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Home My WebLink About20131082.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 April 26, 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 RECEIVED MAY 0 1 2013 WELD COUNTY COMMISSIONERS On April 30, 2013, the Air Pollution Control Division will publish a public notice for Anadarko E&P Company LP — 36018976, 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 �u r� Jce“-) pt, TS�/13 2013-1082 Stephanie Chaousy 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 ryW- COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 12WE1325 Issuance 1 DATE ISSUED: ISSUED TO: Anadarko E&P Company LP THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the 36018976, located in the NWNW Section 1, Township 8N, Range 67W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description FUG1 003 Equipment leaks (fugitive VOCs) from a natural gas exploration and production facility. PG -Flare 1 004 48" Flare with a minimum combustion efficiency of 95%. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMM SSION 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. 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). 2. 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 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.) AIRS ID: 123/9400 Page 1 of 10 Fugitive SM/M Version 2012-2 eparkinen` Ii&'Health and Environment (Air Pollution Control Division 3. The operator ple I Elal"complianQeting a®®' ampling 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.) 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 FUG1 003 8.6 Fugitive PG -Flare 1 004 5.2 Point See "Notes to Permit Holder' for information on emission factors and methods use 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. 6. Point 001: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas analysis, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing 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 PG -Flare 1 004 Natural gas flaring 9125 MSCF/yr AIRS ID: 123/9400 Page 2 of 10 Depar nen of Pa, blic Health and Environment Cdr Pollution Control Division Compliance �p ° s�, ear -to"�� throhimits Abe 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 monthly natural gas throughput and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. 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.) 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. Point 003: This source is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). All condensate collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. The operator shall comply with all applicable requirements of Section XII. 11. Point 003: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). The requirements of condition number 12 below were determined to be RACT for this source. 12. Point 003: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (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 twice a year. (ii) For each leak found in the AVO inspection, use either optical gas imaging (i.e. IR camera) or portable VOC measurement instrument (i.e. a Method 21 instrument) calibrated and maintained per the manufacturer's recommendations to monitor for leaks. (iii) If Method 21 is used, 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. If optical gas imaging is used, a component shall be AIRS ID: 123/9400 Page 3 of 10 ;olora � DepaWnen4&f P clef d Lei ingL,ifany visjt blec tnission ''' monitored and 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." (iv) For repair, valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. (v) Repaired components shall be re -screened to determine if the leak is repaired. (vi) 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. (vii) 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. 13. Point 004: 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) 14. Point 004: 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 I I.A.5:). OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. Point 004: The operator shall complete an initial site specific extended gas analysis of the natural gas produced at this site that is either routed to the open flame flare or vented through the emergency blowdown tank in order to verify the VOC, benzene, toluene, n -hexane, and xylene content (weight fraction) of this emission stream used in the permit application. 