The URL can be used to link to this page

Browse Search

Home My WebLink About20203887.tiffCOLORADO Department of Public Health 8 Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 December 21, 2020 Dear Sir or Madam: RECEIVED DEC 2 8 2020 WELD COUNTY COMMISSIONERS On December 22, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for REP Processing, LLC - Severance 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 Jill Hunsaker Ryan, MPH, Executive Director PV b I ; G 2e c.) cc: ?aro, HL(Gsfro, pw(smiERA.H/c►o, o6@m) O t / 1 t /2 Olio$/2,t aiO2o-3337 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: REP Processing, LLC - Severance Compressor Station - Weld County Notice Period Begins: December 22, 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: REP Processing, LLC Facility: Severance Compressor Station Natural Gas Compressor Station NW SEC8 T7N R66W Weld County The proposed project or activity is as follows: Applicant proposes the modification of the points 002, 003, 004, 005, and 006 on construction permit 18WE1051. Modifications include an updated component count and emission factors for point 002, updated throughput and emission factors for points 003 and 004, and updated blowdown/venting volumes and permitted number of events for points 005 and 006 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 18WE1051 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: Ben Fischbach Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 1 COLORADO Department of Public Health @ Environment 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 Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE1051 Issuance: Facility Name: Plant AIRS ID: Physical Location: County: Description: REP Processing, LLC Severance Compressor Station 123/9FF6 NW SEC 8 T7N R66W Weld County Natural Gas Compressor Station Equipment or activity subject to this permit: 2 Equipment ID AIRS Point Equipment Description Emissions Control Description SK -4100 TEG 001 One (1) Triethylene glycol (TEG), natural gas dehydration unit (make: Black Gold Rush Industries, model: BP2MM28-24, SN: ON20028-15P) with a design capacity of 100 MMscf per day. This emissions unit is equipped with one (1) electric driven glycol pump with a design capacity of 25 gallons per minute (make: Rotor Tech, model: GS2212). This unit is equipped with a flash tank, reboiler and still vent. Stripping gas is injected into the still vent. Emissions from the still vent are routed to an air-cooled condenser and then to the enclosed combustion device. Emissions from the flash tank are routed recycled to the plant inlet. FUG -1 002 Fugitive equipment leaks from a natural gas compressor station V-7000 003 One (1) Low pressure separator Enclosed combustion device V-8100 004 One (1) Low pressure separator Enclosed combustion device BD -1 005 Natural gas venting from compressor blowdown events and Emergency Shutdown Events No control PG -1 006 Natural gas venting from pigging events No control Page 1 of 23 COLORADO Air Pollution Control Division [Department cl Public Health b Enwonment Dedicated to protecting and improving the health and environment of the people of Colorado 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. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. 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.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as 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.) 3. 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.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4. ) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO SK -4100 TEG 001 --- 4.1 21.3 8.2 Point FUG -1 002 --- --- 0.2 --- Fugitive Page 2 of 23 MlM�lu f{J// COLORADO Air Pollution Control Division Department of Public F{ealth 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado V-7000 003 --- 1.1 6.7 2.4 Point V-8100 004 --- --- 6.4 1.8 Point BD -1 005 --- --- 1.0 --- Point PG -1 006 --- --- 0.4 --- 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. Compliance with the annual limits must be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimus reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total must be calculated based on the previous twelve months' data. The permit holder must calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total must apply to all permitted emission units, requiring an APEN, at this facility. 6. 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. 7. Point 001: Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc 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, flash tank temperature and pressure, wet gas inlet temperature, and wet gas inlet pressure. Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into the model and be provided to the Division upon request. 8. Point 001: On a monthly basis, the owner or operator must monitor and record operational values including: flash tank temperature and pressure, wet gas inlet temperature and pressure. These records shall be maintained for a period of five years. 9. Point 002: The operator must calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas analysis, as required in the Compliance Testing and Sampling section of this permit. The operator must maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records must be provided to the Division upon request. Page 3 of 23 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 10. The owner or operator shall 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 SK -4100 TEG 001 Still Vent: Enclosed Flare VOC and HAP V 7000 003 Emissions from the separator(s) are routed to an Enclosed Flare VOC and HAP V 8100 004 Emissions from the separator(s) are routed to an Enclosed Flare VOC and HAP 11. The owner or operator shall operate and maintain the emission points in the table below as a closed loop system and shall recycle 100% of emissions as described in the table below. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Emissions Recycling Description Pollutants Recovered SK -4100 TEG 001 Flash Tank: Recycled to Plant Inlet VOC and HAP PROCESS LIMITATIONS AND RECORDS 12. 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 Process Parameter Annual Limit SK -4100 TEG 001 01 Dry Gas Throughput 36,500 MMscf V-7000 003 01 Natural Gas Venting 10.10 MMscf V-8100 004 01 Natural Gas Venting 6.70 MMscf BD -1 005 01 Compressor Blowdown Events 100 events Page 4 of 23 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 02 Emergency Shutdown Events 2 events 01 Pig Launching 52 events PG -1 006 02 Pig Receiving 52 events Note: 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. 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. 13. Point 001: This unit shall be limited to the maximum lean glycol circulation rate of 25 gallons per minute. The lean glycol recirculation rate shall be recorded weekly 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) 14. Point(s) 003, 004: The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The flow meter must be calibrated and maintained per the manufacturer's specifications and schedule. 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 15. Visible emissions must not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions must not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVI1.B.2.b must have no visible emissions. (Regulation No. 1, Section II.A.1. a 4.) 16. 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) 17. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) Page 5 of 23 COLORADO Air Pollution Control Division Department of Public Heatth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 18. This source is subject to Regulation No. 7, Part D, Section I.C General Provisions (State only enforceable). All condensate collection, storage, processing, and handling operations, regardless of size, shall be designed, operated, and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. The operator shall comply with all applicable requirements of Regulation No. 7, Part D, Section I. 19. Point 001: 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.) 20. Points 001, 003, Et 004: 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 schedule in Regulation Number 7, Part D, Section II.B.2.d. 21. Point 001: 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. 22. Point 001: 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) Page 6 of 23 .." a -ler-- 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 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 located in a UA plus offset and UC 563.761) shall comply with the provisions (d)(2(i) through (iii) of this section. 563.764 (d)(2)(i) - Determine the using the following equation: Lori. 1.15*3.0 gal TEG *(F* (1- O) of an area source not boundary (as defined in specified in paragraphs optimum glycol circulation rate 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) =1.15 1b H,0 - 24hrlday i Where: LOPT = Optimal circulation rate, F = Gas flowrate (MMSCF/D) = Inlet water content (lb/MMSCF) O = Outlet water content (lb/MMSCF) 3.0 = The industry accepted rule ratio (gal TEG/1bH20) 1.15 = Adjustment factor included 563.764 (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 sales 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 §63.775(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 Page 7 of 23 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 MACT HH Applicable Requirements Area Source Outside UA/UC boundary of this section and submit the information specified under 563.775(c)(7)(ii) through (v). §63.774 - Recordkeeping Requirements §63.774 (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 563.774 (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. 863.774 (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 563.764(d)(2)(i) or 563.764(d)(2)(ii), as applicable. §63.775 - Reporting Requirements §63.775 (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). Page 8 of 23 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 §63.775 (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 §63.9(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. §63.775 (c)(7) - The information listed in paragraphs (c)(1)(i) through (v) of this section. This information shall be submitted with the initial notification. §63.775 (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. §63.775 (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 Page 9 of 23 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 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: $63.775 (f)(1) - A brief description of the process change; 563.775 (f)(2) - A description of any modification to standard procedures or quality assurance procedures 563.775 (f)(3) - Revisions to any of the information reported in the original Notification of Compliance Status Report under paragraph (d) of this section; and 563.775 (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. 