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Home My WebLink About20130328.tiffSTATE OF COLORADO John W. Hickenlooper, Governor Christopher F. 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 January 23, 2013 Mr. Steve Moreno Weld County Clerk 1402 N. 17th Ave. Greeley, CO 80631 Dear Mr. Moreno: Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Colorado Department of Public Health and Environment The Air Pollution Control Division will publish a public notice for Marathon Oil Company. This public notice will be published in the Greeley Tribune on January 27, 2013. Thank you for assisting the Division by making the enclosed package (includes public notice. preliminary analysis, Air Pollutant Emission Notice(s) and draft permit(s)) available for public review and comment. It must be available for public inspection for a period of thirty (30) days from the date the public notice is published. Please forward any comment regarding this public notice to the address below. Colorado Department of Public Health and Environment APCD-SS-Bl 4300 Cherry Creek Drive South Denver, CO 80246-1530 Attention: Ellen Evans Regards, Ellen Evans Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Ida C- Pt ,H (--7q-/3 2013-0328 STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver. Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe. state.co. us Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Website Title: Marathon Oil Company — EL -4-63-36-1H I -- Weld County Released to: The Greeley Tribune on January 23, 2013, published January 27, 2013 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT Colorado Department of Public Health and Environment The Colorado Air Pollution Control Division declares the following proposed construction activity warrants public comment. Therefore, the Air Pollution Control Division of the Colorado Department of Public Health and Environment hereby gives NOTICE, pursuant to Section 25-7- 114.5(5), C.R.S. of the Colorado Air Quality Control Act that the Division received an application for an air pollution emission permit on the following proposed project and activity: Marathon Oil Company proposes to operate a natural gas exploration and production wellhead site located at the SWSW of Section 36, Township 4 North, Range 63 West in Weld County . The company has submitted an application requesting issuance of a federally enforceable synthetic minor source permit limiting the potential to emit. As a synthetic minor source the permit is subject to public comment per Regulation 3, Part B, Section III.C. I . the Division hereby solicits and requests submission of public comment from any interested person concerning the aforesaid proposed project and activities to comply with the applicable standards and regulations of the Commission for a period of thirty (30) days from the date of this publication. Any such comment must be submitted in writing to the following addressee: Stephanie Chaousy, P.G. Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, .APCD-SS-131 Denver, Colorado 80246-1 53 0 Within thirty (30) days following the said thirty (30) -day period for public comment. the Division shall consider comments and. pursuant to Section 25-7-114.5(7)(a), either grant, deny, or grant with conditions, the emission permits. Said public comment is solicited to enable consideration of approval of and objections to the proposed construction of the subject project and activity by affected persons. A copy of the applications for the emission permits, the preliminary analysis of said applications, and accompanying data concerning the proposed project and activity are available for inspection at the office of the Clerk and Recorder of Weld County during regular business hours and at the office of the Air Pollution Control Division, Colorado Department of Public Health and Environment, 4300 Cherry Creek Drive South, Denver, Colorado. A copy of the draft permit and preliminary analysis are available on the Air Pollution Control Division's website at: http://wvvw.colorado.gov/es/Satellite/CDPHE-AP/Ct3ON/1251596498449 Construction Permit Application Preliminary Analysis Summary Section 1 — Applicant Information Company Name: Marathon Oil Company Permit Number: 12WE2116 Source Location: SWSW Section 36, T4N, R63W, Weld County (non -attainment) Equipment Description: Point 003: 4SRB engine Point 005: Plant flares with a minimum combustion efficiency of 95%. Point 006: Fugitive VOC leak emissions AIRS ID. 123-9965 Date: November 29, 2012 Review Engineer: Stephanie Chaousy, PE Control Enaineer: i Chris Laplante 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 -I Is the APEN signed with an original signature? X X Yes Yes No No Was the APEN filled out completely? 