identifier SITE CONTAINER Tank 1 Volume 300 barrels TABLE Contents Condensate Tank 2 Volume NA Contents CC 617-24 CC 620-24-43 300 barrels Condensate 95 barrels Water CC 705-22-43 300 barrels Condensate 95 barrels Water CC 604-11 400 barrels ' Condensate NA CC 608-41 400 barrels Condensate NA CC 609-2 400 barrels Condensate NA CC 609-14 300 barrels Condensate NA CC 610-22-43 400 barrels Condensate NA CC 616-21-32 400 barrels Condensate NA CC 697-15-54 400 barrels Condensate NA CC 617-41 400 barrels Condensate NA CC 604-12-13 400 barrels Condensate NA CC 708-1 i 300 barrels Condensate 95 barrels Water CC 632-21-41 300 barrels Condensate NA CC 697-15-01 400 barrels Condensate NA CC 697-05-36 300 barrels Condensate 95 barrels Water CC 627-02 300 barrels Condensate NA Gas Plant Drain Tank 400 barrels Condensate NA Gas Plant Water Makeup 400 barrels Condensate NA Compressor Building Four lube oil tanks (a, 250 gallons each Generator Building Two lube oil tanks (i 272 gallons each p VrQj lspcc plan+nxy spec'oxy num spec. doc Page 34 CC 604-12-13 CC 617-41 CC 609-2 Site Indentifier CC 617-24 CC 620-24-43 CC 705-22.43 CC 604-11 CC 608-41 CC 609-14 CC 610-22-43 Type of Volume, Rate Flow Direction Containment Failure gallons (gallonihr) (gallons) 2.600 12,600 On facility diagram 13,789 ank rupture Tank rupture Tank rupture Tank rupture Tank rupture Tank rupture CC 616-21-32 CC 697-15-54 CC 708-1 CC 632-21-4 CC 697-15-01 CC 697-05-36 CC 627-02 Gas Plant Drain Tank Gas Plant Makeup Tan Compressor Building Generator Building Tank rupture Tank rupture 12,600 12,600 16,800 12,600 On facility diagram 12,600 On facility diagram 31,205 24,820 16,800 16,800 6,800 12,600 16,800 16,800 16.800 On facility diagram 31,712 On facility diagram 21,100 On facility diagram 18,102 12,600 16,800 On facility diagram 18,408 Tank rupture Tank rupture Tank rupture Tank rupture Tank rupture Tank rupture Tank ruptur Tank rupture Tank rupture 16.800 6,800 16,800 16,800 12,600 2,600 16,800 12,600 12,600 16,800 16,800 16,800 16,800 12,600 12,600 16.800 12,600 12.600 On facility diagram 28,053 On facility diagram. 22,852 On facility diagram _ 19,857 On facility diagram 16,486 On facility diagram _ 16,715 On facility diagram 18,448 Tank rupture Tank rupture Tank rupture Tank rupture p''projects 'oxy\spec plon'axy spccloxy mat spec doc 16,800 16,800 250 16,800 16,800 250 On facility diagram 13,470 On facility diagram On facility diagram On facility diagram 35,546 14,104 13,614 On facility diagram 16,435 On facility diagram 272 272 On facility diagram On facility diagram 17,851 10,261 13,260 Page 35 ION • • CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 617-24 Tank Berm Location: Sec. 7 T7S R97W Capacity (Bbls) Capacity (Gal) Tank Diameter (ft) Tank Height (ft) Displacement (Ga11ft) TANK INFORMATIO Tank 1 (Largest) Tank 2 300 NA 12600 12 15 NA Required Freeboard FREEBOARD INFORMAT 3 Inches NA NA NA NA Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Width 29 Length 56 Height (lowest point on bean) 1.5 Interior Slope Ratio (wlh) 1:1 See drawing below CONTAINMENT VOLUME Gross Volume (ft) 2249.25 Volume (Bbls) 400.61 Volume (Gal) 16825.56 Tank Displacement NA NA NA TEST Net Containment < OR > Tank 1 Capacity 328.30 (Bbls) > 300 (Bbls) Containment is Sufficient Freeboard 406 71.31 3037.09 Net 1843.27 328.30 13788.6 p:5prejtas'oxy\spcc plan\oxy spec'kaxy rural spot. doe Page 36 FREEBOARD INFORMATION CONTAINMENT CAPACITY C • LCULATIONS Facility Name: Cascade Creek 620-24 43 Tank Berm Location: SE/SW Sec. 20 T6S R97W Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) TANK INFORMATION 54 Length 1 Tank 1 (Largest) Tank 2 Capacity (Bbls) 300 95 Capacity (Gal) 12600 3990 Tank Diameter (ft) 12 12 Tank Height (ft) 15 4.7 Displacement (Gal/ft) NA 846 Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Width 1 54 Length 1 62.8 Height (lowest point on berm) 1.6 Interior Slope Ratio (wih) 1:1 S e drawing below CONTAINMENT VOLUME Net Containment Gross Tank D s lacement Freeboard Net Volume (ft') 5019.28 113.10 847.80 4171.46 Volume (Bbls) 893.97 20.14 151.00 742.97 Volume (Gal) 37546.79 846.05 6341.98 31204.74 TEST Net Containment < OR > Tank 1 Capacity 742.97 (Bbls) > 300 (Bbls) Containment is Sufficient p Iprojeclsbxylspcc pla&oxy spccloxy mat spec.dx Page 37 CONTAINMENT CAPACITY C • LCULATIONS Facility Name: Cascade Creek 705-22 3 Tank Berm Location: NE/NW Sec. 32 T6S R97W TANK INFORMATIO1S width i 32 Tank 1 (Largest) Tank 2 Capacity (Bbls) 300 95 Capacity (Gal) 12600 3990 Tank Diameter (ft) 12 12 Tank Height (ft) 15 4.7 Displacement (Gal/fl) NA 846 Required. Freeboard FREEBOARD INFORMATION Based on 100 year, 24 hour maximum reci s itation 3 Inches CONTAINMENT INFORMATION (ft) width i 32 Width 2 55.6 Length 1 58 Height (lowest point on berm) 1.9 Interior Slope Ratio (w/h) 1:1 See drawing below CONTAINMENT VOLUME Net Containment Gross Tank Displacement Freeboard Net - Volume (13) 3781.95 113.10 464.00 3317.94 Volume (Bbls) 673.59 20.14 82.64 590.95 Volume (Gal) 28290.93 846.05 3470.96 24819.9 TEST Net Containment < OR > Tank 1 Capacity 590.95 (Bbls) > 300 (Bbls) Containment is Sufficient p Vprojetts'axylspce plantioxy spccloxy mat spoc.doc Page 38 FREEBOARD INFORMA' ION • • CONTAINMENT CAPACITY C LCILATIONS Facility Name: Cascade Creek 604-11 ank Berm Location: NW/NW Sec.4 T6S R97W TANK INFORMATIO ' 36.9 Tank 1 Tank 2 Capacity (Bbls) 400 NA Capacity (Gal) - 16800 NA Tank Diameter (ft) 12 NA Tank Height (ft) 20 NA Displacement (Galift) NA NA Required Freeboard CONTAINMENT INFORMATION (ft) Width 36.9 Length 62.8 Height (lowest point on berm) 2.3 Interior Slope Ratio (w/h) 1:1 r, 24 maximum precipitation S e drawing below CONTAINMENT VOLUME Net Containment < OR > Gross Tank Displacement Freeboard 400 Net Volume (ft3) 4818.65 NA 579.33 4239.26 Volume (Bbls) 858.24 NA 103.18 755.05 Volume (Gal) 36045.97 NA 4333.69 31712.10 TEST Net Containment < OR > Tank 1 Ca acity° J 755.05 > 400 Containment is Sufficient p:lprojectsbxyspcc plank ry spcc\axy mist spcc.doc CONTAINMENT CAPACITY C LCULATIONS Facility Name: Cascade Creek 608-41 ank Berm Location: TANK INFORMATION Width 57.2 Tank 1 Tank 2 Capacity (Bbls) 400 NA Capacity (Gal) 16800 NA Tank Diameter (ft) 12 NA Tank Height (ft) 20 NA Displacement (Gal/ft) NA NA FREEBOARD INFORMATION Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Width 57.2 Length 35.1 Height (lowest point on berm) 1.8 Interior Slope Ratio (w/h) 1:1 See drawing below CONTAINMENT VOLUME _ Net Containment Gross Tank Displacement Freeboard Net Volume 03) 3322.62 NA 501.93 2820.69 Volume (Bbls) 591.78 NA 89.40 502.39 Volume (Gal) 24854.92 NA 3754.70 21100.38 TEST Net Containment < OR > Tank 1 Capacity 502.39 (Bbls) > 400 (Bbls) Containment is Sufficient p 1projtctcbxylspcc plankoxy spccloxy meat spcc.cbc Page 40 CONTAINMENT CAPACITY C LCULATIONS Facility Name: Cascade Creek 609-2 Tank Berm Location: SE/SW Sec.9 T6S R97W Capacity (Bbls) Capacity (Gal) Tank Diameter (ft) Tank Height (ft) Displacement (Gal/ft) TANK INFORMATION Tank 1 400 16800 12 20 NA NA Tank 2 NA NA NA NA FREEBOARD INFORMATION Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Width 35.5 Length 48.8 Height (lowest point on berm) 1.8 1:1 Interior Slope Ratio (w/h) See drawing below CONTAINMENT VOLUME Gross Tank Dis ► lacement Net Volume (Bbls) Volume (Gal) 21341.65 NA TEST Net Containment < OR > Tank 1 Capacity 431.00 (Bbls) > 400 (Bbls) Containment is Sufficient p 1projectsbxylspcc plan'axy spceoxy mat spcc.cloc Page 41 • • • CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 609-14 Tank Berm Location: SW/SW Sec.9 T6S R97W TANK INFORMATION Capacity (Bbls) Capacity (Gal) Tank Diameter (ft) Tank 1 300 12600 Tank Height (ft) Displacement (Gal/ft) 12 15 NA Tank 2 NA NA NA NA NA FREEBOARD INFORMATION Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Width 43.5 Length 49 Height (lowest point on berm) Interior Slope Ratio (wfh) 1.5 1:1 See drawing below CONTAINMENT VOLUME Gross Volume (ft3) 2993.63 Tank Displacement NA Freeboard Net 532.88 Volume (Bbls) Volume (Gal) 533.19 NA 94.91 22393.87 NA 3986.18 TEST Net Containment < OR > I -Tank 1 Ca acity 300 (Bbls) 438.28 (BbIs) Containment is Sufficient p:\prajectsbxy',spcc plan'.oxy spctdxy rmat spa. doe 2460.74 438.28 18407.76 Page 42 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 610-22-43 Tank Berm Location: SE/NW Sec.1O T6S R97W Capacity (Bbls) Capacity (Gal) Tank Diameter (ft) Tank Height (ft) TANK INFORMATIO Tank 1 Tank 2 400 NA 16800 NA 12 NA 20 Displacement (Gal/ft) NA NA NA Required Freeboard FREEBOARD INFORMA 3 Inches Based on 100 ye CONTAINMENT INFORMATION (ft) Width 43.8 Length 49 Height (lowest point on berm) 2.2 Interior Slope Ratio (w/h) 1:1 ION 24 maximum precipitation See drawing below CONTAINMENT VOLU Gross Tank Dis • lacement Freeboard Net TEST Net Containment < OR > Tank 1 Capacity 667.93 (Bbls) > 400 (Bbls) Containment is Sufficient P 1profects‘oxy%spcc planoxy spcc'bry mvat spcc doc Page 43 • • Volume (ft ) Volume (Bbls) CONTAINMENT CAPACITY CALCULATIQNS Facility Name: Cascade Creek 616-21-32 Tank Berm Location: NE/NW Sec. 16 T6S R97W Capacity (Bbls) Capacity (Gal TANK INFORMATION 400 Tank Diameter (ft) Tank Height (ft) Displacement (Gal/ft) 16800 12 20 NA NA NA NA NA FREEBOARD INFORMATION Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Width 32.6 Length 57 Height (lowest point on berm) 2.1 Interior Slope Ratio (w/h) 1:1 See drawing below CONTAINMENT VOLUME Gross Tank Dis i lacement Freeboard Net 3519.43 626.84 Volume (Gal) 26327.18 NA NA NA TEST Net Containment < OR Containment is Sufficient 464.55 82.74 3475.08 3054.87 544.10 22852.20 p: \pmjects'oxylspcc plankoxy spccbxy mtat spec. dot Page 44 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 697-15-54 Tank Berm Location: SW/SE Sec. 15 T6S R97W Capacity (Bbls) Capacity (Gal) TANK INFORMATION Tank 1 400 Tank 2 NA Tank Diameter (ft) Tank Height (ft) Displacement (Gal/ft) 12 16800 20 NA NA NA NA NA FREEBOARD INFORMATION Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Width 31.2 Length 60.9 Height (lowest point on berm) 1.8 Interior Slope Ratio (w/h) 1:1 See drawing below CONTAINMENT VOLUME FNet Containment Gross Tank Displacement Freeboard Net - Volume (fly) 3129.52 NA 475.02 2654.50 Volume (Bbls) 557.39 NA 84.60 472.79 Volume (Gal) 23410.40 NA 3553.40 19857.18 TEST FNet Containment < OR > Tank 1 Capacity 472.79 (Bbls) > 400 (Bbls) — Containment is Sufficient p:''proycets`oxylspcc plan47xy spceoxy rrnas spa. dac Page 45 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 617-41 Tank Berm Location: NE/NE Sec,17 T6S R97W Capacity (Bbls) TANK INFORMATIOIN Tank 1 Capacity (Gal) Tank Diameter (ft) Tank Hei_ht (ft) 400 16800 12 20 Tank 2 NA NA NA NA NA FREEBOARD INFORMA ION Required Freeboard 3 Inches Based on 100 ye: r, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Width 4L5 Length 46.2 Height (lowest point on berm) 1.5 Interior Slope Ratio (win) 1:1 ee drawing below Volume (ft ) Volume Bbls CONTAINMENT VOL ME reeboard Gross 2683 13 Volume (Gal) 477.88 Tank Dis lacement 20071.17 NA NA NA TEST Net Containment < OR > Tank 1 Capacity . 392.51 400 Containment is Sufficient p:\prooectsaxylspcc plan',oxy spccbxy anal spcc.doc 479.33 85.37 3585.6 Net 2203.: 392.51 16485.57 CONTAINMENT CAPACITY C • LCULATIONS Facility Name: Cascade Creek 604-12 13 Tank Berm Location: NW/NW Sec.4 T6S R97W Capacity (Bbls) Capacity (Gal) Tank Diameter (ft) Tank Height (ft) Displacement (Gallft) TANK IN FORMATIO Tank 1 400 16800 12 20 Tank 2 NA NA NA NA NA NA Required Freeboard FREEBOARD INFORMATION 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Width 31 Length 55.1 Height (lowest point on berm) Interior Slope Ratio (wlh) 1.7 1:1 See drawing below Volume (ft ) Volume (Bbls) Volume (Gal) CONTAINMENT VOLL ME Gross 2661.49 474.0 19909.34 Tank Displacement NA NA Freeboard NA TEST Net Containment <OR> 398 Tank 1 Capacity 400 Containment is Sufficient p t€irojects'nxy'spee *realty spcc'uvy meat spot dot 427.03 76.06 Net 2234.46 397.98 3194.03 16715.31 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Federal 708-11 Tank Berm Location: Capacity (Bbls) Capacity (Gal) Tank Diameter (ft) Tank Height (ft) Displacement (Gal/ft) 12 Tank TANK INFORMATION 300 12600 15 NA 3990 Tank 2 95 12 4.7 846 FREEBOARD INFORMATION Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation. CONTAINMENT INFORMATION (ft) - Width 29.5 Length 65 Height (lowest point on berm) 1.8 Interior Slope Ratio (wfh) 1:1 See drawing below Volume (ft ) Volume (Bbls) Volume (Gal CONTAINMENT VOLUME Gross 3153.1 561.59 23586.79 Tank Dis I lacement 203.56 36.26 1522.8 Containment is Sufficient pAprojecteoxylsptt plamoxy $pcctiaxy rmat spec. doc Freeboard 479.38 85.38 3585.97 Net 2466.14 439.95 18448.02 • • CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 632-21-41 Tank Berm Location: Capacity (Bbls) Capacity (Gal) Tank Diameter (ft) Tank Height (ft) Displacement (Gal/f3) Tank 1 TANK INFORMATION 300 12600 12 15 NA Tank 2 95 3990 12 4.7 846 Required Freeboard FREEBOARD INFORMATION 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Width 25.5 Length 50 Height (lowest point on berm) 2.1 Interior Slope Ratio (w/h) 1:1 See drawing below Volume (ft ) CONTAINMENT VOLUME Gross 2356.98 Volume (Bbls) Volume (Gal) 419.78 17630.78 Tank Dis i lacemeat 237.49 42.3 1776.6 Freeboard 318.75 56.77 2384.42 Net 1800.71 319.93 13470.24 p'projects&oxy'ispcc plan'ury spec nxy meat spec doc Page 49 • • TEST Net Containment < OR 320 Tank I Ca acity 300 Containment is Sufficient p:`prolema,oxySc planbxy spcctaxy meal spcc. dor Page 50 ION • • • CONTAINMENT CAPACITY C • LCULATIONS Facility Name: Gas Plant Water Make p TANK INFORMATION Radius 14 Tank 1 Tank 2 Capacity (Bbls) 400 NA Capacity (Gal) 16800 NA Tank Diameter (ft) 12 NA Tank Height (ft) 20 NA Displacement (Gal/ft) 845 NA FREEBOARD INFORMAT Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Radius 14 Length 37 Height 3 Interior Slope Ratio (w/h) . 0 See drawing below CONTAINMENT VOLUME Tank Displacement _ Tank 1 Capacity Gross Freeboard Net Volume (ft3) 2603.3 NA 216.9 2386.4 Volume (Bbls) 464 NA 38.6 425.4 Volume (Gal) 19473.7 NA 1622.8 17850.9 ' TEST Net Containment < OR > Tank 1 Capacity 425.4 (Bbls) > 400 (Bbls) Containment is Sufficient p -V oject*)j' c plan'wxy spcc'Wxy maat spot.doe Page 51 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Gas Plant Drain Tank Capacity (Bbls) Capacity (Gal) Tank Diameter (ft) Tank Height (ft) Displacement (Gai/ft) 2 Tank 1 TANK INFORMATION 400 16800 20 845 Tank 2 NA NA NA NA NA FREEBOARD INFORMATION Required Freeboard Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Diameter < OR > 30 Height ... 3 Interior Sloe Ratio wlh 0 Concave containment bottom surveyed for volume calculation. CONTAINMENT VOLUME Gross Volume (ft) 2373.73 Volume (Bbls) 422.77 Volume (Gal Tank Displacement NA 17756.7 NA NA Freeboard 176.7 Net 2197.03 26.4 396.37 TEST Net Containment < OR > Tank 1 Capacity 396.4(Bbls) ... 400 (Bbls) Sufficient 1321.9 16434.83 h plprojectsbxylspcc pladuxy spccloxy meat spa doc CONTAINMENT CAPACITY CC LCULATIONS Facility Name: Cascade Creek 797-05- 6 Tank Berm Location: SE/SW Sec. 5 T7S R97W TANK INFORMATION Capacity (Bbls) Capacity (Gal) Tank 1 (Largest) 300 Tank 2 2600 95 3990 Tank Diameter (ft) Tank Height (ft) 12 12 15 4.7 Displacement (Gailft) 845 845 FREEBOARD INFORMATION Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft Width 1 31.6 Width 2 48.7 Length 1 54 Height (lowest point on berm) 1.3 Interior Slope Ratio (w/h) 1:1 See drawing below CONTAINMENT VOLUME Gross Tank Freeboard Displacement Volume (ft3) 2425.19 113.1 426.6 Net 1885.48 Volume (Bois) Volume (Gal) 431.94 18141.66 20.14 846.05 75.98 3191.19 335.8 14104.42 TEST Net Containnien <OR> Tank 1 Capacity 335.8 (Bbls) Sufficient 300 (Bbls) p Yro]etts'ox) Pcl aM'O%j' spcac%}' rmal SPCC.doe Page 53 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 627-02 Tank Berm Location: SE/SW Sec. 20 T6S R97W Capacity (Bbls) Capacity (Gal) Tank Diameter (ft) Tank Height (ft) Displacement (Gal It) TANK INFORMATION Tank 1 Tank 2 300 12600 12 15 NA NA NA NA NA NA FREEBOARD INFORMATION Required Freeboard 3 Inches I Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Width 31 Length 48.2 Height (lowest point on berm) Interior Slope Ratio (w/h) 1.6 1:1 Volume (ft ) Volume (Bbls) Volume (Gal) See drawing below CONTAINMENT VOLUME Gross 2193.43 390.67 16407.99 NA Tank Displacement NA NA Freeboard TEST Net Containment < OR 324.13 (Bbls) Tank 1 Capacity 300 (Bbls) Containment is Sufficient p'projecOoxy,spcc pi art.oxy spcc acy rias spcc.doc 373.55 2794.35 66.53 Net 1819.88 24.13 13613.65 Page 54 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 697-15-01 Tank Berm Location: TANK INFORMATION Capacity (Bbls) Capacity (Gal) Tank Diameter (ft) Tank Height (ft) _ Tank 400 Tank 2 NA Displacement (Gal/ft) 16800 12 20 NA NA NA NA FREEBOARD INFORMATION Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORMATION (ft) Width 42.5 Length 52 Height (lowest point on berm) Interior Slope Ratio (w/h) 2.7 1:l See drawing below CONTAINMENT VOLUME Volume ( ) Volume (Bois) Volume (Gal) Gross 5304.34 944.74 Tank Displacement NA NA Freeboard 552 98.4 39679.21 NA 4132.99 TEST Net Containment < DR > Tank 1 Capacity 846.3 400 Containment is Sufficient 846.34 35546.22 P `Prof Foxy3spcc planloxy spcC''oxy rural spcs:. doe Page 55 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Gas Plant Generator Building Location: TANK INFORMATION Capacity (Bbls) Capacity (Gal) Tank Diameter (ft) Tank Height (ft) Tank 1 6.47 271.9 2.25 Tank 2 6.47 271.9 2.25 Displacement (Gal/ft) 3.65 5.1 3.65 5.1 NA NA FREEBOARD INFORMATION Required Freeboard 3 Inches _ Based on 100 year, 24 maximum precipitation H CONTAINMENT INFORMATION (ft) Width 90 Length 96 Height (lowest point on berm) Interior Slope Ratio (w/h) 0.5 1:1 Rectangular soil berm around perimeter of building. See drawing below CONTAINMENT VOLUME Volume (ft') Gross 4320 Tank Freeboard Displacement NA 3110.4 Volume (Bbls) Volume (Gal 769.42 NA NA Net 4320 32315.84 NA TEST Net Containmen <OR> 32,316 (Gal) a Tank 1 Ca acity 271.9 (Gal) Containment is Sufficient NA 769.42 32315.84 pl,rojettsuoWspcc pban•oxy spceoxy rmat spci.doc Page 56 • • • CONTAINMENT CAPACITY CALCULATIONS Facility Name: Gas Plant Compressor Building Location: Capacity (Bbls) Capacity (Gal) TANK INFORMATIOI Tank 1 Tank 2 Tank 3 Tank 4 6 6 6 6 Tank Diameter (ft) Tank Length (ft) Displacement (Gal/ft) 250 3 250 3 250 3 250 3.3 NA NA 4 NA 4 NA FREEBOARDS INFORMATION Tanks inside building; freeboard not required CONTAINMENT INFORMATION (f� Width 43.3 Length 198.3 Height (concrete lip on building) 0.2 Interior Slope Ratio (wlh) Building serves as a containment with 0.2 foot lip providing the lowest point of containment. Volume (ft ) CONTAINMENT VOLUME Gross 1371.7 Volume (Bbis) Volume (Gal) 244 10261.4 Tank Dis + lacement Freeboard Net TEST Net Containment < OR > Tank I Capacity 10261.4 (Gal) > 250 (Gal) Containment is Sufficient p Iprojectsloxylspcc plan\o y spccbxv m.vt spcc.doc Page 57 • • CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 609-33 Location: NW SE S9 T6S R97W TANK INFORMATION Capacity (Bbls) Capacity (Gal) Tank Diameter (ft) Tank Height (ft) Displacement (Gal/ft) Tank 1 400 16.800 12 20 N/A Tank 2 N/A N/A N/A N/A N/A FREEBOARD INFORMATION Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORAMTION (ft) Width Length Height (lowest point on berm) Interior Slope Ratio (will) 35 45 1.6 1:1 Volume (ft ) Volume (ibis) CONTAINMENT VOL C. Toss 2730.26 486.28 Volume (Gal) 20423.77 Tank Dis iacement N/A N/A N/A See drawing below ME Freeboard 393.75 70.13 2945.45 Net Net Containment 416.15 TEST < OR > Tank I Capacity 400 Containment is Sufficient Environmental Scientists and Engineers, LLC 2336.67 416.15 17478 p:Vrojectsbxylspce plmiaxy spec'oxy rmv spcc.doc Page 58 CONTAINMENTS CITY CALCULATIONS Facility Name: Cascade Creek 609-2 Location: SE/SW 59 T6S R97W Ca•acity (Bbis) Capacity (Gal) Tank Diameter (ft) Tank Height (ft) Displacement (Gal/ft) TANK INFORMATION Tank 1 Tank 2 400 16,800 12 20 N/A N/A N/A N/A N/A N/A FREEBOARD INFORMATION Reg1uir'ed Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORAMTION (ftp_ Width Length Height (lowest point on berm) Interior Slope Ratio (rv/h) Volume (ft ) Volume (Bbls) Volume (Gal) 30 47 2.1 1:1 See drawing below CONTAINMENT VOLUME Gross 3312.92 590.06 24782.35 N/A N/A Tank Dis s lacement N/A Freeboard 352.50 Net 2960.61 62.78 2636.88 527.27 22145.34 Containment is Sufficient •=--t .1 =Walsh Environmental Scientists and Engineers, LLC p' \prnjecg'oxy'spcs plaeoxy spceoxy mat Spec.doc Page 59 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 608-43 Location: NE/SW S8 T6S R97W 31 Capacity (Bbls) Capacity (Gal) TANK INFORMATION Tank Diameter ( Tank Height (ft) Displacement (Gal/ft) 16,800 Tank 1 400 12 20 N/A Tank 2 NIA N/A N/A N/A N/A FREEBOARD INFORMATION Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORAMTION (ft) Width 41 Length 43 Height (lowest point on berm) 1.8 Interior Slope Ratio (wilt) 1:1 Volume (ft ) S drawing below CONTAINMENT VOLUME Gross 3453.34 Volume (Bbls) Volume (Gal) 615.07 Tank Dis • lacement N/A 25832.75 N/A N/A Freeboard 440.75 78.50 Net 3012.77 536.56 TEST Net Containment < OR > Tank 1 Capacity 536.56 > 400 Containment is Sufficient "1"1.11W Environmental Scientists and Engineers, LLC 3297.04 22535,52 p:Vrojects'oxy'spec ptsii' y spc6oxy lnW spcc.doc Page 60 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 605-2 Location: Capacity (Bbls) Capacity (Ga Tank Diameter (ft) Tank Height (ft) Displacement (Gal/ft) TANK INFORMATION Tank 1 400 16,800 12 20 N/A N/A N/A Tank 2 N/A N/A N/A FREEBOARD INFORMATION Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT 1NFORAMTION (ft) Width 62.4 Length 28.6 Height (lowest point on berm) 1.5 Interior Slope Ratio (wilt) 1:1 See drawing below Volume ( ) Volume (Bbls) 'glume (Gal) CONTAINMENT VOLUME Gross 2886.21 514.06 21590.35 Tank Diss lacement N/A N/A N/A TEST _ Net Containment < OR > Tank 1 Capacity 434.59 > 400 Containment is Sufficient Mumm "11W Environmental Scientists and Engineers, LLC Freeboard Net 446.16 2440.21 79.46 434.59 3337.51 18252.78 Page 61 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 605-1 Location: S5 T6S R97W TANK INFORMATION Tank 1 Tank 2 Capacity (Bbls) Capacity (Gal) 400 Tank Diameter (ft) 16,800 N/A N/A 12 N/A Tank Height (ft) 20 Displacement (Gal/ft) I N/A N/A N/A FREEBOARD INFORMATION Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORAMTION (ft) Net Containment Width 35.6 458.32 Length 45.2 Containment is Sufficient Height (lowest point on berm) 1.7 1:1 a Interior Slope Ratio (w/h) See drawing below CONTAINMENT VOLUME Gross Tank Displacemen Freeboard Volume (ft') Volume (Bbls) Volume (Gal) 2975.57 529.97 N/A 402.28 Net 2573.45 N/A 71.65 458.32 22258.78 N/A TEST Net Containment < OR > Tank 1 Capacity 458.32 } 400 Containment is Sufficient MMin Environmental Scientists and Engineers, LLC 3009.26 19249.44 P brolec x plareoxy spccloxy mat spcc. Page 62 CONTAINMENT CAPACITY C •_LCULATIONS Facility Name: Cascade Creek 610-24-43 Location: TANK INFORMATIO Tank 1 Tank 2 Capacity (Bbls) 400 Capacity (Gal) Tank Diameter 16,800 N/A N/A (ft) Tank Height (ft) 12 20 N/A NIA Displacement (Gal ft) N/A N/A FREEBOARD INFORMA ION Required Freeboard 3 Inches Based on 100 ye• r, 24 maximum precipitation 1 CONTAINMENT INFORAMTION ft Width 40 Length 45.6 Height (lowest point on berm) 1.6 Interior Slope Ratio (w/h) 1:1 See drawing below CONTAINMENT VOLU E Gross Tank Displacement reeboard Volume (ft') 143.00 N/A 456.00 Net 2687.16 Volume (Bbls) 559.79 Volume (Gal) 23511.25 N/A N/A TEST Net Containment < OR > Tank I Capacity 478.57 > 400 Containment is Sufficient AL -L -Wath Environmental Scientists and Engineers, LLC 81.22 3411.12 478.57 20099.94 Page 63 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 697-08-53 Location: SW/SE S8 T6S R97W Capacity (Bbls) Capacity (Gal) TANK INFORMATION Tank 1 400 16,800 Tank Diameter (ft) Tank Height (ft) Displacement (Gal/ft) 12 20 Tank 2 N/A N/A N/A N/A N/A N/A FREEBOARD INFORMATION Required Freeboard 3 Inches Based on 100 year, 24 maximum precipitation CONTAINMENT INFORAMTION (ft) Width Length Height (lowest point on berm) Interior Slope Ratio (w/h) 40 42.7 1.7 1:1 See drawing below Volume (ft') Volume (Bbls) Volume (Gal) CONTAINMENT VOLUME F reeboa rd Gross 3149.15 560.89 23557.30 Tank Dis i lacement N/A N/A N/A TEST Net Containment 484.84 <OR> 400 Containment is Sufficient 111111 Environmental Scientists and Engineers, LLC ptprojects,asylspct planoxy spec oxy meat spec. doe 427.00 76.05 3194.18 NIA 272:1.36 484.84 203(3.28 Page 64 CONTAINMENT CAPACITY ALCULATIONS Facility Name: Cascade Creek 629-23-42 Location: TANK INFORMATION Tank I Tank 2 Capacity (Bbls) Capacity (Gal) 300 95 12,600 3990 Tank Diameter (ft) 12 Tank Height (ft) Displacement (Gal/ft) 20 12 4.7 N/A FREEBOARD INFORMATION 846 Required Freeboard 3 Inches Based on 100 year, 24 maximum precipii ation CONTAINMENT INFORAMTION (ft) Width Length Height (lowest point on berm) Interior Slope Ratio (w/h) 33.5 39.3 1.9 1:1 e drawing below Volume (ft3) Volume (Bbls) Volume (Gal) CONTAINMENT VOLU Cross 2558.513 455.6907 Tank Displacement 214.88 38.27 ME Freeboard 329.1375 58.62189 NA 19139.008 1607.45 TEST Net Containment < OR 397.07 Tank 1 Capacity 300 Containment is Sufficient Environmental Scientists and Engineers, LLC 2462.119 222' ).53 397.07 166'; 6.89 Page 65 • • CONTAINMENT CAPACITY CALCULATIONS Facility Name: Federal 797-08-51D Location: Capacity (Bbls) TANK INFORMATION Tank 1 300 Tank 2 95 Capacity (Gal) Tank Diameter (ft) Tank Height (ft) Displacement (Ga11ft) 12 12,600 15 N/A 3990 12 4.7 46 FREEBOARD INFORMATION Required Freeboard I 3 Inches Based on 100 ye r, 24 c a imum precipitation CONTAINMENT INFORAMTION (ft) Width Lengt Height (lowest point on berm) Interior Slope Ratio (w/h) Volume (ft 27.4 49.2 1.5 1:1 See drawing below CONTAINMENT VOLUME Gross 2029.324 Volume (Bbls) 361.428 Volume (Gal) 15180.397 Tank Displacement 169.65 Freeboard Net 30.22 1269.04 TEST Containment is Sufficient s Environmental Scientists and Engineers. LLC' 337.02 60.02582 2521.085 162'1.42 301.41 12659.31 Page 66 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Cascade Creek 797-05-36 Location: TANK INFORMATION Capacity (Bbls) Capacity (Gal) Tank 1 (Largest) 300 Tank 2 95 Tank Diameter (ft) Tank Height (ft) 12600 3990 12 12 15 4.7 Displacement (Gal/ft N/A 846 Required Freeboard FREEBOARD INFORMATION 3 Inches Based on 100 year, 24 maximum precipi. ation CONTAINMENT INFORAMTION (ft) Width 1 Width 2 Length 1 Length 2 Height (lowest point on berm) Interior Slope Ratio (w/h) 48 30 63.8 54.1 1.1 1:1 See drawing below CONTAINMENT VOLUME Gross Tank Displacement Freeboard Volume (ft') 3381.286 124A1 Volume (Bbls) Volume (Gal) 602.2326 22.16 25293.771 930.63 765.6 136.3592 Net 2615.85 46.