HomeMy WebLinkAbout20202104.tiff C ��• COLORADO
i ' -�'' Department of Public
CD?H E Health b Environment
Weld County - Clerk to the Board 1150 O St RECEIVED
PO Box 758
Greeley, CO 80632 MAY 18 2020
May 7, 2020 WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On May 8, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
Confluence DJ, LLC - Pickaroon 7 South. 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 Et 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 r.,,,:cly...s„,,,
7 ` 4�„
Jared Polis,Governor ( Jill Hunsaker Ryan,MPH, Executive Director I A„` ,r• ,.).
cc:PLCTP).HLCJT),
Oblic cl►ieo.0
Pw(ERI Sal ICE-+ ICK) 2020-2104
avootao cc1 (9( O
•
f p
( tt
A CDPHE Gas Venting APEN - Form APCD-\211
CO fit 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 tacks 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 at:www.colorado.gov/cdphe/apcd.
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: 11 Y�f 5 01?)1 AIRS ID Number: 123 /ft OLD CJ 00 t
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 1 -Administrative Information
Company Name': Confluence DJ,LIC
Site Name: Pickaroon 7 South
Site Location
Site Location:
NESE S7 T7N R64W County: Weld
NAICS or SIC Code: 1311
Mailing Address: 100117th Street,Suite 1250
(include Zip Cade)
Denver,CO 80202 Contact Person: Mike Dickinson
Phone Number: (303)226-9517
E-Mail Address`: mdickinson@confluencelp.com
the 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.
Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
402007
till'tR.N
Form APtD-11' Gas Vequrvil APEN - Revistoa -123i , 1 ArM `.,
Permit Number: ,ciL0E.O1,NA AIRS ID Number: 1 / / ocil
(Leave blank unless APCO has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
El NEW permit OR newly-reported emission source
-OR-
❑ MODIFICATION to existing permit Icneck eoch box below that applies)
❑ Change fuel or equipment 0 Change company name3 ❑ Add point to existing permit
❑ Change permit limit 0 Transfer of ownership' 0 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 ft Notes: Temporary separator produced gas flaring until sales gas pipeline is installed.
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: Produced gas controlled by enclosed combustors prior
to gas sales line being installed
Company equipment Identification No. (optional): SEPGAS
For existing sources,operation began on:
For new,modified, or reconstructed sources, the projected start-up date is: 5/9/2019
Q Check this box if operating hours are 8,760 hours per year; if fewer,fill out the fields below:
Normal Hours of Source hours/day days/week weeks/year
Operation:
Will this equipment be operated in any NAAQS 0 Yes ❑ No
nonattainment area?
Is this equipment located at a stationary source that is ❑ Yes ❑ No
considered a Major Source of(HAP)Emissions?
Is this equipment subject to Colorado Regulation No.7. Q Yes ❑ No
Section XVII.G?
ceieratm
Form APCD-211 - Gas Venting APEN• Revision i/201c 2 i .r"""-
Permft Number: MRS ID Number: its Aciaikl 00%
(Leave blank unless APCD has already assigned a permit x and AIRS ID]
Section 4 - Process Equipment Information
0 Gas/Liquid Separator
❑ Welt Head Casing
❑ Pneumatic Pump
Make: Model: Serial#: Capacity: gat/min
❑ Compressor Rod Packing
Make: Model: #of Pistons: Leak Rate: Scf/hr/pist
O Slowdown Events
#of Events/year: Volume per event: MMscf/event
O. Other
Description:
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? 0 Yes O No
Vent Gas lL gTU/SCF
Gas Venting Heating Value: tIsts
Process Parameters: Requested: u•-( MMSCF/year Actual: 3 c MMSCF/year
-OR-
Liquid Throughput
Process Parameters: Requested: bbl/year Actual: bbl/year
Molecular Weight: 3t•4o$V5
VOC (Weight%)
Benzene(Weight%) p.m&
Vented Gas Toluene(Weight%) o ics'
Properties: Ethylbenzene(Weight%) u ohi%
Xylene(Weight%) p,Dyr}
n-Hexane(Weight%) t,,z
2,2,4-Trirnethylpentane(Weight%) 0.17032
Additional Required Information:
0 Attach a representative gas analysis(including BTEX&n-Hexane, temperature,and pressure)
❑ Attach a representative pressurized extended liquids analysis(including BTEX&n-Hexane,temperature,and
pressure)
s Requested values will become permit limitations.Requested limit(s)should consider future process growth.
cot
Form APCD-211 -Gas Venting APEN-Revision 3/2019 3 I Y cot
i.kelAtk5 t.( vLEtc'1 c iCRt 0519511.oio
Permit Number: tIA ." 1-yA- AIRS ID Number: / CX7\
[Leave blank unless APCD has already assigned a permit 0 and AIRS ID)
Section 5 - Stack information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.584640,-104.583890
Discharge Height
Operator Above Ground Level Temp. Flow Rate Velocity
Stack ID No. (F) (ACFhi) (/used
(Feet)
SEPGAS "25 1600 299.76 0.05
Indicate the direction of the stack outlet: (check one)
❑✓ Upward O Downward O Upward with obstructing raincap
O Horizontal ❑Other(describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter(inches): 60"
❑Other(describe):
Section 6 - Control Device Information
O Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section.
