HomeMy WebLinkAbout2.0 BOCC Staff Report 04.13.1992REQUEST.
BOCC 4/13/92
PROJECT INFORMATION AND STAFF COMMENTS
Special Use Permit for industrial
support facilities, specifically for the
production of liquid hydrocarbons
from natural gas.
APPLICANTS: Colorado Clean Fuels
LOCATJON:
A parcel of land located in portions
of Sections 34 & 35, T6S, R96W and
Section 2 & 3, T7S, R96W; more
practically described as a parcel
located approximately two (2) miles
northwest of Parachute, off of C.R.
215.
SITE DATA: 241.23 acre site
WATER:
aEMEER:
ACCESS.
EXISTING ZONING:
ADJACENT ZONING -
Bottled drinking water and existing
wells
Sealed vaults pumped by licensed
commercial sewage haulers.
County Road 215
RIL - Lower Valley Floor
R/L - Lower Valley Floor
I. RELATIONSHIP TO THE COMPREHENSIVE PLAN
The subject property is located in District D - Rural Areas, Moderate Environmental
Constraints.
II. DESCRIPTION OF THE PROPOSAL
A. Site Descri tp ion: The site is a relatively flat valley floor area, located between
the County Road and Parachute Creek. Presently the site has industrial support
facilities used for the upgrade, storage and transport of crude shale oil. A
railroad spur comes into the site from the south and extends along the west side
of the site and the eastern boundary is C.R. 215.
B. Project Description; The applicants are requesting the issuance of special use
permits for industrial support facilities for industrial operations for the
production of liquid hydrocarbons from natural gas, in addition to the existing
permits issued to Unocal for the shale oil upgrade facility. It is proposed by the
applicant to use the existing Unocal upgrade facility, with some minor
modifications to manufacture methyl alcohol (methanol), smokeless diesel fuel,
premium grade naphtha and Fischer-Tropsch (F -T) wax from natural gas. It is
proposed to produce 4500 barrels per day (BPD) of all of the products noted
previously, with 4200 BPD of the production being methanol.
The proposed process will utilize the existing upgrade facility, truck loading
facility, railroad spur, natural gas pipeline and power line. At the upgrade site,
the Unocal dearsenator, Unicracker, Unifiner, dewatering equipment,
pretreatment facilities, sulfur and ammonia removal equipment will not be used
as a part of this process. The applicant will add an F -T vessel, methanol
synthesis loop, PDX vessels and a waste heat recovery system to the existing
facility without removing any of the existing equipment. While these portions
of the existing facility will not be utilized, it should be noted that they will remain
on site for future shale oil upgrading. This application will only allow one of the
proposed production processes to occur at one time. Should Unocal or a new
owner of the property reinitiate shale oil production, the applicant's processing
of natural gas will discontinue.
The principal means of transporting the methanol will be by rail. It is projected
that two to three times a month, a 100 car (30,000 gallons/car) unit train will go
out of the area to the proposed markets. If for some reason the train transport
is unavailable, the methanol can be shipped by truck out of the existing truck
loading facility. If this alternative is used, it would result in approximately 24
truck trips daily. All other products will be shipped by truck, at a rate of less
than one truck per day for each product.
During construction, it is estimated that 110 workers will be employed at the
peak of the 10-12 months it will take to add the new equipment and modify the
existing facilities. During operation, there will be an estimated 21 full time
employees.
C. Background: Unocal received a number of permits in 1981 and 1982 for the
upgrade plant and various associated facilities. While Unocal has suspended
their shale oil production, the facilities are not being removed, thus, all of the
permits issued previously are still valid.
III. MAJOR ISSI JES AND1T ONCERNS
1. Zoning: The requested land uses are proposed to be added to the existing and
uses already permitted. Because the zoning resolution does not have a provision
for modifying or amending a special use permit, the requested permits have be
considered new permits to be added to the existing permitted uses.
The applicant has submitted an impact statement to supplement the previously
accepted impact statements submitted by Unocal in support of their existing
land use permits (see application pages 15-20) and the supporting documentation
noted further on in this report.
In summary, the impact statement says that the proposed new process will
comply with the existing state and federal permits and that the impacts will be
less than the present facilities due to a smaller level of production and less toxic
byproducts.
Any approval of the proposed project should require compliance with previously
approved resolutions of approval, as well as any new conditions of approval.
2. Air emissions from the proposed project are projected to be less than the existing
permitted levels. Concerns have been expressed about the applicants ability to
transfer the existing permits to the new operation. Enclosed are letters from the
U.S. Environmental Protection Agency and Colorado State Department of
Health, Air Pollution Control Division (see page ). The EPA letter notes
the transfer process to another owner is "quite simple." The EPA letter also
notes the PSD (Prevention of Significant Deterioration) permits previously
issued by them is new the responsibility of the Colorado Air Pollution Control
Division. The CDH Air Pollution Control Division set out a procedure that
does not appear to present any major obstacles. Prior to receiving these letters,
staff had conferred with the Grand Junction Air Pollution Control Division
representative, who indicated that the transfer procedure was relatively simple
and ministerial in nature.
3. Enclosed are supplemental statements from the applicant further clarifying the
type of reclamation that would occur and that there will not be any unacceptable
impacts due to sound and vibration (see pages ).
4. Enclosed is a letter from Joyce Risley, expressing concerns about the emission
of nitrogen oxide and carbon monoxide (see pages ).
IV. SUGGESTED FINDINGS
1. That proper publication and public notice was provided as required by law for
the hearing before the Board of County Commissioners.
2. That the hearing before the Board of County Commissioners was extensive and
complete, that all pertinent facts, matters and issues were submitted and that all
interested parties were heard at the hearing.
3. That the application is in compliance with the Garfield County Zoning
Resolution of 1978, as amended.
4. For the above stated and other reasons, the proposed use is in the best interest
of the health, safety, morals, convenience, order, prosperity and welfaret
citizens of Garfield County.
V. RECOMMENDATION
APPROVAL, subject to the following conditions:
1. All proposals of the applicant shall
stated otherwise by the Boa
of County Co
a�
itzeti
iral permits shall be submitted prior
2. That copies of all transferre
to issuance of any special use permit.
onditions of approval unless
is ioners.
