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Home My WebLink About20130809.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. Laboratory Services Division Denver, Colorado 80246-1530 8100 Lowry Blvd. Phone (303) 692-2000 Denver, Colorado 80230-6928 Located in Glendale, Colorado (303) 692-3090 http://www.cdphe.state.co.us March 20, 2013 Weld County Clerk & Recorder 1402 N 17th Ave Greeley, CO 80631 Dear Sir or Madam: Colorado Department of Public Health and Environment On March 24, 2013, the Air Pollution Control Division will publish a public notice for Chesapeake Operating, Inc. — State 8-60 16-1H, Girard 2-63 11-1H , Lindstrom 24-8-67 1H, State 7-62 36-1H and Brent 20-8-66 1H, in the 1 he 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: Ellen Evans Regards, Ellen Evans Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure PL,tAL 2013-0809 STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbino, 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. Laboratory Services Division Denver, Colorado 80246-1530 8100 Lowry Blvd. Phone (303) 692-2000 Denver, Colorado 80230-6928 Located in Glendale, Colorado (303) 692-3090 http://www.cdpheatate.co.us Colorado Department of Public Health and Environment Website Title: Chesapeake Operating, Inc. — Five (5) natural gas wellhead facilities, each consisting of condensate storage tanks (general permit), produced water tank (general permit), reciprocating internal combustion engine (permit -exempt), facility flare and associated fugitives. — Weld County Released To: The Greeley Tribune On: March 20, 2013 Published: March 24, 2013 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: Chesapeake Operating, Inc. Facility: State 8-60 16-IH, Girard 2-63 11-1H, Lindstrom 24-8-67 1H, State 7-62 36-1H and Brent 20-8- 66 1H. Five (5) natural gas wellhead facilities, each consisting of condensate storage tanks (general permit), produced water tank (general permit), reciprocating internal combustion engine (pennit- exempt), facility flare and associated fugitives. State 8-60 16-1H (Section 16, T8N, R60W), Girard 2-63 11-1H (Section 11, T2N, R63W), Lindstrom 24-8-67 1H (Section 24, T8N, R67W), State 7-62 36-IH (Section 36, T7N, R62W) and Brent 20-8-66 1H (Section 20, T8N, R66W). Weld County The proposed project or activity is as follows: The operator proposes to maintain and operate five (5) natural gas wellhead sites. 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, including supplemental information, the Division's analysis, and a draft' of Construction Permit 12WEI862, 12WE1860, 12WE1874, 12WE1875 and 12WE1873 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: Stephanie Chaousy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-BI Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Chesapeake Operating, Inc. Permit Number: 12WE1860 Source Location: S11, T2N, R63W, Weld County (Attainment) Equipment Description Point 002: Plant flare with a minimum combustion efficiency of 95%. Point 003: Fugitive emissions AIRS ID: 123-9903 Date: • August 15, 2012 Review Engineer: Stephanie Chaousy, P.E. Control Engineer Chris Laplante Section 2 — Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt 'If tank is a true minor source at a true minor facility, it shall be granted "Final Approval" 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? Yes X 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? 8/15/12: I emailed the Operator for the gas analysis used in the fugitive and flare calculations. RACT for fugitives was agreed on for another project. I received a correct gas analysis on 10/25/12. Received new calculations on 12/21/12 for VOC emissions (including separator emissions) On what date was this application complete? May 23, 2012 Section 4 — Source Description AIRS Point Equipment Description 002 Plant flare used to control gas stream off of a 3 -phase separator. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. 003 Fugitive emission leaks. Is this a portable source? Yes X No Is this location in a non -attainment area for any criteria pollutant? X Yes No If "yes", for what pollutant? PM10 CO X Ozone Page 1 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) PM,o 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) X Yes No Section 5 — Emission Estimate Information AIRS Point Emission Factor Source 002 AP -42, Table 13.5-1 for combustion; mass balance for separator VOC 003 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 002 23,975 MCF/yr 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 --- 6 --- Open -Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 002 23,975 MCF/yr 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 --- 6 --- Open -Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves SO --- 5 --- Other 13 --- 3 --- Basis for Permitted Emissions (Permit Limits1 AIRS Point Process Consumption/Throughput/Production 002 23,975 MCF/yr 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 --- 6 --- Open -Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- Does this facility use control devices? X Yes No Page 2 AIRS Point Process Control Device Description % Reduction Granted 002 of Flare 95 Section 6 — Emission Summary (tons per year) Point NO. VOC CO SOx PM10 Single HAP Total HAP 001 2.0 0.2 1.1 --- --- 0.1 {formaldehyde) 0.1 002 1.8 238.7 10.0 --- --- --- --- PTE: 003 --- 2.1 --- --- --- 004 2.7 75.0 14.9 --- --- 1.1 (n -hexane) 1.3 005 --- 3.6 --- --- --- 0.3 (n -hexane) 0.4 Uncontrolled point source emission rate: 001 2.0 0.2 1.1 --- --- 0.1 (formaldehyde) 0.1 002 1.8 238.7 10.0 --- 003 --- 2.1 -- --- --- --- --- 004 2.7 62.5 14.9 --- --- 1.0 (n -hexane) 1.1 005 -- 3.6 --- --- --- 0.3 (n -hexane) 0.4 TOTAL (TPY) 6.5 307.1 26.0 --- --- 1.3 (n -hexane) 1.6 Controlled point source emission rate: 001 2.0 0.2 1.1 --- --- 0.1 (formaldehyde) 0.1 002 1.8 15.5 10.0 --- --- --- --- 003 --- 2.1 --- --- --- --- --- 004 2.7 39 14.9 --- --- 0.05 (n -hexane) 0.05 005 --- 10 -- --- --- 0.02 (n -hexane) 0.03 INSIGNIFICANTS (TPY) 0.2 0.4 0.2 --- - --- - TOTAL PERMITTED (TPY) g 5 56.2 29.1 --- --- 0.1 (formaldehyde) 0.2 Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (lblyr), 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 standard? X Yes No If "yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 002 0i VOC, HAPS State only requirement Site -specific gas analysis 003 01 VOC, HAPS State only requirement Site -specific gas analysis 003 01 VOC, HAPS State only requirement Hard component count Page 3 Section 9 — Source Classification Is this a new previously un-permitted source? Yes No Point 002: Flare X Point 003: Fugitives X What is this facility classification? True Minor . X Synthetic Minor Major Classification relates to what programs? X Title V PSD X NA NSR 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 (controlled emissions increase > 25/50 tpy)? X Yes No For Reg. 3, Part B, IILC.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? NOx emissions are less than 40 TPY. Yes X No AIRS Point Section 12 — Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 002, 003 Section Il.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 2 — Odor 002, 003 Section LA - 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. Page 4 Regulation 3:=APENs,Construction Permits: Operating Permits PSD=, ` 002, 003 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 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 from production exceed 1 ton per year VOC) 002, 003 Part B - Construction Permit Exemptions Applicant is required to file a permit since uncontrolled VOC emissions are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section Il.D.2.a) Regulation 6'- New Source Performance Standards 002 None 003 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). Is this source at a "natural gas processing plant?" No Is this source subject to NSPS KKK? No WHY? Facility not defined as a natural gas processing plant, therefore, does not meet the criteria of NSPS KKK. .Regulation 7 - Volatile' Orabnieeoniautids9-:, 002 None 003 Section XII.G: If facility is a natural gas processing plant located in non -attainment area, then subject to Section XII.G. Facility is not a natural gas processing plant, therefore, not subject to Section XII.G. 'Regulation 8 — Hazardous" Air:Pollutants' r ` 002 None 003 MACT HI -I: If facility is MAJOR source for HAP (summation of HAPS of dehydrators and fugitives), then fugitive emissions are subject to MACT HH. Is this facility considered MAJOR for HAPS? No Is this source subject to MACT HH? No WHY? Facility is area source for MACT HH, therefore, only TEG dehydrators are subject to MACT HH. This facility has no TEG dehydrators, so facility not subject to MACT HH. Section 13 - Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Factor Pollutant / CAS # Fugitive (Y/N) Emission Factor Source Control (%) 002 01 19.91 lb/MCF VOC No Engineering Calculation 95 Flare 0.068 lb/MMBtu NOx - No AP -42' Table 13.5-1 NA 0.37 Ib/MMBtu CO No AP -42, Table 13.5-1 NA SCC 31000205 -Flares 003 01 Fugitive VOC Leak Emissions VOC Yes EPA-453/R-95-017,4 Table 2- NA SCC 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Page 5 Section 14 — Miscellaneous Application Notes AIRS Point 002 Flare Permit issued because emissions are greater 5 TPY CO (Reg. 3, Part B, Section II.D.2.e) VOC, NOx and CO (from AP -42, Chapter 13, Table 13.5-1 (NOx = 0.068 lb/mmbtu; CO = 0.37 Ib/mmbtu; VOC = 0.14 lb/mmbtu) Operator did not include associated gas analysis with the application. I emailed the Operator on 8/15/12 for the gas analysis. Gas analysis showed no BTEX. Original VOC calculations did not include emissions from the separator. Received new calculations on 12/21/12 and generated a new VOC emission factor to account for "associated gas" emissions that will be controlled.: VOC = (238.72*2000)/23975 = 19.91 lb/MCF AIRS Point 003 Fugitive emissions A permit will be issued because the uncontrolled VOC emissions are greater than 1 TPY (APEN threshold) and TOTAL FACILITY is greater than 2 TPY (permit threshold). Operator did not include associated gas analysis with the application. I emailed the Operator on 8/8/12 for the gas analysis. I received a gas analysis on 8/28/12. Turns out, Operator provided me the wrong gas analysis (not the one used for calculations). Was provided new gas analysis by consultant on 10/25/12. The new gas analysis matched what was on the APEN under VOC wt%. Gas analysis showed no BTEX. I calculated fugitives based on their APEN. Their calculation sheet showed that they used the same emission factor for GAS -compressor seals and GAS -relief valves (even though compressor seals are on the APEN as GAS -pump seals and the relief valves are listed as GAS -Other). Operator used the emission factor for GAS -Other for all sources. I calculated it both ways, and did not get a big difference in emissions, so I will agree with the Operator's calculation of 2.1 TPY VOC. Page 6 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 1 2WE1 860 Issuance 1 DATE ISSUED: ISSUED TO: Chesapeake Operating, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: OH and gas facility, known as Girard 2-63 11-1H, located in Section 11, Township 2 North, Range 63 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS point Description FLARE2 002 Plant flare used to control gas stream off of a 3 -phase separator. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. FUG1 003 Equipment leaks (fugitive VOCs) from an oil and gas 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. YOU MUST notify the APCD no later than fifteen days after issuance of this permit or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state.co.us/aptdownloadforms.html. Failure to notify the APCD of startup of the permitted source is a violation of AQCC Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. 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). 3. 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 AIRS ID: 123/9903 Page 1 of 10 Condensate Tank Version 2009-1 Depa mere of blitz Health and Environment it Pollution Control Division application asspgiated`witl3this permitni) di cohtiFbes cons!. ction for a 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.) 4. 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.) 5. 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 6. 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 FLARE2 002 1.8 15.5 10.0 Point FUG1 003 --- 2.1 --- Fugitive limits. s to Permit Holder #4" for information on emission factors and methods used to calculate 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. 7. Point 003: 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. PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Monthly records of the actual throughput shall be maintained by the applicant andmade 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 FLARE2 002 Natural gas flaring 23,975 MCF/yr AIRS ID: 123/9903 Page 2 of 10 bli% Health and Environment %Air Pollution Control Division as Compliance wfh-,e.n m ro= f li=:be det ,,jned on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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) 10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.) 11. 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.). 12. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. Point 003: 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 for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). The requirements of condition number 14 below were determined to be RACT for this source. 