HomeMy WebLinkAbout20131254.tiffSTATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbina, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.co.us
Weld County Clerk & Recorder
1402 N 17th Ave
Greeley, CO 80631
May 14, 2013
Dear Sir or Madam:
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Colorado Department
of Public Health
and Environment
RECEI t eD
NAY 11 2013
cgtikp cow,
On May 17, 2013, the Air Pollution Control Division will publish a public notice for Bill Barrett Corporation
Cass Farms 11-25H, 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
OALlemnaN
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2013-1254
STATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbino, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.coius
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Website Title: Bill Barrett Corporation — E&P wellsite — Weld County
Released To: The. Greeley Tribune
On: May 14, 2013
Published: May 17, 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: Bill Barrett Corporation
Facility: Cass Farms 11-25H
E&P wellsite
NWNW 25 8N 62W, Weld County, Colorado
Weld County
The proposed project or activity is as follows: Oil and gas exploration and production site. Excess gas is metered
and flared. Condensate loading occurs and fugitives are also permitted. There are three permits under public
comment for the same facility — 12WE2445, 12WE2446, 12WE2447.
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.I.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 12WE2445 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:
Christian Lesniak
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B 1
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: 12WE2445
Issuance 1
DATE ISSUED:
ISSUED TO: Bill Barrett Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the 17282_Cass Farms 11-25H, located in the NWNW of
Section 25, Township 8N, Range 62W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Condensate
Loadout
005
Truck loadout of condensate. Emissions from the loadout
are not controlled.
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 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
AIRS ID: 123/9933 Page 1 of 7
Condensate Loadout TM Version 2012-1
ot'Public Health and Environment
Air Pollution Control Division
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; (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 retain the permit final authorization letter issued by the Division after
completion of self -certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. 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
VOC
Condensate
Loadout
005
7.08
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the 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.
PROCESS LIMITATIONS AND RECORDS
6. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate 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
Monthly Limit
AIRS
Process Parameter
Annual Limit
(31 Days)
Point
AIRS ID: 123/9933
Page 2 of 7
of Public Health and Environment
Air Pollution Control Division
005 l Condensate Loadout 64,650 BBL I N/A
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
7. 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)
8. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
9. This source is not required to follow a Division -approved operating and maintenance
plan.
COMPLIANCE TESTING AND SAMPLING
10. This source is not required to comply with any testing and sampling requirements.
ADDITIONAL REQUIREMENTS
11. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
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 (NOx) in
ozone nonattainment areas emitting less than 100 tons of VOC or NOx per
year, a change in annual actual emissions of one (1) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
AIRS ID: 123/9933 Page 3 of 7
ColB doD p
el or Public Health and Environment
Air Pollution Control Division
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.
12. 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:
13. 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.
14. 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 cannotbe 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.
15. 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.
16. 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.
17. 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
AIRS ID: 123/9933 Page 4 of 7
or Public Health and Environment
Air Pollution Control Division
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 or owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
18. 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.
19. 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:
Christian Lesniak
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Bill Barrett Corporation
Notes to Permit Holder at the time of this permit issuance:
1) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the 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.
2) 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.cdphe. state. co. us/req ulations/ai rregs/100102agcccommonprovisionsreq. pdf.
