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Home My WebLink About20143021.tiff STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH oF.coz Executive Director and Chief Medical Officer ve v ` O Dedicated to protecting and improving the health and environment of the people of Colorado " 4300 Cherry Creek Dr.S. Laboratory Services Division .�""1876. Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Weld County - Clerk to the Board 1150 O St PO Box 758 RECEIVED Greeley, CO 80632 September 23,2014 SEP 2 9 2014 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On September 26,2014,the Air Pollution Control Division will publish a public notice for Noble Energy, Inc. — Wells Ranch EcoNode—Section 6. in the The Greeley Tribune. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the date the public notice is published. Please send any comment regarding this public notice to the address below-. Colorado Dept. of Public Health& Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver. Colorado 80246-1530 Attention: Clara Gonzales Regards, �l Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure I�bllcA 1 eAJ; C1 tt' L IRV)l 1-1-L 2014-3021 10-L -IMF 9/M STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk, MD,MSPH /,o/F••coc i\ Executive Director and Chief Medical Officer e/ E :To o Dedicated to protecting and improving the health and environment of the people of Colorado * ; * 4300 Cherry Creek Dr.S. Laboratory Services Division tare Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Website Title: Noble Energy, Inc.—Wells Ranch EcoNode—Section 6—Weld County Released To: The Greeley Tribune On: September 23, 2014 Published: September 26, 2014 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Noble Energy, Inc. Facility: Wells Ranch EcoNode—Section 6 Oil and Natural Gas Exploration and Production Facility SESE Section 6,T6N, R62W, approximately 13 miles northeast of Kersey, CO Weld County The proposed project or activity is as follows: Applicant is requesting permit coverage for fugitive component leaks at an existing E&P site. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.I.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 14WE0453 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Oluwaseun Ogungbenle Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South,APCD-SS-B 1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 6� .� � AIR POLLUTION CONTROL DIVISION rF TELEPHONE: (303)692-3150 .'•, ,„.,�+ •1876 CONSTRUCTION PERMIT PERMIT NO: 14WE0453 Issuance 1 DATE ISSUED: ISSUED TO: Noble Energy, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Wells Ranch EcoNode - Section 6, located in the SESE Section 6, Township 6N, Range 62W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Equipment leaks (fugitive VOCs) from a natural gas exploration Fugitives 015 and production facility. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. Within one hundred and eighty days (180) after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 2. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (Hi) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) AIRS ID: 123/9B07/015 Page 1 of 9 Fugitive SM/M Version 2012-2 olor Depa en li ealth and Environment it Pollution Control Division 3. The operator pl I i ' m ting mpling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point VOC Emission Type Fugitives 015 63.0 Fugitive See "Notes to Permit Holder for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 6. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total point source emissions from the facility, including permitted emissions and insignificant activities, shall not exceed 100 tons per year of any criteria pollutant. 7. The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas analysis, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. AIRS ID: 123/9B07/015 Page 2 of 9 'S olor ADepa en' : P •Ii Health and Environment . .- it Pollution Control Division STATE AND FEDE r G i-., Ti1F« P E.. '.: NTS 8. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. This source is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). All condensate collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. The operator shall comply with all applicable requirements of Section XII. 11. Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). This requirement to apply RACT shall be satisfied by installing/implementing the following emission controls: a. Directed Inspection & Maintenance as described below shall satisfy the requirement to apply RACT. i. Auditory/visual/olfactory inspection (AVO) will be performed on a monthly basis. ii. For each leak found in the AVO inspection, a gas detector may be used to determine the size of the leak. The gas detector shall be regularly calibrated. Component leaks greater than 10,000 ppm shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. Component leaks less than 10,000 ppm shall not require repair. For such component leaks that require a shutdown to be repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered. Hi. For repair, valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. iv. Repaired components shall be re-screened using AVO to determine if the leak is repaired. v. The following records shall be maintained for a period of two years: • The name of the site screened via AVO inspection and the name of the inspector. • Components evaluated with the gas detector. • Repair methods applied. AIRS ID: 123/9607/015 Page 3 of 9 olor Depa en Ii ealth and Environment it Pollution Control Division • s • ectio as detector calibrations, attempted repairs, successful repairs, repair delays, and post- repair screenings. vi. Leaks shall be repaired as soon as practicable, but no later than 15 calendar days after detection, unless it is technically or operationally infeasible to make the repair within 15 calendar days. Records documenting the rationale shall be maintained if it is technically or operationally infeasible to make the repair within 15 calendar days. OPERATING & MAINTENANCE REQUIREMENTS 12. This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 13. Within one hundred and eighty days (180) after issuance of this permit, the owner or operator shall complete the initial extended gas analysis of gas samples that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the gas analysis and emission calculations to the Division as part of the self-certification process to ensure compliance with emissions limits. Periodic Testing Requirements 14. On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or AIRS ID: 12319B07/015 Page 4 of 9 olor s k Depa t en • P •li "Health and Environment*ff it Pollution Control Division Sr Pa'm; .. Fora ♦' E eta < it a •"sas i - • 'Ili If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 16. