HomeMy WebLinkAbout20203836.tiffCOLORADO
Department of Public
Health b 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 2 1 2020
COMMISSIONERS
On December 15, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
Aka Energy Group, LLC - Kersey Compressor Station. 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 Polls, Governor I Jilt Hunsaker Ryan, MPH, Executive Director
Pv b i; c Ke v: E W
oi/O6121
cc:PL(TP) NL(DShR),PwatNEQ/Ci4/CV)/
O6Ot-t5
12/2x/2O
2020-3836
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Aka Energy Group, LLC - Kersey Compressor Station - 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: Aka Energy Group, LLC
Facility: Kersey Compressor Station
Natural gas compressor station
25630 Weld County Road 55
Weld County
The proposed project or activity is as follows:
Applicant requests a permit for a new TEG dehydration unit (50 MMSCFD) at an existing compressor station
in the ozone nonattainment area of Weld County. As of the time of application receipt, the facility was Title
V Major for VOC and NOx, and a "major stationary source" under NANSR for VOC and NOx. This project to
add TEG dehydration increases the PTE of VOC by 11.84 tpy and the PTE of NOx by 7.1 tpy. The emissions
increase is under the "significant emission rate" of 40 toy for each of the two pollutants, and so this project
is considered a "minor modification at a major stationary source."
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 20WE0531 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.Rov/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:
Andy Gruel
Colorado Department of Public Health and Environment
COLORADO
Department of Public
Health @ En+rfronment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
2
COLORADO
Department of Public
Health 6 Environment
COLORADO
Air Pollution Control Division
Department of Public Health b Env onment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
20WE0531 Issuance:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Aka Energy Group, LLC
Kersey Compressor Station
123/0473
25630 Weld County Road 55
Weld County
Natural Gas Compressor Station
Equipment or activity subject to this permit:
1
Ement
ID
AIRS
Point
Equipment Description
Emissions Control Description
---
017
One (1) Triethylene glycol (TEG)
natural gas dehydration unit (make:
Exterran, model 1 MMBtu/hr,
serial number: 12486) with a design
capacity of 50 MMscf per day. This
emissions unit is equipped with two
(2) electric driven glycol pumps
(make: Hydra -Cell, model: D15X)
with a design capacity of 10.83
gallons per minute. This unit is
equipped with a flash tank, reboiler
and still vent.
Emissions from the still vent are
routed to an air-cooled condenser,
and then to an enclosed combustor.
As a secondary control device, still
vent emissions are routed to the
VRU the enclosed combustor
dwn )
Emissions from the flash tank are
routed directly to the Vapor
Recovery Unit (VRU). As a secondary
control device, flash tank emissions
are routed to the closed -loop
system when the VRU is down.
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
the specific general terms and conditions included in this document and the following specific terms
and conditions.
Page 1 of 16
N •'f
tz,-,
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after
commencement of operation under this permit by submitting a Notice of Startup (NOS) form to
the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and
can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
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. A self certification form and guidance on how to self -
certify compliance as required by this permit may be obtained online at
www.colorado.Qov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period 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. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days of the
latter of commencement of operation or issuance of this permit.
• The dehydrator manufacturer name, model number and serial number
• The glycol circulation pump manufacturer name and model number
This information shall be included with the Notice of Startup submitted for the equipment.
(Regulation Number 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.
Page 2 of 16
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section I I.A.4. )
Monthly Limits:
Equipment
ID
AIRS
Point
Pounds per Month
Emission
Type
PM2.5
NO,
VOC
CO
---
017
---
1206
2011
2408
Point
Note: Monthly limits are based on a 31 -day month.
The owner or operator shall calculate monthly emissions based on the calendar month.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 1,359
pounds per month.
Facility -wide emissions of total hazardous air pollutants shall not exceed 3,398 pounds per
month.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Annual Limits:
Equipment
ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
---
017
---
7.1
11.8
14.2
Point
Note: 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 not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
Compliance with the annual limits, for criteria and hazardous air pollutants, 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
Page 3 of 16
r
C0L0RADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
8. Compliance with the emission limits in this permit shall be demonstrated by running the GRI-
GLYCaIc model version 4.0 or higher on a monthly basis using the most recent extended wet
gas analysis and recorded operational values, including: dry gas throughput, lean glycol
recirculation rate, vapor recovery unit (VRU) downtime, flash tank temperature and pressure,
wet gas inlet temperature, and wet gas inlet pressure. Recorded operational values, except
for dry gas throughput, shall be averaged on a monthly basis for input into the model and be
provided to the Division upon request.
9. On a daily basis, the owner or operator shall monitor and record operational values including:
vapor recovery unit (VRU) downtime, flash tank temperature and pressure, wet gas inlet
temperature and pressure. These records shall be maintained for a period of five years.
10. The owner or operator shalt operate and maintain the emission points in the table below with
the emissions control equipment as listed in order to reduce emissions to less than or equal to
the limits established in this permit. The owner or operator shall operate this dehydration
unit so as to prevent any emissions directly to the atmosphere. (Regulation Number 3, Part B,
Section III.E.)
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
---
017
Still Vent: Enclosed Flare, and Vapor Recovery
Unit when Enclosed Flare is down
VOC and HAP
Flash Tank: Vapor Recovery Unit when closed-
loop recycle to plant inlet is not available.
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
11. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall 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
Monthly Limit
-
017
Dry Gas Throughput
18,250 MMscf/yr
1,550
MMscf/month
ote: The monthly limit is based on 31 days.
The owner or operator shall monitor monthly process rates based on the calendar month. The
volume of dry gas throughput shall be measured by gas meter at the outlet of the dehydrator.
Page 4 of 16
COLORADO
Air Pollution Control Division
Department of Pubhc Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
During the first twelve (12) months of operation, compliance with both the monthly and
annual throughput limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
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.
12. This unit shall be limited to the maximum lean glycol circulation rate of 10.83 gallons per
minute. The lean glycol recirculation rate shall be recorded daily in a log maintained on site
and made available to the Division for inspection upon request. Glycol recirculation rate shall
be monitored by one of the following methods: assuming maximum design pump rate, using
glycol flow meter(s), or recording strokes per minute and converting to circulation rate. This
maximum glycol circulation rate does not preclude compliance with the optimal glycol
circulation rate (Lopt) provisions under MACT HH. (Reference: Regulation Number 3, Part B,
II.A.4)
STATE AND FEDERAL REGULATORY REQUIREMENTS
13. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section'III.E.) (State only enforceable)
14. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
15. This source is subject to Regulation Number 7, Part D, Section I.H. The operator shall comply
with all applicable requirements of Section I and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for glycol natural gas dehydrators; and
• Ensure uncontrolled actual emissions of volatile organic compounds from the still vent
and vent from any gas -condensate -glycol (GCG) separator (flash separator or flash
tank), if present, shall be reduced by at least 90 percent on a rolling twelve-month
basis through the use of a condenser or air pollution control equipment. (Regulation
Number 7, Part D, Section I.H.1.)
16. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B General Provisions (State only enforceable). If a flare or other combustion device
is used to control emissions of volatile organic compounds to comply with Section II, it shall
be enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, II.A.23; and be designed so that an observer can, by means of visual
observation from the outside of the enclosed flare or combustion device, or by other
convenient means approved by the Division, determine whether it is operating properly. This
flare must be equipped with an operational auto -igniter according to the following schedule:
Page 5 of 16
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
17. The glycol dehydration unit covered by this permit is subject to the emission control
requirements in Regulation Number 7, Part D, Section II.D.3. Beginning May 1, 2015, still
vents and vents from any flash separator or flash tank on a glycol natural gas dehydrator
located at an oil and gas exploration and production operation, natural gas compressor
station, or gas -processing plant subject to control requirements pursuant to Section II.D.4.,
shall reduce uncontrolled actual emissions of hydrocarbons by at least 95% on a rolling
twelve-month basis through the use of a condenser or air pollution control equipment.
18. 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, SectionV.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)
19. The glycol dehydration unit at this facility is subject to National Emissions Standards for
Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities,
Subpart HH. This facility shall be subject to applicable area source provisions of this
regulation, as stated in 40 C.F.R Part 63, Subpart A and HH. (Regulation Number 8, Part E,
Subpart A and HH)
MACT HH Applicable
Requirements
Area Source
Outside UA/UC boundary
563.760 -
Applicability and
designation of
affected source
563.760 (f) - The owner or operator of an affected major source
shall achieve compliance with the provisions of this subpart by
the dates specified in paragraphs (f)(1) and (f)(2) of this section.
The owner or operator of an affected area source shall achieve
compliance with the provisions of this subpart by the dates
specified in paragraphs (f)(3) through (f)(6) of this section.
563.764 - General
Standards
563.764 (d)(2) -Each owner or operator of an area source not
located in a UA plus offset and UC boundary (as defined in
563.761) shall comply with the provisions specified in paragraphs
(d)(2(i) through (iii) of this section.
563.764 (d)(2)(i) - Determine the optimum glycol circulation rate
using the following equation:
Page 6 of 16
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
MACT HH Applicable
Requirements
Area Source
Outside UA/UC boundary
gal TEG * F*(I-O)\
L,„,,
gal/hr.
of thumb for a TEG-to water
for a margin of safety.
TEG dehydration unit such that
does not exceed the optimum
in accordance with paragraph
dehydration unit is unable to
for moisture content using the
in accordance with paragraph
must calculate an alternate
Version 3.0 or higher. The
why the TEG dehydration unit
circulation rate and submit
notification in accordance
of the determination
accordance with the
the Initial Notification in
in 563.775(c)(7). If operating
to the optimum glycol
or operator shall prepare a
with paragraph (d)(2)(i) or (ii)
specified under
=I.15*3.0
16 H2O 24hr / day j
Where:
LOPT = Optimal circulation rate,
F = Gas flowrate (MMSCF/D)
I = Inlet water content (lb/MMSCF)
O = Outlet water content (lb/MMSCF)
3.0 = The industry accepted rule
ratio (gal TEG/1bH2O)
1.15 = Adjustment factor included
$63.764 (d)(2)(ii) - Operate the
the actual glycol circulation rate
glycol circulation rate determined
(d)(2)(i) of this section. If the TEG
meet the sates gas specification
glycol circulation rate, determined
(d)(2)(i), the owner or operator
circulation rate using GRI-GLYCalcTM,
owner or operator must document
must be operated using the alternate
this documentation with the initial
with g63.775(c)(7).
563.764 (d)(2)(iii) - Maintain a record
specified in paragraph (d)(2)(ii) in
requirements in 563.774(f) and submit
accordance with the requirements
conditions change and a modification
circulation rate is required, the owner
new determination in accordance
of this section and submit the information
§63.775(c)(7)(ii) through (v).
563.774 -
Recordkeeping
Requirements
563.774 (b) - Except as specified in paragraphs (c), (d), and (f) of
this section, each owner or operator of a facility subject to this
subpart shall maintain the records specified in paragraphs (b)(1)
through (11) of this section §63.774 (b)(1)
563.774 (b)(1) - The owner or operator of an affected source
subject to the provisions of this subpart shall maintain files of all
information (including all reports and notifications) required by
this subpart. The files shall be retained for at least 5 years
following the date of each occurrence, measurement,
maintenance, corrective action, report or period.
Page 7 of 16
COLORADO
Aix Pollution Control Division
artment of Publlc Health b Frnv4ronment
Dedicated to protecting and improving the health and environment of the people of Colorado
MACT HH Applicable
Requirements
Area Source
Outside UA/UC boundary
§63.774 (b)(1)(i) - All applicable records shall be maintained in
such a manner that they can be readily accessed.
§63.774 (b)(1)(ii) - The most recent 12 months of records shall be
retained on site or shall be accessible from a central location by
computer or other means that provides access within 2 hours
after a request.
563.774 (b)(1)(iii) - The remaining 4 years of records may be
retained offsite.
563.774 (b)(1)(iv) - Records may be maintained in hard copy or
computer -readable form including, but not limited to on paper,
microfilm, computer, floppy disk, magnetic tape, or microfiche.
563.774 (f) - The owner or operator of an area source not located
within a UA plus offset and UC boundary must keep a record of
the calculation used to determine the optimum glycol circulation
rate in accordance with §63.764(d)(2)(i) or §63 764(d)(2)(ii), as
applicable.
563.775 - Reporting
Requirements
563.775 (c) - Except as provided in paragraph (c)(8), each owner
or operator of an area source subject to this subpart shall submit
the information listed in paragraph (c)(1) of this section. If the
source is located within a UA plus offset and UC boundary, the
owner or operator shall also submit the information listed in
paragraphs (c)(2) through (6) of this section. If the source is not
located within any UA plus offset and UC boundaries, the owner
or operator shall also submit the information listed within
paragraph (c)(7).
563.775 (c)(1) - The initial notifications required under
§63.9(b)(2) not later than January 3, 2008. In addition to
submitting your initial notification to the addressees specified
under 563.9(a), you must also submit a copy of the initial
notification to EPA's Office of Air Quality Planning and Standards.
Send your notification via e-mail to CCG-ONG@EPA.GOV or via
U.S. mail or other mail delivery service to U.S. EPA, Sector
Policies and Programs Division/Coatings and Chemicals Group
(E143-01), Attn: Oil and Gas Project Leader, Research Triangle
Park, NC 27711.
Page 8 of 16
COLORADO
Air Pollution Control Division
Department c( Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
MACT HH Applicable
Requirements
Area Source
Outside UA/UC boundary
563.775 (c)(7) - The information listed in paragraphs (c)(1)(i)
through (v) of this section. This information shall be submitted
with the initial notification.
563.775 (c)(7)(i) - Documentation of the source's location relative
to the nearest UA plus offset and UC boundaries. This information
shall include the latitude and longitude of the affected source;
whether the source is located in an urban cluster with 10,000
people or more; the distance in miles to the nearest urbanized
area boundary if the source is not located in an urban cluster with
10,000 people or more; and the names of the nearest urban
cluster with 10,000 people or more and nearest urbanized area.
$63.775 (c)(7)(ii) - Calculation of the optimum glycol circulation
rate determined in accordance with $63.764(d)(2)(i).
563.775 (c)(7)(iii) - If applicable, documentation of the alternate
glycol circulation rate calculated using GRI-GLYCalcTM, Version
3.0 or higher and documentation stating why the TEG dehydration
unit must operate using the alternate glycol circulation rate.
563.775 (c)(7)(iv) - The name of the manufacturer and the model
number of the glycol circulation ',pump(s)'in operation.
