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Home My WebLink About20130816.tiffSTATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe.state.co. us March 21, 2013 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Weld County Clerk & Recorder 1402 N 17th Ave Greeley, CO 80631 Dear Sir or Madam: Colorado Department of Public Health and Environment On March 26, 2013, the Air Pollution Control Division will publish a public notice for Chesapeake Operating, Inc. — State 8-61 36-1H, State 7-61-16-1H, State 36-3-63 1H, Hoff 6-62 15-1H, Wagner 11-65 9-1H and Heiby 18-8-66 1H Pad, in The Greeley Tribune. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Ellen Evans Regards, Ellen Evans Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure ---ptjobcd it►e ) ti -o- 1-33 ct fL,7L 3/a57 2013-0816 STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado hltp://www.cdPhe.state.co.us Colorado Department of Public Health and Environment Website Title: Chesapeake Operating, Inc. — Six (6) 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 21, 2013 Published: March 26, 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 8-61 36-1H , State 7-61-16-1H , State 36-3-63, Hoff 6-62 15-1H , Wagner 11-65 9-1H and Heiby 18-8-66 1H Pad ` Six (6) 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. State 8-61 36-1H (Section 36, T8N, R61W), State 7-61-16-1H (Section 16, T7N, R61W), State 36-3-63 IH (Section 36, T3N, R63W), Hoff 6-62 15-1H (Section 15, T6N, R62W), Wagner 11- 65 9-1H (Section 9, TI IN, R65W) and Heiby 18-8-66 1H Pad (Section 18, T8N, R66W). Weld County The proposed project or activity is as follows: The operator proposes to maintain and operate six (6) 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 12WEI877, 12WEI863, 12WE1861, 12WEI872, 12WE1866 and 12WE2038 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 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 12WE1877 Issuance 1 DATE ISSUED: ISSUED TO: Chesapeake Operating, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as State 8-61 36-1 H, located in Section 36, Township 8 North, Range 61 West, in Weld County, Colorado. T Facility Equipment ID AIRS Point Description FLARE2 004 Plant flare used to control gas stream off of the 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/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: 123/9710 Page 1 of 10 Condensate Tank Version 2009-1 blic Health and Environment o it Pollution Control Division application ass_ €t With. i p w najii) da' es con tion fora period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 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 1.0 3.5 5.3 Point FUG1 005 --- 3.0 --- Fugitive ee o es o erm t 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 1500 MCF/yr AIRS ID: 123/9710 Page 2 of 10 Health and Environment it Pollution Control Division Compliance wit e 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 ll.A.5.). 12. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. Point 005: 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 005: 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. (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: 123/9710 Page 3 of 10 Health and Environment Pollution Control Division (v) -f wi+� -c• • all b a' . 'ned f ,. eriod 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 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. 17. 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). 18. 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 the gas and liquids analyses and emission calculations to the Division as part pf the self - certification process to ensure compliance with emissions limits. 19. 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 AIRS ID: 123/9710 Page 4 of 10 20. Point 004: Th heat content on an annual basis. Health and Environment it Pollution Control Division s rout " the flare to determine the 21. 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. 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 (NO„) 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 b. 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 ID). 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: 123/9710 Page 5 of 10 bliHealth and Environment Air Pollution Control Division 25. If this permit s+- « al y sta�etth ` authriz - has be ranted, 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 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: 123/9710 Page 6 of 10 Issuance 1 bli ' Health and Environment it Pollution Control Division Per ) enc•m -d flare and associated fugitives. New synthetic minor source facility. AIRS ID: 123/9710 Page 7 of 10 blicaHealth and Environment it Pollution Control Division Notes to Permit Holder aftherme of errrnttsyuan 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.cdohe.state.co.us/requlations/airreqs/100102aqcccom monorovisionsreq. 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 Uncontrolled 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 43.65 lb/MCF . 2.18 lb/MCF Engineering Calculation 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 AIRS ID: 123/9710 Page 8 of 10 blisHealth and Environment it Pollution Control Division Flanges 3e°%04 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) Applicable Requirement Status Operating Permit Synthetic Minor Source: VOC NANSR True Minor Source 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 SubpartA— SubpartZ 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: 123/9710 Page 9 of 10 Health and Environment it Pollution Control Division 7) An Oil and Gas Indu a , strucf r. P elf Ce fica%n Form ji 1uded with this permit packet. Please use this form to complete the self-certifii cation 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/oilgaspermittinchhtml AIRS ID: 123/9710 Page 10 of 10 Construction Permit Application Preliminary Analysis Summary Section 1 — Applicant Information Company Name: Chesapeake Operating, Inc. Permit Number: 12WE1877 Source Location: S36, T8N, R61W, Weld County (non -attainment) Equipment Description Point 004: Plant flare with a minimum combustion efficiency of.95%. Point 005: Fugitive emissions AIRS ID: 123-9710 Date: September 20, 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 004 Plant flare used to control gas stream off of the 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? PMio 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 i1I.D.2) PM,0 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 emissions; mass balance for 3 -phase separator 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 1500 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 1500 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 10 3 50 5 Other 13 3 Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 004 1500 MCF/yr 005 Equipment Type Gas Connectors Flanges Open -Ended Lines Pump Seals Valves Other 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 80.4 14.9 --- --- 1.2 (n -hexane) 1.4 PTE: 002 --- 12.6 --- -- --- 1.1 (n -hexane) 1.4 003 2.0 0.1 1.1 --- --- 0.08 (formaldehyde) 0.1 004 1.0 32.7 5.3 --- --- --- --- 005 --- 3.0 -- --- --- --- --- Uncontrolled point source emission rate: 001 2.7 67.0 14.9 --- --- 1.0 (n -hexane) 1.1 002 -- 10.5 -- -- --- 0.9 (n -hexane) 1.2 003 2.0 0.1 1.1 --- - 0.08 (formaldehyde) 0.1 004 1.0 32.7 5.3 -- --- --- -- 005 --- 3.0 --- --- --- --- --- TOTAL (TPY) 5.7 113.3 21.3 --- --- 1.9 (n -hexane) 2.4 Controlled point source emission rate: 001 2.7 39 14.9 --- --- 0.05 (n -hexane) 0.06 002 --- 10 --- --- --- 0.04 (n -hexane) 0.06 003 2.0 0.1 1.1 ___ 0.08 (formaldehyde) 0.1 004 1.0 3.5 5.3 --- --- --- --- 005 --- 3.0 --- -- --- --- --- INSIGNIFICANTS (TPY) 0.2 0.4 0.2 --- --- TOTAL PERMITTED (TPY) 5.7 55.6 21.3 --- ___ 0.09 (n- hexane) 0 2 Section 7 — Non -Criteria / Hazardous Air Pollutants Uncontrolled Pollutant 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. CAS # BIN Are the emissions reportable? Controlled Emission Rate (Ib/yr) 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 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? Yes X No If "yes", for which pollutants? Why? For Reg. 3, Part B, III.C.1.a (controlled emissions increase > 25/50 tpy)? Yes X 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)? Yes X No Section 11 — Modeling Is modeling required to demonstrate compliance with National Ambient Air Quality Standards (NAAQS)? If "yes", for which pollutants? Why? N0x emissions are less than 40 TPY. Yes X No AIRS Point Section 12 — Regulatory Review Regulation f! =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 .:E " .=_ 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 Reputation 3. lfPENS, Construction_P__erniits:°aperatmq Permits, PSD : 004, 005 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) 004, 005 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) Rea _ Olation 6- .New Source=Perform ne&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. Requlation-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. Requlation 8 -- HazardousAi'rPollutants 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 (9/0) 004 01 43.65 lb/MCF VOC No Engineering Calculation 95 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 005 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 004 Flare Permit issued because emissions are greater 5 TPY CO (Reg. 3, Part B, Section II.D.3.e). Operator marked on APEN that source is not in nonattainment, however, when I looked at the stationary source map, it looks like it is located in non -attainment. VOC, NOx and CO (from AP -42, Chapter 13, Table 13.5-1 (NOx = 0.068 Ib/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: VOC = (32.74"2000)/1500 = 43.65 Ib/MCF AIRS Point 005 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. 