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? Please see Section 14 for email conversations. On what date was this application complete? June 26, 2012 Section 4 - Source Description AIRS Point Equipment Description 003 005 One (1) Arrow, Model A62, Serial Number 6B11A002579, natural gas -fired, naturally aspirated, 4SRB reciprocating internal combustion engine, site rated at 80 horsepower at 1800 RPM. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used as a pump jack. Produced gas venting to one (1) active facility flare (F-1) for control of VOC emissions. A second flare (F-2) is present for backup. 006 Fugitive VOC leak emissions. Is this a portable source? Is this location in a non -attainment area for any criteria pollutant? If "yes", for what pollutant? Is this location in an attainment maintenance area for any criteria pollutant? Yes No Yes PM,a Yes No CO X No Ozone Page 1 If "yes', for what pollutant? (Note: These pollutants are subject to minor source PM10 RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8 -hour ozone non - attainment region? (Note: If "yes" the provisions of X Yes Regulation 7, Sections XII and XVII.C may apply) CO No Ozone Section 5 — Emission Estimate Information AIRS Point Emission Factor Source 003 Manufacturer for NOx, VOC, CO and formaldehyde. AP -42 for other HAPS. 005 AP -42 for NOx and CO. Site -specific for VOC. Refer to Section 14 for calculations. 006 EPA -453/R-95-017, Table 2-4 Did the applicant provide actual process data for the emission inventory? X Yes No AIRS Point 003 Basis for Potential to Emit (PTEI Process Consumption/Throughput/Production 4.85 mmscf/yr 005 Produced gas: 73 mmscf/yr; Tank Vapors: 73,000 scf/yr 006 Equipment Type Connectors 28 Flanges 24 Open -Ended Lines 0 Pump Seals Valves Other 0 19 11 Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) 84 40 1 2 21 15 Water/Oil 6 0 0 02 6 Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 003 4.85 mmscf/yr 2012 005 Produced gas: 73 mmscf/yr; Tank Vapors: 73000 scf/yr 2012 006 Equipment Type Gas Connectors Flanges Open -Ended Lines Pump Seals Valves Other 28 24 0 Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) 84 40 1 Water/Oil 6 0 19 11 12 21 15 0 02 6 Basis for Permitted Emissions (Permit Limits) 2012 I AIRS Point Process Consumption/Throughput/Production L 003 4.85 mmscf/yr 005 Produced gas: 73 mmscf/yr; Tank Vapors: 73000 scf/yr Page 2 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors 28 84 5 Flanges 24 40 6 006 Open -Ended Lines 0 --- 1 0 Pump Seals 0 --- 2 0 Valves 19 --- 21 02 Other 11 --- 15 6 Does this faci ity use control devices? i X Yes No AIRS Point Process Control Device Description °/0 Reduction Granted 003 01 NSCR and AFRC NOx: 84%, VOC: 50%; CO: 17%, formaldehyde: 99.9% 005 01 Flares 95 Section 6 — Emission Summary (tons per year) Point NO, VOC CO Single HAP PTE: 001 9.0 0.4 (Hexane) Total HAP 0.7 002 0.8 0.03 (n -hexane) 0.1 003 11.4 0.03 004 2.5 4.5 0.07 (formaldehyde) 0.1 (n -hexane) 0.1 0.2 005 3.5 960 19.0 12.1 (n -hexane) 16.4 006 3.5 --- 0.2 (n -hexane) 0.7 Uncontrolled point source emission rate 001 9.0 0.4 (Hexane) 0.7 002 0.8 0.03 (n -hexane) 0.1 003 004 11.4 0.03 4.5 2.5 0.07 (formaldehyde) 0.1 (n -hexane) 0.1 0.2 005 960 19.0 12.1 (n -hexane) 16.4 006 3.5 Controlled point source emission rate: 001 0.5 002 3.7 0.2 (n -hexane) 0.7 0.02 (n -hexane) 0.03 003 1.9 004 2.5 0.1 In -hexane) 0.2 005 3.5 48.0 19.0 0.6 (n -hexane) 0.8 006 3.5 0.2 (n -hexane) 0.7 Total APEN Reported emissions: 5.4 54.5 22.7 0.9 (n -hexane) 1.7 Section 7 - Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (Ib/yr( Are the emissions reportab Controlled Emission Rate (Iblyr) Point 003 Formaldehyde J 50000 A 139 Yes 0.1 Methanol 67561 I C 18 , No 18 Page 3 Acetaldehyde 75070 A 16 No 16 Acrolein 107028 A 15 No 15 Benzene 71432 A 9 No 9 1,3 -Butadiene 106990 A 4 No 4 Toluene 108883 C 3 No 3 Point 005 Benzene 71432 A 4718 Yes 236 Toluene 108883 A 2816 Yes 141 Ethylbenzene 100414 C 369 No 18 Xylenes 1330207 C 693 No 35 n -hexane 110543 i C 24120 Yes 1206 Point 006 Benzene 71432 A 53 Yes 53 Toluene 108883 C 180 No 180 Ethylbenzene 100414 C 137 No 137 Xylenes 1330207 C 164 No 164 n -Hexane 110543 C i 201 No 201 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 1 Yes No If "yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 003 01 NOx/CO Regulation No. 3, Part B., Section III.G.3 Stack Test 006 01 VOC/HAP State only requirements Component hard count 006 01 VOC/HAP State only requirements Extended gas and liquids analysis Section 9 — Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True Minor X Synthetic Minor Major Classification relates to what programs? X Title V PSD i X NA NSR • X MACT Is this a modification to an existing permit? Yes X No If "yes" what kind of modification? Minor Synthetic Minor Major Section 10 — Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No Page 4 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.ii (subject to MACT)? Yes X No r For Reg. 3. Part B, 111.0,1.