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. ic!Health and Environment -kir Pollution Control Division AIRS ID: 123/9400 Page 4 of 10 IicHealth and Environment it Pollution Control Division 17. Point 004: Tti= ®bi+ `er • ,-ope.tQl'sha _ - trate ®r...liance with Condition 13 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5). Periodic Testing Requirements 18. Point 003: 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 19. 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 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. 20. 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). 21, MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major AIRS ID: 123/9400 Page 5 of 10 Iic Health and Environment it Pollution Control Division solely by virtueyof a�`rela t+oft in y ' nit itatio, _nd shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS: 22. 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. 23. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the 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. 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the 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. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, AIRS ID: 123/9400 Page 6 of 10 IicdHealth and Environment it Pollution Control Division civil or crimiS ceu rlt e t4 u ions 25,a-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Anadarko E&P Company LP Newly permitted flare and associated facility fugitives at a synthetic minor facility. AIRS ID: 123/9400 Page 7 of 10 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 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/regulations/ai rregs/ 100102agcccomm onprovisionsreq. 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. e -the of this hermit psi an blicuHealth and Environment it Pollution Control Division AIRS Point Pollutant CAS # BIN Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 003 Benzene 71432 A 52 Yes 52 Toluene 108883 C 92 No 92 Ethylbenzene 100414 C 52 No 52 Xylenes 1330207 C 107 No 107 n -Hexane 110543 C 364 No 364 004 Benzene 71432 A 701 Yes 35 n -Hexane 110543 C 6142 Yes 307 5) The emission levels contained in this permit are based on the following emission factors: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 1048 0 575 42 Flanges 5 0 1 0 Open-ended Lines 0 0 0 0 Pump Seals 1 0 0 0 Valves 177 0 75 13 Other* 15 0 5 3 VOC Content (wt. fraction) 0.3020 --- 1 1 Benzene Content (wt. fraction) 0.00102 0 0.00276 0.00276 Toluene Content (wt. fraction) 0.00061 0 0.00829 0.00829 AIRS ID: 123/9400 Page 8 of 10 Health and Environment it Pollution Control Division Ethylbenzene (wt. rf Jsti4 " 0 ti 8._ n19,0.00555 0.00555 Xylenes Content (wt fraction) 0.000097 0 0.01139 0.01139 n -hexane Content (wt. fraction) 0.00896 0 0.0139 0.0139 *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 Note that the emission limits included in this permit are derived by multiplying the equipment counts in the table above by a factor of 1.2 to accommodate other minor changes to the facility and to provide a conservative estimate of facility -wide emissions. Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable NSPS KKK 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/ AIRS ID: 123/9400 Page 9 of 10 6,4 lid Health and Environment it Pollution Control Division Part 60: Standar rforma a for -New Sta 5/-Sourc -' 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/oi Igasperm itting. htm I AIRS ID: 123/9400 Page 10 of 10 Construction Permit Application Preliminary Analysis Summary Section 1 — Applicant Information Company Name: Anadarko E&P Company LP Permit Number: 12WE1325 Source Location: NWNW Section 1, T8N, R67W, Weld County (non -attainment) Equipment Description: Point 003: Fugitive emissions Point 004: Facility flare AIRS ID: 123-9400 Date: June 25, 2012 Review Engineer: Stephanie Chaousy, PE Control Engineer: Carissa Money, PE 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? 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? 