HomeMy WebLinkAbout20203829.tiffCOLORADO
Department of Public
Health Ft Environment
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
December 14, 2020
Dear Sir or Madam:
RECEIVED
DEC 21 2020
WELD COUNTY
COMMISSIONERS
On December 15, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
Enerplus Resources (USA) Corporation - Orca Facility. 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 beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health a Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www-colorado.gov/cdphe
Jared Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director
Pub Re✓:ew
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GG IpLCTP), H L(DShRi, PGJ(3'f t /ER/cH/c14
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2020-3829
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Enerplus Resources (USA) Corporation - Orca Facility - Weld County
Notice Period Begins: December 15, 2020
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Enerplus Resources (USA) Corporation
Facility: Orca Facility
The facility is an upstream El*P site; the permit includes natural gas flaring during
pipeline downtime.
The facility address is NESW SEC 26 T8N R67W, Weld County, CO.
Weld County
The proposed project or activity is as follows: This permit action includes a reduction in throughput to the
permitted flare. The emission factors and limits were updated as a result of site -specific sampling.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0544 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Nicholas Dummer
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
Health & Enviromxnent
;COLORADO
{ Air Pollution Control Division
1 Department ct t5'ut)::c Health E; EnvIro .. :'fly
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0544 Issuance: 2
Draft
Enerplus Resources (USA) Corporation
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Orca Facility
123/AOOF
NESW SEC 26 T8N R67W
Weld County
Natural Gas Compressor Station
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
FLARE
002
Natural gas flaring during pipeline
downtime
Open Flare
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
this specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. This construction permit represents final permit approval and authority to operate this
emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B,
Section III.G.5.)
EMISSION LIMITATIONS AND RECORDS
2. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section I I.A.4. )
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
FLARE
002
---
0.5
4.4
2.1
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Public Health ;r Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Compliance with the annual limits must 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 must calculate actual emissions each month and
keep a compliance record on site or at a local field office with site responsibility for Division
review.
3. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
4. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
FLARE
002
Emissions are routed to an Open Flare
during pipeline downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
5. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
II.A.4.)
Process Limits
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
FLARE
002
Natural Gas Venting
10.3 MMSCF
Compliance with the annual throughput limits must 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 must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
6. The owner or operator must continuously monitor and record the volumetric flow rate of
natural gas vented to the flare using the flow meter. The owner or operator must use monthly
throughput records to demonstrate compliance with the process limits contained in this
permit and to calculate emissions as described in this permit.
Page 2 of 9
jCOLORADO
Air Pollution Control Division
nrent :?r w'v';v FNt=a[th E,'EnviTonment
Dedicated to protecting and improving the health and environment of the people of Colorado
7. The owner or operator must continuously monitor and record pipeline downtime while
emissions are routed to the control device.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. The permit number and ten -digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III. E. ) (State only enforceable)
9. No owner or operator of a smokeless flare or other flare for the combustion of waste gases
must allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division -approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING Et MAINTENANCE REQUIREMENTS
12. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (OM) 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 the O&M plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
13. The initial testing requirements as part of the initial approval of this permit have been
satisfied with the issuance of the final approval to operate on July 23, 2020.
Periodic Testing Requirements
14. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
Page 3 of 9
COLORADO
I Air Pollution Control Division
i Department of Public Nee€;n 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
15. All previous versions of this permit are cancelled upon issuance of this permit.
16. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on
the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
17. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D, Section VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Page 4 of 9
;COLORADO
Air Pollution Control Division
Departmentet PttPe 'Health b Environnlent
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility
Equipment
ID
AIRS
Point
Equipment
Description
Pollutant
Emissions - tons per year
Threshold
Current
Permit
Limit
FLARE
002
Flare for
separator
emissions
during pipeline
downtime
VOC
NOx
50
50
26.2
15.4
---
001
TEG
Dehydrator
-
003
1680 hp SI
Engine
-
004
362 hp 4SRB
Engine
---
005
Mixed liquids
tanks (2) 400
bbl
Insignificant
Sources
Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources
(excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
18. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
19. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization section
of this permit.
20. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the 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
Page 5 of 9
ICOLORADO
Air Pollution Control Division
Departir nt of Pu b ;c Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
21. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
22. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must 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 of a source may request a hearing before the AQCC for review of the
Division's action.
23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee .
billing will terminate.
24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Nicholas Dummer, P.E.
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
January 9, 2020
Issued to Enerplus Resources (USA) Corporation
Issuance 2
This issuance
Reduction in throughput to the flare. Updated
emission factors and limits as a result of the
site -specific sample.
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of Puhhc Hs&..`- Es Environment
Dedicated to protecting and improving the health and environment of the people of Colorado -
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the 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 must 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: https://www.colorado.gov/pacific/cdphe/agcc-regs
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 sources operates at the permitted
limitations.
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
FLARE
002
Benzene
71432
61
3
n -Hexane
110543
604
30
2,2,4-
Trimethylpentane
540841
32
2
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportab a and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMscf)
Controlled
Emission
Factors
(lb/MMscf)
Source
N0x
0.068
(lb/MMbtu)
AP -42
CO
0.310
(lb/MMbtu)
AP -42
Page 7 of 9
'COLORADO
j Air Pollution Control Division
.t of Public Heath b Environment.
Dedicated to protecting and impro v
CAS #
Pollutant
_ _____--_
Uncontrolled
Emission
Factors
(lb/MMscf)
____, _.................. ..,.....
Controlled
Emission
Factors
(lb/MMscf)
t..... j..... .,a vv.v.uu�
Source
VOC
17,459.1
873.0
Source
(Mass Balance)
71432
Benzene
6.0
0.3
Source
(Mass Balance)
110543
n -Hexane
59.7
3.0
Source
(Mass Balance)
540841
.t .