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 j X No AIRS Point Section 12 — Regulatory Review 003, 005, 006 Regulation 1 - Particulate Smoke Carbon Monoxide and Sulfur Dioxide 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. 003, 005, 006 Regulation 2 — Odor Section LA - 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. 003, 005, 006 Regulation 3 - APENs Construction Permits Operating Permits, PSD 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. A licant is required to file an APEN since emissions exceed 1 ton per year VOC) 003, 005, 006 Part B — Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this facilit aregreater than the 2.0 TPY threshold Re . 3, Part B, Section ILD.2.a) 006 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. 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 fugitives have been in service after the date above, this source is considered "new or modified." Operator has agreed on the Division's standard conditions. I emailed the operator on 12/3/12 the standard condition the Division has for RACE compliance at E&P tanks. He wrote me back same day saying that the condition is fine and that Marathon can comply with it. 003 Regulation 6 - New Source Performance Standards NSPS JJJJ: Based on manufacturer date. RICE > 25 HP and RB on or after 7/1/08. Operator provided a date of 6/21/11. Therefore, this source is subject to NSPS JJJJ. Page 5 006 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? Source is at an E&P site, therefore, does not meet the criteria of KKK. 006 NSPS OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution. For fugitive emissions at natural gas processing plants subject to NSPS OOOO. This subpart establishes emission standards and compliance schedules for the control of volatile organic compounds (VOC) and sulfur dioxide (SO2 ) emissions from affected facilities that commence construction, modification or reconstruction after August 23, 2011. Is this source at a "natural gas processing plant?" No Is this source subject to NSPS OOOO? No WHY? Source is at an E&P site, therefore, does not meet the criteria of KKK. Regulation 7 — Volatile Organic Compounds 003 None 006 Section XII.G: If facility is a natural gas processing plant located in non -attainment area, then subject to Section XII.G. Facility is not a natural gas processing plant, therefore, not subject to Section XII.G. Regulation 8 — Hazardous Air Pollutants 003 MACT 7777: Based on commencement date. Engines at area sources of HAPS new/c/r on or after 6/12/06. Operator provided a date of 3/27/12. Therefore, this engine is subject to MACT ZZZZ. 006 MACT HH: If facility is MAJOR source for HAP (summation of HAPS of dehydrators and fugitives), then fugitive emissions are subject to MACT HH. Is this facility considered MAJOR for HAPS? No Is this source subject to MACT HH? No WHY? Facility is area source for HAPS, therefore, only TEG dehydrators are subject to MACT HH. No dehydrators are at the facility at this time. Section 13 — Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Factor Pollutant / CAS # Fugitive (Y/N) Emission Factor Source Control (%) 003 01 4SRB Reciprocating Internal Combustion Engine 0.04 g/hp- hr VOC No i Manufacturer 50 14.7 g/hp- hr NOx No Manufacturer 84 5.8 g/hp-hr COI, No Manufacturer 17 0.09 g/hp- hr Formaldehyde j /50000 No Manufacturer 99.9 0.0031 Ib/mmbtu Methanol /67561 No AP -42 0 0.0028 Ib/mmbtu Acetaldehyde / 75070 No AP -42 0 0.0026 Ib/mmbtu Acrolein /107028 No AP -42 0 0.0016 lb/mmbtu Benzene /71432 No AP -42 0 0.0007 lb/mmbtu 3- Butadiene No /106990 AP -42 0 0.0006 Toluene Ib/mmbtu /108883 Na AP -42 0 SCC 40400312 — Fixed Roof Tank, Crude oil, working+breathing+flashing losses 005 01 Flare 26275.1 Ib MMscf VOC I No I Engineering Calculation 95 0.3 lb/MMBtu NOx No Manufacturer NA, Page 6 0.5 Ib/MMBtu CO No Manufacturer NA 64.6 lb/MMsc 38.5 Toluene / lb/MMscf 108883 5.1 Ethylbenzene lb/MMscf / 100414 9.5 Xylenes / lb/MMscf 1330207 330.1 n -hexane lb/MMscf Benzene