23. Point 002: The reciprocating compressors grouped with the ;fugitive emissions addressed by AIRS ID 002 are subject to the New Source Performance Standards requirements of `Regulation No. 6, Part A,Subpart OOOO, Standards` of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution including, but not limited to, the following: • 560.5385(a) Owner or operator must replace the reciprocating compressor rod packing according to either paragraph 560.5385(a)(1) or (2). (i) g60.5385(a)(1) - Before the compressor has operated for 26,000 hours. The number of hours of operation must be continuously monitored beginning upon initial startup of your reciprocating compressor affected facility, or October 15, 2012, or the date of the most recent reciprocating compressor rod packing replacement, whichever is later. (ii) 560.5385(a)(2) - Prior to 36 months from the date of the most recent rod packing replacement, or 36 months from the date of startup for a new reciprocating compressor for which the rod packing has not yet been replaced. • 560.5410 - Owner or operator must demonstrate initial compliance with the standards as detailed in 560.5410(c). • 560.5415 - Owner or operator must demonstrate continuous compliance with the standards as detailed in 560.5415(c). • 560.5420 - Owner or operator must comply with the notification, reporting, and recordkeeping requirements as specified in 560.5420(a), 560.5420(b)(1), 560.5420(b)(4), and 560.5420(c)(3). 24. Point 002: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). LDAR Page 10 of 23 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 Requirements as required by the following condition shall satisfy the requirement to apply Reasonably Available Control Technology (RACT). 25. Point 002: Fugitive component leaks at this natural gas compressor station are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re -monitoring, recordkeeping and reporting contained in Regulation 7, Part D, Section II.E. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Part D, Section 11.8.1. 26. 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 It MAINTENANCE REQUIREMENTS 27. Points 001, 003, a 004: Upon startup of these points, the owner: or operator shall follow the most recent operating and maintenance (0>:tM) 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 28. Point 001: The owner or operator shall complete the initial extended wet gas analysis within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit. The owner or operator shall use this analysis to calculate actual emissions, as prescribed in the Emission Limitation and Records section of this permit, to verify initial compliance with the emission limits. The owner or operator shall submit the analysis and the emission calculation results to the Division as part of the self -certification process. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). (Regulation Number 3, Part B, Section III.E.) Periodic Testing Requirements 29. Point(s) 001: The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, on a weekly basis 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 Page 11 of 23 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 minute in any fifteen minute period during normal operation. (Regulation Number 7, Part D, Sections II.B.2. and II.A.23) 30. Point 001: 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. If any site specific emissions factor developed through this analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 31. Point 002: On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. If any site specific emissions factor developed through this analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 32. Points 003 Et 004: On an annual basis, the owner/operator must complete a site specific extended gas analysis ("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be used to demonstrate that the emissions factor established through the Analysis is less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ADDITIONAL REQUIREMENTS 33. All previous versions of this permit are cancelled upon issuance of this permit. 34. 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: 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 Page 12 of 23 .410. COLORADO Air Pollution Control Division Department of Public Heatth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 35. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that t)lis source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 36. 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. 37. 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. Page 13 of 23 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 38. 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. 39. 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. 40. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 41. 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 ownermust notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 42. 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: DRAFT Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 June 19, 2019 Issued to REP Processing, LLC. Issuance 2 This Issuance Issued to REP Processing, LLC. Modification to point 002 to update component counts, emission factors, and permit limits. Page 14 of 23 a �r 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 Modification to points 003 and 004 to update emission factors, throughput, and permit limits. Modification to points 005 and 006 to update event volumes, emission factors, and annual permitted number of events. Page 15 of 23 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 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. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) SK -4100 TEG 001 Benzene 71432 77,918 3,896 Toluene 108883 91,779 4,589 Ethylbenzene 100414 8,438 422 Xylenes 1330207 49,199 2,460 n -Hexane 110543 48,748 2,437 2,2,4- Trimethylpentane 540841 60 3 FUG -1 002 Benzene 71432 2 2 Toluene 108883 6 6 Ethylbenzene 100414 2 2 Xylenes 1330207 9 9 n -Hexane 110543 46 46 2,2,4- Trimethylpentane 540841 0 0 Page 16 of 23 MRS10i 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 V-7000 003 Benzene 71432 450 22 Toluene 108883 722 36 Ethylbenzene 100414 82 4 Xylenes 1330207 167 8 n -Hexane 110543 5,601 280 2,2,4- Trimethylpentane 540841 143 7 V-8100 004 Benzene 71432 475 24 Toluene 108883 495 25 Ethylbenzene 100414 54 3 Xylenes 1330207 111 6 n -Hexane 110543 5,594 280 2,2,4- Trimethylpentane 540841 105 5 BD -1 005 Benzene 71432 2 2 Toluene 108883 2 2 Ethylbenzene 100414 <1 <1 Xylenes _ 1330207 1 1 n -Hexane 110543 8 8 2,2,4-540841 Trimethylpentane <1 <1 PG -1 006 Benzene 71432 2 2 Toluene 108883 4 4 Ethylbenzene 100414 1 1 Xylenes 1330207 2 2 n -Hexane 110543 34 34 2,2,4- Trimethylpentane 540841 <1 <1 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable 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: Point 001: The emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. Controlled emissions are based on an enclosed flare control efficiency of 95.0%. Total actual still vent combustion emissions are based on the emissions for the still vent primary control. Total combustion emissions are based on the following emission factors: Page 17 of 23 COLORADO Air Pollution Control Division Department cf Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Still Vent Primary Control: CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Waste Gas Combusted Source NOx 0.1380(lb/MMbtu) TNRCC CO 0.2775 (lb/MMbtu) TNRCC VOC 23.25 GlyCalc 71432 Benzene 2.13 GlyCalc 108883 Toluene 2.51 GlyCalc 100414 Ethylbenzene 0.23 GlyCalc 1330207 Xylenes 1.35 GlyCalc 110543 n -Hexane 1.34 GlyCalc Note: The combustion emissionfactors are based on a heating value of 1211 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the waste gas flow from the regenerator overheads stream in the monthly GlyCalc report and by the hours per month the waste gas was routed to this control device. Point 002: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 436 0 410 0 Flanges 637 0 170 0 Open-ended Lines 0 0 0 0 Pump Seals 2 0 9 0 Valves 444 0 170 0 Other* 20 0 10 0 VOC Content (wt. fraction) 0.2470 1.00 1.00 1.00 Benzene Content (wt. fraction) 0.0002 0.0 0.0054 0.0 Toluene Content (wt. fraction) 0.0002 0.0 0.0190 0.0 Ethylbenzene (wt. fraction) 4.75E-05 0.0 0.0054 0.0 Xylenes Content (wt. fraction) 9.50E-05 0.0 0.0254 0.0 n hexane Content (wt. fraction) 0.0021 0.0 0.1344 0.0 Page 18 of 23 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 2,2,4- Trimethylpentane (wt. fraction) 3.58E-05 0.0 0.0007 0.0 *Other equipment type includes compressors, pressure re ief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 1.0E-05 7.5E-06 9.7E-06 1.0E-05 Flanges 5.7E-06 3.9E-07 2.4E-06 2.9E-06 Open-ended Lines 1.5E-05 7.2E-06 1.4E-05 3.5E-06 Pump Seals 3.5E-04 --- 5.1E-04 2.4E-05 Valves 2.5E-05 8.4E-06 1.9E-05 9.7E-06 Other 1.2E-04 3.2E-05 1.1E-04 5.9E-05 Source: EPA -453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. As requested, light oil component counts shall include those in water/oil and in heavy oil service. Point 003: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 208.8 208.8 TNRCC CO 469.0 469.0 AP -42 VOC 26,716.4 1,335.82 Extended Gas Analysis 71432 Benzene 44.52 2.23 108883 Toluene 71.48 3.57 100414 Ethylbenzene 8.12 0.41 1330207 Xylenes 16.53 0.83 110543 n -Hexane 554.60 27.73 540841 2'2'4-14.16 Trimethylpentane 0.71 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. Page 19 of 23 Point 004: COLORADO Air Pollution Control Division Department of f'ubiic Heatth b Envtronment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source N0x 236.5 236.5 TNRCC CO 531.3 531.3 AP -42 V0C 38,164.2 1,908.21 Extended Gas Analysis 71432 Benzene 70.90 3.54 108883 Toluene 73.91 3.70 100414 Ethylbenzene 8.12 0.41 1330207 Xylenes 16.53 0.83 110543 n -Hexane 834.97 41.75 540841 2'2'4-15.67 Trimethylpentane 0.78 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. Point 005: Process 01: Natural Gas Vented From Compressor Blowdowns CAS # Pollutant Uncontrolled Emission Factors (lb/event) Source V0C 15.74 Extended Gas analysis/Engineering Calculation 71432 Benzene 1.30E-02 108883 Toluene 1.28E-02 100414 Ethylbenzene 3.00E-03 1330207 Xylenes 6.01E-03 110543 n -Hexane 6.32E-02 540841 2'2'4- Tnmethylpentane 2.26E-03 Point 005: Process 02: Natural Gas Vented During Emergency Shutdown Events CAS # Pollutant Uncontrolled Emission Factors (lb/event) Source V0C 161.39 Extended Gas Analysis/Engineering Calculation 71432 Benzene 1.34E-01 108883 Toluene 1.31E-01 100414 Ethylbenzene 3.08E-02 1330207 Xylenes 6.16E-02 Page 20 of 23 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 CAS # Pollutant Uncontrolled Emission Factors (lb/event) Source 110543 n -Hexane 6.48E-01 540841 2'2'4-2.32E-02 Trimethylpentane Point 006: Process 01: Natural Gas Vented During Pig Launching Operations. CAS # Pollutant Uncontrolled Emission Factors (lb/event) Source VOC 1.69 Extended Gas analysis/Engineering Calculation 71432 Benzene 5.79E-03 108883 Toluene 1.03E-02 100414 Ethylbenzene 2.57E-03 1330207 Xylenes 5.14E-03 110543 n -Hexane 8.36E-02 540841 2'2'4-2.30E-04 Trimethylpentane Point 006: Process 02: Natural Gas Vented During Pig Receiving Operations. CAS # Pollutant Uncontrolled Emission Factors (lb/event) Source VOC 4.98 Extended Gas Analysis/Engineering Calculation 71432 Benzene 1.70E-02 108883 Toluene 3.03E-02 100414 Ethylbenzene 7.57E-03 1330207 Xylenes 1.51E-02 110543 n -Hexane 2.46E-01 540841 2'2'4-6.77E-04 Trimethylpentane 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 Page 21 of 23 r�Yr COLORADO Air Pollution Control Division Department of Public Health fr Envtronment Dedicated to protecting and improving the health and environment of the people of Colorado 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) Point 002: This source is subject to 40 CFR, Part 60, Subpart OOOOa—Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 02, 2016). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: https://www.gpo.gov/fdsys/pkg/FR-2016-06-03/pdf/2016-11971.pdf 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, Benzene, Toluene, Xylenes, n -Hexane, Total HAP NANSR Synthetic Minor Source of: VOC, NOx PSD Synthetic Minor Source of: VOC, NOx, CO MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Applicable NSPS KKK '' Not Applicable NSPS OOOO Applicable 10) 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.gov/ Page 22 of 23 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 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 23 of 23 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Ben Fischbach Package it: 421049 Received Date: 10/22/2029 Review Start Date: 6/26/2020 Section 01- Facility Information Company Name:- REP Processing, LLC County AIRS 10: 123 Plant AIRS ID: 9FFB Facility Name: Severance Compressor Station Physical Address/Location , County: Type of Facility: Natural Gas Compressor Station What industry segment? Oil & Natural Gas Production & Processing is this facility located in a NAAOS non -attainment area? If yes, for what pollutant? Weld County Section 02- Emissions Units In Permit Application Yes Ozone (NOs& VOC) Quadrant) Section I Township I Range NW N 66 AIRS Point a (Leave blank unless APED has already assigned( Emissions Source Tyne Equipment Name Emissions Control? Perini[ a (Leave blank unless APco has already assigned) 002 Fugitive Component Leaks FUG -1 No SSWE1051 ' 003 Separator Venting V-7000 Yes 004 Separator Venting V-8100 Yes 005 Maintenance Blowdowns BD -1 No 006 Maintenance Blowdowns PG -1 No 017 Dehydrator SK-4101TEG Regeneration Skid Yes 18WE1051.CN Section,03- Description of Project Leave Blank - For Division Use Only Issuepnc Self pert Required? Action Engineering Remarks 2 Ye Permit Modification Permit Modification Permit Modification Permit Modification Permit Modification Fugitive VOC missions are below APEN reporting threshold, though operator wishes to retain point on permit. NA Cancellation Per operator, cancellation for this point was submitted. 11/2/2020. JI _ Applicant proposes the modification of the construction permit 18WE1051. Modifications include: -Modifying point 002 to reflect an updated component count, and the new use of Table 2-8 "Less than 10,000ppmv" emissions factors. -Updating emission factors and throughput limits for points 003 and 004 (separator venting points), basedon updated gas samples and an ezceedance of permitted throughput. -Updated blowdown/vent volumes for points 005 and 006, and updated numbers for requested events. Application included an APEN for a neW TEG Dehydrator to be covered under point 017, though this point was cancelled during permitting service. Sections 04, OS & 06- For Division Use Only Section 04 -Public Comment Requiremen Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section OS - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Yes Section O6- Facility -Wide Statiosary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (P50) Title V Operating Permits (OP) Non -Attainment New Source RevEw (NANSR) Is this stationary source a major source? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (P5D) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) N 502 NOz CO VOC PM2.5 PM10 TSP HAPs No _... CO VOC PM2.5 PM10 TSP HAPs 502 NOx I Colorado Department of Public Health Environment Air Pollution Control Division Operation (hrs/yr) 8760 SCC Code: 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Fugitive Component Counts & Emissions Prelir The default list of TOC emissions factors are based on Table 2-4 "Average Emissions Factors" of the EPA Protocal for Fugitive Equipment Leaks. If the company qualifies to use Table 2-8 "Less than 10,000 ppmv" emissions factors based on provisions of Regulation 7, Section XVII.F, you must update and manually enter the Table 2-8 emissions factors into column "E" below. Service Component Type Count TOC EF Iblhr- source TOC EF kg/fir-source Control (%) VOC Benzene Toluene Ethylbenzene Xylene n -Hexane 224 Uncontrolled (tpy) Controlled (tpy) Uncontrolled (Ib/yr)- Controlled (Iblyr) Uncontrolled (Ib/yr) Controlled (Ib/yr) Uncontrolled (Ib/yr) Controlled (Ib/yr) Uncontrolled (Ib/yr)- Controlled (Ib/yr) Uncontrolled ..(Ib/yr) Controlled (Ib/yr) Uncontrolled (Ib/yr) Controlle d(Ib/yr) 0.0 Gas Valves - 444 5.51E-05 2.50E-05 0.0% 0.03 0.0 0.1 0.1 0.1 0.1 0.0 0.0 0.0 0.0 2.4 2.4 0.0 Pump Seals 2 7.72E-04 3.50E-04 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.2 0.2 0.0 0.0 Others 20 2.65E-04 1.20E-04 0.0% 0.01 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 0.5 0.0 0.0 Connectors 436 2.20E-05 1.00E-05 0.0% 0.01 0.0 0.0 . 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.9 0.9 0.0 0.0 Flanges 637 1.26E-05 5.70E-06 0,0% 0.01 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.8 0.8 0.0 0.0 Open-ended lines 0 3.31E-05 1.50E-05 0.00 0,0 0.0 0,0 0.0 ' 0.0 0.0 0.0 0.0 0.0 - 0.0 0.0 0.0 0,0 Light Oil Valves 170 4.19E-05 1.90E-05 0.0% 0.03 0.0 0.3 0.3 1.2 1,2 0.3 0.3 1.6 1.6 8.4 8.4 0.0 0.0 Pump Seals 9 1.12E-03 5.10E-04 0.09/:i 0.04 0.0 0.5 0.5 1.7 1.7 0:5 0.5 2.3 2.3 11.9 11.9 0.1 0.1 Others 10 2.43E-04 1.10E-04 0.0% 0.01 0.0 0.1 0.1 0.4 0.4 0.1 0.1 0.5 0.5 2.9 2.9 0.0 0.0 • Connectors 410 2.14E-05 9.70E-06 0.0% 0.04 0.0 0.4 0.4 1.5 1.5 0.4 0.4 2.0 2.0 10.3 10.3 0.1 0.1 Flanges 170 5.29E-06 2.40E-06 0.0% 0.00 0.0 0.0 0.0 0.1 0.1 0.0 0.0 0.2 0.2 1.1 1.1 0.0 0.0 Open-ended lines 0 3.09E-05 ' 1.40E-05 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Heavy Oil Valves 0 1.85E-05 8.40E-06 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Pump Seals Vfi, eer,*.'::s,� ggf,a s'' a w ; ,,,,.S;: ^,rw ...T«.. w fi9.- �`` ;�,,. s• jo. U. ,,,,tuY; Others 0 7.05E-05 3.20E-05 0.0% 0.00 0.0 O0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Connectors 0 1.65E-05 7.50E-06 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Flanges 0 8.60E-07 3.90E-07 0.0% 0.00 0.0 D.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Open-ended lines 0 1.59E-05 7.20E-06 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Water/Oil Valves 0 2.14E-05 9.70E-06 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Pump Seals 0 5.29E-05 2.40E-05 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Others 0 1.30E-04 5.90E-05 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Connectors 0 2.20E-05 1.00E-05 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Flanges 0 6.39E-06 2.90E-06 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0,0 0.0 0.0 0.0 0,0 0.0 0.0 Open-ended lines 0 7.72E-06 3.50E-06 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTALS (tpy) r.1 r.1 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.02 0.02 0.00 0.00 TOTALS Ih With safety factor: .3 TOTALS (tpy) TOTALS lb 0,00 0.00 0:00 0.00 0.00 0.00 0.00 0.00 0.03 0.03 Emission Factor Source: Stream VOC Fraction (wt) Gas EPA -4531R-95-017, Table 2-8 0.2611 1.0000 1.0000 1.0000 Light Oil Heavy Oil Water/Oil Requlatory Considerations Reg. 3 Is this source located in an ozone non -attainment area or attainment maintenance area? Yes - If yes, is this source subject to leak detection and repair (LDAR) requirements per Regulation 7, Section XVII.F or XII.G or 40 CFR, Part 60, Subparts KKK or OOOO? Yes If you repond'yes" to the first question and "no" to the second, this source is subject to Regulation 3, Part B, Section III.D.2, Reasonably Available Control Technology (RACT) requirements and must implement a leak detection and repair program. The engineer should work with the supervisor to craft an LDAR requirement that mirrors the provisions of Regulation 7, Section XVII.F. Reg. 6 Is this source at an onshore "natural gas processing plant" as defined in 40 CFR, Part 60.631? No Did this source commences construction, reconstruction, or modification after January 20, 1984, and on or before August 23, 2011? No If you answer "yes" to both questions above, this source is subject to the provisions of 40 CFR, Part 60, Subpart KKK "Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants" contained in Regulation 6, Part A. Did this source commences construction, reconstruction, or modification after August 23, 2011? Yes If you answer "yes" to question #1. and #3 this source is subject to the provisions of 40 CFR, Part 60, Subpart OOOO "Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution". Specifically, review subpart 60.5400 for fugitive component leaks and 60.5380 and 60.5385 if the operator reports compressors. - It is possible for an onshore natural gas processing plant to have portions of the facility subject to NSPS KKK and portions subject to NSPS OOOO based on the specific dates of construction of those portions of the facility. If this is the case. the operator will need to report each of those respective fugitive component emissi0its on separate APENs and obtain unique emissions points from the. Division. Reg. 7 Is this source located in an ozone non -attainment area or attainment maintenance area? Yes Is this source at an onshore "natural gas processing plant" as defined in 40 CFR, Part 60.631? No If you answer "yes" to both questions above, this source is subject to the provisions of Regulation 7, Section XII.G regardless of the date of construction Reg. 8 Is this source at a "natural gas processing plant" as defined in 40 CFR, Part 63.761? No Is this facility considered a "major source" of HAP as specifically defined in 40 CFR, Part 63.761 for sites that are not prodcution field facilities? No If you repond'yes" to both questions above, further review if the provisions of 40 CFR, Part 63.769 "Equipment Leak Standards" apply? NA Stream HAP Components Iwt fraction HAP Gas Light Oil Heavy Oil Water/Oil Benzene 0.0004 0.005 0.00 0.00 ,Toluene 0.0004 0.019 0.00 0.00 Ethylbenzene 4.75E-05 0.005 0.00 0:00 Xylene 9.50E-05 0.025 0.00 0.00 n -Hexane 0.0112 0.134 0.00 0.00 224TMP 3.58E-05 0.0007 0.00 0.00 Printed 12/18/2020 Page 2 of 14 Separator Venting crtTisiions Inventory Section 01- Administrative Information Facility AIRS ID: 23 County 9FF8 Plant 003 Point Section 02- Equipment Descripdon Details One (I) 3 -phase separator Detailed Emissions Unit Description: ECO 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 = I Requested Permit Limit Throughput= 1030 MMscf per year 10:10 MMscf per year Requested Monthly Throughput= 95 0.9 MMscf per month I Potential to Emit (PTE) Throughput = 0 '- MMscf per year Secondary Emissions- Combustion Device(s) for Air Pollution Control "Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: 1512.7 Btu/scf scf/bbl Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: scfh :.:. 