14. Point 003: 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) For leak screening, auditory/visual/olfactory inspection (AVO) will be performed on a quarterly basis. (H) For each leak found in the AVO inspection, a gas detector shall 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. 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. (iii) 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 to determine if the leak is repaired. AIRS ID: 123/9903 Page 3 of 10 blid Health and Environment it Pollution Control Division (v) •,Ilowmg ,ecotds shall be maintained for 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. • Dates of the AVO screenings, gas 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 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. Point 002: The operator shall complete an initial site specific extended gas analysis of the natural gas produced at this site that is routed to the enclosed flare 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. 17. Point 002: The owner or operator shall demonstrate compliance with Condition 10 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5). 18. Point 003: 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. 19. Point 003: 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 AIRS ID: 123/9903 Page 4 of 10 20. Point 002: Th ePbr gperato heat content on an annual basis. blicPHealth and Environment it Pollution Control Division gas rout p the flare to determine the 21. Point 003: On an annual basis, the owner or operator shall complete an extended gas analysis of produced gas that is 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 22. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. 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 volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NO„ 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 For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 23. 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 24. 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: 123/9903 Page 5 of 10 'Color^ Depa* eri f P bli&Health and Environment "Air Pollution Control Division ..7 U 25. If this permit s - oificailfi stges,thatfjp ut i izatr'on, has beO granted, then the remainder of this condition is not applicable. Otherwise, theissuance 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. 26. 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. 27. 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. 28. 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. 29. 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. 30. 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: Stephanie Chaousy, PE Permit Engineer Air Pollution Control Division Permit History Issuance Date Description AIRS ID: 123/9903 Page 6 of 10 blicHealth and Environment it Pollution Control Division ±1 Permit-10r" ) enclosed flare and associated fugitives. New synthetic minor source facility. AIRS ID: 123/9903 Page 7 of 10 Notes to Permit Holder F. .bli Health and Environment ,Air Pollution Control Division c•.ar!"G 1) 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 maybe 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. 2) 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 permitas soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.cdphe.state.co.us/requlations/airregs/100102agcccom monprovisionsreq.pdf. 3) The emission levels contained in this permit are based on the following emission factors: Point 002: CAS # Pollutant Emission Factors Uncontrolled Emission Factors Controlled Source NOx 0.068 Ib/MMBtu 0.068 lb/MMBtu AP -42, Table 13.5-1 CO 0.37 lb/MMBtu 0.37 lb/MMBtu AP -42, Table 13.5-1 VOC 19.91 lb/MCF 0.9955 lb/MCF Engineering Calculation Note: The controlled emissions factors for point 002 are based on the flare control efficiency of 95%. Point 003: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors --- --- --- --- Flanges 55 --- 6 --- Open-Ended Lines --- -- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- VOC Content (wt%) 31.72% --- 100% --- Benzene Content (wt%) --- --- --- --- Toluene Content (wt%) --- --- --- --- Ethylbenzene (wt %) --- --- --- --- Xylenes Content (wt%) --- --- --- --- n-hexane Content (wt%) --- --- --- --- *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 SWater/Oil ervi Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 AIRS ID: 123/9903 Page 8 of 10 ,mss ��G ,Color Depa °menhh , 1 ur -J E;w bile Health and Environment Air Pollution Control Division Flanges mks==# 3 4 s l fa ALC07.., E-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. 4) 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. 5) This facility is classified as follows: Applicable - Requirement Status Operating Permit Synthetic Minor Source VOC NANSR Synthetic Minor Source VOC MACT HH Area Source Requirements: Not Applicable 6) 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.govi 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 AIRS ID: 123/9903 Page 9 of 10 f bliHealth and Environment *Air Pollution Control Division 1 rw= 7) An Oil and Gas lndu tructiora,Permit4elf iflcation Form is hgluded 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 I AIRS ID: 123/9903 Page 10 of 10 Construction Permit Application Preliminary Analysis Summary Section 1 — Applicant Information Company Name: Chesapeake Operating, Inc. Permit Number: 12WE1862 Source Location: S16, T8N, R60W, Weld County (attainment) Equipment Description Point 004: Plant flare with a minimum combustion efficiency of 95%. Point 005: Fugitive emissions AIRS ID: 123-9709 Date: September 21, 2012 Review Engineer: Stephanie Chaousy, P.E. Control Engineer: Chris Laplante Section 2 —Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt *If tank is a true minor source at a true minor facility, it shall be granted "Final Approval" 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? Yes X 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? 8/15/12: I emailed the Operator for the gas analysis used in the fugitive and flare calculations. RACT for fugitives was agreed on for another project. Received new calculations on 12/21/12 for VOC emissions (including separator emissions) On what date was this application complete? May 23, 2012 Section 4 — Source Description AIRS Point Equipment Description 004 Plant flare used to control gas stream off of a 3 -phase separator. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. 005 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? PM10 CO Ozone Is this location in an attainment maintenance area for any criteria pollutant? Yes X No Page 1 If "yes", for what pollutant? (Note: These pollutants are subject to minor source RACT per Regulation 3, Part B, Section III.D.2) PM,o 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 Section 5 — Emission Estimate Information AIRS Point Emission Factor Source 004 AP -42, Table 13.5-1 for combustion; mass balance for separator VOC 005 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 (PTE) AIRS Point Process Consumption/Throughput/Production 004 6430 MCF/yr 005 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 --- 6 --- Open -Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --_• Other 13 --- 3 --- Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 004 6430 MCF/yr 005 Equipment Type Connectors Flanges Open -Ended Lines Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil 55 6 Pump Seals Valves Other 10 3 50 5 13 3 Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 004 6430 MCF/yr 005 Equipment Type Connectors Flanges Open -Ended Lines Pump Seals Valves Other Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil 55 6 10 3 50 5 13 3 Does this facility use control devices? X Yes No AIRS Point Process Control Device Description % Reduction Granted Page 2 004 01 Flare 95 Section 6 — Emission Summary (tons per year) Point NO. VOC CO SOx PM10 Single HAP Total HAP 001 2.7 50.4 9.4 --- --- 0:8 (n -hexane) 0.9 002 --- 0.3 --- --- --- 0.02 (n -hexane) 0.03 PTE: 003 2.0 0.1 1.1 --- --- 0.08 (formaldehyde) 0.1 004 1.2 134.3 6.5 --- --- --- --- 005 -- 3.0 --- --- --- --- Uncontrolled point source emission rate: 001 2.7 42.0 9.4 --- --- 0.6 (n -hexane) 0.7 002 --- 0.2 --- --- --- 0.02 (n -hexane) 0.03 003 2.0 0.1 1.1 --- --- 0.08 (formaldehyde) 0.1 004 1.2 134.3 6.5 --- --- --- --- 005 --- 3.0 --- --- --- --- TOTAL (TRY) 5.9 179.8 17.0 --- --- 0.6 (n -hexane) 0.8 Controlled point source emission rate: 001 2.7 39 9.4 --- --- 0.03 (n -hexane) 0.04 002 -- 10 --- --- --- - --- 003 2.0 0.1 11 .(formaldehyde) - -_ __- 0.08 0.1 004 1.2 9.1 6.5 --- --- --- --- 005 --- 3.0 --- --- --- --- --- INSIGNIFICANTS (TRY) 0.2 0.4 0.2 --- --- --- -- TOTAL PERMITTED (TPY) 5.9 61.2 17.0 __ _-_ 0.08 (formaldehyde) 0.1 Section 7 — Non -Criteria ! Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (1b/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) Note: Regulation 3, Part A, Section Il.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 standard? X Yes No If "yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 004 01 VOC, HAPS State only requirement Site -specific gas analysis 005 01 VOC, HAPS State only requirement Site -specific gas analysis 005 01 VOC, HAPS State only requirement Hard component count Page 3 Section 9 — Source Classification Is this a new previously un-permitted source? Yes No Point 004: Flare X Point 005: Fugitives X What is this point classification? True Minor Synthetic Minor Major Point 004: Flare X Point 005: Fugitives X What is this facility classification? True Minor X Synthetic Minor Major Classification relates to what programs? X Title V PSD NA NSR 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 (controlled 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? NOx emissions are less than 40 TPY. Yes. X No AIRS Point Section 12 — Regulatory Review Regulation 1 - Particulate, Smoke Carbon Monoxide and Sulfur Dioxide 004, 005 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 2 — Odor 004, 005 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. Page 4 Regulation3 =APENs; Construction Permits Operating PernlifirPSD 004, 005 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 since emissions from production exceed 2 tons per year VOC) 004, 005 Part B — Construction Permit Exemptions Applicant is required to file a permit since uncontrolled VOC emissions are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section II.D.3.a) Regulation 6 - New Source Performance Standards 004 None 005 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). Is this source at a "natural gas processing plant?" No Is this source subject to NSPS KKK? No WHY? Facility not defined as a natural gas processing plant, therefore, does not meet the criteria of NSPS KKK. Regulation 7 -Volatile Organic Compounds 004 None 005 Section XII.G: If facility is a natural gas processing plant located in non -attainment area, then subject to Section XII.G. Facility is not a natural gas processing plant, therefore, not subject to Section XII.G. Regulation 8 — Hazardous Air Pollutants 004 None 005 MACT HH: If facility is MAJOR source for HAP (summation of HAPS of dehydrators and fugitives), then fugitive emissions are subject to MACT HH. Is this facility considered MAJOR for HAPS? No Is this source subject to MACT HH? No WHY? Facility is area source for MACT HH, therefore, only TEG dehydrators are subject to MACT HH. This facility has no TEG dehydrators, so facility not subject to MACT HH. Section 13 — Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Factor Pollutant! CAS # Fugitive (Y/N) Emission Factor Source Control (%) 004 01 41.77 lb!MCF V0C No Engineering Calculation 95 Flare 0.068 Ib!MMBtu N0x No AP -42, Table 13.5-1 NA 0.37 Ib/MMBtu CO No AP -42' Table 13.5-1 NA SCC 31000205 -Flares 005 01 Fugitive VOC Leak Emissions V0C Yes EPA -453/R-95-017, Table 2-4 NA SCC 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Page 5 Section 14 — Miscellaneous Application Notes AIRS Point 004 Flare Permit issued because emissions are greater 10 TPY CO (Reg. 3, Part B, Section II.D.3.e). VOC, NOx and CO (from AP -42, Chapter 13, Table 13.5-1 (NOx = 0.068 lb/mmbtu; CO = 0.37 lb/mmbtu; VOC = 0.14 lb/mmbtu) Operator did not include associated gas analysis with the application. I emailed the Operator on 8/15/12 for the gas analysis. Gas analysis showed no BTEX. Original VOC calculations did not include emissions from the separator. Received new calculations on 12/21/12 and generated a new VOC emission factor to account for "associated gas" emissions that will be controlled. VOC = (134.28 * 2000/6430 = 41.77 lb/MCF AIRS Point 005 Fugitive emissions A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (APEN threshold) and TOTAL FACILITY is greater than 5 TPY (permit threshold). Operator did not include associated gas analysis with the application. I emailed the Operator on 8/8/12 for the gas analysis. Operator provided me the wrong gas analysis (not the one used for calculations). Was provided new gas analysis by consultant on 10/25/12. The new gas analysis matched what was on the APEN under VOC wt%. Gas analysis showed no BTEX. I calculated fugitives based on their APEN. Their calculation sheet showed that they used the same emission factor for GAS -compressor seals and GAS -relief valves (even though compressor seals are on the APEN as GAS -pump seals and the relief valves are listed as GAS -Other). Operator used the emission factor for GAS -Other for all sources. I calculated it both ways, and did not get a big difference in emissions, so I will agree with the Operator's calculation of 3.0 TPY VOC. Page 6 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: 12WE1862 Chesapeake Operating, Inc. Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as State 8-60 16-1H, located in Section 16, Township 8 North, Range 60 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description FLARE2 004 Plant flare used to control gas stream off of a 3 -phase separator. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. FUG1 005 Equipment leaks (fugitive VOCs) from an oil and gas 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. YOU MUST notify the APCD no later than fifteen days after issuance of this permit or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state.co.us/aptdownloadforms.html. Failure to notify the APCD of startup of the permitted source is a violation of AQCC Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. 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). 3. 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 AIRS ID: 123/9709 Page 1 of 8 Condensate Tank Version 2009-1 kl P abliHealth and Environment it Pollution Control Division application associated with this permt• •ii) d)s'u• ontiri es congt(,gtion for a 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.) 4. 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.) 5. 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 6. 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 NOx VOC CO FLARE2 004 1.2 9.1 6.5 Point FUG1 005 --- 3.0 --- Fugitive See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate limits. 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. 7. Point 005: 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. PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below, Monthly records of the actual throughput 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 FLARE2 004 Natural gas flaring 91,250 MCF/yr AIRS ID: 123/9709 Page 2 of 8 bli&Health and Environment Air Pollution Control Division Compliance w ' t e annga roligb iS li ' to ¢e dete j`'' ed on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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) 10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.) 11. 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.). 12. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 13. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. Point 004: The operator shall complete an initial site specific extended gas analysis of the natural gas produced at this site that is routed to the enclosed flare 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. 15. Point 004: The owner or operator shall demonstrate compliance with Condition 10 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5). 16. Point 005: 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 AIRS ID: 123/9709 Page 3 of 8 the gas and liquids analyses ,an. - onacalcyl ,eons to . - 'ivision as part of the self - certification process to ensure compliance with emissions limits. 17. Point 005: 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 18. Point 004: The owner or operator shall sample the gas routed to the flare to determine the heat content on an annual basis. 19. Point 005: On an annual basis, the owner or operator shall complete an extended gas analysis of produced gas that is 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. f ' blid'Health and Environment 4ir Pollution Control Division ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. 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. 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. 21. 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 AIRS ID: 123/9709 Page 4 of 8 22. This permit and ttachnterltsq uplpe r - ® r rid mages= ailable 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. 23. 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. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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. ejblio`Health and Environment Air Pollution Control Division By: Stephanie Chaousy, PE Permit Engineer AIRS ID: 123/9709 Page 5 of 8 bl cHealth and Environment Air Pollution Control Division �dl Air Poly trolfbimsitik� Permit Histor Issuance Date Description Issuance 1 This Issuance Permit for: (1) enclosed flare and associated fugitives. New synthetic minor source facility. AIRS ID: 123/9709 Page 6 of 8 Notes to Permit Holder a Color A Depa` nu er f e of this perintisstlande'. sdaza bliclHealth and Environment it Pollution Control Division 1) 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 maybe 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. 2) 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: http://www. cdphe. state.co. us/regulations/airreqs/100102aacccom m on provision sreq. pdf. 3) The emission levels contained in this permit are based on the following emission factors: Point 004: CAS # Pollutant Emission Factors Uncontrolled Emission Factors Controlled Source NOx . 0.068 lb/MMBtu --- AP -42, Table 13.5-1 CO 0.37 lb/MMBtu --- AP -42, Table 13.5-1 VOC 41.77 Ib/MCF 2.0885 lb/MCF Engineering Calculation Note: The controlled emissions factors for point 004 are based on the flare control efficiency of 95%. Point 005: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors --- --- --- --- Flanges 55 --- 6 --- Open-Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- VOC Content (wt%) 53.04% 100% 100% 100% Benzene Content (wt%) --- --- --- Toluene Content (wt%) --- --- --- --- Ethylbenzene (wt %) --- --- --- Xylenes Content (wt%) --- --- --- --- n-hexane Content (wt%) --- --- --- --- *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 AIRS ID: 123/9709 Page 7 of 8 Colorr:w,,:_ Depa ;nen4'of F bliC.J Health and Environment Air Pollution Control Division Pump Seals " 2;4E-03 ::: AA E: - ': - '-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. 4) 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. 5) • This facility is classified as follows: Applicable Requirement Status Operating Permit . Synthetic Minor Source: VOC NANSR Synthetic Minor Source: VOC MACT HH Area Source Requirements: Not Applicable 6) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.poaccess.govi Part 60: Standards of Performance for New Stationary Sources NSPS 60:1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63,1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 7) 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/oilgaspermittinq.html AIRS ID: 123/9709 Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 — Applicant Information Company Name: Chesapeake Operating, Inc. Permit Number: 12WE1873 Source Location: S20, T8N, R66W, Weld County (non -attainment) Equipment Description Point 002: Plant flare with a minimum combustion efficiency of 95%. Point 003: Fugitive emissions AIRS ID: 123-9909 Date: September 25, 2012 Review Engineer: Stephanie Chaousy, P.E. Control Engineer: Chris Laplante Section 2 — Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt *If tank is a true minor source at a true minor facility, it shall be granted "Final Approval" 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? Yes X 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? 8/15/12: I emailed the Operator for the gas analysis used in the fugitive and flare calculations. RACT for fugitives was agreed on for another project. Received new calculations on 12/21/12 for VOC emissions (including separator emissions On what date was this application complete? May 23, 2012 Section 4 — Source Description AIRS Point Equipment Description 002 Plant flare used to control gas stream off of a 3 -phase separator. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. 003 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? PM,() CO Ozone Is this location in an attainment maintenance area for any criteria pollutant? Yes X No Page 1 If "yes", for what pollutant? (Note: These pollutants are subject to minor source RACT per Regulation 3, Part B, Section III.D.2) PM,o 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 Section 5 - Emission Estimate Information AIRS Point Emission Factor Source 002 AP -42, Table 13.5-1 for combustion; mass balance for separator VOC 003 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 (PTE) AIRS Point Process Consumption/Throughput/Production 002 5561 MCF/yr 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 --- 6 --- Open -Ended Lines --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 002 5561 MCF/yr 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 --- 6 --- Open -Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- _ Other 13 --- 3 --- Basis for Permitted EmissionsjPermit Limits) AIRS Point Process Consumption/Throughput/Production 002 5561 MCF/yr 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 --- 6 --- Open -Ended Lines --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- Does this facility use control devices? X Yes No AIRS Point Process Control Device Description % Reduction Granted Page 2 002 01 Flare 95 Section 6 — Emission Summary (tons per year) Point NO), VOC CO SOx PM10 Single HAP Total HAP PTE: 001 2.0 0.1 1.1 ------ 0.08 (formaldehyde) 0.1 002 1.2 99.6 6.3 --- --- --- --- 003 --- 2.7 --- --- --- --- --- 004 2.7 91.2 14.9 --- --- 1.4 (n -hexane) 1.6 005 --- 2.3 --- --- --- 0.2 (n -hexane) 0.3 Uncontrolled point source emission rate: 001 2.0 0.1 1.1 --- --- 0.08 (formaldehyde) 0.1 002 1.2 99.6 6.3 --- --- --- - 003 --- 2.7 --- --- --- --- --- 004 2.7 76.0 14.9 --- --- 1.2 (n -hexane) 1.3 005 --- 1.9 -- --- --- 0.2 (n -hexane) 0.2 TOTAL (TPY) 5.9 180.3 22.3 --- --- 1.4 (n -hexane) 1.6 Controlled point source emission rate: 001 2.0 0.1 1.1 --- "— 0.08 (formaldehyde) 0.1 002 1,2 7.3 6.3 --- --- --- --- 003 --- 2.7 --- --- --- --- --- 004 2.7 39 14.9 --- --- 0.06 (n -hexane) 0.06 005 --- 10 --- --- --- 0.01 (n -hexane) 0.01 INSIGNIFICANTS (TPY) 0.2 0.5 0.2 --- --- --- --- TOTAL PERMITTED (TPY) 5.9 59.1 22.3 --- --- 0.08 (formaldehyde) 0.17 Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 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 standard? X Yes No If "yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 002 01 VOC, HAPS State only requirement Site -specific gas analysis 002 of Opacity Regulation No. 1, Section II.A.5 EPA Method 9 003 01 VOC, HAPS State only requirement Site -specific gas analysis 003 01 VOC, HAPS State only requirement Hard component count Page 3 Section 9 — Source Classification Is this a new previously un-permitted source? Yes No Point 002: Flare X Point 003: Fugitives X What is this point classification? True Minor Synthetic Minor Major Point 002: Flare X Point 003: Fugitives X What is this facility classification? True Minor X Synthetic Minor Major Classification relates to what programs? X Title V PSD X NA NSR 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 (controlled 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 — Modelin Is modeling required to demonstrate compliance with National Ambient Air Quality Standards (NAAQS)? Yes X No If "yes", for which pollutants? Why? NOx emissions are less than 40 TPY. AIRS Point Section 12 — Regulatory Review Regulation 1 - Particulate. Smoke, Carbon Monoxide and Sulfur Dioxide 002, 003 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 2 — Odor 002, 003 Section 1.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. Page 4 ',Regulation 3...,APENs, Constrructiori'Permits, Operating Pernrifs, PSD 002, 003 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 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 from production exceed 1 ton per year VOC) 002, 003 Part B — Construction Permit Exemptions Applicant is required to file a permit since uncontrolled VOC emissions are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section II.D.2.a) Requlation 6 - New Source Performance Standards 002 None 003 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). Is this source at a "natural gas processing plant?" No Is this source subject to NSPS KKK? No WHY? Facility not defined as a natural gas processing plant, therefore, does not meet the criteria of NSPS KKK. Redulation 7 — Volatile,. Organic Compounds 002 None 003 Section XII.G: If facility is a natural gas processing plant located in non -attainment area, then subject to Section XII.G. Facility is not a natural gas processing plant, therefore, not subject to Section XII.G. Requlation.8 - Hazardous Air Pollutants 002 None 003 MACT HH: If facility is MAJOR source for HAP (summation of HAPS of dehydrators and fugitives), then fugitive emissions are subject to MACT HH. Is this facility considered MAJOR for HAPS? No Is this source subject to MACT HH? No WHY? Facility is area source for MACT HH, therefore, only TEG dehydrators are subject to MACT HH. This facility has no TEG dehydrators, so facility not subject to MACT HH. Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Factor Pollutant/ CAS # Fugitive (Y/N) Emission Factor Source Control (%) 002 01 35.82 lb/MCF VOC No Engineering Calculation 92.7 Flare 0.068 Ib/MMBtu NOx No AP -42, Table 13.5-1 NA 0.37 lb/MMBtu CO No AP -42, Table 13.5-1 NA SCC 31000205 -Flares 003 01 Fugitive VOC Leak Emissions VOC Yes EPA -453/R-95-017, Table 2-4 NA SCC 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Page 5 Section 14 — Miscellaneous Application Notes AIRS Point 002 Flare Permit issued because emissions are greater 5 TPY CO (Reg. 3, Part B, Section ll.D.3.e). VOC, NOx and CO (from AP -42, Chapter 13, Table 13.5-1 (NOx = 0.068 lb/mmbtu; CO = 0.37 lb/mmbtu; VOC = 0.14 lb/mmbtu) Operator did not include associated gas analysis with the application. I emailed the Operator on 8/15/12 for the gas analysis. Operator provided a gas analysis via email on 8/28/12. Gas analysis showed no BTEX. Original VOC calculations did not include emissions from the separator. Received new calculations on 12/21/12 and generated a new VOC emission factor to account for "associated gas" emissions that will be controlled. VOC = (99.6*2000)/5561 = 35.82 lb/MCF AIRS Point 003 Fugitive emissions A permit will be issued because the uncontrolled VOC emissions are greater than 2 threshold). Operator did not include associated gas analysis with the application. I emailed the for the gas analysis. Operator provided a gas analysis via email on 8/28/12. Gas analysis showed no BTEX (just listed as Hexanes ++). Operator provided me their spreadsheet that converts mol% to wt%. When I entered the results of the gas analysis spreadsheet, I calculated a Wt % VOC of 41.55035%, while the operator (what is on calculated 47.18%. Their calculation sheet also showed that they used the same emission GAS -compressor seals and GAS -relief valves (even though compressor seals are on pump seals and the relief valves are listed as GAS -Other). Operator used the emission Other for all sources. I calculated it both ways, and the Operator's request is higher it with the 2 different wt % VOC. The operator's request of 2.7 TPY VOC is higher, the higher emission limit. TPY (permit Operator on 8/8/12 excel into the the APEN) factor for the APEN as GAS - factor for GAS - as well as calculated therefore, I will accept Was what was on the EPA Factors and 41.55% wt% EPA Factors and 47.18% wt% Combined Factors and 41.55% wt% Combined Factors and 47.18% wt% (Operator) VOC (TPY) 2.3 2.5 2.5 2.7 ` Turns out, Operator provided me the wrong gas analysis (not the one used for calculations). provided new gas analysis by consultant on 10/25/12. The new gas analysis matched APEN under VOC wt%. Page 6 1,7 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 12WE1873 $73 DATE ISSUED: ISSUED TO: Chesapeake Operating, Inc. Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as Brent 20-8-66 1H, located in Section 20, Township 8 North, Range 66 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description FLARE2 002 Plant flare used to control gas stream off of a 3 -phase separator. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. FUG1 003 Equipment leaks (fugitive VOCs) from an oil and gas 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. YOU MUST notify the APCD no later than fifteen days after issuance of this permit or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.htmi. Failure to notify the APCD of startup of the permitted source is a violation of AQCC Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. 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). 3, 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 AIRS ID: 123/9909 Page 1 of 10 Condensate Tank Version 2009-1 ,t4 application o se application assated with this p'enmCii) dlseontlnues con§. tion for a 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.) 4. 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.) 5. 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. f P bliciHealth and Environment Air Pollution Control Division EMISSION LIMITATIONS AND RECORDS 6. 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 yp NO, VOC CO FLARE2 002 1.2 7.3 6.3 Point FUG1 003 --- 2.7 --- Fugitive See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate limits. 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. Point 003: 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. PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Monthly records of the actual throughput 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 FLARE2 002 Natural gas flaring 5,561 MCF/yr AIRS ID: 123/9909 Page 2 of 10 blicPHealth and Environment f`Air Pollution Control Division al Compliance wtt ' t nnual throjgfl % li h:` se detg fiiried on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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) 10. Visible emissions shall not exceed twenty percent (20%) opacity duringnormal 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 ll.A.1. & 4.) 11. 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.). 12. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. Point 003: 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 for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). The requirements of condition number 14 below were determined to be RACT for this source: 14. Point 003: 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 requirementto apply RACT. (i) For leak screening, auditory/visual/olfactory inspection (AVO) will be performed on a quarterly basis. (ii) For each leak found in the AVO inspection, a gas detector shall 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. 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. (iii) 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 to determine if the leak is repaired. AIRS ID: 123/9909 Page 3 of 10 (v) the folwin f'two i ® II qt., dined fprra-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. • Dates of the AVO screenings, gas 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 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) blic'Health and Environment it Pollution Control Division COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. Point 002: The operator shall complete an initial site specific extended gas analysis of the natural gas produced at this site that is routed to the enclosed flare 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. 17. Point 002: The owner or operator shall demonstrate compliance with Condition 10 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section I I.A.5). 18. Point 003: 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. 19. Point 003: 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 AIRS ID: 123/9909 Page 4 of 10 blicHealth and Environment it Pollution Control Division 20. Point 002: Th r m. or to .t sa � L th$ gas ro ® . the flare to determine the heat content on an annual basis. 21. Point 003: On an annual basis, the owner or operator shall complete an extended gas analysis of produced gas that is 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 22. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, 'LC) a. 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 volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO„ 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 For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 23. Federal regulatory program requirements (i.e. PSD, NANSR orTitleV 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 24. 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: 123/9909 Page 5 of 10 blic Health and Environment it Pollution Control Division 25. If this permit spe'citi st® h -utp i4et r3 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 IH.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. 26. 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. 27. 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. 28. 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. 29. 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. 30. 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: Stephanie Chaousy, PE Permit Engineer Air Pollution Control Division Permit History Issuance Date Description AIRS ID: 123/9909 Page 6 of 10 Issuance 1 blia'Health and Environment it Pollution Control Division Permit for ") enclosed flare and associated fugitives. New synthetic minor source facility. AIRS ID: 123/9909 Page 7 of 10 Colorrc Depa :men if F `blic Health and Environment ;Air Pollution Control Division Notes to Permit Holder the -time oftthis permifiss' lance. 1) 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. 2) 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: http://wwwcdphe.state.co.us/regulations/airregs/100102aacccom monprovisionsreq.pdf. 3) The emission levels contained in this permit are based on the following emission factors: Point 002: CAS # Pollutant Emission Factors Uncontrolled Emission Factors Controlled Source NOx 0.068 lb/MMBtu 0.068 lb/MMBtu AP -42, Table 13.5-1 CO 0.37 lb/MMBtu 0.37 lb/MMBtu AP -42, Table 13.5-1 VOC 35.82 lb/MCF 1.7910 lb/MCF Engineering Calculation Note: The control led emissions factors for point 002 are based on the flare control efficiency of 95%. Point 005: Component Gas Service Heavy Oil Light Oil Oil Service Connectors --- --- --- --- Flanges 55 --- 6 --- Open-Ended Lines --- --- --- --- Pump Seals 10 --- 3 -- Valves 50 --- 5 --- Other 13 --- 3 --- VOC Content (wt%) 47.18% --- 100% --- Benzene Content (wt%) --- --- --- --- Toluene Content (wt%) --- --- --- --- Ethylbenzene (wt %) --- --- --- --- Xylenes Content (wt%) --- --- --- --- n-hexane Content (wt%) --- --- --- --- *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 SWater/Oil ervi Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 AIRS ID: 123/9909 Page 8 of 10 Health and Environment it Pollution Control Division Flanges F y 3f,1 -04.A1. --.ID 3 E 3, em1 `45E-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. 4) 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. 5) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source: VOC NANSR Synthetic Minor Source: VOC MACT HH Area Source Requirements: Not Applicable 6) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN -- Subpart XXXXXX AIRS ID: 123/9909 Page 9 of 10 4ColonU Depagine blic Health and Environment '1 FH sir Pollution Control Division 7) An Oil and Gas Indu truptianaPterknit Self C&rk)fication 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://wwwcdphe.state.co. us/ap/oilaasperm ittinq. him! AIRS ID: 123/9909 Page 10 of 10 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Chesapeake Operating, Inc. Permit Number: 12WE1874 Source Location: 524, T8N, R67W, Weld County (non -attainment) Equipment Description Point 002: Plant flare with a minimum combustion efficiency of 95%. Point 003: Fugitive emissions AIRS ID: 123-9910 Date: September 24, 2012 Review Engineer: Stephanie Chaousy, RE. Control Engineer: Chris Laplante Section 2 — Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt `If tank is a true minor source at a true minor facility, it shal be granted "Final Approval" 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? Yes X 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? 8/15/12: I emailed the Operator for the gas analysis used in the fugitive and flare calculations. RACT for fugitives was agreed on for another project. I received a correct gas analysis On 10/25/12. Received new calculations on 12/21/12 for VOC emissions (including separator emissions) On what date was this application complete? May 23, 2012 Section 4 —Source Description AIRS Point Equipment Description 002 Plant flare used to control gas stream off of a 3 -phase separator. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. 003 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? PM10 CO Ozone Page 1 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 IIl.D.2) PM,o 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 Section 5 — Emission Estimate Information AIRS Point Emission Factor Source 002 AP -42, Table 13.5-1 for combustion; mass balance for separator VOC 003 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 (PTE) AIRS Point Process Consumption/Throughput/Production 002 10426 MCF/yr 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 --- 6 --- Open -Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- Basis for Actual Emissions Reported During this APEN Filing (Reported to lnventorvi AIRS Point Process Consumption/Throughput/Production Data Year 002 10426 MCF/yr 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) - Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 --- 6 --- Open -Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 002 10426 MCF/yr 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 --- 6 --- Open -Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- Does this facility use control devices? X Yes No Page 2 AIRS Point Process Control Device Description Reduction Granted 002 01 Flare 95 Section 6 — Emission Summary (tons per year) Point NO„ VOC CO SOx PM10 Single HAP Total HAP PTE: 001 2.0 0.1 1.1 --- "' 0.08 (formaldehyde) 0.1 002 1.3 97.3 7.0 --- --- --- -- 003 --- 2.0 --- --- 004 2.7 54.0 14.9 --- --- 0.8 (n -hexane) 0.9 005 --- 2.6 --- --- --- 0.2 (n -hexane) 0.3 Uncontrolled point source emission rate: 001 2.0 0.1 1.1 --- -__ 0.08 (formaldehyde) 0.1 002 1.3 97.3 7.0 --- - 003 --- 2.0 --- --- --- --- --- 004 2.7 45.0 14.9 --- --- 0.7 (n -hexane) 0.8 005 --- 2.2 --- --- --- 0.2 (n -hexane) 0.2 TOTAL (TPY) 6.0 146.6 23.0 --- --- 0.9 (n -hexane) 1.1 Controlled point source emission rate: 001 2.0 0.1 1.1 --- "' 0.08 (formaldehyde) 0.1 002 1.3 7.4 7.0 --- --- --- --- 003 --- 2.0 --- --- --- -- --- 004 2.7 39 14.9 --- -- 0.03 (n -hexane) 0.04 005 --- 10 --- --- --- 0.01 (n -hexane) 0.01 INSIGNIFICANTS (TPY) 0.2 0.4 0.2 --- --- -- --- TOTAL PERMITTED (TPY) 6.0 58.5 23.0 ___ __ 0.08 (formaldehyde) 0.15 Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 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 standard? X Yes No If "yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 002 01 VOC, HAPS State only requirement Site -specific gas analysis 003 01 VOC, HAPS State only requirement Site -specific gas analysis 003 01 VOC, HAPS State only requirement Hard component count Page 3 Section 9 — Source Classification Is this.a new previously un-permitted source? Yes No Point 002: Flare X Point 003: Fugitives X What is this