3. That all conditions of approval contained in Garfield County Resolutions No.
81-11, 81-12, 81-281, 82-158, 82-186, 82-145 and 86-30 shall be complied with by
the applicant.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
999 18th STREET - SUITE 500
DENVER, COLORADO 80202-2405
Ref: 8ART-AP April 2, 1992
Garfield County Commissioners
109 8th Street
Glenwood Springs, Colorado 81601
Dear Commissioners:
• it
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Unocal has requested that EPA provide you with information
about the procedures required to transfer the existing Unocal
Prevention of Significant Deterioration (PSD) permits to the
Clean Fuels. Development Corporation. The procedure for
transferring the PSD permit of an operating source from one owner
to another owner is quite simple. It is done by notifying the
issuing agency of the name, address and contact of the new owner
and acknowledging that the new owner will operate the plant in
accordance with the PSD permit.
However, there is a problem in transferring a PSD permit for
a source that has-been shut down. If the source was temporarily
shut down, the PSD permit is valid only if,the source will be
operated in the same way that it was operated before the
temporary Shut down. Any changes in the method of operation
would require that the new owner obtain a new or modified permit
from the permitting authority. The federal PSD regulations in 40
C.F.R. 52.21(r) state, "Any owner or operator who constructs or
operates a source or modification not in accordance with the
application submitted pursuant to this section or with the terms,
of any approval to construct ..., shall be subject to appropriate
enforcement action." It is our understanding that Clean Fuels
Development Corporation does not plan to operate the Unocal plant
in the same way that it was previously operated before the
.temporary shut down in June 1991. Therefore, a new or modified
permit must be obtained to allow Clean Fuels Development
H
Corporation to operate as planned. The permitting authority ford%
any new or modified permit is the Colorado Air Pollution Control.:'
Division. The Division now has the authority to issue PSD
permits, as well as all other construction permits for sources in
Colorado.
If you would like to discuss any questions related to
transferring PSD permits to another owner, please contact John
Dale at (303) 294--7611 or Carol Smith at (303) 293-1768.
Sincer ly,
CL--- , c
JohnjO. Ridinger, A ing Director
Air, Radiation, and Toxics Division
cc: Jim Geier (CAPCD)
Leon F. Pahler (Unocal)
§ 122.63
1982. and the permittee applies for the
modification no later than January 24,
1985. If the permittee shows good
cause in its request and that it quali-
fies for the modification. to conform
to changes respecting the following
regulations issued under that Settle-
ment Agreement:
40 CFR 122.45(b)
40 CFR 122.45(c)
40 CFR 122.50
(18) Land application plans. When
required by a permit condition to in-
corporate a land application plan for
beneficial reuse of sewage sludge, to
revise an existing ' land application
plan, or to add a land application plan.
(b) Causes for modification or revo-
cation and reissuance. The following
are causes to modify or. alternatively,
revoke and reissue a permit:
(1) Cause exists for termination
under § 122.64, and the Director deter-
mines that modification or revocation
and reissuance is appropriate.
(2) The Director has received notifi-
cation (as required in the permit. see
1122.41(1)(3)) of a proposed transfer
of the permit. A permit also may be
modified to reflect a transfer after the
effective date of an automatic transfer
(§ 122.61(b)) but will not be revoked
and reissued after the effective date of
the transfer except upon the request
of the new permittee.
(Information collection requirements in
paragraph (a) were approved by the Office
of Management and Budget under control
number 2040-0068)
(Clean Water Act (33 V.S.C. 1251 et seq.).
Safe Drinking Water Act (42 U.S.C. 300f et
seq.). Clean Air Act (42 U.S.C. 7401 et seq.),
Resource Conservation and Recovery Act
(42 U.S.C. 6901 et seq.))
[48 FR 14153, Apr. 1, 1983, as amended at 49
FR 25981. June 25. 1964; 49 FR 37009. Sept.
29, 1984; 49 FR. 38059. Sept. 28, 1984; 50 FR
4514.. Jan. 31. 1985; 51 FR 20431, June 4.
1988; 51 FR 26993. July 28. 1986; 54 FR 258,
258, Jan. 4. 1989; 54 FR 18784. May 2. 1989)
9122.63 Minor modifications of permits.
Upon the consent of the permittee;
the Director may modify a permit to
make the corrections or allowances for
changes in the permitted activity
listed in this section, without follow-
ing the procedures of Part 124. Any
permit modification not'processed as a
40 CFR Ch. 1 (7-1-89 Edition)
minor modification under this section
must be made for cause and with Part
124 draft permit and public notice as
required in § 122.62. Minor modifica-
tions may only:
(a) Correct typographical errors;
(b) Require more frequent monitor-
ing or reporting by the permittee;
(c) Change an interim compliance
date in a schedule of compliance. pro-
vided the new date is not more than
120 days after the date specified in the
existing permit and does not interfere
with attainment of the final compli-
ance date requirement: or
(d) Allow for a change in ownership
or operational control of a facility
where the Director determines that no
other change in the permit is neces-
sary. provided that a written agree-
ment containing a specific date for
transfer of permit responsibility, cov-
erage. and liability between the cur-
rent and new permittees has been sub-
mitted to the Director.
(e)(1) Change the construction •
schedule for a discharger which is a
new source. No such change shall
affect a discharger's obligation to have
all pollution control equipment in-
stalled and in operation prior to dis-
charge under § 122.29.
(2) Delete a point source outfall
when the discharge from that•outfall
is terminated and does not result in
discharge of pollutants from other
outfalls except in accordance with
permit limits.
(f) When the permit becomes final
and effective on or after March 9.
1982, conform to changes respecting
§§ 122.41(e), 122.41(1),
122.41(m)(4)(i)(B), 122.41(n)(3)(1) an
122.42(a) issued September 26, 1984.
(g) Incorporate conditions of a
POTW pretreatment program that
has been approved in accordance with
the procedures in 40 CFR 403.11 (or a
modification thereto that has been ap-
proved in accordance with the proce-
dures in 40 CPR 403.18) as enforceable
conditions of the POTW's permits.
t48 FR 14153. Apr. 1. 1983, as amended at 49
FR 38051, Sept. 26, 1984: 51 FR 20431. June
4. 1986; 53 FR 40618, Oct. 17. 1988]
108
C 6 J9:
Environmental Protection Agee.