No Engineering Calculation 95 No Engineering Calculation 95 No Engineering Calculation 95 No Engineering Calculation 95 No Engineering Calculation 95 SCC 31000205 -Flares 006 01 Fugitive VOC Leak Emissions VOC Yes EPA -453/R-95-017, Table 2-4 NA SCC 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Section 14 — Miscellaneous Application Notes AIRS Point 003 Reciprocating internal combustion engine A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit threshold). Page 7 AIRS Point 005 Flares A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit threshold). I emailed the operator on 12/3/12 regarding the emission factors/limits for NOX and CO. The APEN says manufacturer for E.F. location, so I emailed him for a manufacturer specification. He wrote back same day saying that it should be AP -42. I revised the calculations and emailed them to the operator. He agreed with the new calculations and I redlined the APEN accordingly. Emission factors by engineering calculation: VOC = (960 TPY * 2000) / 7307300 scf/yr = 0.02628 lb/scf = 26275.1 lb/MMscf Benzene = (4718 Ib/yr) / 73073000 scf/yr = 6.45e-5 lb/scf (matches APEN) = 64.6 lb/MMscf Toluene = (2816 Ib/yr) / 7307300 scf/yr = 3.85e-5 lb/scf = 38.5 lb/MMscf Ethylbenzene = (369 Ib/yr) / 7307300 scf/yr = 5.05e-6 lb/scf = 5.1 lb/MMscf Xylenes = (693 lb/yr) / 7307300 scf/yr = 9.48e-6 lb/scf = 9.5 lb/MMscf n -hexane = (24120 Ib/yr) / 7307300 scf/yr = 3.30e-4 lb/scf (matches APEN) = 330.1 lb/MMscf Operator did not include VOC emission factor on the APEN. I emailed the operator on 12/3/12 to confirm the E.F. that I calculated so that I could redline the APEN. He emailed me on 12/5/12 confirming the E.F. I redlined the APEN accordingly. Also, the APEN addendum did not include Toluene (greater than 1000 Ib/yr). I emailed the operator on 12/3/12 to confirm this so that I could redline the APEN. He confirmed this on 12/5/12. Application did not have an O&M plan for the flares. I emailed the operator on 12/6'12 requesting one. He wrote back on 12/7/12: On the other site we did it was determined that since the flare for the storage tanks is the same flare as the produced gas that the O&M plan was sufficient since this comment is included on the last page of the O&M plan. "This O&M plan also covers produced gas, which is routed to flare. Records of produced gas will be monitored by meter. The entire system is monitored via SCADA, which will alert the operator to any potential issues. Weekly inspections of the flare, per Section 5 above, will ensure compliance with control requirements." Will this work? We have also worked with Michael Cleary on a few of these and determined it should work but let me know if you feel we need a separate plan. Since this has been accepted for other Marathon Oil Company applications, I will accept the crude oil O&M .Ian as the flare O&M .Ian as well. I added the flare information into CACTIS. A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit threshold). Source is located in non -attainment. I emailed the operator on 12/3/12 regarding RACT. He wrote back the same day saying that Marathon will be able to comply with the Division's standard RACT condition at an E&P site. Page 8 (ADEN) & Application for Construction Permit — Reci % Emission Source AIRS ID: tee w this equipment is refercooed within y Section 02 —Requested Action (check applicable request boxes) Section III — Administrative Information fur NEW permit or newly reported emission source PORTABLE source permit CA s /\ }_\ ete eeC tress.: 45571)en rose Court Fort Collins, CO "' I" Scott Park ntact o of AOS permanent replacement Fax Number Section 03 -- General Information Internal Combustion En L O C L 3 Y C.J - CCJ � H H ti Ca '5 u o O CWI N E b Permit Number: C 0 0 r v 993) 9S. C C. C 0 C L 4 f 0n 0 Ca r ca-; > x 7 NN 40.262506 -104.392059 cc cc U O L O < L' W C F In N C' rll QI v G car :7 G C O U n U C. N M C TA .12 3 v CC C_ v C ❑S O U V tJ 1 0 m 0 C C C � 0 O motion Informati Section 06 — Fuel Con CC C To V N N L V C C U 0 L 0 C- C 0 IS C0 CC N J a /73 R L Ic O O U ", ° '' ^ I n U N 2' ^l , ll ;' 7IQ I ^1 .^ U ^1 y .- ' - 1-5N = C L e i O N ' fJ = U z ^1 ( I ¢ 999 N J 0 G AP -42 Table 3.2-3 Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. TJ U ll N. C >. 