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 3.0 TPY VOC. Page 6 onent Leak Emissions 5 C S E ^^a,� Emission Source! N ft b.0 0 a T .C Yr a CJ 6 A c cacn a a 3 O y c. m a m o -oo 0. a a 0, 0 G yW c0) al 0 W A U , F a z J rit z O r WW Ea aw o 6 QNN E Z0. 3,U o a W !4 y G G 0 M is 4.. O 3 a .0 0 u k o o u s .O O S y U 1 0 a o Y cr N N r, F. s a 'E UV O 0. ` 04 0 d G r"' L > c.• s d v F L o E A m a G en a z '40 L i'a a a g Section 02 — Re Section 01— Administrative Information a ®❑ en Chesapeake Operating, Inc. Change company name pUp Sec36-T8N-R61W Transfer of ownership w On e 'O a 0 b a a a a O 0 a 4.1 a o a c 9 O i 0 ❑ ❑ d4z N U 04 N P.O. Box 18496 Mailing Addres Oklahoma City, OK Phone Number: F 0 4- H a Person To Contact: ((405) 849-2017 Fax Number: Section 03 — General Information C o q a 0 of O cn .C 3 o a a o .0 a ' a O Q O ma a v a O o 6 a 0 w 0 0 0 0 0 0 0 a 0 w0. w0 z m O 0 ..O O E u F e W C L ¢ N Qj a a z 0 0 E c M M o 0 0 a O O O G en en yY U w a O a 0 8 •'o°� '. z d P4 7.4 :5 ❑ Pwfs y 3 > .; O O fie ... Q u G V a u e R V O N Y y �h ,a3 0 Y� y 4-. p. O O a U O a a .. O o c v 'a m F en P. O w F - E E_ 4, a 3 L M O o N p O 0 C b0 0 Q rl 40 e w d F 3 co-. > a � E Q0 01 fl 06 O d Vn C E' F. U W O U m• 8a0 eq�'!.'O f o a• U C a I O VJ L U O y '9 191 F s: .p �. v G .4 0� o u Lit' ≥ m a a a s5 :71, p O 6 Fx. a� so w <4En sal p 000 in al .-.- M on M € N N N rnrn o.a l0 'O b b cdohe.state.co.us/a APEN forms: h 3 U a a h Application status: htt Information 0 V a Section 04 — Re Is this equipment subject to NSPS 40 CFR Part 60, Subpart 40 CFR Part 63, Subpart I-IH? Is this equipment subject to NES Subpart that applies to this equipmen List any other NSPS o Section 05 - Stream Constituents O O a a n -Hexane (wt. %) Xylene (wt.%) Lthylbenzenc (wt %) F c 0 F_ , ' ' Benzene (wt. %) Ue e 0,. > 3 O N I O cn w 1 taJ m ' Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil' El E N 0 an 0. N to 0, Nq� FORM APCD-203 123-9710-005-APEN-2012-05-23-01 a O m C 0 O of Information PP ,FPIPt Emission Source AIRS ID: Permit Number: .at Section 07 —Leak Detection & a N co C7 Section 08 - Emission Factor Information ctors below if checked. o a❑ CO Ot CO Ca U O c d d z z z d --t-, z z d z d z d z d z d 'z d z d z d z d z d z d z d 'z d z' E u taa E V .0 .0 .0 L z r 00 e In 0 0 0 0 U In M U 0 El Estimated Count w -11 U r7 w 0 d z z d z zz d s O L S U a e U s E O u a 1/40 00 O 0 d a 0 n 0 0 eF a e O N ti U Open -Ended Lines C) F O w Y U p 2 R L w 2 .0 0 o O j c 0 at 5 C 0 n o t C O c , E, at 2 .2 W O U 0 m 0 a a - z 0 r e Documentatio (_. O 5 G O `o '0 a) 2m y o O '''E �w cr W> es U 0 Td 8 o0 c� 00 0 d w d z d zz d z d 'z d z N d z O m 0 0 W Uncontrolled B T:. 0 U 'd U C 0 N m H a) W X 0 0 C 03 k 9 0 0 (' r. O 0. w 0 E 0 u 'J 9 C a. a. d O a R Ca al oc z U d u d O R M y E. E 0 ' CU 0 ` N .0 s 0 = 2 an 2 0 - . o U O UT e no xa w ` > C O R o a C 2 2 W o 0. • s ❑ a Z N 04 a g m f' g 3 m d1:1 a-, w m 2 = C O aU V G M C 9 oq O w° z e8 5 w v ail Lc. C .° .9 E. ation - I hereby certify that all info Section 10 —A Y Tel O r^. nested Action (check applicable request boxes) Section 02 — R Section 01- Administrative Information Cu ni ® ❑ - t to O1 4 3e, OO : o a U U a 11 O v U .2 z� Chesapeake Operating, Inc. Company Name: O K Source Name: Source Location: Sec36-T8N-R61W Change permit limit s with a Federally enforceable limit on PTE 9 C u a > O 0 0 C O ; o-, O O o yp 0 C a 9 m C y p a E a C) o s s+ w u T 3 O r E 0 49, o pPy u . 6 2 o > o « e 3 0.1 z ❑ ❑ ZIP Code: 73154 ailing Address: P.O. Box 18496 Person To Contact: C O co 0 Fax Number: Co - fl Section 03 — General Information Process Flare for gas stream ent and purpose: 0 a z 0 N 0 C CO O A A' o a 0 o 9 0 0 0 N c: O C 0 ti N L M en M E N N N i ON rn Cr, N. O t commm O ` U; C C- O.O O O w ,C 0 v 0 ei C wo mm Nw Z .E-n-'� �°� w a ? N m yq y Q A 0 •G W (0 O X30 Yx E a u u a u >..o a c m o 1) E 0 s a v E '�, P, -a > 2 O e .1: M O> 0 c�J C C q y 0 Q Y `o a. c c u .. 3 o 5 ^r�. b O O O L u eF .� C F �y� u> 0 R L L.N O y 'C 3 y 4. o a U Go o U —\vaN w� s. E.,..., ""' >, m C d O o e g p o u o .� c� u 0 0 .. o C C o m m U o O o N .a+ C 4 U u C -5_ w c^ C Y F _ o Q o > e0 P. t W 4 c'ia o e u E a O '�5Y 0.'O H aKi� Fr q A -1A ¢ Q C oo O x r, O C C z A �c 45 zr .E C C e, 0 o. o °o A u ra CO • R 0 ment Information & M W /Manufacturin Section 04 — Processin 0 o T. a o. �t O 0 O o O O. m rl N 192 �//N J kIJ$k�`k„i '-I Cpg 0 U Y o,? m ar 0 0 u d v zz zz C) ra O 0 - to v j z zz e z z o c.) y ,5 O• W w v ✓ U U U U ❑ ❑ Other Process: } 0 Q m 0E �E a a d E C o. E ,0 .0 an, 9 C- m c A FORM APCD-200 Ct cc Cl Cl a o `o> Q 7 N ry" z z z 3u M 0 Vertical with obstructing raincap 0 Dir 00 Exhaust Opening Shape & Size (check one): N Circular: Inner Diameter (inches) _ 12 tion Information ment & Fuel Consum 4) Section 06 - Combustion E Manufacturer: Company equipment Identification No.: 0 ., ca NTa (0 bo o o T .4 C r,' e 0 °'co 0 Cl N k N e N z 1,020 Btu/SCE m0m Na ° W U I 4: w Natural Gas 0 a a L L F U C U) C uE E w 4) t r 0 4) H F N n 0 C 0 U Ct Estimation Method or Emission Factor Source Q ZZZZ Q Q Q V e d7' Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. • Requested Permitted Emissions4 Controlled (Tons/Year) N/A d z'z'z d z. o ri:k 'n b.48 QS , -a- Uncontrolled (Tons/Year) n, r 4 d Q d d z'zzzz 4 Actual Calendar. Year Emissions3 Controlled (Tons/Year) ri r::4 d d dz d b m zz'2Nr� ; Uncontrolled (Tons/Year) n S zzzzzazz d d 6 41dy d Emission Factor �.,Q ;'zzzz Q Q .d a E a Uncontrolled Basis Q Q Q z z z d e O o g err a oM Control Efficiency (% Reduction) d N/A d d Q 24 z z z z Overall Collection Efficiency Q z d z Q 'z d 'z Q z d z d z Control Device Description �p a d d d d d d g z zz zzz 'z z d¢ a Q Q Q fFY zzzzz'zz a TSP a a PMzs N o x O z DOA O U Pi 0 N Y L 0 0 0 I 9 R c ❑ � v _ ac w as enI ar ac a F 110 b t .0 r a It C a r. o U It h 0 E 'O G 4- .C 'C 0 E G 0 C E c u 0 0 Q1 100 I- 'a w' C a Cfl Q -o o CD 0 ' ft U r LC CA N O N 0 P. STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 12WE1863 Issuance 1 DATE ISSUED: ISSUED TO: Chesapeake Operating, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as State 7-61-16-1 H, located in Section 16, Township 7 North, Range 61 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 the 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/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: 123/9905 Page 1 of 10 Condensate Tank Version 2009-1 bli&Health and Environment `> it Pollution Control Division application ass v✓ith is p WI i) dtsdontifiUes construction fora period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 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 004 1.1 4.6 5.9 Point FUG1 005 --- 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. 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. Annual 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 14.6 MMSCF/yr AIRS ID: 123/9905 Page 2 of 10 blicnHealth and Environment it Pollution Control Division Compliance wefinn - ro ppu li +e det jred 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 005: 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 005: 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. (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: 123/9905 Page 3 of 10 blic Health and Environment 'r it Pollution Control Division (v) "a .® owip :Pc 0,,. Q.Il bfiained fg eriod 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 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. 17. 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). 18. 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 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 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 AIRS ID: 123/9905 Page 4 of 10 20. Point 004: Th heat content on an annual basis. blicsHealth and Environment it Pollution Control Division Iksar s ro the flare to determine the 21. 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. 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: 123/9905 Page 5 of 10 blic'Health and Environment Air Pollution Control Division 25. If this permits Ily'stash auth fizat[enhasb ranted, 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 specificallyidentified 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: 123/9905 Page 6 of 10 bli Health and Environment Air Pollution Control Division enrr it #o ) enc flare and associated fugitives. New synthetic minor source facility. AIRS ID: 123/9905 Page 7 of 10 bli&Health and Environment ": it Pollution Control Division Notes to Permit Holder ;LI ti e of 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.cdohe.state.co. us/requlations/airregs/100102adcccom m onorovisionsreq. 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 Ib/MMBtu --- AP -42, Table 13.5-1 VOC 20.02 lb/MCF 1.001 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%) 30.73% 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 AIRS ID: 123/9905 Page 8 of 10 Depa bli Health and Environment it Pollution Control Division Flanges = # 304hx 3 1E-04 2.9E-06 Open-ended Lines 2.0E-03 1,4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA -453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas and liquids analyses. 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: 123/9905 Page 9 of 10 bli ',Health and Environment it Pollution Control Division 7) An Oil and Gas Indys` strug.ift Per it43eif-C fca Form,is r 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: httb://www.cdphe.state.co.us/ao/oilaaspermitting.html AIRS ID: 123/9905 Page 10 of 10 Construction Permit Application Preliminary Analysis Summary Section 1 — Applicant Information Company Name: Chesapeake Operating, Inc. Permit Number: 12WE1863 Source Location: S16, T7N, R61W, Weld County (Attainment) Equipment Description Point 004: Plant flare with a minimum combustion efficiency of 95%. Point 005: Fugitive emissions AIRS ID: 123-9905 Date: August 8, 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? 