Pollutants Controlled:
Size: Make/Model:
❑ VRU:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Pollutants Controlled: VOC&HAPs
Rating: 11.7 MMBtu/hr
Type: ECD Make/Model: (1)Leed L30-0010
Combustion
0 Device: Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: Waste Gas Heat Content: vac. Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: 0.4 MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Requested Control Efficiency:
ce►e
Form APCD-211 -Gas Venting APEN- Revision ±/2019 4 I o
p \.,mac s ,,, 1/414 '4t S psi'% tato
Permit Number: uD AIRS ID Number: ( iActeg OO,
(leave blank unless APCD has already assigned a permit 0 and AIRS ID)
Section 7- Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6. the following table can be used to state the
overall(or combined)control efficiency(%reduction):
Overall Requested
Pollutant Description of Control Methods) Control Efficiency
(%reduction in emissions)
PM
SO. _
NO.
CO
VOC ECD 95%
HAPs ECD 95%
Other:
horn what year is the following reported octual annual emissions data? Projected
Criteria Pollutant Emissions Inventory
Requested Annual Permit
Emission Factor Actual Annual Emissions Emission Limit(s)S
Pollutant
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Basis Units (AP-42, Emissions Emissions6 Emissions Emissions
Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
PM
SO.
NO. 0.068 ib/MMbtu AP-42 a.'•, a3M a A, o3b
CO 0.31 lb/MMbtu AP-42 I g5 _ t.S3 1.144 t Iti
VOC cs5ra7.s4 ib/MMscf �sr t edo,31 %i•31- I ic,.it .4 I S.Z!
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor Actual Annual Emissions
Abstract
Chemical Name Service CAS Uncontrolled Source Uncontrolled Controlled
( ) Basis Units (AP-42, Emissions Emissions6
Number Mfg..etc.) (pounds/year) (pounds/year)
Benzene 71432 w .'s&- lb/MMscf SSEF 5t .1 tt..Z
Toluene 108883 17,...,,5 lb/MMscf SSEF 441%.+1, LA-k9
Ethylbenzene 100414 it.%-t_ Ib/MMsd SSEF 44.1... LL
-
Xylene 1330207 35.1.1 Ib/MMsd SSEF — G1.44 y V _
n-Hexane 110543 1ta '3..4 j t. lb/MMscf qZ tf j3 tgL
2,2,4- 540841 1-12- lb/MMscf SSEF 9°1 o.s
Trimethylpentane ylp
Other:
S Requested values will become permit limitations.Requested limit(s)should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave
blank.
Ay COLOSAte
Form APCD-211 Gas Venting APEN. Revision 1/2014 5 I
1.4.r} Ll v bta apOscr ~ J5 f("17.0210
Permit Number: UDC
0 AIRS iD Number: ( /A / s.,31
[Leave blank unless APCD has already assigned a permit p and AIRS ID]
Section 8-Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true,and correct. (14141). 7/5/2019
Signature of Legally Authorized Pe (not a vendor or consultant) Date
Mike Dickinson Senior Vice President Operations
Name(please 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 5191.13 to: For more information or assistance call:
Colorado Department of Public Health and Environment Small Business Assistance Program
Air Pollution Control Division (303)692-3175 or(303)692-3148
APCD-SS-B1
4300 Cherry Creek Drive South APCD Main Phone Number
Denver,CO 80246-1530 (303)692-3150
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://wvrw.colorado.stov/cdphe/apcd
co►o��eo
Form APCD-211 Gas Venting APEN-Revision 3/2014 6 I Cell02
C -,...,:- COLORADO
'� Air Pollution Control Division
COPHE
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 19WE0737 Issuance: 1
Date issued:
Issued to: Confluence DJ, LLC
Facility Name: Pickaroon 7 South
Plant AIRS ID: 123/A06B
Physical Location: NESE Section 7 T7N R64W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment AIRS Equipment Description Emissions Control
ID Point Description
Low pressure natural gas venting from one Enclosed
SEPGAS 001 (1) high-low pressure (HLP) separator and Combustor(s)
one (1) vapor recovery tower (VRT).
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
this specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days
after commencement of operation under this permit by submitting a Notice of Startup
(NOS) form to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division
of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1
and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must 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
Page 1 of 11
/ -- COLORADO
• j Air Pollution Control Division
%iil Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. Within one hundred and eighty days (18O) after issuance of this permit, the operator must
install a flow meter to monitor and record volumetric flow rate of the commingled low
pressure natural gas vented from HLP and VRT covered by this permit. Until the flow meter is
installed, the operator must monitor and record condensate produced through the separator
and estimate the gas flow rate based on standard cubic feet (scf) per barrel (bbl) of 86.6
scf/bbl estimated in the permit application.
5. The operator must 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.,)
6. 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
7. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO VOC CO Type X
SEPGAS 001 --- --- 5.3 1.8 Point
Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Compliance with the annual limits, for criteria pollutants, must be determined on a rolling
twelve (12) month total. By the end of each month a new twelve month total is calculated
based on the previous twelve months' data. The permit holder must calculate actual
emissions each month and keep a compliance record on site or at a local field office with site
responsibility for Division review.