facility classification? True Minor X Synthetic Minor Major Classification relates to what programs? X Title V PSD X NA NSR 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 X No If "yes", for which pollutants? Why? For Reg. 3, Part B, IlI.C.1.a (controlled 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)? Yes X No If "yes", for which pollutants? Why? NOx emissions are less than 40 TPY. AIRS Point Section 12 — Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 002, 003 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 2 — Odor 002, 003 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. Page 4 Regulatiort 3 - APENs. Consfructiori Permits, Operating Pen its, PSI '>• 002, 003 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 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 from production exceed 1 ton per year VOC) 002, 003 Part B — Construction Permit Exemptions Applicant is required to file a permit since uncontrolled VOC emissions are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section II.D.2.a) Regulation 6 - Nevi/Source Performance Standards 002 None 003 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). Is this source at a "natural gas processing plant?" No Is this source subject to NSPS KKK? No WHY? Facility not defined as a natural gas processing plant, therefore, does not meet the criteria of NSPS KKK. Regulation 7 -Volatile Organic Compounds 002 None 003 Section XII.G: If facility is a natural gas processing plant located in non -attainment area, then subject to Section XII.G. Facility is not a natural gas processing plant, therefore, not subject to Section XII.G. Regulation 8 - Hazardous Air Pollutants 002 None 003 MACT HH: If facility is MAJOR source for HAP (summation of HAPS of dehydrators and fugitives), then fugitive emissions are subject to MACT HH. Is this facility considered MAJOR for HAPS? No Is this source subject to MACT HH? No WHY? Facility is area source for MACT HH, therefore, only TEG dehydrators are subject to MACT HH. This facility has no TEG dehydrators, so facility not subject to MACT HH. Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Factor Pollutant / CAS # Fugitive (Y/N) Emission Factor Source Control (%) 002 01 18.67 lb/MCF VOC No Engineering Calculation 95 Flare 0.068 Ib/MMBtu NOx No AP -42, Table 13.5-1 NA 0.37 Ib/MMBtu CO No AP -42, Table 13.5-1 NA SCC 31000205 -Flares 003 01 Fugitive VOC Leak Emissions VOC Yes EPA -453/R-95-017, Table 2-4 NA SCC 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Page 5 Section 14 — Miscellaneous Application Notes AIRS Point 002 Flare Permit issued because emissions are greater 5 TPY CO (Reg. 3, Part B, Section II.D.3.e). VOC, NOx and CO (from AP -42, Chapter 13, Table 13.5-1 (NOx = 0.068 lb/mmbtu; CO = 0.37 lb/mmbtu; VOC = 0.14 lb/mmbtu) Operator did not include associated gas analysis with the application. I emailed the Operator on 8/15/12 for the gas analysis. Gas analysis showed no BTEX. Original VOC calculations did not include emissions from the separator. Received new calculations on 12/21/12 and generated a new VOC emission factor to account for "associated gas" emissions that will be controlled. VOC = (97.32 TPY * 2000)/10426 = 18.67 lb/MCF AIRS Point 003 Fugitive emissions A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit threshold). Operator did not include associated gas analysis with the application.' I emailed the Operator on 8/8/12 for the gas analysis. I received a gas analysis on 8/28/12. Turns out, Operator provided me the wrong gas analysis (not the one used for calculations). Was provided new gas analysis by consultant on 10/25/12. The new gas analysis matched what was on the APEN under VOC wt%. Gas analysis showed no BTEX. I calculated fugitives based on their APEN. Their calculation sheet showed that they used the same emission factor for GAS -compressor seals and GAS -relief valves (even though compressor seals are on the APEN as GAS -pump seals and the relief valves are listed as GAS -Other). Operator used the emission factor for GAS -Other for all sources. I calculated it both ways, and did not get a big difference in emissions, so I will agree with the Operator's calculation of 2.0 TPY VOC. Page 6 STATE OF COLORADO zahn COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: DATE ISSUED: ISSUED TO: 12WE1874 Chesapeake Operating, Inc. Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as Lindstrom 24-8-67 1H, located in Section 24, Township 8 North, Range 67 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description FLARE2 002 Plant flare used to control gas stream off of a 3 -phase separator. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. FUG1 003 Equipment leaks (fugitive VOCs) from an oil and gas 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. YOU MUST notify the APCD no later than fifteen days after issuance of this permit or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at wvvw.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the APCD of startup of the permitted source is a violation of AQCC Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. 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). 3. 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 AIRS ID: 123/9910 Page 1 of 10 Condensate Tank Version 2009-1 I-- application assn iatedwit, p rpLt,4(p) di continues cons, r-ction for a 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.) 4. 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.) 5. 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. (blic Health and Environment it Pollution Control Division EMISSION LIMITATIONS AND RECORDS 6. 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 yp NO, VOC CO FLARE2 002 1.1 7.4 7.0 Point FUG1 003 --- 2.0 --- Fugitive See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate limits. 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. Point 003: 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. PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Monthly records of the actual throughput 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 FLARE2 002 Natural qas flaring 10,426 MCF/yr AIRS ID: 123/9910 Page 2 of 10 ,Color Depatlner; 'f bile Health and Environment Air Pollution Control Division Compliance wtt t nnual`tt1,ro gltp linftts'shall be det ' ed on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review: STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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) 10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.) 11. 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.). 12. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. Point 003: 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 for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). The requirements of condition number 14 below were determined to be RACT for this source. 14. Point 003: 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 satisfythe requirement to apply RACT. (i) For leak screening, auditory/visual/olfactory inspection (AVO) will be performed on a quarterly basis. (ii) For each leak found in the AVO inspection, a gas detector shall 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. 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 to determine if the leak is repaired. AIRS ID: 123/9910 Page 3 of 10 blidHealth and Environment Air Pollution Control Division (v) wi0g recoYds4all b ned 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. • Dates of the AVO screenings, gas 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 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. Point 002: The operator shall complete an initial site specific extended gas analysis of the natural gas produced at this site that is routed to the enclosed flare 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. 17. Point 002: The owner or operator shall demonstrate compliance with Condition 10 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5). 18. Point 003: 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. 19. Point 003: 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 AIRS ID: 123/9910 Page 4 of 10 20. Point 002: The ®" or operator's heat content on an annual basis. Depa:1nen, f Fbli Health and Environment rj.Air Pollution Control Division e-tI3 gas ro �tp the flare to determine the 21. Point 003: On an annual basis, the owner or operator shall complete an extended gas analysis of produced gas that is 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 22. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. 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 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 For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 23. 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 24. 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: 123/9910 Page 5 of 10 blicsHealth and Environment it Pollution Control Division 25. If this permit sppciftoaihy statesuthr %authorzation has beep;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. 26. 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. 27. 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. 28. 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 maybe 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. 29. 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. 30. 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: Stephanie Chaousy, PE Permit Engineer Air Pollution Control Division Permit History Issuance Date Description AIRS ID: 123/9910 Page 6 of 10 Issuance 1 his 7Color ; Depa bli&Health and Environment it Pollution Control Division Perm t$ o ) enciditcl flare and associated fugitives. New true minor source facility. AIRS ID: 123/9910 Page 7 of 10 7,737 epat4neri•t.of F;:lbli Health and Environment ;t,_.. I it Pollution Control Division Notes to Permit Holderhe of Bran 1) 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. 2) 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 1I.E.1 of the Common Provisions Regulation. See: http://www.cdphe.state.co.us/regulations/airregs/100102agcccommonprovisionsreq. ndf. 3) The emission levels contained in this permit are based on the following emission factors: Point 002: CAS # Pollutant Emission Factors Uncontrolled Emission Factors Controlled Source NOx 0.068 lb/MMBtu --- Engineering Calculation CO 0.37 lb/MMBtu --- AP -42, Table 13.5-1 VOC 18.67 lb/MCF 0.9335 lb/MCF AP -42, Table 13,5-1 Note: The controlled emissions factors for point 002 are based on the flare control efficiency of 95%. Point 005: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors --- --- --- --- Flanges 55 --- 6 --- Open-Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- VOC Content (wt%) 29.92% --- 100% --- Benzene Content (wt%) --- --- --- --- Toluene Content (wt%) --- --- --- --- Ethylbenzene (wt %) --- --- --- --- Xylenes Content (wt%) --- --- --- --- n-hexane Content (wt%) --- --- --- --- *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 OilWater/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 AIRS ID: 123/9910 Page 8 of 10 Depa 4 en. 1bileHealth and Environment it Pollution Control Division bn; Flanges d, 3c4=04 S AC:, 3 E 07 1 E-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 V0C content from the most recent gas and liquids analyses. 4) 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. 5) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source: VOC NANSR Synthetic Minor Source: VOC MACT HH Area Source Requirements: Not Applicable 6) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http:/%ecfr.gnoaccess.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 AIRS ID: 123/9910 Page 9 of 10 !blicHealth and Environment A•ir Pollution Control Division ff 1 7) An Oil and Gas IndustryGg tru Per i If-gt4ficatrgn Form ds 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.cd phe.stateco. us/ap/oil gasperm ittinq. htm I AIRS ID: 123/9910 Page 10 of 10 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Chesapeake Operating, Inc. Permit Number: 12WE1875 Source Location: $36, T7N, R62W, Weld County (non -attainment) Equipment Description Point 002: Plant flare with a minimum combustion efficiency of 95%. Point 003: Fugitive emissions AIRS ID: 123-9911 Date: September 24, 2012 Review Engineer: Stephanie Chaousy, P.E. Control Engineer: Chris Laplante Section 2 — Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt *If tank is a true minor source at a true minor facility, it shall be granted "Final Approval" 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? Yes X 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? 8/15/12: I emailed the Operator for the gas analysis used in the fugitive and flare calculations. RACT for fugitives was agreed on for another project. I received a correct gas analysis on 10/25/12. Received new calculations on 12/21/12 for VOC emissions (including separator emissions) On what date was this application complete? May 23, 2012 Section 4 —Source Description AIRS Point Equipment Description 002 Plant flare used to control gas stream off of a 3 -phase separator. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. 