3) 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 ID: 123/9933 Page 5 of 7
e of Public Health and Environment
Air Pollution Control Division
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
002
n -Hexane
110543
C
217.1
NO
N/A
Benzene
71432
A
24.8
NO
N/A
4) The emission levels contained in this permit are based on the following emission factors
CAS
Pollutant
Emission Factors
Uncontrolled
Ib/BBL loaded
-
Source
Emission Factors
Controlled
Lb/BBL loaded
—
Source
VOC
.219
AP -42
N/A
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) = 7.25 psia
M (vapor molecular weight) = 50 Ib/Ib-mol
T (temperature of liquid loaded) = 519.67 °R
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 of: VOC, HAPs
NANSR
Synthetic Minor Source of: VOC
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
AIRS ID: 123/9933
Page 6 of 7
Public Health and Environment
Air Pollution Control Division
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
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.ustap/oilqaspermitting.html
AIRS ID: 123/9933 Page 7 of 7
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name:
Bill Barrett Corporation
Permit Number:
12WE2445
Source Name:
17282_Cass Farms 11-25H
Source Location:
NWNW 25 8N 62W
Equipment Description:
Condensate Loadout
AIRS ID:
123/9933/005
Review Date:
2/14/13
Review Engineer:
Christian Lesniak
Section 2 — Action Completed
X
CP1
4 Modification
APEN Required/Permit Exempt
Final Approval
Transfer of Ownership
APEN Exempt/Permit Exempt
Section 3 — Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes '
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
X
Yes
No
Did the applicant submit all required paperwork?
X
Yes
No
Did the applicant provide ample information to determine emission rates?
X
Yes
No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
On what date was this application complete?
8/15/2012
Section 4 — Source Description
AIRS Point
Equipment Description
005
Truck Condensate Loadout
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?
PMio
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 II1.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
Pajc 7
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
005
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 [psis]
M = molecular weight of vapors [Ib/Ib-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
005
64,650 BBL per year condensate loaded
Basis for7,Actual Emissionss;Reported Durinq thiAP£N Filing :(Reported to.Inventory)
AIRS Point
Process ConsumptionIThroughput/Production
005
64,650 BBL per year condensate loaded
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
005
64,650 BBL per year condensate loaded
Does this source use a control device?
Yes
X
No
Section 6 — Emission Summary (tons per year)
Point
NO,
VOC
CO
Single HAP
HAP
PTE:
005
7.08
.1 (n -hexane)
.1
Uncontrolled point
source emission rate:
005
7.08
.1 (n -hexane)
.1
Permitted point source
emission rate:
005
7.08
Total
7.08
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(lb/yr)
Am the
emissions
reportable?
Controlled Emission
4bI r
Rate ( y )
Benzene
71432
A
24.8
No
N/A
Page 2
n -Hexane
110543
C
217.1
No
N/A
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?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
X
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?
Yes
X
No
If "yes", for which pollutants? Why?
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?
Yes
No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)?
Yes
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
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
005
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
005
Section I.A - No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are
measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Page 3
Regulation 3 -APENs, Construction Permits, Operating Permits, PSD,
005
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 in non -attainment.
(Applicant is required to file an APEN since emissions exceed 1 ton 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 ll.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/is not 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). Since the tank
battery from which loadout is occurring has not been in service since before the date
above,this source is considered "new or modified." Operator is using 0.6 saturation factor
(submerged fill), therefore, RACT requirements are satisfied.
Regulation 6 - New Source Performance Standards
005
No applicable subpart. This facility is not a bulk gasoline terminal.
Regulation 7 —Volatile Organic Compounds
005
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
005
MACT EEEE:
Not subject because located at a production field facility and thus exempt per 40CFR
63.2334(c)(1).
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process
Description
Process/
throughput
Limit
Emission
Factor
Pollutant /
CAS #
Fugitive
(YIN)
Emission
Factor
Source
Control
(%)
005
01
Truck Condensate
Loadout
64,650
BBL/yr
5.21
lb/1,000
gallon
throughput
VOC
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
P
7.25
Psia
AP -42
M
50
Lb/lb-mole
AP -42
T
519.67
Deg R
AP -42
L
5.21
Lb/10^3 gal
L = 12.46*S*P*M/T
(AP -42)
.219
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 5.21lb/10^3 gal
2.19E-01 lb/bbl
Annual requested Throughput 2715300ga1/yr
Annual requested VOC emissions 141601b/yr
7.08tpy
Page 5
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
PERMIT NO: 1 2WE2446
DATE ISSUED:
ISSUED TO:
Bill Barrett Corporation
CONSTRUCTION PERMIT
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the 17282_ Cass Farms 11-25H, located in the NWNW of
Section 25, Township 8N, Range 62W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Flare
006
"Produced gas venting to one (1) active facility flare (Leed,
EF4X25, SN: 17328) for control of VOC emissions. Flare has a
minimum combustion efficiency of 95%.