2'2'4
Trimethylpentane
3.16
0.16
Source
(Mass Balance)
The controlled emissions factors for this port are oasetl on a control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must 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, NOx, CO
PSD
Synthetic Minor Source of: NOx
NANSR
Synthetic Minor Source of: VOC, NOx
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.g,ov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
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
Page 8 of 9
COLORADO
Air Pollution Control Division
Department .t Pubhc Health @ EmairOmment
Dedicated to protecting and improving the health and environment of the people of Colora
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
Page 9 of 9
Separator Venting Emissions Inventory -
Section o1- Administrative Information
Facility AIRS ID:
County
A6Gr
Plant
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
MMscf per year
Requested Permit Limit Throughput=101' MMscf per year
Requested Monthly Throughput= 09 MMscf per month
Potential to Emit (PTE) Throughput =
_. MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL o
liquids throughput:
scfh
Btu/scf
Control Device
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
0.15 MMscf/yr
Section 04- Emissions Factors & Methodologies
Weight
Helium
CO2
N2
methane
ethane
propane.
isobutane
n -butane
isopentane
n -pentane
cyclopentane
n -Hexane
cyclohexane
Other hexane,s
heptanes
methylcyclohexane
224-TMP
Benzene
Toluene
Ethylbenzene
Xylenes
CB+ Heavies
Total
VOC Wt
Ib/Ib-mol
Displacement Equation
Ex=O,*MW*Xx/C
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Separator Venting Emissions inventory
Emission Factors
Separator Venting
Emission Factor Source
Pollutant
Uncontrolled Controlled
(Ib/MMscf) (Ib/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
17443.1240
872.0562
atht5detg :_}`"
'bra' ., d Ii•Y;r',p.E$a(YSIs..?a
Benzene
6.0079
Toluene
0.0000
Ethylbenzene
0.0000
Xylene
0.0000
n -Hexane
59.5544
224 IMP
3.3557
.�`-s
Pollutant
Primary Control Device
.$-:
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) Ib/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
t 0000
.
.
APh2er 13.EI;F(a[e's (a;)
_. 1P d2 - srt 13.5 I`nd s ral Flares jet _.
PM2.5
- .,__...
50x
GG
,_
NOx
tOSBO
SS OG56
CO
,Lt.3100
....2.020
Pollutant
Pilot Light Emissions
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) Ib/MMscf
(Waste Heat
Combusted)
(Pilot Gas Throughput)
PM10
0000
1 ...`u.
f � Fierea t'x)
;d-, AP 42 [taa;�te� S 3.5 tnd3 5₹ iaE Flares (f:Zlg
PM2.5
C CYG0G
SOx
..
Gtr :
NOx
4.0vsp
88.0036
VOC
0.0000
CO
0.3100 -
401.2020
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
ARual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
DA
0.0
0.tl,
0.0
0,0
0.0
0.0
0.0
0.0
0.0
0.0
0.3
0.0
0,0
0.0
0.5
0.0
0.0 _
0.5.
.
Ba.4
1.0
0.0
W14
4.4
751
2.1 •
0.1
0.1
2.1
2.1
350
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
Ohs/year) Ohs/year)
Benzene
Toluene
Ethylbenzene
Xylene •
n -Hexane
224 TMP
01
1
0
0
.
0
0
0
0
0
0
5
0
r
0
0
0
0
604
7
604
30
32
0
0
32
2
Section 06 -Re ug Iatory 5ummae Analysis
Regulation 3, Parts A, B
Regulation 7, Part D, Section II.B, F
Regulation 7, Part D, Section 11.B.2.e
(See regulatory applicability worksheet for detailed analysis)
o. ce requiros a permit
Not enough information
enough inforn
2 of 3 C:\Users\ndum mer\Desktop\123-ADOF\19W E0544.CP2
Separator Venting Emissions inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRS ID, and should have been collected within one year of the application received date. However, if the facility has
not been modified (e.g., no new,wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gassample from the equipment being permitted and conduct an emission factor analysis to demonstrate
that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment
area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area?
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors
are less than or equal to the emissions factors established with this application.
-A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors
are less than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point? yes
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180
days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Y WI3=mind _a caFove,r the s-a.t-ad-�cceas a- -e:er rs n:- aV xias ven
Section 09 - SCC Coding and Emissions Factors (For Inventor/ Use Only)
'AIRS Point #
Process # SCC Code
002 01
Section 08 -Technical Analysis Notes
The permitted limit includes both waste gas and pilot light throughput (10,28 total - 0.15 pilot and 10.13 waste gas MM5cf/yr). Site specific sample used
Pollutant Uncontrolled Emissions Factor Control % Units
PM10 0..0 0 ib/MMSCF
PM2.5 0.13 ibjiRM5,,iiF
SOx _.., 0 - i 3i MSC--ri
NOx : ,.s 0 Ib/MMSCF
VOC 745.9._'. 95 Ib/MMSCF
CO 407.3 Ib/fv7MSCF
Benzene 6.0 35 I'bi vMNiSCF
Toluene 0.0 95 Ib/MIVISCF
Ethylbenzene 0.0 9.5 ib/MMSCF
Xylene 0.0 a: `b/MMSCF
n -Hexane 59.-r ..S. tb/MMSCF
224 TMP 3.2 3S t-i1MMSCF
3 of 3 - C:\Users\ndummer\Desktop\123-AOOF\19WE0544.CP2
1
JUL Z ?020
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 19 V V E0544
[Leave crank unless .APCD t135 already SS r
AIRS ID Number: 123 / AOOF /002
and A!Rs
�I
Section 1 - Administrative Information
Company Name': Enerplus Resources (USA) Corporation
Site Name: Orca Facility
Site Location: NESW Sec. 26, TBN, R67W
Mailing Address:
(include Zip codes 950 17th Street, Suite 2200
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Kristin Van Hees
Phone Number: 720-279-5515
E -Mail Address2: KVanHees@enerplus.com
' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
433612
APCD-21': Gas Venting APEN - Revision 07i2020
COLORADO
ROM ft ..arr.
fleJtTBG.Iraa..�ieM
Permit Number: 19WE0544
(Leave UIank uniess APCD hes aiready
AIRS ID Number: 1 23 / AooF / 002
a --RI AIRS RA
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source
-OR -
0 MODIFICATION to existing permit (check each box below that applies)
0 Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
El Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Fc Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
downtime
Natural gas flaring during pipeline
Company equipment Identification No. (optional):
For existing sources, operation began on:
FLARE
11/23/19
For new, modified, or reconstructed sources, the projected start-up date is:
ID Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XYII.G?
Form ARCD-L F 1 ; as Venting APEN - revision 07/2020
days/week weeks/year
0 Yes
❑ Yes
❑ Yes
❑ No
No
❑✓ No
COLORADO
2I Dep.,,,k..rw.,IbiK
ff.. b 6nsuontne t
Permit Number: 1 9WE0544
AIRS ID Number: 123 /A0OF /002
[LeavebiarlM. urie55 APCD has athaarery _ (1 a e a:' .1
Section 4 - Process Equipment Information
0 Gas/Liquid Separator
❑ Welt Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #:
# of Pistons:
Volume per event:
Capacity:
Leak Rate:
gal/min
Scf/hr/pist
MMscf /event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes
Gas Venting
Process Parameters':
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
0 No
' vent Gas
Heating Value:
1294.2
BTU/SCF
Requested:
10.28
MMSCF/year
Actual:
0.11
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
23.00
VOC (weight %)
28.77
Benzene (weight %)
0.0342
Toluene (weight %)
0.00
Ethylbenzene (weight %)
0.00
Xylene (weight %)
0.00
n -Hexane (weight %)
0.3412
z,z,4-Trimethytpentane (weight %)
0.0173
Additional Required Documentation:
0 Attach a representative gas analysis (including BTEX fi n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
El
5 Requested values wilt become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
nrm APCD-211 Gas VenOng Are N - Revision 07!2020
31Ai��Er'.�.