` .87 TEST Net Containment < OR Tank 1 Capacity _ 465.87 (Bbls) a 300 (Bbls) Containment is Sufficient Environmental Scientists and Engineers. LLC Page 67 CONTAINMENT CAPACITY CALCULATIONS Facility Name: Federal 797-08-19D TANK INFORMATION Tank 1 (Largest) Tank 2 Capacity (Bbls) Capacity (Gal) 300 95 12600 3990 Tank Diameter (ft) Tank Height (ft) 12 12 15 4.7 Displacement (Gal/ft Location: 846 FREEBOARD INFORMATION Required Freeboard 3 inches Based on 100 year, 24 maximum precipil ation CONTAINMENT INFORAMTION (ft) Width 1 Width 2 Length 1 Length 2 Height (lowest point on berm) 1.2 Interior Slope Ratio (wlh) _ 1:1 See drawing below CONTAINMENT VOLL ME Gross Tank Displacement Freeboard Volume (ft3) 2738 135.72 570.25 Volume (Bbls) Volume (Gal) 487.6586 24.17 101.5659 20481.661 1015.23 4265.766 Nit 21(7.9 38(.09 16215.9 TEST Net Containment < OR > Tank 1 Capacity 386.09 300 Containment is Sufficient MMMIMA Environmental Scientists and Engineers, LLC p:lpray ects}axy\spec plan nxy spec` y mea[ spcc:doc Page 68 • • APPENDIX D OIL SPILL CONTINGENCY PLAN CHECKLIST AND REGULATORY CF OSS - REFERENCE FOR SPCC PLAN REQUIREMENTS GUIDELINES FOR SPILL CONTINGENCY PLAN AND COMMITMEN1 OF MANPOWER FLOWCHART OF OIL SPILL NOTIFICATION PROCEDURE STATE OF COLORAOD SPILL RULES STATE SPILL FORMS p'',projecis'axy`spcc plana y spcc oxy mut spat doc Page 69 REGULATORY CROSS-REFERENCE Citation Descriptio Sectlo 1 J112..3 Requirement to Prepare and Implement a SPEC Plan §112..3 §112.3(d)(1) Owner/operator must prepare SPCC plan Professional Engineer Certification See bt low All §112.3(e) Maintain complete copy of plan 3 1.p §112..4 Amendment of SPCC Plan by Regional Administrator §112.4(a) Report to EPA after specific discharges Appen Six A 112.4(c) Send above report to appropriate state agencies §112..5 , Amendment of SPCC by Owners / Operators Appendix A §112.5(a) Amendment of SPCC plan by owner or operator §112.5(b) Management of Five Year Review §112.5(c) PE certification of amendment Introdi lotion Introdi iction 1.3 §112,.7 General Requirements for SPCC Plan §112.7 Management approval of plan 1.2 112.7 Cross reference table if plan does not follow sequence of re Discussion of conformance with the requirements of SPCC §112.7(a)(2) Explanation of any deviations ulation Apper dix D 2.6 2.5 §112.7(a)(3) Physical layout of the facility including facility diagram 1.8 112.7 a 3 i Type of oil in each container and its storage capacity Discharge prevention measures including procedures for ro4tine handling of oducts §112.7(a)(3)(ii) §112.7(a)(3)(iii) Discharge or drainage controls such as secondary contain nt around containers and other structures, equipment and procedures for control f a discharge §112.7(a)(3)(iv) Countermeasures for discharge discovery, response and cl$anup §112.7(a)( )(v) §112.7(a)(3)(vi) 112.7(a)(4) §1 12.7(b) 3112.7(c) Methods of disposal of recovered materials Contact list and phone numbers Appel idix C 2.1 Appe tdix C 2.2 2.3 Appeldix D Procedures for reporting a discharge, unless FRP has beer submitted §112.7(d) Discharge prediction / Fault analysi Appe idix 0 Appe tidix C Appropriate containment or diversion: Deviations due to impracticability Appendix C §112.7(e) §112.7(1) §112.7(f)(1) §112.7(f)(2 Inspections, tests, and records 2.5, .7 7.4 Employee training and discharge prevention procedures Oil -handling personnel training 1.7 1.7 Accountable person for discharge prevention §112,7(f)(3) §112.7(g) 4112.7(q)(1) §112.7(g)(2) 112.7(g)(3) Discharge prevention briefing 1.7 1.7 Security (excluding oil production facilitie Fencing and lock/guard gates ) NA NA Fail-safe valves for containers §112.7(g)(4) §112.7(8)(5) 112.7(h) Starter control on each pump NA NA Loadinglunloading connections of oil pipelines or facility pi Lighting ing when not in service NA Tank Car and Tank Truck Loading / Unloading Rack (excli. §112.7(h)(1) §1 §1 12.7(h)(2) 12.7(h)(3) 112.7(i) §112.7(j Handling discharges es offshore facilities) NA 3.5 3.5 Preventing early vehicle departure 3.5..', Inspection for discharges prior to filling and departure .5. # Evaluate field -construct above ground tanks upon repair, etc. onformance with State requirements 3.5.4 2.6 p pi bxykp c pionbxy specbxy neat spcc.d e Page 70 The following guidelines are provided as a general quick -reference o ily. GUIDELINES FOR SPILL CONTINGENCY PLAN AND COMMITMENT OF MANPOWER A. Immediate response by on-site facility personnel. 1. From a safe distance, shut off the source of spill as soon as possible. 2. Eliminate all sources of potential ignition. 3. Assess volume of spill and potential pollution possibilities in vicinity and surrounding areas. 4. Call for manpower and equipment necessary to contain and remove the discharged oil. 5. Call supervisor to report details of spill and to obtain any instructs Ons or assistance which may be appropriate from higher authority levels. The supervisor will notify headquarters office on details of spill and will coordinate any ictions requested by facility personnel at the scene of the oil spill. 6. Assess the flammability and personnel exposure hazards associated with containment for cleanup. B. Immediate Response by Supervisor. 1. Arrange for additional manpower and oil spill containment and clan up equipment as warranted by the oil discharge. Advise the onsite person in charge of any arrangements. 2. Report required information of the spill to headquarters. Also, request any necessary assistance from headquarters. 3. If warranted, proceed to the oil spill location and supervise the containment and clean-up operations. C. Preplanned strategy for containment and clean-up equipment deploymen 1. Local supervisor or senior employee on scene will coordinate clean-up operations.. 2. Upon receipt of manpower and equipment, the person in charge will d rest the construction of appropriate dams, dikes and other containment facilities to contain the discharged oil. In open water spills, oil spill boom can be deployed, weather conditions permitting, to contain the spill or divert it from sensitive areas. 3. At land locations, vacuum trucks or sorbents will generally be used to recover oil once it is contained. At water location, skimmers and vessel -mounted tankage may be required. The oil must be recovered as rapidly as possible to minimize contamination of soil and/or water. PtP@ ects c y\spcc pkan,oxy spct'axy rmat spec.doc Page 71 4. Where possible, all recovered fluids will be return for handling. Absorbents will be considered for fin 5. Burning the spilled oil may be an effective measu such as mechanical containment may not be pr marshes and coated marsh vegetation. Burning of headquarters and the U.S. Coast Guard On -Scene State air quality agency, should be notified and a Once burning is approved, the local I-IAZMAT a d to the process or tank areas 1 clean-up where appror riate. particularly when me sures ctical, or if oil has e itered oil requires prior approval of oordinator. The appropriate proval obtained as req.iired. ency(ies) and the local police department should be notified. The burning of the oil must not be harmful to or be a nuisance to the local public, and the smoke ge crated from the burnin. must not adversely affect the visibility on any nearby hig ways. original condition within the 6. Any damaged land or property will be restored t realm of practicality. 7. Supervisor should be notified of unusual conditi clean-up is completed. Commitment of manpower, equipment and material remove oil discharges. BP America Production Company has the econom manpower, equipment and materials to contain and re occur at this facility. Whatever is needed will be ma gravity of a spill event. Movement of Oily Wastes to Disposal Areas 1. Whenever possible, oil recovered from a spill sho production system for recycling. 2. For oil and oily wastes that must be disposed of o transported by a licensed carrier to a non-hazardo facility or reclaiming facility approved by the app Movement of wastes are tracked with a waste ma representative on the site and the transporter need Company's representative will take one copy and waste tracking coordinator for matching up with a Company by the disposal facility. The copy furni verifies receipt and acceptance of the waste. p_ Ipmjeclsaxy'spec plan o!cy spcc'kxy octet spec doc ns as they may arise and when o expeditiously conti of and resources for provid ng the ove any size oil spill tl at may e available consistent with the Id be returned to the site: oily wastes must b s oil field waste disposa, opriate state agency. ifest. The Company's o sign the manifest. The orward it to the Company's copy that will be furnished to hed by the disposal facility Page 72 • • • Title INTERNAL NOTIFICATION REFERENCES Name Operations Mana,er Office Home Othe. Field Manager Derek Johnson HES Coordinator Tom Scott 970-285- 9346 915-684- 8170 (C): 970-210- 0355 (C): 915-448- 1121 (P): 915-498- 131 EXTERNAL NOTIFICATION REFERENCES Agency Location Office National Response Cente EPA (Region VIII) EPA Washington, D.C. Denver, Colorado 1 800-424-8802 303-293-1603 Oil & Gas Conservation Commission Spill Report 303-293-1751 Denver, Colorado 303-894-2100 EQUIPMENT AND MATERIALS AVAIL Location/Contractor Grand Junction, Colorado Dalbo, Inc. A-1 Tank Rental Roustabout Specialties Parachute, Colorado Mike Brady Rifle, Colorado Flint Engineering & Construction Co. Baggs, Wyoming Chriswell Trucking Equipment Available Oil Field Haulers and Vacuum Trucks Portable Storage Tank BLE TO SUPPOF:T Dirt Equipment Roustabout Contract L: bor Dirt Equipment Telephone Numters 303-245-7333 303-245-7333 303-858-0453 303-285-9508 Roustabout Contract L-bor 303-625-5092 Oil Field Haulers And Vacuum Trucks Portable Storage Tan 's 307-383-6915 p:Vrojecteroxy+5pcc plan',nxy spceoxy mug spec doc Page 73 • • FLOWCHART OF OIL SPILL NOTIFICATION PROCEDURE Immediately notify appropriate Authorities SPILL DISCOVERY 4 -- Activate necessary support Qualified Individual Immediate notification: Operations Isolate s rce and initiate containment Activate/deploy p. appropriate :'ompany and contract r .sources to respond to incident Prepare & communicate written incident report to Operations Supervisor Headquarters Operations Manager Higher Level Management as appropriate I p `projects''exy'spcs p do:1y spec+ory rmat spcc.doc Page 74 • • State of Colorado Spill Rules 906. SPILLS AND RELEASES a. General. Spills/releases of E&P waste, including produ contained immediately upon discovery. impacts resulting from and cleaned up as soon as practicable. The Director may requ mitigate threatened or actual significant adverse environment - biological resource, or to the extent necessary to ensur concentrations and levels in Table 910-1, with consideration to classifications. ed fluids shall be controlled and pills/releases shall be investigated re additional activities to prevent or I impacts on any air, water, soil or compliance with the allowable OCC ground water standards and b. Reporting. (1) Spills/releases of E&P waste or produced fluid e seeding five (5) barrels, including those contained within unlined berms, shall be reporter on COGCC Spill/Release Report Form, 19. Such report shall include information relating 's initial mitigation, site investigation and remediation, and shall be submitted to the Director wi hin ten (10) days of discovery of the spill/release. (2) In addition, spills/releases which exceed twenty (2 {1) barrels of an E&P waste shall be verbally reported to the Director within twenty-four (24) ho rs of discovery. (3) In addition, spill/releases of any size which impact or threaten to impact any waters of the state, residence or occupied structure, livestock or pu s lic byway, shall be verbally reported to the Director as soon as practicable after discovery. c. Surface owner notification and consultation. The ope notify and consult with the surface owner prior to commencing from a spill/release in an area not being utilized for oil and gas d. Remediation of spills/releases. (1) Remediation workplan. When threatened or act impacts on any air, water, soil or biological resource necessary to ensure compliance with the allowable cones with consideration to WQCC ground water standards a require operators to submit a Site Investigation and Reme (2) Remediation requirements. Spills/releases shall concentrations in Table 910-1. Spills/releases exceeding waste shall be remediated in accordance with Rules 909. e. Spill/release prevention. (1) Secondary containment. Secondary containm around tanks containing crude oil, condensate or prod milligrams per liter (mgll) total dissolved solids (IDS). 0 tank and containment requirements under Rules 603. apply to water tanks with a capacity of one hundred (100) (2) Spill/release evaluation. Operators shall determi the extent practicable, shall implement measures to causes in the future. For reportable spills, operators Director on the SpillRelease Report, Form 19 within spilllrelease. tor shall make good faith efforts to operations to remediate E&P waste perations. al significant adverse environmental from a spill/release exists or when ;ntrations and levels in Table 910-1, nd classifications, the Director may diation Workplan, Form 27. e remediated to meet the allowable twenty (20) barrels net loss of E&P nd 910. nt shall be constructed or installed ced water with greater than 10,000 erators are also subject to crude oil nd 604. This requirement shall not barrels or less. e the cause of a spilllrelease, and to revent spills/releases due to similar shall submit this information to the en (10) days after discovery of the p tprojects''axy'spec plan'oxy spce..uxy rmzt spcc.doc age 75 Barium (LDNR True Total Barium) 180,100 mg/kg Boron (Hot Water Soluble _ _ 2 m• I Cadmium • • • Table 910-1 ALLOWABLE CONCENTRATIONS AND LEVELS Contaminant of concern Allowable concentrations I Organics in Soil: EPA Method 8015 (modified) I TPH-Non-Sensitive Area _ 10,0011 mg/kg 1,00# mg/kg TPH-Sensitive Area Organics in Ground Water: EPA Met od 8020 Benzene 1411 Toluene Ethyibenzene Xylene 1.00 •/l 68° ./I 1.0,00 n µg/l 1 I Inorganics in Soi s4 Electrical Conductivity (EC) <4 m hos/cm or 2x back•ound Sodium Adsorption Ratio (SARL pH <12 6-9 Inorganics in Groun • Water Total Dissolved Solids (TDS Chlorides Sulfates 1.25 x back! round <1.25 x background 1 <1.2 x background Total Metals in Soils: EPA Meth • d 30504 Arsenic 41m/kg 2 26 m /kg 1,50 ' mg/kg 2 2 Chromium Copper Lead 750 g/kg 300 g/kg Mercury 17 m!/k• Molybdenum Nickel 210 g/kg Selenium Silver 100 gfkg 2 Zinc 1,40 mg/kg 1 Concentrations taken from CDPHE-WQCC 2 Concentrations taken from API Metals Guido e: Maximum Soil Concentrations 3 Concentrations are dependent on site-specifi• conditions 4 Consideration shall be given to background le els in native soils p''crojec25''oxy'3pcc plamaxy spcc'axy rmat spcc.duc Page 76 OUTSIDE SENSITIVE AREAS -New E&P waste management facilities shat be allowed outside Sensitive Areas. Paints of Compliance shall be established as apprppriate. Figure 901 - SENSITIVE DETERMENT r YES BbX I: Is discharge water or waste: >1 25 >: background ppm TUS >23U ppm Uhlonde or 1.25 x backg ound >250 ppm S'ilfate or 1.25 xl ackgound > 5 ppb Bergen > 1000 ppb Toluene >68O ppb E:hyibenzene > 10,000 ppb xylene YES I BOX 2: Is the site underlain by an unconfined aquifer or recharge zone? -Where complaints are made, Points of Compliance may be established for existing facilitief. !No 1 YES BOX 3: is the kgrcxaulu conductivity of the und3rlyirg sods and geologic material less then or equal to 10 .1 craIsec BOX 4: Is the site within an area c1essifred fordo rustic tse by WQCC, or a focal ,water supply) wellhead prosection ares (WEPA)f LiO 5. 6 the luuL:aliun willtir itS miof a domestic water well, or 11.1 mi. of a public wet i supply well, using the same ar rifer? SIDE SENSITIVE AS -E&P waste anagement acilities shall riot e allowed unless e operator demonstrates no otential for significant alae rs environmental mpact.. -Facilities which are permitted ay have Points of Compliance establi>he i. * Additional requirements may be imposed by the Director in accordanco with Rano 9OI.c. p.\projectslaxy'sspcc plan av, spcc'oxy mut sp e.doc BOX 6: Is the depth to the average high grcund water table {20', from the deeper of the grounc surface, pit bottorr. or from the pent ofspilUreleaae? (�a¢sAotnou) Page 77 • A a 9 • • • MAIN OFFICE 1120 Lincoln Street, Suite 801, Denver, Phone: 303-894-2100 Fax: 303-894-2109 Col Please mail any correspondence for COGCC Comm for forwarding. BALDWIN, DEBBIE AVIS, LOREN FERGUSON, RANDALL CHESSON, ROBERT BELL, MORRIS DILLON, DAVE DIMATTEO, ED ROBBINS, LARRY SHELTON, DAVE ADKINS, JAIME PO Box 98 Loma, CO 81524 ENVIRONMENTAL Colorado 80203 (plaint: 888-235-1101 ssioners to the Main Office lext.111 ext.110 ENGINEERING ext.118 'ext.112 ,ext.105 ext.104 ext.106 !ext.107 FIELD OPERATIONS Northwest Region KRABACHER, JAY Grand Junction, CO 81503 Parachute Office 73 Sipprelle Drive, Ste. J1 Parachute, CO 81654 PO Box 6352 Battlement Mesa, CO 81636 p 'pmjecls',axy`spcc plari•,oxy spccloxy ernat spec doc 0 ext.108 ice1FAX 970/858-7521 Cell 970/250-2440 ice/FAX 970/256-9000 Cell 970/216-5749 Dffice 970/285-9000 Fax 970/285-5659 r� 1 Page 1 • • • APPENDIX E EXAMPLES OF TECHNICAL AND NON-TECHNICAL AMENDMENTS p.''projects''axy'•spcc pLan'axy spcc•axy rrnat spec. dcc Page 2 Piping mc In-kind re TECHNICAL AMENDMEN Amendmen Addition of new tanks Changes i within ma Removal of decommissioning of existing tanks. Replacement of one tank with more than one identical tank resulting in greater storage capacity. New procedures or material changes to existing operational procedures. Changes which materially affect operational procedures. "Changes of product" may materially affect facility operations and therefore be a material changes. An example of a change of product that would be a material change would be a change from storage of asphalt to storage of gasoline. A switch from storage of gasoline to storage of asphalt might result in increased stress on the container leading to its failure. Tank repai Replacem storage ca Changes tc the Plan. Changes o grades of ; change an the Plan i not subsea storage an A "change in service" from previous operating conditions involving different properties of the stored product such as specific gravity or corrosivity and/or different service conditions of temperature and/or pressure. Addition of new oil -service piping or transfer facilities. Addition of new loading/unloading racks or areas. S No Amendment drums, totes in storage areas if imum number stated in Plan. r. nt of one tank resulting in same acity. procedures cited by reference in r product involving different asoline might not be a material l thus not require amendment of the differing grades of gasoline do itially change the conditions of i potential for discharge. difications. .lacement of existing piping p'prolects'flx9'spec P1an'A%9 spcc'exy mat spcc dnc Page 3 • • ADMINISTRATIVE AMENDM ENTS Amendment No Amendment Changes to the contact list. Changes in reference documents. Ordinary maintenance or non -material changes to existing procedures which do not affect the potential for the discharge of oil Editing changes to SPCC Plan text. More stringent requirements for storm water discharges to comply with NPDES rules Phone numbers Product changes if the new product is compatible with conditions in the existing tank and secondary containment Product changes if the product falls into the same generic grouping Change in manager Change in owner or operator Change in person accountable for discharge prevention APPENDIX F OPERATING, MAINTENANCE AND INSPECTION PROC DRAINAGE PROCEDURES DURES p',prnjec[s,oxv'spcc plan''o.xy spccox} anal spec da Page 5 GUIDELINES AND PROCEDURES FOR INSPECTING FACILITIES NOTE: Applicability: These guidelines were developed to serve typical facilities. Certain of the provisions are not applicable to operations over water (e. g., dikes, tank truck load 'ng/unloading), others are not appropriate to facilities on land These inappropriate provisions should be disregarded. In case of uncertainty, contact headquarters. DRIP PANS should be observed at regular intervals and after major rainfall events, and should be emptied when necessary to make sure they do not overflow. Where provided, drain lines and sump tank systems should be inspected to make sure piping is not blocked, that sump level is not excessive, and that pumping systems are operable. POLLUTION PREVENTION E UIPMENT/SYSTEMS inspections, and testing where necessary, should be conducted at periodic inter\ als. Inspections should include ongoing visual surveillance for deterioration, plugging of vents/ports, signs of vandalism, damaged control lines, or other abnormal condition. Testing should be commensurate with the complexity, conditions, and circumstances of the facility and applicable regulations. Where practical, safety devices should be actuated in conjunction with production shutdowns to ensure they are operating correctly. If more specific written inspection/test procedures are used, a copy should be maintained at the facility. Examples of equipment/systems that may be present at a facility are: Surface safety valves Subsurface safety valves Emergency shutdown stations Emergency shutdown valves Liquid level sensors (high and low) Pressure sensors (high and low) SALTWATER DISPOSAL SYSTEMS should be subject to frequent surveillance to detect and repair any leakage, system upsets or other abnormal conditions. Periodic visual inspections should be conducted of the tanks, pumps, injection lines and injection wellheads for indications of potential leakage. SUMP SYSTEMS should be large enough to allow protection against accidental spillage. Redundant pumps should be installed, or an alternate means such as a portable pump should be available for removing the liquid from the sump in case the primary sump pump becomes inoperative. The following actions should be conducted at regular intervals: p:Ipm}ects+ xy'spcc ptanloxy ,pccloxy tmai spcc.doc Page 6 • • • . Make sure drains, drain lines, and sump are clear of blockage or obstructions to proper functioning. Inspect visible portions of equipment for leaks and signs of corrosion. Repair as required. 2. Examine the sump structure (tank and tank supports) for signs of corrosion or deterioration. Repair as required. 3. Inspect and operate the pump and start-up sensing device to ensure they are functioning correctly. Records of the inspections and tests (including those maintained under usual and customary business practices), signed by the appropriate supervisor or inspector are retained on file for a minimum period of three (3) years. (Note: Existing inspections and tests kept under usual and customary business practices will suffice if approved by the certifying engineer). DRAINAGE PROCEDURES I. Diked storage areas, firewalls, and other secondary containment structures that can collect rainwater must be observed periodically, particularly following major rainfall events. Water should not be allowed to accumulate to the point where required capacity for a spill would be reduced, and should be drained as soon as practical. 2. Diked storage areas that are provided with installed drainage lines must have the drainage valves kept closed and sealed. 3. Diked storage areas, firewalls, and other secondary containment that do not have installed drainage valves for releasing collected rainwater must be manually pumped out (before excessive water accumulates). 4. The accumulated rainwater in the diked area must be visually inspected for the presence of a sheen, discoloration or other sign of contamination. Any such observed contamination must be removed from the water prior to draining. Any other signs of suspected contamination from the substances stored within the diked area must be resolved prior to draining. The cause of this abnormal condition must be determined and corrected. 5. If it is suspected to be contaminated, it should not be discharged. Any covered substance accumulated in a diked area will be recovered using portable oil skimmer pumps, absorbent material, vacuum truck or other methods as appropriate. 6. Site drainage ditches, road ditches, oil traps, sumps, and skimmers, if such exist, must be inspected at regularly scheduled intervals for accumulations of oil. If a covered substance (such as oil) or evidence of a covered substance is detected in a ditch, the source of the discharge will be found and stopped, the ditch will be isolated by constructing an earthen dam or other suitable containment (such as sorbent boom), and the material will be recovered using portable oil skimmer pumps, absorbent I, pmjecs'axykspcc planbxy spc4 cr.