Page 2 of 11
• -r: COLORADO
Air Pollution Control Division
COFHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
8. The owner or operator must use the emission calculation methods and 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.
9. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment AIRS Control Device Pollutants
ID Point Controlled
SEPGAS 001 Enclosed Combustor(s) VOC and HAP
PROCESS LIMITATIONS AND RECORDS
10. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
Section II.A.4.)
)
Process Limits
Equipment ID AIRS Process Process Parameter Annual Limit
Point
Low pressure natural gas
01 venting from the high-low 4.4 MMSCF
SEPGAS 001 pressure separator and
vapor recovery tower
02 Combustion of pilot light 1.8 MMSCF
gas
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
11. Upon installation of the flow meter, the owner or operator must continuously (i.e. at least
once every 15 minutes) monitor and record the volumetric flow rate of commingled low
pressure natural gas vented from the high-low pressure separator and vapor recovery tower
and routed to the enclosed combustors using an operational continuous flow meter(s). The
flow meter(s) must be installed, calibrated and maintained according to the manufacturer's
specifications. The flow meter(s) must accurately measure and record the maximum and
Page 3 of 11
C -r . COLORADO
S •-�M Air Pollution Control Division
CDPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
minimum potential rates of low pressure natural gas vented from the high-low pressure
separator and vapor recovery tower. 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
12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. 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 must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section 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
15. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or
after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the commencement of operation by air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
16. 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 Ft MAINTENANCE REQUIREMENTS
17. Upon startup of this point, the owner or operator must follow the most recent operating and
maintenance (0&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
Page 4 of 11
C -r•:•M. COLORADO
Air Pollution Control Division
CDGHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
to the 08M 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
18. Within one hundred and eighty days (180) after commencement of operation or issuance of
this permit, whichever comes later, the owner or operator must complete a site specific
extended gas analysis ("Analysis") of the natural gas vented from this emissions unit that is
representative of commingled low pressure HLP separator and VRT waste gas. The sample
shall be analyzed for gross (higher) heat content and total VOC, benzene, toluene,
ethylbenzene, xylenes, n-hexane, and 2,2,4-trimethylpentane content (weight fraction) of
this emission stream. The sample shall be collected prior to the inlet of the enclosed
combustor and prior to being combined with any other 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 submitted to the Division as part of the self-certification and must demonstrate the
emissions factors established through the Analysis are less than or equal to, the emissions
factors 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 factors 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 these inaccuracies.
Periodic Testing Requirements
19. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
Page 5 of 11
•;.:,�- COLORADO
• Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
21. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D, V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Facility Equipment Emissions - tons per year
Equipment ID AIRS Point Description Pollutant Threshold Current
Limit
SEPGAS 001 Separator
Venting
Condensate
COND 002 Storage
Vessels VOC 50 22.3
LO 003 Hydrocarbon
Loadout
VRU1 004 SI RICE
APEN Exempt
Sources
Notes: The APEN exempt sources do not have permit limits. However, the PTE of these sources is still
considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
Page 6 of 11
Cr•:N- COLORADO
Air Pollution Control Division
CDFHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
22. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation 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.
23. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation 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.
24. This permit is issued in reliance upon the accuracy;,and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
25. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
26. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
Page 7 of 11
CCr: COLORADO
'
Air Pollution Control Division
CDFHE
u Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Harrison Slaughter, P.E.
Permit Engineer
Permit History
Issuance Date Description
Issued to Confluence DJ, LLC
Issuance 1 This Issuance Permit for low pressure natural gas venting from
one (1) HLP separator and one (1) VRT at a new
synthetic minor well production facility.
Page 8 of 11
�, N , COLORADO
-'� Air Pollution Control Division
CDPHE
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions.Regulation. Seer https://www.colorado.gov/pacific/cdphe/aqcc-reps
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the sources operates at the permitted
limitations.
Equipment AIRS Uncontrolled Controlled
ID Point Pollutant CAS # Emissions Emissions
((b/yr) (lb/yr)
Benzene 71432 631 32
Toluene 108883 602 30
Ethylbenzene 100414 54 3
SEPGAS 001 Xylenes 1330207 159 8
n-Hexane 110543 4258 219
2,2,4-
540841 12 1
Trimethylpentane
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.
Page 9 of 11
CNV COLORADO
Air Pollution Control Division
COPHE
Department of Public Health&Env ronment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Process 01: Low pressure natural gas venting from one (1) HLP separator and one (1) VRT.