E] Upward
❑ Horizontal
Permit Number: 19WE0544
AIRS ID Number: 123 / A00F / 002
[Lr ave blank unless APED has alreaoy asst perma = a c' AIPS iD1
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Lotiivde/Longitude or UTM)
40.6312333,-104.8625194
❑ Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator
Stack ID No.
Discharge Height
Above Ground Level
Temp.
(.F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Flare
-r10
1000
Variable
Variable
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
Circular Interior stack diameter (inches): 4
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑ Other (describe):
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section .
❑ VRU:
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed:
❑
Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating: 6.7
Type= Steffes
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature: NA
MMBtu/hr
Make/Model: SVG-3
95 %
98+ %
Waste Gas Heat Content:
Constant Pilot Light: Yes ❑ No Pilot burner Rating:
1294.2
0.027
Btu /scf
MMBtu /hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APED -211 - Gas Venting APEN - Revision 07/2020
® COLORADO
4 [ Ha ., Lnyvr.1ur
t�.au � [n.v.wm..a
Permit Number: 19WE0544
AIRS ID Number: 123 / At)oF / 002
I s 3ve Wank ur P.,; nPCD nas permt an0 IR.; ID1
Section 7 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? E✓ Yes ❑ No
If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Pollutant
Control Equipment Description
Overall Requested
Control Efficiency
(% reduction in emissions)
PM
SOx
NOx
CO
VOC
Fare
95
HAPs
Flare
95%
Other:
Fro, hat year is the follovymg reported actual annual emissions data? 2019
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP 42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
(tons/year)
Uncontrolled
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons year)
PM
SOx
NOx
0.068
IbIMMBtu
AP -42
0.01
0.01
0.45
0.45
CO
0.31
Ib/MMBtu
AP -42
0.04
0.04
2.06
2.06
VOC
17460.7
lb/MMscf
Mass Balance
1.70
0 09
88.40
4.42
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 8 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
❑ Yes No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service (CAS)Uncontrolled
Number
Emission Factor
Actual Annual Emissions
ms's
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(lbs/ysar)
Controlled
Emissionsb
(fbslyear)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
2,2,4-Trimethyipentane
540841
Other:
_
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Form APCD-211 Gas Venting ADEN - Revision 0772020
5 I a
Warb
COLORADO
1
Permit Number: 19WE0544
AIRS ID Number: 123 /AooF / 002
[Leave bank unless APCD has alreadv assigned ,errn,t and AIRS 01
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
'�Il3�zo
Signature g y ( a vendor or consultant) Date
of Legally Authorize Person not
Kristin Van Hees Sr. Environmental Specialist
Name (print) Title
Check the appropriate box to request a copy of the:
C] Draft permit prior to issuance
Q Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $216.00 to: For more information or assistance call:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-61
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Small Business Assistance Program
(303)692-3175
OR
(303)692-3148
APCD Main Phone Number
Make check payable to: (303) 692-3150
Colorado Department of Public Health and Environment
Form APCD-211 - Gas Venting /,PEN - Revision 07/2020
�
tOlOR•00
61
I... aw r�
xwu s n..w.......
1
JUL 1
zpzo
July 13, 2020
VIA FEDEX
Mr. Chris Laplante
Colorado Department of Public Health & Environment
Air Pollution Control Division
4300 Cherry Creek Drive South
Denver, CO 80246
RE: Enerplus Resources (USA) Corporation — Orca Facility
Weld County, CO
Mr. Laplante:
Enerplus Resources (USA) Corporation (Enerplus) is submitting the attached permit application to
modify the flaring volume and associated emissions for a facility flare at a compressor station, the Orca
Facility, located in Weld County, Colorado.
Enerplus is requesting this modification under the new oil and gas application forms along with a
check for the required APEN fees.
Please feel free to contact Ashley Campsie with Evergreen Environmental Engineering at
hle� .Lanip,ie 'tr eeen:4 net or at 303-670-3480 with any questions regarding this permit application.
Thank you in advance for your consideration of this request.
Sincerely,
Enerplus Resources (USA) Corporation
1N\
Kristin Van Hees
Sr. Environmental Specialist
Enclosures
{�1
Form APCD-100
Colorado Department of Public Health and Environment
Air Pollution Control Division
Oil & Gas Industry
Construction Permit Application Completeness Checklist
Company Name:
Source Name:
Date:
Ver. November 29, 2012
Enerplus Resources (USA) Corporation
Colorado Department
of Public I leahh
and Fsnironment
Orca Facility
7/13/2020
Yes No
Are you requesting a facility wide permit for multiple emissions points?
In order to have a complete application, the following attachments must be provided, unless stated
otherwise. If application is incomplete, it will be returned to sender and filing fees will not be refunded.
Attachment
Application Element
Applicant
APCD
A
APEN Filing Fees
�1
❑
B
Air Pollutant Emission Notice(s) (APENs) &
Application(s) for Construction Permit(s) — APCD Form Series 200
C
Emissions Calculations and Supporting Documentation
/1
❑
D
Company Contact Information - Form APCD-101
►1
n
E
Ambient Air Impact Analysis
❑ Check here if source emits only VOC (Attachment E not required)
►1
❑
F
Facility Emissions Inventory — Form APCD-102
❑ Check here if single emissions point source (Attachment F not required)
► .
