HomeMy WebLinkAbout20133105.tiffSTATE OF COLORADO
John W. Hickenlooper, Governor
Larry Wolk, MD, MSPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
'RECEIVED
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
www.colorado.gov/cdphe
Weld County Clerk & Recorder
1402 N 17th Ave
Greeley, CO 80631
October 30, 2013
Dear Sir or Madam:
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
WELD COUNTY
COMMISSIONERS
Colorado Department
of Public Health
and Environment
On November 2, 2013, the Air Pollution Control Division will publish a public notice for On Energy LLC —
AG Facility, in the The Greeley Tribune. A copy of this public notice and the public comment packet are
enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public
copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet
must be available for public inspection for a period of thirty (30) days from the date the public notice is
published. Please send any comment regarding this public notice to the address below.
Colorado Dept. of Public Health & Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
do: AL, i'/,,VL
2013-3105
it -4-43
STATE OF COLORADO
John W. Hickenlooper, Governor
Larry Welk, MD, MSPH
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
www.colorado.gov/cdphe
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Website Title: On Energy LLC — AG Facility — Weld County
Released To: The Greeley Tribune
On: October 30, 2013
Published: November 2, 2013
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
Colorado Department
of Public Health
and Environment
Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado
Air Pollution Control Division for the following source of air pollution:
Applicant: Orr Energy LLC
Facility: AG Facility
Wellhead
NENE Section 32 T6N R66W
Weld County
The proposed project or activity is as follows: Orr Energy is operating a wellhead facility in Weld County.
The Division has determined that this permitting action is subject to public comment per Colorado Regulation No.
3, Part B, Section II1.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 13 WE1008 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:
Peter Armington
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-Bl
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
STATE OF COLORADO
i
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
13WE1008
Issuance 1
DATE ISSUED:
ISSUED TO: Orr Energy LLC
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the AG Facility, located in the NENE of Section 32, Township
6N, Range 66W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Tanks
001
Five (5) 300 BBL fixed roof storage tanks used to store
condensate. Emissions from these tanks are controlled by an
enclosed flare.
AG
Loadout
002
Truck loadout of condensate. Emissions from the loadout are not
controlled.
AG
Fugitive
003
Equipment leaks (fugitive VOCs) from a natural gas wellhead
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 Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of
the permitted source is a violation of Air Quality Control Commission (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 in this permit shall be demonstrated to the Division. It is the owner or
operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate
AIRS ID: 123/9AB3 Page 1 of 12
Condensate Tank SM/M Version 2012-1
Depa'men
li&Health and Environment
Air Pollution Control Division
compliance within418 -days may tesuli jn reVosatidn,of therperrnit. (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
application associated with this permit; (H) discontinues construction for a period of eighteen
months or more; (Hi) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
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
Tanks
001
---
6.8
2.2
Point
AG Loadout
002
---
1.0
---
Point
AG Fugitive
003
---
6.3
---
Fugitive
See "Notes to Permit Holder" 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. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Tanks
001
Enclosed Combustor
VOC
AIRS ID: 123/9AB3
Page 2 of 12
epaiten
PROCESS LIMITAT(QNS'AN OCR[
PblicHealth and Environment
<ir Pollution Control Division
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or operator
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
Tanks
001
Condensate throughput
19,726
BBL/yr
AG Loadout
002
Condensate Loading
19,726
BBUyr
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate 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. Point 001: The permit number and AIRS ID point number (e.g. 123/4567/890) 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. Emission control devices subject to Regulation 7, Sections
XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1,
Section II.A.1. & 4.)
11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
12. The flare covered by this permit is subject to Regulation No. 7, Section XII.C General
Provisions (State only enforceable). If a combustion device is used to control emissions of
volatile organic compounds to comply with Section XII.D, it shall be enclosed, have no
visible emissions, and be designed so that an observer can, by means of visual observation
from the outside of the enclosed combustion device, or by other means approved by the
Division, determine whether it is operating properly. The operator shall comply with all
applicable requirements of Section XII.
13. This source is subject to the recordkeeping, monitoring, reporting and emission control
requirements of Regulation 7, Section XII. The operator shall comply with all applicable
requirements of Section XII.
14. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General
Provisions (State only enforceable). If a flare or other combustion device is used to control
emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed,
have no visible emissions during normal operations, and be designed so that an observer
can, by means of visual observation from the outside of the enclosed flare or combustion
AIRS ID: 123/9AB3 Page 3 of 12
olora'-1
Depa nenH(f PI blicHealth and Environment
'+A. ry�A it Pollution Control Division
�i �`✓ l `� s- l; s�
device, or by ath'e�onvement means-app�obe�1� � the Drvi ion, determine whether it is
operating properly. The operator shall comply with all applicable requirements of Section
XVII.