Weight Uncontrolled Controlled
CAS # Fraction of Pollutant Emission Emission Source
Gas (%) Factors Factors
(lb/MMscf) (lb/MMscf)
--- CO 565.88 565.88 AP-42 Chapter
13.5
54.8491 VOC 47,286.54 2364.33 Gas Analysis
71432 0.1662 Benzene 143.32 7.17 Gas Analysis
108883 0.1585 Toluene 136.65 6.83 Gas Analysis
110543 1.121 n-Hexane 966.4 48.32 Gas Analysis
Note: The controlled emissions factors for this point are based on the enclosed combustor(s)control
efficiency of 95%. The site specific VOC and HAP emission factors in the table above are based
on a site specific extended pressurized liquid sample, ProMax and the displacement equation
(EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10). The site
specific extended pressurized liquid sample was obtained from the outlet of the HLP separator
at the Pickaroon 7 South facility on 06/11/2019 and used to specify the parameters in the
ProMax simulation. The sample pressure and temperature are 57.6 psig and 119°F respectively.
The AP-42 Chapter 13.5 CO emission factor (0:31 lb/MMBtu)in the table above was converted
to units of lb/MMscf using a heat content of 1825.42 Btu/scf. Actual emissions must be
calculated by multiplying the emission factors in the table above by the total metered volume
of low pressure natural gas vented from the HLP separators and vapor recovery tower and
combusted by the enclosed combustor(s).
Process 02: Combustion of pilot light gas
Uncontrolled Controlled
CAS # Pollutant Emission Emission Source
Factors Factors
(lb/MMscf) (lb/MMscf)
CO 565.88 565.88 AP-42 Chapter
13.5
VOC 9.84 9.84 AP-42 Chapter 1.4
Table 1.4-2
110543 n-Hexane 3.22 3.22 AP-42 Chapter 1.4
Table 1.4-3
Note: The CO emission factor listed in the table above was obtained by multiplying the AP-42 Chapter
13.5 CO emission factor (0.31 lb/MMBtu) by a heat value of 1,825.42 Btu/scf. The VOC and n-
Hexane emission factors in the table above were obtained by multiplying the AP-42 Chapter 1.4
emission factors by a ratio of 1,825.42 Btu/scf to 1,020 Btu/scf. Actual emissions must be
calculated by multiplying the emission factors in the table above by the total gas flow of the
pilot light. Pilot light gas flow is based on a constant rate of 200 scf/hr for each enclosed
Page 10 of 11
jik —fa COLORADO
Air Pollution Control Division
CDPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
combustor. There is one (1) enclosed combustor used to control emissions from the HLP
separator and vapor recovery tower. Total volume of pilot light gas flow is determined by
monitoring the hours each enclosed combustor operates with an operational pilot light.
Total actual emissions are calculated using the sum of emissions resulting from venting of
low pressure natural gas from the HLP separators and vapor recovery tower and
combustion of waste gas (Process 01) and the combustion of pilot light gas (Process 02)
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC
PSD True Minor Source
NANSR Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the following website: http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 11 of 11
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Harrison Slaughter
Package U: 402010
Received Date: 7/8/2019
Review Start Date: 2/12/2020
Section 01 - Facility Information
Company Name: Confluence DJ, LLC Quadrant Section Township Range
County AIRS ID: 123 NESE 7 7N 64
Plant AIRS ID: A06B
Facility Name: Pickaroon 7 South
Physical
Address/Location : NESE quadrant of Section 7, Township 7N, Range 64W
County: Weld County
Type of Facility: Exploration & Production Well Pad
What industry segment Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non-attainment area? Yes
If yes, for what pollutant? Ozone (NOx & VOC)
Section 02 - Emissions Units In Permit Application
Leave Blank - For Division Use Only
AIRs Point # Permit #
(Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering
Emissions Source Type Equipment Name Action
APCD has already Control? APCD has already # Required? Remarks
assigned) assigned)
Permit Initial
001 Separator Venting SEPGAS Yes 19WE0737 1 Yes Issuance
Section 03 - Description of Project
Confluence DJ, LLC (Confluence) submitted an application requesting permit coverage for separator venting, condensate storage vessels, hydrocarbon loadout
and one (1) spark ignition engine located at a new synthetic minor well production facility located in the ozone non-attainment area. The storage vessels,
loadout and engine are requesting general permit coverage and are not evaluated in this analysis.
The separator venting source is permit required because uncontrolled VOC emissions are greater than 1 tpy (CO AQCC Regulation 3, Part A, Section 11.6.3.x.;. .
Further, the source is permit required because uncontrolled VOC emissions from all APEN required sources at the facility are greater than 2 tpy (CO AQCC
Regulation 3, Part B, Section II.D.2.a.).
Public comment is required for this source because new synthetic minor limits are being established for this source in order to avoid other requirements.
Sections 04, 05 & 06 - For Division Use Only
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requiremer
Was a quantitative modeling analysis required ? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ O ❑
Title V Operating Permits (OP) ❑ ❑ ❑ Q ❑ ❑ O O
Non-Attainment New Source Review (NANSR) O O
Is this stationary source a major source? No
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) ❑ 0 O 0 ❑ ❑
Title V Operating Permits (OP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑
Non-Attainment New Source Review (NANSR) O ❑
Separator Venting Emissions Inventory
Section 01 - Administrative Information
(Facility AIRS ID: 123 A06B 001
County Plant Point
Section 02 - Equipment Description Details
Low pressure natural gas venting from one (1) high-low pressure separator and one (1) vapor recovery tower.