563.775 (c)(7)(v) - Statement by a responsible official, with that
official's name, title, and signature, certifying that the facility
will always operate the glycol dehydration unit using the optimum
circulation rate determined in accordance with $63.764(d)(2)(i) or
$63.764(d)(2)(ii), as applicable.
563.775 (f) - Notification of process change. Whenever a process
change is made, or a change in any of the information submitted
in the Notification of Compliance Status Report, the owner or
operator shall submit a report within 180 days after the process
change is made or as a part of the next Periodic Report as
required under paragraph (e) of this section, whichever is sooner.
The report shall include:
563.775 (f)(1) - A brief description of the process change;
$63.775 (f)(2) - A description of any modification to standard
procedures or quality assurance procedures
Page 9 of 16
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
MACT HH Applicable
Requirements
Area Source
Outside UA/UC boundary
$63.775 (f)(3) - Revisions to any of the information reported in
the original Notification of Compliance Status Report under
paragraph (d) of this section; and
$63.775 (f)(4) - Information required by the Notification of
Compliance Status Report under paragraph (d) of this section for
changes involving the addition of processes or equipment.
OPERATING £t MAINTENANCE REQUIREMENTS
20. Upon startup of these points, the owner or operator shall follow the most recent operating
and maintenance (0&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 the oam 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
21. The owner or operator shall demonstrate compliance with opacity standards, using ,EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence
of visible emissions. "Visible Emissions" means observations of smoke for any period or
periods of duration greater than or equal to one minute in any fifteen minute period during
normal operation. (Regulation Number 7, Part D, Sections 11.6.2. and II.A.23)
Periodic Testing Requirements
22. The owner or operator shall complete an extended wet gas analysis prior to the inlet of the
dehydration unit on an annual basis. Results of the wet gas analysis shall be used to calculate
emissions of criteria pollutants and hazardous air pollutants per this permit and be provided
to the Division upon request.
ADDITIONAL REQUIREMENTS
23. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
Page 10 of 16
COLORADO
Air Pollution Control Division
Department of Public Fleallh b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
24. This source is subject to the provisions of Regulation Number 3 Part C, Operating Permits
(Title V of the 1990 Federal Clean Air Act Amendments). The application for the Operating
Permit is due by January 27, 2021.
25. The requirements of Colorado Regulation Number 3, Part D shall 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 (Reference: Regulation Number 3, Part D, 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 11 of 16
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Equipment
ID
AIRS
Point
Equipment
Description
Pollutant
Emissions - tons per year
Threshold
Current
Permit
Limit
---
017
TEG Dehy,
50 MMscf/d
NOx
25
7.1
VOC
25
11.8
GENERAL TERMS AND CONDITIONS
26. 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.
27. 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.
28. 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.
29. 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.
30. 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
Page 12 of 16
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
31. 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.
32. 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:
Andy Gruel, P.E.
Permit Engineer`
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Aka Energy Group, LLC as a minor
modification at a major stationary source.
Page 13 of 16
COLORADO
Air Pollution Control Division
Department of Public Health Er 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 shall 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 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.
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
N
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
---
017
Benzene
71432
51061
2553
Toluene
108883
49131
2457
Ethylbenzene
100414
1064
53
Xylenes
1330207
15622
781
n -Hexane
110543
10909
545
224-TMP
540841
11
1
5) The emission levels contained in this permit are based on information provided in the application
and the GRI GlyCalc 4.0 model, based on a 3/3/2020 site -specific inlet gas analysis. Controlled
emissions are based on an enclosed flare control efficiency of 95%.
For NOx, CO, and PM emissions, the permit holder assumed the maximum burner rating of the
enclosed flare, at 8760 hr/yr. This is 11.7 MMBtu/hr, plus 0.05 MMBtu/hr for the pilot light, and
an assumed heat content of 2645 Btu/scf (from 4/10/2019 gas analysis.) This results in an
Page 14 of 16
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
assumed volume of emissions vented to the flare of 38.91 MMscf/yr. The following emission
factors were used for NOx/CO/PM emissions:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/MMscf Waste
Gas Combusted
Source
PMto
7.6
AP -42 Table 1.4-2
PMz.5
7.6
AP -42 Table 1.4-2
SOx
0.6
AP -42 Table 1.4-2
NOx
365.0
TNRCC Flare Emissions
Guidance
CO
728,7
Note: Actual emissions of the pollutants in the table above can be either calculated by: "
• assuming an actual vented volume of 58.91 MMscf/yr (the maximum capacity of the enclosed flare), or
• multiplying the emission factors in the table above by the waste gas flow from the condenser overheads stream in
the monthly GlyCalc report and by the hours per month the waste gas was routed to this control device.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN shall be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.``
7) This permit fulfills the requirement to hold a valid permit reflecting the glycol dehydration unit
and associated control device per the Colorado Oil and Gas Conservation Commission rule
805b(2)(B) when applicable.
8) This facility is classified as follows:
Applicable Requirement
Status
Operating Permit
Major Source of: VOC, NOx
Synthetic Minor Source of: HAPs (formaldehyde, benzene,
toluene, and total)
NANSR
Major Stationary Source of: VOC, NOx
MACT HH
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:
Page 15 of 16
COLORADO
Air Pollution Control Division
Department of Public Health b Env onment
Dedicated to protecting and improving the health and environment of the people of Colorado
http://www.ecfr.gov/
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
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 16 of 16
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
For Division Use Only
Review Engineer:
Package #:
Received Date:
Review Start Date:
Andy Gruel
430344
74/2020
21/9/2020 r
Section 01- Facility Information
Company Name: Aka Energy Group, LLC
County AIRS ID: 123
Plant AIRS ID: 0473
Facility Name: Kersey Compressor Station
Physical
Address/Location:
County:
Type of Facility: s Compressoqd,tion
What industry segment Alit& Natural Gas Produced &Processing •
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? Ozone (Mix& )
Weld County
Section 02 - Emissions Units In Permit Application
Leave Blank - For Division Use Only
AIRS Point #
(Leave blank unless
APCD has already
assigned)
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
(Leave blank unless
APCD has already
assigned)
Issuance
#
Self Cert
Required?
Action
Engineering
Remarks
017
Detsydt^afipr ,
Yes
20WEOS32
Pernmi..nitsof
issearc� -(
Quadrant
Section
Township
Range
Section 03 - Description of Project
Applicant requests a permit for a new TEG dehydration unit (SO MMSCFD) at an existing compressor station in the ozone nonattainment area of =Weld County.
As of the time of application receipt, the facility -Jas Title V Major for VOC and NOx, and a "major stationary source" under NANSR for VOC and 120x. This
project to add TEG dehydration increases the PTE of VOC by 11.84 tpy and the PTE of NOx by 7.1 toy. The emissions increase is under the "significant emission
rate" of 40 tpy for each of the two pollutants, and so this project is considered a "minor modification at a major stationary source."
Sections 04, 05 &
06 - For Division Use Only
Section 04- Public Comment Requirements
Is Public Comment Required?
Yes --
If yes,why? .Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requiremer
Was a quantitative modeling analysis required? Na
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
No
Is this stationary source a synthetic minor?
Pes' °,'.°.
..