G
Process description, flow diagram and plot plan of emissions unit and/or
facility
❑ Check here if single emissions point source (Attachment G not required)
�1
H
Operating & Maintenance (O&M) Plan — APCD Form Series 300
n Check here if true minor emissions source or application is for a general
permit (Attachment H not required)
//
❑
I
Regulatory Analysis
Check here to request APCD to complete regulatory analysis
(Attachment I not required)
10
❑
J
Colorado Oil and Gas Conservation Commission (COGCC) 805 Series Rule
Requirements— Form APCD-105
is
❑
❑
ICheck here if source not subject to COGCC 805 Series requirements
(Attachment J not required)
Send Complete Application to:
Colorado Department of Public Health & Environment
APCD-SS-BI
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Check box if facility is an existing Title V source: ❑ Send an additional application copy
Check box if refined modeling analysis included: U Send an additional application copy
Check box if application is for major NA NSR or PSD permit: f Send eight (8) total application copies
Page 1 of 1
Orca_Form-APCD- I 00.doc
ever
Orca Facility
FLARE
Flow
Rate
Fuel
Heat Value
Hours of
Operation
flour
Rate
NOx
Emissions
NOx
Emissions
CO
Emissions
CO
Emissions
VOC
Emissions
VOC
Emissions
- CO2
Emissions
CH4 ,
Emissions
N2O
Emissions
(seffir)
(f3tuisef)
(hrlyr)
(Paul/ tr)"
lbhh
. (tpy)
(Ruhr)
(tpy)
(ibftir)
(tpy)
d py)
OM
aPsi
Flare gas
4500
1294.2
2250
10.13
0.396
0.446
1.605
2.03
3.93
4.42
766
0.0144
0.00144
Pilot Gas
17.6
1294.2
8760
0.15
0.002
0.01
0.01
0.03
-
-
12
0.000
0.0000
Total
4518
1294
10,28
0.396
0.452
1.812
2.062
3.93
4.42
778
0.015
0.0015
NOx/CO Emissions (tpy) •
EF (lb/MMBturFuel Usage (Mscf/d)"Heat Value (Btu/scf)'Hours Operation (hr/yr)
24 (hrldr1,000 (Mscf/MMscfr2,000 (lb/ton)
Emissions Component
Emissions
Factors
EF Source
Units
NOx
0.068
Ib/MMBtu
AP -42 Table 13.5-1
CO
0.31
Ib/MMBtu
AP -42 Table 13.5-1
CO2
53.06
kg/MMBtu
from EPA Mandatory Reporting Rule 40 CFR Part 98 for natural gas combustion
CH4
0.001
kg/MMBIu
from EPA Mandatory Reporting Rule 40 CFR Part 98 for natural gas combustion
N2O
0.0001
kg/MMBtu
from EPA Mandatory Reporting Rule 40 CFR Part 98 for natural gas combustion
QUESTAR ENERGY SERVICES
1210 D. Street, Rock Springs, Wyoming 82901
(307) 352-7292
Description:
Field:
Meter Number:
Analysis Date/Time:
Date Sampled:
Sample Temperature:
Sample Pressure:
Component
Orca Dehy Outlet
Black Hollow
Enerplus
05 -Dec -19, 11:16:23
4 -Dec -19
71
950
Mol%
Company: EnerPlus
Data File: 004971.D
G.C. Method: GAS EXTENDED.M
GPA Method GPA 2286
Sampled By: KS
Analyst Initials: BMB
Wt%
LW()
Methane 71.0719
Ethane 12.1304
Propane 9.0501
Isobutane 0.8562
n -Butane 2.5860
Neopentane 0.0058
Isopentane 0.3685
n -Pentane 0.3542
2,2-Dimethylbutane 0.0006
2,3-Dimethylbutane 0.0188
2-Methylpentane 0.0285
3-Methylpentane 0.0158
n -Hexane 0.0262
Heptanes 0.0264
Octanes 0.0000
Nonanes 0.0000
Decanes plus 0.0000
Nitrogen 1.1734
Carbon Dioxide 2.2872
Oxygen ND
Hydrogen Sulfide ND
Total 100.0000
Calculated Global Properties Units
Gross BTU/Real CF 1315.7
Sat.Gross BTU/Real CF 1294.2
Gas Compressibility (Z) 0.9958
Specific Gravity 0.7961
Avg Molecular Weight 23.003
Propane GPM 2.480295
Butane GPM 1.092648
Gasoline GPM 0.310801
26# Gasoline GPM 1.123983
Total GPM 7.636861
Base Mol°/0 100.3
49.5683
15.8572
17.3492
2.1634
6.5342
0.0183
1.1559
1.1109
0.0023
0.0705
0.1066
0.0590
0.0983
0.1010
0.0000
0.0000
0.0000
1.4290
4.3759
ND
ND
61.0829
16.4939
12.6521
1.4210
4.1363
0.0114
0.6844
0.6508
0.0013
0.0391
0.0599
0.0326
0.0547
0.0493
0.0000
0.0000
0.0000
0.6527
1.9776
ND
ND
H2S detection limit 100 ppm (+/-)
100.0000
100.0000
BTU/SCF at 60°F and14.73'psia
BTU/SCF at 60°F and14.73 psia
air=1
gm/mole
gal/MCF
gal/MCF
gal/MCF
gal/MCF
gal/M C F
%v/v
Component
Benzene
Toluene
Ethylbenzene
M&P Xylene
O-Xylene
2,2,4-Trimethylpentane
Cyclopentane
Cyclohexane
Methylcyclohexane
Description:
GRI GlyCalc Information
Component
Carbon Dioxide
Hydrogen Sulfide
Nitrogen
Methane
Ethane
Propane
Isobutane
n -Butane
Isopentane
n -Pentane
Cyclopentane
n -Hexane
Cyclohexane
Other Hexanes
Heptanes
Methylcyclohexane
2,2,4 Trimethylpentane
Benzene
Toluene
Ethylbenzene
Xylenes
C8+ Heavies
Subtotal
Oxygen
Total
Mol%
0.0029
0.0000
0.0000
0.0000
0.0000
0.0010
0.0000
0.0039
0.0011
Orca Dehy Outlet
Mol%
Wt% LW/0
0.0099
0.0000
0.0000
0.0000
0.0000
0.0052
0.0000
0.0143
0.0045
Wt%
0.0041
0.0000
0.0000
0.0000
0.0000
0.0027
0.0000
0.0068
0.0022
LV%
2.2872
ND
1.1734
71.0719
12.1304
9.0501
0.8562
2.5918
0.3685
0.3542
0.0000
0.0262
0.0039
0.0637
0.0175
0.0011
0.0010
0.0029
0.0000
0.0000
0.0000
0.0000
100.0000
ND
100.0000
4.3759
ND
1.4290
49.5683
15.8572
17.3492
2.1634
6.5342
1.1742
1.1109
0.0000
0.0983
0.0143
0.2384
0.0671
0.0045
0.0052
0.0099
0.0000
0.0000
0.0000
0.0000
100.0000
ND
100.0000
1.9776
ND
0.6527
61.0829
16.4939
12.6521
1.4210
4.1363
0.6958
0.6508
0.0000
0.0547
0.0068
0.1329
0.0335
0.0022
0.0027
0.0041
0.0000
0.0000
0.0000
0.0000
100.0000
ND
100.0000
Form APCD-101
Colorado Department of Public Health and Environment
Air Pollution Control Division
Company Contact Information Form
Ver. September 10, 2008
Company Name: Enerplus Resources (USA) Corporation
Colorado Department
of Public l'catch
and Environment
Source Name: Orca Facility
Permit
Contact':
Kristin Van Hees
Address:
950 17t'' Street, Suite 2200
Street
Denver
CO
80202
City
State
Zip
Phone Number:
720-279-5515
Fax Number:
E-mail:
KVanHees@enerplus.com
Billing Contact:
Permit Fees
Kristin Van Hees
Address:
950 17th Street, Suite 2200
Street
Denver
CO
80202
City
State
Zip
Phone Number:
720-279-5515
Fax Number:
E-mail:
KVanHees@enerplus.com
Compliance
Contact':
Kristin Van Hees
Address:
950 17th Street, Suite 2200
Street
Denver
CO
80202
City
State
Zip
Phone Number:
720-279-5515
Fax Number:
E-mail:
KVanHees@enerplus.com
Billing Contact:
(Annual Fees)`'
Kristin Van }lees
Address:
950 17th Street, Suite 2200
Street
Denver
CO
80202
City
State
Zip
Phone Number:
72-279-5515
Fax Number:
E-mail:
KVanHees@enerplus.com
Check how would you like to receive your permit fee invoice?