003 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? PM10 CO Ozone Is this location in an attainment maintenance area for any criteria pollutant? Yes X No Page 1 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 Section 5 — Emission Estimate Information AIRS Point Emission Factor Source 002 AP -42, Table 13.5-1 for combustion; mass balance for separator VOC 003 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 (PTE) AIRS Point Process ConsumptionlThroughput/Production 002 19809 MCF/yr 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 --- 6 --- Open -Ended Lines --- Pump Seals 10 --- 3 -- Valves 50 --- 5 --- Other 13 --- 3 --- Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 002 19809 MCF/yr 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 --- 6 --- Open -Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 002 19809 MCF/yr 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 --- 6 --- Open -Ended Lines --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- Does this facility use control devices? X Yes No AIRS Point Process Control Device Description % Reduction Granted Page 2 002 01 Flare 95 Section 6 — Emission Summary (tons per year) Point NO,VOC CO SOx PM10 Single HAP Total HAP PTE: 001 2.0 0.1 1.1 --- --- 0'08 (formaldehyde) 0.1 002 1.7 192.7 9.1 --- --- --- --- 003 --- 2.0 --- --- --- --- --- 004 2,7 90.0 14.9 --- --- 1.4 (n -hexane) 1.5 005 --- 5.2 --- --- --- 0.4 (n -hexane) 0.6 Uncontrolled point source emission rate: 001 2.0 0.1 1.1 --- --- 0'08 (formaldehyde) 0.1 002 1.7 192.7 9.1 --- - - - 003 --- 2.0 -- --- --- --- -- 004 2.7 75.0 14.9 -- -- 1.1 (n -hexane) 1.3 005 --- 4.3 --- -- --- 0.4 (n -hexane) 0.5 TOTAL (TPY) 6.4 274.1 25.1 --- --- 1.5 (n -hexane) 1.9 Controlled point source emission rate: 001 2.0 0.1 1.1 --- --- 0'08 (formaldehyde) 0.1 002 1.7 12.9 9.1 --- --- --- -- 003 -- 2.0 -- - --- --- --- 004 2.7 39 14.9 -- --- 0.06 (n -hexane) 0.06 005 --- 10 --- -- --- 0.02 (n -hexane) 0.02 INSIGNIFICANTS (TPY) 0.2 0.4 0,2 --- --- --- -- TOTAL PERMITTED (TPY) 6.4 64.0 25.1 - ___ 0.08 (n- hexane) 0.2 Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 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 standard? X Yes No If "yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 002 01 VOC, HAPS State only requirement Site -specific gas analysis 003 01 VOC, HAPS State only requirement Site -specific gas analysis 003 01 VOC, HAPS State only requirement Hard component count Page 3 Section 9 — Source Classification Is this a new previously un-permitted source? Yes No Point 002: Flare X Point 003: Fugitives X What is this facility classification? True Minor X Synthetic Minor Major Classification relates to what programs? X Title V PSD X NA NSR 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 (controlled 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? NOx emissions are less than 40 TPY. Yes X No AIRS Point Section 12 — Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 002, 003 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 2 - Odor 002, 003 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. Page 4 Regulation 3'-APENS, Construction Permits,Operating.Permits, PSD" 002, 003 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 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 from production exceed 1 ton per year VOC) 002, 003 Part B — Construction Permit Exemptions Applicant is required to file a permit since uncontrolled VOC emissions are greater than the 2,0 TPY threshold (Reg. 3, Part B, Section 11.D.2.a) Regulation 6 - New Source Performance Standards 002 None 003 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). Is this source at a "natural gas processing plant?" No Is this source subject to NSPS KKK? No - WHY? Facility not defined as a natural gas processing plant, therefore, does not meet the criteria of NSPS KKK. .Regulation -T- Volatile Organic Compounds 2 002 None 003 Section XII.G: If facility is a natural gas processing plant located in non -attainment area, then subject to Section XII.G. Facility is not a natural gas processing plant, therefore, not subject to Section XII.G. Regulation'8 - Hazardous, Air. Pollutants 002 None 003 MACT HH: If facility is MAJOR source for HAP (summation of HAPS of dehydrators and fugitives), then fugitive emissions are subject to MACT HH. Is this facility considered MAJOR for HAPS? No Is this source subject to MACT HH? No WHY? Facility is area source for MACT HH, therefore, only TEG dehydrators are subject to MACT HH. This facility has no TEG dehydrators, so facility not subject to MACT HH. Section 13 — Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Factor Pollutant/ CAS # Fugitive (Y/N) Emission Factor Source Control (%) 002 01 19.46 lb/MCF V0C No Engineering Calculation 93.3 Flare 0.068 lb/MMBtu N0x No AP -42, Table 13.5-1 NA 0.37 Ib/MMBtu CO No AP -42, Table 13.5-1 NA SCC 31000205 -Flares 003 01 Fugitive V0C Leak Emissions V0C Yes EPA -453/R-95-017, Table 2-4 NA SCC 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Page 5 Section 14 — Miscellaneous Application Notes AIRS Point 002 Flare Permit issued because emissions are greater 5 TPY CO (Reg. 3, Part B, Section II.D.3.e). VOC, NOx and CO (from AP -42, Chapter 13, Table 13.5-1 (NOx = 0.068 lb/mmbtu; CO = 0.37 lb/mmbtu; VOC = 0.14 lb/mmbtu) Operator did not include associated gas analysis with the application. I emailed the Operator on 8/15/12 for the gas analysis. Gas analysis showed no BTEX. Original VOC calculations did not include emissions from the separator. Received new calculations on 12/21/12 and generated a new VOC emission factor to account for "associated gas" emissions that will be controlled: VOC = (192.71 * 2000 /19809 = 19.46 lb/MCF AIRS Point 003 Fugitive emissions A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit threshold). Operator did not include associated gas analysis with the application. I emailed the Operator on 8/8/12 for the gas analysis. I received a gas analysis on 8/28/12. Turns out, Operator provided me the wrong gas analysis (not the one used for calculations). Was provided new gas analysis by consultant on 10/25/12. The new gas analysis matched what was on the APEN under VOC wt%. Gas analysis showed no BTEX. I calculated fugitives based on their APEN. Their calculation sheet showed that they used the same emission factor for GAS -compressor seals and GAS -relief valves (even though compressor seals are on the APEN as GAS -pump seals and the relief valves are listed as GAS -Other). Operator used the emission factor for GAS -Other for all sources. I calculated it both ways, and did not get a big difference in emissions, so I will agree with the Operator's calculation of 2.0 TPY VOC. Page 6 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 12WE1875 875 DATE ISSUED: ISSUED TO: Chesapeake Operating, Inc. Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as State 7-62 36-1H, located in Section 36, Township 7 North, Range 62 West, in Weld County, Colorado. T Facility Equipment ID AIRS Point Description FLARE2 002 Plant flare used to control gas stream off of a 3 -phase separator. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. FUG1 003 Equipment leaks (fugitive VOCs) from an oil and gas 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. YOU MUST notify the APCD no later than fifteen days after issuance of this permit or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at wwrw.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the APCD of startup of the permitted source is a violation of AQCC Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. 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). 3. 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 AIRS ID: 123/9911 Page 1 of 10 Condensate Tank Version 2009-1 bli&1Health and Environment it Pollution Control Division application associated with this pe, , lii) digopts u,,,es con _ Lion for a 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.) 4. 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.) 5. 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 6. 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 FLARE2 002 1.7 12.9 9.1 Point FUG1 003 --- 2.0 --- Fugitive See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate limits. 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. Point 003: 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. PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Monthly records of the actual throughput 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 FLARE2 002 Natural gas flaring 19,809 MCF/yr AIRS ID: 123/9911 Page 2 of 10 Health and Environment it Pollution Control Division Compliance wjalu, n - rd'+ t li -Yaffe deter_ eed on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. 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) 9. 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.) 10. 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.). 11. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. Point 003: 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 for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). The requirements of condition number 14 below were determined to be RACT for this source. 13. Point 003: 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) For leak screening, auditory/visual/olfactory inspection (AVO) will be performed on a quarterly basis. (ii) For each leak found in the AVO inspection, a gas detector shall 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. 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. (iii) 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 to determine if the leak is repaired. AIRS ID: 123/9911 Page 3 of 10 blicPHealth and Environment it Pollution Control Division (v) l fj Y wit® ,c all ?tried foria:.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. • Dates of the AVO screenings, gas 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 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. Point 002: The operator shall complete an initial site specific extended gas analysis of the natural gas produced at this site that is routed to the enclosed flare 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. 16. Point 002: The owner or operator shall demonstrate compliance with Condition 10 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5). 17. Point 003: 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. 18. Point 003: 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 componentsthat 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 AIRS ID: 123/9911 Page 4 of 10 ri blicHealth and Environment Air Pollution Control Division 19. Point 002: Th .K-t1e or heat content on an annual basis. 20. Point 003: On an annual basis, the owner or operator shall complete an extended gas analysis of produced gas that is 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. as roulaltp the flare to determine the ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, 'LC) a. 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 volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of V0C or NO„ 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 For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the. existing APEN expires. 22. 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 23. 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: 123/9911 Page 5 of 10 en! f FF tblie Health and Environment Air Pollution Control Division ( 24. If this permit sp ut;�zati'dn 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. 25. 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. 26. 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. 27. 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. 28. 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. 29. 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: Stephanie Chaousy, PE Permit Engineer Air Pollution Control Division Permit History Issuance Date Description AIRS ID: 123/9911 Page 6 of 10 blkPHealth and Environment it Pollution Control Division Issuance 1 This Issnc Per") encto`s"bci flare and associated fugitives. New synthetic minor source facility. AIRS ID: 123/9911 Page 7 of 10 r, ti ... Notes to Permit Holder at the -t me oftf is=perMifiss0anc Depa en. -167f F7lblie Health and Environment Air Pollution Control Division ii 1) 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. 2) 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: http://www.cdphe.state.co.us/regulations/airregs/100102acicccommonprovisionsreg.pdf. 3) The emission levels contained in this permit are based on the following emission factors: Point 002: CAS # Pollutant Emission Factors Uncontrolled Emission Factors Controlled Source NOx 0.068 lb/MMBtu 0.068 lb/MMBtu AP -42, Table 13.5-1 CO 0.37 lb/MMBtu 0.37 lb/MMBtu AP -42, Table 13.5-1 VOC 19.46 lb/MCF 0.9728 lb/MCF Engineering Calculation Note: The controlled emissions factors for point 002 are based on the flare control efficiency of 95%. Point 003: Component Gas Service Heavy Oil Light Oil il Service Connectors --- --- --- --- Flanges 55 --- 6 --- Open-Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- VOC Content (wt%) 30.73% --- 100% --- Benzene Content (wt%) --- --- --- --- Toluene Content (wt%) --- --- --- --- Ethylbenzene (wt %) --- --- --- --- Xylenes Content (wt%) --- --- --- --- n-hexane Content (wt%) --- --- --- --- *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 Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 AIRS ID: 123/9911 Page 8of10 blicHealth and Environment it Pollution Control Division Flanges casza 3c9 14 rte-:. 3fi 0i 9-:z1E-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. 4) 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. 5) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source: VOC NANSR Synthetic Minor Source: VOC MACT HH Area Source Requirements: Not Applicable 6) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gnoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX AIRS ID: 123/9911 Page 9 of 10 Color' Depaf cerf bli Health and Environment Air Pollution Control Division 7) An Oil and Gas Indr gtr G tru e Fig elf -G 'N Form :) eluded 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. cd phe.state. co. us/ap/oilqasperm fitting: htm I AIRS ID: 123/9911 Page 10 of 10 N M O O onent Leak Emissions a U Lam. 0 R d C) C) 0 e. 1.d C 0 C) y CC W 3 N iTl al o 2. 