8/8/12: I emailed the Operator for the gas analysis used in the fugitive and flare calculations. I received a correct gas analysis on 10/25/12. 8/9/12: Facility in non -attainment; fugitives subject to RACT. There was no RACT discussion in the application. I sent him a fugitive RACT condition and Jeff Ingerson called to let me know that the condition will be acceptable for their RACT requirements. 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 the 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 Page 1 Is this location in a non -attainment area for any criteria pollutant? X Yes No If "yes", for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for any criteria pollutant? Yes X No If "yes", for what pollutant? (Note: These pollutants are subject to minor source RACT per Regulation 3, Part B, Section 111.0.2) 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 004 AP -42, Table 13.5-1 for combustion emissions; mass balance for 3 -phase separator 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 Process gas: 4887 MCF/yr Pilot Light: 3.0 MMbtu/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 Process gas: 4887 MCF/yr Pilot Light: 3.0 MMbtu/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 Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 004 Process gas: 4887 MCF/yr Pilot Light: 3.0 MMbtu/yr Page 2 005 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 --- Does this facility use control devices? X Yes No AIRS Point Process Control Device Description Reduction Granted 004 of Flare 95 Section 6 — Emission Summary (tons per year) Point NO. VOC CO SOx PM10 Single HAP Total HAP PTE: 001 2.7 90.0 14.9 --- --- 1'4 (n -hexane) 1.5 002 --- 5.7 -- -- --- 0.4 (n -hexane) 0.5 003 2.0 0.2 1.1 --- --- 0.1 (formaldehyde) 0.1 004 1.1 48.9 5.9 -- --- --- --- 005 --- 2.0 --- --- --- --- --- Uncontrolled point source emission rate: 001 2.7 75.0 14.9 -- --- 1'4 (n -hexane) 1.5 002 -- 4.8 ___ ___ --- 0.4 (n -hexane) 0.5 003 2.0 0.2 1.1 --- "' 0.1 (formaldehyde) 0.1 004 1.1 48.9 5.9 --- --- --- --- 005 --- 2.0 --- --- --- --- --- TOTAL (TPY) 5.8 130.9 21.9 --- --- 1.8 (n -hexane) 2.1 Controlled point source emission rate: 001 2.7 39.0 14.9 --- --- 0.1 (n -hexane) 0.1 002 -- 10.0 --- --- --- --- --- 003 2.0 0.2 1.1 --- --- 4.1 (formaldehyde) 0.1 004 1.1 4.6 5.9 --- -- --- 005 --- 2.0 --- --- --- --- -- INSIGNIFICANTS (TPY) 0.2 0.1 0.2 --- --- -- - TOTAL PERMITTED (TPY) 5.8 55.8 21.9 0.03 1.3 0.1 (formaldehyde) 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 I1.B.3.b APEN emission reporting requirements for non -criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Page 3 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 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 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, IIl.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 Morioxid@'and Sulfur Dioxide Page 4 004, 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. -_ , Regulation 3-APENs. Construction. P_ermits:Operatmg=.ermdsrPSD _ 004, 005 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) 004, 005 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 ll.D.2.a) Regulation 6 -.New Sduree=Performance Standard's: 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. R Regulation 7._.Uolatile 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 -41 -Hazardous AirPollutants . :, 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 Flare 20.02 lb/MCF VOC No Engineering Calculation 95 0.068 lb/MMBtu NOx No AP -42, Table 13.5-1 NA Page 5 0.37 lb/MMBtu CO No AP -42, Table 13.5-1 NA SCC 31000205 -Flares 005 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) Section 14— Miscellaneous Application Notes AIRS Point 004 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 lb/mmbtu; VOC = 0.14 lb/mmbtu) Operator did not include associated gas analysis with the application. I emailed the Operator on 8/8/12 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: VOC = (48.93 TPY * 2000)/4887 lb/MCF = 20.02 Ib/MCF AIRS Point 005 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. 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. RACT was not included in the application. I emailed the operator on 8/8/12 with a common condition the Division uses to meet compliance for fugitive RACT. Mr. Ingerson with Chesapeake called me and said that the fugitive condition is acceptable and Chesapeake will have no problems complying with it. Page 6 2 eave blan Section 02 — Re ®❑❑ Section 01- Administrative Information Chesapeake Operating, Inc. State 7-61-16-111 z z T U A a 0 E in U Change company name 3 Sec16-T7N-R61W Source Location: a ❑ Transfer of ownership Change permit limit ❑❑ v C- U a N g Address: P.O. Box 18496 in C N tein et ' CC 7.4 g-' C .2 0 0 G O a x E E .5 t; 0 .0 G 0 m o Ca Pm C o0. .0 YO N C . 0 o Y O L E 7 7. d N O 72 ,C d T '3 al L 0 C u N el k L A N z C 0 W • 0 m 0 xI 0 ct Ea C 0 G ^ C E • o N a Ca P. i`- 2 Cr a O az Oklahoma City, OK O een n It C Phone Number: G O L d0 Ca Person To Contact: ti N a cc I C Fax Number: jeffingerson@chk.com E-mail Address: Section 03 — General Information 0 0 0 st 0 N z b a 0 0 e C O P. C Oatd k. w a ..e 0,1 r, C) 0 P o O ciT o 0 • cn o .. • 0 a y % Z • CO .m 0 O O ai • z c7 0 O..-4 Oc 0- r M rcll -IA M a O b r ‘To CO R E marl marn Calm o a o0 = C 1 - ca M i E V v O N W w a es .▪ 0 o L .21 � L P z anufacturin Section 04 —Processin Description of equipme Manufacturer: a z V b' v' y 11) Cn 0 a, CO z Q z 0 0 Ut ra R d , '° a z z Q z z 0 V C O P y N a O 0 • 0 a 0. O 0 d am v O 0 O 0 0 0 O 0 [a ell o' Cr „ 2 '0 O A .0 .0 0 123-9905-004-APEN-2012-05-23-0.1 T N X N pp r R y r 0`0 O ra .G PCn Gi? R Q M{ a � 45 N N a — c O a a N Q z a O Y 0 E E a a 'O 0 0 FORM APCD-200 onent Leak Emissions E O U m Fa 0 R E G ti 0 Emission Source AIRS ID: Tz __ Section 07 —Leak Detection 8z Repair (LDAR) & p 0 c .g 8 go at 0 N t0 b 0 a 5' 0 a O a O = . 0 CO ro z -8 e 2® F O.i' P amen a era ca m a C o O c 0 0 3 U U on m.= xz Ys at G o 0 E R Q 0 z T 0 Fa .c u c C a o f o a 0 U" ❑ ❑ m N a 1/40 m- m a 2 a 413 C° cit a Y en b ca C EH o "`o Section 08 — Emission Factor Information ou do not need O 3 C7 zz z d z cv z 0 U z z z z d d a O Ca to a O L .0 a O a O a) N O O d N O an ea e O w V z en to M onducted on the foil d z Et d d z z d z d z 0 U w C U a z d z z z d d z E Ca L .0 a O u S a O Ca L a a O d z 00 0 O d C cu 0 0 CJ b h i. 0 U0 ona:. Open -Ended Lines is Ncn P~i 0 O 'Count shall be the actual or estimated number of compo sed to calculate the "Actual Calend .2 ssion Control Information a-. W L Q O CR E 0 eCi F ua 0 Co C 0. U CI) ons below (e.g. 2007): Ca a ar for actual Ca u 0 R C 0 E P 0 W d z 00z 0 H 0 o h o 0 V U O 'z d z G a) d zz d z d zz d d z d d aa _ iC z d d R a7 C 0 W Ca C 0 L 0 0 E w E O Pro d O Pi d A L O Ca a, .a Ca 0, U a 0 A d C ._. c R Pr a en ch rti 0 a' - o ga 0 as to .0 0 0 N a 0 C 0 Cc L 0 b C C Ca S CJ E 0 0 C 0 8 1 O ti a, 0. .0 .0 0 O CC W U U Section 10 A d District Mona C U b et U a 0 0 N 0 6 v a c F a U N d U N O 0 a N 0 T an N a. 0 E w. z N STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 12WE1861 Issuance 1 DATE ISSUED: ISSUED TO: Chesapeake Operating, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as State 36-3-63 1H, located in Section 36, Township 3 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 004 Plant flare used to control gas stream off of the 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/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, ll.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: 123/9904 Page 1 of 10 Condensate Tank Version 2009-1 jblicsHealth and Environment MAir Pollution Control Division application astoci it p itj%Ji) di a -s con 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 004 1.8 13.7 9.9 Point FUG1 005 --- 1.9 --- 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 24,468 MCF/yr AIRS ID: 123/9904 Page 2 of 10 bli "Health and Environment it Pollution Control Division Compliance w'k, nq,ro ® e s li a 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 ll.A.5.). 12. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. Point 005: 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 005: 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. (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: 123/9904 Page 3 of 10 f A;1blic,Health and Environment =Air Pollution Control Division (v) iegwi c Shall bbl ined f eriod 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 lll.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. 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. 17. 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 I I.A.5). 18. 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 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 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 AIRS ID: 123/9904 Page 4 of 10 bli a Health and Environment it Pollution Control Division 20. Point 004: Th or •„m .t. std 'tasa ri_tti as rout< ' the flare to determine the heat content on an annual basis. 21. 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. 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 (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. 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: 123/9904 Page 5 of 10 bli&Health and Environment it Pollution Control Division 25. If this permit spe,: esta d,,s th ut has b ranted, 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 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: 123/9904 Page 6 of 10 Issuance 1 R a is Issnaan - Per etior ) enclosed flare and associated fugitives. New synthetic minor source facility. bli ' Health and Environment it Pollution Control Division AIRS ID: 123/9904 Page 7 of 10 Notes to Permit Holder a e of l-irrper rirf lan Depa ' Gn en ;l v)f Health 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 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 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.cdohe.state.co.us/requl ations/airreqs/100102aacccom monorovisionsreq.