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 sea), 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
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: 123/9933 Page 1 of 8
Wellhead Version 2012-1
mentff Public Health and Environment
{II4 Air Pollution Control Division
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
point
Tons per Year
Emission Type
NOx
VOC
CO
Flare
006
3.7
29.4
7.4
Point
See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the 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
Flare
006
Venting of produced gas
VOC
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the 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)
AIRS ID: 123/9933
Page 2 of 8
Process/Consumption Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Flare
006
Natural gas flaring
40.15 MMSCF/yr
r_"ment f Public Health and Environment
Air Pollution Control Division
The owner or operator shall calculate monthly process rates based on the calendar month.
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, The permit number and AIRS ID number shall be marked on the subject equipment for ease
of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable)
10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.)
11. No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30% opacity for a period or periods aggregating more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.)
12. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
13. Upon startup of these points, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in order to demonstrate
compliance on an ongoing basis with the requirements of this permit. Revisions to your
O&M plan are subject to Division approval prior to implementation. (Reference: Regulation
No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
14. The owner or operator shall demonstrate compliance with Condition 11 using EPA Method
22 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5).
Periodic Testing Requirements
15. On an annual basis, the operator shall complete a site specific extended gas analysis of the
natural gas produced at this site that is routed to the flare in order to verify the VOC content
(weight fraction) of this emission stream used in the permit application. Results of testing
shall be used to determine site -specific emission factors using Division approved methods.
AIRS ID: 123/9933 Page 3 of 8
2 rci
el �i menu f Public Health and Environment
Air Pollution Control Division
ADDITIONAL REQUIREMENTS
16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, I I.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 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.
17. 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
18. 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.
19. 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.
20. 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
AIRS ID: 123/9933 Page 4 of 8
f Public Health and Environment
Air Pollution Control Division
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.
21. 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.
22. 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.
23. 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.
24. 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.
Christian Lesniak
Permit Engineer
it Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Bill Barrett Corporation
AIRS ID: 123/9933
Page 5 of 8
._1
e _ rnentlbf Public Health and Environment
` 1:1 Air Pollution Control Division
Notes to Permit Holder:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees
will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3,
Part A, Section VI. B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the permittee providing there is no exceedance of any specific emission control regulation or any ambient
air quality standard. A revised air pollution emission notice (APEN) and application form must be
submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
http://www.cdphe.state.co. us/regulations/airreqs/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)
006
Benzene
71432
A
3302
Yes
165
Toluene
108883
C
2997
Yes
150
Ethylbenzene
100414
C
461
No
23
Xylenes
1130207
C
1316
Yes
66
n -Hexane
110543
C
17803
Yes
890
2,2,4-
Trimethylpentane
540841
C
24
No
1
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Weight
Fraction of
Gas (%)
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
NOx
-_-
0.138
lb/MMBtu
N/A
AP -42
CO
---
0.2755
lb/MMBtu
N/A
AP -42
VOC
42.19
29251.4
lb/mmscf
1462.6
lb/mmscf
Engineering
Calculation
71432
Benzene
0.12
82.2
lb/mmscf
4.1
lb/mmscf
Engineering
Calculation
108883
Toluene
0.11
74.6
lb/mmscf
3.7
lb/mmscf
Engineering
Calculation
AIRS ID: 123/9933
Page 6 of 8
"Colo a De r ment f Public Health and Environment
Air Pollution Control Division
CAS #
Pollutant
Weight
Fraction of
Gas (%)
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
100414
Ethylbenzene
0.017
11.5
lb/mmscf
.57
lb/mmscf
Engineering
Calculation
1330207
Xylenes
0.048
32.8
lb/mmscf
1.6
lb/mmscf
Engineering
Calculation
110543
n -hexane
0.65
443.4
lb/mmscf
22.2
lb/mmscf
Engineering
Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the July 22,
2012 analysis of a gas sample collected from the 17282_Cass Farms 11-25H well. The
controlled VOC and HAP emissions factors for point 006 are based on the flare control
efficiency of 95%.