A 122.64 Termination of permits
Me to State programs. see 9 123.
(a) The following are causes
urinating a permit during its to
for denying a permit renewal a
tion:
(1) Noncompliance by the per
with any condition of the permit
(2) The permittee's failure in 1
plication or during the permit is:
process to disclose fully all re
facts. or the permittee's misrer
tation of any relevant facts (:
time;
(3) A determination that the p
ted activity endangers human
or the environment and can of
regulated to acceptable leve
permit modification or terminat:
(4) A change in any condition
requires either a temporary or r
Hent reduction or elimination t
discharge or sludge use or di
practice controlled by the perm
example, plant closure or termti
of discharge by connection
POTW).
(b) The Director shall follow
plicabie procedures in Part 1
State procedures in terminatin
NPDES permit under this sectiol
(48 FR 14153. Apr. 1, 1983; 50 FR 69
19. 1985. as amended at 84 FR 18784.
19891
APPENDIX A-NPDES PRiT4A'
INDOsTRY CATEGORIES
Any permit issued after June 30.
dischargers in the following categon,
include effluent limitations and a .
once schedule to meet the.requiren+
section 301(b)(2)(A), (C). (D); (El ant
C\VA. whether or not applicable (.
limitations guidelines have been proi
ed. See 44 122.44 and 122.46.
Industry Category
Adhesives and sealants
Aluminum forming
Auto and other laundries
Battery manufacturing
Coal mining
Coil coating
Copper forming
Electrical and electronic component:.
Electroplating •
Explosives manufacturing
Foundries
Gum and wood chemicals i
Inorganic chemicals manufacturing
II
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REF: 8AH-A
it
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
1860 LINCOLN STREET
DENVER, COLORADO 80295
CERTIFIED MAIL - PO
RETURN RECEIPT REQUESTED
MAY 2 7 1981
Allen C. Randle, Vice President
Union Oil Company of California,
Oil Shale Operations
Valley Federal Plaza, Suite 505
Grand Junction, CO 81501
Dear lir. Randle:
We have completed final review of your application to construct and
operate a shale oil upgrading plant and hereby issue conditional approval
pursuant to U.S. Environmental Protection Agency (EPA) Regulations for the
Prevention of Significant Deterioration (PSD) 40 CFR 52.21 (as amended
43 FR 26388).
The conditional permit shall become effective in accordance with Article
IV of the enclosed permit. Construction and operation may not take place if
this permit or any part thereof is rejected.
If you have any questions, please contact Mr.John T. Dale of my staff at
(303) 837-3763.
Enclosures
cc: James M. Lents
Sincerely yours,
Roc ert L uprey, D
Air and Hazardous I
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CONDITIONAL PERMIT TO
COMMENCE CONSTRUCTION AND OPERATE
(40 CFR 52.21(i)), Significant Deterioration of Air Quality
Union Oil Company of California,
Oil Shale Operations
Valley Federal Plaza, Suite 505
Grand Junction, CO 81501
I. INTRODUCTION
Union Oil Company of California, Oil._ Shale Operations (hereinafter "the
Applicant") proposes to construct and operate a 10,000 BPD shale oil upgrading
plant in Garfield County three miles north of Parachute, Colorado.
On September 29, 1980, the Applicant requested permission from the U.S.
Environmental Protection Agency, Region VIII (hereinafter "the EPA") to
construct the proposed complex pursuant to 40 CFR 52.21 (Review of Major
Sources and Major Modifications).
The EPA issued a public notice in Rifle Telegram, a newspaper of general
circulation in the area on March 11, 1981. The notice proposed approval of an
air quality permit for the source and gave opportunity for public comments
during the ensuing 30 calendar days. The permit application, and the proposed
permit and its supporting analysis were made available for public inspection
at the Office of the Garfield County Clerk in Glenwood Springs, Colorado. The
public comment period was extended to May 11, 1981. On May 6, 1981, the
Applicant submitted proposed changes to the plant design. A summary of
written comments appears in appendix II.
II. FINDINGS
On the basis of information in the administrative record (see appendix I for
partial listing), EPA has determined that:
1. The applicant will meet all of the applicable requirements of the
PSD regulations.
2. No applicable emission or ambient air quality standard will be
violated by the emissions from this source.
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3. EPA has good reason to Relieve that the Company can comply :•ritn the
conditions of this permit. However, in the issuance of this
permit, EPA does not assume any risk of loss which may occur as a
result of the commencement of construction and operation by the .
Applicant if conditions of this permit are not met hy the Applicant.
4. The stack parameters used for modeling are contained in Table IV.
III. CONDITIONAL PERMIT TO CONSTRUCT AND OPERATE
On the basis of the findings set forth in II above, and pursuant to the
authority (as delegated by the Administrator) of 40 CFR 52.21(r)(2), EPA
hereby grants conditional approval for the Union Oil Company of California,
Oil Shale Operations to commence construction and operation of shale oil
upgrading plant. This approval is expressly conditioned as follows:
1. :The owner or operator shall ebida by all .ceprasentataons,
'•ste.t-errients.Df-'nt ot, and agreem;nts contained in the application
-from Union Oil Company of California, Oil Shale Operations and in
all additions and amendments thereto.
VA1 4 U 01°'P ' 2. ¶tri"dpp1icant=sha:ll.>.:..imi.t=emiss4ons ,Emco=tiie-7sourcemtortljos lsJ]ovrn -
�� Ori --Table==�mial.l.e.:SI,mAnd.Jab.le:�j1•1.
n -- -sulfur=recover
y p 1 ant-stia '1 -W"1 iMi C"ed"•tarp A30
-percent,by'-i 1ff e -nf- :•dacebi sulfur-compounds=and 0:001U-percent=layi
-volurnG.,:of hydrggen,..su.l•fide :calculated-as:.:sulfur..--dioxJcle .atrztero 4'
_per..cent..oxygen--on -a -dry-ha. Comp-tiancecwrith-rthis_ernis-sian--limirt a
shal`•I-be-based-on data-from--The-Cnntino6ff5- rfls `-t10-rritorLCEii
a i eq i r e in=.Cond1tionr5' and appropriate- sourcez-test-met foils.