0 E . 0 z e? C, CC Section 02 — Re C 0 w E W C d 5 C O C 0 U o s_ Cs O. T 0 ❑ O O RU d o, W 0 0 % _ 0 P.,, W C .0 >-. 0 0 c o u O. O .. EO 0 CC 0 0, 0 w d U 0 L O s O o P •E0 = ea L CC X �.,, 0 Gt.t❑ ❑ d = c 7 T U O sd 0 r m >, .N 2 o 3 ',' g d d c E fi CC 0 CI o z ¢ e, ro z o o 0 U w E F. o f >' .0 m Q o N Q' a a" R U m O P. 0, Y Z O 0 o z o 0 o E W .y id' 't L 0 C y ; . e.a. C o a U U 0 CC C S P A a ' ❑ ❑ a a ❑ ❑ o r'a o °1 -,e' ,.5.C.- Chesapeake Operating, Inc. Girard 2-63 11-111 ai z z 0 m G4 8 E OD U N u r 3 o o ir 44 w h fel r o U P.O. Box 18496 Oklahoma City, OK (405) 935-2017 Phone Number: CC 0 L 0 CC 0 0 ti Person To Contact: j eff. fingers on@chk.com E-mail Address: Section 03 — General Information 0 CC U o.0 C oen m Gca 0 O N y O E P C1 o o P 0up 0 w C 0 oN o 0 0 0 P .y x k `C C °z y. m JrC-VE \` rC' O m w' Gl " 2 3 20i2 M M CI M ye z d o w 0 N\ ICJ /01 0 a U L d� \ CC , .ry IO ,O ,O b W q 'O U 'C. M m t1 O -� CZ o 0 o P Y o .0, `' O1 'c w Cn 40, C a 1 C o P. 0 CO 0 ri W Z.. CC 0 •i A N N y1 W ¢ J x A C] N U L '5 ¢. w0 td. 3 0 =x = P c - O U v Oq C R= V� a 0.. 15 E ^ 4 c •3 c el, ,iaAw o 0 a' .d T a a E u ,4'o o Xo. " d L• - ;. L L N o 0 N 0 >4^..a 2 =. U© 0 U -0,9, 0 0ggwt'o 8 oG `o C0 ao� CC U m .a a o ,e = O -0 CQ 0 f" U = o q t e C t0 0, 5 .- .h', a 0 c..).-.,errNCC O 41 he.state.co.usia 3 0 iri a 0P. 0 5 U a U 0 N O 0 C = vn a F O; -a 3 = a z Section 04 — Re ❑ ❑ Is this equipment subject to NSPS 40 CFR Part 60, Subpa ti 40 CFR Part 63, Subpart ripment Subpart that applies to this equipment: List any other NSPS or NES Section 05 -Stream Constituents P 0 .0 0 a 0 0 0 0 A. P. b 00 P. P. 0 0 en 0 0 1D • O 0 ,0 .0 WI .0 .0 0 U ❑❑ n-llexane (wt. %) Xylene (wt. %) Ethylbenzene (wt. %) 0 r-, C SC CC H '5 Benzene (wt. %) U a o'• 9; ' r- .. M , o o CC rHeavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil FORM APCD-203 123-9903-003-APEN-2012-05-23-01 GU ti tl 4.1 d a 0 O U rl 0 O U W tJ O tJ W con 1F �Y Fa rrl F Fa F py Emission Source AIRS ID: Section 07 —Leak Detection & R m 0 cd a 0. C a b O • .0 O .4- 5 0 H c O t O C O U CID 0 E 0 4- ti w y m i N - a O O U 0 Q m A o0 L 6 78 0 0 o V 0. 0 No LDAR program LDAR per NSPS cn CC 01 00 N 00 0 4- ] N.o N ¢ z O W 4- L et W 0 Ca a Ga 00 O U m a u a` a 0 0 7 bp `o a .O c W 0 d O v •R u =19 otcg a a d O 3 ea 0 U Ca C V e e z ¢ z ¢ z z ¢ z ¢ z ¢ z Q z ¢ z Q z a z z ¢ z ¢ z ¢ z Q z a" z" 0 u z G 0 t E O u z r 00 N a 0 a e e a 0 U ea v en N en 3 u 2 0 E Estimated Count z vi 'z 'z O a O CC O F O. O u i. ,.o CC O i z alee 00 0 0 0 N e 0 0 CO 0 in 0 in M 0 tto Open -Ended Lines To 0 a F" ea O Emission Factor Documentation attached El a 00 a 9 s 0cr w W z z z e r RF/�ni.. 'z z a o ca C. O z z z 0 a w 0 0 Ii 'z Q w ea T U' o O o 0'2 'g0 w0 0 U W o Control Device Description 0 0I 0 0 N U o z C z 0 O 0 0 .0 z C 0 '0 K L a w E 4.4 V 0 o 0 cesg m c�LL� wo u ._C a O r" s O 0 C o y 3 G I a O CJ yr C O o 5 C. .CC ECO o z w w is 3 Ti 1 w a w a 0 L 0 O• g y .0 0 o a • R ., 0 • O O 9 O a C • 0. C El $ 0 m v C? wE N O F N O 00g • I . a E w LO. a C _ g t w 81 0 O N T O U va 0 L 2 o d O a Zti) 0 m O O O • F C O U -E • a O N _a U ' v'2 C C 4 o o m O. h Q O. ? O E '-I G g O C cc 0 ation con W C C CO U L y 0 y N O N 0 a e s co 3 tj Section 02 — Re Section 01 —Administrative Information tri Chesapeake Operating, Inc.. Company Name: •-I an ae L 0. G It F .0 C S' U A d u 5 L V C cuo O d x d a Secll-T2N-R63W Change company n 111 Change fuel or equipment ❑ L O Transfer of ownership Change permit limit 0y 0 O Z a O ZI 0 8VO, a 5F, 0 2 1 - 0 N v an 0 U a N P.O. Box 18496 It (405) 935-2017 Phone Number: Oklahoma City, OK 73154 Person To Contact: 7 (405) 849-2017 z I Section 03 — General Information 0 0 0 0 d U YL O 0 0 0 C O w yt In 0 0 o Se 0 0 0 O g 0 U 8� w O O bi 00 yx x w 0 8' p. C E a C O c 0 0. 0 C r � 0 0/ 0 / R'' C`'''':::::2.'",\\0 ._' io�� am „ �.N- / n nw o\"\` ' i sr�.w J \ .��. b l0 i .0 N y \"On 0 Merlin O G O O O ', 0 '.. ‘CLL u L C in in 0 U w i C v . 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U '� O 9 0 n' I, C -, O U p 0 0.0 aai :^.00h t Li s' . 0 C'„ m'°' i qU a o, 0, ^_ U c > m a, m ['L. 0� z' U Po ti *.4in 0 C o 0'•t Z 9 G 0 p.0 0 6 .0 N 7 'U -5 3 re Manufacturin Section 04—Processin Description of equipment': Manufacturer: o o 0 2 y O It U 0- a in z d zz Q zz zz 'z z • 0 • ti L h d O O 0 0 a qa C C • o. d F •a �o O 0 O O y Y N • 0' O 0 o • ? .0 C.) 0 U U ❑ ❑ 123-9903-002—APEN-2012-05-23-01 0 • N > ' 0 o 0 0 G 00 cy m 'Requested values will become pe FORM APCD-200 Tit ED co Ili d Q V L 0 C U kC C Ca z U H y® F m4 o a z E M Emission Source AIRS ID: 0 0 ro 0 0. .C� a) O 0 10, N U et ca H O H aN0 c\ 00 r C r 00 Q C o " M CO C - e 0 N z Lion Information ment & Fuel Consum Section 06 — Combustion E 0 Model: N/A oa Manufacturer: N Company equipment Identification No.: A 0 N A m 3 A a) e a r z -0 d -0z a `.13 e PI r4.3 PI e N v a ) Ca T w C 0 to O U O 0 Ca a 0 0 et o c 0 0 E 0 A 4- ae N C H H G Co O 0 CJ v6)O4 a FA zz Q z a zz Q zz V r y a ea use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. 3 Annual emission fees will be based on actual emissions reported here tflefl hian4 - Requested Permitted Emissions" Uncontrolled Controlled (Tnns/Year) tTnno/Nr<....\ ,r ��-Ct J '/� 7 �`v d d d a G c z z Z z N, m _6 N/A I M d z a z 'z .-1 z d z • y.. "mow tnrougnput above (e.g. 2007): j Emission Factor Actual Calendar Year Emissions' Uncontrolled Uncontrolled Controlled Basis Units (Tons/Year) (Tons/Year) Q d - Q, a o z z 4 4 0.1 4 , N a a .2; a 2; a 2; a 2; 2;' a 9y d E d d y c = .0 A L a Z Q 'z N/A a Z. 'S_ a o o Control Efficiency (% Reduction) a z a z a z a z a z a z a Overall. Collection Efficiency z d z d z a z z d.d z 'z Control Device Description Secondary a z d d--.5. zz a z zz a z a1 z z z z z z z z Pollutant n �+ p O p O H4.acnz>U ea Q C C, o A 0 of a) o a a. O C ao O Y °N 0 0 E 0 w �r O 0 Ca u O 0 0 d 0 U o.9 C u ›, 0 a hp s. x v .E w a 5 ° s.,o g 0 4 0 y ti u _ o O' io N.Z N q2 A ;t 0 0 0 \ a u C N '� E \�^O O ,N Q U tU -c -t ctie U s U .0 a CC d O 0 0 m Cl N hq a N C t0} 0 Co Co Li 3 N N nested Action (check applicable request boxes) Section 01 — Administrative Information -O c C at R ❑0 �- >0 0 0 o c o az)Y y c C m Po A' 'F O u CI L O C g .' N F - C 'O^ ^ y lr 0 A E E 0 @ L 0 ❑ ❑ L y T ^O y 1 nC O rUn �l O o ®❑❑ ❑❑ ¢zo Chesapeake Operating, Inc. State 8-60 16-114 z z C 0 0. U P.O. Box 18496 -c N Oklahoma City, OK 7315 0 an a Phone Number: Person To Contact: jeff.ingerson@chk.com E-mail Address: r c For new or reconstructed sources, the projected st Section 03 — General Information c z '0 0 0 tin p O 471 C `° o a 0 O d a o b o 0 0 a .C a A 0' 0 0 a •a ro ci C W l� .8O �, 0 mein O c o 0 0 o i=1 i A^ y L m C O d m t.'." g q 0 �o C C "Fa O b) o r i z• 0 O 0 7 A ty N FA Z a01 r A C o id ¢ rn v � .L, m 3 . v x+ _ 8 ., of w e T o ft u z — go l to ~ oU ��'• o cMc. P. ow o5. n0 t 0 o 'V O •y M O Q m S _ c 0 A Mtn O 0 p O 0 0. y Oin V in P Z 0 v n m cn F •— C C" W 0 N N N O a� o x •n O, , L = cn 0 U 0 .. w rn N 4J C m 4. c9, .d o_O G fi d o b" a r A d ≥ 00 E 02 O U0 1 ti p c R " 0 O SO 0 cn i Q U O .r,.J`03 C.1� >.' C 0.. w 0 cn O U o. C '.O �, c575 Oy 4'q .0L'0^� 4o.' U N Y 00i — C A o t 00 P+. • o pa - -n o `p aw, o c 5 CWy a F o f /� U �4 Q A Po Q an Q ❑❑ O -o z z v N 0 C o F 00C aE meat Information & Material Use CC /Manufacturin Section 04 — Processin C 0, •o 0 0 0 0 O x o CC mt U N d R Cn zz z N an 0 d zz z z 0 Manufacturer: N/A d zz zz z z C ted level should FORM APCD-200 0 4) O U e Q L / ..c601 4 o ; U coo O oC4 C '4 aS .N h n Release Information (Attach a separate sh o N 40.667845 y 0 0 CC' 0 0 zz Ecn A _ z O N _N O 5. M 0 0 ti M a m 0w_ Q z tion Information z z Manufacturer: Natco Company equipment Iden � N S W O ' 03 W 0 a 0 0 00 0 a. ti on N ea 0 0 q N 0 N 0 3 .o s 1,020 Btu/SCF Q zz a a O F> Natural Gas 0 0 R E t. 11 it a 0 0 021 0 O O L r0. N 0 0 Estimation Method or Emission Factor Source zzzz AP -42 J 01 Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to t ollutants not listed above. Requested Permitted <. Emissions° Uncontrolled - Controlled (Tons/Year) ` (Tons/Year) N/A U'S' Q Q'' 4 N w zzztri ;ft a; -a a z a z a zz a z Q z 's 11.29'5A) MAIM 39.84-6,4A N/A Actual Calendar Year Emissions' Uncontrolled Controlled (Tons/Year) (Tons/Year) a zzz4Lc; a Q i" S N/A r a z zz a z a z s Z a z Emission Factor Uncontrolled Units Basis o= mpjGTC • [❑� Q zzzz a Q Q .4) L L h z a z a z Q l0 0 Q 0 h 0 U w.. N- :.. z N/A z z V/N z z Wio Overall Collection Efficiency a z a z a z 'z N/A a z s z Control Device Description Secondary aQaaaaa z zz z z z z ES 4 y z QQ Fr -ai H �Q_i 2i. Q z Qy fv jai 2: Pollutant TSP a a k en o k °z U °> O u 0 U 0 R G p R R : as y U cu 1p Z. A 0 O/ w . U G u Section 08 — at 4) Ct (U ti 'O u R 0 State8-60_16-I H_GeneralAPEN. doc O U L4+ 0 Section 02 —Re Section 01— Administrative Information G G Ca Ca V ii s ,^^ . 0 O O U 0 E G y W Si 0 C 3 c C m _G o E 1.- E A .^ o o - k U O .0 C E o 61 •U F w a E L o m ❑ ❑ a G L . .. .N 0 •;0 O 00 E a O r a G A 0 z . I r, o • .0 0. G H U y70 3 E 0 W i=t G P. E za. O 00 a w a 0 o u au U u a C • 0. a a a ❑ ❑ a ® ❑ 4 - ti o ae U zen Chesapeake Operating, Inc. Company Name: x O O Ca Source Name: Sec36-T8N-R61W Source Location: a t change O5 0 5 O Q 0 F 0 0 W W T'S Q o m to,m 0 C 0 O v 0 O t 0 O O� R a ❑ ❑ o � y o ❑ ❑ ¢�z en en N 0 U a- N P.O. Box 18496 U Ca E 0 a O 0 N p an en WI C Phone Number: a 0 L 00 N 0 Person To Contact: N 4- O S W en a Fax Number: jeff.ingerson@chk.com E-mail Address: Section 03 — General Information •O G C W r- z 8 U, N -171 F+ N 0- C 0 E 0 N Ca -o O O y C U p 1 Ca • Y O 6 y O O a-. C Oce O 0 w 0 o h O o 43 xccic N 'O 0 0 0 ' w z E X U E _ -25 O c > CN c ri c�J y wv .0x U ._ U C I o b0 E E O c 0 0 N " N L M M C O 1/40 0 CO b M en en 0 O O O C E .C Q 3 ca Q 3 ❑ ❑ ❑ z z z r r ❑ ❑ ❑ 0 Ca 0 O CYyG z`2 C O 0 I O V O aj 2 O Cad m ^ E a a'0 a o O 3z Information Section 04 —Re Is this equipment subject to NS 40 CFR Part 63, Subpart Is this equipment subject to ubpartthat applies to this equipmen List any other NSPS or NE Section 05 - Stream Constituents U c .U. a O 2 a P. cd 0 •O rry za r. 2 o O 0 C-1 .O ❑ ❑ n -Hexane (wt. %) I Xylene (wt. %) Ethylbenzene (wt. °A) Toluene (wt. %) iiii Benzene (wt. %) u o • >aM o in , e g ) Stream Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil......_. C 0 a. a. Ca a Cn 9 Ca pT au C on U •.a. O N 0 2 Ca O 0 123-9709-005-APEN-2012-05-23-01 0 0 a riito s` FORM APCD-203 onent Leak Emissions a O U of Information 0 all N o a0. E E a a ag 6-s •c k s 0 0 e m .c0 Q o O c Q « co 0 .9 v o W O z 00 - 0 •> F4 C j > Q 0. m a a a o cc o y 0 O 3 U U w • VI m v a' m 5 O Z 0 a tvi c. 4 E P" Q y z o Fa y a T « ,a O a O ,. a • ❑❑qu U ,"', E m 0 e C Section 08 —Emission Factor Information z d z dad z z zz d zz d d z d 'z a z a z a z d d Q NUN d z 'z 'z z 'z Actual Count conducted on C O F E H s0. 0 U C 0 r E �Wy 0 4- a H d 0 0 can W a C 0 Emission Factor Documentation attached F z z zz o b t o 0 0 b o ct n cn C 0 y• ro O 0 E0 z z 0 - 4 o0 O • 0 0 w 00 N U O 0 C) N H z 0 F T X k C 43 O es 0 y c 0 c L 0 C L E 0 4.3 m z 73, 0 a L 1 L Yd. c O u c. A C) CL U c z A 0 0 W u 0 H eComponentLeaksAPEN-V er.9-10-2008. doc / )11 0 9 y m O y N 0 0 L 7 a Yo k:Q9 0 U 15.7 O y d m as ye q z m - o up s 0 7 O^ c Ca y . d y E o cal Ti d U o o '' ` z o o Qa O C U ge .. O 0 0 G a 0 Ct 04 • o W_ b F W _ a 2 o 0 0 a m ® ❑ ❑ Section 01— Administrative Information M sci o 0 U U U zct OO ea cia c O i Co i U Company Name: Source Name: Change company name T a o a v o ^ C. 0 Y a 0 0 0 .^. .� 5 a m E 0 0 O 0 o :C-, ° S e o m 0 e N U > 21 'C C ❑ ❑ 0�' L. t u a 3 0 0 Cp [1y t 9 0 i >' N = U 0 ,-' N U N 0 0 0 C M y 'C O Z G z o e00 0u fi W m s d 0 0 0 •.. pd ❑ ❑ g° 4 ❑ ❑ O N Source Location: Sec20-T8N-R66W 30 0 ❑ ❑ ZIP Code: 73154 Ca a ti C a; 0 •0 00 Oklahoma City, OK ti e N fel C-' In c Phone Number: CC C col Y 00 CC m 0 U 0 0 a C t Fax Number: (405) 849-2017 jeftingerson@chk.com E-mail Address: 0 os N 0 0 P. 0 ur 0 0 Ca 0 0 .o. W sr sr 0 0 0 a g a 0. b — g al E 0 C a O a. 0 CC m a a H O CC 0 a 0 o A , 0 ao 0 v F h 0 C7 ❑ o n, I o o 0' an C 0 C � m 0 'k 0. 00 v1 w z O z U sdk I 0 V G zE to q b ` U ooy 0 5 0o .0. cri 3-5 ment Information & anufacturing Equi Section 04 — Processin 0 0 0 c O Ta ONM an to r - AY 23201_ .Ec?e br0 b - C) en com 0 0 o co V -co E 0 9 zz z 0 O 0 y 0 0 0 0 0 .a P. a g m `o 0 0 0 a a U V 2 2 O O o L .0 U U ❑ ❑ zz z z z Q z z z Other Process: 123-9909-002—APEN-2012-05-23-01 N 0 OA Qi Co CO C, Ott FORM APCD-200 Q u 2 Ca U Y C C a) cki z w U F 0 z F a O • L_ • ,L x � z E' Emission Source AIRS ID: 0 c a) b O 0 ea 0 0 0 d N a) N Ca 0 R V co O 0 a w m m a 0 0 y W O G 0 U Ct m Cw7 en b ao en zz M PO O )0 C M N N tion Information a H C 0 U 4 a Section 06 — Combustion E z m ti t as Manufacturer: Company equipment Identification No.: se (% of Ann 0 0 ti z de N N 4e N o Q N eu ea T w K C 0 -C O 0 0 to R 0 E w a o 72 a is o 5 o U o S „ o > w a F�• a-1 1 C '. a o C R a L O 2 G o - C A F C 3 0 a e o W , o c a o is cn QQQQ z z 'z z v Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above Requested Permitted Emissions° Uncontrolled Controlled (Tons/Year) (Tons/Year) c)i N _ N a¢ z z Q Z z• \g‘ ti a' r4i, ka qi ' N/A d zz'zzx'z d Q Q@ Actual Calendar Year Emissions' Uncontrolled Controlled (Tons/Year) (Tons/Year) ' J T Q¢ Q Q 0 � m zz'zz.