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
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http:!iecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
i Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN -- Subpart XXXXXX
AIRS ID: 123/9933
Page 7 of 8
f Public Health and Environment
Air Pollution Control Division
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/oilqaspermittinchhtml
AIRS ID: 123/9933 Page 8 of 8
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name: Bill Barrett Corporation
Permit Number:
12W E2446
Source Location:
NWNW 25 8N 62W
Equipment Description:
Plant flare with a combustion efficiency of 95%.
AIRS ID:
Date:
123/9933/006
4/16/13
Review Engineer: Christian Lesniak
Control Engineer:
Carissa Money
Section 2 — Action Completed
Grandfathered
Modification
[ APEN Required/Permit Exempt
X
CPI
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?
Yes
X
No
Did the applicant submit all required paperwork?
Yes
X
No
Did the applicant provide ample information to determine emission rates?
Yes
X
No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
Throughout February and March
On what date was this application complete?
03/25/2013
Section 4 — Source Description
AIRS Point
Equipment Description
Flare/
Se arator
Separator controlled by a flare. Flare has a minimum combustion efficiency of 95%.
The flare is enclosed.
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?
PM10
CO I
X Ozone
Is this location in an attainment maintenance area for
an criteria ollutant?
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)
PM13
CO
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
No
Page 1
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
Flare/
Separator
Site -specific using VOC weight fraction (Refer to Section 14 for calculations)
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
Flare/
Separator
110,000 scf/day => 40,150,000 scf/yr = 40.15 mmscf/yr
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
Flare/
Separator
110,000 scf/day => 40,150,000 scf/yr = 40.15 mmscf/yr
2012
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
Flare/
Separator
110,000 scf/day => 40,150,000 scf/yr = 40.15 mmscf/yr
Section 6 — Emission Summary
(tons per year)
Point
NO,,
VOC
CO
SOx
PM10
Single
HAP
Total
HAP
PTE:
006
3.7
587.2
7.38
---
---
8.9
(n -hexane)
12.7
Uncontrolled point
source emission rate:
006
3.7
587.2.
7.38
---
---
8.9
(n -hexane)
12.7
Controlled point
source emission rate:
006
----
29.4
----
---
---
0.45 (n-
hexane)
0.6
TOTAL PERMITTED
(TPY)
3.7
29.4
7.38
---
---
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(lblyr)
Are the
emissions
reportable?
Controlled Emission
161 r
Rate ( y )
Flare/Separator - Point 006
Benzene
71432
A
3302
Yes
165
Toluene
108883
C
2997
Yes
150
Ethylbenzene
100414
C
461
No
23
Xylenes
1130207
C
1316
Yes
66
n -Hexane
110543
C
17803
Yes
810
2,2,4-Trimethylpentane
540841
C
24
No
1
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
Page 2
If "yes". complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
006
01
Opacity
Reg. 1
EPA Method 9
Section 9 — Source Classification
Is this a new previously un-permitted source?
Yes
True
Minor
X
Synthetic
Minor
Major
What is this facility classification?
Classification relates to what programs?
X
Title V
X
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? VOC
For Reg. 3, Part B, I II.C.1.a (emissions increase > 25 tpy)?
