HomeMy WebLinkAbout20131206.tiffSTATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbina, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.co.us
Weld County Clerk & Recorder
1402 N 17th Ave
Greeley, CO 80631
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
19
May 8, 2013 Afi1/
4}.
4145,1/4-OO
On May 11, 2013, the Air Pollution Control Division will publish a public for EOG Resources, be —
Critter Creek 5-101-I, in the Greeley Tribune. A copy of this public notice and the public comment packet are
enclosed.
Dear Sir or Madam:
Colorado Department
of Public Health
and Environment
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,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
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2013-1206
STATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbina, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.co.us
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090.
Website Title: EOG Resources, Inc — Critter Creek 5-I0H — Weld County
Released To:
On:
Published:
Greeley Tribune
May 8, 2013
May 11, 2013
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
Colorado Department
of Public Health
and Environment
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:
Facility:
EOG Resources, Inc
Critter Creek 5-10H
Exploration and production facility designed to process 87.6MMscf/yr of gas.
SESE Section 10, Township 11 North, Range 63 West
Weld County
The proposed project or activity is as follows: The applicant proposes to operate an exploration and production
facility and the associated equipment.
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.1.a
(25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 11 WE1181 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 www.colorado.gov/cdphe/AirPublicNotices
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:
Laura Strohkirch
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-Bl
Denver, Colorado 80246-1530
cdphe.commentsaped@state.co.us
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
11WE1181
EOG Resources, Inc
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas production facility, known as Critter Creek 5-10H, located at SESE Section 10,
Township 11N, Range 63W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Crude Oil
Tanks
001
Four (4) 400 BBL fixed roof storage tanks used to store crude oil.
Emissions from these tanks are controlled by a Cimarron
smokeless vapor combustion unit with 95% efficiency.
ET #3815
002
One (1) 400 BBL well blowdown tank, Manufacturer: Connor,
Model: EOG #3815, SN: 25760 used when the produced gas
cannot be combusted in the flare.
Flare
003
One (1) Tornado flare (Manufacturer Tornado, Model No: 40' Flare
Stack, Serial No: 090SADA3X503210) used to combust produced
gas vented from a three-phase separator. This flare is not
enclosed.
Truck
Loadout
004
Truck loading of crude oil and produced water.
PW Tank
#1
005
One (1) 40O BBL fixed roof storage tank used to store produced
water. Emissions from this tank are controlled by a smokeless
Cimarron Energy Combustor with 95% efficiency.
Fugitive
006
Equipment leaks (fugitive VOCs) from a natural gas 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:
AIRS ID: 123/8913/999
Page 1 of 14
Condensate Tank Version 2009-1
EOG Resources, Inc.
Permit No. 11 W E1181
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
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 on this permit shall be demonstrated to the Division. It is the
permittee'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, II.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 fora period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
3. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
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. 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 emissions from the facility, including permitted emissions and insignificant activities,
shall not exceed:
100 tons per year of any criteria pollutant
AIRS ID: 123/8913/999 Page 2 of 14
EOG Resources, Inc.
Permit No. 11 W E1181
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
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
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO
VOC
CO
Crude Oil
Tanks
001
-
0.84
-
Point
ET #3185
002
-
6.0
-
Point
Flare
003
4.6
73.7
25.1
Point
Truck Loadout
004
-
15.2
-
Point
PW Tank #1
005
-
0.3
-
Point
Fugitive
006
-
2.4
-
Fugitive
See "Notes to Permit Holder #4" 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 synthetic minor status of this facility 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 (12) month total. By the end of each
month a new twelve-month total is calculated based on the previous twelve months' data.
The permit holder shall calculate monthly emissions 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 emission units, requiring an APEN, at this facility.
7. Emissions Point 001: Emissions from this point shall be routed to an enclosed vapor
combustion unit (VCU) that reduces uncontrolled emissions of VOC from the crude oil tanks
to the emission levels listed in Condition 6. Operating parameters of the control equipment
are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B,
Section III.E.)
8. Emissions Point 003: This emissions point is a separator controlled by a 40' flare stack.
The flare shall reduce emissions of VOC to the emission levels listed in Condition 6.
Operating parameters of the control equipment are identified in the operation and
maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.)
9. Emissions Point 005: Emissions from this point shall be routed to an enclosed flare that
reduces emissions of VOC to the emission levels listed in Condition 6. Operating
parameters of the control equipment are identified in the operation and maintenance plan.
(Reference: Regulation No.3, Part B, Section lll.E.)
10. Point 006: The operator shall calculate actual emissions from this emissions point based
on representative component counts for the facility with the most recent gas and liquids
analyses, 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
AIRS ID: 123/8913/999 Page 3 of 14
EOG Resources, Inc.
Permit No. 11 W E1181
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
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.
PROCESS LIMITATIONS AND RECORDS
11. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the applicant and
made available to the Division for inspection upon request. (Reference: Regulation 3, Part
B, II.A.4)
Process/Consumption Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Crude Oil
Tanks
001
Crude oil throughput
255,000 BBL/yr
ET #3185
002
Natural gas vented to atmosphere via
emergency tank
0.36 MMscf/yr
Flare
003
Natural gas flaring
87.6 MMscf/yr
Truck
Loadout
004
Crude oil and produced water loading
292,000 BBL/yr
PW Tank
#1
005
Produced water throughput
36,500 BBL/yr
Compliance with the yearly throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate each actual monthly
process rate and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
12. Point 005: Records shall be kept in either an electronic file or hard copy provided that they
can be promptly supplied to the Division upon request. All records shall be retained for a
consecutive period of three years.