15. Point 001: The condensate storage tanks covered by this permit are subject to Regulation 7,
Section XVII emission control requirements. These requirements include, but are not limited
to:
Section XVII.C. - Emission reduction from condensate storage tanks at oil and gas
exploration and production operations, natural gas compressor stations,
natural gas drip stations and natural gas processing plants.
XVII.C.1. Beginning May 1, 2008, owners or operators of all atmospheric condensate
storage tanks with uncontrolled actual emissions of volatile organic compounds
equal to or greater than 20 tons per year based on a rolling twelve-month total
shall operate air pollution control equipment that has an average control
efficiency of at least 95% for VOCs on such tanks.
XVII.C.3. Monitoring: The owner or operator of any condensate storage tank that is
required to control volatile organic compound emissions pursuant to this section
XVII.C. shall visually inspect or monitor the Air Pollution Control Equipment to
ensure that it is operating at least as often as condensate is loaded out from the
tank, unless a more frequent inspection or monitoring schedule is followed. In
addition, if a flare or other combustion device is used, the owner or operator shall
visually inspect the device for visible emissions at least as often as condensate
is loaded out from the tank.
XVI I.C.4. Recordkeeping: The owner or operator of each condensate storage tank shall
maintain the following records for a period of five years:
XVII.C.4.a. Monthly condensate production from the tank.
XVII.C.4.b For any condensate storage tank required to be controlled pursuant
to this section XVII.C., the date, time and duration of any period where
the air pollution control equipment is not operating. The duration of a
period of non -operation shall be from the time that the air pollution control
equipment was last observed to be operating until the time the equipment
recommences operation.
XVII.C.4.c. For tanks where a flare or other combustion device is being used, the
date and time of any instances where visible emissions are observed from
the device.
16. Point 002: This source is located in an ozone non -attainment or attainment -maintenance
area and is subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be
conducted by submerged fill. (Reference: Regulation 3, Part B, III.E)
17. Point 003: This source is subject to Regulation No. 7, Section XII.C General Provisions
(State only enforceable). All condensate collection, storage, processing and handling
operations, regardless of size, shall be designed, operated and maintained so as to
minimize leakage of volatile organic compounds to the atmosphere to the maximum extent
practicable. The operator shall comply with all applicable requirements of Section XII.
18. Point 003: Minor sources in designated nonattainment or attainment/maintenance areas that
are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply
AIRS ID: 123/9AB3 Page 4 of 12
f P ,lic'Health and Environment
g Air Pollution Control Division
k '1Jl , 1A
Reasonably Auaijable-Coptr_0.6Te' aiogy,(PA,, T .;for the vp ltjtants for which the area is
nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a).
This requirement to apply RACT shall be satisfied by installing/implementing the following
emission controls:
a. Directed Inspection & Maintenance as described below shall satisfy the requirement
to apply RACT.
i. For leak screening, auditory/visual/olfactory inspection (AVO) will be
performed on a quarterly basis.
H. For each leak found in the AVO inspection, a gas detector shall be used
to determine the size of the leak. The gas detector shall be regularly
calibrated. Component leaks greater than 10,000 ppm shall be managed
in accordance with Item (vi) below, unless it is unfeasible to make the
repair without shutting down the affected operation of the facility. For
such component leaks that require a shutdown to be repaired, repair
shall occur during the first shutdown of the affected operation after the
leak is discovered.
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.
v. The following records shall be maintained for a period of two years:
The name of the site screened via AVO inspection and the
name of the inspector.
• Components evaluated with the gas detector.
• Repair methods applied.
• 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
19. Point 001: 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
AIRS ID: 123/9AB3 Page 5 of 12
ten f P[[ablid)Health and Environment
�, HAir Pollution Control Division
20. Point 001: Theoperthor shalhc6r plate side `specific sampling; including a compositional
analysis of the pre -flash pressurized condensate routed to these storage tanks and a sales
oil analysis to determine RVP and API gravity. Testing shall be in accordance with the
guidance contained in PS Memo 05-01. Results of testing shall be used to determine a site -
specific emissions factor using Division approved methods. Results of site -specific sampling
and analysis shall be submitted to the Division as part of the self -certification and used to
demonstrate compliance with the emissions factors chosen for this emissions point.
21. Point 001: The owner or operator shall demonstrate compliance with Condition 11, using
EPA Method 22 to measure opacity from the flare. The observation period shall be a
minimum of fifteen consecutive minutes.
22. Point 002: Within one hundred and eighty days (180) after issuance of this permit, the owner
or operator shall complete the initial extended gas analysis of gas samples that are
representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that
may be released as fugitive emissions. This extended gas analysis shall be used in the
compliance demonstration as required in the Emission Limits and Records section of this
permit. The operator shall submit the results of the gas analysis and emission calculations
to the Division as part of the self -certification process to ensure compliance with emissions
limits.