1
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 - Particulates Smoke, Carbon Monoxide and Sulfur Dioxide
006
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or
operator of a source shall allow or cause the emission into the atmosphere of any air
pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive
opacity readings taken at 15 -second intervals for six minutes. The approved reference test
method for visible emissions measurement is EPA Method 9 (40 CFR. Part 60, Appendix
A (July, 1992)) in all subsections of Section II. A and B of this regulation.
Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner
or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty
consecutive minutes.
I
Regulation 2 — Odor
006
Section I.A - No person, wherever located, shall cause or allow the emission of odorous
air contaminants from any single source such as to result in detectable odors which are
measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Page 3
Regulation 3 - APENs, Construction Permits, Operating Permits PSD:
006
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 in non -attainment.
(Applicant is required to file an APEN since emissions exceed 1 tons per year VOC)
006
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 11.D.3.a)
Regulation 6 - New Source Performance Standards
006
None
Regulation 7 — Volatile Organic Co mounds
Reg ulation 8 — Hazardous Air Pollutants
006
None
Section 13 — Aerometric Information Retrieval System Coding
Information
Point
Process
Process Description
Emission
Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor
Source
Control
(%)
Control EF
006
01
Flare
29251.4
lb/mmscf
VOC
No
Engineering
Calculation
95
1462.6
lb/mmscf
0.138
lb/MMBtu
N0x
No
AP -42,
Table 13.5-1
NA
0.138
lb/MMBtu
0.2755
lb/MMBtu
CO
No
AP -42,
Table 13.5-1
NA
0.2755
lb/MMBtu
82.2
lb/mmscf
Benzene
No
Engineering
Calculation
95
4.1
lb/mmscf
74.6
lb/mmscf
Toluene
No
Engineering
Calculation
95
3.7
lb/mmscf
11.5
lb/mmscf
Ethlybenzene
No
Engineering
Calculation
95
.57
lb/mmscf
32.8
lb/mmscf
Xylenes
y
No
Engineering
Calculation
95
1.6
lb/mmscf
443.4
lb/mmscf
n -hexane
No
Engineering
Calculation
95
22.2
lb/mmscf
SCC
31000205 -Flares
Page 4
Section 14 — Miscellaneous Application Notes
AIRS Point
006
Flare
Emission Factors for NOx and CO were taken from TNRCC Table 4 — Values for High Heat Value were
used.
Emissions were calculated using VOC wt fraction.
(scf/hr) * (Ib/Ib-mol) * (% fraction from sales gas analysis) / (379.4 scf/Ib-mol) = lb/hr * (hr/yr) / 2000 lb/T) =
TPY
VOC = (587.2 TPY * 2000 lb/T) / (40.15 mmscf/yr = 29,251.4 lb/mmscf
NOx and CO (from TNRCC Flaring Guidance, Table 4 (NOx = 0.138 lb/mmbtu; CO = 0.2755 lb/mmbtu)
Emission factors for HAPS are:
Benzene = (3302 Ib/yr) / 40.15 mmscf/yr = 82.24 lb/mmscf
Toluene = (2997 Ib/yr) / 40.15 mmscf/yr = 74.64 lb/mmscf
Ethylbenzene = (461 Ib/yr) / 40.15 mmscf/yr = 11.49 lb/mmscf
Xylenes= (1316 Ib/yr) / 40.15 mmscf/yr = 32.78 lb/mmscf
n -hexane = (17803 Ib/yr) / 40.15 mmscf/yr = 443.41 lb/mmscf
Operator provided an extended gas analysis and emissions were calculated using EPA Emission
Inventory Improvement Program Publication, Volume II, Chapter 10 -Displacement equation (10.4-3)
where:
Ex = Q * MW * Xx / C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Emissions generated from the flare are:
Uncontrolled Total (Ib/yr)
Controlled Total (lb/yr)
NOx
3.70
VOC
587.2
29.361
CO
7.38
Benzene
3302
165
Toluene
2997
150
Ethylbenzene
461
23
Xylenes
1316
66
n -hexane
17803
890
224-TMP
24
1
An extended gas analysis was provided in the application dated 05/23/2012. The gas analysis was
perfomed less than a year of submittal. An updated extended gas analysis will not be required.