If yes, indicate programs and which pollutants: SO2
NOx CO
VOC
PM2.5 PM10 TSP
HAPs
Prevention of Significant Deterioration (PSD) ❑
❑ 0
❑
❑
❑
Title V Operating Permits (OP) ❑
❑ I]
❑
❑
❑ ❑
0
Non -Attainment New Source Review (NANSR)
❑
❑
Is this stationary source a major source?
Yes
If yes, indicate programs and which pollutants: SO2
NOx CO
VOC
PM2.5 PM10 TSP
HAPs
Prevention of Significant Deterioration (PSD) ❑
❑ ❑
❑
❑
❑
Title V Operating Permits (OP) ❑
0 ❑
0
❑
000
Non -Attainment New Source Review (NANSR)
❑i
❑'
Glycol Dehydrator Emissions Inventory
Section 01 -Administrative Information
'Facility AIRS ID:
123
County
Plant
017
Point
Section 02- Equipment Description Details
Dehydrator Information
Dehydrator Type:
Make:
Model:
Serial Number:
Design Capacity:
Redreulation Pump Information
Number of Pumps
Pump Type
Make:
Model:
Design/Max Recirculation Rate:
Dehydrator Equipment
Flash Tank
Reboiler Bumer
Stripping Gas
Dehydrator Equipment Description
Emission Control Device Description:
MMscf/day
„gallons/minute
flash tank,
and reboiler burner
o eieisnint a _Nage s r� :007.,7. ... .. aai.-«_so acvc:Tl at li d}ga:;c� E
0:000 avtd .- ead mot:n•,�'_
.. _. tanten tosnt: e..: —.inner d m_ e . .: e -..:. �. r.:l a. °. e.. _. .. � a 00•0 0 ,. e
J"nJ3nannt Baia tiowe:reo..ss.,.r≤from the'la,rmnii :et
muted di-act:y-o the' au :r gv-+���� +0 000 _.-,> a,ecnrndary u,nn'eijtona_ Oath tan+_..
rooted to mediated :am ti,ntere
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Dehydrator Still Vent and Flash Tank (If present)
Requested Permit Limit Throughput=
Potential to Emit (PTE) Throughput= 13.230 MMscf per year
1$,250:0 MMsd per year
Requested Monthly Throughput= :
MMscf per month
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Still Vent Control
Condenser:
Condenser emission reduction claimed:
Primary control device:
Primary control device operation:
Secondary control device:
Secondary control device operation:
Still Vent Gas Heating Value:
Still Vent Waste Gas Vent Rate:
Flash tank Control
Primary control device:
Primary control device operation:
Secondary control device:
Secondary control device operation:
Flash Tank Gas Heating Value
Flash Tank Waste Gas Vent Rate:
Requested Condenser Outlet Temperature:
- ;"$5% Control Efficiency%
hr/yr Requested TO Temp
�'deNfr . 100% Control Efficiency%
hr/yr
2645 Btu/scf
scfh
Section 04 - Emissions Factors & Methodologies
hr/yr
hr/yr
2645 Btu/scf
scfh
Dehydrator
Thesource used. GM Glycale 4,0 to estimate emissions. Wet gas conmosition, pressor
anelwfscailected 3/3/2020, Controlled Efts assume a 95°%control of both stilt vent a;
m xm:am burner rating of 11.7 MMBM/hrand. ges heat content of 264S Stu/sc;;tad
ECD burner rating:
Assumed gas heat content:
Maximum waste gas to ECD:
Input Parameters
Inlet Gas Pressure
Inlet Gas Temperature
Requested Glycol Recirculate Rate
11.05 MMBtu/hr
2645 Btu/scf
.. . MMscf/yr
1275
120
10.43
psig
deg F
gpm
95% Control Efficiency %
Control Efficiency %
Degrees F
Degrees F
d temperature are based on a sne-spectfic extended wet gas
.ash tank emissions. Combustion emissions are assumed at the
are both coriarysiative. „
maximum burner rating, pins 095 MMBtu/hr for pilot
from 4/10/2019 gas analysis
used for NOx/CO/PM/S03 emir -ion salt
STILL VENT
Control Scenario
Primary
Secondary
Pollutant
Uncontrolled(Ib/hr)
Controlled(Ib/hr)
Controlled (lb/hr)
VOC
23.9222
_
0
Benzene
5.5082
Toluene
5.39
0..1-6,15
Ethylbenzene
0.1145
0.0.,5.7.-
Xylenes
1.7522
00,61
n -Hexane
0:5151
J.0?575:
_
224-TMP
- ' 0.0005
0.000025
J
FLASH TANK
Control Scenario
Primary
Secondary
Pollutant Uncontrolled(Ib/hr)
Controlled(Ib/hr)
Controlled(Ilo/hr)
VOC
30.1296
L316=o
a
Benzene
0.3207
0.01500-5
Toluene
0:21B6
0.01093
0
Ethylbenzene
- 0.003
0.0000'1
Xylenes
0.0311
0.001355
,
n -Hexane
0.7302
003631
..
224-TMP
0-0007
0.000035
3
Emission Factors
Pollutant
(Dry Gas Throughput)
VOC
:5.94
Benzene
Toluene
2,._-2)2
Ohylbenzene
0 05632
0.5-559&4
0.59'734
'u.*00575
Xylene
n-Hagene
224TMP
Dry Gas Throughput:
Still Vent Primary Control: 10.2, 13 MMscf/yr 1.530 MMscf/month
Still Vent Secondary Control: 0.0 MMscf/yr
Waste Gas Combusted:
Still Vent Primary Control: tl.J MMscf/yr 0,0 MMscf/month
Still Vent Secondary Control: J.J MMscf/yr
Dry Gas Throughput:
Flash Tank Primary Control: 1?,?n'.: MM. -VW
Flash Tank Secondary Control: 0 J MMscf/yr
Waste Gas combusted:
Flash Tank Primary Control: . aMMscf/yr
Flash Tank Secondary Control: MMscf/yr
Glycol Dehydrator Erntssions Inventory
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (Ib/MMsd)
(Waste Heat
Combusted)
(Waste Gas
Combusted)
PM10
.
7 fi
r T`AN42Table yq-2{Pa430/PM 7 S) '
"`X �� '�� yt2 Tabliq, lA�3sd d10)PM 25k F`n`
h t.. „-AP32 Teble � (Sot) f 4'
? _ TNRCCfIare EmisslontGolderloe(NCh.)_,,,.- v
'r .:YNRCC Flare Emr;srons`Gxdan'ce(C0),e' -'
PM25
r
76
9Dx
0 6
NOx
01380
3650
CO
02755
7297
Section 05 Emissions Inventory
Did operator request a buffer?
Requested Buffer (%)
Criteria Pollutants
Potential to Emit
Uncontrolled
Actual Emissions
Uncontrolled Controlled
Requested Permit Limits
Uncontrolled Controlled
Requested Monthly
Limits
Controlled
(tons/year)
(tons/yearl (tons/year)
(tons/yearl (tons/year)
(Ibs/month)
PM10
01
01
01
0 49
01,9
25
PM25
0 1
0 1
0.
0 a43
0 149
'S
Sox
00
00
_ 00
0012
0012
2
IIOx
71
]1
].
710
]10
1.06 _
i VOC
2367
2367
118
2,675
1184
1011
CO
112
142
141
1418
1418
7408
Potential to Emit
Actual Emissions
Requested Permit Limits
Hazardous AU Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
fibs/year)
(Ibs/year) (Ibs/year)
(Ibs/year) (Ibs/year)
Benzene
Toluene
>1061
51061
255,
5..061
25x3
..9151
49131
245
49131
24a7
Ethylbenzene
1064
1061
_ .s3
1064
53
Xylene
15012
1567.