23. Point 002: Within one hundred and eighty days (180) after issuance of this 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
24. Point 001: 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.1 & 4)
25. Point 002: On an annual basis, the owner or operator shall complete an extended gas
analysis of gas samples that are representative of volatile organic compounds (VOC) and
hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended
gas analysis shall be used in the compliance demonstration as required in the Emission
Limits and Records section of this permit.
ADDITIONAL REQUIREMENTS
26. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, 'LC)
a. Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (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
AIRS ID: 123/9AB3 Page 6 of 12
For sou desremittiegA00 fons_per year ` ore, 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.
27. 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).
f Pplic Health and Environment
Air Pollution Control Division
GENERAL TERMS AND CONDITIONS
28. 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.
29. 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.
30. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the owner or operator and is conditioned upon conduct of the activity, or
construction, installation and operation of the source, in accordance with this information and
with representations made by the owner or operator or owner or operator's agents. It is valid
only for the equipment and operations or activity specifically identified on the permit.
31. 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.
32. 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
AIRS ID: 123/9AB3 Page 7 of 12
Depat nen of Pi 'blic Health and Environment
a1 Alir Pollution Control Division
1 3
and upon such -o rbfs permi s)iall be deemed deraued ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
33. 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.
34. 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:
Peter Armington
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Orr Energy LLC
AIRS ID: 123/9AB3 Page 8 of 12
t om, ; ttliff _
Notes to Permit Holder a'fthertime of=thispermifiS banEe
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees
will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3,
Part A, Section VI.B.)
Depart n eny f P,' liiHealth and Environment
w it Pollution Control Division
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the owner or operator providing there is no exceedance of any specific emission control regulation or any
ambient air quality standard. A revised air pollution emission notice (APEN) and complete application
form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
http://www.cd phe.state. co. us/req u lations/a irregs/100102agcccommonprovisionsreq. pdf.
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(lb/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
001
Benzene
71432
A
473
Yes
23.7
Hexane
110543
C
4,124
Yes
207
002
n -Hexane
110543
C
22
No
22
Benzene
71432
A
2
No
2
Toluene
108883
C
10
No
10
Xylenes
1330207
C
14 -
No
14
003
Benzene
71432
A
29
No
29
Toluene
108883
C
83
No
83
Ethylbenzene
100414
C
8
No
8
Xylenes
1330207
C
73
No
73
n -Hexane
110543
C
146
No
146
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Emission Factors
Emission Factors
Uncontrolled
Controlled
CAS #
Pollutant
lb/BBL
lb/BBL
Source
Condensate
Condensate
Throughput
Throughput
AIRS ID: 123/9AB3
Page 9 of 12
Depaiz ien`l of Pr pl1c-Health and Environment
Pollution Control Division
1
CAS #
c.,- ' E,;;
Pollutant
ni'SAlprjiFactoi ..
Uncontrolled
lb/BBL
Condensate
Throughput
LErnission_Fa_ctors
Controlled
lb/BBL
Condensate
Throughput
Source
NOx
NA
0.037
CDPHE
CO
NA
0.22
CDPHE
VOC
13.7
0.685
Source
110543
n -Hexane
0.21
0.0105
Source
71432
Benzene
0.024
0.0012
Source
Note: The controlled emissions factors for point 001 are based on the flare control efficiency of
95%.
Point 002:
CAS
Pollutant
Emission
lb/BBL loaded
Factors - Uncontrolled
Source
VOC
0.101
AP -42
The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version
1/95) using the following values:
L = 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 3.4 psia
M (vapor molecular weight) = 49.37 lb/lb-mol
T (temperature of liquid loaded) = 520 °R
Point 003:
Component
Gas Service
Heavy Oil
Light Oil
Oil
Service
Connectors
0
0
155
0
Flanges
7
0
50
0
Open-ended Lines
0
0
13
0
Pump Seals
0
0
0
0
Valves
0
0
56
0
Other*
2
0
60
0
VOC Content (wt.
fraction)
0.2920
1.0000
1.0000
1.0000
Benzene Content (wt.
fraction)
0.0010
0.0000
0.0023
0.0000
Toluene Content (wt.
fraction)
0.0049
0.0000
0.0065
0.0000
Ethylbenzene (wt.
fraction)
0.0021
0.0000
0.0005
0.0000
Xylenes Content (wt.
fraction)
0.0069
0.0000
0.0056
0.0000
n -hexane Content (wt.
fraction)
0.0110
0.0000
0.0114
0.0000
AIRS ID: 123/9AB3
Page 10 of 12
Lint -•y:...