<y mna¢ $p[c dc, Page 7 • • material, vacuum truck or other methods as appropriate. If an oil trap or sump has accumulated an excessive amount of covered substance, the material will be recovered using portable oil skimmer pumps, absorbent material, vacuum truck or other methods as appropriate. Recovered material will be either reintroduced into the treatment system or properly managed in accordance with Section 1.8 of this SPCC Plan. 7. Monthly reports are kept showing the dates that drainage was conducted from diked areas. Documentation is also kept showing that the facility's equipment and containers are regularly inspected for the presence of a discharge. p.`,prajects,axy`spcc pkanWxp sp€c'axy rmat spcc:doc Page 8 -al • Environmental Scientists and Engineers, Inc. 604-11 • 1. Bulk Storage Containers: Tank ID or Name Volume 400 bbl 500 Tallon 32 cf Volume 2 — elevated 3 — round level Underground Storage Tanks None Contents natural • as condensate methanol unknown Contents 2. 55 Gallon Drums? Yes Quantity: 2 — triethylene glycol 3. NFPA Label? Yes ❑ No 4. Stairs in containment? ►1 Yes ❑ No Where: I inside as shown below ❑ No 5. Drainage pathway and Distance to Navigable Waters: Spill direction is to the southeast and greater than 1/4 mile to the nearest surface water body. 6. Physical Location: NENE Section 4, T 6 S. R 97 W 7. Spill -kit onsite? ['Yes — Where: CO No S. Exterior Lighting? Dyes — Type: ® No 9. Site Fenced? @ Yes — Type: wire . ❑ No 10. All Tanks Compatible with contents? ►ZtYes ❑ No If No, explain 11. Buried piping onsite? _Yes ❑ No If Yes, cathodically protected and wrapped? Yes ❑ No 12. Above ground piping onsite? Yes El No If Yes, piping supports adequate? Yes ❑ No 13. Corrosion protection for buried tanks? ®'Yes ►Z/ N/A 14. Secondary Containment Calculations: Sketch affacility 6/25/08 t�r 3 get =graphical depiction of how containment capacity was calculated ac Gir 5n 5, Lel e, 0 c, c% ME= Total Spill Containment Capacity (including allowance for displacement from tanks, reduction of capacity from side slopes, and allo�� ance for freeboard) (Bbis) *See SPCC Calculation spreadsheet for detailed calculations Secondary Containment Capacity Adequate for stored tanks? 42.7 142.7 1.6 1:1 400 NA NA NA NA NA NA 400.4356 yes 15. Additional Notes: Additional tanks on pad include the following: one 500 -gal elevated steel tank (labeled methanol and with NFPA) which is contained by an 8' diameter stock trough — dry; 4'x4'x2- tank. contents r e: amens and senings2haines'desktop'gj of£caspec}mesa - reviewed from chnstme1604.t l.doe • Environmental Scientists and Engineers, Inc. unknown, has torn NFPA label; two 55 -gal drums contained in a 6'x2'x2' stock trough — dry. The additional tanks and components are located within earth berm containment approximately 41'x40`x6". c:''ducurnerots and settings lahai.needesktaplg officesspet'+mesa -regi eked From christinel604.11 doe • 604-12-13 mash Environmental scientists and Engineers, Inc. • • 1. Bulk Storage Containers: Tank ID or Name Volume 400 bbl 500 Tallon 48 cf Volume 2 — elevated 3 — • round level Underground Storage Tanks None Contents natural • as condensate methanol unknown Contents 2. 55 Gallon Drums? [Yes 0 No Quantity: 2 drums containing "METALGUARD" 3. NFPA Label? Yes 0 No 4. Stairs in containment? ❑Yes ►l� No Where: I outside as shown below 5. Drainage pathway and Distance to Navigable Waters: Spill direction is to the southeast and greater than 1/z mile to the nearest surface water bod 6. Physical Location: SWNW Section 4, T 6S. R 97 W 7. Spill -kit onsite? 8. Exterior Lighting? 9. Site Fenced? DY es — Where: ❑Yes -- Type: ['Yes — Type: 10. All Tanks Compatible with contents? ►jt No No ® No Yes ❑ No If No, explain 11. Buried piping onsite? Yes ❑ No If Yes, cathodically protected and wrapped? Yes 0 No 12. Above ground piping onsite? Yes ❑ No If Yes, piping supports adequate? Yes ❑ No 13. Corrosion protection for buried tanks? ❑Yes ►;A N/A 14. Secondary Containment Calculations: sdrer sl cr.pe N��I nF 44 // Sketch of facility 6/25/08 OL 0 cit 4 C er cra 4 it P_• Total Spill Containment Capacity (including allowance for displacement from tanks, reduction of •t capacity from side slopes, and o allowance for freeboard) = ec:,.1,.. irk ,x o i^ = (Bbls) *See SPCC Calculation spreadsheet for detailed a calculations Secondary Containment Capacity Adequate for stored tanks? 53.0 29.5 2.0 1:1 400 NA I NA NA NA I NA NA 430.4490 yes 15. Additional Notes: Additional tanks on pad include the following: one 500 -gal elevated steel tank (labeled methanol) which is contained by an 8' diameter stock trough — dry; 4'x4'x3' tank. contents unknown: two 55 -gal drums contained in a 6'x2'x2' stock trough --- dry. The additional tanks and components are located within earth berm containment approximately 40'x40'xl'. c:\documents and inbstiahaenes',des}aaop',.gj of£ce spccVnesa - mven,cd from cinstlnt'.6C4- [2.13 doc CDC 1161., Project: OXY Corm Creek H Compressor Station Submittal Item Number: 11.1.B.1 CDPHE Air Pollution Control Division Attached is a copy of the CDPHE Construction Permit. Page 1 of 1 ENSR ENSR 1601 Prospect Parkway, Fort Collins, CO 80525 T (970) 493-8878 F (970) 493-0213 www.ensr.aecom.com October 9, 2008 Mr. Chris Laplante Air Permit Engineer Colorado Air Pollution Control Division Colorado Department of Public Health and Environment APCD-SS-B1 4300 Cherry Creek Dr. S. Denver, CO 80246-1530 Subject: Proposed Expansion of Conn Creek Gas Treating Facility, Garfield County, Colorado Dear Mr. Laplante, AECOM On behalf of OXY USA WTP LP (OXY), ENSR Corporation (ENSR) submits the enclosed construction permit application package for a project to expand compression capacity at OXY's existing Conn Creek Gas Treating Facility (CCGTF I) located in Garfield County Colorado. CCGTF I is a natural gas processing plant, currently with a capacity to treat and process up to 40 MMscfd. As discussed with you during our meeting on September 24, 2008, OXY is undertaking a project to expand gas production and gathering capacity for its Grand Valley Field in Garfield County. The expansion will be facilitated by increased pipeline capacity and an increase in compression capacity. The required increase in compression capacity will be achieved by construction of a new 60 MMscfd compressor station (CCGTF II) adjacent to and contiguous with CCGTF I. The project will also involve some changes to CCGTF I. In accordance with a contractual agreement with the local pipeline operator, the low-temperature natural gas liquid (NGL) extraction (propane refrigeration) process at CCGTF I will be shut down, but not permanently removed from service. Essentially, the CCGTF I and II facility will be a compressor station with the capacity to compress and treat (dehydrate) up to 100 MMscfd field gas received from the Grand Valley gathering systems. For air quality permitting purposes, CCGTF I and II are considered a single stationary source. A comprehensive and detailed explanation of the project is provided in the enclosed application package. CCGTF I is a major source with respect to Colorado's Operating Permit (Title V) program. The facility is currently a minor source for purposes of Prevention of Significant Deterioration (PSD) regulations, as the currently permitted criteria pollutant emissions are less than 250 tons per year (tpy). The project is a minor modification under PSD. For purposes of National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Categories, known as Maximum Available Control Technology (MACT), CCGTF I is currently a "synthetic minor" source. As a result of the expansion however the combined facility will be a major source of Hazardous Air Pollutants (HAP) upon startup. As discussed with the Division, OXY proposes to begin construction of the project in March 2009. Toward that goal. ENSR has carefully followed the Division's new permit application process for oil and gas industry sources and we have made every effort to prepare and submit a complete application. Accordingly, each copy of the enclosed application package is comprised of a bound document with chapters and appendices that include the following: 1. A detailed discussion of the project (Chapter 2) and emissions (Chapter 3) • ENSR Mr. Chris Laplante October 9, 2008 Page 2 • • 2. A "Construction Permit Application Completeness Checklist", Form APCD-100 (Appendix A) 3. Completed and signed Equipment specific APEN forms, Form Series 200 (Appendix A) 4. A completed "Company Contact Information" Form APCD-101 (Appendix A) 5, Completed O&M Plan Templates for the RICE and TEG Dehydration Units (Appendix A) 6. Supporting documentation of emissions calculations (Appendix B) 7. An ambient air impact analysis (Chapter 5 and Appendix C and D) 8. "Operating & Maintenance Plan" forms, Form Series 300 (Appendix A) 9_ A detailed Regulatory Analysis (Chapter 4) OXY requests that the Division write a single facility -wide construction permit for the CCGTF II compressor station project. As noted above the facility will, upon startup, be a major source of HAP. As a consequence, some provisions of the following MACT rules (40 CFR Part 63) will apply to those affected sources at CCGTF I and II. • Subpart HH—National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities • Subpart ZZZZ—National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines • Subpart EEEE—National Emission Standards for Hazardous Air Pollutants for Organic Liquids Distribution (Non -Gasoline) A detailed discussion of federal MACT rules that apply to the facility is provided in the attached application document (Chapter 4). Note that the existing affected sources at CCGTF I will have three years after startup of CCGTF II to meet compliance obligations under the applicable MACT rules. The new sources comprising CCGTF II will be in compliance with MACT at startup, All affected sources that are subject to air pollution control standards and requirements under the applicable federal MACT rules listed above will be equipped with such controls conforming to the rules. Furthermore, OXY will meet all applicable requirements set out in the rules and in the General Provisions (Subpart A). The project is subject to preconstruction review requirements set out in 40 CFR §63.5. OXY requests that the enclosed construction permit application also be considered our application for approval of construction or reconstruction required by 40 CFR §63.5(d). The enclosed package includes all of the required elements listed in §63.5(d). OXY also requests that the enclosed application for approval of construction fulfill the initial notification requirements of §63.9(b)(5). ENSR Mr. Chris Laplante October 9, 2008 Page 3 Enclosed, we are providing three (3) bound copies of the construction permit application package. Pursuant to the preconstruction review and initial notification requirements under MACT (Subpart A) discussed above, we request that you forward one of the enclosed copies of the application to Beth Pilson, the Division's administrator for federal programs. GarfieldCounty also requires documentation that air quality permitting requirements have been met for the project. We therefore request written confirmation that an administratively complete application has been received by the Division. Please provided a letter to OXY and we will forward a copy to Garfield County. The APEN fees ($152.90 each of eight APENs, for a total of $1,223.20) will be paid by OXY separately by credit card. ENSR has prepared a detailed and complete permit application and we respectfully request that the Division make every effort to expedite the permitting process. We trust that you will find the enclosed application administratively complete and technically sound. If you or the Division have any questions or concerns, please contact me or Jamie Christopher at (970) 530-3458 or (970) 530-3459 respectively, or Alonzo Hernandez, OXY HES Superintendent at (970) 263-3609. We look forward to working closely with you and the Division to obtain a timely permit. Sincerely yours, Kenneth A. Malmquist Senior Air Quality Engineer kennv.malmquist@aecom-com enclosure cc: Alonzo Hernandez, OXY Jamie Christopher Senior Air Quality Engineer jam ie.christopherAaecom.com • Prepared for: OXYUSAWTPLP Grand Junction, Colorado Construction Permit Application Minor Modification to the Conn Creek Gas Treating Facility, Garfield County, Colorado ENSR Corporation October 2008 Document No.: 05252-008-140 ENSR AECOM Prepared for: OXY USA'WTP LP Grand Junction, Colorado Construction Permit Application Minor Modification to the Conn Creek Gas Treating Facility, Garfield County, Colorado ((L Prepared By: Patrick McKean Reviewed By: Kenny Malmquist ENSR Corporation October 2008 Document No.: 05252-008-140 ENSR • • ENSR Contents 1.0 Introduction 1.1 2.0 Project Description 2-1 2.1 Process Description 2-1 2.1.1 Inlet Separation 2-1 2.1.2 Compression 2-2 2.1.3 Glycol Regeneration 2-2 2.1.4 Heat Medium (Process Heat) ... 2-2 2.1.5 Power Generation 2-2 2.1.6 Emergency Flare 2-3 2.2 Existing CCGTF I Modifications 2-3 2.2.1 Existing Generator Engines 2-3 2.2.2 Existing EG Unit 2-4 2.2.3 Existing Flare 2-4 2.2.4 Existing Condensate Tank Battery 2-4 3.0 Emissions Summary 3-1 3.1 Proposed Project (CCGTF II) Criteria Pollutant Emissions 3-1 3.1.1 Internal Combustion Compressor Engines 3-1 3.1.2 Internal Combustion Generator Engines 3-2 3.1.3 Heat Medium Heaters 3-3 3.1.4 Glycol Dehydration Unit 3-4 3.1.5 Emergency Flare 3-4 3.2 Existing Source Modifications 3-5 3.2.1 Caterpillar G3512 Generator Sets — Permit No. 05GA0068 3-5 3.2.2 EG Unit — Permit No. 05GA0069 3-5 3.2.3 Emergency Flare — Permit No. 05GA0173 3-6 3.2,4 Existing Condensate Storage Tanks — Permit No. 06GA1232 3-6 3.3 Total Project Criteria Pollutant Emissions Summary 3-8 3.4 Hazardous Air Pollutant Emissions Summary 3-9 4.0 Regulatory Applicability 4-1 4.1 General 4-1 4.2 Applicability of PSD — New Source Review 4-1 4.3 Applicability of Title V — Major Source Operating Permit 4-1 4.4 Applicability of NSPS 4-2 4.4.1 Subpart A — General Provisions 4-2 4.4.2 Flare 4-2 4.4.3 Subpart Dc — Steam Generating Units 4-3 05252-008-140 October 2008 • • ENSR 4.4.4 Subpart Kb — Volatile Organic Liquid Storage Vessels 4-3 4.4.5 NSPS JJJJ — Spark Ignition Internal Combustion Engines 4-3 4.5 40 CFR 63 National Emission Standards for Hazardous Air Pollutants 4.5.1 Subpart A — General Provisions 4.5.2 Subpart HH — Oil and Natural Gas Production Facilities 4.5.3 Subpart 7777 — Stationary Reciprocating Internal Combustion 4.5.4 Organic Liquids Distribution MACT 4-3 4-4 4-5 Engines 4-6 4-8 4.6 Colorado Air Quality Control Commission Regulations — General 4-11 4.7 Colorado Air Quality Control Commission — Regulation 7 4-12 4.7.1 Condensate Tanks (Reg. 7, XVII.C) 4-12 4.7.2 Glycol Dehydration Units (Reg. 7, XVII.D) 4-12 4.7.3 New or Relocated Natural Gas -Fired Reciprocating Internal Combustion Engines (Regulation 7, XVII.E) .... 4-12 5.0 Air Dispersion Modeling Analysis 5-1 5.1 Dispersion Modeling Methods 5-1 5.1.1 AERMOD Overview 5-1 5.1.2 Meteorological Data 5-1 5.1.3 Receptors 5-1 5.1.4 Good Engineering Practice Stack Height and Building Downwash 5-2 5.2 Source Characterization 5-2 5.2.1 CCGTF Sources 5-2 5.2.2 Off -Site Source Inventory 5-3 5.3 Modeling Results 5-4 5.3.1 Significant Impact Analysis 5-4 5.3.2 Cumulative Impact Analysis 5-4 6.0 References 6-1 List of Appendices Appendix A Colorado Construction Permit Application Forms & Air Pollution Emission Notices Appendix B Detailed Emission Calculations Appendix C Electronic Model File Archive README Appendix D September 19, 2008 CCGTF I Condensate Tank Battery Modification Construction Permit Application Package 05252-008-140 II October 2008 • • ENSR List of Tables Table 2-1 OXY CCGTF II Site Location 2-1 Table 3-1 Hourly Criteria Pollutant Emission Rate Summary — Caterpillar G3616LE IC Engines 3-2 Table 3-2 Annual Criteria Pollutant Emission Rate Summary — Caterpillar G3616LE IC Engines....,3-2 Table 3-3 Hourly Criteria Pollutant Emission Rate Summary — Caterpillar G3512LE IC Engines 3-3 Table 3-4 Annual Criteria Pollutant Emission Rate Summary -- Caterpillar G3512LE IC Engines 3-3 Table 3-5 Summary of Criteria Pollutant Emissions — Heat Medium (Therminolj Heaters 3-4 Table 3-6 Summary of Criteria Pollutant Emissions — TEG Dehydration Unit 3-4 Table 3-7 Summary of Criteria Pollutant Emissions — Emergency Flare 3-5 Table 3-8 Annual Criteria Pollutant Emission Rate Summary — Existing Caterpillar G3512 IC Engines 3-5 Table 3-9 Annual Criteria Pollutant Emission Rate Summary — Existing Flare Permit No. 05GA0173 3-6 Table 3-10 Emission Rate Summary — Condensate Tank Battery Permit No. 06GA1232 3-7 Table 3-11 Annual Criteria Pollutant Emissions Summary (tpy) — CCGTF II 3-8 Table 3-12 Total Project Emissions Increases/Decreases Summary (tpy) 3-8 Table 3-13 Summary of Hazardous Air Pollutant Emissions — CCGTF II 3-9 Table 4-1 Summary of Regulatory Requirements of NSPS Subpart A -- General Provisions 4-2 Table 4-2 Emission Standards for Stationary Non -Emergency Natural Gas -Fired Engines 4-3 Table 4-3 Summary of Regulatory Requirements of 40 CFR 63 Subpart A — General Provisions 4-5 Table 4-4 RICE-MACT Affected Source Designation Criteria for Stationary RICE >500 bhp 4-7 Table 4-5 Subpart 777Z Emission and Operating Limits for New 4SLB Stationary Rice >250 bhp at Major Sources 4-7 Table 4-6 Air Quality Control Commission Regulations Applicability Table 4-11 Table 4-7 Regulation XVII.E Emission Standards ............. 4-12 Table 5-1 Modeled Stack Parameters 5-5 Table 5-2 Modeled Emission Rates 5-6 Table 5-3 Significant Impact Analysis Results 5-7 Table 5-4 Cumulative Impact Analysis Results 5-7 05252-008-140 Hi October 2008 • • ENSE. List of Figures Figure 2-1 Site Location (Togo) Map 2-6 Figure 2-2 Facility Plot Plan 2-7 Figure 5-1 Farfield Receptor Network and AERMAP Terrain Contours for Significant Impact Analysis 5-8 Figure 5-2 Nearfield Receptor Network and AERMAP Terrain Contours for Significant Impact Analysis 5-9 Figure 5-3 Project Sources, Buildings, and Fenceline 5-10 Figure 5-4 Off-site Source Locations Relative to Project Location 5-11 Figure 5-5 Annual NO,c Significant Impact Area (1 pgtm3) 5-12 Figure 5-6 24 -Hour SO2 SIL Exceedance Receptors (5 pg/m3) 5-13 Figure 5-7 Annual SO2 SIL Exceedance Receptors (1 pg/m3) 5-14 Figure 5-8 24 -Hour PM10 SIL Exceedance Receptors (5 pg/m3) 5-15 Figure 5-9 Annual NO, Modeled Cumulative Impact Concentration Isopleths 5-16 Figure 5-10 3 -Hour SO2 Modeled Cumulative Impact Concentration Isopleths 5-17 Figure 5-11 24 -Hour SO2 Modeled Cumulative Impact Concentration Isopleths 5-18 Figure 5-12 Annual SO2 Modeled Cumulative Impact Concentration Isopleths 5-19 Figure 5-13 24 -Hour PM10 Modeled Cumulative Impact Concentration isopleths 5-20 Figure 5-14 Annual PM10 Modeled Cumulative Impact Concentration Isopleths 5-21 05252-008-140 iv October2008 • • ENSR 1.0 Introduction OXY USA WiP LP (OXY) owns and operates the Conn Creek Gas Treating Facility (CCGTF 1) in Garfield County, Colorado (AIRS ID 045/0831). The facility is designed and operated to treat and process field gas received from the gathering systems comprising the Grand Valley Field. Field gas is treated to remove carbon dioxide (CO2) using an amine sweetening process and gas hydrates are removed using an ethylene glycol dehydration unit. After treatment, natural gas liquids (NGL) are extracted from the gas using a propane refrigeration system. The residue gas is transported to markets via pipeline, while the NGL are stored in "bullet" vessels and transported via truck. The facility is designed to treat and process 40 million standard cubic feet of field gas per day (MMscfd) and is currently operating under several construction permits. In addition, a timely and complete Title V Operating permit application has been submitted to the Colorado Department of Public Health and Environment (CDPHE), and is currently under review, OXY is undertaking a project to expand gas production and gathering capacity for its Grand Valley Field (Field No. 31290) in Garfield County. The expansion will be facilitated by increased pipeline capacity and an increase in compression capacity. The required increase in compression capacity will be achieved by construction of a new 60 MMscfd compressor station (CCGTF II) adjacent to and contiguous with CCGTF I. The project will also involve some changes to CCGTF I. For air quality permitting purposes, CCGTF I and it are considered a single stationary source. CCGTF I is considered a major source with respect to Clean Air Act (CAA) Operating Permit (Title V) requirements and is awaiting issuance from CDPHE its Title V Operating Permit. CCGTF I is considered a minor source with respect to Prevention of Significant Deterioration (PSD) regulations, as the currently permitted criteria pollutant emissions are less than 250 tpy and it is not one of the 28 named source types listed in Section 169 of the CM. Therefore, 250 tpy is the threshold for major source status. For purposes of National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Categories, known as Maximum Available Control Technology (MACT), CCGTF I is currently a synthetic minor source. As a result of the expansion however the combined facility will be a major source under the MACT program. The area surrounding the proposed facility has been classified as attainment for all pollutants. The proposed modification will not trigger review under PSD regulations since the potential -to -emit (PTE) from the modification will be less than 250 tpy for each criteria pollutant. However, the PTE for one or more criteria pollutants will be greater than the respective Colorado Air Quality Control Commission (AQCC) Regulation No. 3 exemption threshold levels, and per AQCC Reg. 3, Parts A and B, an Application for Construction and APENs are required to be submitted. The proposed new sources at CCGTF II will comply with all applicable requirements of the AQCC Regulations. This permit application demonstrates that all applicable standards and requirements of AQCC Reg. 3, Part A and Part B have been satisfied. In addition to the application forms that are included in Appendix A of this application, the permit application also includes the following information: • A summary and detailed process description including the physical location of the facility and what will be processed, along with any operational restrictions; • Emission estimates and supporting calculations for all air contaminants; • Identification of all applicable federal air regulations, and, a statement that the facility will comply with all applicable federal air regulations and emission standards adopted under the AQCC; and • A demonstration that the proposed new source will not cause or contribute to causing any ambient air quality standard to be exceeded. 05252-008-140 1-1 October 2008 • ENSR This application contains several additional sections. Chapter 2.0 provides a description of the proposed modification and facility processes. Estimated potential emissions of criteria and hazardous air pollutants (HAPS) are provided in Chapter 3.0 of this application, while Chapter 4.0 includes a summary, of applicable requirements for the proposed modification including Colorado air quality regulations and federal New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAPs). Ambient air quality impact analysis results are discussed in Chapter 5.0. Chapter 6,0 provides a technical reference list. The completed APENs and an Application for Construction Permit are provided as Appendix A. Appendix B contains detailed emission calculations and supporting information and Appendix C includes data file descriptions and a CD-ROM containing the model input/output and related files used in this application, including the cumulative source inventory used in the cumulative modeling analysis. In addition, for the Division's convenience we have included in Appendix D, the complete September 19, 2008 permit application package for the modification of the existing condensate tank battery at CCGTF I. 05252-008-140 1-2 October 2008 • ENSR 2.0 Project Description The CCGTF II project is designed to compress and dehydrate up to 60 MMscfd of field gas and deliver gas to the TransColorado Pipeline. The proposed CCGTF II will be located in Garfield County approximately 17 kilometers north of DeBeque, along the Conn Creek, which parallels Conn Creek Road north-northeast of County Road 45 adjacent to the existing CCGTF I. The site is located on private land located in the SW/4, SW/4, Section 32, Township 6 South, Range 97 West. Table 2-1 presents a summary of the location data for CCGTF II. Figure 2-1 is an area map showing the facility location and Figure 2-2 depicts a preliminary facility plot plan. Table 2-1 OXY CCGTF II Site Location County Garfield UTM Easting 736,676.5 meters UTM Northing 4,374,002.5 meters UTM Zone' 12 Base Elevation 5,960 feet NAD 27 Coordinates Note: UTM coordinate references the CCGTF II Compressor Building. • The major facility components include: • • Inlet gas pressure control and slug catcher (mixed liquids routed to CCGTF l) • Three (3) natural gas-fired four-stroke lean -burn Caterpillar G3616LE, 2 -stage compressors, each controlled by an oxidation catalyst; • One (1) 60 MMscfd triethylene glycol dehydration unit with the flash separator vent controlled by an enclosed combustor and TEG regenerator still vent controlled by a BTEX Unit (condenser) followed by an enclosed combustor; • Two (2) 14 MMBtulhr (gross heat input capacity each) heat medium heaters; • Three (3) natural gas-fired four-stroke lean -burn Caterpillar G3512LE electric generators, each controlled by an oxidation catalyst; and • One (1) emergency flare. The CCGTF II will not engage in the forced extraction of NGL from field gas and will not increase the extraction capacity of the existing CCGTF I gas plant. The following sections describe the primary facility processes. 