4. HSS'�oncentratiori - in-ftiel' g"ayesT'Sfral-riot,=70cceed-.O:•10
cgrains/dscfi. Comp tenteT-shall-be-haled- on -data __f rom•.•the-•CEM--as
r�4gpiz'ed..in.. c 'tion�(i and -appropriate- source -test-methods:.-
5. A continuous monitoring system for:measuring sulfur dioxide shall
be installed, calibrated, maintained and operated by the owner or
operator. This system shall be located in the exit gas stream of.
the sulfur recovery unit. The monitoring system sT 1 comp y with
the aporopria a requirements in 40 CFR 60.7c. Quar.terly%excess !`, I°;
Emission -.reports and--record}seeping ,requirements -specs 0vOFR
50'105"•sliai1"b fo'i'lo011: Periods-af--ext ss iss7ons r'C=der ried
ras-any._roar4ing-twelvehour-per'idd-during,which7the average
concentration -of,hydrogen su-lf-ide:•or-reduced ,sulfur. -compounds -0' j
he gases-d1Scharged--into--the---atmosphere-exceed-the-emissi on,..l,j.rrgt
iri tondit,ion 3.
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6. A continuous monitoring system for measuring and recording
concentration of hydrogen sulfide in fuel gases to be burned shall
be installed, calibrated, maintained and operated by the owner or
operator. This system shall be located at a point which accurately
represents the con .I • _'• • •• 1 #f• "u• as
burned and shall have a span of 30p_2m _ Periods of excess
emissions re as any running three-hour period during which
the average concentration of hydrogen sulfide exceeds 0.10
�" '�• grains/dscf. Equipment design specifications and performance
� ) procedures must be approved by EPA prior to purchase.
7. Properly performed performance test results which exceed the
emission limits in Table 1 unless specified elsewhere shall
constitute prima facie evidence in any proceeding to enforce the
terms of this permit that the emissions from the source exceed the
limits.
8. At all times, including periods of start-up, shutdown, and
equipment malfunction, owners and operators, to the extent
practicable, shall maintain and operate the facility in a Manner
consistent with good air pollution control practice for minimizing
emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information
available to the Administrator, which may include, but not be
limited to, monitoring results, review of operating and maintenance,
procedures, and inspection of the source.
9. rf" :Applicant':stYall::not1fy.-EPA"within '48 hours -"of discovery (or as
soon as possible) of:exces- "emissions dur.irig-periods"af-start-up,
shutdown, equipment malfunction,--or-process upset": Within 10.days
of discovery all of the following shall be provided to EPA in
writing:
•. a. The identity of the stack or other emission point where
excess emissions occurred
b. The magnitude of excess emissions expressed in terms of
permit conditions
'c. Pertinent operating data during the time of upset
d. The time and duration of excess emissions
e. The identity of the equipment or process causing the upset
and the suspected reasons for the upset
f. Steps and procedures taken during the upset period to
minimize excess emissions
g•
Steps and procedures taken or anticipated to be taken to
prevent reoccurrence of the upset conditions
10. This permit shall expire if construction is not commenced within
the time specified or, once commenced, construction is delayed for
the time specified in 40 CFR Section 52.21(r)(2).
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11. Permit transfers shall be in accordance with 40 CFR 122.
12. EPA and its authorized representatives may inspect the permitted
facility dur.ing:inormal _business- hours, for purposes of ascertaining
compliance with all conditions of this permit.
13. All pgrformance-•testin'g required pursuant to this permit shall be
conducted in accordance with the time schedules and procedures
contained in 40 CFR Section 60.8 and in appendix-.-t4J of this
permit. The permittee shall demonstrate compliance with all
emission limitations of this permit not later than 45 days after
the first day of the required performance test.
14. The Applicant shall prepare an ambient air quality monitoring plan
that will determine the impact of source emissions on air quality.
The pollutants to be measured are sulfur dioxide, ozone, and
nitrogen oxides. EPA shall approve the site locations,
instrumentation, duration of data collection, and determine when
the plan should be implemented. All monitoring must conform to the
requirements of 40 CFR Part 58. The monitoring system must be in
place and operating prior to the plant's operation.
15. Nothing in this approval shall excuse the Applicant, the owner,
and/or the operator from complying with all other applicable
Federal, State, and local regulations.
c".,<T. The floating roof tanks shall comply with the standards in
40 CFR 60.112a.
IV. GENERAL
This permit is issued in reliance upon the completeness and accurateness of
the information set forth in the Applicant's application to EPA for
permission to construct and operate a shale oil upgrading plant. On the
effective date of this permit, the conditions herein become enforceable by
EPA pursuant to any remedies it now has or may have in the future, under the
Clean Air Act. Each and every condition of this permit is a material part
hereof and is not severable. This permit is immediately effective, unless
you notify this Regional Office, in writing (Attention: Mr. Norman A. Huey,
Chief, Technical Support Section, BAH -A), that this permit or a term or
condition of it is rejected. Such notice should be made within ten (10) days
after receipt of the permit and should include the reason(s) for rejection.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
BY •
DATE:
ot L. Duprey }recto
Air and Hazardous M., rials : ision
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Table I
MAXIMUM UPGRADING FACILITY EMISSIONS
Source
Sulfur Dioxide Nitrogen Dioxide Particulates Hydrocarbons Carbon Mon
lb/hr ton/yr lb/hr tons/yr lb/hr ton/yr lb/hr ton/yr lb/hr to
Process and Combustion Emissions
Reformer
Furnace 1.0 4.4 53.1 232.5 1.3 5.8 0.8 3.3 4.5.
Dearseniter
Charge Htr. 0.7 2.9 2.3 -.10.1 0.1 0.5 0.1 0.3 0.4
Dearseniter
Purge Htr. 0.5 2.2 1.8 8.0 0.1 0.4 . 0.1 0.2 0.3.