kColor ADepa� ,
IicLHealth and Environment
Air Pollution Control Division
*Other equipment type;. includes c. o_Lpn resisors -4ress'li`r_e, telief valvesf valves, diaphragms, drains,
dump arms, hatches, instrument meters, polish rods and vents
TOC Emission Factors (kg/hr-component):
Component
Gas Service
Heavy Oil
Light Oil
Water/Oil
Service
Connectors
2.0E-04
7.5E-06
2.1E-04
1.1E-04
Flanges
3.9E-04
3.9E-07
1.1E-04
2.9E-06
Open-ended Lines
2.0E-03
1.4E-04
1.4E-03
2.5E-04
Pump Seals
2.4E-03
NA
1.3E-02
2.4E-05
Valves
4.5E-03
8.4E-06
2.5E-03
9.8E-05
Other
8.8E-03
3.2E-05
7.5E-03
1.4E-02
Source: EPA -453/R95-017
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors
listed in the table above with representative component counts, multiplied by the VOC content from the
most recent gas analysis.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC
MACT HH
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
httpaiecfr.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
163.1-63.599 I
Subpart A — Subpart Z
AIRS ID: 123/9AB3
Page 11 of12
blic-Health and Environment
git Pollution Control Division
MACT
63.600S3fIT9/9/ r- -
thiaparkA ahbph%&_DDD -"
MACT
63,1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
9) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit packet.
Please use this form to complete the self -certification requirements as specified in the permit conditions.
Further guidance on self -certification can be found on our website at:
http://www.cdphe.state.co.us/ap/oilqaspermittinci.html
AIRS ID: 123/9AB3 Page 12 of 12
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Orr Energy LLC
Permit Number:
13W E1008
Source Location:
NENE Section 32, T6N, R66W
Equipment Description:
Five 300 bbl condensate tanks
AIRS ID:
123/9AB3/001
Date:
5/16/2013
Review Engineer:
Peter Armington
Control Engineer:
Carissa Money
ISection
2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
Initial Approval
Transfer of Ownership
APEN Exempt/Permit Exempt
* If tank is a true minor source at a true minor facility, it may be granted "Final Approval" without first
being issued an Initial Approval permit
"Grandfathered exemption is for any tanks in service prior to December 30, 2002
Section 3 -- Applicant Completeness Review
Was the correct APEN submitted for this source type?
X I Yes
No
Is the APEN signed with an original signature?
X I Yes
No
Was the APEN filled out completely?
X Yes
No
Did the applicant submit all required paperwork?
X , Yes
No
Did the applicant provide ample information to determine emission rates?
X Yes
No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
On what date was this application complete?
May 16, 2013
Section 4 — Source Description
AIRS Point
Equipment Description
001
Five 300 bbl condensate tanks
Is this a portable source?
Yes
X
No 1
Is this location in a non -attainment area for any criteria
pollutant?
X
Yes
No
If eyes", 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 III.D.2)
PM10
CO
No
__
Ozone
____
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
Re ulation 7, Sections XII and XVII.C may apply)
X
Yes
Page 1
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
001
CDPHE Condensate Storage Tank Emission Factors
Did the applicant provide actual process data for the emission inventory? I X
Yes I
f No
i
Basis for Potential to Emit (PTE)
AIRS Point
Process Consumption/Throughput/Production
001
19,726 BBL per year
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
001
16,438 BBL per year
2012
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
001
19,726 BBL per year
Does this source use a control device?
X
Yes
No
AIRS Point
Process
Control Device Description % Reduction
i Granted
001
01
Flare
95
Section 6 — Emission Summary (tons per year)
Point
NO„
VOC
I CO I Single HAP
Total HAP
PTE:
001
0.36
135
j 2.2
2.06 (Hexane)
2.30
Uncontrolled point
source emission rate:
001
135
2.06 (Hexane)
2.30
Controlled point
source emission rate:
001
0.36
6.8
2.2
0.1 (Hexane)
0.12
Total APEN Reported
emissions:
001
0.30
5.6
1.8
0.09 (Hexane)
0.1
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(Ib/yr)
Are the Controlled Emission
emissions
reportable? Rate (Ib/yr)
Benzene
71432
A
473
Yes
23.7
n -Hexane
110543
C
4,124
Yes
207
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?
Yes
X
No
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
What is this facility classification?
Page 2
True X
Minor
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 (emissions increase > 25/50 tpy)?
Yes
X
No
For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
X
Yes
No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
Yes
X
No
AIRS Point
Section 12 — Regulatory Review
_
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
001
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
001
Section I.A - No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are
measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Regulation 3 - APENs, Construction Permits, Operating Permits, PSD
001
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in a nonattainment area with uncontrolled actual emissions
of one tons per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is nonattainment.