8tu/scf e 0 MMscf/yr Section 04 - Emissions Factors & Methodologies Description Sample ID V-7000 3 -Phase Separator. Sample was collected_ and analyzed on 7/30/2020 at a pressure of 75 psi and a temperature of 79F. Results of the speciation were converted to wt%and used along with the Displacement equation below to generate emission factors. MW 26.267 Component Helium H2S C02 N2 methane ethane Weight% 0.00 0.00 3.54 0.24 36.66 21.01 19,40 propane sobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane other heptnes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies .....2.87 8.28 2:07 2.56 0.01 0:80 0.22' 0:86 0.73 0.16 0.02 0.06 0:10 0.01 0.02 0.37 Total VOC Wt % b/Ib-mol Component MW 4.0026 34.1 44.01 28.0134 16.04 30.02 44.03 58.04 58.04 72.15 72.15 70.1 86.18 84.16 86.18 100.2 98.19 114.22 78.11 92.14 106.17 106.17 166.1961009 Displacement Equation Ex=Q*MW*Xx/C Mal % 0 0.0003 2.1152 0.2214 60.0402 18.3824 11.5763 1.2971 3.7464 0.7524 03317 0.0054 0.2439 0.0696 0.262 0.191 0.0423 0.0047 0.0216 0.0294 0.0029 0.0059 0.0579 100 Total 3 of 14 K:\PA\2018\18WE1051.CP2 Separator Venting Emissions Inventory Emission Factors Pollutant Uncontrolled (Ib/MMscf) Separator Venting Controlled (Ib/MMscf) (Gas Throughput) (Gas Throughput) Emission Factor Source VOC 26713,4 1330.82 Benzene 2.23 Toluene Ethylbenzene Xylene n -Hexane 224TMP Pollutant PM10 PM2.5 SOx NOx CO Pollutant PM10 PM2.5 SOx NOx VOC CO 16.53 554330 14.' 6 Primary Control Device ided gas anal ded gas analy! nded gas analysi tided gas analysi tided gas analysis elided gas analysi -ended gas analysi Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) Uncontrolled Ib/MMscf (Gas Throughput) Emission Factor Source 0.0030 0.00 00 :moot) 0.1380:!, 208.36 463,93 Emission Factor Source Pilot Light Emissions Uncontrolled Uncontrolled (Ib/MMBHO Ib/MMscf (Waste Heat Combusted) (Pilot Gas Throughput) 0.0020 0.3000 30003 0.0000= Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tans/year) (tons/year) Requested Monthly Limits Controlled Ohs/month) PM10 PM2.5 Sox NOx VOC CO 0.0 0„ 0.0 .. 0,0 0 .3.0 v 0 um o.0 OM 0.0 0.0 1 L 1,1 _.1 11 r. _ 17 134.9 134.9 S,) 134.9. 5.7 2.4 2.4 2.4 2.4 5 5 55 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 IMP ,__ 450 22 430 22 -<.. -_ 36 722 u., 15" -33,01 5601 5501 MB 143 to _ 113 t conservative factor chosen for both Nox and CO -while not from same source, this method is acceptable.' Section 06 - Regulatory Summary AnaWsis Regulation 3, Parts A, B Regulation 7, Part D, Section ILB, F Regulation 7, Part D, Section 11.B.2.e (See regulatory applicability worksheet for detailed analysis) anni requires a permit Stn. 00 is not anitinst ' ha .cnt•ol device_ for this -rear,,. -- -.ireigiiiiarion a2 " ..s..... _- 5555... 6.2. t 4 of 14 KAPA\2018\18W E1051.CP2 Sepal ator Venting Emissions Inventory ' Section 07 Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company F p y use site specific emission factors haled an a gas sample to estimate emissions? � syes - 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 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 Are facility wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattamment 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 Imtlal 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 P5 Memo 20-02 You have indicated above that the monitored process parameter is natural gas vented The `allowing questions do not require an ausner i Section 08 Technical Analysts Notes _ _ _ __ _ _ __ __ _ I I Ongmal emission factors for this point were based on a Promax model For this modification I requested an updated gas sample from this equipment in order to verify the original permitted emission factors or update any which were inconsistent 1{f 4The newly permitted emission factors are based on a site -specific gas sample from the permitted vessel collected In July 2020 (see above notes for more information) + ` ' 9 f ', ' s i ( r I 1 i t++ Section 09 SCC Coding and Emissions Factors (For Inventory Use Only) AIRS Point # 003 r r Process# SCC Code 01 3 10-001-89 glares 1 I Pollutant Uncontrolled Emissions Factor Control% Units PM10 00 0 Ib/MMSCF PM2 5 0 0 0 Ib/MMSCF SOx 00 0 Ih/MMSCF NOx 2088 0 Ib/MMSCF VOC 2u7164 95 Ib/MNISCF CO 4689 0 Ib/MMSCF Benzene 445 95 Ib/MM5CF Toluene 715 95 Ib/MMSCF Ethylhenzene 81 95 Ib/M v1SCF Xylene 165 95 Ib/MMSCF n Hexane 554 6 95 Ib/M MSC" 224 TMP A 2 95 Ib/MMSCF }1 I l 5 of 14 K \PA\2018\18WE1f151 CP2 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Re u lation 3 Parts A and B-AREN and Permit Requirements Source is in the Non.haminme=r_ Ama ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.l.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ii.D.3)7 I'l , indicated that me, la la the Non -Attainment Am, NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3, Part A, Section ll.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOM greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? IScu-ca requires a it ei? Colorado Regulation T, Part Co, Section II 1. Was the well newly constructed, hydraulically fractured, or recompleted on' or after August 1, 2014? retiree . not sublecc la. Regulation 7, Part 0, Realm, MS.?, Section II.B.2— General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section II.F - Control of emissions from well production facilities Alternative Emissions Control (Optional Section). a. Is this separator controlled Ina back-up or alternate combustion device (Le., not the primary control device) that is not enclosed? 'The control device for Masa-el:armor is not subject to Re.:.'_..._.. 7, Part D. Section R.B.?.a Section II.B.2.e-Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any,other binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,""may"'should,"and 'can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "muSt"and `required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Yes it Source Re Yes Source Re Source is l Itjp'?'IThe contra Separator Venting `missions Inventors/ Section 01 -Administrative Information Facility AIRS ID: 123 County 9FFB Plant 004 Point Section 02 - Equipment Description Details One (1) cendensate,surge vefsef Detailed Emissions Unit Description: ECD Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter k2uat Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions -Separator Actual Throughput= 6.7X MMscf per year 6.70' MMscf per year Requested MonthlyThroughput= 95 Requested Permit Limit Throughput= 06 MMscf per month Potential to Emit (PTE) Throughput = 5 7 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: Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: scfh Btu/scf 0.'7 MMscf/yr Section 04 - Emissions Factors& Methodologies Description • Sample. ID V-8100 Condensate Storage. Sample was collected and analyzed on 7/30/2020 at a pressure of 48 psi and a temperature of 89F. Results of the speciation were converted to wt% and used along with the Displacement equation below to generate emission factors. MW 29,9 Weight Helium H25 CO2 N2 methane ethane 0.00 0.00 3.13 0.10 25.55 22.88 23.77 propane isobuta ne n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies 3.65 10.55 2.74 3.42 0.02 1.06 0.28 1.16 0.85 0,15 0:02. 0.09 0.09 0.01 0.02 0.47 Total VOC wt % Ib/Ih-mol Component MW 4.0026 34.1 44.01 28.0134 16.04 30.02 44.03 58.04 58.04 72.15 72.15 70.1 86.18 84.16 86.18 100.2 98.19 114.22 78.11 92.14 106.17 106.17 166.1961009 Displacement Equation Ex=q*MW*Xx/C Mol 0 0.0001 2.1239 0.109 47.6211 22.7873 16.1426 1.8823 5.4359 1.137 1.4169 0.0083 0.3672 0.1001 0.404 0.2533 0.0468 0.0052 0.0344 0.0304 0.0029 0.0059 0.0854 100 7 of 14 K:\PA\2018\18WE1051.CP2 Separator Venting Emissions inventory Emission Factors Separator Venting Uncontrolled (Ib/MMscf) Pollutant VOC Benzene n -Hexane 224TMP (Gas Throughpu Controlled (16/MMscf) (Gas Throughput) Primary Control Device Emission Factor Source iced gas analyst ,ded gas analysIS;. p ed gas analysis,, ed gas analysts ed gas analysis's ded gas analysis ded gas analysis Pollutant , Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) Uncontrolled Ib/MMscf (Gas Throughput) Emission Factor Source PM10 PM2.5 SOx NO CO 0.1380 0,3100 TNRCC Rare Emissions Guidance.(NOx) AP -42 Chapter 13.5 Industrial Flares. (CO) Pollutant PM10 Pilot Light Emissions Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) Uncontrolled Ib/MMscf (Pilot Gas Throughput) Emission Factor Source Section 05 - Emissions Inventory Most conservative factor chosen for both Nox and. CO - while not from same source, this method is acceptable. Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual 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 5Ox NOk VOC CO 0.0 0 0 0.0 0,0 _.- 0.0 0.0 0.0 0,0 0 u 0 0.0 O.u` 0 0.8 0.8 0.8 0,8 135 __ _ 128.2 6.4 129.3 5.4 1086 ..._ 1,8 1.2 1.5 1.8 302 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) Ohs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TNIP 4T5 `75 2a 1'5 24 395 49 _. _ 2 n 5 F _ 111 c 121 5 5594 5511. 251 00 I x30 1,05 105 s ... Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Part D, Section ILB, F Regulation 7, Part D, Section 11.6.2.e (See regulatory applicability worksheet for detailed analysis) : egs.D. s a pe, r Source ,5 not subject i.7-. ! 'he ontl of dev:ce fof D1,5 ,enat ft.r• :• •,,, x _ ..J neanl.5: ;.n l P.irt yection B 2 e 8 of 14 - KAPA\2018\18WE1051.CP2 Separator Venting Emissions Inventory J i 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 appropnate to use an older site specific sample If no 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 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 95A for a flare or combustion device? If yes the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 You have Indicated above that the monitored Process parameter Is natural gas vented The following questions do not require an answer Section 08 Technical Analysis Notes _ / _ _ - _ __ _ _ _ _ __ _. ___ t Original &miss on factors for this point werebased on a Promax model For this modification I requested an updated gas sample from this equipment in orderto verify the original permitted emission factors or update any which were I. inconsistent The newly permitted emission factors are based on a site specific gas sample from the permitted vessel collected in July 2020 (see above notes for more information) I -- F Section 09 SCC Coding and Emissions Factors (For Inventory Use Only' AIRS Point JJ Process JJ SCC Code 004 01 110-001 60 Flares Pollutant Uncontrolled Emissions Factor Control .6 Units PM10 0 0 0 Ib/FAMSIF PM25 00 0 Ib/Ms4SCF 5Ox 0 0 0 Ib/MM1)5CF NOx 236 5 0 Ib/Mrs15CF VOC 38164 2 95 Ib/61615CP CO 5313 0 Ib/MN15CF Benzene 70 9 95 Ib/MMSCc Toluene 739 95 Ib/NIMSCF Ethylbenzene 81 95 Ib/Mt ISCF Kylene 16 5 95 Ib/rv1M5Cr n Hexane 8350 95 Ib/MVISC= 224 TMP 15 7 95 lb/61715U 1 9 of 14 K \PA\2018\18WE1051 CP2 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B-APEN and Permit Requirements rrco is in the Nan-Attelnrrznt Ares ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 11.0.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part%Section 11.0.3)? 'You have mdica tad that source sin the Von.Attamment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3, Part A, Section 11.0.1.a)7 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, section 11.0.2)7 'Source req.."