2.1 Process Description 2.1.1 Inlet Separation The inlet separation area design includes a pig launcher/receiver and an inlet separator vessel (slug catcher) used to drop out liquids (hydrocarbon condensate and water). Mixed liquids will be piped from the inlet slug catcher to CCGTF I for separation. Stabilized condensate product will be loaded from storage tanks at CCGTF Ito truck. Water will be piped from CCGTF Ito the Cascade Central Facility (Water Plant). The Water Plant is formerly known as the Cascade Central Compressor Station_ 05252-008-i 40 2-1 October 2008 • • • ENSR 2.1.2 Compression Compression will be achieved using three natural gas-fired four-stroke dean -bum (4SLB) Caterpillar G3616LE engine compressor packages. Each engine will have a site rating of 4,514 brake horsepower (bhp) at 1,000 rpm and the low-NOx design engines will each be equipped with an oxidation catalyst designed to reduce emissions of carbon monoxide (CO), volatile organic compounds (VOC), formaldehyde (HCHO) and other organic HAPs. Inlet gas exiting the slug catcher will enter the first stage of compression. Gas discharged from the first stage will be routed to a triethylene glycol (TEG) dehydration unit to remove water. Dry gas discharged from the TEG unit will be further compressed to pipeline pressure via the second stage compressors. See Section 3.1.1 for more data on the emissions from these engines. 2.1.3 Glycol Regeneration The new TEG dehydration unit (TEG Unit) is designed to dehydrate up to 60 MMscf/day of wet field gas. The unit includes a contactor tower (absorber), glycol pump, flash separator and a TEG regeneration system (reboiler). The wet field gas discharged from first -stage compressors enters the top of the absorber where it is contacted counter -currently with "lean" TEG, which absorbs water. The dry gas exits the top of the absorber and is discharged to sales via the second -stage compressors. The "rich" TEG exits the contactor and enters the flash separator and TEG regeneration process where the water is removed and the TEG is recycled. The rich TEG leaves the bottom of the absorber and is pumped through a flash separator to the reboiler. Gas discharged from the flash separator will be routed to an enclosed combustor (>95 percent destruction/removal efficiency). The rich TEG exits the flash separator and enters the reboiler where the rich TEG is heated to drive off water. The reboiler is nota fuel -fired unit, but rather uses process heat provided by the heat medium heaters (Therminol). The lean TEG discharged from the reboiler will be circulated back to the absorber via an electric pump with a maximum design capacity of 14.7 gallons per minute (gpm) where the cycle is repeated. The water vaporized in the reboiler is discharged from the Still Vent. Some organic compounds are absorbed by the TEG along with water vapor in the contactor. As a consequence, vapor emissions from the reboiler Still Vent may also contain n -hexane, and benzene, toluene, ethylbenzene and xylenes (collectively known as BTEX compounds) and other organic HAP if such compounds are present in the wet gas. The Still Vent exhaust will discharge to a BTEX Unit (condenser) where water and some hydrocarbons will condense. Non - condensed gas/vapor discharged from the condenser will be routed to an enclosed combustor to oxidize the organic constituents. Uncontrolled and controlled emissions of VOC and HAP compounds from the TEG Flash Separator and Still Vent were estimated using the GRI GLYCaic program (version 4.0). See Section 3.1.4 for more data on the emissions from the TEG Unit. 2.1.4 Heat Medium (Process Heat) Process heat for the TEG regeneration process will be provided by a closed loop heat medium (Therminol) system. The heat medium heater(s) will be natural gas-fired and each will have a design rating of 14 MMBtu/hr. See Section 3.1.3 for more data on the emissions from the heat medium heaters. 2.1.5 Power Generation There will be three natural gas-fired Caterpillar G3512LE generator sets used to generate primary power for the facility. Each of the engines has a site rating of 782 bhp at 1,200 rpm. These 4SLB low -NO, design engines will also each be equipped with an oxidation catalyst designed to control CO, VOC, and formaldehyde emissions. See Section 3.1.2 for more data on the emissions from these engines. 05252-008-140 2-2 October 2036 • ENSR 2.1.6 Emergency Flare A vertical elevated open -flame air -assisted flare will be designed and operated primarily to oxidize (combust) hydrocarbons during over -pressure conditions that may occur during periods of startup or shutdowns, including planned or emergency shutdown (ESD) events. The flare will not be a control device for any source. Section 3.2.3 contains details on the emissions from the flare. 2.2 Existing CCGTF I Modifications In addition to the new sources that will be installed as a result of CCGTF II, there will also be some minor modifications to a few of the existing sources at CCGTF I. • All three existing generator engines will be permitted to operate concurrently (Permit No. 05GA0068 currently allows concurrent operation of only two engines on a 12 -month rolling basis) • Under terms and conditions of OXY's gas delivery contract with Enterprise, the existing low- temperature (propane refrigeration) process unit will not be used and the facility will not extract or handle NGL. The gas processing unit will be kept on standby. Some portion or all of the system will be purged with inert gas (nitrogen) during the inactive period. • The existing low-temperature ethylene glycol gas hydrate inhibition process (Permit No. 05GA0069) will be removed, since no low-temperature processing will occur. The low temperature EG system will be replaced with a TEG unit. if OXY re -activates the NGL extraction process unit, the TEG system will be used to dehydrate the inlet gas, prior to the Gas/Gas exchanger inlet and prior to low-temperature processing. The TEG unit process vents will be controlled in accordance with Colorado AQCC Reg. 7. The Flash Separator vent will be controlled by an enclosed combustor. Emissions from the Still Vent will be controlled by a BTEX Unit (condenser) and noncondensibles discharged from the condenser will be burned in an enclosed combustor. • The existing flare (Permit No. 05GA0173) will be returned to emergency service and will no longer receive emissions from any source. • Finally, on September 19, 2008 OXY submitted a permit application for the modification of the CCGTF I Condensate Tank Battery. This modification is not part of the CCGTF II project, however, as a result of the centralized condensate handling operation at CCGTF 1, there will be additional sources of combustion emissions (3-phase separator heater, heater treater, and three vapor combustion units for VOC emission control) that were included in this application's modeling analysis. See Section 3.2 for details on the emissions increases/decreases from these minor modifications to the existing sources. 2.2.1 Existing Generator Engines Fuel consumption and emission limitations set out in Permit No. 05GA0068 are based on the operation of only two of the three permitted engines concurrently on a 12 -month rolling total basis. Typically, only two of the three units are operated at a time, but occasionally a third engine may be brought online and warmed up while two engines are running. To avoid potential violations of the permit terms and conditions for 12 -month total fuel consumption and emissions of NOx, CO and VOC, OXY is submitting a revised APEN and request to modify Permit No. 05GA0068 to allow unrestricted operation of the three existing generator engines. No physical modification to the engines will occur; only revisions to Permit No. 05GA0068 are requested. The modeling presented in Chapter 5.0 demonstrates compliance with the national ambient air quality standards with all three engines operating at full capacity 8,760 hours per year; therefore, there is an increase in combustion emissions from the operation of the third engine. 05252-008-140 2-3 October 2008 • • ENSR 2.2.2 Existing EG Unit Since low-temperature processing will no longer occur at CCGTF I, the existing low-temperature EG Unit (Permit No. 05GA0069) will be replaced with a TEG dehydration unit (TEG Unit). The replacement TEG Unit will have uncontrolled VOC emissions that exceed 15 tons per year (tpy), so the unit will be subject to air pollution control requirements set out in AQCC Reg. 7 (90% control). The flash separator process vent will be connected to an enclosed vapor combustor unit (VCU) conforming to Reg. 7. The TEG regenerator still vent emissions will also be controlled. Still vent emissions will be routed to a BTEX Unit (condenser). Non - condensable gas/vapor exiting the condenser will be routed to the VCU. VOCs emissions will be reduced by 98 percent or more. As a result of increased HAP emissions, primarily formaldehyde, from the CCGTF II, the combined facility will now be a major source of HAPs and subject to 40 CFR 63, Subpart HH. Actual annual emissions of benzene from the replacement TEG Unit will be less than 1.0 tpy, so the unit will not be subject to MACT control standards. Records will be maintained documenting that actual annual benzene emissions do not exceed MACT thresholds. 2.2.3 Existing Flare The existing flare at CCGTF I (Permit No. 05GA0173) currently receives via the Flare Knockout Drum small volumes of gas flashed from condensate received by TK -415 and TK -416 and gas vented from the existing EG Flash Separator. These two sources will be disconnected from the flare system and an enclosed combustor will be used instead to control VOC/HAP emissions. The flare will only be used for emergency shutdown (ESD) events. 2.2.4 Existing Condensate Tank Battery A detailed discussion summarizing the proposed modification to the CCGTF I Condensate Tank Battery along with the appropriate APENs and supporting emissions calculations were provided in the construction permit application submittal package dated September 19, 2008. The new sources and/or modifications to existing sources as a result of the modification to the CCGTF [Condensate Tank Battery include: • three (3) 400 -bbl (each) condensate storage tanks: one new tank (TK -417) and two existing tanks (TK -415 and TK -416); • one (1) new 400 -bbl Separator Feed Tank (TK -5235); • one (1) Relief Knockout vessel (V-5115); • one (1) new three-phase separator (V-5240) and associated natural gas-fired heater (0.8 MMBtu/hr); • one (1) new 0.5 MMBtu/hr natural gas-fired heater treater (V-5245); • three (3) natural gas-fired enclosed vapor combustion units (VCU -5116, -5117, -5118); • one (1) new Water Surge Tank (T-5310); one (1) new separator feed pump (P-5234); • one (1) new water pump (P-5311) and piping to the Water Plant; • one (1) new Condensate Unloading Pump (P-5234); and • new truck loading station. It should be noted that the number of VCUs necessary for VOC emission control was not determined at the time of the September 19, 2008 submittal. As such the application stated that one or more VCUs would be installed. However, the total capacity (MMBtufhr) was known and accounted for in the emission calculations. Further the application package did not include the gas-fired heater for the three-phase separator. In the short 05252-008-140 2-4 October 2008 ENSR amount time since the application submittal, OXY has determined that the three-phase separator will have a 0.8 MMBtulhr gas-fired heater associated with it_ An APEN for this unit is contained in Appendix A of this application. The emissions from the combustion units listed above have been included in the modeling analysis contained in Chapter 5.0. The remodeled sources include: • V-5245 — natural gas-fired heater treater (Model ID HTRTR1); • V-5240 — natural gas-fired heater for the three-phase separator (Model ID HTRTR2); • VCU -5116 — vapor combustion unit (Model ID VCU1); • VCU -5117 — vapor combustion unit (Model ID VCU2); • VCU -5118 — vapor combustion unit (Model ID VCU3). See Section 3.2.4 for detailed emissions increases/decreases associated with the Condensate Tank Battery modification. In addition, for your convenience the complete September 19, 2008 construction permit application package is contained in Appendix D. 05252-408-140 2-5 October 21708 cC Z • Site Location iLLl7VN'SJ001-0 Eu44VoN Wlf1 Figure 2-1 Site Location (Topa) Map • ENSR 4374000 z 4373950 a) a, E 4373900 rn Z 4373850 H 4373800 736550 736600 736650 736700 736750 736800 736850 UTM Fasting (meters. NAD27) CCGTF l Sources CCGTF II Sources CAI( USA Cam Creek Gas Tfeatmea! Facurty Faciey Piot Plan Dale 1Q062008 Figure 2-2 Facility Plot Plan 05252-008-140 2-7 0 clobts 2008 • • ENSR 3.0 Emissions Summary 3.1 Proposed Project (CCGTF II) Criteria Pollutant Emissions OXY is proposing to expand the existing CCGTF I by constructing a new compressor station (CCGTF II) adjacent/contiguous to CCGTF I. The new CCGTF II will be capable of compressing and treating up to 60 MMscfd of gas. As stated previously, CCGTF II will be designed for dehydration and compression only and not NGL extraction. This proposed expansion project is to be classified as a minor modification with respect to PSD regulations. The new emissions sources from the proposed project include: • Three (3) gas-fired Caterpillar G3616LE internal combustion (IC) compressor engines; • Three (3) gas-fired Caterpillar G3512LE IC generator engines; • Two (2) gas-fired heat medium heaters; • One (1) 60 MMscfd TEG dehydration unit with the flash separator vent controlled by an enclosed combustor and TEG regenerator still vent controlled by a BTEX Unit (condenser) followed by an enclosed combustor; and • One (1) emergency flare. Lean -burn design on the Caterpillar engines will minimize oxides of nitrogen (NOx) emissions. All of the Caterpillar G3616LE and G3512LE IC engines will be installed with an oxidation catalyst to minimize carbon monoxide (CO),, volatile organic compounds (VOC), and formaldehyde (HCHO) emissions. Pipeline -quality gas will be used minimizing emissions of sulfur dioxide (SO2) and particulate matter with an aerodynamic diameter of 10 microns or less (PM10). The facility will be permitted to operate 24 hours per day and 8,760 hours per year for all emissions sources. Detailed emissions calculations and vendor specifications for the emission units are located in Appendix B. 3.1.1 Internal Combustion Compressor Engines One of the primary sources of emissions at the CCGTF II will be three Caterpillar engines driving compressors. Current design calls for the installation of three Caterpillar G3616LE IC engines. The IC engines are expected to typically operate at 100 percent load, but may, at times, be operated at less than 100 percent load. The IC engines will fire pipeline -quality gas, supplied directly from the facility. Maximum hourly emission rates for each pollutant were established after reviewing the vendor provided data over the range of 100, 75, and 54 percent loads for the IC engines, which represent the range of expected operating conditions. Maximum hourly emissions from each IC engine were calculated from manufacturer supplied site rating (bhp) and guaranteed emission factors (g/brake hp [bhp] -hr) for NOx, CO, and VOC. 502 emissions were calculated using the manufacturers' supplied maximum fuel consumption data (Btu/bhp-hr) for the range of operating loads, a maximum fuel gas sulfur content of 5.0 grains per 100 standard cubic feet (gr/100 scf), and an estimated lower heating value of 966 Btu/scf. PM10 emissions were calculated using manufacturers' supplied maximum fuel consumption data (Btu/bhp-hr) and a PM,p emission factor (filterable and condensable) for natural gas-fired reciprocating engines from the U.S. Environmental Protection Agency's (USEPA's) Compilation of Air Pollutant Emission Factors, Fifth Edition AP -42, Section 3.2 (USEPA 2000). Each Caterpillar G3616LE engine will be equipped with an oxidation catalyst. Manufacturer -specified control efficiencies for CO, VOC, and HCHO were incorporated into the hourly air pollutant emission rates for these three pollutants. Table 3-1 summarizes the IC engine operating parameters, and maximum hourly potential emission rates of NOx, CO, VOC, SO2, and PM10 for the Caterpillar G3616LE engines. Vendor specification 05252-008-140 3-1 October 2008 • ENSR sheets for the Caterpillar engine emission rates and manufacturer -designated control efficiencies are provided in Appendix B-3. Table 3-1 Hourly Criteria Pollutant Emission Rate Summary — Caterpillar G3616LE IC Engines Pollutant Emissions for One G3616LE IC Engine 100% Load 75% Load 54% Load NOx 6.97 lb/hr 5.22 lb/hr 3.77 lb/hr CO 1.74 Iblhr 1.31 lb/hr 0.95 lip/hr VOC 3.96 lbfhr 3.12 lb/hr 2.37 lb/hr SO2 0.46 tb/hr 0.36 Iblhr 0.28 lb/hr PM10 0.31 lb/hr 0.24 lb/hr 0,19 lblhr Annual emissions for each pollutant were conservatively estimated using the maximum hourly emission rate associated with the worst-case load, and the worst-case scenario of 8,760 hours of operation/year. Annual criteria pollutant emission rates for the IC engines are presented in Table 3-2. Detailed emission calculations for the engines are provided in Appendix B-1 (Table B-1.1). Table 3-2 Annual Criteria Pollutant Emission Rate Summary — Caterpillar G3616LE IC Engines Pollutant Annual Emission Rates One Engine Three Engines NO% 30.5 tpy 91.5 tpy CO 7.6 tpy 22.9 tpy VOC 17.4 tpy 52.1 tpy SO2 2.0 tpy 6.0 tpy PM10 1.4 tpy 4.1 tpy 3.1.2 Internal Combustion Generator Engines In addition to the three Caterpillar engines driving compressors there will also be three Caterpillar engines driving generators for power supply at CCGTF II. Current design calls for the installation of three Caterpillar G3512LE IC engines. The IC engines are expected to typically operate at 100 percent load, but may, at times, be operated at less than 100 percent load. The IC engines will fire pipeline -quality gas, supplied directly from the facility. Maximum hourly emission rates for each pollutant were established after reviewing the vendor provided data over the range of 100, 75, and 55 percent loads for the IC engines, which represent the range of expected operating conditions. Maximum hourly emissions from each IC engine were calculated from manufacturer supplied site rating (bhp) and guaranteed emission factors (g/bhp-hr) for NOx, CO, and VOC. SO2 emissions were calculated using the manufacturers' supplied maximum fuel consumption data (Btu/bhp-hr) for the range of operating loads, a maximum fuel gas sulfur content of 5.0 gr/100 scf, and an estimated lower heating value of 966 Btu/scf. PM10 emissions were calculated using manufacturers' supplied maximum fuel consumption data (Btulbhp-hr) and a PM10 emission factor (filterable and condensable) for natural gas-fired reciprocating engines from the U.S. Environmental Protection Agency's (USEPA's) Compilation of Air Pollutant Emission Factors, Fifth Edition AP -42, Section 3.2 (USEPA 2008). 05252-008-140 3-2 October 2008 • • ENSR Each Caterpillar G3512LE engine will be equipped with an oxidation catalyst. Manufacturer -specified control efficiencies for CO, VOC, and HCHO were incorporated into the hourly air pollutant emission rates for these three pollutants. Table 3-3 summarizes the IC engine operating parameters, and maximum hourly potential emission rates of NOx, CO, VOC, SO2, and PM10 for the Caterpillar G3512LE engines. Vendor specification sheets for the Caterpillar engine emission rates and manufacturer -designated control efficiencies are provided in Appendix B-3. Table 3-3 Hourly Criteria Pollutant Emission Rate Summary - Caterpillar G3512LE IC Engines Pollutant Emissions for One G3512LE IC Engine 100% Load 75% Load 54% Load NOx 2.59 l blhr 1.94 lblhr 1.42 lb/hr CO 0.34 Ib/hr 0.25 lb/hr 0.19 lb/hr VOC 0.38 lb/hr 0.30 lb/hr 0.25 lb/hr SO2 0.09 lb/11r 0.07 113/hr 0.05 lb/hr PM10 0.06 lblhr 0.05 lb/hr 0.04 Iblhr Annual emissions for each pollutant were conservatively estimated using the maximum hourly emission rate associated with the worst-case load, and the worst-case scenario of 8,760 hours of operation/year. Annual criteria pollutant emission rates for the IC engines are presented in Table 3-4. Detailed emission calculations for the engines are provided in Appendix B-1 (Table B-1.2). Table 3-4 Annual Criteria Pollutant Emission Rate Summary - Caterpillar G3512LE IC Engines Pollutant Annual Emission Rates (tpy) C One Engine Three Engines NOx 11.3 tpy 34.0 tpy CO 1.5 tpy 4.5 tpy VOC 1.7 tpy 5.0 tpy SO2 0.4 tpy 0.3 tpy 1.2 tpy 0.8 tpy PM10 3.1.3 Heat Medium Heaters The CCGTF II design includes provisions for two natural gas-fired heat medium (Therminol) heaters. The heat medium heaters will provide process heat for TEG regeneration and plant operations. Emissions from the heat medium heaters are based on the maximum design rating of 14.0 MMBtulhr. USEPA emission factors from AP -42, Chapter 1.4, were used to estimate emissions, with the exception of SO2 (USEPA 2008). SO2 emissions were calculated using a maximum natural gas sulfur content of 5.0 gr/100 scf, and a lower heating value of 966 Btu/scf. Annual PTE emissions from the heat medium heaters are based on maximum operation of 8,760 hrlyr. Criteria pollutant emissions calculations for the heat medium heaters are summarized in Table 3-5. Detailed emission calculations for the heaters are provided in Appendix B-1 (Table B-1.3). 05252-008-140 3-3 October 2008 ENSR Table 3-5 Summary of Criteria Pollutant Emissions - Heat Medium (Therminol) Heaters Pollutant Maximum Emissions One Heater Two Heaters NO„ 1.45 lb/hr 6.35 tpy 2.9 Ibihr 12.7 tpy CO 1.22 lb/hr 5.33 tpy 2.44 Ibihr 10.7 tpy VOC 0.08 lb/hr 0.35 tpy_ 0.16 Ibihr 0.7 tpy SO2 0.21 lb/hr 0.91 tpy 0.42 Ib/hr 1.8 tpy PM,0 0.11 lb/hr 0.48 tpy 0.22 Iblhr 1.0 tpy 3.1.4 Glycol Dehydration Unit The TEG Unit has two process vents: flash separator; and still vent. Process heat for TEG regeneration (reboiler) will be provided by the heat medium heaters (the reboiler is not fuel -fired). As mentioned in the process description, flash gas from the glycol flash drum will be sent to an enclosed combustor (VCU) for VOC and HAP destruction, while overhead gas from the glycol regenerator still vent will be sent to a BTEX unit followed by the VCU for VOC and HAP destruction. The TEG Unit control system (condenser and combustor) design and operation will conform to the applicable provisions of Colorado AQCC Reg. 7. The GLYCaIc model (version 4.0) was used to estimate uncontrolled and controlled emissions of VOC and HAP from the TEG dehydration unit still vent. GLYCaIc is a PC-based program developed by the Gas Research Institute (GRI) and Radian Corporation to estimate emissions from glycol dehydration unit process vents (GRI 1996). The program has been evaluated and approved by EPA for estimating HAP emissions from glycol dehydration unit regenerator vents and flash vessels (EPA 1995).OXY used a variety of PROMAXTM simulation runs in order to determine inlet gas composition and process conditions. Table 3-6 provides a summary of the controlled VOC emissions from the TEG dehydration unit. Table B-1,4 contains the detailed emission calculations for the VCU controlling the VOC emissions from the TEG unit. A printout of the GRI-GLYCaIc program can be found in Appendix B-1 immediately following Table B-1.4. It should be noted that the printout does not account for the 95% control efficiency from the VCU for the emissions coming off the Flash Tank, however, Table 3-6 below does account for the additional control. Table 3-6 Summary of Criteria Pollutant Emissions - TEG Dehydration Unit Emission Point VOC Emissions Hourly Annual Regenerator Still Vent (Controlled by BTEX Unit & Enclosed Combustor) 0.18 Ibihr 0.77 tpy Flash Separator (Controlled by Enclosed Combustor) _ 0.10 Ibihr 0.45 tpy Total 0.28 lb/hr 1.22 tpy 3.1.5 Emergency Flare The CCGTF II design includes provisions for one emergency flare. The flare will combust vented emissions during process upsets. Preliminary design analysis depicts that a throughput of 250 scf/hr (2.2 MMscf/yr) of gas will be sent to the flare on a continual non -emergency basis. This continuous throughput includes both the pilot gas and the maximum amount of purge gas. USEPA emission factors from AP -42, Chapter 13.5, were used to estimate emissions, with the exception of SO2 (USEPA 2008). SO2 emissions were calculated using a maximum natural gas sulfur content of 5.0 grains per 100 scf, and an estimated natural gas heating value of 05252-008-140 3-4 October 2008 ENSR 2,000 Btu/scf. Annual PTE emissions from the flare are based on maximum operation of 8,760 hours/year (pilot and purge gas). Criteria pollutant emissions calculations for the flare are summarized in Table 3-7. Detailed emission calculations for the flare are provided in Appendix B-1 (Table B-1.5). Table 3-7 Summary of Criteria Pollutant Emissions — Emergency Flare Pollutant Maximum Emissions Hourly Annual NO„ 0.03 lb/hr 0.15 tpy CO 0.19 lb/hr 0.81 tpy VOC 0.07 Ibfhr 0.31 tpy SO2 0.004 lb/hr 0.02 tpy _ PM10 0.007 lb/11r 0.03 tpy 3.2 Existing Source Modifications 3.2.1 Caterpillar G3512 Generator Sets — Permit No. 05GA0068 As discussed in Section 2.2 as part of this modification OXY would like to operate all three of their existing Caterpillar G3512 generator sets that are used to generate power at full capacity 8,760 hr./yr each, instead of only two as is currently permitted. This will result in an increase in total potential emissions from the third engine. Table 3-8 summarizes the annual criteria pollutant emissions rate increase resulting from operating the third engine and the resulting total emission rates for all three engines. These emission rates are based on the currently permitted emission rates as contained in Construction Permit 05GA0068 Initial Approval Modification 1. All three of these engines were modeled at full capacity, see Chapter 5.0 for the modeling results. Table 3-8 Annual Criteria Pollutant Emission Rate Summary — Existing Caterpillar G3512 IC Engines Pollutant Annual Emission Rates — Existing Caterpillar G3512 IC Engines Currently Permitted Emission Rates New PTE for Three Engines Emissions Increase NO, 39.6 tpy 59.4 tpy 19.8 tpy CO 1.5 tpy 2.25 tpy 0.75 tpy VOC 2.9 tpy 4.35 tpy 1.45 tpy SO2 -- 1.08 tpy 0.36 tpy PM10 -- 0.75 tpy 0.25 tpy 3.2.2 EG Unit — Permit No. 05GA0069 Since low-temperature processing will no longer occur at CCGTF I, the existing low-temperature EG Unit (Permit No. 05GA0069) will be replaced with a TEG dehydration unit (TEG Unit). The replacement TEG Unit will have uncontrolled VOC emissions that exceed 15 tons per year (tpy), so the unit will be subject to air pollution control requirements set out in ADCC Reg. 7 (90% control). The flash separator process vent will be connected to an enclosed vapor combustor unit (VCU) conforming to Reg. 7, The TEG regenerator still vent emissions will also be controlled. Still vent emissions will be routed to a BTEX Unit (condenser). Non - condensable gas/vapor exiting the condenser will be routed to the VCU. VOCs emissions will be reduced by 98 percent or more. The GLYCaIc model (version 4.0) was used to estimate uncontrolled and controlled emissions of VOC and HAP from the TEG dehydration unit process vents. OXY used a variety of PROMAXTM simulation runs in order to determine inlet gas composition and process conditions. 