781
1'5021
781
n Hexane
224 TMP
10509
10909
545
'C^09
S..5
>i
zl
11
1
..1
Section 06 Regulatuy Summary Analysis
Regulation Parts B
Regulation 7 Part D Section II B & II D
Regulation 7, Part D Section 11 B 2 e
Regulation 7 Part D Section I H
Regulations Part MACF Subpart HH(Area)
Regulations Part MAR Subpart HH(Malor)
Regulations Part MAR Subpart HHH
(See regulatory applicability worksheet for detailed analysis)
So_rc. require a nerrd
Jxh d-ator is sub ct to P eulation 7 Part D Section it B D 3
`ise control d vice for tnls dehydrator is rat subiect to Re u than 7 Part D - than II 91 e
De ydratar IS ubler o Regulation 7 ?..rt D Section I H
Den/ Is sublet, to arm c. MACF Hi" per th renuhrements in*3764(dl/2)
You ha, Indlcetad tha this facility is no-smmo to for Source requirement of NIACT HN
Yoa has.. indlmtcd b this facility is not si hiect to MACT hEIH
Section 07 Initial and Periodic Sampling and Testing Requirements
Was the extended wet gas sample used In the GlyCalc model/Process model hte specific and collected within a year of ,77,1_17,77
application submittal? Yee S H-... .1
lino the permit will contain an Initial Compliance testing requirement to demonstrate compliance with emission limits
Does the company request a control device efficiency greater than 954 for a flare or combustion device?
If yes the permit will contain initial and periodic compliance testing in accordance with PS Memo 2002
H the company has requested a control device effidenry greater than 95% is a thermal oxidizer or regenerative thermal oxidizer being used to achieve it?
No
If yes the permit win contain an Initial Compliance stack testing requirement AND the permit will contain a condition speofying the minimum combustion chamber temperature for the thermal oxidizer based on
the O&M plan and application Once a stack test is approved by the division the minimum combustion chamber temperature will he based on the mast recent stack tert results
Is the company using athermal oxidizer AND requesting a minimum combustion chamber temperature lower than 1400 degrees F? NZ:Lk
dyes the permit win contain an Initial Compliance testing requirement AND a permit condition spedfymg the minimum combustion chamber temperature for the therm!
oxidizer based on the O&M plan and application Once a stack test is approved by the division the minimum combustion chamber temperature will be based on the most recent
stack test results
Section 08 Technlul Analysis Notes a _
Applicant modeled flash tank and regenerator vent emissions using GLYCaIc Flash tank emissions will be recovered using a vapor recovery unit Re„enerator vent
emissions nail be -sent to a condenser and emissions from the condenser vent will then be sent to a combustion device at959' control (Flash tank s
o emissions are sent to the Paola, Inlet using a dosed loop system when the VRU Is down condenser vert emissions are sent to the VRU when the
combustion device its down) The applicant assumed that 954, of combined VOC and HAP emissions are controlled The permit will con aln requirements to adequatelf demonstrate actual emissions
r a
Section 09 SCC Cosine and Emissions Factors (For Inventory Use Only)
AIRS Point R
017
Process SCC Code
01 ra7004,01iOlycO detjirdrator's—redo c ll'vonB trletlytgne glyco
Pollutant
PM10
PM25
SOx
NOa
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n Hexane
224 TMP
Uncontrolled
Emissions Factor Control %
0 016 0 0
0 016
0 001
0 778
25 9
1 »4
2 798
? 69,
0 058
0 856
0>99
0 001
00
00
00
95 0
00
95 0
95 0
95 0
95 0
95 0
950
Units
b/MMsd
b/MMscf
b/MMsd
b/MMsd
b/MMsd
b/MMsd
b/MMscf
b/MMsd
b/MMsd
b/MMsd
b/MMsd
b/MMsd
(
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Aka Energy Group, LLC
123
0473
Kersey Compressor Station
History File Edit Date
11/19/2020
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons per year
EMISSIONS With Controls (tons Der year
POINT
AIRS
ID
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
S02
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
4.0
4.0
0.0
0.2
159.6
183.8
0.1
353.1
47.9
4.0
4.0
0.0
0.2
56.9
74.0
0.1
62.1
11.1 _
Previous taken from Sept 2019 tab
Previous Permitted Facility total
3.9
3.9
0.0
0.2
157.7
183.6
0.0
351.5
47.7
3.9
3.9
0.0
0.2
55.0
73.9
0.0
60.5
10.9
041
95WE175.1.CN
RICE Ajax DPC380 346 HP (SN: 77355)
Y
0.0.
_
- .
.. -
0,0
Cancellation received 07130/2004
002
sevvei75-2.CN
RECE Ajax 'DP0380346 HP (SN: 79838)
.-.._:
-
- -
-.
-,
0.0
-- -
-_
..
-..
OA
Cancellation received 07/30/2004
003
95WE175-3.CN
Glycol Dehydrator
-
0.0
-
0.0
Cancellation request received 05/08/2003.
004
GPOB
Two (2) 300 barrel fixed roof stabilized
condensate storage vessels
42.1
1.9
5.9
-
0.1
No change
005
GP02
RICE Waukesha F3524G51 4SRB 787 HP
0.5
0.5
0.0
110.3
3.4
83.7
0.7
0.5
0.5
0.0
7.6
3.4
7.6
0.4
No change
00e
00WE0010.CN:
-
RICE Caterpillar G342TA288HP4SR6
IUrbocharged (SN: 71B3001)
-
_ -
'.
o.0
Point Candelled- Cancellation request received
07/28/2014. Source no longer exists at the facility.
007
GP02
RICE Caterpillar G3516B 4SLB 1380 HP
turbocharged (SN: JEF02880)
0.5
0.5
0.0
6.7
14.8
38.2
7.0
0.5
0.5
0.0
6.7
7.4
9.5
1.5
No change
008
GP02
RICE Caterpillar G3516B 4SLB 1380 HP
turbocharged (SN: JEF02889)
0.5
0.5
0.0
6.7
14.8
38.2
7.0
0.5
0.5
0.0
6.7
7.4
9.5
1.5
No change
009
GP02
RICE Caterpillar G35768 4SLB 1380 HP
turbocharged (SN: JEF02875)
0.5
0.5
0.0
6.7
14.8
38.2
7.0
0.5
0.5
0.0
6.7
7.4
9.5
1.5
No change
010
GP02
RICE Caterpillar G35168 4SLB 1380 HP
turbocharged (SN: JEF03273)
0.5
0.5
0.0
6.7
14.8
38.2
7.0
0.5
0.5
0.0
6.7
7.4
9.5
1.5
No change
011
GP02
RICE Caterpillar G3516B 4SLB 1380 HP
turbocharged (SN: JEF03260)
0.5
0.5
0.0
6.7
14.8
38.2
7.0
0.5
0.5
0.0
6.7
7.4
9.5
1.5
No change
012
GP07
Hydrocarbon Loadout
5.7
0.1
10.0
0.1
No change
013
GP02
RICE caterpillar Gee AL 4SLB 1438 '
rP
�
-
-
"-
0.0
--
....
0.0
_...