6/25/12: I emailed the operator asking about RACT for the fugitives and an O&M plan for the flare. Please see Section 14. On what date was this application complete? March 9, 2012 Section 4 - Source Description AIRS Point Equipment Description 003 Fugitive V0C leak emissions 004 48" Flare with a minimum combustion efficiency of 95%. Is this a portable source? Yes X No Is this location in a non -attainment area for any criteria pollutant? X Yes No X i Ozone If "yes", for what pollutant? PM10 , CO Is this location in an attainment maintenance area for any criteria pollutant? Yes X No If "yes", for what pollutant? (Note: These pollutants are subject to minor source RACT per Regulation 3, Part B, Section III.D.2) PM,o CO Ozone Is this source located in the 8 -hour ozone non - attainment region? (Note: If "yes" the provisions of Regulation 7, Sections XII and XVII.C may apply) X Yes No Page 1 Section 5 — Emission Estimate Information AIRS Point Emission Factor Source 003 EPA -453/R-95-017, Table 2-4 004 For NOx and CO: AP -42 For VOC and HAPS: Flowrate/wt. fraction Please see 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 Year Inventory 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil 2011 Connectors 1049 --- 575 42 Flanges 5 --- 1 0 Open -Ended Lines 0 --- 0 0 Pump Seals 1 --- 0 0 Valves 177 --- 75 13 Other 15 --- 5 3 004 9125 MCF/yr 2011 Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors 1049 --- 575 42 Flanges 5 --- 1 0 Open -Ended Lines 0 --- 0 0 Pump Seals 1 --- 0 0 Valves 177 --- 75 13 Other 15 --- 5 3 004 9125 MCF/yr Basis for Permitted Emissions (Permit Limits1 AIRS Point Process Consumption/Throughput/Production 003 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors 1049 --- 575 42 Flanges 5 --- 1 0 Open -Ended Lines 0 --- 0 0 Pump Seals 1 --- 0 0 Valves 177 --- 75 13 Other 15 --- 5 3 004 9125 MCF/yr Does th's source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted Page 2 004 01 48" Flare 95 Section 6 — Emission Summary (tons per year) Point NOx VOC CO Single HAP Total HAP PTE: 003 --- 8.6 --- 0.2 (Hexane) 0,3 004 0.4 103.6 2.1 3.1 (Hexane) 3.4 Uncontrolled point source emission rate: 003 --- 8.6 --- 0.2 (Hexane) 0.3 004 0.4 103.6 2.1 3.1 (Hexane) 3.4 Controlled point source emission rate: 003 --- 8.6 --- 0.2 (Hexane) 0.3 004 0.4 5.2 2.1 0.2 (Hexane) 0.2 Total APEN Reported emissions for this modification: 0.4 13.8 2.1 0.4 0.5 Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # 1Uncontrolled BIN Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) Point 003 Benzene 71432 A 52.2 Yes 52.2 Toluene 108883 C 91.8 No 91.8 Ethylbenzene 100414 C 52.2 No 52.2 Xylenes 1330207 C 106.5 No 106.5 n -Hexane 110543 C 364.2 No 364.2 Point 004 Benzene 71432 A 701 Yes 35 n -Hexane 110543 C I 6142 Yes 307 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non -criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Section 8 —Testing Requirements Will testing be required to show compliance with any emission rate or regulatory standard? X Yes No If "yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 004 01 VOC/HAP State -only Extended gas analysis Section 9 — Source Classification Is this a new previously un-permitted source? X Yes No What is this point classification? Point 003: True Minor Point 004: Synthetic Minor Major What is this facility classification? True Minor X Synthetic Minor Major Classification relates to what programs? I Xi Title V PSD X NA NSR MACT Page 3 Is this a modification to an existing permit? Yes X No If "yes" what kind of modification? Minor Synthetic Minor Major Section 10 — Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If "yes, for which pollutants? Why? For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? 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? Yes X No AIRS Point Section 12 — Regulatory Review Requlation 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. Requlation 2 — Odor 003, 004 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. Requlation 3 - APENs, Construction Permits, Operating Permits, PSD 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 exceed 1 ton per year VOC) 003, 004 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 8, Section 11.D.2.a) Requlation 6 - New Source Performance Standards 003 NSPS KKK: Equipment Leaks of VOC from onshore natural gas processing plants. Affected facilities at onshore natural gas facilities (any processing site engaged in the extraction of natural gas liquids from field gas, fractionation of mixed natural gas liquids (NGLs) or both). Is this source at a "natural gas processing plant?" No Is this source subject to NSPS KKK? No WHY? Facility does not meet the definition of a "natural gas plant." Therefore, not subject. 