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 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 16.54 lb/MCF 0.827 Ib/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%) 27.38% --- 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, d'aphragms, 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: 123/9904 Page 8 of 10 blikHealth and Environment Air Pollution Control Division Flanges 34 3v t=+ 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.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: 123/9904 Page 9 of 10 Depa -nen, F blic Health and Environment Air Pollution Control Division 7) An Oil and Gas Ind yCottrCertification Form.icluded 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/ao/oilgaspermitting.html AIRS ID: 123/9904 Page 10 of 10 Construction Permit Application Preliminary Analysis Summary Section 1 — Applicant Information Company Name: Chesapeake Operating, Inc. Permit Number: 12WE1861 Source Location: S36, T3N, R63W, Weld County (non -attainment) Equipment Description Point 004: Plant flare with a minimum combustion efficiency of 95%. Point 005: Fugitive emissions AIRS ID: 123-9904 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 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 004 Plant flare used to control gas stream off of the 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? 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) Milo 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 emissions; mass balance for 3 -phase separator 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 24468 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 24468 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. Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 004 24468 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 --- Does this facility use control devices? X Yes No AIRS Point Process Control Device Description % Reduction Granted Page 2 L 004 01 Flare 95 Section 6 — Emission Summary (tons per year) Point NO,VOC CO SOx PM10 Single HAP Total HAP PIE: 001 0.7 73.8 3.6 --- --- 1.1 (n -hexane) 1.3 002 --- 12.3 --- --- --- 1.0 (n -hexane) 1.4 003 2.0 0.1 1.1 --- --al 8 (formaldehyde) 0.1 004 1.8 202.4 9.9 --- --- --- --- 005 --- 1.9 --- --- --- --- --- Uncontrolled point source emission rate: 001 0.7 61.5 3.6 -- --- 1.1 (n -hexane) 1.3 002 --- 10.3 --- --- --- 1.0 (n -hexane) 1.4 003 2.0 0.1 1.1 --- --- 0.08 (formaldehyde) 0.1 004 1.8 202.4 9.9 --- -- --- --- 005 --- 1.9 --- --- --- -- --- TOTAL (TPY) 4.5 276.2 14.6 --- --- 2.1 (n -hexane) 2.8 Controlled point source emission rate: 001 0.7 39 3.6 --- --- 0.05 (n -hexane) 0.05 002 --- 10 --- --- --- 0.04 (n -hexane) 0.05 003 2.0 0.1 1.1 --- --- 0.08 (formaldehyde) 0.1 004 1.8 13.7 9.9 --- -- -- --- 005 --- 1.9 --- -- --- --- --- INSIGNIFICANTS (TPY) 0.2 0.4 0.2 --- --- --- --- TOTAL PERMITTED (TPY) 4.5 64.7 14.6 --- _.. 0.09 (n- hexane) 0.2 Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (Iblyr) Are the emissions reportable? Controlled Emission Rate (lb/yr) Note: Regulation 3, Part A, Section I1.B.3.b APEN emission reporting requirements for non -criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. 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 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 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. t Page 4 Regulation 3 - APENs,'Construction Permits, Operating P units, RS0' 004, 005 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) 004, 005 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 ILD.2.a) =:Regulation 6 -New Source=Perronriance.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. Requ-lation 7 b atile 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 (c)/0) 004 01 16.54 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 005 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 004 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 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: VOC = (202.39 TPY * 2000)/24468 MCF/yr = 16.54 lb/MCF AIRS Point 005 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. 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 1.9 TPY VOC. Page 6 uested Action (check applicable request boxes) Section 02 — Re 2 N E CL ,z� Z o- C w o C C 4-1O • s••• t N 0 0 w U, 0 et OC h 0 L O 0 ^o Request for NEW permit or newly reported emission source x 6.•G O 0. T A ❑ m 0 W V N O T O "ita E a F -4°k' o k c '"ai A. ▪ o 0 :0 L C.0 a C 7 'C E k c g et' a. o .. n • 0 o 0 E E U' V y • 0 O V 0 > w N o 1. CU o �, 60 U H • e W L o A E c P n E e ❑ ❑ Te V O Te • W L k m c6. am+ Cy @ N • U • Z S T z ' E i .3 o w k o 0. N d o • 't y at FA :0 0g Ea z m m E. 4 0 0 • 7 ti 0 0 04 U U « • d d v v C) O 0 0 0 Cr Cr LS 0 a ❑ ❑ g & ❑ ❑ N❑❑ - 0 L o 0 a U U zcn r 41. tn — M M N In 0 U N P.O. Box 18496 Phone Number: Person To Contact: N C N 00 0 Section 03 — General Information N m a 0 .0 N C 0 0 O • 0 .0 O • O. O P. • O U 7 O O wz CC p F w z Process Flare for gas stream U .2 4) a O E C 00 Y 0.0 ��'_' V M Cr, M W0 ea rn lo rn 0 o V V d U l0 .0 i0 .o 0 4" E c+t M-Th M O •≥ . L O O O „ a y C C C w 0. '0 b0 O V W CO 0 m m -» CW�yy F h 0 o �E 01 6 Q EA .k ^ 3 E vx =' • 0 a m y a o E. UP F O d e c E c .201 a Co E C P. 'o a0+. • t; ' O a OU i V 4'. 0 3 •L M O Q 0 w o g CO 0 ti al •o i 0 E Yea o ko. .8 4on .Y E a U o C o y ✓ .d E 0 .. m P U ^ 0 O 0 Q (0 Y G U o C 0 0 a' y F Vi w t k O 0 .F Vj Z is 'O^ ' .k E 0 Y o Q p .00 P.. N APEN forms: htt ill U CC 0 Application status: 0 ea CC et R E U L R O 0 m ^� C C CC e=cn a F • z`_• cc a E C C • C • 9 al 4 • a 00 • 04 0 O O V r • cn y - A E� d Ur U 'G O c� • 3� /Manufacturi Section 04 — Processin z CC V> ❑ ❑ 'z z z z 7-31 z Other Process: N N FORM APCD-200 123-9904-004-APEN-2012-05-23-01 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General EEOIE Emission Source AIRS ID: Permit Number: O C a m • a) a) .�C 0 iC 0 0 0 CO 0 Ca t C 0 2 w FC-C m d ai N 0 0 a v .. C, rr1 en e to 00 ` m A 20 a a c o` o x aa0 b teEl 00 etle z en 00 e N r -I x O. < (5 CO o 0 d en N 0 LJ .50 T c � El El ith obstructing raincap Direction of outlet (check one): 0 Exhaust Opening Shape & Size (check one): tion Information uinment & Fuel Consum Section 06— Combustion E b R CO a Manufacturer: Company equipment Identification No.: N en el e I N �tin .4 E urn 1,020 Btu/SCF 'z U en e 9 7 a. 00 M T< 0 C., L z Section 07 —Emissions Inventory Information & Emission Control Information N 0 00 0 m 0 i. 421 .0 e E g z� ° a R cen Tr. oR °' N R 'do E a 0 U a O N CO o .� u 0 U .? re o m E 0 u U Q 0 U O 0 o � - C H CO E U a❑ Estimation Method or Emission Factor Source z Q Z Q Z `E Z t `a N n FA, Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. ) Qd Requested Permitted Emissions4 Controlled (Tons/Year) s M oci Q ¢ C Z Z Z Z <1 rn cl Uncontrolled (Tons/Year) d ¢ VIN d u d 'z z 'z 'z Z z Actual Calendar Year Emissions' Controlled (Tons/Year) Jrs ' M z ¢ z ¢ z ¢ z Ia+, .i e i/ e; Q c.1 Uncontrolled (Tons/Year) Ct a z z z z zp z z Emission Factor Units e 3 e 'z ¢¢¢ z z z ..o ..o ca 0 Uncontrolled .'Basis n z z z o o a Control Efficiency (% Reduction) ¢ a a N/A a a a 2:2:2: 2:2:2: Overall Collection Efficiency z z z z z 'z Control Device Description No 0 rn z d 'z N/A V/N ¢ z N/A d z ddddddd Z Z Z Z z Z z TSP o" a a a N z> rep Er- 0 y� � o o •0 G 9 a fd 3N v tO a To 0 0e R4 tru t 0 U 2. Q c e U m RR n� m NyLe o a v w E O O 0• v 0 C) CO O ti n contained herein and information subm q -0 CI O C ¢ a0 a w a o 0 :yC U_ CO w Z Emission Source uested Action (Check applicable request boxes) Section 02 — Re G 0 C E s. H 4a L 4-4 E 'C zo. w, o C ^ O Gi Y la <44 w au C .4t a, A G G O T W A ElO s , p o a p O 0. La t y a k p m W Si 0 u.0 T O c L 1 s p y 0- 0- o E w0 E `0 .N E C v O o R E 0 p V U ' O P. d t.,", W a. O 0 s °° 0 3 w E .. Id 4 u p 0 U H w a 2 s g c e y U L N U O C. >'p O O G m L y Tic S .y N k n 0 v oP. wca v K 12 3 o as n. K E o y .5 ,@3 Q o m Q ea m 3 w o c Y E G O w Q P. P. .� z n v' a sw� o m m - �y �a c: mc�a « aTi a a A .. Nr 'a E i o U U d v c cr 0. 0 K ❑ ❑ a 4 D El 0 Chesapeake Operating, Inc. Company Name: County: Weld Sec36-T3N-63W Source Location: 0 W in r 0 U N P.O. Box 18496 Mailing Address: Oklahoma City, OK Person To Contact: ❑ c eo •0 5 z C 0 ¢ ((405) 849-2017 Fax Number: Section 03 — General Information es, the projected starhip date C6 z CC era O c m O o _0 c o a O 0 o ti Ur0 O U U L w o o y N 0 ° o v 0 0 0. v. �_ .�i £ E Z OJ U N1 (+1 en: E J C U o P�-,C °� rn rnrn o L. `° ai 2 ,o �o an -g y GA a ri �nm o 0 0 0 2.. en en en o 00,. - 'Oct 0 0 0 c Q I.V. 0 w . E y on a a �- y . CI c w tin 0 CI II Z a � � u�sa 0) < o ti •G 0. x /„�' V] 0 U o 0 Q v 6 3i O W C, 4 Y 0 R o h t •. c y a v c a 0 3 a mx s a E 0 0 w p T o a •u L '� a ,= T T p L. v O' R V] Q py .J O O d° > 2 3 'a" a > o 0 .2 0 3 aU+ - E cc Q o 44 c n3n o A� a O. 3 y �, c c 0 0 - CG1 ._ T 0 E _.'� L N .0 O N q d w 0 a L U cc o U o cu c• 0 o c. c q �' t'O 2 A t .CIIV V O 0 n g o m U 0 0 s s: ex, m c b0 P. Gi I U ri a., - , / / --CUD 0 0 0 0 0 0 ❑ ❑ ❑ ® ❑ ❑ F Section 04 - R Is this equipment subject to NSPS 40 CFR Part 60, Subpart 40 CFR Part 63, Subpart Is this equipment subject to NES P Subpart that applies to this equipment List any other NSPS or NE Section 05 - Stream Constituents est copy of draft permit prior to issuance. est copy of draft permit prior to public notice. Y C o 0 .o A'. K e Cp O k 3 de 3 I e 3 U'a o Y h m an del r-• ' N ♦+ C7 9 C r7 O M Light Oil (or. Light Liquid) O a 0 0 0 0 E i O 0. O W H ro 0 tdo P. OJ T N c 0 CdCa eat O C) ro P. t J c\.t to rs FORM APCD-203 123-9904-005-APEN-2012-05-23-01 onent Leak Emissions Permit Number: M co N N m • z Section 08 —Emission Factor Information d U 4) 40 4) z z z z z z C 7 z z z z z C 4) at z F. O U -C a OL. u t a ..7 C0 P2! U z z z z• z z a E a 00 7 z z N 40 N z z a E O .4)'0 a 111 zz z a E 4. a NO M Actual Count conducted on the following date: O GAS d '0 z 3 a za 8 s I a E u Obi b VI E I 8 0 m I Count shall be the actual or estimate A d CO C• q F 4 z z z z C C W 4) 0 U: 0 r 8 o z z z AV 80 a z j z 4) H Q. z { C z 4) C k x C 4 O is application is complete, true and correct. V- ` !HIV A. a Y o �^ u II c VI V. . N 8a a>o .0 o U N 00 U w .9. 