0 U F'I x r N o r C 'O y 4i o f 0 C OO OI "' 0 fn o c- ^ o °° 4t= r c c o 0 c 0 0 o Actual Calendar Year Emissions! Uncontrolled Controlled (Tons/Year) (Tons/Year) '4 N c C r o en n 0 O n o 0 n o l o © ,y n o O 2 rr a N o o x = 0 x 0 0 In o0 0 Emission Factor Uncontrolled Basis Units r4 x Ib/M MB to Ib/M MB to o Cl 00 = L :0 r t 00 m Acroleiu 2.63E-3 lb/MMBtu Benzene _ 1.58E-3 lb/MMBtu n _1 a a rl L -J U 02 n 9 0 a; 14.7 Z ^ j a n -U.. r rr Control Efficiency (°U Reduction) o o/ x e C r 2 r 1 a a Control Device Description Primary Secondary T W R J C v " T y 5 U >. C 44 ;. /i I , 0' .. z > I L c0 0 Q sr c c c C O u v J _9 true and correct. m , N 1 dtr t O 73 C z C z C C- V M Emission Source MRS ID: [Leave Flank Section 02 —Requested Action (check applicable requtst ho Section 01 — Administrative Information Request for NEW permit or newly reported emission source Request PORTABLE source permit v at - a C C J 9 n T v L C O C C w 0 , .. c C ❑ Z y o L c o C q v U C o° U V w ❑ ❑ ® ❑ ❑ Source Name: 9 0 •T F U U rcc Location: C 2-- ); 220 22 G 0 C 0 .0 e 3 C c o y .. L 0 o v` re '^ --,'.4 y i u y u n T 341 V Q C 1.4 c c } c v c Z `o 0 4 f o o c c or Y ❑ ❑ ❑ ❑ Thrc O N 0 [L, Section 03 — General Information N N 0 C C 0 0 r c v C N N 'J' Ln c a Y U N v. A. �I 5). 00 C Ph e4 c 0 a N C. O L > C �+ c 2 a.. y > 0 c _+ E Nca ra C J I a C- J er cq C al - al 0 ,° iC _ n 9 ? L T It c0 .J L Q C o - C O G U, — J L �r at Cl < Q Q 0 ment Information & Material Use roeessin C- z at 0 Design Process Rate (Specify Units/[ lour) c o c C C_" a Actual Level Annual Requested Permitted Level2 (For Data Year) (Specify Units) 73 MMscf per year o L r C a n c Produced Gas cc c c C T > G 0. oQC U U 'U wet' the next five yea materials and II O 0 c v n G Permit Number: L I 0 C 0 see; provide datum & eit 0 C J U C r ll 3 C. Section 05 — Emission Release Information C 2 2- O 0 Z. N N :n c J L � 2 Field Measured -104.392059 ti cc ci V a) U v 3 V Q In F 4. J C _ �,1 bstmcting raincap Vertical wit J J n of outlet (check one): a) Circular: Inner Diameter (i uuiem.tojul wind Section 06 — Combustion Eguipment & Fuel C V) L E. T.) N N ry ry C C C C C a) Ca c` CO Y L- 9.33 MMBtu/hr L C C O C` G ins. Requested level should con Section 07-- Emissions Inventory Information & Emission Control Information } C uz • v C z C Ic C 2 L_ IC N z Id c Ca 4- C. CL .122 0 C Ti - v 74 m C T'. Q C C w u C Ei 0 v LI C Si y .E E G. a) ZI C O O U CO N C, N' a L E lh/MMBtu z c d -j 0 a v ll J C C U a) 9 2 Please use the APCD Non-Crite E.; c t42 a V C v 0 C 'J o — 3 wF Gv F n _ 5. c15. — C ca. Q F 15 T.) CC a) 0 W O W O CO) O L',7) w • c H a z o • U O D N J E J -t°o O c Nd o li. N Q N J Q CY 0 a W W `H 0 Z AIRS ID Number: Permit Number: N -c C U a N C C C U c co as co al o I Z U',v a m c') C co Company Name: Plant Location: Person to Contact: Fax Number: marathonoil.com E-mail Address: Controlled Actual Emissions (lbs/year) CO C5) CO Uncontrolled Actual Emissions (lbs/year) 3,774 CO m N m nr n I_-7 , Emission Factor Source Site Specific Site Specific 6.1c I Emission Factor (Include Units) 6.5E-5 lb/scf 3.3E-4 lb/scf Control Equipment / Reduction (%) o tn O) a L C) $ ''n 3 Reporting BIN a U J Chemical Name cp C N N C m w CD C X O--:) ,„— C 1) i Chemical Abstract Service (CAS) Number N c'i co V LO O r W o I Calendar Year for which Actual Data Applies: O N O m C a) U O U) 0 U L RI C N 9) O CC CO CC Ct ❑ a U) 0 -c Q) N O iQ CD m Ct C Ca U) C O Ca a) ca a ❑ O <a ❑ m ≥ m a ❑ a >, (� a O a -o N O O N N Lc o` Q C CN T _ O CO Q C7) T E J O- C O) GPI O O CI C C)' O Title of Person Leg GUIDANCE FOR NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM C J. c7 N >` N -O 0 N .0 C U y. N ti a p a) O p O) N E - p > a co c w = 0 i w N 9 O ? a) O N O o E U N >� G O6 coc6 N V C .�-. LL o p c _ w c -c a) c .� a) G o cc E ._ c L O = = E m c E c N `m a ( m o N N J a) w' N a O ..n C N m ≥ N LL T N O E C O LL >, p t,b 'g `m oc - a E. w N C U C C L N N N Q U) C m O U o C E E N �[ O a T C_ `p T 'C c O -o p a) c a oo N Q L Q -O 7 0 0 -O L O N C C E Y to ^ — > U C (o M C_ > C 6 CO I N O O a N C L f0 wc m a o f E T.a) a a s a� — `? c E as I E O C N00 C E O a co a N N LL Co C C . E m -O X C_ O O O ct m N N .7 N fa a) a) C a c a) _ 2 .X C l_ 6 E C .C a C m C O) O E ca o E >. a) O N Z co m _ c o U tUil a N U '- C -C -= N C CO - C U O y } m sC Ec E Da)3 4 ( v ° E c n w a) s a) c Z c .E `a) 0 co (c) 5) c '5 0 .. 5 N O 4o m c' 0 E N ! 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E m W a > > U N 0 U < C a C a .C m O a P a C - c c .2 O .O ` Q N N U .2 c E U OE Emission Source AIRS II): CA Ca S > C [Leave blank unless APC Section 01— Administrative Information R C Pru y C i L E al ' z C Y 5 V ❑ ❑ G CO V G T h y % V V G o _ p Z .` O V •741 t J V 3 ll 7 a • C m Co Y15 0:1 ccC c'ecd v F ❑ ❑ Fes. L14) ® ❑ V C. r -I V 5 m i C V a U C ✓ G 7 Co G V C ❑ ❑ N Ca G 0 ,. V v C C V C u a 970-419-7809 Phone Numbe Fax Number Section 03 — General Information NI \1 N N m v p V CO C 5 0 N T"' T r C Y C E $ 5 G N N U_ ▪ L 5. G ti I T 5 V C L c C — G C 5 - C 9 Y n C V — E 2.