05252-008-140 3-5 October 2008 ENSR The current EG unit permit (Permit No. 05GA0069) limits VOC emissions to 8.4 tpy without control. The BTEX unit in combination with the VCU will substantially reduce VOC emissions from the replacement TEG Unit to 0.83 tpy, for an overall decrease in VOC emissions of 7.6 tpy. A printout of the GRI-GLYCaIc program can be found in Appendix B-1 immediately following the printout of the new TEG unit. It should be noted that the printout does not account for the 98% control efficiency from the VCU for the emissions coming off the Flash Tank, however, the 0.83 tpy emission rate does account for the additional control. 3.2.3 Emergency Flare — Permit No. 05GA0173 As discussed previously the existing flare at CCGTF I (Permit No. 05GA0173) currently receives via the Flare Knockout Drum small volumes of gas flashed from condensate received by TK -415 and TK -416 and gas vented from the existing EG Flash Separator. These two sources will be disconnected from the flare system and an enclosed combustor will be used instead to control VOC/HAP emissions. The flare will only be used for emergency shutdown (ESD) events. The existing flare is designed for a continual non -emergency gas throughput basis of 250 scf/hr (2.2 MMscf/yr). This continuous throughput includes both the pilot gas and maximum purge amount of purge gas. USEPA emission factors from AP -42, Chapter 13.5, were used to estimate emissions, with the exception of SO2 (USEPA 2008). SO2 emissions were calculated using a maximum natural gas sulfur content of 5.0 grains per 100 scf, and an estimated natural gas heating value of 2,000 Btu/scf. Table 3-9 summarizes the emissions from the existing flare. Table 3-9 Annual Criteria Pollutant Emission Rate Summary — Existing Flare Permit No. 05GA0173 Pollutant Annual Emission Rates — Existing Flare Permit No. 05GA0173 Currently Permitted Emission Rates New PTE for Flare Emissions Decrease NO, 0.9 tpy 0.15 tpy -0.75 tpy CO 3.3 tpy 0.81 tpy -2.49 tpy VOC 1.3 tpy 0.31 tpy -0.99 tpy 3.2.4 Existing Condensate Storage Tanks — Permit No. 06GA1232 As discussed in Section 2.2.4, OXY submitted a construction permit application on September 19, 2008 for the centralization of the condensate handling operations from the three areas of operation (Valley, Mesa and Logan Wash). The centralized tank battery will be located at CCGTF I. The September 19, 2008 modification is not part of the CCGTF II project however, as discussed previously there will be an increase in combustion emissions resulting from heating needed for separation as well as the addition of three VCUs for control of VOC emissions from the condensate tanks. The increased emissions from these new combustion sources have been included in the CCGTF II project's modeling analysis to ascertain compliance with the NAAQS. One new 400 -bbl "Separator Feed Tank" (TK -5235) and one new 400 -bbl condensate storage tank (TK -417) will be installed. The two existing condensate tanks (TK -415 and TK -416) will be converted from flashing tanks to stabilized condensate storage tanks. In addition, one new 400 -bbl produced water tank will be installed (T-5310). The new Separator Feed Tank will receive mixed liquids from the facility's Inlet Slug Catcher, which receives field gas and produced liquids from the Grand Valley Gathering Systems. The condensate received by Separator Feed Tank will be at Inlet Slug Catcher pressure conditions and will contain solution gas, so flash emissions will occur from the Separator Feed Tank when the pressure is reduced to atmospheric. All four hydrocarbon tanks and the three-phase separator/heater treater will be connected to the new VCUs by a closed vent system. Mixed liquids from the Separator Feed Tank will be routed to a new three-phase separator and heater treater to separate water, condensate and any gas still in solution. Water will be routed from the separator/heater treater to the new 400 -bbl produced water surge tank. Stabilized condensate (no solution gas) will be routed from the separator/heater treater to three condensate storage tanks (TK -415/416/417). The 05252-008-140 3-6 October 2008 • • • ENSR condensate received by the three storage tanks will be at near -atmospheric conditions, so no flash emission will occur. Working and standing losses may however occur from vapor displacement during filling operations and from diurnal fluctuations in ambient temperature. Condensate will be piped to a new truck loading station located just east of the CCGTF. Water will be pumped from the Water Surge Tank (T-5310) to the Water Plant. E&P Tank 2.0 was used to determine the emissions from the Separator Feed Tank, while EPA TANKS V.4.0.9d was used to estimate working and standing losses from the three condensate storage tanks (TK -415/416/417), all of which will be controlled by the new VCUs to a level of 98% or better. Condensate truck loading emissions were estimated using an emission factor derived from equation 1 of AP -42 Chapter 5.2. Truck loading emissions will be uncontrolled. USEPA emission factors from AP -42, Chapter 1.4, were used to estimate emissions for the heaters associated with the separation process and for the VCUs, with the exception of SO2 (USEPA 2008). SO2 emissions were calculated using a maximum natural gas sulfur content of 5,0 gr/100 scf, and a heating value of 966 Btu/scf and 2,000 Btu/scf respectively. Table B-1.6 of Appendix B contains the detailed emission calculations for 0.8 MMBtufhr 3 -Phase Separator heater that was not included in the September 19, 2008 submittal. It should be noted that the proposed modification to the CCGTF I Tank Battery will result in a substantial decrease in VOC emissions. The existing condensate tanks (two) in operation at CCGTF I received an Initial Approval Construction Permit No. 06GA1232 on October 17, 2007. The permit is for two 400 barrel (bbl) capacity condensate tanks without control. The current permit limits emissions of VOC to 55.3 tpy without control. This is based on an annual condensate throughput of 7,300 bbifyear. As discussed in detail in the September 19, 2008 permit application, the centralization of condensate handling operations will increase the annual condensate handled at CCGTF I from 7,300 bbl/year to 96,360 bbliyear (264 bbl/day), while decreasing the total VOC emissions as a result of the three VCUs to be installed for VOC control. Table 3-10 summarizes the emissions increases and decreases resulting from the centralization of the condensate handling operations. Table 3-10 Emission Rate Summary — Condensate Tank Battery Permit No. 06GA1232 Annual Emission Rates — Existing Condensate Storage Tanks Permit No. 06GA1232 Emission Unit NO), CO VOC TK -415 & TK -416 — — 55.3 tpy Annual Emission Rates from Proposed Centralized Tank Battery at CCGTF I Emission Unit NOx CO VOC Heater Treater 0.22 tpy 0.19 tpy 0.01 tpy 3 -Phase Separator Heater 0.36 tpy 0.30 tpy 0.02 tpy VCU #1 0.66 tpy 0.55 tpy — VCU #2 0.66 tpy 0.55 tpy — VCU #3 0.66 tpy 0.55 tpy — Total Condensate Tanks 1 -- -- 10.79 tpy Truck Loading — -- 13.91 tpy Total 2.56 tpy 2.14 tpy 24.73 tpy Total Emissions Increases 1 Decreases NOx CO VOC 2.56 tpy 2.14 tpy ( 30.57) tpy 1The VOC emissions from the condensate tanks will be emitted through the VCU s (#1 through #3). 05252-008-140 3-7 October 2008 • ENSR As shown in Table 3-10, there will be a slight increase in NO and CO emissions and an overall VOC emission decrease of 30.6 tpy as a result of installing emission controls. 3.3 Total Project Criteria Pollutant Emissions Summary Table 3-11 combines the criteria pollutant emission rates summarized in this section to establish the PTE for the CCGTF II project. Table 3-12 summarizes the overall increases/decreases in emissions taking into account the change in emissions from the existing sources discussed in Section 3.2. The existing CCGTF I is not a major source with respect to PSD. The addition of the CCGTF II source emissions will not trigger review under PSD, as the total emissions increase is less than 250 tpy for each criteria pollutant. See Section 4.2 for a more detailed discussion on PSD applicability. Table 3-11 Annual Criteria Pollutant Emissions Summary (tpy) - CCGTF II Emission Unit NO, CO VOC SO2 PM10 Cat G3616LE #1 30.51 7.63 17.37 2.00 1.35 Cat G3616LE #2 30.51 7.63 17.37 2.00 1.35 Cat G3616LE #3 30.51 7.63 17.37 2.00 1.35 Cat G3512LE #1 11.33 1.49 1.66 0.39 0.26 Cat G3512LE #2 11.33 1.49 1.66 0.39 0.26 Cat G3512LE #3 11.33 1.49 1.66 0.39 0.26 HMH #1 6.35 5.33 0.35 0.91 0.48 HMH #2 6.35 5.33 0.35 0.91 _ 0.48 TEG Dehydration Unit' -- - 1.22 - VCU #4 0.66 0.55 -- 0.09 0.05 Emergency Flare 0.15 0.81 0.31 0.02 0.03 Totals 139.0 39.4 59.3 9.1 5.9 _ 'The VOC emissions from the TEG Dehydration Unit are emitted through the VCU #4. Table 3-12 Total Project Emissions Increases/Decreases Summary (tpy) Emission Unit NOx CO VOC SO2 PM,o CCGTF II Total 139.0 39.4 59.3 9.1 5.9 CCGTF I Modified Sources Cat 3512 IC Engine 19.80 0.75 1.45 0.36 0.25 TEG Dehydration Unit 1 -- - (7.60) -- - Emergency Flare (0.75) (2.49) (0.99) - - Heater Treater 0.22 0.19 0.01 - - 3 -Phase Separator heater 0.36 0.30 0.02 - - VCU #1 0.66 0.55 - -- - VCU #2 0.66 0.55 - - VCU#3 0.66 0.55 -- -- - Total Condensate Tanks' (44.51) -- - Truck Loading 13.91 Totals 160.61 39.80 21.59 9.46 6.15 'VOC emissions from the TEG Dehydration Unit and condensate tank battery are emitted through the VCUs. 05252-008--140 3-8 October 2008 • • ENSR 3.4 Hazardous Air Pollutant Emissions Summary Emissions of HAPs from proposed emission sources at the CCGTF II have been estimated using a combination of vendor -supplied performance data/emission guarantees, emission factors from USEPA's Compilation of Air Pollutant Emission Factors, Fifth Edition AP -42, Sections 1.4, 3.2, and 13.5 (USEPA 2008), and emission estimating software programs (GRi_GLYCalc 4.0, E&P Tank 2.0, EPA TANKS v.4.O.9d). The Caterpillar IC engines` formaldehyde emission factors are manufacturer -specified emission factors taking the control efficiency of an oxidation catalyst into account. Unit design parameters and operational practices have been incorporated into the analysis to make the emission estimates realistic and representative of on-site conditions. The summary presented below has been prepared for the HAP emission sources for the proposed CCGTF II facility, which include the following: • Three gas-fired Caterpillar G3616 IC engines; • Three gas-fired Caterpillar G3512LE IC engines; • Two gas-fired heat medium heaters; • One TEG unit (process vents); and • One emergency flare. Calculated HAPs emissions confirm that the CCGTF II by itself will be a major HAP source subject to pre - construction permitting under 40 CFR 63 (Maximum Achievable Control Technology [MALT]). A summary of HAP emissions from the facility is provided in Table 3-13, and detailed HAP emission calculations are provided in Appendix B-2. Table 3-13 Summary of Hazardous Air Pollutant Emissions — CCGTF II Emission Unit Total. HAP Emissions from Emission Units Maximum Individual HAP Caterpillar G3616LE IC Engines (3) 16.8 tpy 12.87 tpy Formaldehyde Caterpillar G3512LE IC Engines (3) 2.34 tpy 1.58 tpy Formaldehyde Heat Medium Heaters (2) 0.24 tpy 0.23 tpy Hexane TEG Dehydration Unit 1 -- ._ VCU #4 0.46 tpy 0.19 tpy Toluene Emergency Flare 0.01 tpy 0.003 tpy Propylene Totals 19.85 tpy 14.45 tpy Formaldehyde Emissions from the TEG Dehydration Unit are emitted through the control device VCU #4. The new engine and dehydration APEN forms include non -criteria pollutant emission rate information. The general APEN forms do not include non -criteria pollutant information and indicate that the APCD Non -Criteria Reportable Air Pollutant Addendum form should be used to report non -criteria pollutants. In order to be exempt from filing a non -criteria APEN, individual emission points of non -criteria reportable pollutants must have uncontrolled actual emissions less than the de minimis levels in Appendix A of Regulation No. 3. In accordance with Regulation No. 3, Appendix A, Method for Determining De Minimis Levels for Non -Criteria Reportable Pollutants, an analysis was conducted to determine which HAPs, if any, exceeded the de minimis levels for non -criteria reportable pollutants. The release height for the various emission points all fall within Scenario 2. 05252-008-140 3-9 October 2008 • ENSR For the HMHs and emergency flare, each non -criteria reportable pollutant was assigned the appropriate bin (A, B, or C) according to Regulation No. 3, Appendix B. Emissions were calculated for each non -criteria reportable pollutant to be emitted, in Ibsiyear. The emission rates were compared with the Scenario 2 de minimis levels for Bin A (125 lbs./year), Bin B (1,250 lbslyear) and Bin C (2,500 lbslyear). After conducting this analysis, there were no non -criteria reportable pollutants that exceeded their respective de minimis levels for these sources, as such the non -criteria pollutant Addendum Form was not required to be completed. 05252-008-140 3-10 October 2008 ENSR 4.0 Regulatory Applicability 4.1 General This section discusses the potential applicability of New Source Review (NSR) regulations for attainment area pollutants (Prevention of Significant Deterioration) and nonattainment area pollutants, federal New Source Performance Standards (NSPS) and NESHAPs, and applicable Colorado Air Quality Control Commission (AQCC) Regulations applicable to the proposed modification. The proposed modification will comply with all applicable air quality regulations. Per the requirements set forth in AQCC Reg. 3, Parts A and B, an Application for Construction Permit and Air Pollution Emission Notices (APENs) have been completed and are provided in Appendix A. 4.2 Applicability of PSD — New Source Review There are three basic criteria used to determine PSD applicability. The first and primary criterion is whether the proposed project is sufficiently large in terms of emissions to be considered a "major" stationary source or a "major" modification to an existing "major" stationary source. Source size is defined in terms of "potential to emit"', which is its capability at maximum design capacity to emit a pollutant, except as constrained by federally enforceable permit conditions. The PSD rules contained in AQCC Reg. 3, Part D,VI, AQCC Reg. 3, Part D.Il.A.24(a) state that a facility is classified as a "major stationary source if the facility emits or has the potential to emit: i. 100 tpy or more of a regulated air contaminant in an area designated attainment for that air contaminant and the facility is a source classified as a Categorical Source; and ii. 250 tpy or more of a regulated air contaminant in an area designated attainment for that air contaminant. The definition for major stationary source in AQCC Reg. 3, Part D.II.A.24(a)(i) lists the Categorical Sources listed in 40 CFR §52.21. Gas plants and/or compressor stations are not listed in that section; therefore, the major source emission rate threshold for this source type is 250 tpy. The CCGTF I is an existing minor stationary source with respect to PSD because it has the potential to emit less than 250 tpy of all regulated pollutants. The proposed CCGTF II is not one of the 28 named source types listed in Section 169 of the CM; therefore, 250 tpy is the threshold for major source status. As shown in Table 3-11 and Table 3-12, the proposed facility's potential emissions are below 250 tpy for all regulated pollutants; therefore, PSD review does not apply. 4.3 Applicability of Title V — Major Source Operating Permit The State of Colorado has authority to implement the major source operating permit program (Title V) in accordance with the requirements of 40 CFR Part 70 and Title V of the 1990 CAA Amendments. The operating permit regulations are contained in AQCC Regulation 3, Part C. The minimum requirements for operating permit application contents are provided in Regulation 3, Part C.III — Operating Permit Application Requirements. As stated previously, the existing CCGTF I is a "major source", as defined in AQCC Reg. 3, Part A.I.B.23.b. As a new major source, CCGTF I was required to submit an application for an operating permit within 12 months of commencing operation pursuant to Part C, Section III of Reg. 3. The facility submitted a timely and complete application for CCGTF I which is currently under review. Per AQCC Reg. 3, Part C.III.B.2, within 12 months of startup of CCGTF II, OXY will apply fora modification to the CCGTF I Title V Operating Permit application for incorporating the sources associated with CCGTF II. 65252-408-140 4-1 October 2048 • ENSR 4.4 Applicability of NSPS The regulation of new sources, through the development of standards applicable to a specific category of sources, was a significant step taken by the CAA (P,L. 91-604). The Administrator was directed to prepare and publish a list of stationary source categories that, in the Administrator's judgment, cause or contribute significantly to air pollution and that may reasonably be anticipated to endanger public health. Further, the Administrator was to publish a proposed regulation establishing a Standard of Performance for any new source, which fell into any category. The significant feature of the law is that it applies to all new, modified, or reconstructed sources within a given category, regardless of geographic location or the existing ambient air quality. The standards defined emission limitations that would be applicable to a particular source group. The NSPS potentially applicable to the project include: • Subpart A -- General Provisions; • Subpart Dc — Standards of Performance for Small Industrial -Commercial -Institutional Steam Generating Units, • Subpart Kb — Standards of Performance for Volatile Organic Storage Vessels; and • Subpart JJJJ — Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. 4.4.1 Subpart A — General Provisions Certain provisions of 40 CFR Part 60 Subpart A apply to the owner or operator of any stationary source subject to a NSPS. As discussed in the following sections, since there will be several new NSPS-affected sources, the facility will be required to comply with the applicable provisions of Subpart A. Subpart A provisions which impose requirements on the facility are identified in Table 4-1. Table 4-1 Summary of Regulatory Requirements of NSPS Subpart A — General Provisions 40 CFR 60 Subpart A Section Requirement Compliance Action 60.7 Initial notification and recordkeeping OXY will submit all NSPS-related notifications to USEPA Region VIII and CDPHE for the proposed project in a timely manner. 60.8 Performance Tests OXY will conduct all required performance tests using designated reference test methods or other methods approved by the Administrator. 60.11 Compliance with standards and maintenance requirements OXY will operate and maintain the units using good air pollution control practices 60.13 Monitoring requirements Required pollutant monitoring pursuant to NSPS will utilize methods outlined in 60.13. 60.19 General notification and reporting requirements All NSPS reports and notification will follow the format and schedule set forth in 60.19. 4.4.2 Flare General Control Device Provisions that apply to flares used as a control device for NSPS affected sources are set out in 40 CFR §60.18. Since the flare will not be receiving "leaks" of VOC from one or more pressure relief devices in gas vapor service that are affected by Subpart KKK and it will not be considered a "control device" for any other NSPS or Part 63 affected source, the flare will not be subject to the General Control Device Provisions of 40 CFR §60.18(b) or 40CFR §63.11. 05252-008-140 4-2 October 2008 ENSR 4.4.3 Subpart Dc — Steam Generating Units The Heat Medium Heaters will be used to heat a "heat transfer medium" (Therminol) and will each have a maximum heat input capacity greater than 10 MMBtulhr. Both of the heaters are therefore "steam generating units" that will be affected by Standards of Performance for Small Industrial -Commercial -Institutional Steam Generating Units set out under 40 CFR Part 60, Subpart Dc. As the heaters are fired exclusively on natural gas, only recordkeeping provisions of 40 CFR §60.48c(g) apply, which require the facility to record the amount of fuel combusted each day. 4.4.4 Subpart Kb — Volatile Organic Liquid Storage Vessels As part of the September 19, 2008 permit application package, Subpart Kb was reviewed with respect to the tanks associated with the centralized tank battery. The tanks are not affected by federal New Source Performance Standards (NSPS) set out at 40 CFR Part 60 Subpart Kb and incorporated by AQCC Reg. 6 because the tanks each have a design capacity less than or equal to 1,589.874 m3 (40,000 gallons) and they are each used for petroleum or condensate stored, processed, or treated prior to custody transfer [40 CFR §60.110b(d) (4)]. 