8 u a• s g Cg a +. • 8 .0 o pis Q. u coi 4 Q o o U N• h .C O to O G N a9 u u •o y y N 8 9 '- C w 0 tiZ C 4) C d b C Ca 0 rs .E 4) u 4- d C O T 4) U 0 Section 10 A STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 1 2WEI 872 Issuance 1 DATE ISSUED: ISSUED TO: Chesapeake Operating, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as Hoff 6-62 15-1H Station, located in Section 16, Township 6 North, Range 62 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 the 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 sect), 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.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: 123/9908 Page 1 of 10 Condensate Tank Version 2009-1 Depaw•.mert bli&Health and Environment it Pollution Control Division application as p lat� it p"Prnitzi(ii) d' m s conduction 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 004 2.9 39.4 15.6 Point FUG1 005 --- 2.5 --- 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 44,253 MCF/yr AIRS ID: 123/9908 Page 2 of 10 blii, Health and Environment Air Pollution Control Division Compliance Inn limi e de tp aa�a:9ed 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 005: 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, Pad B, III.D.2.a). The requirements of condition number 14 below were determined to be RACT for this source. 14. Point 005: 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 requirementto 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. (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: 123/9908 Page 3 of 10. bli!Health and Environment Air Pollution Control Division (v) wi cids fall ,;?ined *aperiod 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 004: The operator shall complete an initial site specific extended gas analysis of the natural gas produced at this site that is routed totheenclosed 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 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 I I.A.5). 18. 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 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 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 AIRS ID: 123/9908 Page 4 of 10 20. Point 004: The - heat content on an annual basis. !bli Health and Environment it Pollution Control Division ante - +,-s ro to the flare to determine the 21. 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. 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: 123/9908 Page 5 of 10 Depanen` bli Health and Environment it Pollution Control Division 25. If this permit s fic Est- h f,' .ut has be igranted, 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 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 AIRS ID: 123/9908 Page 6 of 10 bli Health and Environment it Pollution Control Division Issuance Date Description Issuance 1 This Issuance Permit for: (1) enclosed flare and associated fugitives. New synthetic minor source facility. AIRS ID: 123/9908 Page 7 of 10 Notes to Permit Holder a tl a ofl erhitn nan 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/reoulations/airreas/100102aocccom monprovisionsreq. pdf. blid'Health and Environment it Pollution Control Division 3) The emission levels contained in this permit are based on the following emission factors: Point 004: CAS # Pollutant Emission Factors Uncontrolled Emission Factors Uncontrolled Source NOx 0.068 lb/MMBtu 0.068 lb/MMBtu AP -42, Table 13.5-1 CO 0.37 Ib/MMBtu 0.37 lb/MMBtu AP -42, Table 13.5-1 VOC 30.5 lb/MCF 1.525 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 SWater/Oil ervi Service Connectors --- --- --- --- Flanges 55 --- 6 --- Open-Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- VOC Content (wt%) 42.38% 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 Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 AIRS ID: 123/9908 Page 8 of 10 Color; Depa bile= Health and Environment it Pollution Control Division Flanges Aso, 301&44mtala 31 = 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.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: 123/9908 Page 9 of 10 blid9Health and Environment ''Air Pollution Control Division „mw 7) An Oil and Gas Ind oAtruct ,P elf Cerbifacrahon Form i rluded 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/oiloaspermittinq.html AIRS ID: 123/9908 Page 10 of 10 Construction Permit Application Preliminary Analysis Summary Section 1 — Applicant Information Company Name: Chesapeake Operating, Inc. Permit Number: 12WE1872 Source Location: S15, T6N, R62W, Weld County (Non -Attainment) Equipment Description Point 004: Plant flare with a minimum combustion efficiency of 95%. Point 005: Fugitive emissions AIRS ID: 123-9908 Date: August 22, 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. / received the 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 24, 2012 Section 4 — Source Description AIRS Point Equipment Description 004 Plant flare used to control gas stream off of the 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? x Yes No If "yes", for what pollutant? PM10 CO X 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) PKo CO Ozone Is this source located in the 8 -hour ozone non - attainment region? (Note: If "yes" the provisions of Regulation 7, Sections Xil and XVII.C may apply) X Yes No Section 5 — Emission Estimate Information AIRS Point Emission Factor Source 004 AP -42, Table 13.5-1 for combustion emissions; mass balance for 3 -phase separator 005 EPA -4531R-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 44253 MCF/yr Pilot: 3.0 mmbtu/hr 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 Inventorvt AIRS Point Process Consumption/Throughput/Production Data Year 004 44253 MCF/yr Pilot: 3.0 mmbtu/hr 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 Permitted Emissions (Permit Limits1 AIRS Point Process Consumption/Throughput/Production J 004 44253 MCF/yr Pilot: 3.0 mmbtu/hr 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 --- Does this facility use control devices? X Yes No Page 2 AIRS Point Process Control Device Description Reduction Granted 004 of Flare 95 Section 6 — Emission Summary (tons per year) Point NO. VOC CO SOx PM10 Single HAP Total HAP PTE: 001 2.7 93.0 14.9 --- --- 1'4 (n -hexane) 1.6 002 --- 8.9 --- --- 0.7 (n -hexane) 1.0 003 (XP) 2.0 0.2 1.1 -- '-- 0.1 (formaldehyde) 0.1 004 2.9 674.9 15.6 --- --- - --- 005 --- 2.5 --- --- --- --- -- Uncontrolled point source emission rate: 001 2.7 77.5 14.9 ------ 1'2 (n -hexane) 1.3 002 --- 7.4 0.6 (n -hexane) 0.8 (XP) 2.0 0.2 1.1 --- --' (formaldehyde) 0.1 004 2.9 674.9 15.6 --- --- -- -- 005 --- 2.5 --- --- --- --- --- TOTAL (TPY) 7.6 762.5 31.6 --- --- 1.8 (n -hexane) 2.2 Controlled point source emission rate: 001 2.7 39.0 14.9 --- --- 0.1 (n -hexane) 0.1 002 --- 10.0 --- --- --- --- --- 003 (XP) 2 0 0.2 1.1 --- -_- 0.1 (formaldehyde) 0.1 004 2.9 39.4 15.6 --- --- --- --- 005 --- 2.5 --- --- --- --- --- INSIGNIFICANTS (TPY) 0.2 0.10.2 --- --- --- --- TOTAL PERMITTED (TPY) 7.6 91.1 31.6 --- --- 0.1 (n -hexane) 0.2 Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (Iblyr) 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 004 01 VOC, HAPS State only requirement Site -specific gas analysis 005 01 VOC, HAPS State only requirement Site -specific gas analysis Page 3 005 0� VOC, HAPS State only requirement Hard component count 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 X NA NSR X MACT Is this a modification to an existing permit? Yes X No If "yes" what kind of modification? Minor Synthetic Minor Major Section 10 — Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If "yes", for which pollutants? Why? For Reg. 3, Part B, III.C.1.a (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 Regulation '3-APENs. Coittruction'Permits. Operating Pertillts._P-SD."""" 004, 005 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) 004, 005 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 H.D.2.a) Regulation 6-N"ew_SoureePerformance 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—VolatiltO.rganic 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. Requfetion 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 30.5 lb/MCF V0C No Engineering Calculation 94.17 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 005 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 004 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 lb/mmbtu; VOC = 0.14 lb/mmbtu) 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 from the operator but it did not match the calculations. When I talked to the consultant, a gas analysis performed on 2/20/12 was used to calculate the emissions (the operator sent me a gas analysis performed on 5/31/12, which was after the receiving date of the application). So, I used the gas analysis dated 2/20/12. 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: VOC = (674.88 *2000)/44253 = 30.50 lb/MCF AIRS Point 005 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 accidentally submitted a duplicate APEN from another facility. I revised and redlined the APEN to match the Hoff 6-62 15-1 H Station. 