STATE AND FEDERAL REGULATORY REQUIREMENTS
13. The permit number and AIRS ID number shall be marked on the subject equipment for ease
of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable)
14. 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. (Reference: Regulation No. 1, Section II.A.1. & 4.)
15. No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30% opacity for a period or periods aggregating more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.).
16. This source is subject to the odor requirements of Regulation No.2. (State only enforceable)
AIRS ID: 123/8913/999 Page 4 of 14
EOG Resources, Inc.
Permit No. 11 W E1181
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
17. Emissions point 004: the loading of crude oil and produced water into truck tanks shall be
conducted by submerged fill. (Reference: Regulation 3, Part B, III.E)
OPERATING & MAINTENANCE REQUIREMENTS
18. Emissions points 001 and 003: Upon startup of these points, the applicant shall follow the
operating and maintenance (O&M) plan and record keeping format approved by the Division,
in order to demonstrate compliance on an ongoing basis with the requirements of this
permit. Revisions to your O&M plan are subject to Division approval prior to implementation.
(Reference: Regulation No. 3, Part B, Section III.G.7.)
19. Emission point 005:
a. VCU's shall be enclosed, have no visible emissions, and be designed so that an
observer can, by means of visual observation from the outside of the enclosed VCU,
or by other convenient means approved by the Division, determine whether the VCU
is operating properly.
b. If a control device is used to comply with the emission limits of this permit, the
following conditions must be met:
(i) Leakage of VOCs to the atmosphere must be minimized as follows:
1. Thief hatch seals shall be inspected for integrity annually and
replaced as necessary. Thief hatch covers shall be weighted and properly
seated.
2. Pressure relief valves (PRV) shall be inspected for proper
operation annually and replaced as necessary. PRVs shall be set to
release at a pressure that will ensure flashing and working and breathing
losses are routed to the control device under normal operating conditions.
3. Annual inspections of thief hatches and PRV shall be documented
with an indication of status, a description of any problems found, and their
resolution.
(ii) Control devices shall be adequately designed, and operated and
maintained according to manufacturer specifications to achieve a control
efficiency of at least 95%, and to handle reasonably foreseeable
fluctuations in emissions of VOCs. Fluctuations in emissions that occur
when the separator dumps into the tank are reasonably foreseeable.
(iii) The permittee shall monitor and document the proper operation of the
control device. Time intervals between monitoring shall not exceed 14
days. Indications of improper operation for a VCU include, but are not
limited to, absence of pilot light, malfunction of electronic ignition, and/or
presence of smoke. A check box is suitable for recording proper
operation. Improper operation of a control device shall be further
documented with a description of the problem and its resolution, the date
range the control was inoperable, and the produced water production
through the battery during the downtime. During control device downtime,
emissions shall be considered to be uncontrolled.
AIRS ID: 123/8913/999 Page 5 of 14
EOG Resources, Inc.
Permit No. 11WE1181
E1181
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
20. Emissions point 001: The operator shall complete site specific sampling including a
compositional analysis of the pre -flash pressurized crude oil routed to these storage tanks
and a sales oil analysis to determine RVP and API gravity. Testing shall be in accordance
with the guidance contained in PS Memo 05-01. Results of testing shall be used to
determine a site -specific emissions factor using Division approved methods. Results of site -
specific sampling and analysis shall be submitted to the Division as part of the self -
certification and used to demonstrate compliance with the emissions factors chosen for this
emissions point.
21. Emissions points 002 and 003: The operator shall complete an initial site specific
extended gas analysis of the natural gas produced at this site that is either routed to the
open flame flare or vented through the emergency blowdown tank in order to verify the VOC,
benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4-trimethylpentane content
(weight fraction) of this emission stream used in the permit application. Results of testing
shall be used to determine site -specific emission factors using Division approved methods.
Results of site -specific sampling and analysis shall be submitted to the Division as part of
the self -certification and used to demonstrate compliance with the emissions factors chosen
for this emissions .point. For example, the benzene emission factor shall be calculated
according to the following equation using the benzene weight fraction and the natural gas's
average molecular weight determined in the site -specific gas analysis:
IL, tenzene U oh.c 1. L 1 4 stf
Mitsey`" heYEZE'Y!£°bt�t.,frQc *' s.92:: ac,1tMTrt c„ Lmod 13.79fscf.
22. Point 003: The owner or operator shall demonstrate compliance with Condition 14 using
EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section
I I.A.5).
23. Point 006: Within one hundred and eighty days (180) after issuance of permit, the permittee
shall complete the initial extended gas analysis of gas samples and extended natural gas
liquids analysis of liquids that are representative of volatile organic compound (VOC) and
hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended
gas and liquids analyses 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 and liquids analyses and emission calculations to the Division as part of the self -
certification process to ensure compliance with emissions limits.
24. Point 006: Within one hundred and eighty days (180) after issuance of permit, the operator
shall complete a hard count of components at the source and establish the number of
components that are operated in "heavy liquid service", "light liquid service", "water/oil
service" and "gas service". The operator shall submit the results to the Division as part of
the self -certification process to ensure compliance with emissions limits.
Periodic Testing Requirements
25. Points 002 and 003: On an annual basis, the operator shall complete a site specific
extended gas analysis of the natural gas produced at this site that is routed to the flare in
order to verify the VOC content (weight fraction) of this emission stream used in the permit
application. Results of testing shall be used to determine site -specific emission factors using
Division approved methods.
AIRS ID: 123/8913/999 Page 6 of 14
EOG Resources, Inc.
Permit No. 11 W E1181
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
26. Point 006: On an annual basis, the owner or operator shall complete an extended gas
analysis of gas samples and an extended natural gas liquids analysis of liquids that are
representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that
may be released as fugitive emissions. This extended gas and liquids analyses shall be
used in the compliance demonstration as required in the Emission Limits and Records
section of this permit.