Hydrogen Charge
Heater 0.8 3.5 2.8 12.4 0.2 0.7 0.1 0.4 0.5
Fractionator
reboiler htr. 0.7 3.1 2.5 11.1 0.1 0.6 0.1 0.4 0.5
Sulfur Recovery
Unit
Steam Boiler
Fugitive Emissions
1.9 8.3 0.1 0.5 -- -
2.6 11.3 12.0 52.5 0.6 2.6 0.3 1.5 2.1
Tank Car Loading - - 0.0 0.0 -
Storage Tanks - - - 2.0 7.7
Miscellaneous
(pumps, valves) - - 19.1 83.4
Locomotive •9.4 1.0 1.6 7.1 - - 0.1 0.6 0.8
Vehicle Travel - - - 0.4 1.7 - -
Facility Total 17.6 36.7 76.2 334.2 2.8 12.3 22.7 97.8 9.1
Intermittent Emissions
Dearseniter Catalyst Replacement Negligible
Maximum flaring
due to upset*
or shutdown
480
81
4 - - 13
*Emissions occur during emergency shut -downs or upsets, for a maximum duration of 15 minute
Such occurrances are expected no more than once per year.
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TABLE 11
HYDROCARBON EMISSION ESTIMATES FOR FLOATING -ROOF TANKS
I
Tank Total
Tank Number Capacity Vapor Losses
Service Tanks (BBL) each lbs/day tons/year
Jet Fuel 2 20,000 13.68 2.50
Syncrude 2 50,000 34.08 6.222
Total
.t�
47.76 8.72
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TABLE IV
STACK PARAMETERS FOR THE PROPOSED SHALE OIL UPGRADING PLANT
Source
Stack Parameters
Emission Rates Height Temperature Volume Velocity
(g/sec) (m) (°K)
Flow (m/sec)
SO2 N0 (m3/sec)
Reformer
Furnace 0.126 6.69 46 442 39.3 9.14
Dearseniter
Charge Heater 0.082 . 0.34 30 578 4.6 6.46
Dearseniter
Purge Heater 0.064 0.27 30 578 4.6 6.10
Hydrogen Charge
Heater 0.101 0.42 46 616 6.4 7.77
Steam Boiler 0.324 1.51 11 417 12.6 24.31
Fractionator
Reboiler Heater 0.089 0.38 30 616 5.4 7.62
Sulfur Recovery
Unit 0.239 0.01 34 311 0.54 1.45
NOX was modeled with higher emission rates than will actually occur, to
provide a more conservative estimate.
TABLE III
MISCELLANEOUS HYDROCARBON EMISSIONS FROM THE PROPOSED SHALE OIL UPGRADING PLANT
•
Emissions
Source Emission Factorsa lbs/day tons/yr
Pue;p Seals 10 lb/1000 bbl feed ' 100 18 ri
Compressor Seals 1007. recovery of non -methane HC through vapor recovery 0 0
Valves and Flanges 14 lb/1000 bbl feedb 140 26
1 Relief Valves (Closed system; refer to text for flare system emissions) 0 0
API Separator and See footnote c 187 34
Plant Effluent Basinc
1
Cooling Towerd 6 lb/MM gallons of cooling water 30 5.5
TOTAL 457 83.5
aSource for all emission factors except for compressor seals, API Separator and Plant Effluent Basin is U.S.
EPA publication AP -42, Table 9.1-2 (U.S. EPA 1978).
bBased on study conducted by KVB, Inc. (KVB 1977).
cBased on calculations made by Fluor Engineers and Constructors, Inc., 1980a.
dThe cooling tower will process approximately 2.88 million gallons of water daily (3.17 M?! gallons/day maximum).
•
-9 -
APPENDIX I
HO. DESCRIPTION DATE
1. Union Oil Company PSD application 9/29/80
2. Union Oil Company (J. Cloninger) corrections
to application 10/23/30
3. EPA (N. Huey) Request for additional information 10/30/C0
4. Union Oil Company (J. Cloninger) supplemental
application data to EPA (R. Burro) 11/18/80
5. Woodward -Clyde Consultants (L1. Steiner) additional
information about models to EPA (R. Fisher) 11/26/80
6. Woodward -Clyde Consultants (W. Steiner) reevaluation
of modeling results to EPA (R. Fisher) 1/26/81
7. EPA (J. Dale) technical memo 3/4/81
8. EPA (R. Fisher) technical memo 3/9/31
9. Application Analysis (EPA) 3/4/81
10. Public Notice in the Rifle Telegram 3/11/81
11. Holland & Hart letter 4/8/81
12. Exxon Company and ARCO Coal Company Letters 4/9/81
13. EPA (R. Duprey) extending continent period 4/14/81
14. Public notice in the Denver Post 4/14/81
15. Public' Notice. in'the Rifle Telegram 5/6/81
16. Union Oil Company (A. Randle) modifications to the permit 5/6/81
application.
17. Exxon Company, U.S.A. comments 5/9/8I.
18. ARCO Coal Company comments 5/11/81
19. Chevron Shale Oil Company comments 5/11/81
20. Colorado Department of Health Continents 5/12/80
21. Application Analysis (EPA) 5/20/81
Comment 1:
-10-
APPENDIX II
Union Oil Company of California
Summary of Public Comments
Our greatest concern with the permit as proposed was the
virtually complete consumption of SO2 increment in the
Parachute Creek valley by the emissions that would have been .
permitted. This could have affected operations of the Colony
Shale Oil Project under its existing PSD permit.
Response 1: The modeling technique used to predict the impact is considered
to be very conservative and thereby predicated an increment
consumption greater than what mould actually occur. Union Oil
Company submitted design modifications on May 6,.1981 which
resulted in a large decrease in SO2 emissions. This
modification has alleviated the commenters concerns.
Comment 2:
Response 2
Comment 3
We were further concerned that the consumption of SO2
increment which would have been allowed by the proposed permit
would have placed an unreasonable burden upon other operators
who may in the future Trish to construct and operate shale oil
processing facilities in the vicinity.
As was noted in response 1A, the predicted increment consumed •
was on the high side. The burden placed on future operators is'
one of determining the maximum accumulated impact from their
source combined with the existing increment consuming sources.
The design modification has alleviated the commentors concerns.