Detailed Emissions Unit Description:
Enclosed Cornbustor(s)
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %: 95
Limited Process Parameter Natural Gas Vented
Gas meter Yes, meter will be installed within 180 days
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput = 3.7 MMscf per year
Requested Permit Limit Throughput = 4.4 MMscf per year Requested Monthly Throughput = 0.4 MMscf per month
Potential to Emit (PTE) Throughput = 4.4 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value: 1825.4 Btu/scf
Volume of waste gas emitted per BBL of
liquids throughput: 86.596 scf/bbl
Control Device
Number of pilot lights 1
Pilot Fuel Use Rate: 200 scfh 1.752 MMscf/yr
Pilot Fuel Gas Heating Value: 1825.42 Btu/scf 3198.13584 MMBtu/yr
Section 04 - Emissions Factors & Methodologies
Description
A commingled liquid stream flows from the wellhead to one (1) HLP separator. The condensate from the HLP separator is sent to one (1) vapor recovery tower for additional two phase separation. The high pressure gas
from the HLP separator is sent to a sales pipeline. The low pressure gas from the HLP separator and vapor recovery tower is commingled and sent directly to the onsite enclosed combustors. The operator obtained a site-
specific pressurized liquid sample on 06/11/2019. The sample temperature and pressure are 119°F and 57.6 psig respectively. This sample was used as the input for a ProMax simulation. The ProMax simulation was used
to determine the molecular weight and composition of the combined low pressure separator and vapor recovery tower waste gas streams. The molecular weight and weight % values from the ProMax simu ation in
conjunction with the displacement equation (EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10) were used to develop emission factors and estimate emissions.
MW 32.6865 Ib/Ib-mol Displacement Equation
Ex = Q • MW • Xx / C
Weight %
Oxygen/Argon 0.00000
CO2 3.27708
N2 0.77842
methane 19.51351
ethane 21.58192
propane 25.43653
isobutane 3.99257
n-butane 12.60360
isopentane 2.91909
n-pentane 3.86281
cyclopentane 0.33933,
n-Hexane 1.12095
cyclohexane 0.39632
Other hexanes 1.92442
heptanes 1.14893
methylcyclohexane 0.00000
224-TM P 0.00316
Benzene 0.16624
Toluene 0.15851
Ethylbenzene 0.01405
Xylenes 0.04175
C8+ Heavies 0.72081
Total 100.0
VOC Wt % 54.84907
2 of 5 C:\Users\hslaught\Desktop\123A068\19WE0737.CP1
Separator Venting Emissions Inventory
Emission Factors Separator Venting
Uncontrolled Controlled
Emission Factor Source
Pollutant (lb/MMscf) (lb/MMscf)
(Gas Throughput) (Gas Throughput)
VOC 47286.5410 2364.3270 Extended gas analysis
Benzene 143.3173 7.1659 Extended gas analysis
Toluene 136.6507 6.8325 Extended gas analysis
Ethylbenzene 12.1158 0.6058 Extended gas analysis
Xylene 35.9935 1.7997 Extended gas analysis
n-Hexane 966.3962 48.3198 Extended gas analysis
M
224 TMP 2.7225 0.1361 Extended gas analysis
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
PM10 0.0075 13.6012 AP-42 Table 1.4-2 (PM10/PM.2.5)
PM2.5 0.0075 13.6012 AP-42 Table 1.4-2 (PM10/PM.2.5)
SOx 0.0006 1.0738 AP-42 Table 1.4-2 (5Ox)
NOx 0.0680 124.1286 AP-42 Chapter 13.5 Industrial Flares (NOx)
CO 0.3100 565.8802 AP-42 Chapter 13.5 Industrial Flares (CO)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Pilot Gas Throughput)
PM10 0.0075 13.6012 AP-42 Table 1.4-2 (PM10/PM.2.5)
PM2.5 0.0075 13.6012 AP-42 Table 1.4-2 (PM10/PM.2.5)
SOx 0.0006 1.0738 AP-42 Table 1.4-2 (5Ox)
NOx 0.0680 124.1286 AP-42 Chapter 13.5 Industrial Flares (NOx)
CO 0.3100 565.8802 AP-42 Chapter 13.5 Industrial Flares (CO)
VOC 0.0054 9.8430 AP-42 Table 1.4-2 (VOC)
n-Hexane 0.0018 3.2213 AP-42 Table 1.4-3 (n-Hexane)
Section 05 - Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month)
PM10 0.042 0.037 0.037 0.042 0.042 7
PM2.5 0.042 0.037 0.037 0.042 0.042 7
SOx 0.003 0.003 0.003 0.003 0.003 1
NOx 0.382 0.335 0.335 0.382 0.382 65
VOC 104.039 86.307 4.324 104.039 5.210 885
CO 1.741 1.528 1.528 1.741 1.741 296
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 630.60 523.11 26.16 630.60 31.53
Toluene 601.26 498.78 24.94 601.26 30.06
Ethylbenzene 53.31 44.22 2.21 53.31 2.67
Xylene 158.37 131.38 6.57 158.37 7.92
n-Hexane 4257.79 3532.99 182.01 4257.79 218.25
224 TMP 11.98 9.94 0.50 11.98 0.60
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B Source requires a permit
Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVIl.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
:4 `5
Does the company use site specific emission factors based on a gas sample to estimate emissions? �y
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 90 tons per year? x ,.� ' ' ->1.r'c �
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? No
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? ` z
If yes, the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on
inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.