~�, N/A N/A S N/A Q zzz Q Q z‘ Emission Factor Uncontrolled Basis Units z z z z a 0 a S .0 r g z z z a Q 'z e o.a e N C Control Efficiency (% Reduction) Q z Q zz Q\ zzz.z Q Q Q Overall Collection Efficiency d z et z d z d z N/A Q z d z rControl Device Description Secondary z z z z z z p a z z a z a z Q z Q z a z W C TSP o.. w a z > OU i 41,4yzi \ " • 1 t"eca u 'D iR 0 G dat • CJ a) y E Ca F U nJ t� 0 O a) • . ' ..o F do oLra F a a o 0 C cri Ta Y -C 0 0 N s 0 3 na n L U y U o 0 sy v - y y0 ] v � y a 0 ] g u a Co at Ct Y a S 0 E G a a) N T. S a 0 u 0 w R R as+ u .0 F c ay C) O U (42 S Section 08 - N a 0 N a a) 0 0 z 0 Brent20-8_66-1 H_GeneralAPEN. doc N 0 N Co O ran E N C O O ;54 E GJ a C II • o c o ° 0 m • d W "a Co 0 w.� a W c H F O CA z O EMI m E-• N u 5 Emission Sou C r7 Section 02 — Re Section 01— Administrative Information C o z E C u . U C N a cc a a a ❑ El en LO b vi 0 U z� Chesapeake Operating, Inc. Company Name: Change process or equipment Brent 20-8-66 111 Station Source Name: County: Weld Change permit limit Sec20-T8N-R66W Source Location: 0 N 0 w , a O 0 0. W v o l' C = .q .F. o �`., 0 — c e ER F. Co C) 8 Y ,Co • °be n' 4 R ° Co m Lo a k " .14 U u o ▪ - x+ Po > 3q 0 u m C =• p 0 « m • 0 w o a ✓ Q o R Co W • 0 CD 0 • 7j 9. .J• C ❑ ❑❑ In N U a P.O. Box 18496 Oklahoma City, OK Phone Number: Jeff Ingerson Person To Contact: ((405) 849-2017 E-mail Address: 9 0 z Section 03 — General Information b O O 0 �o F 0 con 0 O Co Co U 0 O at Q 'C N C O a. oE 0 N -1 p0 Co 9 E 0. 0 0 •a a v P. 0 O • C o `O w a h e' o 0 •k pm 'a O G N • z wL -2 L R 4 C, Co CO ➢ t) o a C • Q .8 a G1 Co a°4" [-Ca E 0 m v a w Q Co Co q O.Co 'Coa.. C m 0 p ° •".ui 0 x i Co R s � Co O V Q 0 .. a i 5 3 -.5 C y C O T O 0- L., U ) Co a N 9 % y U E o 0 .0 L q R ° w T C Y P` 'O > O A Q W a o nI. �o O. 0. w qR7 ,'Q F E o O 00 .. '° U O h Co L .a. a as U 0q w F s' .R. U> ca0 p0, _pUpyC m .c' ox'£' iU6rii G w Qrn F o:. d a 0 i o p °IW 43 fe a• . V .0 Co A° 0 • c u 00 £ Co L G Co ,Co Y th 0 0 P. 0 E C m G o q N c k m e• o 5 L e N G p Q O 0 O N .0 M M to '0 '0 q R o a en M.v ` v o R 0 V ai y C) .7 0 O V ai ..o O CA Section 04 — Re ❑ ❑ Is this equipment subject to NSPS 40 CFR Part 60, Subp C 40 CFR Part 63, Subpa Is this equipment subject to NES P Subpart that applies to this equipme List any other NSPS o Section 05 — Stream Constituents 0 0 0 00q G 0) a P. a N teaR 9 a w w 0 n 0 Y a 0 O 0 .n 0 Che ❑ ❑ n -Hexane (wt. %) Xylene (wt. %) Ethylbenzene wt. %) Toluene (wt. %) Benzene (wt. %) U a m r r - luennly tile v Vv. W iu.i ..vuwu� Stream Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil 0 a a - 0 0 b E IJ 0 0 CC 0 .0 64) N 0 P. CO N At FORM APCD-203 cz I Ct CJ Q O O L O 0 en 0 2 C O W tzt U H C z O Ct H WW C Permit Number: Section 07 —Leak Detection & R Section 06 — Location Information (Provide Datum and either Lat/Long or UTM) o oN 0 N 0 0 0 N Q 0. CJ N N R e en co U Section 08 — Emission Factor Information u s C h L Ca C 0 C C ° 0 C C 9 o. H 0 a SUr � y° 0 R C. .0 a O be 0 C.) PT -1 I?7 0 d 444 d d V/N d 4Z d d z d z N/A d 'z L - V/N d z d z zz d z d z d z d z 0. 0 L .0 R R 0 U a 00 U .0 z O 0 N W 0 h N 0 0 e z b M In M w C 0 C 2 Estimated Count 00 cr A o C wi 0 U z ea C7 R 0 U s 0. 0 .0 .0 R o, R 0 erru .0 e 00 O C O a C O .ci 0 0 U V0 O In en 0 0 2 U C w Open -Ended Lines en 0 Py 0 Section 09 —Emissions Inventory Information & Emission Control Information O �^ 0 C U v w zz z z -0 o b ee O". d d N t 0 C 7. 7. CO m u tor Documen 0 ° L1 Actual Calendar Year Emissions d d z -o O y 0 o o o 0 N d d z d fW 0 0 '0 0 Control Device Description E a U 9 N Ca F v C .o Cc) G K x 00 C X pollutants not listed above. C 0. L E E C d C Ca C a .70 L 0 v n .Ca U C z A d m C It Pi d .2 ti .0 U 3 00 Iw m °° =C 0 C 0 ° o 0 `,3 CD-203-FugitiveComponentLeaksAPEN-V 000 p 0 N 0 a a v y m ro a • ❑ a 0 o "m 0 ▪ O t c - ^ s CA O W o U '.. E © d o • Q G t. u - ' a a a i2 • E" 3 a p ,Pc Z, 1c W E o W 0 H P. H 0 C 0 Z d w Q a .o rioc o .-.. s AIR POLLUT nested Action (check applicable request boxes) Section 02 —It Section 01— Administrative Information u L C 0 Ca u T L O C L u C L 0 E e z a ®❑❑ 44-1 'U U zrip S CC n 0 C) c CC U z. C 3 Change company name Change fuel or equipment 0 r N 0 ❑ 0 2 o Transfer of ownership a 0 tab U ^ C " a 0 0 a W N O E 3 w▪ 0 0 0 o g bn a m k v. O . • a ✓ .O T 3 0 C 0 0 o W o w . 6 0 is o 0 g, c o m o O C tA E W o o m y � ; '0 a a Z 0 u a. P 0' as❑❑ ❑ ❑ C en 0 P. N P.O. Box 18496 Oklahoma City, OK C T N Phone Number: 0 e a -o z C W O Fax Number: jeff.ingerson@chk.com E-mail Address: Section 03 — General Information O CC b 0 U 0 0 a Y 0 O b 7 0 4-4 O C) o L.1.4 m >44 0 rl N r N to > 4.3. v a 0 N Process Flar 0 a p bit o CC 0 0. 0 a rd '� p U w vi O O N o 8 0 h a 72 0 O 0 c p 2. O 0 .- o� 0 7" a y o N V p N co rn m E Z N N 8 W cn a i N 0 G .4O ..O .O 'O ,0 P. V r.. 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CC U: Y y 'm O. zz z zz zz z zz z z z z ❑ ❑ zz a z z a z a z z z z z ¢ 0 a s O a 0 CO 1.0 O 0 O N W CD O 0-1 ti N N O 0 CO a Cif r- p6�p._ rtNia FORM APCD-200 Emission Source AIRS ID: Permit Number: information in the e U) .X: O 4 N o O C o a M C2 sue, 43 0.i w O ob... o?J Q b oo N co z E a -ea rog A0 al ° z ye e 0 o w 0. ❑ 0 ❑ N ea N �z. z N ►V ment & Fuel Consumption Information Section 06— Combustion Eaui z U) a .n a C N E U 4) C) 0 4) 0 0 0 4) U) N CD O N CC Q a N ea N .O Q) "it R ) N CC L x aw w N a 'C) a 4 aCU 2x900 MCF w d a a t4 u a To .o z -c4 z z 1 3166 i-, 35 AP -42-6m (, 966 jz,0 3 AP -42 Requested Permitted Emissions4 Uncontrolled' - Controlled (Tons/Year) (Toh.g/Nte.nrt i '. 4 z /NI I Q z Q I 't Q ,1Vl'r k e.g. LVV /): Actual Calendar Year Emissions Uncontrolled "Controlled (Tons/Year) (Tons/Yeat} `. V/Ni H V/Ni z SOX N/A N/A N/A N/A N/A N/A N/A N/A NOx N/A N/A N/A N/A 0.068 lb/MMBtu N/A 1,-78 1,2.1 VOC N/A N/A N/A N/A 071-40'lJ,19? Ib/MMlstu.()),;_f. NJ '432, 3.66 -pi CO N/A N/A N/A N/A 0.370 lb/MMBtu N/A ?S66 '1, Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not lis Annual emission fees will be based on actual emiQainna rrnnrlorl harp V/M z z Emission Factor Uncontrolled' Basis Units V/NI z N/A 1 N/A Q z Control Efficiency (% Reduction) ti z vim z 1 Overall Collection Efficiency Q z Q z . z Control Device Description 8.. I.: din 4 z n L 0. V/N V/N d `z � CO t Q - H , Ai L 6) U 4) a L 4r a W a co 0.. a) O CO u a A: a. 0 Pt O h' O at E 0 11 i N .G L G O ;, tn Ne. ❑ o NL N Q p O R m E' G W m o L F 8 E 0m W C u, G G C C .0 o A a o « a N F o o E 5-'1' p u U u W u G v. 0 ° 4, N + cp O .u.cCJ A Y • F b0OU u r U Fy. O. O I Pa E - c o N O L Y © E 5 O G u J. .y C >, 3 % C v u C « a a 0 V. o E ZO 0 o U W o 3 c L H 0. a ro G e' " d 'oN z a00 - . E w ia' ti U O 0 0 c as PG 4 ED u' '41:1101 Lez ui Section 01— Administrative Information 14 0o an U z� Chesapeake Operating, Inc. Lindstrom 24-8-67 111 Station V N 0-1 It, r o O U > 0, N a CC N Cl Cm C O [a N Z z o ccz 4 a 0. E 0 0 U E rn 0 U rY P.O. Box 18496 0 d m Oklahoma City, OK Phone Number: Person To Contact: ((405) 849-2017 jeftingerson@chk.com E-mail Address: Section 03 — General Information a 0 C W 0 0 z N b ‘z EL i 0 0 I-, 0 o F E o,nin W N G U %. U N c4 M 0 W t y N N N rn rnrn.`o L . F 0 F b �p b ^~j F 0, ai r Q o 0 AT E M M M O W U JP, G.-, c 000 r .0 P+ .4 u W -2 L '�.' v �/ o w e G N .E a a‘ G W w O •'-a,, 000 N W `z �I xi O O E 74 Sm w Q Q O U p' cn N W y O �.r.1 F" r F G o 3.9 y u S' a) �: W O T O •0. U? F t C C n. O G v d' cy aF V] 5 Ot. g ryi 0 ., v •>« t W 0a > o fat'�+ t G O Q N 1 Q N >.. aW w >,d c 8 y7' o 2 3 q O O QEZ QQ ,� 4-, 'C E., G_ cOm : W 0 U vl - N 'OCI 8 2 C Q Pi L O 8. OzA G d C U ,5 m i ., Eg P U a 2 a^ z' .a = o U o F m W 6 s 1'' c t° > M m E' o " E F. 0,=. UavG w QCf] �¢ U C o ; oC o ❑ ❑ ❑ z z • z O El El Cd 0.0 r' N O C .0 C 0 0 V a ^L. N ao a ^ U al 0 0 O 0 w 't - O r E O o 0 U 00ao 0 O co, 0 O O 0 q . 0 0,5 E o 0 C1 0 0 y .5 a, G car W 0 0 -8 0 z w Information 0 Ct a Section 04 —Re co co ❑ ❑ List any other NSPS or NE Section 05 — Stream Constituents Check box to re n -Hexane (wt. %) I u F c k„3 Ethylbenzene;: (wt. %) 1 I Toluene (wt. %) Benzene (wt. ti/e) Gas 29.92% Heavy Oil (or Heavy Liquid) Light Oil (or Light. Liquid) 100% Water/Oil.. -- O 0 0 00 ra C C (70 N N ID 0 b 5, 123-9910-003-APEN-2012-05-23-01 FORM APCD-203 a. & Control Informati Section 07 —Leak Detection & R o tt;oz w p ct P Q ." T T o m 0 Q 0 o z ❑ ❑ q d' d ❑❑ a � a ao m � C i j . 0 c T1 ‘'D 7 a to o m E 3 U U `o (7 d a 0 -9 EF N m o0 0 'En m o a C F. 0 F 0 coa M 0 In a 0 Q Section 08 — Emission Factor Information 9 a Ca a 0 0 a '0 a. C 0 w W v 0 _ 5 m� d y G u m 'a cr L C u z zz zz z z Q z 'z Q--e-.d z z z z z z z z' E Q u d z a z a U L E O V L a U a N O Ca O N 00 0 an In ca to b O Q M N M U Te 0 Q U w z z z z 0 0 C) 0 Q 'z z z z Q 'z d z z d s C V d s s e C d .0 a e s L .O z 00 W 0 0 a 0 Q 0 a 0\ 0 0 In M 0 C) 0 0 Open -Ended Lines 0 d a 0 rvice used to calculate the "Actual Calen ission Control Information Section 09 —Emissions Inventory Information & E a. a w z zz 0 0 O F • m o o 0 o 4z en U H o C N j.d e R CC 4 Ca Ca CC C a CC 0 Ca W E C'S W 0 E• w d 0 0 a ) 0 C 0 ro: 0 0 Q Q d 'z C a 0 0 o Y C C) H z .o .0 W z d d C 'C y 0 75 CC C- 0 G E E CU C CC CC 0 R L C C.)m L C 0 q , F•I 0 o cr Section 10 —A N O' Emission Source 1 3 F•1 Section 02 — Re Section 01— Administrative Information Change fuel or equipment >1 3 O U O ¢ ' O E 01 r. It 0 0 _. « Y �C. N O E m o U R CU y o P. F U can 3 w • `g1 eg F • t . m m c k Ca d a a ? ❑ rg O O .O. Lta! d a, -❑3 PO u W •5 .11•A a C l ▪ u, 1 z g .� e O W .c W G u 4 0 CC U F y 7,1 •O C3 m• @ • , o0 ?' o • E Z Oy o a -8a et .0 217.! ▪ a V. c 0 ❑ as❑❑ ® ❑ ❑ ❑ ❑ c. b4 W C' 0 6 0 tt Company Name: State 7-62 36-113 Source Name: Sec36-T7N-R62W Source Location: z R al ¢ z , N 0 N M Cr M 0\ 00 N 0 e U N N P.O. Box 18496 Oklahoma City, OK Mailing Address: Phone Number: c 0 L 00 s 5 Person To Contact:. Fax Number: jeffingerson@chIc.com E-mail Address: Section 03 — General Information a z 0 0 N I"- 9 0 N Process Flare for gas stream O C 0. O C 0 C 0 m •0 2 F o a 6 9 o 0 o W O „ 0 • " o F4 . • 0 Q a c C y k c g 0 O 0 Z C7 L U U E M en M 0 O O O v M U a' L Ca .0 \ ^l T O GL u A o' m G • 3 g A n o- ?�, b 0'0 0.E . It .9 171 2o b e. m▪ > V `d 1 ei O C O N '� >`"� E dUw o u s c:, v 8 o O °LO. o' to 8 o c k c U g 2 O N �•' .0 Vl 21. L ...2 — tg w N m r m Q. ' o fli .>24..k' ± 3 e Q W d C/1 N • C G• 0m Q O O O • 0. 4 ▪ .a N • CO b b O 0 o ,o 0' 0 • 0 Check box to r merit Information & Material Use /Manufacturin Section 04 —. Processin z en z 0 Manufacturer: U s En - P 0t) . 9 2 O wF 04 Check box to re ❑ ❑ 0 O 0. 123-9911—002-APEN-2012-05-23-01 FORM APCD-200 Emission Source AIRS ID: e 00 b e a'_ g N a • rr H0 `o N d e 00 uP. E■ 0 O 012 w v• zz ❑ Other (Describe): Width (inches) = N II .f+ cUc .v ❑ 2 h ® a ai u C yN Ca 00 ✓) O c O O 0 v a - k A w ment & Fuel Consumption Information Section 06— Combustion Eaui U 0 8 d z N z e N ^S; "V z z Q z eg 457 N 0 en z z .O b ev O N z z z z z -E. z z a O z O U a a 0 0 a: e 0 L O s E 'O O O Q m 0 0 L d .0 �.o IM 2 U C Pz a s a q O 0 u s 3tate7-62_36-1H Genera N O N N Q m O 0 Ca ra Ca Q 8 O 9 3 ES N a i p a, r" a N R ❑ a o Section 01— Administrative Information 04 9 L y T y 3 .CaN s. C O rr. F.1 0 C m c U W 5 z ❑ ❑ 6 , - w € z o GI ` v x o^ 0 U U 0 0 E. 44OO4 4OO. 0 •> o 0 _� W a O F . c y 0 ^ O 0 0 E o so c y C E m E 0 v ea O P. o o o o m u 13= 0 49 o w -. O O /+ V • a 2 5 a a 0 F • a. 3 o N d y 0 w 7). ,0 0 0 R a r z o z .. ❑ U W t ••••• O m G `o .Em a' o Wd m 08 •'a Ut. = U o 0. 2 ®❑ 0 • Loki CO U U zin Chesapeake Operating, Inc. z C U N.„ 0 0 U 0 w See36-T7N-R62W P.O. Box 18496 Mailing Address: Oklahoma City, OK e M U, e Phone Number: Jeff Ingerson ((405) 849-2017 .0 a W jeffingerson@chk.com U � N F o % U < 0 oo 0 CO3 9 u.. 0 •O O ¢5z Section 03 — General Information z UI 0 . N 'a Q N 0 ba N C .0 • 0 a 20 P. o O 0 o • 00 • o o C V 0 o z 0 m 00. 0 P. E V U 0 0 .0 73 0 0 it rn e R 0 O 0 O 0, 0 0 NL o o F ti 7 M ... M M O RL G \U \0 co 01c.2 ao aO a)ra co M M M o d d d G q v� 0 \ 5 m C .b 4 '.'o0. R ,z .. O o �. /C J fl pa o id C/3 V •r h o s U V 0 a o • n .. .. '9 0 APEN forms: o0 DODO O ❑ ❑ z z0 Ig En N r r Information 0 O 0 Section 04 —Re Is this equipment subject to NSPS 40 CFR Part 60, Subpa C. 40 CFR Part 63, Subpa Is this equipment subject to NES appl List any other NSPS or NE Section D5 — Stream Constituents J 4 N 9 0 0. 0.. Check box to request c Check box to request c ❑ ❑ n -Hexane.. (wt. %) xylene (wt. %) Ethylbenzene (wt. %) 1 1 . Toluene (wt. o o).... Benzene_. (wt. %) III, Ua © i J 3 e 0 t.1 I a o - Stream Gas Heavy Oil (or Heavy: Liquid) Light Oil (or Light Liquid) Water/Oil m U 0 0 0 0 0 F R1 en P U_ T G m b ijd a bq a 0 P. El i wI z LCD CO CQ FORM APCD-203 .123-9911-003-APEN-2012-05-23-01 Emission Source AIRS ID:. of Information Section 07 —Leak Detection & Re a 0 `• z `0 E Igo • 0 i fl z o H F P E In v N C\ ti M Section 08 — Emission Factor Information C u .O e e 0 S C 0 C 0 C C 0 y 5 o n `a E m ai v S g Ca m 0 rl 0t 0 O u 0 U 0 'z Q z z 'z z ' a e u L c E u .0 E e V a E 0 u a ui z O O z 0` 00 O 0 y b e a U z M M 0 CJ O Q d 'z 'z va a U z z z d z C.7 E u L 'z E e V 0- a c E Ca ag e V i 4.4 w b 00 0 z e1 co N a 0, 0 GC\ 0 z Val O U) en 0 0 C1 0 00 Open -Ended Lines 0) a N 0 ssion Control Information F0 O y O ai 00° 9 0 or 2 o 2 z w cd. z a) C U F 00 z C d\ z z -451 at 0 F F o ] F d z v o tG O 0 Emission Factor Uncontrolled Basi > o 0 o o F'o d o W N ti C 4 CC 0 z N a CC c a N 0 0 N .0 .c V7 a T d z C ort pollutants no 0 C w a 0 CC .O 0 . a 0o.a a o 3 a d a b .. m 0' a. .0 = 0 O.F _ g = R o U E m ` xi r w ° o C R a) R 9 az i w Section 10-A 0 N N O N Hello