4.4.5 NSPS JJJJ — Spark Ignition Internal Combustion Engines Stationary Natural -Gas Fired Engines ?500HP On January 18, 2008, the USEPA published in the Federal Register finalized rules for NOx, CO, and VOC from certain new stationary spark -ignited IC engines (40 CFR 60, Subpart JJJJ) that commence construction, modification, or reconstruction after the date the particular standard for a specified engine is identified. For the purposes of this Subpart, the date that construction commences is the date the engine is ordered by the owner or operator. The requirements of NSPS Subpart JJJJ apply to owners and operators of stationary spark -ignition (SI) IC engines that commence construction after June 12, 2006, and where IC engines greater than or equal to 500 hp that are non -emergency four-stroke lean -burn (4SLB) units are manufactured on or after January 1, 2008. As the rule was promulgated, non -emergency SI natural gas-fired engines with a maximum engine power a 500 hp that are subject to the rule must comply with the emission standards as identified in Table 4-2. Table 4-2 Emission Standards for Stationary Non -Emergency Natural Gas -Fired Engines Engine Power Manufacture Date Emission Standards' NOx CO NMHC HPa500 July 1, 2007 to June 30, 2010 2.0 g/hp-hr 4.0 gfhp-hr 1.0 gfhp-hr From 40 CFR 60. Subpart JJJJ - Table 1 The three Caterpillar G3616LE compressor engines and the three Caterpillar G3512LE power generation engines to be located at CCGTF II will be subject to this NSPS. All six of the Caterpillar engines will be manufactured after January 1, 2008; therefore, NSPS Subpart JJJJ will apply. As shown on the manufacturer's specification sheets located in Appendix B-3, the Caterpillar G3616LE and G3512LE IC engines to be installed as part of the proposed CCGTF II will meet these emission standards. NSPS does not apply to the existing engines at CCGTF I. 4.5 40 CFR 63 National Emission Standards for Hazardous Air Pollutants National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Categories known as Maximum Available Control Technology or MACT standards affect certain designated industrial sources referred to as "source categories" that may emit or have the potential to emit one or more of 188 designated 05252-008-140 4-3 October 2008 ENSR hazardous air pollutants (HAP). MACT standards (subparts) are codified at 40 CFR Part 63. The following MACT rules are relevant to the CCGTF I and II: Subpart HH—National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities; • Subpart 7777—National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines; and • Subpart EEEE—National Emission Standards for Hazardous Air Pollutants for Organic Liquids Distribution (Non -Gasoline). Most MACT standards only regulate affected sources located at a "major source", defined in Subpart A (§63.2) as: any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants .. . Pursuant to the Urban Air Toxics Strategy, USEPA has developed and is currently developing standards to control certain HAP compounds from "area" sources, defined as a source that is not a major source. "Area" sources are those sources that emit less than 10 tons annually of a single HAP or less than 25 tons or more annually of a combination of one or more HAP. The Clean Air Act (CAA or Act) requires USEPA to identify a list of at least 30 air toxics that pose the greatest potential health threat in urban areas. The CAA also requires USEPA to identify and list the area source categories that represent 90 percent of the emissions of the 30 urban air toxics associated with area sources and subject them to standards under the CAA (section 112(d)). Through three separate listings (including a list in the Urban Air Toxics Strategy), USEPA identified 33 air toxics and a total of 70 area source categories which represent 90 percent of the emissions of the 30 listed air toxics. Of these 70 area source categories, 28 had been regulated by June 2007 and the remaining area source standards are under development. The EPA was recently put on a court ordered schedule to issue the area source rules listed under the Urban Air Toxics Strategy. As discussed further below, area source standards have been promulgated for the Oil and Natural Gas Production source category via amendments to Subpart HH and area source rulemaking for Reciprocating Internal Combustion Engines (amendments to Subpart Z777) was finalized on January 18, 2008 (73 FR 3568 et seq.). Currently, the CCGTF I is an area source (synthetic minor source) of HAP emissions. As shown in Table 3-13, however, with the construction of CCGTF II, the facility will be a major source of HAPs, specifically for formaldehyde as the total emissions of formaldehyde are greater than 10 tpy. 4.5.1 Subpart A – General Provisions The General Provisions set out in Subpart A of 40 C.F.R. Part 63 were originally published on March 16, 1994 (59 FR 12430) and amendments to the General Provisions were finalized on April 5, 2002 (67 FR 16582). The intent of the General Provisions was to put into one subpart (Subpart A) many of the requirements common to all MACT standards. Some provisions of Subpart A apply to any source that is regulated by any MACT standard. Individual standards under Part 63 have requirements that differ from Subpart A, whereby the requirements within the relevant rule should be followed. USEPA provides a tabular summary at the end of each MACT that specifies those General Provisions that apply and those which do not for a particular rule. Once a source becomes subject to a MACT rule, the General Provisions rule requires applications for approval of new construction and reconstruction, notifications, performance testing, monitoring, recordkeeping, and reporting. Additionally, a Startup, Shutdown and Malfunction Plan (SSMP) must be developed for some affected sources, as specified by the relevant standard, that describes, in detail, procedures for operating and maintaining the source during periods of startup, shutdown, and malfunction; and a program of corrective action for malfunctioning process, air pollution control, and monitoring equipment used to comply with the 05252-008-140 4-4 October 2008 • ENSR relevant standard. Table 4-3 lists the Subpart A provisions that impose requirements and compliance actions on the CCGTF II. Table 4-3 Summary of Regulatory Requirements of 40 CFR 63 Subpart A — General Provisions 40 CFR 63 Subpart A Section Requirement Compliance Action 63.5 Pre -Construction Review This application meets provisions for pre - construction review. 63.6 Operational requirements including Startup, Shutdown, and Malfunction (SSM) Plan. Compliance with opacity and non- opacity standards. _ OXY will develop a SSM Plan, maintain a copy on site, and verify operations in accord with a SSM checklist. OXY will comply with applicable emission standards. 63.7 Performance Testing OXY will conduct all required performance testing using the designated reference methods. 63.8 Monitoring Requirements Required monitoring will be conducted in accord with this regulation. 63.9 Notification Requirements OXY will provide required notifications, including the initial notification, special notifications as applicable, and notification of compliance status. 63.10 Reporting Requirements OXY will provide routine semi-annual reports, special reports. reports of excess emissions, reports when SSM Plan is not followed. 4.5.2 Subpart HH — Oil and Natural Gas Production Facilities The oil and natural gas production MALT (40 CFR 63, Subpart HH) regulates upstream petroleum production operations including well sites/pads, tank batteries, gas plants and compressor stations and other facilities that operate one or more "affected sources". For major sources, the affected source for purposes of Subpart HH is comprised of each of the following emission points located at a "facility", as defined in the rule: • Each glycol dehydration unit, as defined in §63.761; • Each storage vessel with the potential for flash emissions, as defined in §63.761; • The group of all ancillary equipment, except compressors, intended to operate in volatile hazardous air pollutant (VHAP) service (as defined in §63.761), which are located at natural gas processing plants; and • Compressors intended to operate in volatile hazardous air pollutant service (as defined in §63.761), which are located at natural gas processing plants. Facilities that do not operate one or more "affected sources,' as listed above, are not subject to the rule [§63.760(d)]. For area source oil and natural gas production facilities, the affected source is each TEG dehydration unit. The existing CCGTF I facility is an "area source" (synthetic minor) for purposes of MACT and Colorado Reg. 8. Relevant area source provisions of Subpart HH for sources that commenced construction prior to July 8, 2005 do not become effective for affected TEG units until January 5, 2009. The CCGTF I currently operates an EG Unit, so area source provisions of the rule do not apply. The CCGTF I/11 facility will be a major source of HAP and relevant provisions of Subpart HH will apply. 05252-008-140 4-5 oclober 2008 • ENSR The combined/modified facility will operate two affected TEG Units, one at CCGTF I and one at CCGTF II. The TEG Units will be regulated by AQCC Reg. 7 and the units will be subject to enforceable limitations on potential to emit HAP (>90% control requirements) set out therein. As a consequence, actual average emissions of benzene from each TEG Unit's process vents to the atmosphere will be less than 0.90 megagram per year (1.0 ton/year) and the TEG Units will not be subject to controls, as provided by 40 CFR §63.764(e)(ii). Since each TEG Unit will meet the exemption criteria in §63.764(e)(1)(ii), OXY will be required by §63.774(d)(1) to maintain records of the actual average benzene emissions (in terms of benzene emissions per year), as determined using GLYCaIc in accordance with §63.772(b)(2). The condensate tanks currently in operation at CCGTF I (TK -415 and TK -416) do not meet the definition of a "storage vessel with the potential for flash emissions", defined in Subpart HH to mean: any storage vessel that contains a hydrocarbon liquid with a stock tank GOR equal to or greater than 0.31 cubic meters per liter [1,750 cf/bbl) and an API gravity equal to or greater than 40 degrees and an actual annual average hydrocarbon liquid throughput equal to or greater than 79,500 liters per day [500 BOPD], Flash emissions occur when dissolved hydrocarbons in the fluid evolve from solution when the fluid pressure is reduced. The API gravity and the stock tank GOR of the condensate stored and handled at the facility may exceed the criteria set out in the rule, but the storage vessels at the facility that contain condensate have an annual average hydrocarbon liquid throughput that is less than 500 BOPD. As such, the condensate storage vessels currently operating at CCGTF I do not qualify as "storage vessel with the potential for flash emissions." The condensate tanks are not affected by Subpart HH. In addition, after the modification to the tank battery only the new 400 -bbl "Separator Feed Tank" (TK -5235) will have the potential for flash emissions. However, this tank will also have an annual average hydrocarbon liquid throughput that is less than 500 BOPD, and will also not qualify as ""storage vessel with the potential for flash emissions." The condensate tanks will not be affected by Subpart HR The CCGTF I is a natural gas processing plant that is affected by NSPS (40 CFR 60, Subpart KKK). Even in the unlikely event that one or more process streams at CCGTF I is "in VHAP service" (total volatile HAP concentration equal to or greater than 10 percent by weight), ancillary equipment and compressors that are subject to Subpart HH and that are also subject to and controlled under the provisions of 40 CFR 60, Subpart KKK, are only required to comply with the requirements of NSPS Subpart KKK. As provided by 40 CFR §63.762(e), owners or operators are not required to prepare a startup, shutdown, and malfunction plan (SSMP) for any facility where all of the affected sources meet the exemption criteria specified in §63.764(e), or for any facility that is not located within a UA plus offset and UC boundary. The TEG Units meet the exemption in §63.764(e)(ii), as discussed above, and the facility is not located within a UA plus offset and UC boundary. Consequently, an SSMP will not be required by Subpart HH. 4.5.3 Subpart 7777 — Stationary Reciprocating Internal Combustion Engines The RICE-MACT (40 CFR 63, Subpart ZZZZ) affects certain stationary RICE at a major or area source of HAP emissions. Subpart ZZZZ was proposed on December 19, 2002 (67 FR 77830 et seq.), The final rule was promulgated on June 15, 2004 (69 FR 33474 et seq.). The June 15, 2004 rulemaking only applied to owners or operators of stationary RICE with a site rating greater than 500 bhp located at a "major source" of HAP emissions. USEPA proposed revisions to Subpart ZZZZ on June 12, 2006 (71 FR 33804 et. seq) to regulate certain stationary RICE located at area sources and stationary RICE with a site rating of 500 bhp or less located at major sources. USEPA issued the final rule on December 20, 2007 and the final rule was published in the Federal Register on January 18, 2008. The rulemaking was combined with the proposed New Source 05252-008-140 4-6 October 2008 ENSR Performance Standard (HSPS) for stationary spark -ignition (SI) engines (proposed 40 G.F.R. Part 60 Subpart JJJJ). The effective date of the amended/new provisions of the rule is March 18, 2008. An affected source is any existing, new, or reconstructed stationary RICE located at a major or area source of HAP emissions. Criteria for determining whether a stationary RICE is new, reconstructed or existing are set out in Table 4-4 below. Table 4-4 RICE-MACT Affected Source Designation Criteria for Stationary RICE >500 bhp RICE Located at a ... Commenced Construction or Reconstruction ... - Source Designation Major Source On or after December 19, 2002 New Major Source Before December 19, 2002 Existing Area Source On or after June 12, 2006 New Area Source Prior to June 12, 2006 Existing Owners and operators of existing stationary engines located at an area source of HAP emissions and stationary engines with a site rating of X500 bhp located at a major source are not subject to emission limitations or to any specific requirements under subpart 777Z or of subpart A of 40 CFR park 63. The CCGTF I is currently an area source for purposes of MACT and the existing engines are not subject to MACT The modified/combined facility will be a major source with all engines, including those existing units at CCGTF I, having commenced construction after December 19, 2002. As a consequence, all stationary RICE at the new/combined facility (CCGTF I and II) will be "new" 4SLB engines subject to new source MACT standards and requirements set out in Subpart 7777 For new stationary RICE located at a major source of HAPs, an owner or operator must comply with the applicable emission limitations and operating limitations in Subpart 7777 upon startup of the affected source. Table 4-5 summarizes the emission limitations and operating limitations that will apply to the new stationary RICE at CCGTF I & II. Stationary RICE constructed before an area source becomes a major source of HAP must be in compliance with applicable standards and rule provisions within 3 years after the area source becomes a major source (i.e., 3 years after startup of CCGTF II. Table 4-5 Subpart 7777 Emission and Operating Limits for New 4SLB Stationary Rice >250 bhp at Major Sources Emission Limitation Operating Limitation Reduce CO emissions by X93 %; Or Limit exhaust concentration of HCHO to 514 ppmvd at 15% 02 Maintain catalyst so the pressure drop does not change by more than 2 inches of water @100% load ± 10% from pressure drop measured during initial performance test; and Maintain the temperature of exhaust so catalyst inlet temperature is ? 450°F and z 1,350°F As shown on the manufacturer's specification sheet located in Appendix B-3, the Caterpillar G3616LE compressor engines and the Caterpillar G3512LE power generator engines to be installed as part of the CCGTF II will meet this emission standard. The IC engines will be installed with oxidation catalysts. The CCGTF I engines were installed with oxidation catalysts and will also meet this emission standard. All of the engines will operate and maintain the control devices following the manufacturer's written instructions and procedures. The operating limitations required by MACT, as described in Table 4-5, are consistent with 05252.008-140 4-7 October 2CO8 • • ENSR requirements set out in the Division's General Operating and Maintenance Plan (O&M Plan) for Natural Gas - Fired Stationary Engines. 4.5.4 Organic Liquids Distribution MACT As previously noted, the combined CCGTF I and II facilities will be a major source of HAP emissions (as defined in §63.2) upon startup of CCGTF II. As a consequence, the separator feed tank and the three condensate storage tanks (TK -415/416/417) comprising the proposed tank battery at CCGTF I will be affected sources under the Organic liquids distribution (OLD) MACT. Except as provided in §63.2338(c), the affected source is the collection of activities and equipment used to distribute organic liquids into, out of, or within a facility that is a major source of HAP. The affected source is composed of [§63.2338(b)]: (1) All storage tanks storing organic liquids. (2) All transfer racks at which organic liquids are loaded into or unloaded out of transport vehicles and/or containers. (3) All equipment leak components in organic liquids service that are associated with: (i) Storage tanks storing organic liquids; (ii) Transfer racks loading or unloading organic liquids; (iii) Pipelines that transfer organic liquids directly between two storage tanks that are subject to [Subpart EEEE]; (iv) Pipelines that transfer organic liquids directly between a storage tank subject to this subpart and a transfer rack subject to [Subpart EEEE]; and (v) Pipelines that transfer organic liquids directly between two transfer racks that are subject to [Subpart EEEE]. (4) All transport vehicles while they are loading or unloading organic liquids at transfer racks subject to this subpart. (5) All containers while they are loading or unloading organic liquids at transfer racks subject to this subpart. The following equipment listed in §63.2338 (c) and used in the identified operations is excluded from the affected source: (1) Storage tanks, transfer racks, transport vehicles, containers, and equipment leak components that are part of an affected source under another MACT. (2) Non -permanent storage tanks, transfer racks, transport vehicles, containers, and equipment leak components when used in special situation distribution loading and unloading operations (such as maintenance or upset liquids management). Storage tanks, transfer racks, transport vehicles, containers, and equipment leak components when used to conduct maintenance activities, such as stormwater management, liquid removal from tanks for inspections and maintenance, or changeovers to a different liquid stored in a storage tank. (3) As mentioned above, the affected source definition in the OLD is described as the collection of activities and equipment. Since CCGTG I commenced construction before April 2, 2002 it would be considered an existing affected source under the Rule [§63.2338(f)]. However, when CCGTG I was constructed the facility was not a major source of HAP emissions. Accordingly, the site was not subject to OLD MACT because it did not satisfy 05252-008-140 4-8 OcEotler 2648 • • ENSR the applicability criteria in §63.2334(a) of the Rule, Installation of the new CCGTG II will be considered a modification of an existing affected source. Because installation of the new CCGTG II is not a replacement of components of an affected or previously non -affected source, this activity would not meet the definition for Reconstruction in §63.2. Since the existing facility, which is currently an area source, will increase its potential to emit HAP such that it becomes a major source, the rule provides that the CCGTF I and II must be in compliance with applicable provisions of OLD MACT on or before three years after the date in which the area source becomes a major source (i.e., three years after startup of CCGTF II) (§63.2342(c)]. CCGTF I transfers condensate and natural gas liquid products out of the plant site. The condensate handled by equipment at CCGTF I meets the definition of an "organic liquid". As set out in Subpart EEEE, organic liquid means: (1) Any non -crude oil liquid or liquid mixture that contains 5 percent by weight or greater of the organic HAP listed in Table 1 to [Subpart EEEE], as determined using the procedures specified in §63.2354(c). (2) Any crude oils downstream of the first point of custody transfer... The condensate does not meet the definition of "crude oil", which means: any of the naturally occurring liquids commonly referred to as crude oil, regardless of specific physical properties. Only those crude oils downstream of the first point of custody transfer after the production field are considered crude oils in [§63.2406]. EPA has previously interpreted condensate as a byproduct of natural gas processing. For example in 40 CFR Part 63 Subpart HH, EPA defines condensate as [§63.761): Condensate means hydrocarbon liquid separated from natural gas that condenses due to changes in the temperature, pressure, or both, and remains liquid at standard conditions, as specified in §63.2. Crude oil is defined separately in Subpart HH. Accordingly, it is assumed that EPA did not intend to include condensate within the definition of crude oil. The condensate is a non -crude oil that, based on an analysis of the Inlet Separator liquid condensate, contains benzene, toluene, ethylbenzene and xylenes, collectively at a concentration exceeding 5 percent by weight. The condensate handling activities at the facility comprise an "organic liquids distribution (OLD) operation", as broadly defined in Subpart EEEE [§63.2406]. "OLD operation" means the combination of activities and equipment used to store or transfer organic liquids into, out of, or within a plant site regardless of the specific activity being performed. Activities include, but are not limited to, storage, transfer, blending, compounding, and packaging. As provided by 40 CFR §63.2334(c), OLD operations do not include the activities and equipment, including product loading racks, used to process, store, or transfer organic liquids at: (1) Oil and natural gas production field facilities, as the term "facility" is defined in §63.761 of subpart HH. (2) Natural gas transmission and storage facilities, as the term "facility" is defined in §63.1271 of subpart HHH. 05252.008-149 4-9 October 2608 • • • ENSR "Production field facility is defined in 40 CFR Part 63 Subpart HH to mean: those facilities, as the term oil and natural gas production "facility" is defined in the rule, that are located prior to the point of custody transfer. Subpart HH defines "custody transfer" to mean [§63.761]: the transfer of hydrocarbon liquids or natural gas: after processing and/or treatment in the producing operations, or from storage vessels or automatic transfer facilities or other such equipment, including product loading racks, to pipelines or any other forms of transportation. For the purposes of this subpart, the point at which such liquids or natural gas enters a natural gas processing plant is a point of custody transfer. The CCGTF I is a natural gas processing plant, so for purposes of Subpart HH (and Subpart EEEE by reference), the inlet to the plant is the point of custody transfer and the facility (i.e. CCGTF I) is located after custody transfer. Consequently, the CCGTF I does not qualify for the exemption set out in 40 CFR §63.2334(c). OLD MACT applies to each new, reconstructed, or existing OLD operation affected source that is located at a major source of HAP emissions [§63.2334(a)]. The CCGTF I and II facility will not operate transfer racks, defined in the rule to mean (§63.2406]: a single system used to load organic liquids into, or unload organic liquids out of, transport vehicles or containers. It includes all loading and unloading arms, pumps, meters, shutoff valves, relief valves, and other piping and equipment necessary for the transfer operation. Transfer equipment and operations that are physically separate (i.e., do not share common piping, valves, and other equipment) are considered to be separate transfer racks. Since the condensate tanks are not affected sources in Subpart HH or any other MACT rule, they do not qualify for the "other NESHAP" exemption described in §63.2338(c)(1). Therefore, the condensate tanks are an affected source under OLD MACT and the tanks are subject to controls and other applicable rule provisions (e.g., Startup, Shutdown, and Malfunction Plan). Since the condensate loading station is not a "loading rack", as defined in the rule, only the equipment leak components from equipment comprising the tank battery is included in the affected source definition [§63.2338(b)(3)(i)]. The transport vehicles and any "containers" would not be included in the affected source definition because no transport vehicles or containers at the facility are loading or unloading organic liquids at "transfer racks" subject to the OLD MACT [§63.2338(b)(4) and (b)(5)]. Affected Source Equipment Applicable (Y/N) Reason Notes Tanks Y storing organic liquids Condensate tanks Transfer Racks N no organic liquid OLD operations use "transfer racks" as defined in the OLD MACT Equipment Leaks Y facility has an affected source subject to controls (i.e. tanks) associated with condensate tanks Containers N not load/unloaded with "transfer racks" subject to_OLD MACT Transport Vehicles N not load/unloaded with "transfer racks" subject to OLD MACT 05252.O08-140 4-10 October 2008 • ENSR 4.6 Colorado Air Quality Control Commission Regulations — General The Colorado Air Pollution Prevention & Control Act (CAPPCA) lays the framework for the state air quality laws and regulations. CAPPCA allows the federal government to delegate the implementation of the CAA Amendments of 1990 to the state government. CAPPCA establishes the legal authority of the CDPHE to enforce the regulations set forth by CAPPCA and the AQCC Regulations 1 through 19. Table 4-6 lists the Colorado AQCC Regulations and determines project applicability. Table 4-6 Air Quality Control Commission Regulations Applicability Table Regulation Title Applicability Reason Reg. 1 — Particulates, Smokes, Carbon Monoxide & Sulfur Oxides Applicable Applies to all new and existing sources Reg. 2 — Odor Emissions Applicable Applies to any potential source of air contaminants Reg. 3 — Air Contaminant Emission Notice Applicable Applies to all sources of air pollutants Reg, 4 — New Wood Stoves & the Use Certain Woodburning Appliances during Pollution Days of High Not Applicable Source will not have woodburning stoves Reg. 5 — Generic Emissions Trading and Banking Not Applicable Source will not be subject Reg. 6 — Standards of Performance for Stationary Sources New Applicable Adopted by reference from federal NSPS regulations. See Section 4.4. Reg. 7 — Emissions of Volatile Organic Compounds Applicable Source is not located in an ozone non - attainment area, but is subject to XVII.C, XVII.D and XVILE Reg. 8 — Control of Hazardous Air Pollutants Applicable See Section 4.5. Reg. 9 — Open Burning, Prescribed Fire, Permitting and Applicable Open burning or prescribed fire will not be conducted without proper approvals Reg. 10 — Criteria for Analysis of Conformity Not Applicable Source is not a part of transportation plan requirements Regs. 11, 12 ,13, 14 (repealed) Not Applicable Applies to motor vehicle program Reg. 15 — Control of Emissions of Ozone Depleting Compounds Not Applicable Source does not manufacture refrigerants Reg. 16 — Street Sanding Emissions Not Applicable Regulation does not apply to source category Reg. 17 — Clean Fuel Fleet Program Not Applicable Source is not required to have a clean fuel fleet program Reg. 18 — Control of Emissions of Acid Deposition Precursors Not Applicable Source not subject to the Acid Rain Program Reg. 19 — Lead Based Paint Abatement Not Applicable Regulation does not apply to source category 05252-008-140 4-11 October 2008 • ENSR 4.7 Colorado Air Quality Control Commission — Regulation 7 4.7.1 Condensate Tanks (Reg. 7, XVILC) Beginning May 1, 2008, owners or operators of all atmospheric condensate storage tanks with uncontrolled actual emissions of VOC equal to or greater than 20 tons per rolling 12 -months shall operate air pollution control equipment that has an average VOC control efficiency of at least 95 percent. The proposed condensate tanks will have uncontrolled actual VOC emissions greater than the 20 tpy threshold. As such, these tanks will be subject to provisions of AQCC Regulation 7, XVII.C. OXY will achieve compliance with the all applicable provisions of AQCC Regulation 7, XVII upon start-up. The emissions from the condensate tanks will be routed to a vapor control unit capable of achieving 98 percent destruction efficiency. 