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). 17. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS: 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. AIRS ID: 123/9807/015 Page 5 of 9 olor Depa en li Health and Environment it Pollution Control Division 21. Unless specifi ed g spe ' onditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Oluwaseun Ogungbenle Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. Newly permitted fugitive component leaks AIRS ID: 123/9807/015 Page 6 of 9 olor Depa err' li Health and Environment .. ... ,....., it Pollution Control Division .,..,. Notes to Permit Holder - - ime o e an 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDOcumenf C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Controlled Emission Are the Emission AIRS Rate emissions Rate Point Pollutant CAS # BIN (Ib/yr) reportable? (Ib/yr) Benzene 71432 A 427 Yes 427 Toluene 108883 C 427 Yes 427 015 Ethylbenzene 100414 C 320 Yes 320 Xylenes 1330207 C 320 Yes 320 n-Hexane 110543 C 2436 Yes 2436 5) The emission levels contained in this permit are based on the following emission factors: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2150 160 780 160 Flanges 270 0 90 20 Open-ended Lines 0 0 10 0 Pump Seals 0 0 10 0 Valves 840 130 650 150 Other' 660 20 110 40 VOC Content(wt. 0.3123 1.0000 1.0000 1.0000 fraction) Benzene Content(wt. 0.0010 0.0036 0.0036 0.0036 fraction) Toluene Content(wt. 0.0010 0.0000 0.0000 0.0000 fraction) Ethylbenzene (wt. 0.0005 0.0000 0.0000 0.0000 fraction) Xylenes Content(wt. 0.0050 0.0000 0.0000 0.0000 AIRS ID: 12319B07/015 Page 7 of 9 olor Depa en li Health and Environment it Pollution Control Division fraction) n-hexane Content(wt. 0.0030 0.0286 0.0286 0.0286 fraction) *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA-453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor/Major Source of: NOx, CO,VOC, n-Hexane, and total HAPs NANSR Synthetic Minor Source of NOx and VOC PSD Synthetic Minor Source of CO MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Applicable NSPS KKK Not Applicable NSPS OOOO Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.qpoaccess.qov/ q ov/ AIRS ID: 123/9B07/015 Page 8 of 9 •k .. � f 3 olorh Depa Fen 1 P '.li Health and Environment ., x it Pollution Control Division Part 60: Standar.` . "- -rfor "5 e NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ— Subpart YYYY MACT 63.6580-63.8830 Subpart 777Z—Subpart MMMMM MACT 63.8980-End Subpart NNNNN— Subpart XXXXXX 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.00v/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9807/015 Page 9 of 9 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Noble Energy, Inc. Permit Number: 14WE0453 Source Name: Wells Ranch EcoNode— Section 6 Source Location: SESE Section 6, Township 6N, Range 62W Equipment Description: Fugitive Component Leaks AIRS ID: 123-9807-015 Date: March 20, 2014 Review Engineer: Oluwaseun Ogungbenle Control Engineer Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X Initial Approval Transfer of Ownership APEN Exempt/Permit Exempt Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no" to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? November 14,2013 Section 4—Source Description AIRS Point Equipment Description 015 Fugitive VOC leak emissions Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM10 CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region? (Note: If"yes"the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Page 1 Section 5—Emission Estimate Information AIRS Emission Factor Source Point 015 EPA-453/R-95-017,Table 2-4 Did the applicant provide actual process data for the emission inventory? Yes i X No Basis for Potential to Emit(PTE) AIRS Process Consumption/Throughput/Production Point Equipment Type Gas Heavy Oil (or Light Oil (or Water/Oil Heavy Liquid) Light Liquid) Connectors 2150 160 780 160 015 Flanges 270 --- 90 20 Open-Ended Lines — — 10 -- Pump Seals — — 10 — Valves 840 130 650 150 Other 660 20 110 40 Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Process Consumption/Throughput/Production Point Equipment Type Gas Heavy Oil (or Light Oil (or Water/Oil Heavy Liquid) Light Liquid) Connectors 2150 160 780 160 015 Flanges 270 - 90 20 Open-Ended Lines -- --- 10 - Pump Seals --- --- 10 -- Valves 840 130 650 150 Other 660 20 110 40 _ Basis for Permitted Emissions(Permit Limits) AIRS Process Consumption/Throughput/Production Point Equipment Type Gas Heavy Oil(or Light Oil (or Water/Oil Heavy Light Liquid) Liquid) Connectors 2150 160 780 160 015 Flanges 270 --- 90 20 Open-Ended Lines — --- 10 -- Pump Seals — — 10 -- Valves 840 130 650 150 Other 660 20 110 40 Does this source use a control Yes X No device? Section 6—Emission Summa (tons per year) Point NO„ VOC CO Single HAP Total HAP PTE: 015 62.9 1.2 (Hexane) 2.0 Uncontrolled point 015 62.9 1.2 (Hexane) 2.0 source emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled An the Controlled Emission Pollutant CAS# BIN Emission Rate emissions (Iblyr) reportable? Rate(Iblyr) Benzene 71432 A 427 Yes 427 Toluene 108883 C 427 Yes 427 Page 2 Ethylbenzene 100414 C 320 Yes 320 Xylenes 1330207 C 320 Yes 320 n-Hexane 110543 C 2436 Yes 2436 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 015 01 VOC, State only requirement Site-specific gas HAPS analysis Section 9—Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V X PSD X NA NSR X