ADDITIONAL REQUIREMENTS
27. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a.
b.
d.
e.
Annually whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level reported
on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
Whenever there is a change in the owner or operator of any facility, process, or
activity; or
Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
Whenever a permit limitation must be modified; or
No later than 30 days before the existing APEN expires.
28. 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).
GENERAL TERMS AND CONDITIONS
29. 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.
30. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
AIRS ID: 123/8913/999 Page 7 of 14
EOG Resources, Inc.
Permit No. 11 W E1181
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
31. 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.
32. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the applicant 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 applicant or applicant's agents. It is valid only for the
equipment and operations or activity specifically identified on the permit.
33. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
34. 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 applicant, or the Division revokes a permit, the applicant
or owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
35. 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.
36. 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:
Laura Strohkirch
Permit Engineer
AIRS ID: 123/8913/999
Page 8 of 14
EOG Resources, Inc.
Permit No. 11 W E1181
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
Air Pollution Control Division
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Facility -wide permit for a new E&P facility issued
to EOG Resources, Inc. This permit
encompasses points 001-006. This facility is
synthetic minor for Title V and PSD.
AIRS ID: 123/8913/999 Page 9 of 14
EOG Resources, Inc.
Permit No. 11WE1181
E1181
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees
will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the permittee 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 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 permittee 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:
htto://www.cdphe.state.co. us/regulations/airregs/100102aocccom monorovisionsreo. odf.
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.
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(lb/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
001
Benzene
71432
A
219
Yes
10.95
Toluene
108883
C
192
No
9.6
Xylenes
1330207
C
70
No
n/a
n -Hexane
110543
C
1,452
No
73
002
Benzene
71432
A
27
No
n/a
Toluene
108883
C
20.4
No
n/a
Ethylbenzene
100414
C
3.4
No
n/a
Xylenes
1330207
C
8.5
No
n/a
n -Hexane
110543
C
165.4
No
n/a
003
Benzene
71432
A
6,570.7
Yes
328.5
Toluene
108883
C
4,961.4
Yes
248.1
Ethylbenzene
100414
C
834.1
No
41.7
Xylenes
1330207
C
2,060.8
Yes
103
n -Hexane
110543
C
40,281.2
Yes
2,014.1
004
Benzene
71432
A
203.13
Yes
n/a
Toluene
108883
C
665.19
No
n/a
Ethylbenzene
100414
C
49
No
n/a
AIRS ID: 123/8913/999
Page 10 of 14
EOG Resources, Inc.
Permit No. 11WE1181
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
Xylenes
1330207
C
884.93
No
n/a
n -Hexane
110543
C
1,212.55
Yes
n/a
005
Benzene
71432
A
255.5
Yes
12.8
n -Hexane
110543
C
803
No
40.2
006
Benzene
71432
A
7.5
No
7.5
Toluene
108883
C
12.2
No
12.2
Ethylbenzene
100414
C
1.7
No
1.7
Xylenes
1130207
C
4.5
No
4.5
n -Hexane
110543
C
252
No
252
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
CAS #
Pollutant
Emission Factors
Uncontrolled
Emission Factors
Controlled
Source
VOC
0.13141b/bbl
0.0066 lb/bbl
E&P Tank
71432
Benzene
8.4 x 10-0 lb/bbl
4.2 x 10-° lb/bbl
E&P Tank
110543
n -Hexane
0.0078 lb/bbl
3.9 x 1e lb/bbl
E&P Tank
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
These emission factors were developed using sampling from Critter Creek 2-03H well site
and E&P Tank.
Point 002:
CAS #
Pollutant
Weight
Fraction of
Gas
Emission Factors
Uncontrolled
Emission
Factors
Controlled
Source
VOC
0.4618
33,333 lb/MMscf
natural gas vented
Eng.
Calculation
71432
Benzene
0.0010
75 lb/MMscf natural
gas vented
--
Eng.
Calculation
110543
n -Hexane
0.0063
459 lb/MMscf natural
gas vented
Eng.
Calculation
The emission levels in this permit for this point are based on the use of this tank to blowdown produced
natural gas when the flare used to combust the natural gas is down at three (3) events per year and
twelve (12) hours of venting through this tank per event at a maximum gas flow rate of 10,000 scf/hr.
The VOC content of the produced gas used in the application was based on a gas sample from the
Critter Creek 2-03H well.
AIRS ID: 123/8913/999
Page 11 of 14
EOG Resources, Inc.
Permit No. 11 W E1181
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
Point 003:
CAS #
Pollutant
Natural Gas
Composition
(Weight %)
Emission
Factors
Uncontrolled
lb/MMscf
natural gas
vented
Emission
Factors
Controlled
lb/MMscf
natural gas
vented
Source
NOx
--
105.0
105.2
AP -42, Table
13.5-1, 1549
Btu/scf
CO
--
573
572
AP -42, Table
13.5-1, 1549
Btu/scf
VOC
46.18
33,634.7
1,681.71
Eng.
Calculation
71432
Benzene
0.1029
77
3.75
Eng.
Calculation
108883
Toluene
0.08
56.6
2.8
Eng.
Calculation
100414
Ethylbenzene
0.01
9.5
0.48
Eng.
Calculation
1330207
Xylenes
0.03
23.5
1.18
Eng.
Calculation
110543
n -Hexane
0.63
459.8
23
Eng.
Calculation
540841
2,2,4-TMP
0.0012
0.90
0.045
Eng.
Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the August 10,
2010 analysis of a gas sample collected from the Critter Creek 2-03-H well. The controlled
VOC and HAP emissions factors for point 003 are based on the flare control efficiency of
95%.
Point 004:
Note: The emission factor below may be used for both crude oil and produced water loading.
CAS #
Pollutant
Emission Factors
Uncontrolled
Emission Factors
Controlled
Source
VOC
0.104 lb/bbl
--
AP -42
71432
Benzene
0.0007 Ib/bbl
--
AP -42
108883
Toluene
0.0023 lb/bbl
--
AP -42
1330207
Xylenes
0.0030 lb/bbl
--
AP -42
110543
n -Hexane
0.0041 lb/bbl
--
AP -42
The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version
1/95) using the following values:
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 5.18 psia
M (vapor molecular weight) = 33.43 lb/lb-mol
T (temperature of liquid loaded) = 524 R
AIRS ID: 123/8913/999
Page 12 of 14
EOG Resources, Inc.
Permit No. 11WE1181
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP determined in the pressurized oil analysis by the VOC
emission factor.
Points 005:
CAS #
Pollutant
Emission Factors
Uncontrolled
Emission Factors
Controlled
Source
VOC
0.262 lb/bbl
0.0131 lb/bbl
PS Memo 09-02
71432
Benzene
0.007 lb/bbl
0.0004 lb/bbl
PS Memo 09-02
110543
n -Hexane
0.022 lb/bbl
0.0011 lb/bbl
PS Memo 09-02
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
Point 006:
Component
Gas Service
Heavy Oil
Light Oil
Water/Oil
Service
Connectors
576
---
520
51
Flanges
8
---
24
4
Open -Ended Lines
9
---
7
5
Pump Seals
---
---
2
---
Valves
56
---
72
24 -•
Other
35
---
15
6
VOC Content (wt%)
3.5%
100%
29.2%
100%
Benzene Content (wt%)
0.023%
---
0.027%
0.12%
Toluene Content (wt%)
0.039%
---
0.075%
0.032%
Ethylbenzene (wt %)
0.002%
---
0.017%
0.001%
Xylenes Content (wt%)
0.01%
---
0.036%
0.004%
n -hexane Content (wt%)
0.338%
---
2.43%
--
'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 and liquids analyses.
AIRS ID: 123/8913/999
Page 13 of 14
EOG Resources, Inc.
Permit No. 11 W E1181
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
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
Requirement
Status
Operating Permit
Synthetic Minor Source of VOC
Synthetic Minor Source of HAP
PSD
Synthetic Minor Source of VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart M — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
9) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit packet.
Please use this form to complete the self -certification requirements as specified in the permit conditions.
Further guidance on self -certification can be found on our website at:
http://www.cdphe.state.co.us/ap/oilgaspermitting.htm l
AIRS ID: 123/8913/999
Page 14 of 14
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
EOG Resources, Inc.
Permit Number:
11WE1181
Source Location:
SESE Sec 10, T11N, R63W
Source Name:
Critter Creek 5-10H
Equipment Description:
Point 001- Four (4) 400BBL storage tanks for crude oil
Point 002- One (1) 400 BBL emergency tank
Point 003- One (1) Tornado Flare
Point 004- Crude oil and produced water truck loadout
Point 005- One (1) 400 BBL fixed roof produced water storage tank
Point 006- Fugitive emissions
AIRS ID:
123-8913
Date:
Began reviewing: March 5, 2012
Review Engineer:
Laura Strohkirch
Control Engineer:
Carissa Money
Section 2 — Action Completed
Grandfathered Modification
APEN Required/Permit Exempt
X CP1
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 May 23, 2011 Jake, whois also
working on some EOG sites, e-
mailed David Long about the flare
calculations. The mole fraction VOC
had been used instead of mass
fraction VOC. This !caused the
emissions to be underestimated and
with the correct calculations facility
status could change. New
calculations for this facility were
submitted August 23, 2011
On what date was this application complete?
December 1, 2010 original
application was received.
Supplemental data received August
23, 2011. Fugitives added to facility
February 14, 2012
Page 1
Section 4 — Source Description
AIRS Point
Equipment Description
001
Four (4) above ground 400 bbl atmospheric crude oil storage tank. Emissions from
these tanks are controlled with a Cimarron smokeless combustor unit (VCU) with
95% control efficiency.
002
One (1) above ground 400 bbl atmospheric emergency tank. This tank is used when
there is a need to vent the natural gas from blowdowns of the flare rather than put it
into the pipeline. There are no controls for this tank.
003
One (1) Tornado Flare that is controlling a separator. This is a 40' candlestick flare
that is not enclosed and has been granted 95% destruction efficiency.
004
Crude oil and produced water truck loadout.
005
One (1) above ground 400 bbl atmospheric produced water storage tank. Emissions
from this tank are controlled by a smokeless Cimarron Smokeless Combustor (SN:
4952) with a destruction efficiency of 95%.
006
Fugitive emission leaks.
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
Yes
X
No
If "yes", for what pollutant?
PM1p
CO
Ozone
Is this location in an attainment maintenance area for
any criteria pollutant? -
Yes
X
No
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT per Regulation 3, Part B, Section III.D.2)
PM10
CO
Ozone
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions
of Regulation 7, Sections XII and XVII.C may
apply)
Yes
X
No
Point 005: Is this source claiming exempt status for
this source based on the fraction of oil in the stored
water (less than 1% by volume crude oil on an average
annual basis)?
X
Yes
No
Point 005: Are these produced water tanks located at
a commercial facility that accepts oil production
wastewater for processing?