Cancellation request received 11/01/2017,
014
GP02 .;RICE
Caterpillar f7.1606TALE 4SLle 1498
.>_.
,__
-._
,-.�,..
_.
.;.00
,_- ,..._..-
,..
_.....
,.-.
- ...,0.0
Cancellation- request received 11101/2017, -..
015
GP02
RICE- Caterpillar G3606TALE 4SLB 1438
HP (site rated) turbocharged (SN:
4ZS01186)
0.4
0.4
0.0
6.9
29.2
38.4
5.1
0.4
0.4
0.0
6.9
8.8
2.7
1.5
No change
016
GP02
RICE- Caterpillar G3606TALE 4SLB 1438
HP (site rated) turbocharged (SN:
4ZS02065)
0.4
0.4
0.0
6.9
29.2
38.4
5.1
0.4
0.4
0.0
6.9
8.8
2.7
1.5
No change
017
20WE0531
TEG dehy, 50 MMscf/d
0.1
0.1
0.0
7.1
263.8
14.2
63.9
0.1
O.
0.0
7.1
11.8
14.2
3.2
May 2020: new point
XA
TEG Reboiler '
0.1
0.1
0.0
0.9
0.1
0.8
0.1
0.1
O.
0.0
0.9
0,1
0.8
0.1
APEN Exempt/Insignificant Source
XA
Tank Heater
0.0
0.0
0:0
0,5
0.0
0.4
0.1
0.0
0.0
0.0
0.5
0.0
0.4
0.1
APEN Exempt/Insignificant Source
XA
Tank Heater
0.0
0.0
0.0
0.5
0.0
0.4
0.1
0.0
0.0
0.0
0.5
0.0 '
0.4
0.1
APEN Exempt/Insignificant Source
XA
Water Tank
0.0
0.0
0.0
0.0
APEN Exempt/Insignificant Source
XA
Water Loadout
0.0
0.0
0.0
0.0
APEN Exempt/Insignificant Source
XA
Fugitives
0.1
0.0
0.1
0.0
APEN Exempt/Insignificant Source
0.0
0.0
0.0
0.0
FACILITY TOTAL
4.2
4.2
0.0
0.3
166.7
447.5
0.1
367.2
111.8
4.2
4.2
0.0
0.3
64.0
85.9
0.1
76.3
14.3
VOC: Major (NANSR and OP)
NOx: Major (NANSR and OP)
CO: Syn Minor (PSD and OP)
HAPS: Syn Minor HCHO, B, T, and Total
HH: Area source requirements applicable
7777: Syn Minor (Area source)
Permitted Facility Total
4.0
4.0
0.0
0.2
164.8
447.4
0.0
365.6
111.6
4.0
4.0
0.0
0.2
62.1
85.8
0.0
74.7
14.1
Excludes units exempt from pennits/APENs
(0) Cha ge in Permitted Emissions
0.1
0.1
0.0
0.0
7.1
11.8
0.0
14.2
Pubecm required foi 20WE0531 -- need federally
enforceable limits on emissions to avoid NANSR
significant emission rate.
Note 1
Total VOC Facility Emissions (point and fugitive)
J (�) Change in Total Pe miffed VOC emissions (point and fug five)
86:0
Facility is eligible for GP02 because < 90 tpy
Project emissions less than 25 tpy
11.8
I
May 2020: added new permit 201/VE0531 to point 017. No change to other points. This is a "minor modification" at a major stationary source for NANSR (VOC and NOx, both increase under 40 tpy).
Note 2
Page 4 of 8
Printed 11/19/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Aka Energy Group, LLC
County AIRS 10 123
Plant AIRS ID 0473
Facility Name Kersey Compressor Station
Emissions - uncontrolled ( bs per year
POINT PERMIT Description
rormaidehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL
(tPY)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
009
95WE175-1,CN
RICE Ajax DPC360 30 HP (SN:
77355)
0:0
002
95WE175-2:CN
RICE Ajax DPC360346HP,(SN:
79338)
0:0
003 .96WE175-3,CN
Glycol Dehydrator
0.0
004
GP08
Two (2) 300 barrel fixed roof
stabilized condensate storage
vessels
851
723
.5
382
1872
1.9
005
GP02
RICE Waukesha F3524GSI 4SRB
787 HP (SN: C-14999/1)
761
148
'139
84
30
10
162
0.7
006
09WE0010:CN
RICE CaterpillarG342TA 288 HP
4SRB turbocharged (SN: 7163001)
0.0
007
GP02
RICE Caterpillar G35166 4SLB 1380
HP turbocharged (SN: JEF02880)
11472.2
752.9
462.9
11/.1
733
3.6
24.6
100
225.2
22.5
7.0
008
GP02
RICE Caterpillar G3516B 4SLB 1380
HP turbocharged (SN: JEF02889)
11472 2
752.9
462.9
117.'1
733
3.6
24.6
100
225.2
22.5
7.0
009
GP02
RICE Caterpillar G35168 4SLB 1380
HP turbocharged (SN: JEF02875)
11472.2
752.9
462.9
117.1
733
3.6
24.6
100
225.2
22.5
7.0
010
GP02
RICE Caterpillar G35168 4SLB 1380
HP turbocharged (SN: JEF03273)
11472.2
752.9
462.9
117.1
733
35
24.6
100
225.2
22,5
7.0
011
GP02
RICE Caterpillar G35168 4SLB 1380
HP turbocharged (SN: JEF03260)
11472.2
752.9
462.9
117,'I
733
3.6
24.6
100
225.2
22.5
7.0
012
GP07
Hydrocarbon Loadout
20
'175
0.1
013
GP02
RICE Caterpillar G3606TALE 4SLB
1438 HP {site rated) turbocharged
(SN.4ZS01559)
0.0
014
GP02
RICE.Caterplllar G3606TALE 4SLB
1438 HP (site rated) turbocharged
(SW 4ZS01593)
0.0
015
GP02
RICE - Caterpillar G3606TALE 4SLB
1438 HP (site rated) turbocharged
(SN:4ZS01186)
7788
744
458
116
725
4
24
99
223
22
5.1
016
GP02
RICE - Caterpillar G3606TALE 4SLB
1438 HP (site rated) turbocharged
(SN:4ZS02065)
7788
744
458
116
725
4
24
99
223
22
5.1
017
20WE0531
TEG dehy, 50 MMscf/d
51061
49131
1064
15622
10909
11
63.9
XA
TEG Reboiler
15
13
13
18
37
23
31
17
50
0.1
XA
Tank Heater
7
6
7
d
'19
12
15
8
25
0.1
XA
Tank Heater
7
8
7
9
19
'12
15
8
A2`'i
0.1
XA
Water Tank
0.0
XA
Water Loadout
0.0
XA
Fugitives
5
'10
0.0
0.0
5
20W E0531.CP1
11/19/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Aka Energy Group, LLC
County AIRS ID 123
Plant AIRS ID 0473
Facility Name Kersey Compressor Station
TOTAL (tpy)
36.9
2.7
1.7
26.4
27.5
0.6
5.1
6.9
0.9
0.1
0.0
0.0
111.8
*Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions de minimus
6
20 W E0531. CP1 - 11/19/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY- HAPs
Company Name Aka Energy Group, LLC
County AIRS ID 123
Plant AIRS ID 0473
Facility Name Kersey Compressor Station
Emissions with controls (Ibs per year
POINT PERMIT Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL
(tPY)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
95WE175-1.CN
RICE Ajax DPC360 346 HP (SN:
77355)
0.0
002
95WE175-2.CN
RICE Ajax DPC360 346 HP (SN:
79338)
0.0
003
95WE175-3.CN
Glycol Dehydrator
0.0
004
GP08
Two (2) 300 barrel fixed roof
stabilized condensate storage
vessels
43
36
0.2
19
94
0.1
005
GP02
RICE Waukesha F3524GSI 4SRB
787 HP (SN: C-14999/1)