„?. G 5 L J Z /y /u✓ \ \ \ m . QPr '5 V `y j' "X --.0 E I /I v F. - G� C y p0 IJ 'y Z a an y _ tO i .5 G Q s )1 = Q C] N W V c cc i V V ^ —E 'C C_ y U_ _ N m T Ca ▪ C 1 Y ,,Sr ~_ Y 7 v L- C) j 5 C ≥ " p v, ° 0 7 "' = -° 3 — = v - 3 E v 7 55 C :' > L= 5 F & _ ll m `E C.0 .-' O.ra: L O U C Y y C ,n J G y 9 f� Fs u :E V N r L ^ - C -3 ?) — L. J C Cll L r, ,X J A C ._ O h 75 AP EN forms a Ca ction 04 — Re this equipment d Section 05— Stream Constituents U -) V a 3 7 rI C 7_ a Ni 0 C C C• — o 4 I z c C 7 a .75 5 C 1 or 0 a N V L eV 3 55 Ca - G G c N 5 ;ET CD 2 2- v L f c^, A onent beak Emissions \ L • +. v 0 z .J C L • O con z a cJ 0, 4r_1 z C f r .J C Permit Number: Section 07 —Leak Detection & Repair (WAR) & Control Information Dillon (Provide Datum an( Section 06 — Location Infor 0 0 N V v m -104.392059 .i n J Section 08—A mission Factor Information r xI All } C 9-i U L L `I Cr ry u o [L Ia7v012 0 VI a tj h a' < 2 r i at _ o Gi v y C J 3 N 0- N O N r vC. y U J N Equipment Type c v .z• - •t) - m used to calculate the Actual Ca Section 09—f missions Inventory Information & Emission Control Information for Documentation attached U y Z" 0 o G 2 0 '' o c c O F 22 77 y o L_ o F. O T o 0 c Qi 0 Identify in Section 08 0 7-7 0 v U 0 C C C_ Identify in Section 07 C C X N ti 0 is will be base S a tamed herein a N G C STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 1 2WE21 1 6 Issuance 1 DATE ISSUED: ISSUED TO: Marathon Oil Company THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the French Lake 4-63-36-1 H, located in SWSW Section 36, Township 4N, Range 63W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description E-01 003 One (1) Arrow, Model A62, Serial Number 6B11A002579. natural gas -fired, naturally aspirated, 4SRB reciprocating internal combustion engine, site rated at 80 horsepower at 1800 RPM. This engine shall be equipped with a non- selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used as a pump jack. Produced Gas, F-1 and F-2 005 Produced gas venting to one (1) active facility flare (F-1) for control of VOC emissions. A second flare (F-2) is present for backup. Fugitive 006 Equipment leaks (fugitive VOCs) from an exploration and production facility. Point 003 may be replaced with another engine in accordance with the temporary engine replacement provision or with another Arrow A62 engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. 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 AIRS ID: 123/9965 Page 1 of 17 NGEngine Version 2012-1 ri Co11i 'do D=1pertmei it of Public Health and Environment =A Air Pollution Control Division rait'rn 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; (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.) 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.) Points 003 and 005: The following information shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. 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 7 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) AIRS ID: 123/9965 Page 2 of 17 Annual Limits: Q CoVi7?),do Dimp?rtmey, or Public Health and Environment Air Pollution Control Division Y!%SY R tlii vv Ya tr Facility Equipment ID AIRS Point Tons per Year Emission Type r NO, VOC CO E-01 003 1.9 --- 3.7 Point Produced Gas, F-1 and F-2 005 3.5 48.0 19.0 Point Fugitive 006 -- 3.5 --- 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. 8. 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 E-01 003 Produced Gas, F-1 and 005 F-2 A non -selective catalytic reduction (NSCR) ' NOx, VOC and system and air/fuel ratio controller CO Flares VOC PROCESS LIMITATIONS AND RECORDS 9. 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 Facility Equipment ID iAIRS Point Process Parameter Annual Limit E-01 003 Consumption of natural gas as a fuel 4.9 MMscf/yr AIRS ID: 123/9965 Page 3 of 17 cY "a e iE tl Colrn 4do D partmei:1 or Public Health and Environment % A `('+ x, $' li'l Air Pollution Control Division f a Produced Gas, F-1 005 I and F-2 Venting of produced gas Venting of tank vapors T 73 MMSCF/yr 73,000 scf/yr 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 10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. 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.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. Point 006: 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. 