Yes
X
No
Point 005: Are these produced water tanks subject to
Colorado Oil and Gas Conservation Commission
(COGCC) 805 Rule? -
If so, submit Form APCD-105
Yes
X
-
No
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
001
Source used E&P Tanks along with site -specific sampling to calculate a site -
specific emission factor
VOC E.F.= 0.13141b/bbl
002
Used maximum gas vented to atmosphere along with VOC weight fraction to
determine a site -specific emission factor.
VOC E.F.= 33,333 Ib/MMscf
Page 2
003
Emission Factors for NOx, Sox, CO and PM10 came from AP -42 Tables 13.5-
1&2
VOC emissions are based on a VOC weight -fraction
VOC E.F.= 33,333.3 Ib/MMscf
004
AP -42, Table 5.2-1, equation 1
005
CDPHE Emission Factors (PS Memo 09-02)
006
EPA -453/R-95-017, Table 2-4
Did the applicant provide actual process data for the emission inventory?
X
Yes
No
Basis for Potential to Emit (PTE1
AIRS Point Process Consumption/Throughput/Production
001
306,600 BBL per year (255,500 x 1.2)
002
360,000 scf/yr or 0.36 MMscf/yr
003
240,000 scf/day or 87,600,000scf/yr or 87.6 MMscf/yr
004
292,000 BBL/yr
005
43,800 BBL/yr (36,500 x 1.2)
006
Equipment Type
Gas I Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
576 , ---
520
51
Connectors
Flanges
8 ---
24
4
Open -Ended Lines
9 ---
7
5
Pump Seals
--- , ---
2
---
Valves
56 ---
72
24
Other
35 H--
15
6
Basis
for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
001
255,500 BBL per year while controls are in operation
2010
360,000 scf/yr or 0.36 MMscf/yr
2010
002
003
87.6 MMscf/yr
2010
004
292,000 BBL/yr
2010
005
36,500 BBL/yr
2010
006
Equipment Type
Gas
Heavy Oil
(or Heavy
Liquid)
Light Oil
(or Light
Liquid
Water/Oil
2010
Connectors
576
---
520
51
Flanges
8
---
24
4
Open -Ended
Lines
9
---
7
5
Pump Seals
---
---
2
---
Valves
56
---
72
24
Other
35
---
15
6
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
001
255,500 BBL per year while controls are in operation
002
360,000 scf/yr or 0.36 MMscf/yr
Page 3
003
87.6 MMscf/yr
004
292,000 BBL/yr
005
36,500 BBI../yr
006
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
576
---
520
51
Flanges
8
---
24
4
Open -Ended Lines
9
---
7
5
Pump Seals
---
---
2
---
Valves
56
---
72
24
Other
35
---
15
6
Does this source use a control device? X Yes No
AIRS Point
Process
Control Device Description
% Reduction
Granted
001
01
Cimarron Smokeless Combustor (VCU)
95
003
01
Tornado, 40' Flare Stack, SN 090SADA3X503210
95
005
01
Cimarron Smokeless Combustor (VCU), SN 4952
95
Section 6 — Emission Summary (tons per year)
Point
NO,
VOC
CO
Single HAP
Total HAP
PTE:
001
0.05
20.2
0.27
002
-
6.0
-
0.08 (n -hexane)
0.1
003
4.6
1473.2
25.1
20.1 (n -hexane)
27
004
-
15.2
-
0.6 (n -hexane)
1.5
005
-
4.8
-
0.4 (n -hexane)
0.5
006
-
2.4
-
0.1 (n -hexane)
0.1
Total (TPY) PTE:
4.65
1,521.8
25.28
29.2
Uncontrolled point
source emission rate:
001
0.05
16.78
0.27
0.7 (n -hexane)
1
002
-
6.0
-
0.08 (n -hexane)
0.1
003
4.6
1473.2
25.1
20.1 (n -hexane)
27
004
-
15.2
-
0.6 (n -hexane)
1.5
005
-
4.8
-
0.4 (n -hexane)
0.5
006
-
2.4
-
0.1 (n -hexane)
0.1
Controlled point
source emission rate:
001
0.05
0.84
0.27
0.03 (n -hexane)
0.05
002
-
6.0
-
0.08 (n -hexane)
0.1
003
4.6
73.7
25.1
1.0 (n -hexane)
1.3
004
-
15.2
-
0.6 (n -hexane)
1.5
005
-
0.3
-
0.02 (n -hexane)
0.03
006
-
2.4
-
0.1 (n -hexane)
0.1
Total APEN Reported
emissions:
4.65
98.44
25.28
1.83 (n -hexane)
3.08
Page 4
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(lb/yr)
Are the
emissions
reportable?
mission
Controlled r
RateIE
( y )
POINT 001
Benzene
71432
A
219
Yes
10.95
n -Hexane
110543
C
1,452
Yes
73
POINT 002
Benzene
71432
A
27
No
NA
n -Hexane
110543
C
165.4
No
NA
POINT 003
Benzene
71432
A
6,570.7
Yes
328.5
Toluene
108883
C
4,961.4
Yes
248.1
Ethylbenzene
100414
C
834.1
No
41.7
Xylenes
1330207
C
2,060.8
Yes
103
n -Hexane
110543
C
40,281.2
Yes
2,014.1
POINT 004
Benzene
71432
A
203.13
Yes
NA
Toluene
108883 -
C
665.19
No
NA
Ethylbenzene
100414
C
49.00
No
NA
Xylenes
1330207
C
884.93
No
NA
n -Hexane
110543
C
1,212.55
Yes
NA
POINT 005
Benzene
71432
A
255.5
Yes
12.8
n -Hexane
110543
C
803
Yes
40.2
POINT 006
Benzene
71432
A
7.5
No
7.5
Toluene
108883
C
12.2
No
12.2
Ethylbenzene
100414
C
1.7
No
1.7
Xylenes
1130207
C
4.5
No
4.5
n -Hexane
110543
C
252
No
252
Note: Regulation 3, Part A, Section I1.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.