190
148
139
84
30
1
10
162
0.4
006
09WEOOtO.CN
RICE Caterpillar G342TA 288 HP
4SRB turbocharged (SN: 7163001)
0.0
007
GP02
RICE Caterpillar G3516B 4SLB 1380
HP turbocharged (SN: JEF02880)
1721
376.5
231.5
58.5
367
2
12
50
112.6
11.2
1.5
008
GP02
RICE Caterpillar G3516B 4SLB 1380
HP turbocharged (SN: JEF02889)
1721
376.5
231.5
58.5
367
2
12
50
112.6
'11.2
1.5
009
GP02
RICE Caterpillar G3516B 4SLB 1380
HP turbocharged (SN: JEF02875)
1721
376.5
231.5
58.5
367
2
12
50
112.6
11.2
1.5
010
GP02
RICE Caterpillar G3516B 4SLB 1380
HP turbocharged (SN: JEF03273)
1721
376.5
231.5
58.5
367
2
'12
50
112.6
11.2
1.5
011
GP02
RICE Caterpillar G3516B 4SLB 1380
HP turbocharged (SN: JEF03260)
1721
376.5
231.5
58.5
367
2
'12
50
'112.6
11.2
1.5
012
GP07
Hydrocarbon Loadout
20
175
0.1
013
GP02
RICE Caterpillar G3606TALE 4SLB
1438 HP (site rated) turbocharged
(SN:4ZS01559)
0,0
014
GP02
RICE Caterpillar G3606TALE 4SLB
1438 HP (site rated) turbocharged
(SN:4ZS01593)
0.0
015
GP02
RICE - Caterpillar G3606TALE 4SLB
1438 HP (site rated) turbocharged
(SN:4ZS01186)
1558
424
261
66
413
2
'14
56
127
'13
1.5
016
GP02
RICE - Caterpillar G3606TALE 4SLB
1438 HP (site rated) turbocharged
(SN:4ZS02065)
1558
424
261
66
413
2
14
56
127
13
1.5
017
2DWE0531
TEG dehy, 50 MMscf/d
2553
2457
53
781
545
1
3.2
XA
TEG Reboiler
15
13
13
18
37
23
31
17
50
0.1
XA
Tank Heater
7
6
7
9
19
12
15
8
25
0.1
XA
Tank Heater
r
6
7
9
19
12
15
8
25
0.1
XA
Water Tank
0.0
XA
Water Loadout
0.0
XA
Fugitives
3
5
10
5
0.0
7
20W E0531.CP1
11/19/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Aka Energy Group, LLC
County AIRS ID 123
Plant AIRS ID 0473
Facility Name Kersey Compressor Station
0.0
TOTAL (tpy)
6.0
1.5
0.9
1.6
2.6
0.1
0.5
0.6
0.5
0.1
0.0
0.0
14.3
8
20WE0531.CP1 - 11/19/2020
Glycol Dehydration Unit APEN
Form APCD-202
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 glycol dehydration (dehy) units only. 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: 110 W E- 0 6 t 1
AIRS ID Number: 123 /0473 / (In
Section 1 - Administrative Information
Company Name': Aka Energy Group, LLC
Site Name: Kersey Compressor Station
Site Location: 25630 Weld County Road 55
Mailing Address:
(Include Zip Code) 125 Mercado Street, Suite 201
Durango, CO 81301
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person:
Phone Number:
E -Mail Address2:
Graham Stahnke
(720) 946-0244
gstahnke@akaenergy.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.
130342
go
co�oR�oo
i bymmencol PuMrt
�Hmbt6Enr.mnn.cnt
Permit Number:
AIRS ID Number: 123 / 0473 /
APC,i) MRS
Section 2 - Requested Action
Q NEW permit OR newly -reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
❑ 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 £t Notes: R 9'3012KniMlimMajncivAVARkiNAletihgA lehi sdmt q►klc AGG
actual emissions estimated @ 5% downtime 11/19/20
per
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. attached
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: dehydration of natural gas
Company equipment Identification No. (optional):
For existing sources, operation began on:
April 1, 2015
For new or reconstructed sources, the projected start-up date is:
El 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?
(See APCD website for NAAQS nonattainment area boundary map)
Is this unit located at a stationary source that is considered a Major
Source of (HAP) Emissions?
days/week weeks/year
Yes ❑ No
❑ Yes No
email
2 ' e:co LORA.DO
aaaanmantof Pobnk
Honk, 4.1.vmrcmoni
Permit Number:
AIRS ID Number: 123 /0473 /
Section 4 - Dehydration Unit Equipment Information
Manufacturer:
Exterran
Dehydrator Serial Number: 12486
Model Number:
1 MMBtu/hr
Reboiler Rating: 1.0 MMBTU/hr
Glycol Used: ❑ Ethylene Glycol (EG) ❑ DiEthylene Glycol (DEG) ❑✓ TriEthylene Glycol (TEG)
Glycol Pump Drive: ❑r Electric ❑ Gas If Gas, injection pump ratio:
Pump Make and Model: Hydra -Cell D15X
Glycol Recirculation rate (gal/min):
Lean Glycol Water Content:
Max: 10.83
1.5 wt.%
Acfm/gpm
# of pumps: 2
Requested: 10.83
AG 11/10/20
per attached emails
Dehydrator Gas Throughput:
Design Capacity: 50 MMSCF/day
Requested5: 50- 1$25 MMSCF/year
Actual: 49 1825(kimSCF/year
Inlet Gas: Pressure: 1275 prig
Water Content: Wet Gas: lb/MMSCF
Flash Tank: Pressure: 38 psig
Cold Separator: Pressure: psig
Stripping Gas: (check one)
O None ❑ Flash Gas ❑ Dry Gas ❑ Nitrogen
Flow Rate:
scfm
Temperature:
CI Saturated
Temperature:
Temperature:
120 F
Dry gas: lb/MMSCF
160 F ❑ NA
'F NA
Additional Required Documentation:
❑r Attach a Process Flow Diagram (this item is not required for APEN updates)
Q Attach GRI-GLYCaIc 4.0 Input Report Ft Aggregate Report (or equivalent simulation report/test results)
Q Attach the extended gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
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.
3
IS
COLORADO
oeam�be.rcanub�z
Permit Number:
AIRS ID Number: 123 / 0473 /
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or 117M)
40.373228/ -104.543751
❑ 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 ip IVo.
i)ischarge Naught
Abave Grtund Ltvei
Temp.
t'F
Flow Rate
(AC
Velocity
(ft/sec)
ECD-6090
25
Indicate the direction of the stack outlet: (check one)
❑� Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
(] Circular Interior stack diameter (inches): 48
❑ Square/rectangle Interior stack width (inches):
❑ Other (describe):
Interior stack depth (inches):
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.