MACT Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? Minor Synthetic Major Minor Section 10— Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes", for which pollutants?Why? VOC For Reg. 3, Part B, III.C.1.a (emissions increase> 25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? Yes No Section 11 — Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? AIRS Point Section 12— Regulatory Review Requlation 1 -Particulate Smoke, Carbon Monoxide and Sulfur Dioxide Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which 015 is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A(July, 1992)) in all subsections of Section II. A and B of this regulation. Requlation 2—Odor Section I.A- No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are 015 measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7)or more volumes of odor free air. Page 3 Regulation 3-APENs.Construction Permits,Operating Permits, PSD Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 015 each individual emission point in a non-attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant(pollutants are not summed) for which the area is non-attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) Part B—Construction Permit Exemptions 015 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold(Reg. 3, Part B, Section II.D.3.a) Part B, III.D.2-RACT requirements for new or modified minor sources This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or attainment/maintenance areas. This source is located in the 8-hour ozone nonattainment area. 015 The date of interest for determining whether the source is new or modified is therefore November 20, 2007 (the date of the 8-hour ozone NA area designation). Since the fugitives came into service after the date above, this source is considered "new or modified." Operator has agreed to the Division's standard conditions. Regulation 6-New Source Performance Standards NSPS KKK: Equipment Leaks of VOC from onshore natural gas processing plants. Affected facilities at onshore natural gas facilities(any processing site engaged in the extraction of natural gas liquids from field gas, fractionation of mixed natural gas liquids (NGLs)or both). 015 Is this source at a"natural gas processing plant?" No Is this source subject to NSPS KKK? No This source is not subject to NSPS KKK because it does not meet the definition of a natural gas processing plant. NSPS OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution. For fugitive emissions at natural gas processing plants subject to NSPS OOOO. This subpart establishes emission standards and compliance schedules for the control of volatile organic compounds(VOC)and sulfur dioxide(SO2)emissions from affected facilities that commence construction, modification or reconstruction after August 23, 2011. 015 Is this source at a"natural gas processing plant?" No Is this source subject to NSPS OOOO? No This source is not a natural gas processing plant; therefore, the fugitives at this facility are not subject to the requirements of NSPS OOOO. Also, operator did not indicate that reciprocating compressors are part of the"other category in the component count. Regulation 7—Volatile Organic Compounds 015 Section XII.G: If facility is a natural gas processing plant located in non-attainment area, then subject to Section XII.G. Regulation 8—Hazardous Air Pollutants MACT HH: If facility is MAJOR source for HAP at a natural gas processing plant ONLY (summation of HAPS of dehydrators and fugitives),then fugitive emissions are subject to MACT HH. 015 Is this facility considered MAJOR for HAPS? No Is this source subject to MACT HH? No This facility is not subject to MACT HH because it is not considered a major source of HAPs. Page 4 Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Description Pollutant/ Fugitive Emission Factor Control o CAS# (Y/N) Source (%) 015 01 Fugitive VOC Leak VOC Yes EPA-453/R-95-017, NA Emissions Table 2-4 SCC 31000220: All Equip. Leak Fugitives (Valves,flanges, connections,seals, drains) Section 14—Miscellaneous Application Notes AIRS Point 015 Fugitive VOC Leak Emissions A permit will be issued because uncontrolled VOC emissions are greater than 2 TPY (permit threshold). Permitted VOC emissions from these fugitive component leaks exceed 25 tpy. Therefore, per Reg. 3, Part B, III.C.1.a, this permit will be sent to public notice. These fugitive component leaks are a newly permitted emission point at this facility. These fugitive VOC emissions push the permitted facility VOC emissions to 153.1 tpy, which is above the 100 tpy threshold for TV Operating Permit. However, this facility is not a "listed" source, which makes its fugitive VOC emissions inconsequential to the overall facility emissions. Therefore, since the permitted facility emissions (minus fugitives) are below 100 tpy, this facility will maintain its Synthetic Minor designation. As part of the recently concluded rule making, the AQCC revised regulation 3 part A to standardize the HAP/NCRP threshold to 250 pounds per year for all pollutants on an uncontrolled actual basis. While this change is expected to become effective on April 141h, 2014, HAP emissions from these fugitive component leaks were evaluated in light of the new reporting threshold because there are no anticipated changes—neither to the reporting threshold nor the reported fugitive HAP emissions. Process Description: The wellheads produce fluid to gas/liquid separator(s). The produced oil is routed through the vapor recovery tower and then on to oil tank(s). The produced water is routed to water tank(s). The liquids are trucked out, as needed. Emissions from the production tanks and truck loadout operations are routed through the flash VRU and to the enclosed flare device(s) on site. Produced gas is routed to the gas lift injection compressors where gas is sent down hole. The gas not sent down hole is routed to the wellhead compressors to be sent to the gas pipeline. When the wellhead compressors are offline, some gas is sent down the pipeline and the remainder is routed to the flare. 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