Page 5
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
X
Yes
No
If "yes", complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
001
01
VOC
CDPHE PS Memo 05-01
Site -specific
sampling
002
01
VOC &
HAP's
State -only requirement
Site -specific gas
analysis
003
01
VOC &
HAP's
State -only requirement
Site -specific gas
analysis
006
01
VOC,
HAPS
State only requirement
Site -specific gas
analysis
006
01
VOC,
HAPS
State only requirement
Hard component
count
Section 9 — Source Classification
Is this a new previously un-permitted
source? (Points 001-005)
X
Yes
No
What is this point classification?
True Minor
Synthetic Minor
Major
Point 001: Four (4) above ground 400
bbl atmospheric crude oil storage
tank
X
Point 002: One (1) above ground 400
bbl atmospheric emergency tank
X
Point 003: One (1) Tornado Flare
X
Point 004: Crude oil and produced
water truck loadout
X
Point 005: One (1) 400 BBL fixed roof
produced water storage tank
X
Point 006: Fugitive VOC emissions
X
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what
programs?
X
Title V
X
PSD
NA NSR
X
MACT
Is this a modification to an existing
permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why?
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?
X
Yes
No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
X
Yes
No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
Yes
X
No
Page 6
AIRS Point
Section 12 — Regulatory Review
'Regulation 1 - Particulate, Smoke. Carbon=Monoxide and:SUIfur Dioxide ;_..;
001-006
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator
of a source shall allow or cause the emission into the atmosphere of any air pollutant
which is in excess of 20% opacity. This standard is based on 24 consecutive opacity
readings taken at 15 -second intervals for six minutes. The approved reference test method
for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July,
1992)) in all subsections of Section II. A and B of this regulation.
Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner
or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty
consecutive minutes.
;Regulation-�- Odor _ .,...,,_:-
001-006
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
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.
Regulation'`3 - APENs, Construction_ Permits. Operating •Permits RSD
001-006
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in an attainment area with uncontrolled actual emissions of
two tons per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is attainment.
(Applicant is required to file an APEN for points 001-005 since emissions exceed 2
tons per year VOC)
001-006
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit for points 001-005 since uncontrolled VOC
emissions from this facility are greater than the 5.0 TPY threshold (Reg. 3, Part B,
Section 1f.D.3.a)
005
Part B, 111.0.2 - 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 attainment
area, therefore, not subject to RACT. However, operator is using 0.6 (submerged,
dedicated normal service) for its saturation factor.
Reaulation:6 - NatiskSource Perfortnance Standards
001,002,005
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
Is this source greater than 19,800 gallons (471 bbl)? No
Is this source subject to NSPS Kb? No
003,004,
006
none
Regulation 7 -_Volatile Organic .Compounds
001,002,005
XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS
OPERATIONS
(Applicant is not subject to the emission control requirements for condensate tanks
since it is located in an attainment area.)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
(Applicant is not currently subject to this since these are not condensate storage
tanks
003,004,
006
None
=Regulation 8 - Hazardous Air Pollufants _- _ _. .°. _.
Page 7
001, 002,
005
MACT EEEE: Organic Liquids Distribution
• This source is not subject to MACT EEEE because it is located at a "production
field facility' as defined in 40 CFR 63.761 (located upstream of the natural gas
processing plant).
001,002
MACT HH
• This source is not subject to MACT HH because it is not located at a major source
of HAP.
003,004,
006
none
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process Description
Emission Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission
Factor Source
Control
(%)
001
01
E&P Crude Oil
Storage Tanks
3.13 lb/1000 gal
throughput
VOC
No
Site -specific
95
0.02 lb/1000 gal
throughput
Benzene
No
Site -specific
95
SCC
40400312 — Fixed Roof Tank, Crude Oil, working+ breathing + flashing losses
Point
Process
Process Description
Emission Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission
Factor Source.
Control
(%)
002
01
Emergency Tank
33,333 Ib/MMscf
VOC
No
Mass Balance
NA
75 lb/MMscf
Benzene
No
Mass Balance
NA
459 lb/MMscf
n -Hexane
No
Mass Balance
NA
SCC
31000299- Natural Gas Production: other, not classified
Point
Process
Process Description
Emission Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission
Factor Source
Control
(%)
003
01
Tornado Flare
33,634.7 lb/MMscf
VOC
No
Mass Balance
95
105.0 Ib/MMscf
NOx
No
AP -42
NA
573.0 lb/MMscf
CO
No
AP-42
NA
6.8 lb/MMscf
SOx
No
AP -42
NA
77 lb/MMscf
Benzene
No
Mass Balance
95
56.6 Ib/MMscf
Toluene
No
Mass Balance
95
23.5 lb/MMscf
Xylenes
No
Mass Balance
95
459.8 Ib/MMscf
n -Hexane
No
Mass Balance
95
SCC
31000205 — Flares at gas production facility)
Point
Process
Process Description
Emission Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission
Factor Source
Control
(%)
004
01
Crude Oil and Produced
Water Tank Truck
Loadout.