4.7.2 Glycol Dehydration Units (Reg. 7, XVII.D) Beginning May 1, 2008, any still vent and vent from any gas -condensate -glycol separator (flash separator or flash tank), if present, on a glycol natural gas dehydrator located at an oil and gas exploration and production operation, natural gas compressor station, drip station or gas -processing plant shall reduce uncontrolled actual emissions of VOC by an average of at least 90 percent through the use of air pollution control equipment. The rule (AQCC Regulation 7, XVII.D) shall not apply to any single or multiple collocated natural gas dehydrators with uncontrolled actual VOC emissions less than 15 tpy based on a rolling 12 -month total. Both of the TEG units to be operated at CCGTF I and II will have uncontrolled VOC emissions greater than 15 tpy. As such, they will be subject to this regulation. Flash gas from the glycol flash drums will be sent to the enclosed combustors (VCUs) for VOC and HAP destruction, while overhead gas from the glycol regenerator still vents will be sent to BTEX units followed by the VCUs for VOC and HAP destruction, thus complying with the 90 percent reduction standard. 4.7.3 New or Relocated Natural Gas -Fired Reciprocating Internal Combustion Engines (Regulation 7, XVII.E) The owner or operator of any natural gas-fired reciprocating IC engine greater than 100 horsepower that is either constructed or relocated to the state of Colorado from another state after the dates shown in Table 4-7, shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards set out in AQCC Regulation 7, XVII.E, as provided below. Table 4-7 Regulation XVII.E Emission Standards Maximum Engine Horsepower Construction or Relocation Date Emission Standard (glbhp-hr) N©x CO VOC 100<HP<500 January 1, 2008 2.0 4.0 1.0 January 1, 2011 1.0 2.0 0.7 500zHP July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 05252-008-140 4-12 October 2008 • ENSR As shown on the manufacturer's specification sheet located in Appendix B-3, the Caterpillar IC engines to be installed as part of the proposed CCGTF II will meet these emission standards. The engines at CCGTF II will be subject to federal NSPS and MACT rules. Consequently, statewide controls for natural gas-fired RICE set out under AQCC Regulation 7, XVII_ will not apply to the RICE installed at CCGTF II (AQCC Regulation 7, XVII.B.4). The engines at CCGTF I were constructed before January 1, 2008, so AQCC Regulation 7 does not apply to the CCGTF I engines. Furthermore, these engines will be subject to MACT. 05252-008-14C 4-13 October 20Ce. • • • ENSR 5.0 Air Dispersion Modeling Analysis This chapter presents the methodology and results of an air quality impact analysis (AQIA) performed for the proposed project. The project location is approximately 17 kilometers north of DeBeque along the Conn Creek, which parallels Conn Creek Road north-northeast of County Road 45. Significant terrain features surround the site, as shown in Figure 2-1, requiring inclusion of complex terrain features into dispersion calculations. Dispersion modeling was conducted in accordance with the CDPHE Colorado Modeling Guidance for Air Quality Permits (CDPHE 2005), and USEPA's Guideline on Air Quality Models (USEPA 2005). The USEPA-approved AERMOD model was used to model criteria pollutants for comparison against the Colorado and National Ambient Air Quality Standards (AAQS) and Class ll significant impact levels (SILs). The Significant Impact Analysis conducted for this project demonstrates project impacts do exceed Class II SILs for some pollutants and averaging periods. Therefore, a Cumulative Impact Analysis (CIA) was performed for those pollutants and averaging periods that exceeded SILs to demonstrate compliance with the AAQS. 5.1 Dispersion Modeling Methods 5.1.1 AERMOD Overview Following CDPHE guidance, the USEPA AERMOD (version 07026) dispersion model was used to estimate facility impacts (CDPHE 2005). AERMOD is a refined, steady-state dispersion model for modeling either simple or complex terrain within 50 kilometers (km) of a source. The AERMOD model has two pre-processors that prepare needed input files in an AERMOD-ready format. The pre-processors are AERMET, used to calculate required meteorological inputs, and AERMAP, used to calculate receptor elevations and critical hill heights. Model options were set to regulatory defaults outlined in the Guideline on Air Quality Models (USEPA 2005). 5.1.2 Meteorological Data CDPHE provided AERMOD-ready meteorological files, processed with AERMET (version 06341) (CDPHE 2008a). Surface meteorological data were collected at the Williams Parachute Creek Gas Plant meteorological monitoring station located approximately 12 km east of the proposed project site. The Williams Parachute Creek meteorological tower data was combined with upper air soundings collected at Grand Junction, Colorado, for the 1 -year period from June 16, 2006 through June 15, 2007. Following guidance from CDPHE, winds were rotated in AERMOD using a rotation angle of -45 degrees (CDPHE 2008a). This rotation aligns the dominant valley nocturnal drainage flow from the Parachute Creek Gas Plant tower with the orientation of the Conn Creek drainage near the proposed project by rotating the dominant nocturnal Parachute Creek wind direction from 315 deg to 0 degrees. 5.1.3 Receptors Two networks of receptors were generated for this AQIA. Both networks were developed in accordance with CDPHE modeling guidance (CDPHE 2005). The first receptor network was used to model the project's significant impact area (SIA). A second, subset of the SIA receptor network was used in the CIA. All receptor elevations were determined using the USEPA-approved AERMAP (version 06341) terrain processor. AERMAP was run using 7,5 -minute Digital Elevation Model (DEM) data with the facility and receptor coordinates anchored in United States Geological Survey (UGSG) Universal Transverse Mercator (UTM) coordinates projected in North American Datum 1927 (NAD27), Zone 12. The receptor network that was used to predict the project's SIA consisted of the following spacing: 05252-008-140 5-1 October 2008 ENSR • Fenceline receptors placed every 50-m; • 100-m spacing from the fenceline to 1 km from the fenceline; • 250-m spacing between 1 km to 3 km from the fenceline; and • 500-m spacing between 3 km to 10 km from the fenceline. Figures showing the nearfield and farfield receptor grids overlaid onto topographic maps are shown in Figure 5-1 and Figure 5-2. AERMAP-contoured receptor elevations are also shown in Figure 5-1 and Figure 5-2. For the CIA, the above receptor set was reduced to include only areas that had significant impacts due to the project emissions. By definition, the project sources are deemed to have an insignificant contribution to the AAQS outside of the SIA. Thus, it was not necessary to model receptors outside the SIA for the CIA. As demonstrated during the SIA analysis, the radius of the largest SIA is 4.1 km (annual NO2 assuming 100 percent conversion of NOx-to-NO2) from the center of the facility. Therefore, the receptor set generated for the CIA only extends 4.1 km from the proposed project. The receptor network used for the CIA consisted of the following spacing: • Fenceline receptors placed every 50-m; • 100-m spacing from the fenceline to 1 km from the fenceline; • 250-m spacing between 1 km to 3 km from the fenceline; and • 500-m spacing between 3 km to 4.1 km from the fenceline. 5.1.4 Good Engineering Practice Stack Height and Building Downwash All CCGTF point sources were evaluated to determine if stack heights are consistent with Good Engineering Practice (GEP) as defined in 40 CFR 51.100 and described in the Guideline on Air Quality Models (USEPA 2005). The Building Profile and Input Program with PRIME (BPIP-PRIME, Version 04274) was used for the GEP stack height evaluation and to obtain direction -specific building dimension data for input to AERMOD. Figure 5-3 provides a depiction of project sources, buildings, and the fenceline, input into BPIP-PRIME. Building downwash and GEP stack height were not evaluated for off-site sources, with the exception of the TransColorado Conn Creek Compressor Station, as described in Section 5.2.2. Building downwash parameters were included for this off-site source due to its close proximity to the CCGTF facility and the data were readily available for this application. It is noted that inclusion of building downwash effects typically increase concentrations in the near -field of the source, it is conservative to not include downwash for distant off-site sources outside of the SIA. 5.2 Source Characterization 5.2.1 CCGTF Sources The project sources, buildings, and receptors were digitized in UTM coordinates in NAD27 Zone 12. The layout of the project fenceline, buildings, and sources are depicted in Figure 5-3. The heights of the emission sources reflect the modeled release heights, which are slightly different from the physical release characteristics for some sources such as the flares and capped stacks, as described below. Modeled stack parameters represent worst-case parameters for the compressor engines over the range of loads and ambient temperature conditions for all modeling analyses. Worst-case stack parameters are defined as the lowest exhaust temperature and velocity over all possible operating conditions. It is assumed that using the worst-case stack parameters (e.g., lowest temperature and velocity) will result in the highest possible impacts since downwash is a driving factor in the dispersion of the plumes. 05252-008-140 5-2 October 2006 • • ENSR The modeled stack parameters for the flares were based on USEPA guidance for determining the effect release parameters for flares (USEPA 1995). The effective stack diameter and release height for both flares were based on the actual release height of 38.4 meters and a fuel heat content of 0.50 MMBtuihr for each flare. The flare release temperature and velocity were modeled at 1,273 Kelvin (K) and 20 meters per second (mis), respectively, per USEPA (1995). The existing heaters have capped stacks and are not affected by building downwash. Per the USEPA AERMOD Implementation Guide (USEPA 2008b), the modeled release height was reduced by a factor of 3 times the physical stack diameter. The exhaust velocity was set to 0.001 mis and effective diameter was calculated based on the actual flow rate for each stack using a velocity of 0.001 mis. These sources were modeled at 100 percent load. The base elevations for each proposed source were obtained from an elevation drawing of the proposed facility at full build -out with the exception of the vapor combustion units 1, 2, and 3. The base elevations for VCUs 1, 2, and 3 were determined by inspection of digital terrain data in the vicinity of these source locations. The base elevations for existing project sources were obtained from modeling files provided by CDPHE (2007) and were verified by inspection of the existing source locations compared to the surrounding terrain and the existing grading of the site. Table 5-1 provides the modeled stack parameters for each source, Table 5-2 provides the modeled emission rates for CCGTF sources used in the AQIA, as described in Chapter 3.0 . 5.2.2 Off -Site Source Inventory A cumulative emissions inventory was obtained from CDPHE for all pollutants (CDPHE 2008b). The emissions inventory includes emissions from sources within 14 km of the proposed project site. The extent of the off-site emissions inventory included a substantial buffer beyond what is normally required, which is typically the extent of the maximum SIA plus 5 km. ENSR requested an extensive inventory to ensure that all appropriate off-site sources were included in the CIA. The CDPHE-provided emissions inventory contained stack locations and parameters that were used for modeling each source with a few exceptions as described in the next paragraph. Facilities that lacked stack parameters were assigned conservative stack parameters (i.e., stack heights of 0 feet were modeled at a height of 0 meters above grade, stack velocity and diameter of 0 feet per second and 0 feet were modeled at 0.001 mis and 0.001 m, respectively). The CDPHE provided updated model inputs for OXY's Cascade Creek Compressor Station' and the EnCana Logan Wash Amine Plant for a previous permit application ENSR prepared for the TransColorado Conn Creek Compressor Station (ENSR 2007, CDPHE 2007). The CDPHE-provided stack parameters for these two facilities were used in place of the inventory parameters provided by the CDPHE (2008b). In addition, ENSR used the stack parameters provided in ENSR (2007) for the TransColorado Conn Creek facility, along with the addition of the fuel gas heater which was not included in the off-site inventory provided by CDPHE (2008b). Building downwash parameters were also included in the off-site inventory for the TransColorado Conn Creek facility sources, as provided in ENSR (2007). The modeled off-site inventory is provided on the CD ROM in Appendix C. The locations of modeled off-site sources relative to the proposed project location are depicted in Figure 5-4. ' The Cascade Central Facility (AIRS 045/0355), also known as the "Water Plant', was formerly and for unknown reasons designated the "Cascade Creek Compressor Station'. The facility is nota compressor station, but rather is a central handling facility for stabilized condensate and produced water. 05252-008-140 5-3 October 2008 ENSR 5.3 Modeling Results This section discusses the results of the various modeling analyses performed. Digital modeling files are provided on CD-ROM and a listing of the files is provided in Appendix C. All modeled impacts are below the Colorado and National MOS. 5.3.1 Significant Impact Analysis The AERMOD model was run for the stack parameters and emission rates, as shown in Table 5-1 and Table 5-2. The modeled impacts for the proposed expansion sources at the facility were compared against the Class II SIL for each pollutant and averaging period. The modeled NO2 impact assumed 75 percent conversion of NOx-to-NO2. Table 5-3 presents the results of the significant impact analysis. Significant impacts were predicted for annual NO2, 24-hour PM10, and annual and 24-hour S02. Figure 5-5 through Figure 5-8 present the SIA isopleths, or individual receptors locations exceeding the SILs as appropriate, along with the maximum impact locations for those pollutants and averaging times which exceeded SILs. Since the project NO2, PM10, and SO2 impacts exceeded the respective SILs, a CIA was performed for these pollutants. CO impacts were insignificant; therefore, no further analysis was performed for CO. 5.3.2 Cumulative Impact Analysis Only pollutants that exceeded SILs (shown in Table 5-3) were modeled in the CIA. The emissions inventory for off-site sources was requested and processed as described in Section 5.2.2. This emissions inventory of off-site sources was modeled in conjunction with all CCGTF sources using the truncated receptor network described in Section 5.1.3. The modeled NO2 impact assumed 75 percent conversion of NO-to-NO2. The CDPHE provided project -specific background concentrations (CDPHE 2007c). The peak AERMOD impacts due to all CCGTF sources and off-site sources were added to the background concentrations for comparison to the AAQS. All modeled impacts, plus background, were below the AAQS, as shown in Table 5-4. Figure 5-9 through Figure 5-14 show concentration isopleths for the respective pollutants and averaging periods modeled in the CIA. 05252-008-140 5-4 October 2008 • ENSR Table 5-1 Modeled Stack Parameters Source Model ID UTM Easting' (m) UTM Northing' (m) Base Elevation (m) Stack Height (m) Stack Temp. (K) Stack Velocity (nils) Stack Diameter (m) Project Sources Compressor Engine #9 stack A ESA 736685.8 4373991.2 1817.1 10.4 741. 20.82 0.66 Compressor Engine #9 stack B E96 736685.5 4373996.8 1817.1 10.4 741. 20.82 0.66 Compressor Engine #10 stack A E1 OA 736685.3 4374000.3 1817.1 10.4 741. 20.82 0.66 Compressor Engine #10 B El OB 736685.0 4374005.9 1817.1 10.4 741. 20,82 0.66 _stack Compressor Engine #11 stack A El lA 736684.8 4374009.4 1817.1 10.4 741. 20.82 0,66 Compressor Engine #11 stack B El 1B 736684.5 4374015.1 1817.1 10.4 741. 20.82 0.66 Gen -Set E12 736627,6 4374044.3 1821.7 10,4 716. 29.68 0.30 Gen -Set E13 736627.3 4374049.6 1821.7 10.4 716. 29.68 0.30 Gen -Set E14 736627.0 4374054.9 1821.7 10.4 716. 29.68 0.30 Therminol Heater H3 736663.1 4374114.5 1822.4 7.0 644. 10.63 0.61 Therminol Heater H4 736667.5 4374114.5 1822.4 7.0 644. 10.63 0.61 Flare PF2 736555.0 4373917.7 1835.8 39.1 1273. 20.00 0.12 Vapor Combustion Unit 1 VCU1 736594.6 4373820.3 1818.0 2.4 644. 19.70 1.22 Vapor Combustion Unit 2 VCU2 736594.6 4373814.2 1818.0 2.4 644. 19.70 1.22 Vapor Combustion Unit 3 VCU3 736594.6 4373808.1 1818.0 2.4 644. 19.70 1,22 Vapor Combustion Unit 4 VCU4 736674.7 4374078.7 1819.0 2.4 644. 19.70 1.22 Heater Treater HTRTR1 736646.1 4373767.0 1814.2 3.7 644. 1.84 0.25 3 -Phase Separator Heater HTRTR2 736646.1 4373772.9 1814.2 3,7 644. 2.94 0.25 Existing Sources Compressor Engine #1 El 736702.0 4373878.3 1815.1 10.4 733. 55.63 0.30 Compressor Engine #2 E2 736701.2 4373890.4 1815,1 10.4 733. _ 55.63 0.30 Compressor Engine #3 E3 736700.5 4373902.5 1815.1 10.4 733. 55.63 0.30 Compressor Engine #4 E4 736699.8 4373914.7 1815.1 10.4 733. 55.63 0.30 Compressor Engine #5 E5 736698.8 4373925.6 1815.1 10.4 733. 55.63 0.30 Gen -Set E6 736629.2 4373928.0 1818.1 10.4 701. 31.33 0.30 Gen -Set E7 736629.0 4373933.4 1818.1 10.4 701. 31.33 0,30 Gen -Set E8 736628.5 4373938.5 1818.1 10.4 701. 31.33 0.30 Therminol Heater H1 736646.1 4373755,1 1813.3 5.2 644. 0.001 62.86 Therminol Heater H2 736646.4 4373749.9 1813.3 5.2 644. 0.001 _ 62.86 Flare PF1 736536.1 4373918.0 1835.8 39.1 1273. 20.00 0.12 'Ali UTM coordinates reported are in NAD27 zone 12, meters. 05252-008-140 5-5 October2008 • i ENSR Table 5-2 Modeled Emission Rates Source NOx Ws) Co gls) SO2 Wisp PMia 9ls) Annual 1 -hour t 8 -hour 3 -hour 1 24-hour Annual 24-hour I Annual Project Sources Compressor Engine #9 stack A 0.439 0.110 0.110 0.029 0.029 0.029 0.019 0.019 Compressor Engine_#9 stack B 0.439 0.110 0.110 0.029 0.029 0.029 0.019 0.019 Compressor Engine #10 stack A 0.439 0.110 0.110 0.029 0.029 0.029 0.019 0.019 Compressor Engine #10 stack B 0.439 0.110 0.110 0.029 0.029 0.029 0.019 0.019 Compressor Engine #11 stack A 0.439 0.110 _0.110 0.029 0.029 0.029 0.019 0.019 Compressor Engine #11 stack B 0.439 0.110 0.110 0.029 0,029 0.029 0.019 0.019 Gen -Set 0.326 0.043 0.043 0.011 0.011 0.011 0.008 0.008 Gen -Set 0.326 0.043 0.043 0.011 0.011 0.011 0.008 0.008 Gen -Set 0.326 0.043 0.043 0.011 0.011 0.011 0.008 0.008 Therminol Heater 0.183 0.153 0.153 0.026 0.026 0.026 0.014 0.014 Therminol Heater 0.183 0.153 0.153 0.026 0.026 0.026 0.014 0.014 Flare 0.004 0.023 0.023 0.0004 0.0004 0.0004 0.0008 0,0008 Vapor Combustion Unit 1 0.019 0.016 0.016 0.003 0.003 0.003 0.001 0.001 Vapor Combustion Unit 2 0.019 0.016 0.016 0.003 0.003 0.003 0.001 0.001 Vapor Combustion Unit 3 0.019 0.016 0.016 0.003 0.003 0.003 0.001 0.001 Vapor Combustion Unit 4 0.019 0.016 0.016 0.003 0.003 0.003 0.001 0.001 Heater Treater 0.006 0.005 0.005 0.0009 0.0009 0.0009 0.0005 0.0005 3 -Phase Separator Heater 0.010 0.009 0.009 0.001 0.001 0.001 0.0008 0.0008 Existing Sources Compressor Engine #1 0.513 0.027 0.027 0.017 0.017 0.017 0.012 0.012 Compressor Engine #2 0.513 0.027 0.027 0.017 0.017 0.017 0.012 0,012 Compressor Engine #3 0.513 0.027 0.027 0.017 0.017 0.017 0.012 0.012 Compressor Engine #4 0.513 0.027 0.027 0.017 0.017 0.017 0.012 0.012 Compressor Engine #5 0.513 0.027 0.027 0.017 0.017 0.017 0.012 0.012 Gen -Set 0.558 0.021 0.021 0.010 0.010 0.010 0.007 0.007 Gen -Set 0,558 0.021 0.021 0.010 0.010 0.010 0.007 0.007 Gen -Set 0.558 0.021 0.021 0.010 0.010 0.010 0.007 0.007 Therminol Heater 0.088 0.148 _ 0.148 0.001 0.001 0.001 0.013 0.013 Therminol Heater 0.088 0.148 0.148 0.001 0.001 0.001 0.013 0.013 Flare 0.004 0.023 0.023 0.0004 0.0004 0.0004 0.0008 0.0008 05252-008-140 5-6 October 2009 ENSR Table 5-3 Significant Impact Analysis Results Pollutant Averaging Period Maximum Modeled Related Impact (pglm3) Project- 1 Location of Maximum Impact Class Il SIL (pg/m3) Radius of SIA (km) Impact Exceeds SIL? UTM Easting (m) UTM Northing (m) NO22 Annual 20.0 736618 4373919 1 4.1 Yes CO 1 -hour 141.1 736900 4374000 2000 N.A. No 8 -hour 44.4 737000 4374300 500 N.A. No SO2 3 -hour 18.8 737000 4374200 25 N.A. No 24-hour 8.9 736737 4373913 5 0.3 Yes Annual 1.2 736618 4373919 1 0.3 Yes PM,a 24-hour 5.8 736737 4373913 5 0.2 Yes Annual 0.8 736618 4373919 1 N.A. No As stipulated by CDPHE, the highest first -high values were used for comparison to applicable standards (CDPHE 2008a) 2 Modeled impact assumes 75 percent conversion of NO,,-to-NO2. Table 5-4 Cumulative Impact Analysis Results Pollutant Averaging Period Maximum Modeled Cumulative Impact 1'3 (pgfm3) Background (1151m) Cumulative Impact (pg/m3) AAQS (pglrn3) Percent of AAQS NO2t Annual 60.3 9 69.3 100 69 SO2 3 -Hour 27.2 24 51.2 700 7 24 -Hour 14.9 13 27.9 365 8 Annual 2.2 5 7.2 _ 80 9 PM10 24 -Hour 10.4 36 46.4 150 31 Annual 2.1 11 13.1 50 27 As stipulated by CDPHE, the highest first -high values were used for comparison to applicable standards (CDPHE 2008a) Modeled impact assumes 75 percent conversion of NO, -to -NO#. Impacts for existing and proposed CCGTF sources plus off-site sources. 05252-008-140 5-7 October 2008 • ENSR 4384000 4382000 4380000 4378000 4376000 E 4374000 Z 4372000— t - 4370000 372000— r 4370000 4368000 4366000 4364000 728000 730000 732000 734000 736000 738000 740000 742000 744000 746000 UTM Easting (meters, NAD27) LEGEND • RECEPTOR Contoured etevatic are m feet ASL o Y USA Corn, Cm* Gas LWrc4n Fn[. v, Dui* O7+049908 vbs Figure 5-1 Farfield Receptor Network and AERMAP Terrain Contours for Significant Impact Analysis 05252-008.149 5-8 October 2008 • • ENSR 4374200 2 44 4374000' u E rn s 4373800 r 0 2 IS 437 4372600- 735600 735500 736000 736200 736400 736600 736800 737000 737200 737400 737600 737800 UTM Easting (meters. NAD27) LEGEND RECEPTOR Contoured elevations are in feet ASL oxr VSA Cem C W Grs TI WINK! r Wity Cats. OSF007006 rr..nisrd Revepw GM Figure 5-2 Neaeld Receptor Network and AERMAP Terrain Contours for Significant Impact Analysis 05252-008-140 5-9 October 2008 ENSR Project Sources Modeled Release 4374 50- ID Height (meters agl) E9A 10.4 E98 10.4 E1OA 10.4 ElOB 10.4 ,e,104374100 EllA 10.4 E11B 104 (INIC3h E12 10 4 E13 10.4 _s11r E 14 10.4 4374050-'45A3l H4 7.0 t' Ai ti PF2 381 0V1, th` VCU1 2.4 VCU2.4 4374000- se VCU4 2 4 t< HTRTRI 3 7 ca HTRTR2 37 0 Q Existing Sources Z 4373950- Modeled Release siiID Height (meters 4911 41 01.,_02 0 El 10.4 E+* E2 10.4 E3 10 4 4373900- 0 E4 10.4 [7) Erl E5 10.4 C E5 E6 104 1= E7 104 o Ea 10.4 z 4373850- H1 5.2 H2 52 I. - A03\ F F 1 39 1 v0A 4373800- 1R K 4373750- 4373700- 4373650- 736550 736600 736650 736700 736750 736800 736850 UTM Easting (meters, NAD27) CCGTF I Sources CCGTF II Sources c: Y us: Conn Creak Gas Tre.lmere Facie, Cate 1ryti;2 re36 Preyed Somites euksngs and Feecerne Lxaoern Figure 5-3 Project Sources, Buildings, and Fenceline 05252-008-140 5-10 October 2008 ENSR 4385000 4380000 z ai ▪ 4375(100 E 0 2 - 4370000 4365000 726000 730000 734000 738000 742000 UTM Eastmg {meters, NAD27) Legend • CCGTF A Off -Site Sources 746000 750000 OXY USA Com Gwek Gas Trralerend ixgy Sire LocaI on and Off-Siie Sources Cure UXOSC2-08 Figure 5-4 Off-site Source Locations Relative to Project Location 05252-008-140 5-11 October 2008 • • ENSR 4380000 4379000 4378000 4377000 ._ 4376000 r - C" z 4375000 d E 4374000 c o 4373000 2 2 n 4372000 4371000 4370000 4369000 4368000 4367000 730000 731000 732000 733000 734000 735000 736000 737000 738000 739000 740000 741000 742000 74 3000 UTM Easting (meters. NAD27 LEGEND + Maximum Impact Receptor Localton CXV 45p, font's 4rcek G3, Tac arneeart F 4 c PO 06.200 Figure 5-5 Annual NOx Significant impact Area (1 pghr13) 05252-008-140 5-12 HQ SXam Impart ..rna October 2008 • • • ENSR 4376500 4376000 437550 4375000 4374500 a) iv 4374000 0 2 4373500 F 4373000 4372500 4372000 4371500 734000 734500 735000 735500 736000 736500 737000 737500 738000 738500 739000 UTM Easting (meters, NR0327) OXY USA CCGTF 1 LEGEND • SIL Exceedance Receptor Locations + Maximum Impact Receptor Location. OXY vsA Conn C.