0 Condenser:
Used for control of: regenerator vent
Type: Make/Model: Jatco BTEX Eliminator/ Model 5-120 Duplex
Maximum Temp: F Average Temp: `F
Requested Control Efficiency: o %
Ej VRU:
Used for control of: flash tank, condenser vent (when combustion device is down)
Size: Make/Model:
Requested Control Efficiency: 95
VRU Downtime or Bypassed: 5 %
Rotorcomp Verdichted Model NK100-GAS
❑ Combustion
Device:
Used for control of: condenser vent
Rating: ti.7 MMBtu/hr
Type: enclosed Make/Model: Cimmaron 48'
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98 %
Minimum Temperature: 'F Waste Gas Heat Content: 2645 Btu/scf
Constant Pilot Light: Yes ❑ No � Pilot Burner Rating: 0.05 (max) MMBtu/hr
Closed Used for control of: flash tank (when VRU is down)
E] Loop Description:
System: System Downtime:
❑ Other:
Used for control of:
Description:
Requested Control Efficiency:
0
A co,rCOLORADO
4 j Ho ttle6 Er MPararc4m
Permit Number:
AIRS ID Number: 123 /0473 /
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑Q Yes ❑ No
If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Pollutant
Control Equipment Description
Collection Efficiency
(% of total emissions captured
by control equipment)
Control Efficiency
(96 reduction of captured
emissions)
PM
SO.
NO.
CO
VOC
VRU, condenser, combustor
100%
95%
HAPs
VRU, condenser, combustor
100%
95%
Other:
From what year is the following reported actual annual emissions data?
2020
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 -41,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled''
Emissionsb
(tans/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
7.6
lb/MMscf
AP -42
0.15
0.15
0.15
0.15
SOx
0,6
lb/NIMsef
AP -I2
0 01
0 01
0.01
0.01
NO.
0,138
lb/1IMBtu
-TNRCC
7.1
7.1
7.1
7.1
CO
0.2755
lb/iv(MBtu
TNRCC
14.2
1.1.2
14.2
14.2
VOC
25.94
Ib/MMSCF
calculated
224.91
11.25
236.75
11.84
5 Requested values will become permit (imitations 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.
AGG
11/19/20
per attached email
Section 8 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteriaEl Yes
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -41,
Mfg., etc:)
Uncontrolled
Emissions
(lbs/year)
Controlled
Emissionsb
(lbs/year)
Benzene
71432
2.80
Ib/MMSCF
calculated
48-508
7425 —
Toluene
108883
2.69
Ib/MMSCF
calculated
46,675
2.&34
Ethylbenzene
100414
583E-02
Ib/MMSCF
ealoulated
tact-
-5t
Xylene
1330207
0.85
Ib/MMSCF
calculated
14'840"
342—
n -Hexane
110543
0.93
Ib/MMSCF
calculated
—16.003
—803
2,2,4-Trimethy(pentane
540841
5.48E-04
Ib/MMSCF
calculated
-40-
-3-
Other:
❑ No
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
51061 2553
49131 2457
1064 53
15622 781
10909 545
11 1
AG 11/10/20
per attached
email
40, coLaaAoo
5 i ::�",
Permit Number:
AIRS ID Number: 123 /0473 /
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
Graham Stahnke
Digitally signed by Graham Stahnke
Date: 2020.05.01 10:45:31 -07'00'
5/1/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Graham Stahnke Senior Environmental Compliance Specialist
Name (print) Title
Check the appropriate box to request a copy of the:
1:1 Draft permit prior to issuance
E 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 Reguiation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to: For more information or assistance call:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
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
441A.coLopAao
6
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0Eeah4 S ERrim�mzn�
11/10/2020
State.co.us Executive Branch Mail - Kersey CS - TEG Dehy - 20WE0531, 123-0473-017
STATE OF
COLORADO
Gruel - CDPHE, Andrew <andrew.gruel@state.co.us>
Kersey CS - TEG Dehy - 20WE0531, 123-0473-017
Stahnke, Graham <gstahnke@akaenergy.com> Tue, Nov 10, 2020 at 10:47 AM
To: Andy Gruel - CDPHE <andrew.gruel@state.co.us>
Thanks Andy, yes please redline to match the 18,250 MMscf/yr.
Graham Stahnke, PE, CSP
Office: (720) 946-0244
Cell: (970) 759-5712
From: Andy Gruel - CDPHE <andrew.gruel@state.co.us>
Sent: Tuesday, November 10, 2020 10:42 AM
To: Stahnke, Graham <gstahnke@akaenergy.com>
Subject: Re: [EXTERNAL] Kersey CS - TEG Dehy - 20WE0531, 123-0473-017
One followup -- the APEN reports "actual" throughput of 49 MMscf/yr -- would you like to revise that as well at this
time? It could save you from filing another APEN on this next year.
Andy Gruel, P.E.
Oil and Gas Program
Colorado Air Pollution Control Division
(303) 692-3143 andrew.gruel@state.co.us
On Tue, Nov 10, 2020 at 7:44 AM Stahnke, Graham <gstahnke@akaenergy.com> wrote:
Hi Andy,
https://mail.google.com/mail/u/0?ik=9030c1528b&view=pt&search=all&permmsgid=msg-f%3A1682996452105730991 &dsgt=1 1/2
11/10/2020
State.co.us Executive Branch Mail - Kersey CS - TEG Dehy - 20WE0531, 123-0473-017
STATE OF
COLORADO
Gruel - CDPHE, Andrew <andrew.gruel@state.co.us>
Kersey CS - TEG Dehy - 20WE0531, 123-0473-017
Stahnke, Graham <gstahnke@akaenergy.com> Tue, Nov 10, 2020 at 7:43 AM
To: Andy Gruel - CDPHE <andrew.gruel@state.co.us>
Hi Andy,
Yes, it should be for 50 MMscf/d (18,250 MMscf/yr), thanks for catching that. Both of the CAT 3606 TALE
engines/compressor packages are operational at the facility.
Thanks,
Graham
From: Andy Gruel - CDPHE <andrew.gruel@state.co.us>
Sent: Monday, November 09, 2020 4:35 PM
To: Stahnke, Graham <gstahnke@akaenergy.com>
Subject: [EXTERNAL] Kersey CS - TEG Dehy - 20WE0531, 123-0473-017
Hi Graham,
I'm reviewing the permit application rec'd 5/4/20 for a TEG dehy (50 MMscfd) at Kersey CS.
In my initial review I have two preliminary questions:
1) The requested throughput on the APEN (see attached) is entered as 50 MMscf/yr, but I suspect that's a misentry. 50
MMscfd at 365 days is 18250 MMscf/yr -- if that's your requested amount please grant permission to redline the APEN.
2) The Form 102 (facility -wide table) in the permit application does not include points 015 and 016, which are both
Cat 3606TALE that are registered under GP02. What is the operating status of those engines?
Thank You,
Andy Gruel, P.E.
Permit Engineer
Oil and Gas Program
P 303.692.3143.
4300 Cherry Creek Drive South, Denver, CO 80246-1530
andrew.gruel@state.co.us I www.colorado.gov/cdphe/apcd
Are you curious about ground -level ozone in Colorado? Visit our ozone webpage to learn more.
APCD COVID-19 FAQ
https://mail.google.com/mai I/u/0?ik=9030c1528b&view=pt&search=al I&permmsg id=msg-f%3A1682984873167079475&dsqt=1
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