2.47 lb/1000gal
VOC
No
AP -42
NA
0.016 lb/1000 gal
Benzene
No
AP -42
NA
0.098 lb/1000 gal
n -Hexane
No
AP -42
NA
SCC
4060132: Crude Oil: Submerged Loading (Normal Service)
Page 8
Point
Process
Process Description
Emission Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission
Factor Source
Control
(%)
005
01
E&P Produced
Water Storage
Tanks
6.2381 lb/1000 gal
throughput
VOC
No
CDPHE PS
Memo 09-02
95
0.166716/1000 gal
throughput
Benzene
No
CDPHE PS
Memo 09-02
95
0.5238 lb/1000 gal
throughput
n -Hexane
No
CDPHE PS
Memo 09-02
95
SCC
40400315 — Fixed Roof Tank, Produced Water, working+breathing+flashing losses
Point
Process
Process Description
Pollutant /
CAS #
Fugitive -
(Y/N)
Emission Factor Source
Control
(%)
006
01
Fugitive VOC Leak
Emission
VOC
Yes
EPA -453/R-95-017, Table 2-4
NA
SCC
31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains)
Section 14 — Miscellaneous Application Notes
AIRS Point
001
Crude Oil Tanks
These tanks contain oil with an API gravity less than 40 degrees. EOG used E&P Tank to estimate the
flash emissions off this tank battery.
From E&P Tank- uncontrolled ton/year= 16.78 TPY VOC
VOC=(16.78 TPY)*(20001b/ton)/(255,500bbl/yr)= 0.1314 lb/bbl VOC or 3.12851b/1000 gallons
AIRS Point
002
Emergency Tank
Gas going to the flare would be routed to this tank in case of a flare outage. The gas is vented to
atmosphere from this tank. The APEN was submitted with worse -case scenario calculations. This
consists of 3 upset conditions in a 12 month period. Each instance of upset conditions was estimated to
be 12 hours in length.
Max gas vented to atmosphere= 10,000 scf/hr
Molecular wt. of gas= 27.6 lb/lb-mole
VOC fraction= 0.4618
379.4 scf/Ib-mole
VOC= 10,000scf/hr (27.6 lb/lb-mole)/(379.4 scf/Ib-mole)*0.4618=335.9 lb/hr VOC
Using the 3 upset conditions at 12 hrs per condition:
335.9/hr*(12 hr/event)* (3 events/yr) / (2,000lb/ton)= 6.0 tpy VOC
VOC E.F.: 6.0 ton/yr *( 2,000lb/ton)/(0.36 MMscf/yr)= 33,333.3 Ib/MMscf
Page 9
AIRS Point
003
Tornado Flare
The tornado flare is controlling gas coming off the well since there is no pipeline available in the area at
this time. EOG will continue to flare gas until a pipeline is available.
Emissions were calculated using VOC wt fraction.
(scf/hr) * (Ib/Ib-mol) * (% fraction from sales gas analysis) / (379.4 scf/lb-mol) = lb/hr * (hr/yr) / 2000 lb/T) =
TPY
Emission factors for NOx, CO, and PM10 came from AP -42, table 13.5-1
Emission factor for SOx also came from AP -42 and is based on 100% conversion of sulfur to SO2 at
2000 grains/MMscf
VOC E.F. = (1,473.2 TPY * 2000 lb/T)/ (87.6 mmscf/yr) = 33,634.7 lb/MMscf
HAP's Emission Factors:
Benzene =.(6,750.7 Ib/yr) / 87.6 MMscf/yr = 77 lb/MMscf
Toluene = (4,961.4 Ib/yr) / 87.6 MMscf/yr =.56.6 lb/MMscf
Ethylbenzene= (834.1 Ib/yr) / 87.6 MMscf/yr= 9.5 lb/MMscf
Xylenes= (2,060.8 Ib/yr) / 87.6 MMscf/yr = 23.5 Ib/MMscf
n -hexane = (40,281.2 Ib/yr) / 87.6 MMscf/yr = 459.8 lb/MMscf
AIRS Point
004
Truck Loadout of Crude Oil and Produced Water
Converting the Ib/1000gallon factor to lb/bbl
AP -42: Chapter 5.2
Equation 1
L = 12.46*S*P*M/T
L = loading losses in lb per 1000 gallons loaded
S = Saturation Factor
P = true vapor pressure of liquid loaded [psia]
M = molecular weight of vapors [lb/lb-mole]
T = temperature of bulk liquid loaded [deg. R]
S 0.6 Submerged loading: dedicated normal service
P 5.18 psia
M - 33,43 lb/lb-mole for gasoline with RVP = 11.5
T 523 deg. R (64 deg. F)
L 2.47Ib/10^3 gal - -
Annual requested Throughput 12264000ga1/yr
Annual requested VOC emissions 303571b/yr
15.2tpy
Page 10
AIRS Point
005
Produced Water Storage Tanks
Operator originally requested this point to be a General Permit, however, having the general permit
emission limit of 39TPY for VOC would have made them a major source so operator requested that the
point be added to the facility -wide construction permit so actual, controlled emissions would be accounted
for instead of the general permit limit.
State -Developed Emission factors in lb/1000 gal are:
County
Produced Water Tank Default
Emission Factors (lb/1000 gal)
VOC
Benzene
n -Hexane
Adams, Arapahoe, Boulder, Broomfield, Denver,
Douglas, Jefferson, Larimer and Weld
6.2381
0.1667
0.5238
The APEN states that the tanks contain less than 1% by volume crude oil on an annual average basis
which qualifies•the source for the categorical exemption (Regulation 3, Part B, Section II.D.1.m).
However, this source will be permitted because if it was not controlled, the overall permitted VOC
emissions would be greater than 100 TPY and become a major facility. The operator has requested
synthetic minor status and accepted Federally enforceable controls, so this point will be included to
ensure synthetic minor eligibility.
AIRS Point
006
Fugitive VOC emissions
A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (APEN
threshold) and the total facility is greater than 5 TPY (permit threshold).