The source contacted me before I was able to complete the permit with revisions to their APENs for the
flare and fugitives. The old gas analysis was about 61 percent VOC, and the new gas analysis, dated
07/22/2012, is about 42 percent VOC. The analysis is site -specific and I am accepting it. Looking over the
facility -wide emissions, it appears that the source can use the new throughputs, which have greatly
increased, resulting in a slight increase in VOC, and still keep its GP02s. Regulatory applicability has not
changed due to this revision.
Regarding public comment, this source by itself is considered for public comment due to it causing that
need for synthetic minor limits. However, as a project, the grouping of this source with the condensate
loading and fugitives permits causes an additional reason for public comment — The summed VOC
emissions for the three sources are above 25 tons in a non -attainment area.
Page 5
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
12WE2447
Issuance 1
DATE ISSUED:
ISSUED TO: Bill Barrett Corporation, Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the 17282 Cass Farms 11-25H, located in the NWNW,
Section 25, Township 8N R62W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Fugitives
007
Equipment leaks (fugitive VOCs) from a natural gas exploration
and production facility.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
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 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 application associated with this permit; (ii) discontinues construction for a period
AIRS ID: 123/9933 Page 1 of 8
Fugitive SM/M Version 2012-2
en Of PlrzIbliddHealth and Environment
Pollution Control Division
it VA d
of eighteen m rttb me" F(ili)' co.es noLcoMSiete conc..ction 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,
IILF.4.)
4. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. 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
VOC
Fugitives
007
2.75
Fugitive
See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the 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.
6. 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.
STATE AND FEDERAL REGULATORY REQUIREMENTS
7. 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.)
8. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
AIRS ID: 123/9933 Page 2 of 8
f P µolic-Health and Environment
it Pollution Control Division
9. This source isc'Tbj '°to R • ulati x 7 SeotNInXII.C ,.-eeral 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. .
10. Minor sources in designated nonattainment or attainment/maintenance areas that are
otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply
Reasonably Available Control Technology (RACT) for the pollutants for which the area is
nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B,
III.D.2.a). This requirement to apply RACT shall be satisfied by installing/implementing
the following emission controls:
a. Directed Inspection & Maintenance as described below shall satisfy the
requirement to apply RACT.
i. For leak screening, auditory/visual/olfactory inspection (AVO) will be
performed on a quarterly basis.
H. For each leak found in the AVO inspection, a gas detector shall be
used to determine the size of the leak. The gas detector shall be
regularly calibrated. Component leaks greater than 10,000 ppm shall
be managed in accordance with Item (vi) below, unless it is unfeasible
to make the repair without shutting down the affected operation of the
facility. For such component leaks that require a shutdown to be
repaired, repair shall occur during the first shutdown of the affected
operation after the leak is discovered.
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
11. This source is not required to follow a Division -approved operating and maintenance
plan.
AIRS ID: 123/9933 Page 3 of 8
Health and Environment
air Pollution Control Division
COMPLIANCE TESTING "'N
Initial Testing Requirements
12. 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
13. 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
14. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, ll.C)
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 (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.
15. 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
AIRS ID: 123/9933 Page 4 of 8
t lieHealth and Environment
it Pollution Control Division
h3
not exceed th a �= g e al pr r shoId •uatilta-, permit granted. (Regulation No. 3
Part D).
GENERAL TERMS AND CONDITIONS:
16, 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.
17. 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.
18. 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.
19. 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.
20. 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 owner or operator, or the
Division revokes a permit, the owner or operator or owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
21. 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.
22, 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.
AIRS ID: 123/9933 Page 5 of 8
li Health and Environment
it Pollution Control Division
By:
Christian Lesniak
Permit Engineer
Permit Histo
issuance
Date
Description
Issuance 1
This Issuance
Issued to Bill Barrett Corporation, Inc.