3 of 5 C:\Users\hslaught\Desktop\123A06B\19WE0737.CP1
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
1. The operator obtained a site-specific pressurized liquid sample on 06/11/2019. The sample temperature and pressure are 119°F and 57.6 psig respectively. This sample was used as the input for a ProMax simulation. The ProMax
simulation was used to determine the molecular weight and composition of the combined low pressure separator and vapor recovery tower waste gas streams. The molecular weight and weight % values from the ProMax simulation in
conjunction with the displacement equation (EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10) were used to develop emission factors and estimate emissions. Since ongoing compliance is demonstrated
by tracking gas throughput, the operator will be required to obtain an initial sample that is representative of only low pressure separator and VRT gas in order to demonstrate the initially developed emission factors are accurate or
conservative.
2. According to the application, one (1) well produces to the HLP separator located at this facility. The well name and API number is as follows: (i) Pickaroon 1t7-14-2L (05-123-48022). According to COGCC data, this well was fractured in
December 2018 and began production in February 2019. As a result, the gas vented from the separators is subject to Regulation 7 Part D Section II.F.
3. The permit will not contain initial or periodic testing for opacity because the O&M plan addresses visible emissions observations that must be conducted on a weekly basis.
4. Pilot light emissions associated with the enclosed combustors contribute to the overall emission limits for this source. As a result, the permit contains a process limit for use of pilot fuel and emission factors for calculating emissions
associated with combustion of pilot fuel. It should be noted that the enclosed combustors also control emissions from the condensate storage vessels, produced water storage vessels and hydrocarbon loadout. According to engineer
guidance, pilot light emissions should be grouped with the highest emitting source that is covered by an individual permit. In this case, the highest emitting source is the separator venting source.
5. The operator indicated that the enclosed combustor used to control emissions from this source has a pilot fuel use rate cf 200 scf/hr. The pilot light gas rate is sent to the enclosed combustor at a constant rate and is not metered. As a
result, the operator will be required to monitor the hours of combustor operation and use a constant pilot light gas rate of 200 scf/hr in order to track compliance with the pilot light gas combustion process limit contained in the permit.
6. Ethylbenzene, xylene and 2,2,4-TMP emissions are below APEN reporting thresholds. As a result, an emission factor for these pollutants will not be included in the permit.
7. Generally, HLP separators and vapor recovery towers are not allowed to be grouped for permitting purposes. This is due to the fact that the emissions profile for each source is drastically different. Further, the control scenarios for
these two units is typically different. In this case, it was determined that the low pressure gas vented from the HLP separator and VRT could be grouped for permitting for the following reasons: (i) The low pressure gas from the HLP
separator and low pressure gas from the VRT is sent to the enclosed combustors at all times. As a result, the total volume of low pressure waste gas vented from the HLP separator is indistinguishable from the total volume of waste gas
vented from the VRT. (ii) The operator is capable of obtaining and will be required to obtain an initial sample of commingled low pressure separator and VRT gas in order to demonstrate the emission factors established in this analysis are
either accurate or conservative. If this control scenario changes in the future (i.e. due to addition of a pipeline or vapor recovery units), this source grou ping may no longer be acceptable. The next engineer that evaluates this facility
must confirm the waste gas streams from the HLP separator and VRT remain indistinguishable in order to maintain the source grouping.
8. Engineering guidance indicates that NOx and CO emissions from each source controlled by a common control device need to be added together to evaluate APEN applicability. Total CO emissions from all sources at this facility that are
controlled by the enclosed combustor (produced water storage vessels, condensate storage vessels, separator venting and hydrocarbon loadout) are greater than APEN thresholds. Total NOx emissions from all sources at this facility that
are controlled by the enclosed combustor (produced water storage vessels, condensate storage vessels, separator venting and hydrocarbon loadout) are less than APEN thresholds. As a result, this permit will only contain a limit and
emission factors for CO.
9. The pressurized liquid sample was obtained from the outlet of the HLP separator at this facility. As a result, the ProMax simulation would normally be set up with the HLP outlet stream specified using the information from the sample.
In this case, the operator specified the sample as the inlet to the low pressure separator in the ProMax simulation. This was done in order to obtain the composition of the low pressure gas vented from the HLP separator. Since the
operator demonstrated this simulation design was conservative for the storage vessels, it was accepted for developing emission factors and emissions for this source as well. As discussed above, the operator will be required to obtain an
initial commingled low pressure separator and vapor recovery gas sample in order to demonstrate the emission factors developed through this analysis are either conservative or accurate. This initial compliance demonstration further
supports the decision to accept the simulation design for initial permitting purposes.
10. The operator was provided with a draft permit and APEN redline to review prior to public comment. The operator reviewed both documents and expressed they had no comments.