14 Point 006: Minor sources in designated nonattainment or atta.nment/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. ii. For each leak found in the AVO inspection, a gas detector shall be used to determine the size of the leak. The gas detector shall be regularly calibrated. Component leaks greater than 10,000 ppm shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the AIRS ID: 123/9965 Page 4 of 17 .A taZNf ..2,A ... Cokilldo D partmeiLtjfl or Public Health and Environment Air Pollution Control Division 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 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. Point 003: A source initial compliance test shall be conducted on emissions point 003 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. 17. Point 006: Within one hundred and eighty days (180) after commencement of operation, the owner or operator shall complete the initial extended gas analysis of gas AIRS ID: 123/9965 Page 5 of 17 tj Colr)i bio D partmei=) of Public Health and Environment , Air Pollution Control Division samples and extended natural gas liquids analysis of liquids that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas and liquids analyses shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the gas and liquids analyses and emission calculations to the Division as part of the self -certification process to ensure compliance with emissions limits. 18. Point 006: Within one hundred and eighty days (180) after commencement of operation, 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 19. Point 003: This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. 20. Point 006: On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples and an extended natural gas liquids analysis of liquids that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas and liquids analyses shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30`h whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on The last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or 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. AIRS ID: 123/9965 Page 6 of 17 do D,pgrtrhetlt of Public Health and Environment i � a Air Pollution Control 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. f. Point 003: Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative -operating scenario and is installing a permanent replacement engine. 22. 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: 23. 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. 24. 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. 25. 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. 26. 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. AIRS ID: 123/9965 Page 7 of 17 t of ij)do D parrmer:1 or Public Health and Environment 1.4 _' Air Pollution Control Division tfi 27. 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. 28. 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. 29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date i Description Issuance 1 This Issuance ' Issued to Marathon Oil Company. Newly permitted synthetic minor facility. AIRS ID: 123/9965 Page 8 of 17 AIarstr^al if) Col ii,;do D partmeor Public Health and Environment k Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The production or raw material processing limits and emission I mits 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/regulations/airregs/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 Point Pollutant CAS # BIN Uncontrolled, Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 003 Formaldehyde 50000 A 139 I Yes 0.1 Methanol 67561 C 18 No 18 Acetaldehyde 75070 A 16 No 16 Acrolein 107028 A 15 No 15 Benzene 71432 A 9 No 9 1,3 -Butadiene 106990 A 4 No 4 Toluene ' 108883 I C 3 No 3 005 Benzene 71432 l A 4718 Yes 236 Toluene 108883 A 2816 Yes 141 Ethylbenzene 100414 C 369 No 18 Xylenes 1330207 C 693 No 35 n -hexane 110543 C 24120 Yes 1206 006 Benzene 71432 A 53 Yes 53 Toluene 108883 C 180 No 180 I Ethylbenzene 100414 C 37 No 37 Xylenes 1330207 i C 164 No 164 n -Hexane 110543 C 201 No 201 AIRS ID: 123/9965 Page 9 of 17 Colsii.do a.floartmer,i, or Public Health and Environment Air Pollution Control Division 4) The emission levels contained in this permit are based on the following emission factors: Point 003: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Controlled lb/MMBtu Factors — g/bhp-hr NOx 3.9046 14.7 0.6375 2.4 CO 1.5406 5.8 1.2750 4.8 VOC 0.0106 0.04 0.0053 0.02 50000 Formaldehyde 0.0239 0.09 0 0 67561 Methanol 0.0031 0.0115 0.0031 0.0115 75070 Acetaldehyde 0.0028 0.0105 0.0028 0.0105 107028 Acrolein 0.0026 0 0099 0.0026 0.0099 71432 Benzene 0.0016 0 0059 0.0016 0.0059 106990 1,3 -Butadiene 0.0007 0.0025 