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The 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.cdphe.state.co.us/requlations/airreqs/1 001 02acicccommonprovisionsreq.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
(lb/yr)
007
Benzene
71432
A
55
Yes
55
Toluene
108883
C
101
No
101
Ethylbenzene
100414
C
190
No
190
Xylenes
1330207
C
90
No
90
n -Hexane
110543
C
200
No
200
5) The emission levels contained in this permit are based on the following emission factors:
Component
Gas Service
Heavy Oil
Light Oil
Water/Oil
AIRS ID: 123/9933
Page 6 of 8
lic'Health and Environment
it Pollution Control Division
r :
3 A& 46
Am
Service
Connectors
605
0
186
52
Flanges
1
0
0
0
Open-ended Lines
0
0
0
0
Pump Seals
0
0
0
0
Valves
44
0
42
8
Other*
0
0
0
0
VOC Content (wt.
fraction)
0.4218
0
.9986
.9986
Benzene Content (wt.
fraction)
0.0012
0
0.012
0.012
Toluene Content (wt.
fraction)
0.0011
0
0.027
0.027
Ethylbenzene (wt.
fraction)
0.0002
0
0.007
0.007
Xylenes Content (wt.
fraction)
0.0005
0
0.030
0.030
n -hexane Content (wt.
fraction)
0.0064
0
0.055
0.055
*Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms,
drains, dump arms, hatches, instrument meters, polish rods and vents
TOC Emission Factors (kg/hr-component):
Component
Gas Service
Heavy Oil
Light Oil
Water/Oil
Service
Connectors
2.0E-04
7.5E-06
2.1E-04
1.1E-04
Flanges
3.9E-04
3.9E-07
1.1E-04
2.9E-06
Open-ended Lines
2.0E-03
1.4E-04
1.4E-03
2.5E-04
Pump Seals
2.4E-03
NA
1.3E-02
2.4E-05
Valves
4.5E-03
8.4E-06
2.5E-03
9.8E-05
Other
8.8E-03
3.2E-05
7.5E-03
1.4E-02
Source: EPA -453/R95-017
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission
factors listed in the table above with representative component counts, multiplied by the VOC content
from the most recent gas 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
AIRS ID: 123/9933
Page 7 of 8
olorarDeparnen. f Pblii Health and Environment
it Pollution Control Division
rol
W
NANSR '` '
xo ,k, 1�- J' i ..
Syntfiet Mi Sdbrc 1%OC u`"�'
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
NSPS KKK
Not Applicable
NSPS OOOO
Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
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/oildaspermittind.html.
AIRS ID: 123/9933 Page 8 of 8
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Bill Barrett Corporation, Inc.
Permit Number:
12WE2447
Source Location:
NWNW 25 8N 62W
Equipment Description:
i AIRS ID:
Fugitives
123/9933/007
Date:
4/16/2013
Review Engineer:
Christian Lesniak
Control Engineer:
Carissa Money
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
CP1
Transfer of Ownership
APEN Exempt/Permit Exempt
Section 3 — Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
Yes
X
No
Did the applicant submit all required paperwork?
Yes
X
No
Did the applicant provide ample information to determine emission rates?
Yes
X
No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
Throughout February and March
On what date was this application complete?
3/25/2013
Section 4 — Source Description
AIRS Point
Equipment Description
007
Fugitive VOC leak emissions
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?
PM13
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.2L
PM,o
CO
Ozone
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
Regulation 7, Sections XII and XVII.C ma _apply)
X
Yes
No
Page 1
Section 5 — Emission Estimate Information
AIRS
Point
Emission Factor Source
007
EPA -453/R-95-017, Table 2-4
Did the applicant provide actual process data for the emission inventory?
