HomeMy WebLinkAbout20131204.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
May 7, 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
RECEIVED
MAY a 3 2013
WELD COUNTY
COMM;,SS3ONERS
On May 10, 2013, the Air Pollution Control Division will publish a public notice for Chesapeake Operating, Inc.
— State 27-1, 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: Ellen Evans
Regards,
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
sleeiftitO
2013-1204
STATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbino, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health andenvironmentof the people of Colorado..
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.co.us
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Colorado Department
of Public Health
and Environment
Website Title: Chesapeake Operating, Inc. — A natural gas wellhead facility, consisting of condensate storage
tanks (general permit), produced water tank (general permit), facility flare and associated fugitives. — Weld
County
Released To: The Greeley Tribune
On: May 7, 2013
Published: May 10, 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 27-1
A natural gas wellhead facility, consisting of condensate storage tanks (general permit), produced
water tank (general permit), facility flare and associated fugitives.
State 27-1 (Section 27, T9N, R66W)
Weld County
The proposed project or activity is as follows: The operator proposes to maintain and operate a natural gas
wellhead site.
The Division has determined that this permitting action is subject to public comment per Colorado Regulation No.
3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.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 12WE1859 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-B1
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: 12WE1859
859
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 27-1, located in Section 27, Township 9 North, Range 66
West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
point
Description
FLARE2
003
Plant flare used to control gas stream off of 3 -phase seperator.
Flare has a minimum combustion efficiency of 95%. The flare is
enclosed.
FUG1
004
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: 123/9039
Page 1 of 10
Condensate Tank Version 2009-1
bliHealth and Environment
it Pollution Control Division
application ass ith /I1ie pemitA,ii) dtscoptis cons. traction 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
yp
NO,
VOC
CO
FLARE2
003
1.0
4.7
5.6
Point
FUG1
004
---
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 004: 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
003
Natural gas flaring
7,300 MSCF/yr
AIRS ID: 123/9039
Page 2 of 10
blic'Health and Environment
Air Pollution Control Division
Compliance with , nn ro lirrli s f a ie 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. 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 004: 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 004: Minor sources in designated nonattainment or attainment/maintenance areas that
are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply
Reasonably Available Control Technology (RACT) for the pollutants for which the area is
nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a).
This requirement to apply RACT shall be satisfied by installing/implementing the following
emission controls:
a. Directed Inspection & Maintenance as described below shall satisfy the requirementto apply
RACT.
(i) For leak screening, auditory/visual/olfactory inspection (AVO) will be
performed on a quarterly basis.
(ii) For each leak found in the AVO inspection, a gas detector shall be used to
determine the size of the leak. The gas detector shall be regularly
calibrated. Component leaks greater than 10,000 ppm shall be managed in
accordance with Item (vi) below, unless it is unfeasible to make the repair
without shutting down the affected operation of the facility. For such
component leaks that require a shutdown to be repaired, repair shall occur
during the first shutdown of the affected operation after the leak is
discovered.
(iii) For repair, valves adjacent to the equipment to be repaired will be closed if
practicable, minimizing the volume released.
(iv) Repaired components shall be re -screened to determine if the leak is
repaired.
AIRS ID: 123/9039
Page 3 of 10
f F bli Health and Environment
.A4ir Pollution Control Division
(v) e flowim®c . all bmaitained fo seriod 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 003: 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 003: 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 004: 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 004: 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: 123/9039 Page 4 of 10
Health and Environment
it Pollution Control Division
20. Point 003: Thy "r a t Barr}(? t)a,gas ro the flare to determine the
heat content on an annual basis.
21. Point 004: On an annual basis, the owner or operator shall complete an extended gas
analysis of produced gas that is representative of volatile organic compounds (VOC) and
hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended
gas analysis shall be used in the compliance demonstration as required in the Emission
Limits and Records section of this permit.
ADDITIONAL REQUIREMENTS
22. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO„ per year, a change
in annual actual emissions of one (1) ton per year or more or five percent, whichever
is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level reported
on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
23. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall
apply to this source at any such time that this source becomes major solely by virtue of a
relaxation in any permit condition. Any relaxation that increases the potential to emit above
the applicable Federal program threshold will require a full review of the source as though
construction had not yet commenced on the source. The source shall not exceed the
Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
24. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
AIRS ID: 123/9039 Page 5 of 10
-3:1coloraVA Depai" timer
bile,. Health and Environment
it Pollution Control Division
25. If this permit se- st , fha finAkauthonzati„on,has b granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
26. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the applicant and is conditioned upon conduct of the activity, or construction, installation
and operation of the source, in accordance with this information and with representations
made by the applicant or applicant's agents. It is valid only for the equipment and operations
or activity specifically identified on the permit.
27. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
28. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit 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: 123/9039
Page 6 of 10
FxblidHealth and Environment
griAir Pollution Control Division
Issuance 1
is ti nc'e
Pe `' ) encl s d flare and associated
fugitives. New synthetic minor source facility.
AIRS ID: 123/9039
Page 7 of 10
Notes to Permit Holder . He of thisperir irssan
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.)
bli Health and Environment
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
permittee providing there is no exceedance of any specific emission control regulation or any ambient air
quality standard. A revised air pollution emission notice (APEN) and application form must be submitted
with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as
possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
http://www.cdphe.state.co.ustrepulations/airreqs/1 001 02acicccom m onprovisionsreq. pdf.
4) The emission levels contained in this permit are based on the following emission factors:
Point 003:
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
41.13 lb/MMscf
2.06 lb/MMscf
Engineering
Calculation
Note: The controlled emissions factors for point 003 are based on the flare control efficiency of 95%.
Point 004:
Component
Gas Service
Heavy Oil
Light OilWater/Oil
Sce
Service
Connectors
---
---
-
Flanges
55
---
6
---
Open-Ended Lines
---
---
---
---
Pump Seals
---
---
3
---
Valves
50
---
5
---
Other
13
---
3
---
VOC Content (wt%)
51.49%
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):
AIRS ID: 123/9039
Page 8of10
Health and Environment
Air Pollution Control Division
1600.7
Component
Gas Service
-,
eavy i
•
ig t Oil
Water/Oil
Service
Connectors
2.0E-04
7.5E-06
2.1E-04
1.1E-04
Flanges
3.9E-04
3.9E-07
1.1E-04
2.9E-06
Open-ended Lines
2.0E-03
1.4E-04
1.4E-03
2.5E-04
Pump Seals
2.4E-03
NA
1.3E-02
2.4E-05
Valves
4.5E-03
8.4E-06
2.5E-03
9.8E-05
Other
8.8E-03
3.2E-05
7.5E-03
1.4E-02
Source: EPA -453/R95-017
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors
listed in the table above with representative component counts, multiplied by the VOC content from the
most recent gas and liquids analyses.
5) 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.
6) 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
7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart M — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
AIRS ID: 123/9039
Page 9 of 10
MACT
63.89
Color,$\ Depal fnen f bli&Health and Environment
*;Air Pollution Control Division
ifc
S
Nt'1
bpart XX)OUSX
8) 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/oilqasperm ittinq. htm l
AIRS ID: 123/9039 Page 10 of 10
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Chesapeake Operating, Inc.
Permit Number:
12WE1859
Source Location:
S27, T9N, R66W, Weld County (Attainment)
Equipment Description
Point 003: Plant flare with a minimum combustion efficiency of 95%.
Point 004: Fugitive emissions
AIRS ID:
123-9039
Date:
August 23, 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: J emailed the Operator for the gas analysis
used in the fugitive and flare calculations.
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
003
Plant flare used to control gas stream off of 3 -phase separator. Flare has a
minimum combustion efficiency of 95%. The flare is enclosed.
004
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
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
Page 1
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
X
Yes
No
Regulation 7, Sections XII and XVII.C may apply)
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
003
AP -42, Table 13.5-1; mass balance for separator VOC
004
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 (PTEZ
AIRS Point
Process Consumption/Throughput/Production
003
2630 MCF/yr
Pilot: 3.0 MMBtu/yr
004
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
---
---
---
---
Flanges
55
---
6
---
Open -Ended Lines
---
---
---
---
Pump Seals
---
---
3
---
Valves
50
---
5
---
Other
13
---
3
---
Basis for
Actual Emissions Reported During this APEN Filing (Reported to Inventor)
AIRS Point
Process Consumption/Throughput/Production
Data Year
003
2630 MCF/yr
Pilot: 3.0 MMBtu/yr
004
Equipment Type
Gas
Heavy Oil
(or Heavy
Liquid)
Light Oil
(or Light
Liquid)
Water/Oil
Connectors
---
---
---
---
Flanges
55
---
6
---
Open -Ended
Lines
---
Pump Seals
---
---
3
---
Valves
50
---
5
--
Other
13
---
3
---
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
003
2630 MCF/yr
_Pilot: 3.0 MMBtu/yr _
004
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
---
---
---
---
Flanges
55
---
6
---
Open -Ended Lines
---
Pump Seals
---
---
3
---
Valves
50
---
5
---
Other
13
---
3
---
Does this facility use control devices?