* GIs T.estrnont Fxgry Dalt ix OE -::0)6 2t,nour SJ Slt E.utosnct Re 000 Figure 5-6 24 -Hour SO2 SIL Exceedance Receptors (5 µfilm) 05252.008-140 5-13 October 2008 • • • ENSR 4376500 4376000 4375500 4375000 N 4374 a e 4374000 0I 0 4 2 437350 4373000 4372500 4372000 4371500 734000 734500 735000 735500 736000 736500 737000 737500 UTM Eastrng (meters. NAD27) LEGEND ■ SIL Exceedance Receptor Locations -�- Maxenum Impact Receptor Location OXY USA Conn Creek Gas Treatment Facility On. 50 C6Q@0! 738000 738500 739000 Annual SO SIL Exceedance Receptors Figure 5-7 Annual SO2 SIL Exceedance Receptors (1 pgirn) 05252-008-140 5-14 October 2008 • ENSR OXY USA CCGTF ¢ 4374500 Qf E 4374000 t C L 4373500 4371500 734000 734500 735000 735500 736000 736500 737000 737500 738000 738500 739000 UTM Easting (meters. NAD27) LEGEND e SIL Exceedance Receptor Locations Maximum trnc act Recepto Lac -alien OXY USA Conn Creek Gas Treatment. Faoixy Dose Ili W 008 24 -Hour PM SIL Exceedance Recepiccs Figure 5-8 24 -Hour PM10 SIL Exceedance Receptors (5 pg/m3) 05252-008-140 5-15 October 2008 • • • ENSR 4376500 4376000 4375500 4375000 ti 4374500 43. E 4374000 to c r 4373500 4373000 4372500 OXY USA CCGTF 4372000 4371500 734000 734500 735000 735500 736000 736500 737000 737500 738000 738500 739000 UTM Easting (meters. NAD27) LEGEND X Maxxnum Impact Receptor Location oxr OSA Conn Creek GK 71,011.4 Fame, L'm 10'392048 Annual NOGwnuHmre Irilpatt Connte»omrsacied s Figure 5-9 Annual NOx Modeled Cumulative Impact Concentration Isopleths 05252-008-140 5-16 OdoOer2008 ENSR I• N 4374500 Iss 4374000 rn 0 4373500 4371500 734000 734500 735000 735500 736000 736500 737000 737500 738000 738500 UTM Easting (meters. NA027) LEGEND X Maximum Impact Receptor Location OAY USA Com. Ca** GA[ itATIAAVI FRAly Dee 10t62csa 739000 }Hpe S0 CIA Camaro ow. IsoFYMf Figure 5-10 3 -Hour SO2 Modeled Cumulative Impact Concentration Isopleths 05252.008-140 5-17 Oc:aber 2005 • • ENSR 43765000 4376000 4375500 4375000 CI 4374500 0) a) E 4374000- C c c 2 4373500 OXY USA CCGTF 4373000 4372500 4372000 4371500 734000 734500 735000 735500 LEGEND X Maximum Impart Receptor Location 736000 736500 737000 737500 UTAH Easting (meters. NAD27) ox, USA Co CrM Gbt TMAIR*11FJ.IIRr base 12062002 738000 738500 739000 24rwue S0 CIA Cone *.O, isrokeln Figure 5-11 24 -Hour SO2 Modeled Cumulative Impact Concentration Isopleths 05252-008-140 5-18 October 2008 • • • ENSR 4376500 4376000- 4375500 4375000 CI N 4374500 Z 4374000 oI OXY USA CCGTF 4371500 734000 734500 735000 735500 736000 736500 737000 737500 738000 738500 739000 !JTM Easting (meters, NAD27) LEGEND }( klaxununv Impact Receptor Location [MY 1J$A Com C'. Gas Treae»ant F ■mal SU C+A C4nSfrnaaen +so4Ie+11s Figure 5-12 Annual SO2 Modeled Cumulative Impact Concentration Isopleths 05252-008-140 5-19 October 2008 ENSR 4376500 4376000 4375500 4375000 M1 f>k a 4374500 E 4374000- 437350[7 4373000 4372500 4372000 4371500 734000 734500 735000 735500 736000 736500 737000 737500 738000 738500 739000 UTM Easting (meters. NAD27) LEGEND X Ma+umum Impact Receptor Location OX? USA Conn Creek Gas Treatment Facddy Oa 1: [1L.:G:C 241iout PM CIA Concentration Isaaplettls Figure 5-13 24 -Hour PM70 Modeled Cumulative Impact Concentration Isopleths 05252-008-140 5-20 October 2008 ENSR 4376500 437 f 7r r c r ' LSA f 2 w OXY USA CCGTF LEGEND X Maximum impact Receptor Location 735500 736000 736500 737000 UTM Easting (meters. NAD27) OXY USA Cam Creek Gas Treatment Faddy Dau t00&:00e Annual PM CIA Concentration isopleths Figure 5-14 Annual PM1,D Modeled Cumulative Impact Concentration Isopleths 05252-008-140 5-21 October 2008 ENSR 6.0 References Colorado Department of Public Health and Environment (CDPHE). 2008a. E-mail correspondence from Chuck Machovec of CDPHE to Patrick McKean of ENSR. March 9 and July 16, 2008. 2008b. E-mail correspondence from David Thayer of CDPHE to Patrick McKean of ENSR. August 12, 2008. . 2008c, E-mail correspondence from Nancy Chick of CDPHE to Doug Bopray of ENSR. August 8, 2008. 2007. E-mail correspondence from Jon Torizzo of CDPHE to Patrick McKean of ENSR. October 23, 2007. . 2005. Colorado Modeling Guideline for Air Quality Permits; December 27, 2005. ENSR Corporation (ENSR). 2007. Letter to Denise Onyskiw of CDPHE from Chuck Cornell of ENSR. October 24, 2007. United States Environmental Protection Agency (USEPA). 2008a. Compilation of Air Pollutant Emission Factors, Volume I, Fifth Edition, U.S. EPA, and Supplements A through F. Office of Air Quality Planning and Standards. Research Triangle Park, North Carolina. January 1995. . 2008b. AERMOD Implementation Guide. January 9, 2008. . 2005. Guideline on Air Quality Models (Revised). Codified in the Appendix W to 40 CFR Part 51. Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. November 2005. . 1995. Screen3 Model User's Guide. Office of Air Quality Planning and Standards. Research Triangle Park, North Carolina. September 1995. EPA -454/B-95-004. 05252-008-140 6-1 October 2008 • ENSR • • Appendix A Colorado Construction Permit Application Forms & Air Pollution Emission Notices 05252-008-14Q OctetDer 2'JQ8 • ENSR • Construction Permit Application Form Company Contact Information Form Construction Permit Application Completeness Checklist 05252.008.190 Oc!ober 21b0 These sections tyre tai he costpleted only Vo company 9. Permit previously issued to: 10. Transfer of Ownership Information Effective !)ate of Permit Transfer: As responsible party for the emission source(s)lis sold. and agree to transfer the permit to said part) Signature of legally Authorized Person of Compt Type or Print Name and Official Title of Person S name change or transfer of ownership hos occurred. Air Pollution Control Division (AI'CD) - Construction Permit Application PLEASE READ INSTRUCTIONS ON REVERSE SIDE. 1. Permit to be issued to: 2. Mailing Address: 3. General Nature of Business: OXY USA WTP LP 2754 Compass Drive, Suite 170 Natural Gas Comprestlo SIC code (if known) 1321 3 Air Pollution Source Description: (List permit numbers if existing source. attach additional pages if needed) Processing, and Treating Three (3) inlet compression It engines (Cat C3616L1:), three (3) gensels (Cal G3512LP).TEG Dehydrator, two (2) HAFT heaters and an emergency flare. _ 5. Source Location Address (Include Location Map) Conn Creek Gas Treating Facility 11 SW/SW Section .32, T6S, I197%\` Is this a Portable Unit? NO If portable, include the initial location and home base location Garfield County. Colorado 6. Reason for Application: (Check all that apply ) • New or Previously Unreported Source O Modification of I xistine Source O Request for Synthetic Minor Permit [] Other: . Projected Startup Plate: March 209 t dnitnistrative Permit : tine ral+tt, nig O Transfer of Ownership (Complete Section. 9 & 10 below) • Co+npany Name Change (Complete Section 9 below) o Other; _ Signature c Yegally Authorized Per- o+ Company listed in Section 1 Alonzo Hernandez — PIES Supndeitl Type or Print Name and Official 'lithe of Person Signing Above S. Check appropriate box if) DLI want: 0 Copy of preliminary analysis conducted by Division To review a draft of the permit prior to issuance Mail completed application. APEN's. Colorado Department of Public I Air Pollution Control Division -1300 Cherry Creek Drive South. Denver, Colorado 50216.1530 /v -7-a8 Date Signed Phone 970-263-36U9 Fax 970-243-2525 ted above. I certify that the business associated with this source has been Ay fisted in Section igning Above Phone: Fax: Date Signed and filing fee to: health and Env ironment A PC' i)—Ss-131 ILttp:rtxyw►y.cdlphe state.co.us'tip.stationary.hnnl Phone: (iO3) 092-3150 Revised August 2004 • • Form APCD-101 Colorado Department of Public Health and Environment Air Pollution Control Division Company Contact Information Form Ver. September 10. 2008 Company Name: OXY USA WTP LP Source Name: Colorado 1)epartntent of Public I lcalch and Environment Conn Creek Gas Treating Facility H Permit Contarlt: Alone Ilernandcz Address: 2754 Compass Drive. Suite 170 Street Grand Junction CO 81506 City StAle /,ip Phone Number: 970-263-3609 Fax Number: 970-245-2525 E-mail: aloneo_hernandez cDoxy.cont Billing Contact: s Same As Above street City Stale Compliance Contact': Address: Phone Number: Fax Number: E-mail: Alonzo Hernandez 2754 Compass Drive. Suite 170 Street Grand Junction ity ^CO lip k 8150+5 970-263-3609 970-245-2525 a l on zo_h c rn an de z@o xy .c m Billing Contact: Address: Phone Number: Fax Number: E-mail: Check how would you like to receive your permit fee invoice? Mail: E-mail: El Fax: Same As Above Skrrs^I 1 State Lip Footnotes: The permit contact should be the point of contact for technical information contained in the permit application. This may be a company representative or a consultant. ' The compliance contact should be the point of contact for discussing inspection and compliance at the permitted fail ity. The billing contact (Permit Ices) should be the point of contact that should receive the invoice for fees associated with processing the permit application & issuing the permit. (Reg. 3, Pat A. Section The billing contact (Annual fes) should be the point of contact that should receive the invoices issued on an annual basis for fees associated with actual emissions reported on APENs for the facility. (Reg. 3. Part A. Section VI.C) Page I of 1 ccoir ii_ .i Ambient Air impact Analysis - n Check here if source ern: Operating & Maintenance (O& See Appendix A of Application n Check here if true minor ter4 of Application 'CD to complete regulatory analysis (Attachment • • Form APCD-100 Colorado Department of Public Health and Environment Air Pollution Control Division Color -Ado !_icpsi 'ILL•/I( of Public! icaldt Oil & Gas Industry and Elivicon men t Construction Permit Application Completeness Checklist Ver, September 10. 2008 Company Name: Source Name: Date: OXY USA WTP LP Conn Creek Gas Treating Facility iI October 7. 2008 Yes No Arc you requesting a facility wide permit for multiple emissions points? In order to have a complete application, the following attachments must be provided, unless stated otherwise, If application is incomplete, it will be returned to sender and Mine fees will not he refunded. tachmenl Application Element A A'PE.N Filing Fees — Sent separately via email Air Pollutant Emission Notice(s) (APENs) & Application(s) for Construction Permit s - A PCD Form Series 200 -See Appendix A of Application Emissions Calculations and Supporting Documentation See Cha •ter 3 & A radix B of - • •fication R C E F G 11 Applicant APCI Company Contact Information - Form APCO-1D1 -See Appendix A of Application see Chapter 5 & Appendix C & t7 of Application ® ❑ is only VOC (Attachment E not required) Facility Emissions inventory -- Form APCU-102 See Chapter 5 & Appendix B of Application Check here ifsingle emissions point source (Attachment F not required) Process description, flow diagram and plot plan of emissions unit and/or facility •- Sec Chapter 2 of Application [� Check here if single emissions point source (Attachment G riot required) Regulatory Analysis - See Chai ❑ Check here to request A I not required) M) Plan - APCD Form Series 300 emissions source (Attachment i 1 not required) El ❑ Send Complete Application to: Colorado Department of Public Health & Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Check box if facility is an existing Title V source; Send an additional application copy Check box if refined modeling analysis included: ® Send an additional application copy Page 1 of t rCC iF i1_Form rco-lee-Appcompiocc eckhst-ver i•!r+•2C8 dk+: • • ENSR Caterpillar G3616 IC Engines APEN (3 Engines — 9 APEN) 45252-009-14G Oct Op@rzoo • • Internal Combustion E APEN) & Application for Construction Permit — Rec AIR POLLUTANT EMISSION NOTICE c4 Kl 0 Emission Source Al. blank unless APCD has already assigned a permit ti & AIRS ID] Permit Number: how tins equipment is referenced within your nrganimtion.J (Provide Facility Equip N 0 0 Request for NEW permit or newly reported emission source Request PORTABLE source permit a = J. °.. t c a M. 2,~. V a L . C Y m 4+ G J L✓ c C e .0 - C v. C G •. C C C a C L - F „2 G = C.1 .-- i V _ CO Jl V i al,. O '� C E" F1. o m c Y n 'v t a a V E. C a at a 0 50;---; r •gip L' 'IC G 4 11' s LY V "Jr C C9 ✓ -0 %' V 1.. 91. L 0 C G u ,, C E v E _ v E a o 7...� .G ,e d cr E s' v .'n o w i U U v C1 C K L • y au U U c V aj :-.,F." 33 3 a CC 4:. Cd CIs °.6u a ❑ L. I �❑❑ ❑❑ ❑4 Z sources. the protected startup dat Section 01 - Administrative Information N +'1 O CJ U d Z u: Conn Creek Gas Treating Facility II CC Ca 0 vOj C 0 SW/4 SW/4 Section 32, T6S, 8971 0 L. CP, O 11 g Drive, Suite 170 O C O C i O r!r N CC - v Phone Number a •0 C T. (970)243-2525 z a a C E-mail Address Section 03— General Information a CC a P C _ aG U Z n "G 2 u U o N ❑ ❑ U N G E F= - - m ca, c. C C APEN forms. L Ca L 0- O V C- 1.1 C o For existing sources. operation began on Normal houra of source operation: General descript inn of equipment purpor after 6112106 Date the engine was ordered: = Date the engine was relocated into Col Engine displacement: n/a Serial No.: -FBIi after January 1, 200S Engine date afmanuf. Manufacturer: ❑❑ C 0- Pd a a .C.. y co q a ov Y •.P 6. N oC K 8 L � Cµ C m 'U C C a 0 a. •G yr — C O 0. G T 58 ca 7i I) 2 2 G p ti! C O at 0 a a � Ca UU .� El el u U} y ti c � o = CC o - CCGTF 11 ForinAt'CD-201-MCI APEN Cat 3616doe 151 Ca CL sC Manufacture's max Manufacturer's max Engine FORM APCD-20I I n2 Internal Combust' G 7 f - .73D C O L s 6 :J F 8 i V C E • C et G. r�.=c -r - ' MD CD .r, c+c®cc C; c,®v,o 0 MFF, r r r r- .91 +1 R R .1 K K 5C yf��; .1 Y. y.7. c lF• Y M ae ,„ „,M „,- - F Pte- r- n rM- r- r - 0,1 W In U 05– Stark Information I An Mr 5 gi n 47 !j. irr 43 a o :i itwLI; L,.1 5 v 0 Vortical with ohttntt N 'l. n CC 3 • z 2 74 E - 0 G C G C d C � o mC P ue! 0 Z A !r. 7 to H � g a LL L 279.1 MMsc S! G c v 1 flticction of s 41. A %/MEAI. E\ FOR EACH 41 }stim;xtirat IsIcthud or F..missir n Factor I— Source - atAtmlcin 3z. Cttlys_--- Pd IN 2 L=' a r r C C C 0 F o .4:7'M - a N r!, c 50% 5.14E-03 Ihf►MMMBtu 0.1 0.4 AP42 Thl 3.2-2 &li ns. Ox. (:tttalyst , 50% 1.40E-04 Ihf l hBtu 0.06 0.03 A1'42It:1 3.2-2 l _ Please use the APCD Non-C:riterw�sortable Air Pollutant :Addendum form to rort pollutants not listed above. _ J 7.j C UC a Y [' V R M 3 u } w , L. Mq ra +r, G *r .1 • w c V. ,n. Actual Calendar Year Emissions' Uncontrolled Controlled T n0Yesr} fl om' 'ear) I ` I Emtsston Factor J V L L L t L .0 L .0 Y.' - o L G r ® o ® ri6 i r ! N2 na 111 g 0 13 La fB C • C C F. T� v n A o Control Device Description 1 = C' >Y. w n O atj n ^v w a Oy a w O a-. F. .,7, Z > U 48 • ENSR • • 05252.008.140 Caterpillar G3512 IC Engines APEN (3 Engines — 1 APEN) Ociutt, 2CO8 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Reel :reed a permit k & AIRS ID] ss APCD has ahead!. 'Leave blank un Permit Number: referenced within your organization catty Equipment 11) to identify how this equipment Facility Equipment n (check applicable request hexes) N 0 Section 01 — Administrative Information Request for NEVE.•' permit or newly reported emission source Request PORTABLE source permit 5 C RF 0 e ion uuwentary limits or previously reported Change fuel or equipment Change permit limit E❑❑ DO L L.L. 0 G S i Q v m 0 v >` p ✓ O a U U 0 T. U • Lo U u OXY ISA wrr LP z n. E 0 0 3 2754 Compass Driv C 0 L C C + L 6. '0 ▪ = r C. {� .'J3 e. t • w C o c. .2 c "f .2 epY. ci 0 r , O o C ❑ �.�1 Alonzo I lernander. •a} E-mail Address: Section 03 — General Information 0- sources. the project For new or reconstruct 0 G. ✓ t, 4I � E r IW C. 4 -g 0 L C. • 107 U b N C C 0i 47. -0 It '= 0 - 2 W ,l L Date engine construction commenced: a N V L. m C e rJ o 1(1 L.-) f1 fes. fF ,�, e 0,•° SD se fn •1 f"7 0 O L rn v _ G We L. c Date of any reconsttvctionimodificatiout: C ne was relocated into Colorado: W cc 0 0 z ►1 0 R F C U C E E C Cr r < ,Z = • e' C 2y C. V L E CJ "Le a r Q 7., • C ineInformation Section 04 — En cc C m c 4 v E z. .G LJ CC LY o _§.' e V, R ❑ .':_l -o G = y Dl R LF .0 L'.. L' E O O- VAL L a • 0 UJ after January 1, 2008 N C c R 713 Manufacturer: 0 Pr a L E 0. C, C. 1 O 0 -0o E • EC Engine function 0 4 N M or; C u a c4 1 u mS e C C iJ Cr � a O C 0 0 0. X L L 0 G C- V u a v 9 2 0 O 22 y -E U E ▪ 5 g J 0 rI /r4 L 0 5 _ Lt E V Q C C`• J a a Manufacturer's maximum rated h Manufacturer's maximum site rat N C•' r 0 0 a Engine Brake Specific Fuel Canso Qom. 0 C1 J a 0. 1 Ve a E ACJ Cc C V G C E C G Cc u FORM APCD-201 CCCiTF II FormAPCD-2LI-RICEAPF N Cat3512doe N 0 U Cd Ll rocatine. Internal Combustion En AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — 7 Lc K R � Ast 4.4 5 9 H 0 3 04, xturol Girt 0 onstnvcnto cctmn 07 — F:mi t C 5 52 . 4 EW t AP42 Th{ 3 2-2 I A "` 8 C 8 C 4 C A A .+i L t ''`I '1 W P42 Tbl 3.2-2 T M v C z.7 c C L 9 y r=. it 2 S V Q V V Rcqucsted Permitted Emissions la 5 g D C =, 2.R 1 f rt O O ..7 £ tit n 111 �It J, e f Iti W 'G .- 5_0 grl100 scf I.{0 t glbhry-hr , s 1. r 'i-- ..l. 7 A 7. 7 in 1. 7 m r, .--' L c La _ C7 C! G ���1 �4 ri G. :-; i7 M � Lr ". Z y.] K Control %f cii nc (% Reduction) C v rt a ; s n H 3 t4 a S N c et C 2 r d rJ` t� ~i rorm3:Jr4. do r s J• c II FounAKL) 20 Att I Al'l. ri • [5252-0CZ-14C HMH Heaters APEN (2 Heaters — 1 APEN) ENSR Ccixe: 2GOE3 C 6 O � 0 7. F E 2 r r C � r EE i1 Fori nAr'c[}_'YJ €icrirratAPEN 1 1Hs dor CI C FORM APCD-200 Permit Number: • C S ection 05 — Emission Release informs 7 N 3 a C qJ Y. 7 d ^�9 F. 7.77 Y3 1,1 L. I14:A I EH S ection 07—Emissions Inventory Information & Emission Control Information NOTE: EMISSION INFORMATION IS FOR EAC:II IMMDIVID AP42 Tbl AP42 Thl i.4-2 I AP42 Thl 14 6 and emission Factor documentation to this ANN form len rt 4 ton oEon— ten a, s-. umb z V Y A E C 0. r- r - a - fornAPC-'a•2C1CiuTiiolAl'I N II • ENSR • • Tri -Ethylene Glycol Dehydrator APEN 05252-008-140 October 2608 • • • 0 0 L.1 G 0 L c 0 U 6r� LC 0 4,1 0 z U 7. 0 W i.3 1-4 O. C4 cc 0 U, ivied a permit « S AIRS IIJJ [Leave blank. unless APCD has already Permit Number: Facility Equipment ID: Section 02 — Requested Action (Check applicable request boxes) Section 01 — Administrative Information u 0 N b 6i 'h h 0 ❑ ❑ U Li L. L W L O a 1 O C 1 C} + ) G C V u 2 s7.1 NJZ 71 Company Name: CIXY (SA HTP LP 32, T6S, R97W SW/4 SWM Sec CC O g Grand Junction, CO E-mail Address: 3 y tit Section 03 —General Information or reconstructed sources, the projected startup date is: C lC Z Z ❑ co V yLI r r El 1E1 C 0 41 C 0 ;] u u aC. u CG G C xs• • o For existing sources, operation began on: Normal 1 -lours of Source Operatiun: 24 hoursfday General description of equipment and purpose: Triethylene glycol ► Is this unit subject to the 90% control requirement o1- Colorado Regula units at this stationary source. including APEN Exempt units. ? 15 ton g 4.. O N ur ear 5 01 07. i< alL• 41 = 3 t ✓ a H N f C w o C O U < Sa C� Ca Sa Ca a O7 -C • d at a stationary sou ■ Is this unit 1 C 0 C C v C ▪ R 52 79 oL+ u▪ • L Ci U C 0 ✓ O O ]IC rry ✓ ...1- — C' - r M. 41 0.. 0, 0, O' 'C .0 0 'C • u o O Cs▪ ' ti G u I, I� -a f.;° 'a1 LJ d a Z u o R- ." ,.� d '''471 L� 4 cn < < Section 04— Dehydration Unit Equipment Information O z C E 7 R N w5 78 of water content: i. 7 0 N z' z ❑ 2 n Yui r-. 'C ` • CJ C t «y1 - a (J o a %s e w t 0' ci. a E E. w N 0 ,c v Cd) El Ei 0 a B O C 1 recirculation rate (galfmin): Design Capacity: C O Can In A - u 2 E u C e C U C G O E. wgC,� 6 iJ 0 0 a- a o °u E E 4 O _a - V �? LJLj a 7 2.E Cr-i 678a B9nC Gm W 7 .g- G C © GC C G O- ZC.! = C v4d w x u L::. °a, 0 < C1} dd C t C t% v N nC C' Q 4o ..C.' 'O IT 4W G b S L; 8 P- C f • S1 N C7 v 1Cy C) t n0FLe n rs C C CCDM F It FonnAPC11-202DchyAPEN TF.GU due • • of llchvdraiion 0D O Emission Source AIRS ID: y 3a V a, C U 0 9. J Inner Diameter Permit 0 ea % ndlar regencr4 rols the Bash r tnk i Indicate i fa control device co Senior" 07 — Coot 2 8 to CZ C C Enclosed Combu C 8 te a Tj E Pe o J R. u ° F 3 $ ti 5 L 0 0 C C 2 c' C D. CC C n W + ' r ti. t. c ...1 5 w -- t V R— (.3 z V mi J u f.7 u R ;2 V z J U m :7 :a C i p E 7 7 0. r !, .t {; e V a Ems. E C...0 J rl S ~ s V , N Y 4. C O 'C, 4 C� G+ . Yhrconrnaiicd ITons ' rsrl ° rq °'i r. Sp+ r r ry ad 96 g r .11 u C C 7 L, r IN c r - y vI v`: I` w .— _. i. r J F G C7 V 'u L: 0, Identify in Section 07 Control ihniCe DCScription e C V7 i S LIt4. � nut xal i •u 4 4 3 0 • ENSR • Emergency Flare APEN 05252-008-140 October 2008 AIR POLLUTANT EMISSION NOTICE (ADEN) & Application for Construction Permit — General r CO 0 0 Emission Source AIRS ID: apermrir&MRS ID] Unlet APCD fu, ahead) a n Permit Number: or or:.:tnr-Ititx+.1 nr t5 rcle er4ca u rth nI ID to tdui:rll ti 1. thts ecus [Provide Fjcilir? kq Facility Equipment ID: Action (check applicable request buses) Section 02 — Re Section 01 — Administrative Information Request for NEW permit or nev.lr reported 0 Request rOR7 ABLE: source permit J C id G E I: % 4 c — L it .lo '� - a . 'J 1 L t O v m e n ,. J C 4f6. c 9 0.- . E 5 D Q „ ; 4' 9 2 .T c s. D cr re L 0 = = c u ti.l v a 'J ' y < G ✓ r.-... 44-t: 7 4 j . r' - D 2.-1}, GC A u 74 y c E7. `- 5 5 0 d' i Z7 C OM F s <'r n. U :� 9 otr 0 s J J 9 ❑ ❑ x =❑ ❑ .8 14 'Es y t 0 El e.w n C Source N:1TIl:. Source t.ocatk , G 0d 0 2754 Compass Drive, Suite 170 z -cc C. ra! nd Junction. CO Fax Number: 9 QI Section 03 — General Information e c I E c 7' C an ,f4 G a- c -. r+ t!a �i 4C .1. t 'it i .a L w,. _ - e cc d e� ^2 fi_ C C ? C ,� L. Y L '1 3 YPY .= { ... y c .f - J L ... r - y �. Zob d L J0 am EI 1 `-+ ~ E - L 2 J "1 C 7 O. r .D., :.. � �' G' - . a 6 i n F. _ .rz 1:• c fQ` o' Q y 0.c rr ,L �. O 4 E X +l p O7v: n t W ;It go CJ ,4 t a u G a L a o- • r C G L O i:. G J w. .i. Cl !i.7 d { F I c c c General description of equipment and purpogr fT N r Y 9 5- E a a. ..J a 7w x , W 5 C v C. xs � ui S c n l v 8 4 C 2 r 2 .a h.r C C -co c C a 9. 4 i3 v 9- e a o 0 .c u u L .9 ICJ 0 1 1 3 4 G ruivl1I over the n..1 II'. year~ kora Rei. .cstrJ {cvel �hnuldcpnai.k ,xu_r: :tcL .alum urtl becunw perm! (icr..ralAP1 N New Flare do: f IP I•oxu>_Al't ta- rl 0 9 FORM APCD-200 C O N I- r O r M r3 AIR POLLU'T'ANT EMISSION NOTICE (ADEN) & Application for Construction Perm co Lig C Emission Source AIRS ID: Permit Number: nn (Atiach a separate slicer with relevant infbrma C i 0 2 0 on of outlet (check mar Shape 1 Stec (check onr): 0 M 1 rC. Y C t 'J 7 L o 5 C' � LI E C C E tiC 1- (.4 fa4 r a •4 °Re uc1c,3 tialu : will b can% ix" rt lerltitatit Rn{ M N r� Z n 0 ri O C, a c e C C a r rxr w v to 4 Ci tc Control flc% ice Description C O 0 0 0 noble Air Pollu tan ■ a i 7 C r C E u C C GrocralAPEl+ Hix doc CL 57. ENSR Revised APEN for Permit No. 05GA0068 — Existing Three Caterpillar G3512LE IC Engines 05252-008-140 Octrbei 2008 • • Internal Combust AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit - Emission Source AIRS ID: ce aG E We [I gave blank unless APCD has 05GA0068 Permit Number: how this equipment is referenced within your organization I 0 [Provide Facility Equiprnen 6801, G802, G803 Facility Equipment ID: Section 02 — Requested Action (check applicable request boxes) Section 01 —Administrative Information Request for NEW permit or newly reported emission source Request PORTABLE source permit 0 M OXi'ISAWTPLf U E A z C. O L.) Change company name •transfer of onnership I- e. A V] C S LI u SW /4 SW/4 Section 32, T6S, R97W Source I.ocali Request to limit 11A Ps with a Federally enforceable limit on PTE Request AI'EN update only (check the box below that applies) 0 1. CC LI C- N 2754 compass Drive, Suite 170 Mailing Address A e j OW c C, i s C. o2--' "O L O a �+ c a O to a v .E u i E V 2 u & ' 1 = 8 O y K C N V C r tl .c U U M J N a 71 e+- E. 2 a c 'a1,-, Li; i az D c cC eOr O C U C = .Y u 0.W) E e . F R V C V v C � C, .� £ '6 ,t c ii V} D[ o >. 4 £ to c o «;" J G o e, o 4�ivvC U r. •j ,' 2L _ E N0. 01 `� U u 11 v 7. (;rand Junction, CO (970)263-3609 (970)243-2525 E E Z 7 O_ L. 1 Alonzo Hernandez E I Section 03 — General Information For new or reconstructed sources, the projected startup da General description of equipment purpos Date engine construction commenced: L. C O r L C. 4 Date the engine was ordered: a U r L., iO C C zy C- c Y.7 a- C N 'YJ U CL I •I tC n C T. M fie ^y L E c c o c S. C ii W n C i ea w 51 o to 2 • t 1 = :c E Cy. i. rA E e. N L U s I- O R L= C U Op ,0 LI o U a o a. ca C iX' e . n = © 7P N ... N O 7 J v "Y ,:t. V E 3 L L $ LM C T za, c E v� p i. _ < -= w `� `v L c o ca o a o c ~t' 0 8 o O f ^ G m O %; U d y U. = UQ O JL_, i p' O L .7 C 0 0. ir U Gi'E 2Z.+' <7C <d C �IC,^ VI rn CN ne Cv 4,L a- .2' .ns U V E M1J ^4 c. Date of any reconstruction/modification: C Date the engine was relocated into Colorado: a5 z 0 • C E a E c L C!) G CY!j < E. < '401 4 C. -i 3 LI1 £ 11- ine Information C C 0 Let: 00 0 C eV C b V R C lC E a U m L C Cd1 Lc C e. V a L Manufacturer L_ o a. ❑ a U4,3 U E c 7- v y. a E 7- El ❑ C v ri d;r. a a N c U C .rL C O Co C.C. 4 40 CO C. o. yu yU CJ U N U a C L V f :r V C -c ❑PI 0 C 17 C C r. I1 U 'a lz G 1st F. 0 `J} C'�.. • 0. C E x x CO CO c0 :.e G U 0 C E U C U C Manufacturer's maximum site razing P1 n 0 C C n a R U C C E 11U c P the maximum number of h CCtITF1 FormAPCf-20I-141( IN C FORM APCD-20I L AIR POLLUTANT EMISSION NOTICE (ADEN) & Application for Construction Permit Emissi• 5 0. F •r rs 4 e` 1 E Tr a Ito w 0 < U- E C d a r 04 Y A r62- O D 6 C u 0 C E 0 t a tC O m n E 4) G 9 C C: - k -40O 2 2 J 3 f E L. F J4 O' M E Q 6I C O 8 3 C G C e G y C G • C • o N F -r G C+ Y 8 C N 1• tlncon acoIled Ras!, 5 Oy C •C V; /. t' L F. Of 7 F-• ri t I. F G 0 L C. `cL C. s k a V V. 0 0 SY` 0 E 7 Q +O X. ,. L v a C •51. y' G 3 7 h 5 O e EE 0 G • ENSR • Revised APEN for Permit No. 05GA0069 -- Existing Ethylene Glycol Dehydrator (now TEG Unit) 05252-008-140 GuoDer 2CCC