Mail: ❑
E-mail:
Fax: ❑
Footnotes:
1 The permit contact should be the point of contact for technical information contained in the permit application.
This may be a company representative or a consultant.
The compliance contact should be the point of contact for discussing inspection and compliance at the permitted
facility.
' The billing contact (Permit fees) should be the point of contact that should receive the invoice for tees
associated with processing the permit application & issuing the permit. (Reg. 3, Part A, Section VI.B)
° The billing contact (Annual fees) should be the point of contact that should receive the invoices issued on an
annual basis for fees associated with actual emissions reported on APENs for the facility. (Reg. 3, Part A,
Section VI.C)
Page 1 of 1
Orca_Form-APC D-101.doc
Form ar -Io2 I
Company Name: EncrpIns Resources NSA) Corporation
Source Nance: Ikea Facility
Source AIRS ID: 1231AOOF
Colorado Department of Public Health and Env ironmenl
Air Pollution Control Division
Facility Wide Emissions Inventory Form
Ver. April, 2015
lbumtmled Potential to Ft* IPTE)
Controlled Potential to Fmk (PTE)
Craene 111 Y) I IIAPs Ohxkrl
(cited.(I PI) Itlt Sllo/01
Al*In
Equipment
peeerlFOmn
TSP
PMIO
PM15
NO2
ti(h
VO('
10 10110
Areul
,Seen
a7
Tol
10
X55
n4lee
Meth
324-1'.IIP
ISP
P5110
P5I2.5
102
T(h
101
CO 11111(1
Arand
Atm
HZ
Td
Cg
XSI
n410
51011
224-1MP
TEG1
Ut
24.1
10,071
8,611
1.160
1,125
01
12
0.5
549
411
58
154
119
FLARE
n5
884
l21 I
U!
4a
21
EN01
1 1
7 1
I I
00
2'25 5
11 4
141 1 I 1.622
) 1
1 1
I I
011
11.4
11.4
241 I 811
GE'NI
02
02
02
00
2r1
25
466, I 50'1
U.2
02
1.
00
15
25
)0 I 254
Tarke
14 9
1
456
07
I
21
I
I
Permitted Sources Subtotal..
.MEN 1.1* - Penult Exempt Sonrm
1.4
1.4
IA
0.0
211.4
141.4
1092 I 2,129
0
0
14921
1.611
1.160
11'15
I,LM
0
0
I.4
14
1.4
OU
1.5.5
20.2
.M.O ; 1.045
0
11
544
171
Sa
159
62
U
0
I
I
I
I
I
I
I
I
I
I
I
.MEN I)*Subtotal 5,
.MEN Exempt i InV W1knt wren
0.0
0.0
0.0
0.0
QA
as
0.0 I 0
U
p
0
0
0
0
11
p
0
0.0
0.0
0.0
0.0
0.0
QO 0.0 I O
0
0
0
0
U
0
V
0
0
HTRI
0.0
00
rig
00
00
OU I
00
00
00
00
00
00 I
I1.romvEs
o.o
I
o.o
PIIX1M0
t
06
I
0.6
I
Comm.*. Illtin
03
I
02
I
I
I
I
I
I
I
LWOrdknt Subtotal.
Totµ .ea SlNrea.
0.0
0.0
0.0
0.0
0.0
09
0.0 1 0
0
0
0
0
0
0
0
0
U
OU
0.0
0.0
0.0
OA
0.9
0.0 I 0
00
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0
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0
0
0
0
1.4 1.4 1.4 00 25.1.4 1413 1092 1 I.129 0 0 11921 1611 1,1011 ),125 11216 0 0 I.4 1.4 1.4 OA 155 21.1 .55.8 t 1,045 II 0 V9 451 VI 159 62 tl 0
I nronndled 1EMI Stnamer2(TP1).4
l' nsntrvdled '10011 AB HAP•
I ( ontrolkd H.Mx X*4105
ContnAled ntok All HAN
1.1 I 0.0 I 0.0 I 5.5 I 4.5 I 0.6 I 1.6 I 0.6 I 0.0 I 0.0
ITPV)-I as I 00 I U.0 I ad I 0.2 I oo I at I on I OA I on
I
I
0 PV) •1 13.6
0,11 _I 1.2
Footnotes:
1. This tor, should be completed to include both existing sources and all proposed new or modifications to existing emissions sources
2. If the emissions source is new then enter "proposed" under the Permit No. and AIRS ID data columns
3. HAP abbreviations include
BZ = Benue e
Tnl Y Toluene
EB = Eth596evene
Xrl = Xylene
HCHO = Formaldehyde
4. APEN Exempt/Insignificant Sources should be included when warranted
224-TNIP = 2.2A-Trimethylpentanc
Aeetal =.Acetaldehyde
Acro = .Aoroletn
n-Hes n-Hexanc
Meth = Methanol
Company Name
711012020
Pawl oft
1
Field Gas to flare when no pipeline or pipeline is down
Inlet Field Gas
Field Gas to compression
Form APCD-309
cDPHE
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
APCD Internal Use Only
Received Date
Approved? ❑ Approval Date
Operating and Maintenance Plan Template fol
Separators'
Ver. January 27, 2020
This O&M plan was
superseded by the one at
the end of this document
ND 10/30/220
This term "separators" is intended throughout to include two-phase separators, three-phase separators, mgnitow pressure
separators, heater -treaters, vapor recovery towers, etc., and the associated air pollution control equipment.
The Air Pollution Control Division developed this Operating and Maintenance Plan (0&M Plan) for separators that
use emissions controls, permitted at synthetic minor and major oil and gas facilities in the State of Colorado. One
O&M Plan may be used for multiple separators at one facility if each are controlled and monitored in the same
manner.
An OEtM Plan shall be submitted with the permit application when required. The facility operator must comply
with the requirements of the 0&M Plan upon commencement of operation. An existing approved OEtM Plan may
be modified without a permit modification or permit reissuance, but the operator must adhere to the requirements
of the existing approved O&M Plan until an approval letter is issued for the new OEtM Plan.