We had substantial concerns about the adequacy of the PSD
permit application in regards to the application of Best
Available Control Technology for the control of sulfur dioxide
emissions from the upgrading facility. These concerns have noir
been mitigated by the design modification.
Response 3 Specific concerns were not expressed.
Comment 4 The permit application indicated that control options other
than a four -stage claus plant were available to Union which
would more effectively and economically control sulfur dioxide
emissions from the proposed upgrading facility.
Response 4 Seven SO2 control strategies were evaluated in the control
technology review to determine what should be required as best
available control technology (BACT). IIACT was the emission
• limit based on the maximum degree of SO2 reduction, taking
into account energy, environmental, and economic impacts and
other costs, determined to be achievable for the source. More
efficient control options than the proposed four -stage claus
plant were evaluated. However, they were not more economical'
in the control of SO2 emissions. The modification has
alleviated the comrnentors concerns.
-11 -
Convent 5: The modeling approach is unduly conservative in that it
over -predicts the degree of increment consumption and impact on -
ambient air quality standards likely to occur from construction
and operation of the upgrading facility.
Response 5: (See Response 1A)
We agree with the conmentor which supports our original
determination that the SO2 increment will be protected.
An applicants burden under 52.21(k) is.to demonstrate that the
applicable increments will not be violated. For convenience, an applicant
can use conservative modeling. Future applicnts, in the impact area, must
make an independent showing under 52.21 (k) and are not bound by previously
predicted impacts.
Conimentors Date
Gerald D. Ortloff 5/9/81
Exxon Company, U.S.A.
J. W. Lerew 5/11/81
ARCO Coal Company
Douglas S. Moore 5/11/81
Chevron Shale Oil Company
Colorado Department of Health 5/12/81
• Ft
-12-
APPENDIX III
1. The permittee shall provide EPA with the following:
a) Notification within seven (7) days of the date of commencement of
construction of a major new source or modification.
b) Notification within seven (7) days of the date of the completion
of construction of a major new source or modification.
c) Notification within seven (7) days of: 1) startup and 2) the date
upon which full operational status is attained.
d) No later than thirty (30) days after the end of each six month
period beginning from the date of permit issuance, submittal of a
progress report for the source or modification subject to this
permit. Once compliance with any limitation in this permit has
been achieved and reported, further reporting of that fact is not
required. The data and other information from which the progress
report is drawn shall be retained for EPA inspection for at least
one year following the date of submittal of the progress report.
e) Notification within forty-eight hours by telephone and registered
mail of any breakdown in pollution control equipment or other
upset which may cause violation of any condition of this permit.
f) Notifications associated with the conducting of any performance
tests required by or provided for under this permit shall be made
in accordance with 40 CFR 60.8.
9)
Notification within fifteen (15) days in advance of any planned
bypassing of control equipment for maintenance or other purposes.
2. Any records required to be kept by the permittee under this permit shall
be available during normal business hours for inspection and copying by
EPA and EPA's authorized representatives for at least one (1) year from
the date of their recording.
3. All reports, notices, control plans, and other information that must be
submitted in satisfaction of a requirement of this permit shall be
submitted through certified mail to:
Director, Enforcement Division
EPA, Region VIII
1860 Lincoln Street
Denver, Colorado 80295
Attention: General Enforcement Branch
Notices shall be in writing unless provided otherwise in this permit.
•
L
a•
-13-
Union Oil Company of California
Shale 0i1 Upgrading Facility
APPLICATION ANALYSIS (Statement of Basis)
May 20, 1981
-A. Applicability Determination
Maximum potential emissions for the proposed 10,000 barrel per day size
plant to upgrade and fractionate raw shale oil in the original application
were as follows:
Potential emissions (tons/year)
SO2 NOx Particulates NC CO
Process and combustion 201.7 320.7 8.7 5.0 29.7
Storage tanks, pumps, loading 90.9
Locomotives 1.0 7.1 0.6 3.4
Vehicle travel 1.7
Totals
202.7 327.8 10.4 96.5 33.1
Union submitted a number of design changes on May 6, 1981 which
resulted in a signficant decrease in the sulfur dioxide emissions and minor
net increases in the other pollutants. The revised maximum potential
emissions for the plant area are as follows:
Process and combustion
SO2 NOx Particulates HC CO
35.7 327.1 10.6 6.1 36.3
Storage tanks, pumps, loading 91.1
Locomotives 1.0 7.1 0.6 3.4
Vehicle travel 1.7
Totals
36.7 334.2 12.3 97.8 39.7
The shale oil upgrading operation is considered to be a major
stationary source. Emissions of nitrogen dioxide, and volatile organic
compounds exceed the significant emission limits. The net emission.
inrrPacer of nnrh nnllirtnnt at'+z hf'1n'4 thn cinnifirint nrnirrinn jimi}� }hn
•
-14-
B. Application Overview
The PSD permit application was received by EPA on September 29, 1980.
Additional information was requested on October 30, 1980 and received on
November 24, 1980. Supplemental modeling information was received on
December 1, 1980 and January 26, 1981. A modification to the design was
received on May 6, 1981.
C. Stack Heights
Good engineering practice (GEP) stack heights for the reformer furnace,
sulfur recovery unit and hydrogen charge heater were determined to be 150
feet (46 meters) in chapter 6 of the application. The revised sulfur
recovery unit stack height will be 34 meters. All other stacks are 30 meters
or less which meet the requirements of GEP.
D. Control Technology Review
A control technology review was done for sulfur dioxide, nitrogen
dioxide and volatile organic compound emissions. The rationale for the
technology to be used is contained in Chapter 5 of the application. The best
available control technology (BACT) analysis is described in a technical memo
dated March 4, 1981. It was determined that Union will utilize BACT
controls. The design modifications received on May 6, 1981 decreased the
potential SO2 emissions from 202.7 tons/year to 36.7 tons/year which is
below the significant emission limit. Therefore a BACT analysis is no longer
required for SO2 emissions.
E. Air Quality Modes
The short term maximum concentrations were modeled using Woodward -Clyde
Consultants, (WCC) version of the EPA PAL model. Annual Concentrations were
determined using the WCC version of the EPA Valley Model. A description of
how the models were modified and used are discussed in chapter 6 of the
application. An evaluation of the models used is contained in a technical
memo dated March 9, 1981.