(Applicant is required to file an APEN since emissions exceed 1 tons per year VOC)
001
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled V0C emissions from this
facility are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section ll.D.3.a)
Regulation: -6'- New Source Performance Standards
001
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
Is this source greater than 19,800 gallons (471 bbl)? No
Is this source subject to NSPS Kb? No
Page 3
Regulation 7 — Volatile Organic Compounds
001
XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
(Applicant is subject to the emission control requirements for condensate tanks
since it is located in a nonattainment area.)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
(Applicant is currently subject to this since actual uncontrolled emissions are
greater than 20 tpy of VOC.)
Re. ulation 8 — Hazardous Air Pollutants
001
MACT EEEE: Organic Liquids Distribution
Pick one:
• This source is not subject to MACT EEEE because it is not located at a major
source of HAP.
001
MACT HH
Pick one:
• This source is not subject to MACT HH because it is not located at a major source
of HAP.
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process
Description
Emission
Factor
Pollutant/
CAS #
Fugitive
(Y/N)
Emission Factor Source
Control
(%)
001
01
E&P Condensate
Storage Tanks
326.1905
lb/1000 gal
throughput
V0C
No
CDPHE PS Memo 05-01
(converted to lb/1000 gal)
95
5.24
lb/1000 gal
throughput
CO
No
Average of Similar Sites
NA
0.5714
lb/1000 gal
throughput
Benzene /
71432
No
CDPHE PS Memo 05-01
(converted to lb/1000 gal)
95
5.0
lb/1000 gal
throughput
n -Hexane
/ 110543
CDPHE PS Memo 05-01
No 95
(converted to lb/1000 gal)
SCC
40400311 — Fixed Roof Tank, Condensate, working+breathing+flashing losses
Section 14 —Miscellaneous Application Notes
AIRS Point
001
Condensate Storage Tanks
A permit will be issued.
This source is located in the 8 -hour ozone non -attainment area. Therefore, the provisions of Regulation
7, Section XII do apply to this source. The statewide requirements of Regulation 7, Section XVII.C
currently apply to this source since actual uncontrolled emissions are greater than 20 tpy.
Page 4
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Orr Energy LLC
Permit Number:
13WE1008
Source Name:
AG Facility
Source Location:
LAT 40.45065023 LON -104.7951454
Equipment Description:
Oil Loadout
AIRS ID:
123/9AB3/002
Review Date:
9/18/2013
Review Engineer:
Peter Armington
Section 2 — Action Completed
X
CP1
Modification
APEN Required/Permit Exempt
Final Approval
i Transfer of Ownership
APEN Exempt/Permit Exempt
Section 3 — Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes I
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
X
Yes
No
Did the applicant submit all required paperwork?
X
Yes
No
Did the applicant provide ample information to determine emission rates?
X
Yes
No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
On what date was this application complete?
May 20, 2013
Section 4 - Source Description
AIRS Point
Equipment Description
002
Truck Condensate Loadout
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
ollutant?
X
Yes
No
If "yes", for what pollutant?
PM,o
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 III.D.2)
PM10
CO
_
Ozone
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
Regulation 7, Sections XII and XVII.C may apply)
X
Yes
No
Is this source located at an oil and gas exploration site?
X
Yes
No
Page 1
If yes, does this source load less than 10,000 gallons of
crude oil per day on an annual average, splash fill less
than 6750 bbl of condensate (hydrocarbons that have
an API gravity of 40 degrees or greater) per year or
submerged fill less than 16,308 bbl of condensate per
year?
Yes
X
No
Is this source located at a facility that is considered a
major source of hazardous air pollutant (HAP)
emissions?
Yes
X
No
Will this equipment be operated in any NAAQS
nonattainment area?
X
Yes
No
Does this source load gasoline into transport vehicles?
Yes
X
No
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
002
AP -42: Chapter 5.2, Equation 1
L = 12.46*S*P*M/T
L = loading losses in lb per 1000 gallons loaded
S = Saturation Factor
P = true vapor pressure of liquid loaded [psia]
M = molecular weight of vapors [lb/lb-mole]
T = temperature of bulk liquid loaded [deg. R]
Did the applicant provide actual process data for the emission inventory?
X
Yes
No
Basis for Potential to Emit (PTE)
AIRS Point
Process Consumption/Throughput/Production
002
19,726 BBL per year condensate loaded
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
002
16,438 BBL per year condensate loaded
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
002
19,726 BBL per year condensate loaded
Does this source use a control device?