-=,�cnrY Colorado Regulation 7. Part O, Section II 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 20147 katiree is not stmt.._ .art O, Section Section 11.6.2 —General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section IhP- Control of emissions from well production facilities Alternative Emissions Control (optional section) a. Is this separator controlled by a back-up or alternate combustion device (I.e., not the primary control devicet that Is not enclosed/ ?i a control device for this seaseator is not subject to R.eguiae=on 7. Part 0. Secnoit II B.2.c Section 11.6.2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, Its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law. regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute orregulaticn will control. The use of non -mandatory language such as'recommend,"may,""should,"and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as must" and 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Yes ISoureRe Yes Source Re .1sourreisi AThe cantn Compressor Slowdown Volume= Requested Compressor Slowdown Events= Actual Compressor Slowdown Events= Emergency Shutdown Volume= Actual Emergency Shutdown Events= Requested Emergency Shutdown Events= Actual Gas Throughput = Requested Permit Limit Throughput = Potential to Emit (PIE) Throughput= Section 01-Adminstrative Information IFacillty AIRS ID: 123 9FF8 005 County Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: { pressor blq d e t a d E g y SI utdowns (ESDS) Emission Control Device 'Emissions from: this n tcdrdrolled. Description: Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Information for Emissions Estimates ' 1.07E-03 MMscf/event 100 events/year 0 events/year 0.011 MMscf/event 0 events/year :2 events/year -,.:07 MMscf per year From APEN 13 3133 MMscf per year :3E01 MMscf per year Section 04- Emissions Factors & Methodologies Emission Calculation Method EPA Emission Invention/ Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.43) Ex=4.mw. x/C Ex = emissions of pollutant x 4= Volumetric flow rate/volume of gas processed MW = Molecular weight of gas =SG of gas' MW of air Xx = mass fraction of x In gas C = molar volume of ideal gas (379 scf/Ib-mol) at GOF and 1 atm Throughput (CD MW 215E01 2736 MMscf/yr Ib/Ib-mol 1.4EE+o1 0.000364237 sd/hr MMscf/d VOCFF 146]1.34315 /b/MMscf mole% MW Ihx/Ibmol m ass fraction lb/hr Ib/yr tpy Helium 0:00 4.0026 0 %a 1900 0 , 1333 0 90 CO2 '108 44.01 0.0.. 0.332 30.33 282.0r 0.14 N2 -0.51 28.013 9.143 0 003 0351 X333 0.02 methane :72.67 16.041 11,657 0.52"- 3..3.» 199 ethane .33.85 30.063 4.154 0.136 0.16 132-5.3? 0 71 Propane :].45 44:092 3 213 0 .1-.7 0.13. 2220.23 0.56 lsobWane -.0.74 58.118 01723 0.019 ,,..e.. .w5 . 0.07 n -butane 2.02 58.118 71.71 ua52 5315 39957 0.20 isopentane ": 032 72:114 0.2,30 0.010 _.. 75.35 094 n -pentane 0.36 ' 72.114 0.259 D.022 3315. 333.47 9.04 klimane 0.00 86.38 0.00:1 0.000 0_ a?7 0.00 n -Hexane 0.05 86,38 0.047 0-002 _ 32 M 0.01 cyclohexane - 0.01 84.16 0.011 9100 _ _ 0.00 Other hmanes 0.07 86.18 0.055 X0.19 0.01 heptanes 0.03 100.21 0.034 1333 __ 11.73 0-01 methylcyclohmane ' 0.01 98:19 0,006 .0^0 3-7.1) 20a 0.00 224-TMP 0.00 114.23 0.001 0WO 000 Benzene 0.01 78.12 0.005 0 060 _.1, ..57 0.00 Toluene - 0.00 92.15 0.005 1.0000 _.0_ ._u 6.00 Ethylbenzene 0.00 106.17 0,001 0 00 -:._ X 36 0.00 Xylenes 0.00 106.1] 0.000 ... _ 0 00 CBt Heavies ..0.02 114 0.001 0 ._ 0.00 100.00 VOC mass fraction: 1135_ MW Total VOCIUncontrolleM 0 s Notes Mole %, MW, and mass fractions are based on a representative gas sample token from the TEG Dehy inlet on 7/30/2020 Sample was collected at a pressure of 895 prig and a temperature of 103F. Emis i are based 100 compressor bi wd wn events apd2Emergenry Shutd (ESDf eve.�is Per year. Section OS - Emissions Inventory Emissions Summary Table - Compressor Blowdowns Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions s Controlled Emissions Source VOC _5.74 lb/event 15.74 lb/event 5.39 tpy 0.73 tpy Gas Analysis Benzene 2.30P-02. lb/event 0.013 lb/event _.3 Ib/yr 1.3 Ib/yr Gas Analysis Toluene 0.__ J_ lb/event 0_013 lb/event 15235 Ib/yr 1_25 Ib/yr Gas Analysis Ethylbenzene - " lb/event 0.00316/event 0.335 lb/yr 0.301b/yr Gas Analysis Xylenes 3333:.." lb/event 0,0061b/event 0.50 Ib/yr n.39 Ib/yr Gas Analysis n -Hexane _.._3 33 lb/event 0.033 lb/event P.S2 Ib/yr Ib/yr Gas Analysis 2,2,4-TMP 2.2SE . lb/event 0.00_ lb/event .,.'v Ib/yr Ib/yr Gas Analysis Emissions Summary Table - Emergencv Shutdowns Pollutant Uncontrolled Emlssion Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 161335 lb/event _0_.,83 lb/event 0.15. tpy 0.1G tpy Gas Analysis Benzene 1.34:31 lb/event O. 7, lb/event ..._% Ib/yr 0.27 1b/yr Gas Analysis Toluene 151E-^'_ lb/event 0.+31 lb/event ti..o Ib/yr 0.261b/yr Gas Analysis Ethylbenzene 3.05E-021b/event 0.031 lb/event _.651b/yr 0.061b/yr Gas Analysis Xylenes -._6, 1G lb/event 0.0.02 lb/event _.12 1b/yr n..12 1b/yr Gas Analysis n -Hexane 33.43E-0_ Ib/event O.G4G lb/event 1.501b/yr 1.30 Ib/yr Gas Analysis 2,2,4-TMP 2.32E-52 lb/event 11.02: lb/event 0,.'.5 Ib/yr _.03 Ib/yr Gas Analysis Emissions Summon Table -Tote (Compressor Slowdowns 3. Emergency Shutdowns Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC NA lb/event NA Ib/event. 0.95 tpy a.0• tpy Gas Analysis Benzene NA lb/event NA lb/event _57 Ib/yr .. ,: Ib/yr Gas Analysis Toluene NA lb/event NA lb/event 1.541b/yr Ib/yr Gas Analysis Ethylbenzene NA lb/event NA lb/event 3305 lb/y/ Ib/yr Gas Analysis Xylenes NA lb/event NA lb/event 0.12 Ib/yr ," Ib/yr Gas Analysis n -Hexane NA lb/event NA lb/event .6i Ib/yr .::: Ib/yr Gas Analysis 2,2,4-TMP NA lb/event NA lb/event • 4307 16/yr ..2" Ib/yr Gas Analysis 18WE1051.CP2 Section 06- Regulatory Summary Analysis ACICC Regulation 1 Section II.A.1- Except as provided In paragraphs 2 through 6 below, no owner or operator of a source shall allow ar cause the emission Into the atmosphere of any air pollutant which Is in excess of 20%. opacity. This standard's based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method emissions for visible - measurement is EPA Method (40 CFR, Part 60, Appendix A (July, 1992))nall subsections of Section II. A and B of this regulation. - AQCC Regulation 2 Section I.A applies to allemissionsources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source suchas to result in detectable odors which e measured In excess of. the following Pmts: For areas used predominantly for residential or commercial purposes its a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air." Section 07 -Technical Analysis Notes Operator provided calculefoon sheets for +aptlei ompressor blowdown and Emergency Shutdown vent vole. blowdown volume calcutatons ak rYo ar oiin4 ar4urt phys(ial equipment volumes as well as equip lowdown vonts tvnkm f+st bleeding each compown to the suction pressure of the fir e p xn to ?ion pressure, the ningg released to atmosphere. P Pre cy SEutdawn evants ial anlY mperature at tin like in blowdown even phy utdon operating pressure and temperatu ge inlet (-9s psig,.h+eh is the gast �iurnes ofeache stage of compression for ail ei sed on standard operating conditions of comp`. pre s a t'+me of event Per e g I ne oressureI. Aker at kh f 1:y, asw It ec7utPmant operating her thana. wings repress or to. bleed dourn 18WE1051.CP2 Section O1-Adminstrative Information Facility AIRS ID: 123 County 9FFB 006 Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Natural gas venting from pigging. Emissions from this source are vented to the atmosphere. Description: Emission Control Device Emissions from this source are not controlled. Description: Requested Overall VOC & HAP Control Efficiency %: 0 Section 03 - Processing Rate Information for Emissions Estimates Pig Receiver Blowdown Volume= 3.21E-04 MMscf/event Requested Pig Receiver Blowdown Events= 52 events/year Actual Pig Receiver Blowdown Events= 0 events/year Pig Launcher Blowdown Volume= 1.09E-04 MMscf/event Requested Pig Launcher Blowdown Events= 52 events/year Actual Pig Launcher Blowdown Event- events/year Actual Gas Throughput = MMscf per year Requested Permit Limit Throughput= 1.24E-02 MMscf per year Potential to Emit (PTE) Throughput = 2._4E-02 MMscf per year Section 04 - Emssions Factors Methodologies Emission Calculation Method EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW*Xx/C Ex = emissions of pollutant x Q= Volumetric flow rate/volume of gas processed MW = Molecular weight of gas= SG of gas * MW of air Xx = mass fraction of x in gas C= molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm Throughput (Q) MW MMscf/yr Ib/Ib-mol scf/hr MMscF/d, 5.12603ff mole% MW Ibx/Ibmol mass fraction lb/hr Ib/yr tpy Helium 0.00 4.0026 0.000 _.�. _ .. .._. 0.0.3 CO2 1.88 44.01 0.82? ...,,.:. _ 4c '- 0.02 N2 0.51 28.013 0.143 0.006 - ... 0.00 methane 72.67 16.041 11.657 0.521 0,34 ethane 13.85 ..30.063 4.164 0.18-6 0.12 propane 7.45 44.092 3.284 - 0,147 - .. -_ 0.10 isobutane 0.74 58.118 0.428 0.019 0.00 0.G1 n. -butane 2.02 58.118 1.171 3.052 0.01 .,_.._ 0-03 isopentane 0.32 72.114 0.230 0.010 0.00 13.55 0.01 n -pentane 0.36 72.114 0.259 C.012 0.00 15.30 0.01 i-hexane 0.00 86.18 0.001 0.000 . - 0.00 0.08 G ca n -Hexane 0.05 86.18 0.047 0.013 0.00 17.15. .,,.._ cyclohexane 0.01 84.16 0.011 0.000 i 0.00 0.63 0.00 Other hexanes 0.07 86.18 0.059 2.003 0,00 3.51 0.00 heptanes 0.03 100.21 0.034 0.082 0.00 2.03 0.CC methylcyclohexane 0.01 98.19 0.006 -3.000 0.00 0.36 4.00 224-TMP 0.00 114.23 0.001 0.000 0.00 0.05 0.01 Benzene 0.01 78.12 0.005 . _.__ 0.00 1.19 0.00 Toluene OM 92.15 0.005 ....... 1.00 2.11 ..03 Ethylbenzene 0.00 106.17 0.001 .. ,_... 0.00 053 0,00 Xylenes 0.00 106.17 G.-.".: .. 0-00 1.05 s.__ C8. Heavies 0.02 114 1.32 0.00 VOC mass fractic MW %t.351 Notes Total VOC (Uncontrolled) Mole %, MW, and mass fractions are based on a representative gas sample taken from the TEG Dehy inlet on 7/30/2020. Sample. was collected at a pressure of 895 psig and a temperature of 103F. re Emissions are based on 52 Pig Launcher Blowdown events and 52 Pig Receiver Blowdown events per year. Section OS - Emissions Inventory Emissions Summary Table - Combined/Overall Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 6.67 lb/event 6.'07 lb/event 0.35 tpy 0.35 tpy Gas Analysis Benzene 0.023 lb/event 0.023 lb/event 2.4 Ib/yr 2.— Ib/yr Mass Balance Toluene 0.041 lb/event 0.041 lb/event . 4.2 Ib/yr • 4.22 Ib/yr Mass Balance Ethylbenzene 0.010 lb/event 0,010 lb/event 1.1 Ib/yr 1.0> Ib/yr Mass Balance Xylenes 0.020 lb/event 0.020 lb/event 2.1 Ib/yr 2.11 Ib/yr Mass Balance n -Hexane - 0.330 lb/event 0.330 lb/event 34.3 Ib/yr 34.25 Ib/yr Mass Balance 2,2,4-TMP 0.001 lb/event 0.001 lb/event 0.1 Ib/yr 0.09 Ib/yr Mass Balance 18WE1051.CP2 EmissionsSummary Table - Pig Receivin Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC --. lb/event 2.'I lb/event r,%2F, tpy ..2.6 tpy Gas Analysis Benzene lb/event ...` lb/event 1.