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 from the operator but it did not match the calculations. When I talked to the consultant, a gas analysis performed on 2/20/12 was used to calculate the emissions (the operator sent me a gas analysis performed on 5/31/12, which was after the receiving date of the application). So, I used the gas analysis dated 2/20/12. 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 2.5 TPY VOC. RACT was not included in the application. I emailed the operator on 8/8/12 with a common condition the Division uses to meet compliance for fugitive RACT. Mr. Ingerson with Chesapeake called me and said that the fugitive condition is acceptable and Chesapeake will have no problems complying with it. Page 6 Emission Source APCD has already assigned a permit # & AIRS ID] .0 -o 0 0 N 0 0 0 0 0 c 151 0 0 0 6 L 0 0. 0 Ca M r. 0 c ca u 0 N .0 on 0 0 u L 0 L °- = C0 m 0 U 0 0 O Ill u. E W 4 d c .? U ¢ w a z a A Section 02 — Re Section 01 — Administrative Information L En 0 = ° o ) Nr ® ❑ ❑ Chesapeake Operating, Inc. Company Name: Source Name: Hoff 6-62 15-111 Station Change company name O Transfer of ownership ❑ ❑ Change fuel or equipment CC O t o a 0 0 K Cit — G 0 G ° y E 6 Z 0 4 3 ° c m G m n ., N_ U 0 r d Y ria v G Y C 0 W a ° 0 d 0 " 0 U 7 "0 CO O . 0 ° Y m 8 w C !n o "9 ppy v° o o d >0 CA 4 U P 2 u m Cr 0'4 ❑ ❑ ai 4OO o ❑❑ P,O. Box 18496 Oklahoma City, OK 73154 r- eel C\ to e Phone Number: C 0 Ca CC 4- W fJ Person To Conta 'e n 9 O a4z jeff.ingerson@chIc.com Eta 0 Po 0 Q CO W Section 03 — General Information C 52 weeks/year Q z 0 ES C 0. C � o0n o `- ,0- p, a o0 O O 4+ 0 0 K v w o b o a 0 U .416 OP .21 O O C 0 0 0. z � E 0 L tci T c O 0 y u q P ° C a O CCG ° o E T. ^° v L 0 O R U U a .9 E O.1 z0w F 0 O y 0 U a Y C O °p 0 9 y ° N cn CC 0 0 3 E 0 0, • c C N O > w 3 w O C o 0 T a >o o >> y 4.9 .. O O o C a o 0 G m y~ U - X G F N'i APEN forms: httn://wwi he.state.co.us/an/ss/ss 0 5 Application status: htt CC R merit Information & Ma CC Fa /Manufacturin Section 04 — Processin a 0 0 0 a a Model No.: N/A z Manufacturer: CC d z d z Q d Q d zz d U 0 G .0 9 0 R 0 0 •0 • 0 a a • P. �O 0 •o v` w 0 O O 0 0 0 0 a+ ut 0 P ' 0' U 0 00 0 A .0 u u ❑ ❑ 0 to 0 G _o 0 P 0 0 r u .0 N0 011 E E El- � t v m U cae AC ea a z z z z y O 0 E o d z O 4 0 123-9908-004-APEN-2012-05-24-01 N 0 04 a CO CD CYS r•- FORM APCD-200 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Pe Emission Source AIRS ID: Permit Number: Section 05 — Emission Release Information (Attach a separate sheet with rele o C C co N Q 0 e ti M N en eel a II O a ca s U ❑ L., 00 0 1.4 C � ❑ Vertical with obstructing raincap Direction of outlet (check one): N Circular: Inner Diameter (inches) _ ion Information ment & Fuel Consum Section 06 — Combustion E O 0 Fa w ro N O C Company equipment Identifica O O O Ca o v 0 N N .O3 o CU. 0, x zz d cnz 1,020 Btu/SCF eg 0 a 0 04 b e. a) • a a a Q < Natural Gas s. Requested level should consider process growth over the next five years. Section 07 —Emissions Inventory Information & Emission Control Information C 0 m c _G 0 7. 0 C 0 a OO Cr, x-." z 75, c 0 ,(1% o s. 0 E O 0 ro 0 E b R .2 .W, O 0 °s 0 a O t O ct o C m 8 U ❑ s a Estimation Method or Emission Factor Source d 2- Q -2 N/A Q z AP -42 G� i\4 a� N Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions4 Controlled (Tons/Year) N/A ; y^, d d N to led m z -z-'zMi_� a ni Uncontrolled (Tons/Year) V/N r d 2:2:2: d ¢ ¢ Z a a Actual Calendar Year Emissions3 `. Controlled (Tons/Year) zz'z'2M,-: Uncontrolled I (Tons/Year) A Emission Factor C O Q z Q z d z d z a G Jo i Uncontrolled Basis Q z a z d 'z Q z O o rl o M d. Control Efficiency (% Reduction) z Q z •z Q z Q z Q z z Overall Collection Efficiency d zz 'z d zz d zz d z d z Q z Control Device Description 1 'c,::. 8 z Q z d z Q z V/N d z d z' P 5 •c,zzzzzz Q Q -Q Q Q- Q d 0 3 o ti a a cn z I DOA 11 C) u ac lication is complete, true and correct. ro s n contained herein and information submitted wit Section 08 —. v District Mona a F N CC 'G 00 .C U u �> �i ra O O y s m az N 0 N • N) QI Leak Emissions •11 o a c O T R CA .ace ❑ o YU. c F R en 0 k i° 0 F" .. F y F A O u L T O 0 6 C .`C. .0 '- s m . c c 9 H 7 R 5w a o y £' 0 O 0: 0 U = O y O a U 0, y.0 m y cC a O d N 4 U O i-4. '" U H c. N m u a c e 0 I. d a c❑❑ � � 0 0 CL)R Y a T c >. 3 o o U W c o c _ 0 c i > F o O c o W F F o 0 3 y 0 d o 3[] w 0 .E o �. d y .4 O . R Z g y in d 3 Y Q b0 b0 E W W /-i R R i N 6R a 4 O4) U 0 0 PO4 r a g0 g ❑ ❑ a a Ill c. ® ❑ ❑ ❑ aSz Section 02 — Re Section 01— Administrative Information ❑ p • zz T O N 1 E O U d Source Location: 0 } c~1, V 0 II) t-- P.O. Box 18496 `0, tan Oklahoma City, OK Person To Contact: jeffingerson@chk.com E-mail Address: Section 03 — General Information PO 0 O C CO C `. O 0trj ^O Q P. 0 i °o o a C"O4 O O y F C.< u wO Z C 0 a O OO 0 U 0 R O Te Brief description of equip O b0 0 0 0 q 3 .O e rip' co h O U 0, CA 79. ra go 04 w Q En cdohestate.co.us/a C L he.state.co.ns/a E H o w a �¢ d C Q C p C p to 3,933 ❑ ❑ ❑ Information 0 a Section 04 — Re ❑ ❑ Is this equipment subject to NSPS 40 CFR Part 60, Subpart 40 CFR Part 63, Subpart Is this equipment subject to NES P Subpart that applies to this equiprnen List any other NSPS or NE Section 05 - Stream Constituents 0 • C g 0 .O N Q 00 0 0 a a C Check box to request copy of draft pe ❑ ❑ n -Hexane (wt. %) I I ce U ,7„, 3 Ethylbenzene'. (wt. %) : I O- c c c H 8 I I I f Benzene (wt. %) 4 U e Q . 3 ' c a e e - ' f I E at U a -.' ci Heavy Oil(or Heavy Liquid) Light Oil (or Light Liquid).. Water/Oil c N - w U 0 a) C � 0 FORM APCD-203 123-9908-005-APEN-2012-05-24-01 (APEN) & Application for Construction Permit — Fu MR POLLUTANT EMISSION NOTICE Emission Source AIRS ID: Permit Number: of Informatio Section 07 —Leak Detection & Re n 06 — Location Information (Provide Datum and either Lat/Long or UTM) m 0 O pNro E ;. c 0, 0 a b O > C ,e ,T3 b N " > A > a a ,0 a 0 m 0 t 0 3 0ab jab 49a Ec= v;m m' o v 0 m o 0 v C•9 o NN o 0 1/4,40 b -104.319222 z Section 08 — Emission Factor Information U et CI di uS Q z C CJ c F-. z z d c 0 Ca .0 d 0, 0 u L a c 0 r .0 c 0 .0 'z 0 C C CO C N C 0 0 0 0 b M In M :ond U a z O E N z z Q d d z a z z z E 0 V t .C z E 0 V S E 0 V C- .0 E 0 V .0 wi Q e m 0 0 Q m 0 00'0' 0 0 a 0 a U 41, z O N en O d U Open -Ended Lines m Ct C: C each type o£ service used to calculate the "Actual Calendar Year Emissions" halo ation & Emission Control Information Section 09 — Emissions Inventory Infor below (e.g. 200 Ca Ca an Documentatio 0 E stimation Method 0 0 w 8 '4'1 CC 9 w a zz z zz zz b o ° 0 Q z d z Q d z Q Th a d z Emission Factor Control Device Description e d w 0 0 x 0 CO c i C X a q 0 C N 0 0 0 c k ti e a m 0 0 0 0 L 0 L 0 S e c at c a Q .0 L C. a Oa `Ca 0.4 z 0 d Ci W 0 a n 0. 51 on o e0 0 ed Em 0. 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: 12WE1866 Chesapeake Operating, Inc. Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as Wagner 11-65 9-1 H, located in Section 9, Township 11 North, Range 65 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 the 3 -phase separator. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. FUGI 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/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: 123/9712 Page 1 of 9 Condensate Tank Version 2009-1 blilHealth and Environment it Pollution Control Division application as ated✓itl tf1is p tii) danti` s constr trtion 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 1.4 12.9 7.4 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 12,775 MCF/yr AIRS ID: 123/9712 Page 2 of 9 blic!Health and Environment it Pollution Control Division Compliance w' bnn roh}t IinTt `' a 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, IIF.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: 123/9712 Page 3 of 9 Color Depa ner if F iblic-Health and Environment Air Pollution Control Division the gas and ligi,asarielyse'syan ionapyrations to Division 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. 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: 123/9712 Page 4 of 9 blid Health and Environment s'Air Pollution Control Division 22. This permit an array ac is e r ' d . d ma 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. By: Stephanie Chaousy, PE Permit Engineer AIRS ID: 123/9712 Page 5 of 9 bli&Health and Environment it Pollution Control Division Air Polly ,dntrol,,Rivisi Permit Histor Issuance Date Description Issuance 1 This Issuance Permit for (1) enclosed flare and associated fugitives. New synthetic minor source facility. AIRS ID: 123/9712 Page 6 of 9 Notes to Permit Holder e" . e of permit -is an 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 Pad II.E.1 of the Common Provisions Regulation. See: http://www.cdphe. state.co.us/regulations/airregs/100102aucccom m onprovisionsreq.odf. 3) The emission levels contained in this permit are based on the following emission factors: Health and Environment it Pollution Control Division Point 004: 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 41.57 lb/MCF 2.08 lb/MCF Engineering Calculation f Note: The controlled emissions factors for point 004 are based on the are control efficiency o 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 Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 AIRS ID: 123/9712 Page 7 of 9 blic1Health and Environment it Pollution Control Division Flanges AE -04 2.9E-06 34g:04 3ati0gazi • 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 PSD 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.