F. Air Quality Analysis
The ambient concentrations were determined from the monitoring stations
located at Tracts C -a and C -b as well as earlier monitoring done by Union
Oil. A summary of the maximum concentration is shown on Table 6-3 in the
application.
G. Ambient Air increments
Maximum concentrations of sulfur dioxide emissions from the Union
operations were calculated to be 78.8 ug/m3 over an 24-hour period when the
emissions were 202.7 tons per year. With the design change submitted on
May 6, 1981, the sulfur dioxide emissions decreased to 36.7 tons per year
which would significantly decrease the maximum concentrations. However,
since the potential SO2 emissions are below the significant emission limit,
an air quality analysis is not required.
ri
-15-
The total predicted NOx concentrations were estimated t9 be 19.6
ug/m3
and when added to the background amounted to 57.6 ug/mi which is
below the national standard of 100 ug/m3. The validity of modeling results
is discussed in a technical memo dated March 9, 1981. No violations of
increments or ambient standards were predicted.
Predicted Facility Impacts
(ug/m3)
Aver- Union
aging Tract Tract Union,Upgrading
Time C -aa C -ba Retort ColonyFacility Total (NAAQS)
Increment
NO2
Annual 0 0 4.1 1.2 14.3 19.6 57.6
a Source: U.S. EPA, 1979.
b Based on modeling Colony's emissions using the VALLEY model
H. Source Information
The original application dated September 29, 1980 contains most of
the information needed to make the required determinations in the PSD
regulations. Additional information regarding Union's proposed emission
monitoring program, emissions from locomotives, emissions and operation of
the emergency flare, and supplemental sulfur control strategies were
provided in a.letter dated November 18, 1980. Additional modeling
descriptions and results were provided in letters dated November 26, 1980
and January 26, 1981. A modification to the design was made on May 6, 1981.
I. Additional Impact Analyses
Visibility impacts were discussed on page 6-37 of the application and
were determined to be insignificant at the Flat Tops Wilderness Area.
Starting on Page 6-39, an analysis of the impacts on soils and vegetation
is presented. Conclusions from the analysis are that impacts will be from
slight to negligible. With the additional reduction of the SO2
emissions, impacts would be reduced.
J. Public Participation
The application, analysis and proposed permit were made available for
public inspection at the EPA offices in Denver, and the Garfield County
Clerk's office in Glenwood Springs. The Colorado Department of Health
issued a public notice in the Rifle Telegram on January 28, 1981. EPA gave
opportunity to request public hearing and a 30 day public comment period by
a public notice in the Rifle Telegram on March 11, 1981. The public
comment period was extended to May 11, 1981 and public notices were issued
in the Rifle Telegram and the Denver Post. Three written comments were,
received and considered in the final permit. These comments are summarized
in the summary of public comments (appendix II of the permit). •
A 'lit
COLORADO
DEPARTMENT
OFAHEALTH
•
4210 East 11th Avenue
Denver, Colorado 80220-3716
Phone (303) 320-8333
April 2, 1992
Telefax Numbers:
Main Building/Denver
(303) 322-9076
Ptarmigan Place/Denver
(303) 320-1529
First National Bank Building/Denver
(303) 355-6559
Grand Junction Office
(303) 248-7198
Pueblo Office
(719) 543-8441
P
ROY ROMER
Governor
JOEL KOHN
Interim Executive Director
Garfield County Commission
109 Bth Street
Glenwood Springs, W 81601
Dear Sir:
APR 8 1992
GARFIELD COUWY
APR 61992
COLI TY COMMISSIONERS
Mr. Leon Pahler requested we send a letter regarding a transfer of
ownership of air pollution permits from Unocal to Clean Fuels
Development Corporation.
I -have attached a copy of the letter sent Unocal in this regard.
you have any questions regarding this information please call me
331-8582
Si ncerely,
James S. Geier, P.E., Chief
New Source Review Section
Air Pollution Control Division
JSG/de
enclosures: Note to Applicant for Air Emission Permits
Excerpt from Regulation No. 3
Revised APEN's
cc: John Dale, EPA
As
If
at
pr:nmd on reryrlyd pni •e r
COLORADO
4210 East 11th Avenue
Denver, Colorado 80220-3716
Phone (303) 320-8333
Telefax Numbers:
Main Building/Denver
(303) 322-9076
Ptarmigan Pace/Denver
(303) 320-1529
]Fret National Bank Building/Denver
(303) 355-6559
Grand Junction Office
(303) 248-7198
Pueblo Office
DEPARTMENT (719) 643-8441
OFAHEALTH
1.1
ROY ROMER
Governor
JOEL KOHN
Interim Executive Director
April 2, 1992
Mr. Peter D. Nichols
UNOCAL
10735 County Road 215
Parachute, Colorado 81635
Dear Mr. Nichols:
Mr. Leon Pahler requested we send a letter regarding a transfer 'of
ownership of air pollution permits from [hxocal to Clean .Bels
Development Corporation. Transfer of ownership of State issued permits
requires the following:
1) Submittal of revised Air Pollution Emission Notices (APENs) for
each 'emission point with the required $60.00 Filing Fee for each
notice. These Apens must note the method of operation of each
emission point.
2) Submittal of an application form.
3) A statement noting that the source will be operated is such a
manner that it will not be considered a modified source.
Upon receipt of this information the Division will review the Apens and
redraft the permits. A fee letter will then be sent to cover•the
Division's cost of processing the request. Once the fees are paid the
permits are issued.
The Unocal situation does require that Prevention of Significant
Deterioration (PSD) issues be addressed. Currently the U.S. EPA retains
authority for Unocal's PSD permits. Since the PSD permits were issued,
however, the Colorado Air Pollution Control Division has taken over the
PSD Program. Consequently PSD issues must be addressed with': the
Division prior to issuance of new permits. It is likely that. ati
"emission netting' procedure can be employed to simplify the PSD review.,
Ci priuiedon reeyekelP.iper
I
i
-Page two -
Y would suggest that Clean Fuels Development Corporation meet with the
Division to discuss these issues prior to making an application.
Please call me at (303) 331-8582 to schedule a meeting or if you have
any questions regarding this letter.