₹ Ib/yr "..a` Ib/yr Mass Balance Toluene lb/event -a lb/event 3.2 Ib/yr a.1a Ib/yr Mass Balance Ethylbenzene lb/event ,..3 lb/event 0.9 Ib/yr ,..7.9 Ib/yr Mass Balance Xylenes lb/event 025 lb/event 1.s Ib/yr 1.53 Ib/yr Mass Balance n -Hexane lb/event Y.,245 lb/event 25,6 Ib/yr - 25120 Ib/yr Mass Balance 2,2,4-TMP : lb/event U :)7. lb/event 0,1 Ib/yr 0,27 Ib/yr Mass Balance Emissions Summary Table - Pig Launchin Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC `? lb/event '..?, lb/event .,v9 tpy R,:" tpy Gas Analysis Benzene - lb/event �5 lb/event 0,6 Ib/yr 0,6 Ib/yr Mass Balance Toluene ... r lb/event J%a lb/event _.1 Ib/yr 1'` Ib/yr Mass Balance Ethylbenzene .. lb/event ..'s' lb/event ,-2 Ib/yr ., .'; Ib/yr Mass Balance Xylenes ... lb/event :I- lb/event -.i Ib/yr .,..:+_ Ib/yr Mass Balance n -Hexane lb/event ", lb/event ,.' Ib/yr -- Ib/yr Mass Balance 2,2,4-TMP 2 . _ _ ;:. lb/event ?: lb/event .1 Ib/yr 2.02.,..kZZ Ib/yr Mass Balance Section 06 - Regulatory Summary Analysis -- AQCC.Regulation 1 Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) In all subsections of Section II. A and B of this regulation. AQCC Regulation 2 Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air." Section 07 - Technical Analysis Notes WHILE THE ANNUAL VOC EMISSIONS OF POINT 006 FALL BELOW APEN THRESHOLD, BOTH THIS POINT AND 005 ARE CONSIDERED ROPE ACTIVITIES WHICH MUST BE GROUPED FOR PERMITTING. THEREFORE, THE ACTIVITIES COVERED BY THIS POINT 006 ARE NOT APEN-EXEMPT. Operator provided calculation sheets for updated pigging -related event volumes. - Pig receiver/launcher volume calculations take into account actual physical equipment volumes as well as equipment operating pressure and temperature at time of event. Per operator calculation sheet, the inlet receiver and discharge launcher at this facility are bled down to suction pressure (^95 psig) before releasing the remaining gas volume to atmosphere. 1SWE1051.CP2 Blowdown Volumes/Maintenance Releases Assume 2:1 Semi -elliptical Heads; GPSA Formula Section 6, Storage V= (n/12)•D3 + (n/4)•D2•L Vessel volume with 2:1 ellipsoidal heads Equipment Ta Suction Pressure, Psig m _ Discharge Pressure, Psig;, Equipment Name Ilnput pressures here. Diameter, Wall O.D. Thickness, Length (In) (In) (ft) Operating Volume Pressure Operating (ft3) (psig) Temp (F) % Gas Std Volume (Msd) C-2100 Suction Piping 10.000 0.365 15:000 7.030 95 60 100 0.051 C-2100 Suction Bottle 36:000 0.000 6.250 51.247 95 60 100 0.372 C-2100 Suction Pulsation Bottle 24.000 0.375 6.000 19.594 95 60 100 0.142 C-2100 Suction Pulsation Bottle 18.000 0.375 6:000 10.515 95 60 100 0.076 C-2100 2nd Stage Suction Bottle 30.000 0.000 5.667 31.907 95 91 100 0.218 C-2100 2nd Stage Pulsation Bottle 20.000 0.375 0,667 2.428 95 91 100 0.017 C-2100 Discharge Piping 4.000 0.237 15.000 1.017 95 200 100 0.006 C-2100 3rd Stage Suction Bottle 24.000 0.000 5.000 1 15.708 95 200 100 0.090 C-2100 Discharge Pulsation Bottle 18.000 0.375 4:667 8.351 95 200 100 0.048 C-2100 Discharge Pulsation Bottle 18.000 0.375 4,667 8.351 95 200 100 0.048 C-2100 Recycle Piping 4.000 0.000 12.000 :' 1.047 95 200 100 0.006 Compressor Total Total Compressor Blowdown ,.• PR -1000 Inlet Receiver 24.000 0.375 15.000 44.225 95 60 100 rq. PL -6000 Discharge Launcher 16.000 0.375 15.000 19.026 13 200 100 I?- Blowdown Volumes/Maintenance Releases Assume 2:1 Semi -elliptical Heads; GPSA Formula Section 6, Storage V= (n/12)•D3+(n/4)•Dz•L Vessel volume with 2:1 ellipsoidal heads Equipment Tag Equipment Name Suction Pressure, Psig %17 95 Discharge Pressure, Psig ; 250:® Diameter, wail O.D. Thickness, (In) (In) Inputpressures here. Length (ft) Operating Volume Pressure Operating (ft3) (psig) Temp (F) %Gas Std Volume f Mscfl C-2100 Suction Piping 10.000 0.365 7.030 95 60 100 0.051 C-2100 Suction Bottle 36.000 0.000 51.247 95 60 100 0.372 C-2100 Suction Pulsation Bottle 24.000 0.375 t:'p(70 19.594 95 60 100 0.142 C-2100 Suction Pulsation Bottle 18.000 0.375 6.000 10.515 95 60 100 0.076 C-2100 2nd Stage Suction Bottle 30.000 ! 0.000 5.667_, 31.907 95 91 100 0.218 C-2100 2nd Stage Pulsation Bottle 20.000 '' 0.375 0.661417 2.428 95 91 100 0.017 C-2100 Discharge Piping 4.000 '' 0.237 15.000 1.017 250 200 100 0.014 C-2100 3rd Stage Suction Bottle 24.000' 0.000 5.000 15.708 250 200 100 0.220 C-2100 Discharge Pulsation Bottle 18.000 0.375 4.667 8.351 250 200 100 0.117 C-2100 Discharge Pulsation Bottle : 18.000 -' +0.375 4.667 . _ 8.351 250 200 100 0.117 C-2100 Recycle Piping 4.000 0.000 12.000': 1.047 250 200 100 0.015 Compressor Total Total Compressor Blowdown Station ESD Volume 10.872 Fugitive Component Leak Emissions APEN Form APCD-203 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 fugitive component leak emissions only. If your emission source 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: 18WE1051 AIRS ID Number: 123 / 9FFB 002 [Leave blank unless .APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Mailing Address: (Include Zip Code) REP Processing, LLC Severance Compressor Station NW 1/4, S8, T7N, R66W County Rd 27, Ault, CO 80610 1138 N. Robinson Ave., Suite 102 Oklahoma City, OK 73103 Site Location Weld County: NAICS or SIC Code: Contact Person: 211130 Lance King Phone Number: 405-400-9672 E -Mail Address2: Lking@rimrockenergy.com 1 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. Form APCD-203 Fugitive Component Leak Emissions APEN Revision 07/2020 !COLORADO . NUIfA b kT Permit Number: 18WE1051 AIRS ID Number: 123 / 9FF6 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source (check one below) -OR - ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑ Change process or equipment ❑ Change company name3 ❑ Add point to existing permit ✓❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) - OR APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. ' For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information Company equipment Identification No. (optional): For existing sources, operation began on: FUG -1 9/19/2019 For new or reconstructed sources, the projected start-up date is: 0 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 Facility Types: ❑ Well Production Facility ❑✓ Natural Gas Compressor Station ❑ Natural Gas Processing Plant ❑ Other (describe): days/week weeks/year 5 When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 07/2020 ':COLORADO 2 Department ,tPublic Neat. a Environment Permit Number: 18WE1051 AIRS ID Number: 123 / 9FFB / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Regulatory Information What is the date that the equipment commenced construction? Will this equipment be operated in any NAAQS nonattainment area? Will this equipment be located at a stationary source that is considered a Major Source of Hazardous Air Pollutant (HAP) emissions? Are there wet seal centrifugal compressors or reciprocating compressors located at this facility? Is this equipment subject to 40 CFR Part 60, Subpart KKK? Is this equipment subject to 40 CFR Part 60, Subpart OOOO? Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? Is this equipment subject to 40 CFR Part 63, Subpart HH? Is this equipment subject to Colorado Regulation No. 7, Section XII.G? Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? Is this equipment subject to Colorado Regulation No. 7, Section XVI1.B.3? December 2018 ❑✓ Yes ❑ Yes ✓❑ Yes ❑ Yes ❑ Yes ❑✓ Yes El Yes ❑ Yes ❑✓ Yes ❑✓ Yes ❑ No ❑✓ No ['No r❑ No ❑✓ No ❑ No ❑ No ❑✓ No ❑ No ❑ No Section 5 - Stream Constituents ' ❑ The required representative gas and liquid extended analysis (including BTEX) to support the data below has been attached to this APEN form. Use the following table to report the VOC and HAP weight % content of each applicable stream. Stream VOC (wt %) Benzene (wt %) Toluene (wt %) Ethylbenzene (wt %) Xylene (wt %) n -Hexane {wt %) 2'2'4 Tnmethylpentane (►+'t %) Gas 24.70 0.02 0.02 0.005 0.009 0.21 0.00 Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) 100 0.54 1.90 0.54 2.54 13.44 0.07 Water/Oil Section 6 - Geographical Information Geographical Coordinates (LatitudelLongftede or UTM) UTM N 4493424.09, E 516573.65 - approx center of facility Attach a topographic site map showing location Form APCD-203 Fugitive Component Leak Emissions APEN - Revision 07/2020 cOLORADO 3 I HathEntivmmard Permit Number: 18WE1051 AIRS ID Number: 123 / 9FFB / 002 [Leave Lbtank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Leak Detection and Repair (LDAR) and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: ❑ LDAR per 40 CFR Part 60, Subpart KKK ❑ Monthly Monitoring - Control: 88% gas valve, 76% light liquid valve, 68% light liquid pump ❑ Quarterly Monitoring - Control: 70% gas valve, 61% light liquid valve, 45% light liquid pump ❑✓ LDAR per 40 CFR Part 60, Subpart 0000/0000a ❑ Monthly Monitoring - Control: 96% gas valve, 95% light liquid valve, 88% light liquid pump, 81% connectors ❑� LDAR per Colorado Regulation No. 7, Section XVII.F ❑ Other6: ❑ No LDAR Program 6 Attach other supplemental plan to APEN form if needed. Form APCD-203 Fugitive Component Leak Emissions APEN - Revision 07/2020 4 'COLORADO f Department 6 £n of Public Permit Number: 18WE1051 AIRS ID Number: 123 / 9FFB / 002 [Leave blank unless APCD has already assigned a permit s and AIRS ID] Section 8 - Emission Factor Information Select which emission factors were used to estimate emissions below. If none apply, use the table below to identify the emission factors used to estimate emissions. Include the units related to the emission factor. ❑ Table 2-4 was used to estimate emissions. Q Table 2-8 (< 10,000ppmv) was used to estimate emissions. Use the following table to report the component count used to calculate emissions. The component counts listed in the following table are representative of: ❑ Estimated Component Count ❑✓ Actual Component Count conducted on the following date: 3/11/2020 as Connectors 637 Equipment Type` Open -Ended Lines Pump Seals 444 20 Count$ 436 0 2 Emission Factor 2.20e-5 1.26e-5 3.31e-5 7.72e-5 5.51e-5 2.65e-4 Units lb/hr-source lb/hr-source lb/hr-source lb/hr-source lb/hr-source lb/hr-source Heavy Oil (or Heavy Liquid) Count$ Emission Factor Units Light Oil (or Light Liquid) CountB 410 170 0 9 170 10 Emission Factor 2.14e-5 5.29e-6 3.09e-5 1.12e-3 4.19e-5 2.43e-4 Units lb/hr-source lb/hr-source lb/hr-source lb/hr-source lb/hr-source lb/hr-source ater/Oil ' Count$ Emission Factor Units 7 Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates (Document EPA -453/R- 95-017). 8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the actual calendar year emissions below. 9 The "Other" equipment type should be applied for any equipment other than connectors, flanges, open-ended lines, pump seals, or valves. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 07/2020 icercoLoRADo 5; Department of Public Permit Number: 18WE1051 AIRS ID Number: 123 / 9FFB / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Pollutant CAS Number Actual Annual Emissions Requested Annual LiPermit Emission (°)io Limit(s) Uncontrolled (tons/year) Controlled"' (tons/year) Uncontrolled (tons/year) Controlled' (tons/year) voc 13.0 0.18 1.6:-9 0.24 0.24 0.18 io 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. Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 10 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteriaID 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 CAS Number Actual Annual Emissions Requested Annual Permit Emission Limit(s)t° Uncontrolled Otos/year) Controlledii Ohs/year) Uncontrolled (Ibs/year) Controlled (tbs/year) Benzene 71432 1-1-9 2 2 Toluene 108883 367 6 33 6 Ethylbenzene 100414 .14 2 6 2 Xylene 1330207 466 9 3-7 9 n -Hexane 110543 2568 46 46 2,2,4-Trimethylpentane 540841 Other: ❑ No io 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. Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. -BF 12/18/2020 Per attached email Form APCD-203 Fugitive Component Leak Emissions APEN - Revision 07/2020 '!cOLORADo 6 _��'«r HwitT b ETviromnam Permit Number: 18WE1051 AIRS ID Number: 123 / 9FFB / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 11 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 10/22/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Lance King Director of Environment & ROW Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ✓❑ 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-B1 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-203 Fugitive Component Leak Emissions APEN - Revision 07/2020 pate Department of Public COLORADO nw WAIN 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: 18WE1 051 AIRS ID Number: 123 / 9FFB /003 [Leave blank unless APCD has already assigned a permit f` and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: REP Processing, LLC Severance Compressor Station NW 1/4, S8, T7N, R66W County Rd 27, Ault, CO 80610 Mailing Address: 1138 N. Robinson Ave., Suite 102 (Include Zip Code) Oklahoma City, OK 73101 Site Location County: Weld NAICS or SIC Code: 211130 Contact Person: Phone Number: E -Mail Address2: (.king@rimrockenergy.com L ance King (405) 400-9672 1 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. Form APCD-211 - Gas Venting APEN - Revision 07/2020 =COLORADO 1 i +.t Dow etAr3lle F x.m.intanara m Permit Number: 18WE1051 AIRS ID Number: 123 / 9FFB / 003 (Leave blank unless APCD has already assigned a permit # and AIR; IDj Section 2 - Requested Action ❑ 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 - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: This update is based on revised gas flows and updated emission factors. Also, Vessels V-7000 and V-8100 are both controlled by a single enclosed combustor. 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: Pressure Vessel V-7000 is a 3 -phase separator controlled by a shared enclosed combustor. Company equipment Identification No. (optional): For existing sources, operation began on: V-7000 September 2019 For new, modified, or reconstructed sources, the projected start-up date is: ❑✓ 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 XVII.G? Form APCD-211 - Gas VentIn; APEN - Revision 07/2020 days/week weeks/year O Yes ❑ Yes • Yes ❑ No O No ❑ No 2 g®ICOIORADO Detnwn.uetPm litanh [n lieruneni Permit Number: 18WE1 051 AIRS ID Number: 123 / 9FFB / 003 floave blank unless APCD has already assignod a permit t, and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well 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 Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ No Vent Gas 1512 BTU/SCF Heating Value: , Requested: 10.1 MMSCF/year Actual: 10.1 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 26.267 VOC (Weight %) 38.5 Benzene (Weight %) 0.06 Toluene (Weight %) 0.10 Ethylbenzene (Weight %) 0.01 Xylene (Weight %) 0.02 n -Hexane (Weight %) 0.08 2,2,4-Trimethylpentane (Weight %) 0.02 Additional Required Documentation: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids 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. Form APCD-211 - Gas Venting APEN - Revision 07/2020 COLORADO 3 I HelsillIttramisarmml ❑✓ Circular ❑ Square/rectangle ❑ Other (describe): Permit Number: 18WE1051 AIRS ID Number: 123 / 9FFB / 003 [Leave blank untess APC D has .already assigned a Perm€t: and AIRS ID] Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) N4493368 E516584.30 ❑ 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 (Feet) Temp. CF) Flow Rate (ACFM) Velocity (ft/sec) F-9500 32 1,500 387 (from all sources) 9 (from all sources) Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) Interior stack diameter (inches): 91.2 ❑ Upward with obstructing raincap Interior stack width (inches): 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. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: ❑ Combustion J Device: Pollutants Controlled: VOC and HAPs Rating: Type: Enclosed Combustor Make/Model: MMBtu / hr Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 GCO Beast 3200 Minimum Temperature: Waste Gas Heat Content: 1,512 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 07/2020 4,081 COLORADO DepArtemodftW. WWhiYnrtronlnat Permit Number: 18WE1051 AIRS ID Number: 123 / 9FFB / 003 (heave blank unle,s APO has already astidrleci a permit a and AIRS ICS] 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? ❑r 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 NO. CO VOC Enclosed Combustor 95 HAPs Enclosed Combustor 95 Other: From what year is the following reported actual annual emissions data? 2019 t 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 Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOX NO. 0.138 Ib/MMBIu TCEQ 1.1 1.1 1.1 1.1 CO 0.2755 Ib/MMBtu TCEQ 2.4 2.4 2.4 2.4 VOC 26,716 Ib/MMscf Gas Analysis 134.7 6.7 134.7 6.7 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 Yes pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? -criteria aollutant fHAP ) emissions from source: ❑ No .. ,-_, _- _ --- Chemical Name -- - -,- - - Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions Ohs/year) Controlled Emissions6 Ohs/year) Benzene 71432 44.52 Ib/MMscf Gas Analysis 449 22 Toluene 108883 71.48 Ib/MMscf Gas Analysis 720 36 Ethylbenzene 100414 8.12 Ib/MMscf Gas Analysis 82 4 Xylene 1330207 16.53 Ib/MMscf Gas Analysis 167 8 n -Hexane 110543 554.60 Ib/MMscf Gas Analysis 5,590 280 2,2,4-Trimethylpentane 540841 14.16 Ib/MMscf Gas Analysis 143 7 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 APEN - Revision 07/2020 Cokonwoo 5 14tr = Permit Number: 1$WE1051 AIRS ID Number: 123 / 9FFB / 003 [Leave dank unto ss Aro) [las Mread j assWed a permit =s and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 9/3/2020 Signature of Legally Authorized rson (not a vendor or consultant) Date Lance King '� Director of Environment & ROW Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance i] 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-B1 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 APEN - Revision 07/2020 6, GO COLORADO OWN.. of Addis NaaLh6YmEeoneatetl Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit Alt 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 wilt 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: 18WE 1051 AIRS ID Number: 123 / 9FFB / 004 [Leave blank unless APCD has already assigned a permit K and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: REP Processing, LLC Severnace Compressor Station NW 1/4, S8, T7N, R66W County Rd 27, Ault, CO 80610 Mating Address: 1138 N. Robinson Ave., Suite 102 (Include Zip Code) Oklahoma City, OK 73101 Site Location County: Weld NAICS or SIC Code: 211130 Contact Person: Phone Number: E -Mail Address2: Lance King (405) 400-9672 l.king@rimrockenergy.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. Form APCD-211 - Gas Venting APEN - Revision 07/2020 !COLORADO x rw�n nani Permit Number: 18WE1051 AIRS ID Number: 123 / 9FFB / 004 [Leave blank unless APCD has already assigned a permit and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source -OR- ❑J 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 - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Fc Notes: This update is based on revised gas flows and updated emission factors. Also, Vessels V-7000 and V-8100 are both controlled by a single enclosed combustor. 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: Pressure Vessel V-8100 is a condensate surge vessel controlled by an enclosed combustor. Company equipment Identification No. (optional): For existing sources, operation began on: V-8100 September 2019 For new, modified, or reconstructed sources, the projected start-up date is: 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 XVII.G? Form APCD-271 - Gas Venting APEN - Revision 07/2020 days/week weeks/year El Yes ❑ Yes ❑✓ Yes ❑ No ❑✓ No ❑ No (COLORADO aep.�au.vaweue 2 NxUTbC¢Atoemant Permit Number: 1 8WE1051 AIRS ID Number: 123 / 9FFB /004 [leave Wank untess- APCD has already assi:;necl a permit. it and AIR ID] Section 4 - Process Equipment Information Gas/Liquid Separator ❑ Well 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 Parameterss: Liquid Throughput Process Parameterss: Vented Gas Properties: ❑✓ No Vent Gas 1 713 BTU/SCF Heating Value: I Requested: 6.72 MMSCF/year Actual: 6,72 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 29,90 VOC (Weight %) 48.4 Benzene (Weight %) 0.09 Toluene (Weight %) 0.09 Ethylbenzene (Weight %) 0.01 Xylene (Weight %) 0.02 n -Hexane (Weight %) 1.06 2,2,4-Trimethylpentane (Weight %) 0.02 Additional Required Documentation: ❑✓ Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids 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. Form APCD-211 - Gas Venting APEN - Revision 07/2020 COLORADO 3 iHUM,' ZeikrOMIKIst Permit Number: 18WE1051 AIRS ID Number: 123 / 9FF6 / 004 [Leave blank unless APCD has already assi4necl a permit „ and AIRS ID] Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) N4493368 E516584.30 ❑ 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 (Feet) Temp. ('F) Flow Rate (ACFM) Velocity (ft/sec) F-9500 32 1,500 387 (from all sources) 9 (from all sources) 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): 91.2 ❑ 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: Type: Enclosed Combustor Make/Model: MMBtu / hr Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 % GCO Beast 3200 Minimum Temperature: Waste Gas Heat Content: 1,356 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: % Form APCD-211 - Gas Venting APEN - Revision 07/2020 y� (COLORADO 4 11�t►I, Permit Number: 18WE1051 AIRS ID Number: 123 / 9FFB / 004 [Leave btank: unless APCD has already' assigned a permit It) and FIRS ID] 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? ❑✓ Yes ❑ No If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or bined values if multi le emission control methods were identified in Section 6): com Pollutant p Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC Enclosed Combustor 95 HAPs Enclosed Combustor 95 Other: From what year is the following reported actual annual emissions data? 2019 from source: Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Source (AP -42, Mfg., etc.) Uncontrolled Units Emissions Emissions (tons/year) Controlled 6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SO. NO. 0.138 Ib/MMBtu TCEQ 0.8 0.8 0.8 0.8 CO 0.2755 Ib/MMBIu TCEQ 1.8 1.8 1.8 1.8 VOC 38,164 IbIMMscf Gas Analysis 128.2 6.4 128.2 6.4 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 ❑✓ Yes ❑ No pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? criteria pollutant (HAP) emissions from source: Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (Ibs/year) Controlled Emissions6 Ohs/year) Benzene 71432 70.90 Ib/MMscf Gas Analysis 475 24 Toluene 108883 73.91 Ib/MMscf Gas Analysis 495 25 Ethylbenzene 100414 8.12 Ib/MMscf Gas Analysis 54 3 Xylene 1330207 16.55 Ib/MMscf Gas Analysis 111 6 n -Hexane 110543 834.97 Ib/MMscf Gas Analysis 5,594 280 2,2,4-Trimethylpentane 540841 15.67 Ib/MMscf Gas Analysis 105 5 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 APEN - Revision 07/2020 afOIORADO Permit Number: 1 8WE1 051 AIRS ID Number: 123 / 9FFB / 004 (Leave blank unless APCD has already assigned a permit it anti AIRS ID; Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and corr t tvc4 ,� , 9/3/2020 Signature of Legally iSuthorized`rson (not a vendor or consultant) Date Lance King Director of Environment & ROW Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance D 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-B1 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 APEN - Revision 07/2020 .COLORADO 6 I �Mit I st="e. .