004 None Page 4 Regulation 7 - Volatile Organic Compounds 003, 004 None Rice ulation 8 - Hazardous Air Pollutants 003 MACT HH: If facility is MAJOR source for HAP (summation of HAPS of dehydrators and fugitives), then fugitive emissions are subject to MACT HH. Is this facility considered MAJOR for HAPS? No Is this source subject to MACT HH? No WHY? Area source MACT HH is only subject to TEG dehydrators. There are no dehydrators at this facility, so it is not subject. 004 None I Section 13 — Aerometric Information Retrieval System Coding Information Point Process Process Description Pollutant / CAS # Fugitive (Y/N) Emission Factor Source Control (%) 003 01 Fugitive V0C Leak Emissions V0C Yes EPA -453/R-95-017, Table 2-4 NA SCC 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) 001 01 22.707 lb/scf VOC No Engineering Calculation 95 0.068 Ib/MMBtu NOx No AP -42 0 Flare 0'37 lb/MMBtu CO No AP -42 0 0.077 Jb/scf Benzene No Engineering Calculation 95 0.673 lb/scf n -hexane No Engineering Calculation 95 SCC 31000205 -Flares Page 5 Section 14 — Miscellaneous Application Notes AIRS Point 003 Fugitive VOC Leak Emissions A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit threshold). Operator provided a Notice of Startup with the application. Therefore, I will not require it in the permit. Operator provided an extended gas analysis with a sample date of 8/30/11. This was done less than a year of the date of application. Therefore, I am not going to request another initial gas analysis. A hard component count was done on 12/5/2011 (date of application was 3/9/2012). Since this count was done within 6 months of application date, and nothing new has been added to the facility since this count, I will not require an initial hard count requirement. I worked with the operator to determine RACT for this facility. I emailed KMG a condition based on AVO that might be sufficient for RACT on 7/19/12. Kerr-McGee did not think that the Division's condition was applicable to their facility because KMG felt that if they were to follow this condition, they should receive control credit since they felt it was a smaller version of a LDAR program. We had several back and forth email conversations regarding this. Some suggestions KMG brought up to satisfy RACT were: 1. The O&M plan: The Division felt that the O&M did not fully meet all the criteria for RACT. 2. 2. Using screening factors: Chris emailed KMG on 3/14/13 saying that the Division will not accept screening emission factors to represent uncontrolled fugitive emissions. KMG must use the average emission factor approach to calculate uncontrolled emissions from fugitive sources. Carissa Money emailed me on 3/20/13 (per meetings and emails with KMG): Please move forward with processing the Kerr McGee E&P site applications that were on hold due to the minor source RACT condition for fugitives. Kerr McGee has been notified that we are moving forward with existing applications using our standard language for minor source RACT. For these applications, we will use our standard emission calculation methodology for fugitives and we will not be assigning a control efficiency for implementing the minor source RACT requirements. If Kerr McGee has not yet seen a draft of the permits and requested to see a draft, please do send them the draft but we will not modify the minor source RACT condition for fugitives. If you have any questions, let me know. AIRS Point 004 Flare A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit threshold). Operator provided a Notice of Startup with the application. Therefore, I will not require it in the permit. Operator used AP -42 emission factors for NOx and CO. Site -specific emission factors using flowrate and wt. fraction for VOC and HAPS. VOC = (103.6 TPY * 2000 lb/T) /9125 SCF/yr = 22.707 lb/scf Benzene = (700.97 Ib/yr) / 9125 SCF/yr = 0.077 lb/scf n -hexane = (6142.25 lb/yr) / 9125 SCF/yr = 0.673 Ib/scf Page 6 £OZ-aDdv EAU a CD NJ r C) co n n CD CD n N' Cr C- II n o o0 F 0 N a I El u a 1 CD 3 3 o T N 'r c i m S 1 0Z-ajda wioj 123-9400-003-APEN-2012-03-09-01 Identify the VOC & HAP content of each applicable stream: a 0 O a 611 Z v N to 3 m n 2 N o cn » C- 7 Di s m d a co Is this equipment subject to NESHAP 40 CFR Part 63, Subpart HI -I? Is this equipment subject to NSPS 40 CFR Part 60, Subpart KKK? O O CO CD N 1'/1 0 0 all - 170 uoi;gag uoi;emmjul 0'< O Z 0 O O O a 0 aa a m rt 0 0 0 a 0 Irs -0 a m n z DI ct O J9 a s • a 5 - ID r m ro C a e/sn•oDa;e;sdaq a D oT 3 — o W E O_ F .N N J N u' 0 0 J 0 0 ao a J H o 3 o 0 2 3 ca a J O LULU 0 pl O O O a LOW LO 3 1.0 i° LO rt N N N W W 3 -4 cri in W 0 0 ro In Z 0 3 Brief description of equipment associated with these components: s}uauodwon engl6n; app -Am 00 3 o y x, c0 LO o c co m R m a C O CO. J 0 0 J NJ 0 C a 0 rn 0 N O For new or reconstructed sources, the projected startu a m n 03 - General Information rn woa•mpepeue©an !l000rauuatneN :ssaippV lie Fax Number: (720) 929-7511 fo C R ^^ M fl w o T C o a C m m a 0 CD 3 m a vi d o I J O a 9 Fn` Z eu m a 3 n s N cn J co CD a 0 3 3 0 a c 2 Person To Contact: Katherine Doolittle Phone Number: (720) 929-6511 O n O Mailing Address: PO Box 173779 6L1£-LIZ08 :apt d!Z fin C C n ID y. PP O 9 _ m 3 C c z R H d d a 91 Cu CD CD ti Ct. 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Form APCD-203 - FugitiveComponentLeaks A N P 0 C a O ab le}uawuO MAu3.101 V - 60 voll3eS ta NI z= CD c N_ C 0(/� 6 1/1 1 n o J 01 m R m f7 a F fo 3 2 Q N m n .Q 0 o m MI NC0 7 . a (n O FT 4 m v QA - C J - PD O F CD o < N o D O 4 ncn a Ea _o at c Ft o m O O 3 N. 0 O N J p1 n o o o F a= as O. - JO 0 CD o m J r J m d -n a om J u1 o c 2. 3 l o I":o Q. ¢ y o 5 0 N O. Ul C 0 O O' 4 C O 0 N d a c, a oa S V co S in 01 0 1751 Emission Factor Documentation attached m rn m O d 02. n a its tie N ED A cr fD C N La NS C V a ?d m r E I 8 n F o 7 o 01 2 II A o ¢ O- o o N N v o DJ o C H T m T a 0 m J a 'o q � 3 3 CD rt' m 0 N = F rn o2 m dm 2. r O a ao 1 (p -` A 3 C 0 0 F 3 Lb _ �: Q Bo N O 0 3 o a 0 . O mV�m CD O. ° to o o u.2 a C 2 a C 3 oJ C 0 5.1 N s m co o N F CD ° ° ¢ 3 T = a m v d m m m o A O � o o a n . 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Info & Notes: There is no natural gas gathering in place at this location y Email Address: Katherine.Doolittle@anadarko.com Fax Number: (720) 929-7511 Person To Contact: Katherine Doolittle Phone Number: (720) 929-6511 O O 6LLE-LTZ08 :apop dl2 Mailing Address: PO Box 173779 1 JO C A C C a ≤. I'D P. a N T a O c '0 U^ no -< o 2 rit 0, O - C 10 = a to m n R 2 ai (D (0 = O 3 m -c 0 o ° m .c+ n n3 T S (0 S DJ V R LO (D O ro 3 G 0 (D 0 a0 01 0 a O Q N 0 (n v c 0 n T Request to limit HAPs with a Federally enforceable limit on PTE :uogeaoi aaanos Z In ML9 :N 'N8 :1 m n c c c LC w m 0 a N CO 9L68T09£ :aweN °Janos Company Name: Anadarko E&P Company LP Section 01 - Administrative Information 1n2 nn n fn a • 0 o xi xi Es S T A N CCD O N DJ Ol CO VI M M R w ' I1' 1 (D 0D O p ft (D C0 a w < C o n r * ro n 9 m m 0 -, c• y y 6 3 ® e 3 0 a n r re n M O 7 7 ff 9 a0 % 4 m o ® M R3€ .. a e R i.s08a m e 0 flIA1 digs Facility Equipment ID: PG-Flarel .aagwngd 1pwaad A conn N 17 r 0 P C9 ni 0 10 0 0 &I 0 C C N K n A W o- co ' ---- co Q A.0 R 0 71 S 0- a to O 0 0 A W D A N 9 C CD CD CD a 3 o N N 0 01 M N o D Di N S B. CDN -00 n01 ID = M c 9 =, Q d m a al O O = c m 0' CD 0 3 ex 0 0 v 0 o y c a o- - ao O a 8 m N ❑ O o N C O w 0CD O ry o 9 CD N UV C In m s A ro n v Z 0 i N ti m 0 d Q m .a 0 C n a e3 uolsslw3 or Documentation attached Data year for actual calendar yr. emissions below & fuel use above (e.g. 2007): rO 3 co a 3 O 7 O 0 o a O a C 7 m Ra 3 C H 0 7 3(71 o a 7 m 'I 3 0 3 m 0 Section 0.7 - Emissions Invento 51 fD a n g n B Wi •..• C, 7 - v !`F v 71 CD a m a O � B 5 ed 0 o 0 5 9. cn i II d s d a C wnsuo3 land rg buew uol;ewJo;ul uol (sayaul) U]P!M aagno lo uorpana 71 0 F V 0 m. r.Prco 0 O C O'. n aA C Si N p ND L. m 0 0 co w C T O 0 LO N a N: 0.3. m a 0 - COO) I; tiAbEA m m 0 CD m O CD ED CD 7 O Cr. In CD CD n d N C CD c 0 co co m rt co m cu 3 m co - to :JagwnN;Iwtad O r r c T 3 in � z z A rn z d O rn A ni 3 O ET O g C I M R 9 W rt LD a- R O Hello