The operator is required to use the division -developed O&M Plan template forms in order to meet minimum
expectations within a standard, organized format. Do not modify the structure and/or content of this template.
If the facility or emissions unit is subject to other state or federal regulations with duplicative requirements, the
operator must follow the most stringent regulatory requirement.
Please note that 0&M requirements are different for facilities in the Denver Metro and North Front Range 8 -hour
ozone nonattainment area.
For sources that are subject to the Title V Operating Permits program: In accordance with Colorado
Regulation No. 3, Part C, Section V.C.5., some or all of the monitoring specified in this 0&M plan will be
incorporated as specific conditions in the source's Title V Operating Permit (if applicable). Additional monitoring
not listed in this OEtM Plan may be included in the source's Operating Permit in order to satisfy the periodic
monitoring requirements of Regulation No. 3, Part C, Section V.C.5.b.
Submittal Date: 7:13/2020
Section 1 - Source Identification
For new permits, some of this information (i.e., Facility AIRS ID, Permit Number, and AIRS Point ID) may not be known at the
time of application. Please only fill in the fields that are known and leave the others blank.
Company Name:
Facility Name:
Enerplus Resource (USA) Facility
Corporation Location:
Orca Facility
Is this facility located in the Denver
Metro and North Front Range 8 -hour
ozone nonattainment area?
® Yes
❑ No
NESW Sec. 26, T8N, R67W
Facility AIRS ID (for existing facilities) 123 - AOOF
Emission Units Covered by this OEtM form
Facility Equipment ID
Permit Number
FLARE
19WE0544
AIRS Point ID
002
Page 1 of 5
COLORADO
.Air Pollution Control Division
Department of Public Health b Environment
Section 2 - Maintenance Schedules
Check one of the following:
Facility shall follow manufacturer recommendations for the operation and maintenance of the emissions
unit and control devices. These schedules and practices, as well as all maintenance records showing
compliance with these recommendations, shall be made available to the division upon request.
Facility shalt follow individually developed maintenance practices and schedules for the operation and
maintenance of the emissions unit and control devices. These schedules and practices, as well as all
maintenance records showing adherence to these practices, shall be made available to the division upon
request and shall be consistent with good air pollution control practices for minimizing emissions as
defined in the New Source Performance Standard (NSPS) general conditions.
Confirm the following requirement, if the separator has a pressure relief valve (PRV):
The operator shall inspect the separator pressure relief valve (PRV) at a minimum once every calendar
year. The inspection shall include a check that the PRV set point is adequate to ensure that emissions
are routed to the emissions control device during normal operation. Records of these inspections, and
any repairs, shall be made available to the division upon request.
Section 3 - Recordkeeping Requirements
The following box must be checked for the O&M Plan to be considered complete:
Synthetic minor and major sources are required to maintain maintenance and monitoring records for
the requirements of this OEtM Plan for a period of five (5) years. If applicable state requirements or
any Federal NSPS, NESHAP, or MACT require a longer record retention period, the operator must comply
with the longest record retention requirement.
Page 2 of 5
CDPHE
COLORADO
Air Pollution Control Division
Depat ti lent of Public Health & Environment
Section 4 - Monitoring Requirements
Emission Unit Information
The following boxes must be checked for the OEtM Plan to be considered complete:
Attach a diagram or plot plan of the configuration of the separator(s), control device(s), and vapor
recovery unit(s), as well as the location(s) of flow meters. This diagram is required in addition to the
facility -wide diagram required for new permit applications. This diagram shall be retained with the
O&M Plan for reference by the operator and division inspector.
The permit requires calculation and recordkeeping of actual emissions from this source, but the calculation
methods are not incorporated into the permit. In the space below, describe the formulas used to calculate the
volume of gas vented from the separator and sent to the control device, using data from the meter if required.
If using a vapor recovery tower (VRT), describe the method used to calculate the volume of gas vented from the
VRT. If the permit throughput limit is in terms of hydrocarbon liquid, then in the space below describe how the
liquid throughput shalt be tracked.
Examples:
Flow meter at enclosed flare directly measures the volume of gas sent to flare from a single separator.
OR
Volume from low pressure separator sent to control device = (Metered volume through high pressure separator) - (Metered volume through low pressure separator)
OR
Volume vented from VRT = (Total gas volume metered at flare) - (Metered volume to flare from low pressure separator) - (Volume to flare from tanks)
OR
Permit throughput limit is based on hydrocarbon liquid, which is tracked by tank inlet meter, with backup of sales/haul tickets.
OR etc.
Please be clear and specific about the sources of input data, and describe how the input data is collected and recorded. Attach additional pages if needed.
Total gas sent to flare is metered
Page 3 of 5
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Control Equipment Information
Table 1 below details the monitoring parameters and frequency for control equipment depending on the type of
control equipment and the requested permitted emissions at the facility. Indicate the separator emissions control
by checking the appropriate boxes. In addition, check the appropriate box for "Monitoring Frequency" based on
the facility attainment area status and facility -wide permitted VOC emissions.
Table 1
Emissions Control
or
Recycling Method
Parameter
Monitoring Frequency
Ozone Nonattainment Area
Ozone Attainment Areas
❑ Permitted
Facility
Emissions
a 80 tpy VOC
❑ Permitted
Facility
Emissions
< 80 tpy VOC
II Permitted
.1 Permitted
Facility
Emissions
a 40 tpy VOC
Facility
Emissions
< 40 tpy VOC
Enclosed Flare
or Elevated
Open Flare a
Pilot Light / Auto -
igniter Monitoring
and
Visible Emissions
Observation
Daily b' c
Weekly b. c
Daily b' c
Weekly b' c
A
Vapor Recovery
Unit (VRU) or
Recycled or
Closed Loop
System d
❑
Monitoring requirements, including parameters and frequency, to be determined by the
operator and listed below in footnote d.
Other
M
Monitoring requirements, including specific parameters and frequency, to be described
a Elevated Open Flare
An open flare permitted after May 1, 2014 and used to comply with Regulation No. 7 Section XVII must be
approved by the division as an alternate emission control device prior to operation, in accordance with
Regulation No. 7 Section XVI1.B.2.e.; see PS Memo 15-03.
b Pilot Light Monitoring Options
If emissions are controlled by combustion device, then the operator must indicate in Table 2 the method by
which the presence of a pilot light will be monitored. One primary method for Pilot Light Monitoring must be
checked and, optionally, secondary methods may be checked.