When reviewing calculations for a similar facility in non -attainment, another engineer working on these
sites noticed the fugitive emissions were calculated incorrectly. These errors triggered fugitives in
attainment facilities to be permit -required (increase from 1.5 TPY to 2.4 TPY). EOG submitted APENS
for the fugitive emissions on 2/14/12.
Points 001-006: No monthly limits will be put in the permit even though this is a synthetic minor source.
After discussing this source with Chris Laplante 3-8-2011 it was decided that since production at an E&P
site is not steady enough to impose those kinds of limits. Compliance on a monthly limit may not be
possible, while a yearly limit could be.
Page 11
Air Pollutant Emission Notice (APEN)._ and — Application for Construction Permit
OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY.
TO-TO-ZT-OtO.Z-NREV-Z00-Et68-6Z1
Current Status (Chi all,that apply)
AIRS ID #': • 125 / t 1 YO.,› I
Reason for APEN Submittal
(Check all that
only'
to existing sources
for coverage under
request for individual
for or Modification
permit amendment?
apply) 25 (>693
general permit no. GPOI
permit6:
i . APEN update
® New or previously unreported battery
GP01
] l Wk11 S I
■ Modification
IN Previously grandfathered battery'
■ Registration
❑ Synthetic minor facility
& cancellation
III Located in the 8 -hr Ozone Control Area'
8; Application
of' an individual permit
■ Registered under general permit no.
■ Administrative
Ea Permitted under individual permit
❑ Other:
For individual permit applications, check if you wants:
analysis conducted by the Division
of the permitprior to issuance
• A copy of the preliminary
• To review a draft
Company Name': EOG Resources, Inc. OGCC Operator #: 27742
MailingAddress'o: 600 17a' Street, Suite 1000N
' david long@eogresour
City; Denver State: CO Zip: 80202 E-mail: ces.com
.
Contact MUM: David Long Phone: 303-262-9448 Fax: 303-262-9449
Tank Battery Name": Critter Creek 5-10H
Number of tanks:
capacity [bbl]:
2010
4
LocationI2 (QQ Sec. Twp. Range.): SESE Sec 10, TI 1N,R63W County: Weld Total tank
1,600 (400 ea)
Calendar year for which "Actual" data appliesS3:
Control Description1s: Cimarron Smokeless
' 2010
Year(s) tank(s) were placed in service":
combustion unit [VCU]) Control Efficiency16:
Combustor (vapor
95%
Condensate Throughput17 [bbl/year] Requested's:
Actual20:
Other equipment at facility22: VCU, flare, heater
255,500 Maximum
for PTE calculation":
While Controls Operationa121
H2O tank (1), emergency
306,600
255,500
255,500
treater (1), line heater (I), produced
blow down tank
Comments: Due to the low gravity of the oil, the tanks do not qualify for GPOI coverage. Therefore, an individual permit is being requested.
Estimated emissions at throughputs listed above. Use N/A for requested
throughput/emission
Check if site -specific
• Requested
Uncontrolled26
N/A
values unless
emission factors provided
Emissions"
'ControlledZ7
N/A
requesting an individual
to calculate
Actual Emission?'
Uncontrolled26
16.78
permit
emissions'3.
Controlled"
0.84
• Check if the Division is to calculate emissions. ► I
Emission Factor
Pollutant'' [b/bbl]
VOC [tons/year] 0.1314
Batter
PTE
20.2
NOx [tons/year] N/A
0.05
.0.05
0.05
CO [tons/year] N/A
0.27 •
027
0.27
Benzene [lbs/year]
n -Hexane [lbs/year]
Wells serviced by this tank or tank battery'
API it: 05-123-31275 Name: Critter Creek 5-10H
Well
Well
Well .
Well
Well
Well
Well
►li . Newly Reported
API #: Name: . . MINewly Reported
API #: Name: • Newly Reported
API it: Name: ■ Newly Reported
API*: Name U Newly Reported
API #: Name: ■ Newly Reported
API #:. - . Name: O Newly Reported
The signature below indicates that I have knowledge
my knowledge and belief If this is a registration
compliance with each condition general
of the facts herein set forth and that the same are true, accurate, and complete to the best of
for coverage under general permit GP01, I further certify that this source is and will be operated
permit GP01. //--Z2.--/Z2
0.Mull
S1rratur rued endor or consultant) pate •
CO ` -. l
David • Division Environmental Manager
C ype or • t N r"of Pers g Above Official Title ! E L Q I 'mil
n N nn with $152.90 for each Colorado Department of Public Health and Environment Forlinformation call:
. Submit this,form� g eP
,dllmg of u -to 5 tank�attery APENS. Include Air Pollution Control Division, APCD-SS-Bl (303) 692-3150
J0 General P ; r'tjfee for each new GP 4300 Cherry Creek Drive South „ O r2,registration to: ' i Denver, CO 80246-1530
- Page 1 of 2 EOG CC 5-1 OP" FormAPCD-205-E&PCondensateTankAPEN.docx
TORM APCD-205
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Section 02 — R
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Section 02 — R
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Request for NEW permit or newly reported emission source.
EOG Resources, Inc.
Request PORTABLE source permit
Critter Creek 5-1011
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Control Equipment /
Reduction (%)
95%
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Reporting
BIN
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Chemical Name
Benzene
Toluene
Xylenes
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Chemical
Abstract Service
(CAS) Number
71432
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1330207
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enario (1, 2 or 3):
ly Authorized to Supply
Division Environmental Manager
Title of Person Legally Authorized to Supply Data
Name of Person Legally Authorized to Supply Data (Please print)
Form Revision Date: December 4. 2006
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