Section 09 - Inventory SCC Coding and Emissions Factors
Uncontrolled Emissions
AIRS Point tf Process # SCC Code Pollutant Factor Control % Units
001 01 3-10-001-60 Flares PM10 13.6 0 lb/MMSCF
PM2.5 13.6 0 Ib/MMSCF
SOx 1.1 0 lb/MMSCF
NOx 124.1 0 Ib/MMSCF
VOC 47286.5 95 Ib/MMSCF
CO 565.9 0 lb/MMSCF
Benzene 143.3 95 lb/MMSCF
Toluene 136.7 95 Ib/MMSCF
Ethylbenzene 12.1 95 Ib/MMSCF
Xylene 36.0 95 Ib/MMSCF
n-Hexane 966.4 95 Ib/MMSCF
224 TMP 2.7 95 Ib/MMSCF
02 PM10 13.6012 0 Ib/MMSCF
PM2.5 13.6012 0 lb/MMSCF
SOx 1.0738 0 Ib/MMSCF
NOx 124.1286 0 Ib/MMSCF
CO 565.8802 0 Ib/MMSCF
VOC 9.8430 0 lb/MMSCF
n-Hexane 3.2213 0 lb/MMSCF
'Process 02 represents emission factors used for pilot light combustion.
4 of 5 C:\Users\hslaught\Desktop\123A06B\19WE0737.CP1
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Re ulation 3 Parts A and B - APEN and Permit R uirements
Sourer :14- the Non-Attamrnenr Area
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.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 B, Section II.D.3)? 11111
You have Indicated that source ts in the Yon-Attalnmcnt Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Source Requires an APEN Go to the next question
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than S TPY or CO emissions greater than 10 WY (Regulation 3, Part B, Section II.D.2)? Yes Source Requires a permit
Source r rquir es a petni.t
Colorado Regulation 7,Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes Source is subject, go to next question
Source is subject to Regulation 7, Section XV1{.B.2, G
Section XVII.B2-General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XV1I.G - Emissions Control
Alternative Emissions Control (Optional Section)
a Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? ' '• .:2_w_ The control device for this separator is not subject to Regulation 7, Section XVII B.2.e
The control device for this separator ;s not subject to Regulation 7. Section XVR 9.2 e
Section XV11.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 anaysrs 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 or regulation will control. Tne 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.
)
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name Confluence DJ,LLC
County AIRS ID 123 Hlsiory File Edit Date 5152020
Plant AIRS ID A06B Ozone Status Non Attainment
Fanldy Name Prckaroon 7 South
EMISSIONS Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2 5 H2S SO2 NOx VOC Fug CO Total PM10 PM2 5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS ID VOC HAPs VOC HAPs
Previous FACILITY TOTAL 00 00 00 00 00 00 00 0.0 00 00 00 00 00 00 00 00 00 00 New FacfN No Previous Total
Prom's Pemuaed Faa7, 10141 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 NewFadfry No Previous Total
001 19WE0737 Lou pressure newrel gas ventrrg from 00 00 00 04 1040 18 29 00 00 00 04 5.3 18 01 New Source
one(1)HLP separator and one(1)
VRT
002 GPOB Three(3)538 barrel fbred roof storage 01 30.8 0 3 0 6 0 1 59 03 0 0 New Source GP08 approval letter issued SSEF
vessels dovotoped end approved
003 GP07 Hydrocarbon Loadom 0.0 80 01 01 00 100 01 00 New Source GP07 approval letter issued
004 GP02 SI RICE GMVorIec 57L,4SRB 92 01 01 124 07 98 01 01 01 09 07 18 01 New Source engine used for compression GP02
HP,SN 10CHMM410510053 approval letter issued
XA Fugitives 01 00 01 00 Insignificant Source
XA One(1)0625MMBlu/hr separator 00 00 04 00 03 00 00 00 04 00 03 00 Insgnrficant Source
bumer
XA Pneumatic controllers 04 00 04 ES lnspnrficent Source
XA One(1)500bbl fixed root produced 00 0.2 00 00 00 00 00 00 insignificant Source
water storage vessel
00 00
00 00
00 00
00 00
FACILITY TOTAL 01 01 00 00 133 1421 01 122 37 01 01 00 00 17 223 01 43 03 VOC Syn Minor(NANSR and OP)
NOx True Minor(PSD NANSR and OP)
CO True Minor(POD and OP)
HAPS True Minor
HH Area source no affected sources
2272 Area source
Pounded FaWdv Total 01 01 00 00 129 1415 00 119 37 01 01 00 00 14 219 00 3.9 03 Excludes ands exempt frompemids/APENs
(A)Change in Permitted Emissions 01 01 00 00 14 219 00 39 Modeling not required based on A change in
emissions Pubcom is required b/c new syn minor
limits are being established
Total VOC Facility Emissions(point and 105000) 22 4 Fealty is elgale for GP02 because<90 tpy CO
and<45 tpy(NO4&VOC)
(A)Change In Total Permitted VOC emissions(putt and(ugdrve) 219 Project emissions less than 25 tpy(Nox 5 VOC)and
less then 50 tpy
Note 1
Note 2
Page I of 2
Printed 5/5/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - IIAPs
Company Name Confluence DJ, LLC
County MRS ID 123
Plant AIRS ID A06B
Facility Name Pickaroon 7 South