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: 123/9712 Page 8 of 9 Health and Environment it Pollution Control Division 7) An OH and Gas IndFormncluded 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: 123/9712 Page 9 of 9 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Chesapeake Operating, Inc. Permit Number 12WE1866 Source Location: S9, T11N, R65W, Weld County (Attainment) Equipment Description Point 004: Plant flare with a minimum combustion efficiency of 95%. Point 005: Fugitive emissions AIRS ID: 123-9712 Date: September 13, 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 004 Plant flare used to control gas stream off of the 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? Milo 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,() 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 emissions; mass balance for 3 -phase separator 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 9793 MCF/yr 005 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 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 9793 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 Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 004 9793 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 --- 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 Tl HAPota PTE: 001 2.7 67.2 ' 14.9 --- --- 1.0 (n -hexane) 1.2 002 --- 11.7 --- --- --- 1.0 (n -hexane) 1.3 003 2.0 0.1 1.1 --- __ 0.08 (formaldehyde) 0.1 004 1.4 203.6 7.4 --- --- --- -- 005 --- 3.0 --- --- --- --- --- Uncontrolled point source emission rate: 001 2.7 56.0 14.9 --- --- 0.9 (n -hexane) 1.0 002 --- 9.7 --- -- --- 0.8 (n -hexane) 1.1 003 2.0 0.1 1.1 --- "-0.1 0.08 (formaldehyde) 004 1.4 203.6 7.4 --- --- --- --- 005 --- 3.0 --- --- --- --- --- TOTAL (TPY) 6.1 272.4 23.4 --- --- 1.7 (n -hexane) 2.2 Controlled point source emission rate: 001 2.7 39 14.9 --- --- 0.04 (n -hexane) 0.05 002 --- 10 --- --- --- 0.04 (n -hexane) 0.05 003 2.0 0.1 1.1 --- _-- 0.08 (formaldehyde) 0.1 004 1.4 12.9 7.4 --- --- --- --- 005 --- 3.0 --- --- --- --- --- INSIGNIFICANTS (TPY) 0.2 0.4 0.2 --- __ _-- --- TOTAL PERMITTED (TPY) 6.1 65.0 23.4 --- _.. 0.08 (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 (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 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 facility classification? True Minor X Synthetic Minor Major Classification relates to what programs? X Title V X 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? Yes X No If "yes", for which pollutants? Why? For Reg. 3, Part B, III.C.1.a (controlled emissions increase > 25/50 tpy)? Yes X 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)? Yes X 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 v< < 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. _._ .4 _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 - Rea ulation 3-APEI€,=:Construction Permits. OA'eratinq=Permits;wPSO` 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) R Regulation S=New So.urce-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. Requlatron 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 A PdlfeataPts — . 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 41,571b/MCF VOC No Engineering Calculation 95 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 005 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 004 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 Ib/mmbtu) Operator did not include associated gas analysis with the application. I emailed the Operator on 8/15/12 for the gas analysis. I received a correct gas analysis on 10/25/12. 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: VOC = (203.55*2000)/9793 = 41.57 Ib/MCF AIRS Point 005 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. 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 3.0 TPY VOC. Page 6 0 C C i O U O 023 z w U H 1--1 O O Emission Source [Leave blank unless APCD has already assigned a permit # & AIRS ID] nested Action (check applicable request boxes) Section 02 — Re m m P., Lai CC emission source en en o0 U U z5 Chesapeake Operating, Inc. Company Name: Change company name Transfer of ownership ❑ ❑ Change fuel or equipment I ❑ ❑ 0 i o g o o U o LU 0 Ima 0 0' v 0 E 00 a ❑ ZIP Code:. 73154 P.O. Box 18496 ' y m 0 o m o v E Q .Ox bo 0 Oklahoma City, OK 73154 ❑ Person To Contact: R E a a a o ¢�z jeff.ingerson@chk.com E-mail Address:. Section 03 — General Information onstructed sources, the projected 0 c w N N 0 N m 8' a O m o ro C C F P. R C '0 0 o a O U W Q O 0 o o a al a U N a m E o o 3. c 0 ..0 0.� W to g V Q O g W N 4 G p�G it cn C . 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N 0 0 C"1 CO pC�� Z gio C\1 FORM APCD-200 AIR POLLUTANT EMISSION NOTICE (APEN) &Application for Construction Per Permit Number: m O -gyp , 0 0 tic a0 ) Z. gen F o 0 ]N 00 R O rl en O e I - a z M 00 O ti 5 0 M b to ® Vertical ❑ Vertical with obstructing rain ® Circular: Inner Diameter (inches) = Lion Information meet & Fuel Consum .E Section 06 — Combustion E co O Manufacturer: p w e QWI N m 3 0 U ' C d z 0 'a U g O r4 .5 m pp b0 C W C o 7 W w T. 0 CI O Ct R m T N ct tU I ko a -o 0 -0 F b m O H H a a 3 a pW 0 0 0 C V 'OO CO U W O H C Co 0 J 0 . C ' Estimation Method or Emission Factor Source ¢ Z a z d z Q z < I I. Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above,.,. Requested Permitted Emissions° Controlled (Tons/Year) s z z z zz - e6 i. n o. -O -o N at ¢ ¢ a d ¢ 1¢ ¢ g..o z z z z z Z`i z P Actual Calendar Year Emissions3 Controlled (Tons/Year) ≥ .y 7 z z z z .-i? <4 ca V Uncontrolled (Tons/Year) . ¢ z a z d z d zz ¢ zz 6 z b. - ¢ z Emission Factor Units Y/N c. Z z z 1 1 Uncontrolled Basis ¢ N/A N/A ¢ 2 C a 4 I"- 0 Control Efficiency (% Reduction) 2:2:2:2:2: ¢ ¢ ¢ a N/A 'z Overall Collection Efficiency d d d a d z 'z zz 'z z 'z z Control Device Description Secondary ¢ 'z ¢ z ¢ z ¢ z -.:-,I z ¢ z m ¢ ¢ ¢ ¢ d ¢ d w z z z z z z zz Pollutant TSP k U O L L O is G N CO R G C Q O 7 w U y L Q h IS. A Pi Eac 'K : .a 3 b N .0 h O) O CC L a a 0) i b 1 G Y 0 O O E W C CC R s N U L O O U Y s+ F 0 Section 08 — Richard K. McClanahan O d O U 'F4 Q a can 0 0 ' Q T C. •� a• ~ C E 3 CA 0.4 A c „ � e 4 Q U 332, O € o w a AT Q 9 C v O 0 E C- ul w 3a w Facility Equipment ID: Section 02 — Re Section 01— Administrative Information Request for NEW permit or newly reported emission source Company Name: Chesapeake Operating, Inc. Source Name: Wagner 11-65 9-1H Source Location: Sec9-T11N-R65W <11 a 0 W ble limit on PTE 1a V C) d 'C Request to limit U, en 0 U p. N P.O. Box 18496 Oklahoma City, OK Person To Contact: T C) O p a 0 a g, O m v O 3 5 W C yC • W X. am ❑ a IS - 4 0 z ((405) 849-2017 Fax Number: j eff. ingerson@chk.com Section 03 — General Information CD N ri 7 days/week a 0 .O 0 c o m 0 rd C w 0 O d O N O O co w a 0 o k W w z C 0 c C 0 ,C E O aW a a 0 C a A co c X d 'a 33 3 .5 -a -fa) o c C) m a 8 N -8 0 0 0 4' o o -2 g - y et o v w c9 2 E a'O z N W 'OO Y z m O -c p E O E zO.-c-; M ;, ;,E C) � C) 0 N N N 4 N N Cp] c'C b ;g:' '� O b O M M M ca. y F Q . O O O .Wp W > . . L ...,�v 5 c Q .0. 0 y. '> o ro _ ,,,,..a..5 c U o a a w to = 00 m N°Y= z .. p Ta G W 0 of w y p A �i .L+ o wV q s 6 , U p W. V FO N a' Y •C pJ a 8,0 o >+ o a c zz .._, A a' cat .aa z V EG p O -a o C"' o r.. O L M 0 .J U ..≥ i o o C F G 7 o CQ 0 3 73. 41 0go — v T o _o E i e o a y 3_ Q al L_. i U W L NO �+ O y a N O' EA g a. y La .0 E a'y V 00 O U r^. a O ,0. V •2 T CC i U 'WO eO. 77 =1 5,— z .. 0 p pUp.�, o c m P. W W a H m'� "UQ vO w .<- Q Q Information ection 04 - R ❑ ❑ Is this equipment subject to NSPS 40 CFR Part 60, Subpart 0 CFR Part 63, Subp equipment Subpart that applies to this equipment: List any other NSPS or NE Section 05 - Stream Constituents Identify the VOC & HAP content of each applicable stream. Check box to request copy of draft permit prior to issuance. xi a c e cm Co 0 3 ca w : N O o o O k c O C4 a 0 a Check box to request copy of draft permit prior to public notice. FORM APCD-203 a O E E O v AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit - Fu Emission Source AIRS ID: Information Section 07 —Leak Detection & Re 0 ca a� a L C m Q b R a a 4. 5a al a 0 U O 0 0 0 cep N o ) tio d t m 0 a. leak definition: E C wh N j C ‘.O.o N j a a m m m o e r- 0 x a O 3 u th rea L7 CO 0 0 e 0 Section 08 —Emission Factor Information w a U tat a L tat a z 44444z a d d a a s N/A a d d z ' z a z a z ad z z a z G E 0 L E 0 a E 0 E 0 .0 w 0 O CO O O O 1.4 O a 0 en a a a a O 0 a a CO M N a 0 a Q 0 Estimated Count d z a z a U d a z d z d z a 0 .0 r a 0 E U L E U L Vi a 0 c E 0. b 0 0 a 0 en O 0 Cs ca N 0 N M V 0 U Open -Ended Lines a 0 cn a a 0 Section 09 — Emissions Inventory Information & Emission Control Information £rm a' .9 t- ya 0° C a N O a a or actual calendar year e >, Ca u 0 E_ sion Factor D 2-4 0 a U V a W z z zz z zz z d z 'z d z z 'z N Q z z Emission Factor Control Device Descript a m en a 0 a C 0 O N a) ro a F a) a) ,30 W G X N N G O info. in Sec. 03 - to ntained herein and information submitted with this Certification - I. hereby certify that all information c be Richard K. McClanahan N aa H c a a 0 ell 'O 4) 0 N m i-7 0 cd Z a W CD-203-FugitiveComponentLeaksAPEN-V er.9-10-2008.doe STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 12WE2038 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 Heiby 18-8-66 1H, located in Section 18, 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 FL -2 004 Plant flare used to control gas stream off of the 3 -phase separator. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. FUG 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/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: 123/9949 Page 1 of 10 Condensate Tank Version 2009-1 A ,Color4 Depa bliciHealth and Environment it Pollution Control Division application as ® it p j (ji) di s as con Lion for a period of eighteen months or more; (Hi) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, 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 FL -2 004 1.1 6.4 6.1 Point FUG 005 --- 2.8 --- 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 FL -2 004 Natural gas flaring 4,992 MCF/yr AIRS ID: 123/9949 Page 2 of 10 blic!Health and Environment it Pollution Control Division Compliance w' la n ro e - li ha19 be deter_ 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 005: 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 005: 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 requirementto 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. (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. (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: 123/9949 Page 3 of 10 Health and Environment it Pollution Control Division (v) e.fallnwi ccdsk hall bum '.fined for 2period 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 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. 