X
Yes
No
Basis for Potential to Emit (PTE)
AIRS
Point
Process Consumption/Throughput/Production
007
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
605
0
186
52
Flanges
1
0
0
0
Open -Ended Lines
0
0
0
0
Pump Seals
0
0
0
0
Valves
44
0
42
8
Other
0
0
0
0
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS
Point
Process Consumption/Throughput/Production
007
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
605
0
186
52
Flanges
1
0
0
0
Open -Ended Lines
0
0
0
0
Pump Seals
0
0
0
0
Valves
44
0
42
8
Other
0
0
0
0 __
Basis for Permitted Emissions (Permit Limits)
AIRS
Point
Process Consumption/Throughput/Production
007
Equipment Type
Gas
Heavy Oil (or
Heavy
Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
605
0
186
52
Flanges
1
0
0
0
Open -Ended Lines
0
0
0
0
Pump Seals
0
0
0
0
Valves
44
0
42
8
Other
0
0
0
0
Does this source use a control device?
Yes
X
No
Section 6 — Emission Summary (tons per year)
Point
NO,,
VOC
CO
Single HAP
Total HAP
PTE:
007
2.75
0.1 (Hexane)
0.3
Uncontrolled point
source emission rate:
007
2.75
0.1 (Hexane)
0.3
Total APEN Reported
emissions:
2.75
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(lb/yr)
Are the
emissions
reportable?
Controlled Emission
Ib! r
Rate ( Y )
Benzene
71432
A
55
Yes
N/A
Page 2
Toluene
108883
C
101
No
N/A
Ethylbenzene
100414
C
' 190
No
N/A
Xylenes
1330207
C
90
No
N/A
n -Hexane
110543
C
200
No
N/A
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?
I
Yes
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 1 X
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 I
No
If "yes", for which pollutants? Why?
(Total project >25 tons)
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?
X
Yes
�No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
Yes
No
AIRS Point
Section 12 — Regulatory Review
Regulation 1 - Particulate. Smoke. Carbon Monoxide and Sulfur Dioxide,. •`.
007
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.
Regulation 2 — Odor
007
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
Re•ulation 3-APENs Construction Permits, Operating Permits, PSD
007
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 in non -attainment.
(Applicant is required to file an APEN since emissions exceed 1 tons per year VOC)
007
Part B - Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section Il.D.3.a)
007
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.
Operator has agreed on the Division's standard conditions.
Re•ulation 6 - New Source Performance Standards
007
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
007
NSPS 0000: Standards of Performance for Crude Oil and Natural Gas Production,
Transmission and Distribution. For fugitive emissions at natural gas processing
plants subject to NSPS 0000. This subpart establishes emission standards and
compliance schedules for the control of volatile organic compounds (VOC) and
sulfur dioxide (S02 ) emissions from affected facilities that commence construction,
modification or reconstruction after August 23, 2011.
Is this source subject to NSPS 0000? No
Regulation 7 - Volatile Organic Compounds
007
Section XII.G: If facility is a natural gas processing plant located in non -attainment
area, then subject to Section XII.G.
Regulation 8 — Hazardous Air Pollutants
007
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
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process Description
Pollutant/
CAS #
Fugitive
(Y/N)
Emission Factor
Source
Control
(%)
007
01
Fugitive VOC Leak
Emissions
VOC
Yes
EPA -453/R-95-017,
Table 2-4
NA
Benzene / 71432
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
Before finishing this permit, the source contacted me to change this permit and the flaring permit. The
new gas analysis sent was from 07/22/12 and was site specific. The previous gas analysis sent was from
05/23/2012. I have accepted the new analysis, which lowers all emissions.
This goes to public comment because adding this total to the flare puts the project above 25 tons.
007
Fugitive VOC Leak Emissions
Page 4
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Section 01 — Administrative Information
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Section 01 —Administrative information
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Section 06 — Location Information (Provide Datum and either Lat/Long or UTM)
Section 07 —Leak Detection & Repair (LOAD) & Control Informati
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