Table 2: Pilot Light Monitoring
Primary
Secondary
Monitoring Method
n
Visual Inspection
Optical Sensor
_
_
_
Auto -Igniter Signal
Thermocouple
Page 4 of 5
GDPHE
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Visible Emissions Observation and Method 22 Options
At the frequency specified in Table 1, the operator is required to conduct an inspection of the subject combustion
device for the presence or absence of smoke (e.g., visible emissions). If smoke is observed during the visible
emissions inspection, the operator has the option to either (1) immediately shut-in the emissions unit to
investigate the cause of the smoke, conduct any necessary repairs, and maintain records of the specific repairs
completed; or (2) conduct a formal Method 22 observation to determine whether visible emissions (as defined
per Regulation No. 7, Section XViI.A.16.) are present.
If a Method 22 is conducted, the record of the observations shalt be maintained as required in Section 3 of this
OEtM Plan (Reference: Regulation No. 7, Section XVILC.3.d). If visible emissions are observed by Method 22, the
operator shall immediately conduct any necessary repairs and maintain records of the specific repairs completed;
if repair cannot be immediately completed, the operator shall shut-in the emissions unit, conduct any necessary
repairs, and maintain records of the specific repairs completed.
If the emissions unit is subject to Regulation No. 7, Section XII.E, operators must document the required
inspections for the presence or absence of smoke. The division has historically approved a "check box" to satisfy
the documentation procedures referenced in Section XII. The division will continue to accept the "check box"
recordkeeping format in instances where no visible emissions are observed in order to demonstrate compliance
with Regulation No. 7 Section XIl.E.4.a.
If a flare is not subject to Regulation No. 7 requirements (as described in the permit), a similar approach may
be employed where the operator may conduct an inspection for presence or absence of smoke, and, if smoke is
observed, the operator has the option to (1) immediately conduct repairs and maintain records of the specific
repairs completed; (2) shut-in the emissions unit to investigate the cause of the smoke, conduct any necessary
repairs, and maintain records of the specific repairs completed; or (3) conduct a formal Method 9 observation
to determine the opacity of the visible emissions, and conduct repairs if necessary.
d Vapor Recovery Unit (VRU) or Recycled or Closed Loop System
In the space provided below, please provide a description of the emission control or recycling system, including
an explanation of parameters monitored, monitoring frequency, and how the system design ensures that
emissions are being routed to the appropriate system at all times, or during all permitted runtime. Also, provide
a description of how downtime is tracked and recorded. Attach additional pages if necessary.
Section 5 - Additional Notes and O£tM Activities
Please use this section to describe any additional notes or operation and maintenance activities, or if additional
space is needed from a previous section. Attach additional pages if necessary.
Page 5 of 5
Regulatory Review
This section provides a regulatory review of the applicability of state and federal air quality permitting
requirements and air pollution control regulations for the flare located at Orca Facility. The purpose of
this section is to provide appropriate explanation and rationale regarding the applicability or non -
applicability of these regulations.
Regulation 3, Part A, Section II: The engines, flare and dehydration unit is subject to APEN reporting.
The reboiler, combustor and fugitives are APEN deminimis.
Regulation 3, Part C: This facility as proposed will not exceed Title V Operating Permit thresholds and
therefore is not subject to this regulation.
Regulation 3, Part D: This facility is not a listed source in Regulation 3, Part A.I.23.b and therefore
would trigger Prevention of Significant Deterioration (PSD) requirements if emissions exceed 250 tpy of
any criteria pollutant. This facility as proposed will not be greater than 250 tpv and therefore is not
subject to this regulation. The source is located in the ozone non -attainment area. This facility as
proposed and aggregated will be a synthetic minor source with respect to non -attainment NSR.
Regulation 7, Part D: The flare is not an affected facility under this regulation.
Form APCD-309
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health £r Environment
APCDed Date
inY ti e00nly
ReceiiW
v��II u0
Approved? ® Approval Date 10/30/202
Operating and Maintenance Plan Template for
Separatorst
Ver. January 27, 2020
This term "separators" is intended throughout to include two-phase separators, three-phase separators, high/low pressure
separators, heater -treaters, vapor recovery towers, etc., and the associated air pollution control equipment.
The Air Pollution Control Division developed this Operating and Maintenance Plan (OEtM Plan) for separators that
use emissions controls, permitted at synthetic minor and major oil and gas facilities in the State of Colorado. One
OEtM Plan may be used for multiple separators at one facility if each are controlled and monitored in the same
manner.
An O&M Plan shall be submitted with the permit application when required. The facility operator must comply
with the requirements of the OEtM Plan upon commencement of operation. An existing approved OEtM Plan may
be modified without a permit modification or permit reissuance, but the operator must adhere to the requirements
of the existing approved atM Plan until an approval letter is issued for the new atM Plan.
The operator is required to use the division -developed OEtM Plan template forms in order to meet minimum
expectations within a standard, organized format. Do not modify the structure and/or content of this template.
If the facility or emissions unit is subject to other state or federal regulations with duplicative requirements, the
operator must follow the most stringent regulatory requirement.
Please note that atM requirements are different for facilities in the Denver Metro and North Front Range 8 -hour
ozone nonattainment area.
For sources that are subject to the Title V Operating Permits program: In accordance with Colorado
Regulation No. 3, Part C, Section V.C.5., some or all of the monitoring specified in this atM plan will be
incorporated as specific conditions in the source's Title V Operating Permit (if applicable). Additional monitoring
not listed in this atM Plan may be included in the source's Operating Permit in order to satisfy the periodic
monitoring requirements of Regulation No. 3, Part C, Section V.C.5.b.
Submittal Date: 7/13/2020
Section 1 - Source Identification
For new permits, some of this information (i.e., Facility AIRS ID, Permit Number, and AIRS Point ID) may not be known at the
time of application. Please only fill in the fields that are known and leave the others blank.
Company Name: Enerplus Resource (USA)
Corporation
Facility Name: Orca Facility
Is this facility located in the Denver
Metro and North Front Range 8 -hour
ozone nonattainment area?
® Yes
❑ No
Facility
Location:
NESW Sec. 26, T8N, R67W
Facility AIRS ID (for existing facilities) 123 - AOOF
Emission Units Covered by this OEM form
Facility Equipment ID
Permit Number
FLARE
19WE0544
AIRS Point ID
002
Page 1 of 5
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Section 2 - Maintenance Schedules
Check one of the following:
Facility shall follow manufacturer recommendations for the operation and maintenance of the emissions
unit and control devices. These schedules and practices, as well as all maintenance records showing
compliance with these recommendations, shall be made available to the division upon request.
Facility shall follow individually developed maintenance practices and schedules for the operation and
maintenance of the emissions unit and control devices. These schedules and practices, as well as all
maintenance records showing adherence to these practices, shall be made available to the division upon
request and shall be consistent with good air pollution control practices for minimizing emissions as
defined in the New Source Performance Standard (NSPS) general conditions.