17. Point 004: The owner or operator shall demonstrate compliance with Condition 11 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5). 18. 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 that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the gas and liquids analyses and emission calculations to the Division as part of the self -certification process to ensure compliance with emissions limits. 19. 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 AIRS ID: 123/9949 Page 4 of 10 blio'Health and Environment Air Pollution Control Division 20. Point 004: The ,aerror .,A t fksami t ,- s rou o the flare to determine the heat content on an annual basis. 21. 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. 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 ILB upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. AIRS ID: 123/9949 Page 5 of 10 Health and Environment it Pollution Control Division 25. If this permit sp ' ' st ha` 4i ut 'z has b j ranted, 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 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 Page 6 of 10 AIRS ID: 123/9949 Issuance 1 AIRS ID: 123/9949 bli °Health and Environment it Pollution Control Division ;Penn) ® ) enct®7. : ® flare and associated fugitives. New synthetic minor source facility. Page 7 of 10 bli&Health and Environment it Pollution Control Division Notes to Permit Holder e- ittie of :er nor %uance. 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.stote.co.us/regulations/airregs/100102aacccom m onprovisionsreq.odf. 3) The emission levels contained in this permit are based on the following emission factors: Point 004: CAS # Pollutant NOx CO VOC Emission Factors Uncontrolled 0.068 lb/MMBtu 0.37 lb/MMBtu 33.29 lb/Mcf Emission Factors Controlled 0.068 Ib/MMBtu 0.37 lb/MMBtu 1.664 lb/Mcf Note: The controlled emissions factors for point 004 are based on the flare control efficiency of 95% Source AP -42, Table 13.5-1 AP -42, Table 13.5-1 Point 005: Engineering Calculation Component Connectors Flanges Open -Ended Lines Pump Seals Valves Other VOC Content (wt%) 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): Gas Service 55 10 50 13 47.49% 0.1278% 0.1298% 0.0073% 0.0378% 0.6302% Heavy Oil Light Oil 6 3 5 3 100% Water/Oil Service Component Connectors Flanges AIRS ID: 123/9949 Gas Service 2.0E-04 3.9E-04 Heavy Oil 7.5E-06 3.9E-07 Light Oil 2.1E-04 1.1E-04 Water/Oil Service 1.1E-04 2.9E-06 Page 8 of 10 Health and Environment it Pollution Control Division a as Open-ended Line 2 3_ 1-. i E-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 8.5E-03 3.2E-05 7.5E-03 1.4E-02 ource: 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: httn://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 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. AIRS ID: 123/9949 Page 9 of 10 blic Health and Environment it Pollution Control Division Further guidanc o sett aiiv ' foL n on our website at: http://www.cdphe.state.co.us/ap/oilciaspermittinct html AIRS ID: 123/9949 Page 10 of 10 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Chesapeake Operating, Inc. Permit Number: 12WE2038 Source Location: S18, T8N, R66W, Weld County (non -attainment) Equipment Description Point 004: Plant flare with a minimum combustion efficiency of 95%. Point 005: Fugitive emissions AIRS ID: 123-9949 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? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no" to any of the above, when did you mail an Information Request letter to the source? Received new calculations on 12/21/12 for VOC emissions (including separator emissions) On what date was this application complete? June 11, 2012 Section 4 — Source Description AIRS Point Equipment Description 004 Plant flare used to control gas stream off of the 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? PKo CO Ozone Is this location in an attainment maintenance area for any criteria pollutant? Yes X No If "yes", for what pollutant? (Note: These pollutants are subject to minor source RACT per Regulation 3, Part B, Section III.D.2) PM,o CO Ozone Page 1 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 and AP -42, Table 1.4-1 for. combustion emissions; mass balance for 3 -phase separator 005 EPA -453/R-95-017, Table 2-4 Did the applicant provide actual process data for the emission inventory? Basis for Potential to Emit (PTE) X Yes No AIRS Point Process Consumption/Throughput/Production 004 4992 MCF/yr Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or _ Light Liquid) Water/Oil Connectors --- --- --- --- Flanges 55 _ --- 6 --- 005 Open -Ended Lines --- --- -' --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- O Other 13 --- 3 --- Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 004 4992 MCF/yr Water/Oil Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Connectors --- --- --- --- Flanges 55 --- 6 --- 005 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 004 4992 MCF/yr Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors --- --- --- Flanges 55 --- 6 --- 005 Open -Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- - Does this facility use control devices? X Yes No % Reduction AIRS Point Process Control Device Description Granted 004 of Flare 95 Page 2 Section 6 — Emission Summary (tons per year) Point NO,, VOC CO SOx PM10 Single HAP Total HAP PTE: 001 2.7 34.5 14.9 --- -- 0.5 (n -hexane) 0.6 002 --- 1.7 --- --- --- 0.14 (n -hexane) 0.2 003 2.0 0.1 1.1 --- --- 0'08 (formaldehyde) 0.1 004 1.1 83.1 6.1 -- --- -- -- 005 --- 2.8 --- --- --- --- --- Uncontrolled point source emission rate: 001 2.7 28.8 14.9 -- --- 0.4 (n -hexane) 0.5 002 --- 1.4 --- --- --- 0.12 (n -hexane) 0.2 003 2.0 0.1 1.1 --- -" 0.08 (formaldehyde) 0.1 004 1.1 83.1 6.1 --- --- ___ --- 005 --- 2.8 --- --- --- --- --- TOTAL (TRY) 5.8 116.2 22.1 --- --- 0.5 (n -hexane) 0.8 Controlled point source emission rate: 001 2.7 39 14.9 --- --- 0.02 (n -hexane) 0.02 002 --- 10 --- --- --- 0.01 (n -hexane) 0.01 003 2.0 0.1 1.1 --- 0.08 (formaldehyde) 0.1 004 1.1 6.4 6.1 --- --- _-_ -- 005 --- 2.8 --- --- --- --- -- INSIGNIFICANTS (TPY) 0.2 0.2 0.2 -- --- --- --- TOTAL PERMITTED (TPY) 5 8 58.3 22.1 ___ ___ 0.08 (formaldehyde) 0.1 Section 7 — Non -Criteria / Hazardous Air Pollutants Uncontrolled Emission Rate (Ib/yr) Note: Regulation 3, Part A, Section I1.B.3.b APEN emission reporting requirements for non -criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Pollutant CAS # BIN Are the emissions reportable? Controlled Emission Rate (Ib/yr) 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 Section 9 — Source Classification Is this a new previously un-permitted source? Yes No Page 3 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 X NA NSR MACT Is this a modification to an existing permit? Yes X No If "yes" what kind of modification? Minor Synthetic Minor Ma or I 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 Reouiation.l- 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` "r 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 • 'fLegulation 3 - APENs, Construction Permits. Operating= -Permits; PSD 004, 005 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) 004, 005 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 ll.D.2.a) Reoulation 6:-:NewSource 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. , Reau►at►on.7 Volatile Orgarrtic 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 -- Haim dour Air ollutants 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 (YIN) Emission Factor Source Control (%) 004 01 30.5 lb/MCF VOC No Engineering Calculation 92.37 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 005 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 004 Flare Permit issued because emissions are greater 1 TPY for APEN, and the facility is permitted over 5 TPY CO (Regulation 3, Part B, Section II.D.2.e). NOx and CO (from AP -42, Chapter 13, Table 13.5-1 (NOx = 0.068 lb/mmbtu; CO = 0.37 lb/mmbtu; VOC = mass balance) for the flare stream. 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 from the operator but it did not match the calculations. When I talked to the consultant, a gas analysis performed on 2/20/12 was used to calculate the emissions (the operator sent me a gas analysis performed on 5/31/12, which was after the receiving date of the application). So, I used the gas analysis dated 2/20/12. 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 VOC = (83.08 * 2000)/4992 = 33.29 lb/MCF AIRS Point 005 Fugitive emissions A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit threshold). 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 2.8 TPY VOC. Page 6 N ac ea O O A m O C' QI I:[... co ea I a a ° _ C o 0 u Pr O .£ A O 0 0 on .J C o u hI o M c Q he v m :G -o V) • u C W y U a o O 6 > A ❑ o _ T 0 3 o c. o E) C O k q O P. p m m T E G u F G O^ e R P 5--d cel .F .t, ° O Q w u © et : a'4,O° d eq E .s u.. c°d m u 0 C m v "' 0 F o a O g. o o. C F d E c v o i. a o 5 �' - an ❑ ❑ :Ft' .g m s r2 y 9 u T O 4 y o .eki p W u ') G o ca G V.ISta . «= Py go c P. 3 0 m..6 G ° c. .-1 d o Qad O °' N 7°�' z.. v .. mow" c o Y . u '� F `w' d z yam' �. y o o Y Q 9 4 O 0 F N P' U .U. C d a w+ y. ... U 0 .. d. 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