0.0007 0.0025 108883 Toluene 0.0006 0.0021 0.0006 0.0021 Emission factors are based on a Brake-Specfic Fuel Consumption Factor of 8300 Btu/hp-hr, a site -rated horsepower value of 80, and a fuel heat value of 1200 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer Manufacturer 50000 Formaldehyde Manufacturer Manufacturer Point 005: CAS # Pollutant Weight Fraction of Gas (%) Emission Factors Uncontrolled Emission Factors Controlled Source NOx 0.068 Ib/MMBtu AP -42 CO 0.37 lb/MMBtu AP -42 VOC 39.06 26275.1 lb/MMscf 1313.76 Engineering Ib/mmscf Calculation 71432 Benzene 0.10 64.6 lb/MMscf 3.23 lb/mmscf Engineering Calculation 108883 Toluene 0.06 38.5 lb/MMscf 1.93 lb/mmscf Engineering Calculation 100414 Ethylbenzene 0.01 5.1 lb/MMscf 0.26 lb/mmscf Engineering Calculation 1330207 Xylenes 0.01 9.5 lb/MMscf 0.48 lb/mmscf Engineering Calculation 110543 n -hexane 0.49 330.1 Ib/MMscf 6 51 Ib/mmscf Engineering Calculation Note: The uncontrolled VOC and HAP emissions for this point were calculated using the April 11, 2012 analysis of a gas sample collected from the French Lake 2 well. The controlled VOC and HAP emissions factors for point 003 are based on the flare control efficiency of 95%. AIRS ID: 123/9965 Page 10 of 17 Point 006: Cola l \do a,u of Public Health and Environment Air Pollution Control Division Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors Flanges O.en-ended Lines Pump Seals Valves Other* VOC Content (wt. fraction) Benzene Content (wt. fraction) Toluene Content (wt. fraction) Ethylbenzene (wt. 28 24 0 0 19 11 0 0 0 0 0 0 84 40 1 2 21 15 5 6 0 0 2 6 0.3906 1 0.9985 0.6737 0.001 0.00056 0.0001 0 0 0.0092 0.0397 0.007 0.0081 0 0.0086 0.0006 Xylenes Content (wt. fraction) 0.0001 0 0.0387 0 0022 n -hexane Content (wt. fraction) 0.0049 0 0.0328 0.0286 *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 and liquids analyses. 5) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 6) Point 003: This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado AIRS ID: 123/9965 Page 11 of 17 '77-71 7.77,11! olVi ,do D partmeiy of Public Health and Environment 4.,.,,,,; „ aj Air Pollution Control Division Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ja08.pdf 7) Point 003: This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.gov/ttn/atw/area/arearules.html 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -hexane Synthetic Minor Source of: VOC NANSR MACT ZZZZ Area Source Requirements: Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr. g poaccess. g ov/ Part 60: Standards of Performance for New Stationary Sources NSPS i 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 10) 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.cclphe.state.co.us/ap/oileaspermittinci.html AIRS ID: 123/9965 Page 12 of 17 Col n )do Dlipgrtmei of Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123/9965 Page 13 of 17 4,4 Cok,t 'do D,prtmei ,1 or Public Health and Environment :44 Air Pollution Control Division 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer. model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that 'based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: h ttp: //www. co l orado. g ovlcs/Satellite/C D P H E-AP/C BO N/ 1251596520270. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating lours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. AIRS ID: 123/9965 Page 14 of 17 Col fi'.'do DkAparmei 1t or Public Health and Environment Air Pollution Control Division For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI, and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater :han 500 hp shall use an oxidation catalyst to reduce emissions. AIRS ID: 123/9965 Page 15 of 17 1 lS'^ Col%,i ado D jparimei -,t of Public Health and Environment Air Pollution Control Division Rr i Rr.,p,r3ra The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII. E — State -only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine HP Construction or Emission Standards in G/hp-hr Relocation Date NOx January 1, 2008 January 1, 2011 July 1, 2007 July 1, 2010 CO VOC 100<Hp<500 2.0 4.0 0 1.0 2.0 0.7 500<Hp 2.0 14.0 1.0 12.0 ".0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However as of October 1. 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § LB (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting AIRS ID: 123/9965 Page 16 of 17 oldo DYpartmei Z of vi aPublic Health and Environment ro Air Pollution Control Division gi requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has tc go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123/9965 Page 17 of 17 Hello