Confirm the following requirement, if the separator has a pressure relief valve (PRV):
The operator shall inspect the separator pressure relief valve (PRV) at a minimum once every calendar
year. The inspection shall include a check that the PRV set point is adequate to ensure that emissions
are routed to the emissions control device during normal operation. Records of these inspections, and
any repairs, shall be made available to the division upon request.
Section 3 - Recordkeeping Requirements
The following box must be checked for the O&M Plan to be considered complete:
EZ
Synthetic minor and major sources are required to maintain maintenance and monitoring records for
the requirements of this OEtM Plan for a period of five (5) years. If applicable state requirements or
any Federal NSPS, NESHAP, or MACT require a longer record retention period, the operator must comply
with the longest record retention requirement.
Page 2 of 5
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health £r Environment
Section 4 - Monitoring Requirements
Emission Unit Information
The following boxes must be checked for the 0&M Plan to be considered complete:
Attach a diagram or plot plan of the configuration of the separator(s), control device(s), and vapor
recovery unit(s), as well as the location(s) of flow meters. This diagram is required in addition to the
facility -wide diagram required for new permit applications. This diagram shall be retained with the
OEtM Plan for reference by the operator and division inspector.
The permit requires calculation and recordkeeping of actual emissions from this source, but the calculation
methods are not incorporated into the permit. In the space below, describe the formulas used to calculate the
volume of gas vented from the separator and sent to the control device, using data from the meter if required.
If using a vapor recovery tower (VRT), describe the method used to calculate the volume of gas vented from the
VRT. If the permit throughput limit is in terms of hydrocarbon liquid, then in the space below describe how the
liquid throughput shall be tracked.
Examples:
Flow meter at enclosed flare directly measures the volume of gas sent to flare from a single separator.
OR
Volume from low pressure separator sent to control device = (Metered volume through high pressure separator) - (Metered volume through low pressure separator)
OR
Volume vented from VRT = (Total gas volume metered at flare) - (Metered volume to flare from low pressure separator) - (Volume to flare from tanks)
OR
Permit throughput limit is based on hydrocarbon liquid, which is tracked by tank inlet meter, with backup of sales/haul tickets.
OR etc.
Please be clear and specific about the sources of input data, and describe how the input data is collected and recorded. Attach additional pages if needed.
Total gas sent to flare is metered
Page 3 of 5
Jg
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health £r Environment
Control Equipment Information
Table 1 below details the monitoring parameters and frequency for control equipment depending on the type of
control equipment and the requested permitted emissions at the facility. Indicate the separator emissions control
by checking the appropriate boxes. In addition, check the appropriate box for "Monitoring Frequency" based on
the facility attainment area status and facility -wide permitted VOC emissions.
Table 1
Emissions Control
or
Recycling Method
Parameter
Monitoring Frequency
Ozone Nonattainment Area
Ozone Attainment Areas
❑ Permitted
Facility
Emissions
≥ 40 tpy VOC
❑ Permitted
Facility
Emissions
≥ 80 tpy VOC
❑ Permitted
Facility
Emissions
< 80 tpy VOC
/1 Permitted
Facility
Emissions
< 40 tpy VOC
Enclosed Flare
or Elevated
Open Flare a
Pilot Light / Auto -
igniter Monitoring
and
Visible Emissions
Observation
Daily b' c
Weekly b, `
Daily b' c
Weekly b'
►1
Vapor Recovery
Unit (VRU) or
Recycled or
Closed Loop
System d
❑
Monitoring requirements, including parameters and frequency, to be determined by the
operator and listed below in footnote d.
Other
❑
Monitoring requirements, including specific parameters and frequency, to be described
in Section 5 below, and approved by the division. ,
a Elevated Open Flare
An open flare permitted after May 1, 2014 and used to comply with Regulation No. 7 Section XVII must be
approved by the division as an alternate emission control device prior to operation, in accordance with
Regulation No. 7 Section XVII.B.2.e.; see PS Memo 15-03.
b Pilot Light Monitoring Options
If emissions are controlled by combustion device, then the operator must indicate in Table 2 the method by
which the presence of a pilot light will be monitored. One primary method for Pilot Light Monitoring must be
checked and, optionally, secondary methods may be checked.
Table 2: Pilot Light Monitoring
Primary
Secondary
Monitoring Method
1
❑
Visual Inspection
❑
❑
Optical Sensor
❑
❑
Auto -Igniter Signal
❑
❑
Thermocouple
Page 4 of 5
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health £r Environment
Visible Emissions Observation and Method 22 Options
At the frequency specified in Table 1, the operator is required to conduct an inspection of the subject combustion
device for the presence or absence of smoke (e.g., visible emissions). If smoke is observed during the visible
emissions inspection, the operator has the option to either (1) immediately shut-in the emissions unit to
investigate the cause of the smoke, conduct any necessary repairs, and maintain records of the specific repairs
completed; or (2) conduct a formal Method 22 observation to determine whether visible emissions (as defined
per Regulation No. 7, Section XVII.A.16.) are present.
If a Method 22 is conducted, the record of the observations shall be maintained as required in Section 3 of this
OEtM Plan (Reference: Regulation No. 7, Section XVII.C.3.d). If visible emissions are observed by Method 22, the
operator shall immediately conduct any necessary repairs and maintain records of the specific repairs completed;
if repair cannot be immediately completed, the operator shall shut-in the emissions unit, conduct any necessary
repairs, and maintain records of the specific repairs completed.
If the emissions unit is subject to Regulation No. 7, Section XII.E, operators must document the required
inspections for the presence or absence of smoke. The division has historically approved a "check box" to satisfy
the documentation procedures referenced in Section XII. The division will continue to accept the "check box"
recordkeeping format in instances where no visible emissions are observed in order to demonstrate compliance
with Regulation No. 7 Section XII.E.4.a.
If a flare is not subject to Regulation No. 7 requirements (as described in the permit), a similar approach may
be employed where the operator may conduct an inspection for presence or absence of smoke, and, if smoke is
observed, the operator has the option to (1) immediately conduct repairs and maintain records of the specific
repairs completed; (2) shut-in the emissions unit to investigate the cause of the smoke, conduct any necessary
repairs, and maintain records of the specific repairs completed; or (3) conduct a formal Method 9 observation
to determine the opacity of the visible emissions, and conduct repairs if necessary.
d Vapor Recovery Unit (VRU) or Recycled or Closed Loop System
In the space provided below, please provide a description of the emission control or recycling system, including
an explanation of parameters monitored, monitoring frequency, and how the system design ensures that
emissions are being routed to the appropriate system at all times, or during all permitted runtime. Also, provide
a description of how downtime is tracked and recorded. Attach additional pages if necessary.
Section 5 - Additional Notes and O&M Activities
Please use this section to describe any additional notes or operation and maintenance activities, or if additional
space is needed from a previous section. Attach additional pages if necessary.
Page 5 of 5
Hello