Yes
X
No
Section 6 — Emission Summar)
(tons per year)
Point
NO„
VOC
CO
Single HAP
HAP
PTE:
002
1.0
0.011 (n -hexane)
0.026
Uncontrolled point
source emission rate:
002
1.0
0.011 (n -hexane)
0.026
Permitted point source
emission rate:
002
1.0
0.011 (n -hexane)
0.026
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled Emission
Rate (Ib/yr)
Benzene
71432
A
2
No
2
n -Hexane
110543
C
22
No
22
Page 2
Toluene
108883
C
10
No
10
Xylenes
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.
1130207
C
14
No
14
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
Yes
X
No
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
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
10 — Public Comment
_Section
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why?
For Reg. 3, Part B, ill.C.1.a (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)?
X
Yes
No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
Yes
X
No
AIRS Point
Section 12 — Regulatory Review
Regulation 1 - Particulate Smoke, Carbon Monoxide and Sulfur Dioxide
002
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.)
Regulation 2 — Odor
002
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 3
Regulation 3 - APENs Construction Permits Operating Permits PSD
002
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for
each individual emission point in a nonattainment 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 nonattainment.
(Applicant is required to file an APEN since emissions exceed 1 tons per year VOC)
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section II.D.3.a)
Part B, III.D.2 - RACT requirements for new or modified minor sources
This section of Regulation 3 requires RACT for new or modified minor sources located in
nonattainment or attainment/maintenance areas. This source is located in the 8 -hour ozone
nonattainment area, but not the 1 -hour ozone area.
The date of interest for determining whether the source is new or modified is therefore
November 20, 2007 (the date of the 8 -hour ozone NA area designation). Operator is using
submerged fill (0.6 saturation factor), therefore, RACT requirements are satisfied.
Re. ulation 6 - New Source Performance Standards
002
No applicable subpart.
Regulation 7 — Volatile Organic Compounds
002
No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum
liquid storage and distribution facility that has a daily average throughput of more than
76,000 liters of gasoline (20,000 gallons), which is loaded directly into transport vehicles.
This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C.
Regulation 8 — Hazardous Air Pollutants
002
MACT EEEE:
Not subject because minor source of HAPs
Section 13—Aerometric Information Retrieval System Coding Information
Point
Process
Description
Process/
throughput
Limit
Process Emission Pollutant/ Fu itive
Factor
CAS #
(Y/N)
Emission
Factor
Source
Control
(%)
002
01
Truck Condensate
Loadout
19,726
BBL/yr
2.4
lb/1,000
gallon
throughput
V0C
No
AP -42
0
SCC
40600132: Crude Oil: Submerged Loading (Normal Service)
Page 4
Section 14 — Miscellaneous Application Notes
AIRS Point
002
Truck Condensate Loadout
Units
Basis
S
0.6
Submerged loading:
dedicated normal service
based on source's
description/drawinqs
AP -42
P
3.4
Psia
M
49,37
Lb/lb-mole
AP -42
T
520
Deg R
Based on source's
knowledge of bulk liquid
temperature
L
2.4
Lb/10^3 gal
0.101
Lb/bbl
AP -42: Chapter 5.2
Equation 1
L = 12.46*S*P*M/T
L = loading losses in lb per 1000 gallons loaded
S = Saturation Factor
P = true vapor pressure of liquid loaded [psia]
M = molecular weight of vapors [lb/lb-mole]
T = temperature of bulk liquid loaded [deg. R]
L 2.41b/10^3 gal
0.101lb/bbl
Annual requested Throughput 828492ga1/yr
Annual requested VOC emissions 19881b/yr
1.Otpy
Page 5
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Pump Seals
Others
Connectors
ZD.
Valves
Pump Seals
Others
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Valves
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The date of interest far determining whether the source is new or modified is therefore November 20, 2007 (Ne date of the e -hour ozone NA area designation). Cnmetol has agreed all It'd prvlsimt3 slendaN conditions
NSPS KKK: Equipment Leaks of VOC from onshore natural gas processing plants. Affected facilities et 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 pmcessin0 Plant?' No
Is this source subject to NSPS KKK? No
Naps OOOO: Standards of Performance forerude Oil and Natural Gas Production, Transmission and Distribution. For tugilive emissions at natural gas processing plants subject to NSPS OOOO. This subpart
establishes emission standards and compliance schedules fortbe control of volatile organic corn pounds (VOC) and sulfur dioxide (SO) emissions from affected facilities that commence construction,
modification or reconstruction after August 22, 2011.
Is this source at a'natural gas processing plant?' No
Is this source subject to NSPS OOOO? No
section AII.G: K facility is a natural gas processing plant located in non -attainment area, then subject to Section KILO.
Is this source at a'natural qas processing planer No
RAC T NH: Hfacndy is MAJOR source for HAP at a natural gas processing plant ONLY(summation of HAPS of dehydrators and fugitives), then fugitive emissions are subject to MALT HH.