X
Yes
No
AIRS Point
Process
Control Device Description
% Reduction
Granted
003
01
Flare
95
Page 2
Section 6 — Emission Summary (tons per year)
Point
NO„
VOC
CO
SOx
PM10
Single HAP
Total
HAP
PTE:
001
2.1
75.0
11.7
---
---
1.2
(n -hexane)
1.3
002
---
2.9
---
---
"""
0.2
(n -hexane)
0.3
003
1.0
54.1
5.6
---
---
---
---
004
---
2.5
--
---
--
---
---
Uncontrolled point
source emission rate:
001
2.1
62.5
11.7
---
---n
1.0
he ane
( n-hexane
1.1
002
---
2.4
--
--
-""
0.2
(n -hexane)
0.3
003
1.0
54.1
5.6
--
---
--
---
004
---
2.5
---
---
---
---
---
TOTAL (TPY)
3.0
121.5
18.6
---
---
1.2 (n -hexane)
1.4
Controlled point
source emission rate:
001
2.1
39.0
17.3
---
---
0.05 (n -hexane)
0.1
002
---
10.0
--
---
---
---
---
003
1.0
4.7
5.6
---
---
---
---
004
---
2.5
---
---
---
---
---
INSIGNIFICANTS
(TPY)
0.3
0.5
0.3
---
---
---
---
TOTAL PERMITTED
(TPY)
3.1
56.2
17.3
---
---
0.1 (n -hexane)
0.1
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(lb/yr)
Are the
emissions
reportable?
Controlled Emission
Rate (Ib/yr)
Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non -criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
X
Yes
No
If "yes", complete the information listed below
AIRS Point
.Process
Pollutant
Regulatory Basis
Test Method
003
01
VOC,
HAPS
State only requirement
Site -specific gas
analysis
003
of
Opacity
Regulation No. 1, Section II.A.5
EPA Method 9
004
01
VOC,
HAPS
State only requirement
Site -specific gas
analysis
004
01
VOC,
HAPS
State only requirement
Hard component
count
Section 9 — Source Classification
Is this a new previously un-permitted source?
Yes
No
Point 003: Flare
X
Point 004: Fugitives
X
Page 3
What is this point classification?
True Minor
Synthetic Minor
Major
Point 003: Flare
X
Point 004: Fugitives
X
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
PSD
X
NA NSR
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why?
For Reg. 3, Part B, III.C.1.a (controlled emissions increase > 25/50
tpy)?
X
Yes
No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
X
Yes
No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
NOx emissions are less than 40 TPY.
Yes
X
No
AIRS Point
Section 12 — Regulatory Review
Regulation 1 - Particulate, Smoke. Carbon Monoxide and Sulfur Dioxide
003, 004
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 v,:
003, 004
Section l.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.
rReatilation 3-APENs, Construction -Permits: Operating Permits.. PSD Y -7'" ,.;
003, 004
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 I ton
per year VOC)
003, 004
Part B — Construction Permit Exemptions
Applicant is required to file a permit since TOTAL FACILITY uncontrolled VOC
emissions are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section lI.D.2.a)
Page 4
Regulation 6 - New Source PerformanceStandards
003
None
004
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.
Reg elation 7 Volatile Organic+Compodn s,
003
None
004
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.
Requlalioh,8 — Hazardous Air Pollutants
003
None
004
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
(%)
003
01
41.13 lb/MCF
VOC
No
Engineering
Calculation
95
Flare
0.068
lb/MMBtu
N0x
No
AP -42,
Table 13.5-1
NA
0.37
Ib/MMBtu
CO
No
AP -42,
Table 13.5-1
NA
SCC
31000205 -Flares
004
01
Fugitive V0C 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
Permit issued because emissions are greater 5 TPY CO (Reg. 3, Part B, Section II.D.2.e)
VOC, NOx and CO (from AP -42, Chapter 13, Table 13.5-1 (NOx = 0.068 lb/mmbtu; CO = 0.37 Ib/mmbtu;
VOC = 0.14 Ib/mmbtu)
003
Flare
Operator did not include associated gas analysis with the application. I emailed the Operator on 8/8/12
for the gas analysis. Operator emailed gas analysis on 8/28/12.
Gas analysis showed no BTEX.
Original VOC calculations did not include emissions from the separator. Received new calculations on
12/21/12 and generated a new VOC emission factor to account for "associated gas" emissions that will be
controlled:
VOC = (54.09 *2000)/ 2630 = 41.13 lb/MCF
Page 5
AIRS Point
004
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 8/15/12
for the gas analysis. Operator emailed gas analysis on 8/28/12.
Gas analysis showed no BTEX.
I calculated fugitives based on the spreadsheet provided by the operator that converted mol °A from the
gas analysis to wt % VOC. I calculated the same emissions as the operator.
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
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Section 05 — Stream Constituents
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