Sincerely,
James S. Geier, P.E., Chief
New Source Review Section
Air Pollution Control Division
JSG/de
enclosures: Note to Applicant for Air Ein.ission Permits
Excerpt from Regulation No. 3
Revised APEN's
cc: John Dale, EPA
7
COLORADO CLEAN FUELS
April 6, 1992
Garfield County Board of County Commissioners
Garfield County Courthouse
109 8th Street
Glenwood Springs, Colorado 81601
RE: Special Use Permit Rehabilitation Plan
Dear Commissioners:
I�e cr
NTOr
APR 9 1992
GA;
COUNTY
Per a request by Mr. Don Deford, this letter is to confirm and further elaborate on the
rehabilitation program anticipated by Colorado Clean Fuels in the event the facility is
decommissioned and abandoned.
In the event Colorado Clean Fuels does not exercise its option to purchase the facility
at some point during or at the end of the 15 year lease term with Unocal, the terms of its lease
agreement with Unocal specifically provide that "upon the termination of this lease, lessee shall
surrender the premises to lessor; provided, however, lessee shall have a period of up to one
year from the date of termination of the lease to remove all buildings, improvements,
equipment and personal property owned by lessee on the premises and return the premises to
lessor in the same condition as when received, ordinary wear and tear excepted. Lessee shall
repair any damage to the premises occasioned by the removal of lessee's buildings,
improvements, equipment and personal property." Colorado Clean Fuels' rehabilitation plan
for the duration of the lease is to return the facility to Unocal in its existing condition.
Therefore, in the event Colorado Clean Fuels returns the facility to Unocal, any obligations for
site rehabilitation that Unocal currently has will remain with Unocal, after Colorado Clean
Fuels completes its obligations to remove its buildings, improvements, equipment and personal
property.
9085 East Mineral Circle, Suite 350
Englewood, Colorado 80112
Phone: (303) 792-3037
Fax: (303) 792-5603
_q g
27405 Puerta Real, Suite 340
Mission Viejo, California 92691
Phone: (714) 582-0373
Fax: (714) 582-0642
•
i1
Garfield County Board of County Commissioners
4/6/92
Page 2
In the event Colorado Clean Fuels exercises its option to purchase the facility at some
point during or at the end of the 15 -year lease term with Unocal, it will become obligated to
rehabilitate the site if the facility is decommissioned and abandoned. Colorado Clean Fuels
expects that a one-year period in which full rehabilitation would be accomplished is a
reasonable time period, consistent with the rehabilitation timing provided for in its lease
agreement with Unocal. Rehabilitation is construed by Colorado Clean Fuels to mean the
removal of all equipment, buildings, fixtures and other structures and the restoration of topsoil
to excavated areas, along general topographic contours that were present prior to the initial
construction of the facility.
I trust that the above clarifies our intentions, expectations and obligations
understanding in the event the facility is decommissioned and abandoned. If additional
information is required, please contact me at 303-792-3037.
Sincerely,
12042 A
Robert A. Downey
Executive Director
cc: L. Elliott
P. Nichols
D. Stranger
'4
APR-- 9-05WE_D
20 : 5
•
EFiEF C `r � FJ V F
APR 7 'S2 13:94 FROM JB -HOUSTON 35
JOHN BROWN
April 07, 1992
Nr' `
APR 9 1992
GARFIELD COON" y
•
T-
TO 2444915037925603 PAGE . 9Q2/Okla
Mr. Robert Downey
COLORADO CLEAN FUELS
9085 E. Mineral Circle, Suite 350
Englewood, Colorado 80112
John Brown E & 0
7909 Parkwood Circle Drive • 77036
P.C. Box 720421
Houston, Texas 77272
Telephone (713) 988-2002
FAX: (713) 772-4673
Telex: 275518 JBECH - UR
RE: COLORADO CLEAN FUEL
Parachute, CO
JRE&C Job No. J8 -192H499
Letter No. 003
Subject: Colorado Clean Fuels
Methanol Conversion
Noise Level Design
Dear Mr. Downey:
This is to answer questions pertaining to the noise levels which may be
expected from the Methanol Conversion and related operating units at the
Upgrade Facility in Parachute, Colorado.
It is John Brown's practice to design all units such that noise levels from
operating equipment do not exceed 95 decibels, when measured within 3 feet
of the battery limit of the unit. Since the units' large machines will all
be in excess of 200 feet from the property line, the noise levels would be
considerably less than 86 decibels at the property line.
ROC/gnr
cc: D. Sheppard
M. Islam,
File: 2.1
Very truly yours,
JOHN
Ral p" 7D. Cooper
Sr. Project Ma .ger
14.
•:j
'3.
APR 8 '32 15:59 FROM J8 -HOUSTON ##3
JOHN BROWN
April 08, 1992
•
TO 0000413037325603 PAGE.002/602
APR 9 1992
GARFIELD COUNTY
Mr. Robert Downey
COLORADO CLEAN FUELS
9085 E. Mineral Circle, Suite 3E0
Englewood, Colorado 80112
John Brawn B & C
7909 Parkwood Circle Drive • 77036
P.O. Box 720421 •
Houston, Texas 77272
Telephone (713) 988-2002
FAX: (713)772-4673
Telex: 275518 JBBCH - UR
RE: COLORADO CLEAN FUELS
Parachute, CO
JBE&C Job No, JB -192H449
Letter No. 005
Subject: Methanol Conversion
Vibration Design
Dear Mr. Downey:
This is to answer questions pertaining to the vibrations which may be
expected from the Methanol Conversion and related operating units at the
Upgrade Facility in Parachute, Colorado.
The methanol conversion and related operating units will include several
machines with centrifugal and/or reciprocating movements inherent within the
individual machines. John Brown will design foundation and mechanical
systems supporting these machines to both support the large 'weight' masses..;
and dampen aninherent vibrations occurring. These'procedures are a normal!
part of the design process and will be followed for the units in question.
The results of this design will result in an operating unit which will have;:
no detectable vibrations at the property line.
RDC/gnr
cc: D. Sheppard
M. Islam
File: 2.1
Very truly yours,
JOB
WN E C
Ra
sr Project Manager
D. Coo o': r