Is this facility considered MAJOR for HAPS? No
Is this source subject to MACT NH? No
K
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Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above_
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Air Pollutant Emission Notice (APEN) — and — Application for Construction Permit
OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY
Current Status (Check all that apply)
AIRS ID #': /,j •, Vo.' I
® New or previously unrepdrted battery
Previously grandfathered battery'
Synthetic minor facility
Located in the 8 -hr Ozone Control Area3
Registered under general permit no. GPO'
Permitted under individual permit: / 3 ti./ /C'O
Reason for APEN Submittal (Check all that apply)
❑ APEN update only'
Modification to existing sources
Registration for coverage under general permit no. GPO I
& cancellation request for individual permit6:
Application for or Modification of an individual permit
Administrative permit amendment'
Other:
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For individual permit applications, check if you wants:
O A copy of the preliminary analysis conducted by the Division
❑ To review a draft of the permit prior to issuance
Company Name9: Orr Energy LLC
MailingAddress1°: 1813 61st Ave Suite 200
City:
Contact Name:
Greeley
Tarah Leigh Johnson
OGCC Operator #: 1015 4
State: CO Zip: 806 3 4 E-mail: tarah@orrland . com
Phone: 970 351-8777 Fax: 970 351-7851
Tank Battery Name' AG Facility
Location"- (QQ Sec. Twp. Range.): NENE 32 6N 66W
Calendar year for which "Actual" data applies13: 2012
Control Description'`: Cimarron 48" ECD
Condensate Throughput" [bbl/year] Requested's: 19,726
Actual'°: 16,438
Number of tanks: 5
County: Weld Total tank capacity [bbl]: 15 0 0
Year(s) tank(s) were placed in service": 2010
Other equipment at facility': No AIRS ID # s yet assigned.
Comments:
Control Efficiency36: 95%
Maximum for PTE calculation19: 19 , 72 6
Mile Controls Operational'-' 16, 4 3 8
Estimated emissions at throughputs listed above. Use N/A for requested throughput/ emission values unless requesting an individual permit
❑ Check if the Division is to calculate emissions, C Check if site -specific emission factors provided to calculate enissions23.
Pollutant2'
VC/C (tons/year]
NOx (tons/year]
CO [tons/year]
Benzene [lbs/year]
n -Hexane (lbs/year]
Emission Factor
[lb/bbl]
13.7
135
Batter
PTE
Requested Emissions's
Uncontrolled26 Controlled2J
135
6 8
Actual Emissions''°
Uncontrolled26 Controlled"
113
5 6
0.037
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Wells serviced by this tank or tank battery2s
API #: 05--123-31456Name: AG 32-31D Newly Reported Well
API #: 05 -12 3 - 313 4 5 Name: AG 32-32D ❑ Newly Reported Well
AP] #: 05 -123-3134 6 N a me: AG 32-41 ❑ Newly Reported Well
API#: 05-123-31347Name: AG 32-65D ❑ Newly Reported Well
API #: 05 -12 3 - 314 3 8 Name AG 33-11D ❑ Newly Reported Well
API #: Name: 0 Newly Reported Well
API #: Name: 0 Newly Reported Well
The signature below indicates that I have knowledge of the facts herein set forth and that the same are true, accurate, and complete to the best of
my knowledge and belief. If this is a registration for coverage under general permit GPO I, I further certify that this source is and will be operated
in full compliance > h-eaelt fottdition of general permit GPO!.
Signe re orLegally Authorized Person (not a vendor or consultant)
CD VN
Type or Print Name of Person Signing Above
rz.,/•))/ia
Date
��� -J23
Official Title
Submit this form, along with 5152.90 for each
filing of up to 5 tank battery APENS. Include
S250 General Permit fee for each new GP
registration to:
FORM APCD-205
Colorado Department of Public Health and Environment
Air Pollution Control Division, APCD-SS-Bl
4300 Cherry Creek Drive South
Denver, CO 80246-1530
For information call:
(303) 692-3150
Page 1 oft FonuAPCD-205-E&PCondensateTankAPEN-Ver.9-28-2009.docx
Air Pollutant Emission Notice. (APEN) — and -- Application for Construction Permit
OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY
Notes and Instructions
See PS Memo 05-01: Condensate Tank Guidance forfitrther. information on policies, APEN requirements, definitions and emission calculations.
1 AIRS ID #: For previously reported sources, the AIRS ID number is the 10 digit point number found in the detail section of the Division's annual
emission fee invoice. For newly reported sources, leave blank so the Division may assign one.
2 Previously grandfathered: Batteries installed prior to 12/30/02 and not subsequently modified are grandfathered from minor source permitting.