-"`", 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 locks 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: 1 8WE 1 05 1 AIRS ID Number: 123 / 9FFB /9-03 005 [Lease blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: REP Processing, LLC Severance Compressor Station NW 1/4, S8, T7N, R66W County Rd 27, Ault, CO 80610 Mailing Address: 1138 N. Robinson Ave., Suite 102 (Include Zip Code) Oklahoma City, OK 73101 Site Location County: Weld NAILS or SIC Code: 211130 Contact Person: Phone Number: E -Mail Address2: Lance King (405) 400-9672 Lking@rimrockenergy.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. Form APCD-211 Gas Venting APEN - Revision 07/2020 1 ;COLORADO Department. Nagel(' Environment Permit Number: 1 8WE1 051 AIRS ID Number: 123 / 9FFB / O3j 005 [Leave blank unless ARC) has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source -OR- O MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit O Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR - ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info It Notes: This update is based on revised blowdown volumes and an actual gas analysis. Also, two emergency shutdowns (ESD) have been added. 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: Routine and predictable blowdowns. The majority of the gas will be returned to the suction header. Company equipment Identification No. (optional): For existing sources, operation began on: BD -1 September 2019 For new, modified, or reconstructed sources, the projected start-up date is: ❑✓ 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 XVII.G? days/week weeks/year 0 Yes ❑ Yes ❑ Yes Form APCD-211 - Gas Venting APEN - Revision 07/ 2020 2 ❑ No O No O No COLORADO j Ilewrenenr of wwic - Health 6 Environment Permit Number: 1 8WE1 051 AIRS ID Number: 123 /9FFB/4203 005 [Leave blank unless APCD has already assigned a permit ,» and AIRS ID] Section 4 - Process Equipment Information ❑ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial #: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: # of Pistons: Leak Rate: Scf/hr/pist ❑✓ Blowdown Events # of Events/year: 1 00 Volume per event: 0.001 MMscf/event ❑✓ Other Description: Two Emergency Shutdowns (ESDs) at 0.011 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 Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ✓❑ No Vent Gas Heating Value: 1 301 7 BTU/SCF Requested: 0.129 MMSCF/year Actual: 0.067 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 22,32 VOC (Weight %) 24.7 Benzene (Weight %) 0.02 Toluene (Weight %) 0.02 Ethylbenzene (Weight %) 0.0005 Xylene (Weight %) 0.01 n -Hexane (Weight %) 0.21 2,2,4-Trimethylpentane (Weight %) 0.004 Additional Required Documentation: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) El 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. Form APCD-211 - Gas Venting APEN - Revision 07/2020 COLORADO 3 � n,«. Hu1N b EnHronmerrt Permit Number: 18WE1051 AIRS ID Number: 123 / 9FFB / 003 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude " UFM) N/A ❑✓ 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. N/A N/A N/A N/A N/A Indicate the direction of the stack outlet: (check one) ❑ Downward ❑✓ Other (describe): Fugitive ❑ Upward ❑ Horizontal Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): ❑✓ Other (describe): Fugitive ❑ Upward with obstructing raincap 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. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: % % ❑ Combustion Device: Pollutants Controlled: Rating: Type: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: MMBtu / hr Make/Model: Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑ Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 07/2020 Aci.ggikicoLoRAoo 4 I 11,==�edinroi� H.eakbb6vrtuanrtunt PM PM Permit Number: 18WE 1051 AIRS ID Number: 123 / 9FFB / 8013 005 [Leave blank unless APCD has already assigned a permit k and AIRS ID] 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? ✓❑ 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): Control Equipment Description Overall! Requested ContrO1 Efficiency' '(% redrtctiOn hi entissfons) SOX NO. CO VOC HAPs Other: From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Emission Factor Actual Annual Emissions Requested Annual Permit: Emission ,Limit(s)s Uncontrolled__ Basis Ib/Mscf Source (AP -42,. Mfg., etC,) Uncontrolled Emissions (wns/yeor) , a� Controlled, Emissionsb' (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/yettr) SO. NO. CO VOC 14.54 Gas Analysis 0.48 0.48 0.94 0.94 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 Servite. (CAS) Number. ;' Emission Factor _. `, Actual Annual Emissions Controlied ��missions� (f#slyearl , - Uncontrolled Basis . Units Sour~re SAP -42, Mfg etc.) uncontroued ;Emissions (fbslyear) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4-Trimethylpentane 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 APCID-211 Gas Venting APEN - Revision 07/2020 CalVCOLORADO 5I r l Permit Number: 18WE1051 AIRS ID Number: 123 / 9FFB / 0O-3 005 [Leave blank unless APCD has already assigned a permit « and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 10/22/20 Signature of Legally Authorized Person (not a vendor or consultant) Date Lance King Director of Environment & ROW Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance ❑✓ 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-B1 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 APEN - Revision 07/202© 6 ICOIORADO nm =uK «Public Health 66nV/anunent 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: 1 8WE1051 AIRS ID Number: 123 / 9FFB / 006 [Leave blank unless APCD has already assigned a permit r and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: REP Processing, LLC Severance Compressor Station NW 1/4, S8, T7N, R66W County Rd 27, Ault, CO 80610 Mailing Address: 1138 N. Robinson Ave., Suite 102 (Include Zip Code) Oklahoma City, OK 73101 Site Location County: Weld NAICS or SIC Code: 211130 Contact Person: Lance King Phone Number: (405) 400-9672 E -Mail Addressz: I.king@rimrockenergy.com 1 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. :,COLORADO Form APCD-211 - Gas Venting APEN - Revision 07/2020 Permit Number: 18WE1051 AIRS ID Number: 123 /9FFB/O04 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑ 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 ownership' ❑ 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 Et Notes: This update is based on revised pigging volumes and an actual gas analysis. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. ' 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: Routine and predictable pigging. The majority of the gas will be returned to the suction header. Company equipment Identification No. (optional): For existing sources, operation began on: PG -1 September 2019 For new, modified, or reconstructed sources, the projected start-up date is: O 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 XVII.G? days/week weeks/year 0 Yes ❑ Yes ❑ Yes Form APCD-211 - Gas Venting APEN - Revision 07/2020 2 ❑ No Q No ll No ;COLORADO ! Department oee,w6c Health 6 Environment Permit Number: 18WE1051 AIRS ID Number: 123 /9FFB/G84 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: Serial #: # of Pistons: ❑ Blowdown Events # of Events/year: Volume per event: ❑✓ Other Description: Routine pigging operations, 104 events per year Capacity: gal/min Leak Rate: 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 Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ No Vent Gas Heating Value: 1 301 7 BTU/SCF Requested: 0.02 MMSCF/year Actual: 0.01 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 22,32 VOC (Weight %) 24.7 Benzene (Weight %) 0.02 Toluene (Weight %) 0.02 Ethylbenzene (Weight %) 0.0005 Xylene (Weight %) 0.01 n -Hexane (Weight %) 0.21 2,2,4-Trimethylpentane (Weight %) 0.004 Additional Required Documentation: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) El 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. Form APCD-211 - Gas Venting APEN - Revision 07/2020 3 'COLORADO Public 6 £nviranment ❑ Upward ❑ Horizontal Permit Number: 18WE 1051 AIRS ID Number: 123 /9FFB/G04 006 [Leave blank unless APCD has already assigned a permit M and AIRS ID] Section 5 - Geographical/Stack Information Geographical, Coordinates (LatitudelLongitude or UTM) N/A ❑✓ 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. �_- N/A N/A N/A N/A N/A Indicate the direction of the stack outlet: (check one) ❑ Downward ❑✓ Other (describe): Fugitive Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): O Other (describe): Fugitive ❑ Upward with obstructing raincap 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 . ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: % ❑ Combustion Device: Pollutants Controlled: Rating: Type: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: MMBtu / hr Make/Model: Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑ Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: % Form APCD-211 - Gas Venting APEN - Revision 07/2020 4j - .COLORADO nenartmeniwweue Health &Environment Benzene Permit Number: 1 8WE 1 051 AIRS ID Number: 123 / 9FFB / Q0. 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] 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? ❑✓ 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 NO. CO VOC HAPs Other: From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Pollutant Emission Factor Uncontrolled Basis Ib/Mscf Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Source (AP -42, Mfg-, etc.) Uncontrolled ; Emissions (tons/year) Controlled#, Emissionss (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions ". (tons/year) PM SO. NO. CO VOC 14.54 Gas Analysis 0.1 0.1 0.33 0.33 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? If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: ❑ Yes 0 No Cherriical Abstract Service {CAS) .number Emission Factor Uncontrolled Basis . Actual Annual Emissions , Source (AP -42, Mfg., etc-) Uncontrolled Emisslgns,. .(tbstyearj '=Control(ed l;missf©nss. (fbs/year) , 71432 Toluene Ethylbenzene Xylene n -Hexane 108883 100414 1330207 110543 2,2,4-Trimethylpentane Other: 540841 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 APEN - Revision ©7/2020 ;COLORADO 5 empamnrta»aUc tMY11aYEntHiwtnw�q Permit Number: 1 8WE1 051 AIRS ID Number: 123 / 9FFB /004 006 [Leave biank unless APCD has already assigned a permit x and AIRS IDI Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 10/22/20 Signature of Legally Authorized Person (not a vendor or consultant) Date Lance King Director of Environment & ROW Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance ✓❑ 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-B1 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 APEN - Revision 07/2020 6 COLORADO Department of Public Nea1tA 6 Eneironmem Hello