3 8 -hour Ozone Control Area: Adams, Arapahoe, Boulder, Broomfield, Denver, Douglas, Jefferson, and portions of Latimer and Weld counties.
4 APEN Update Only : This notice is valid for five (5) years unless a significant change is made, A revised APEN shall be filed no less than 30 days
prior to the expiration date of this APEN form.
5 Modification to existiva.source: Modifications include but are not limited to well additions, tank installation or replacement, repiping, etc.
e General Permit Registration: This AP -EN will be considered a cancellation request for an individual permit, if general permit coverage is selected
for a battery. The individual permit will not be cancelled until the general permit registration is approved.
7 Administrative Permit Amendment: This includes company name changes, transfer of ownership, and other changes defined in Regulation No. 3,
Part A, Section I.B.1. You must also submit a general Permit Application form to document the administrative amendment.
8 Review Draft Request: Review requests will usually add to both processing time and costs. Any additional charges incurred by the Division in
providing a draft and correspondence with the applicant will be billed to the applicant. The Division will consider the request an official extension
of the processing deadlines specified by Regulation No. 3, Part B, Section III.
9 Company Name: The name of the owner or operator of the condensate storage tank battery.
1° Mailing Address: This isahe address to which correspondence, including permits and fee invoices, will be sent. 1f invoices are to be sent to a
different address please attach a separate page with billing address(s).
11 Tank Battery Name: A unique name for each tank battery.
I2,Location: The legal STR (Section, Township, Range) location of the facility to the nearest Quarter -Quarter Section.
13 Calendar year for which "Actual" data applies: Emissions reported in this APEN will be used to calculate annual emission fees for this and all
subsequent years until a revised APEN is filed.
14 Yearfs) tank(s) were placed in service: The year that the battery was installed or placed in service.
15 Control Description: List any control equipment such as flares, VRUs, carbon canisters, or other capture devices, which reduce VOC emissions.
16 Control Efficiency: Enter the control efficiency (reflecting the combined destruction and capture efficiency) while controls are operational.
17 Condensate Throughput: The quantity of condensate transferred through this tank battery annually in units of barrels of condensate per year.
IS Requested: Requested throughput / emission levels are used for individual permitting purposes and should include a reasonable margin above
actual values. Use N/A for requested throughput/ emission values if the battery retains grandfathered status or if applying for GP coverage.
19 Maximum for PTE calculation: Multiply the greater of the highest rolling 12 -month production total during the last five years or the projected
throughput for the following 12 -month period by a factor of 1.2.
20 Actual: Actual reporting levels should represent the best estimates of total annual condensate throughput and pollutant emissions for the specified
data year. For the first year of operation, projected annual throughputs / emissions are acceptable. in subsequent years, actual data from the
previous calendar year should be used.
21 While Controls Operational: The best estimates of actual condensate throughput while controls were installed and operational. If controls were
operational for the entire calendar year, this value will be equal to the actual annual throughput. Otherwise, the throughput subjected to controls
should be proportioned based on the dates the controls were operational.
22 Other equipment at facility: Enter the AIRs ID of other APEN reportable equipment at facility if assigned to a different AIRs facility ID.
23 Site -specific emission factors: Check this box if site specific emission factors are provided and used to estimate emissions. Attach supporting
site -specific emission factor documentation. State EFs may be used only if uncontrolled emissions calculated with the state EFs are less than 80 tpy.
24 Pollutant: Estimated annual emissions of the specified criteria and non -criteria reportable pollutants (NCRP) emitted by this tank battery and
associated control equipment. If values are left blank, the Division will estimate emissions based on the reported condensate throughputs. If NCRP
other than those listed are emitted above reporting thresholds, attach a completed Non -Criteria Reportable APEN Addendum listing these emissions.
Zs Potential to Emit (PTE): Estimated annual maximum potential tonnage of pollutant emitted by this tank or tank battery calculated by multiplying
the "Maximum for PTE" throughput value by the appropriate emission factor. Note: This PTE value is for the battery only, the emissions from
other equipment at the same stationary source should be considered when determining the PTE for the facility.
2s Uncontrolled: Estimated uncontrolled emissions from this tank battery based on the annual condensate throughput.
27 Controlled: Estimated controlled emissions from this tank battery. This value is calculated by applying the appropriate control efficiency to
emissions generated from throughput "while controls operational". A control efficiency of zero should be used for emissions generated while no
controls were operating. These two values are summed to obtain the annual controlled emissions.
28 Wells serviced by. this tank or tank battery: List all wells from which this tank battery receives condensate. Provide the well name and API
number as reported to the Colorado Oil and Gas Commission. Check if this well has not previously been reported for this tank battery.
Page 2 of 2 FommAPCD-205-ESPCondensateTankAPEN-Ver.9-28-2009.docx
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