Emissions - uncontrolled (lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy)
Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 , 0 0.0
001 19WE0737 Low pressure natural gas venting from 631 602 54 159 4258 12 2.9
one (1) HLP separator and one (1) VRT
002 GP08 Three (3) 538 barrel fixed roof storage 121.3 98 7.8 24.2 978.1 2.4 0.6
vessels
003 GP07 Hydrocarbon Loadout 21.1 182.8 0.1
004 GP02 SI RICE GM Vortec 5.7L, 4SRB, 92 HP, 148.7 20.2 19.1 11.5 22.2 0.1
SN: 10CHMM410510053
XA Fugitives 1 4 0.0
XA One (1) 0.625 MMBtu/hr separator 0.0
burner
XA Pneumatic controllers 2.3 15.3 0.0
XA One (1) 500 bbl fixed roof produced 6 3 5.2 OA 1.4 15.5 0.0
water storage vessel
0.0
0.0
0.0
0.0
TOTAL (tpy) 0.1 0.0 0.0 0.4 0.4 0.0 0.1 2.7 0.0 0.0 0.0 0.0 3.7
*Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
Emissions with controls (lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy)
'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 19WE0737 Low pressure natural gas venting from 32 30 3 8 219 1 0.1
one (1) HLP separator and one (1) VRT
002 GP08 Three (3) 538 barrel fixed roof storage 6.1 4.9 0.4 1.2 48.9 0.1 0.0
vessels
003 GP07 Hydrocarbon Loadout 1 1 9.1 0.0
004 GP02 SI RICE GM Vortec 5.7L, 4SRB, 92 HP, 148.7 20 2 19.1 11.5 22 2 0.1
SN: 10CHMM410510053
XA Fugitives 1 4 0.0
XA One (1) 0.625 MMBtuihr separator 0.0
burner
XA Pneumatic controllers 2.3 15.3 0.0
XA One (1) 500 bbl fixed roof produced 0 3 0.3 0.0 0.1 0.8 0.0
water storage vessel
0.0
0.0
I
0.0
0.0 •
TOTAL (tpy) 0.1 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.0 0.0 0.0 0.0 0.3
2 123A06R 5/5/2020
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Harrison Slaughter
Package #: 402010
Received Date: 7/8/2019
Review Start Date: 2/12/2020
Section 01 - Facility Information
Company Name: Confluence DJ, LLC Quadrant Section Township Range
County AIRS ID: 123 NESE 7 7N 64
Plant AIRS ID: A06B
Facility Name: Pickaroon 7 South
Physical
Address/Location : NESE quadrant of Section 7, Township 7N, Range 64W
County: (Weld County
Type of Facility: Exploration & Production Well Pad
What industry segmentiOil & Natural Gas Production & Processing
Is this facility located in a NAAQS non-attainment area? Yes
If yes, for what pollutant? Ozone (NOx & VOC)
Section 02 - Emissions Units In Permit Application
Leave Blank - For Division Use Only
AIRs Point # Permit #
(Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering
Emissions Source Type Equipment Name Action
APCD has already Control? APCD has already # Required? Remarks
assigned) assigned)
Permit Initial
001 Separator Venting SEPGAS Yes 19WE0737 1 Yes Issuance
Section 03 - Description of Project
Confluence DJ, LLC (Confluence) submitted an application requesting permit coverage for separator venting, condensate storage vessels, hydrocarbon loadout
and one (1) spark ignition engine located at a new synthetic minor well production facility located in the ozone non -attainment area. The storage vessels,
loadout and engine are requesting general permit coverage and are not evaluated in this analysis.
The separator venting source is permit required because uncontrolled VOC emissions are greater than 1 tpy (CO AQCC Regulation 3, Part A, Section II.B.3.a.).
Further, the source is permit required because uncontrolled VOC emissions from all APEN required sources at the facility are greater than 2 tpy (CO AQCC
Regulation 3, Part B, Section II .D.2.a.).
Public comment is required for this source because new synthetic minor limits are being established for this source in order to avoid other requirements.
Sections 04, 05 & 06 - For Division Use Only
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requiremer
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑
Title V Operating Permits (OP) ❑ ❑ ❑ 0 ❑ ❑ ❑ ❑
Non-Attainment New Source Review (NANSR) ❑ 0
Is this stationary source a major source? No
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑
Title V Operating Permits (OP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑
Non-Attainment New Source Review (NANSR) ❑ ❑
Separator Venting Emissions Inventory
Section 01 - Administrative Information
123 A06B 001
Facility AIRS ID:
County Plant Point
Section 02 - Equipment Description Details
Low pressure natural gas venting from one (1) high-low pressure separator and one (1) vapor recovery tower.
Detailed Emissions Unit Description:
Enclosed Combustor(s)
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %: 95
Limited Process Parameter Natural Gas Vented
Gas meter Yes, meter will be installed within 180 days
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput = 3.7 MMscf per year
Requested Permit Limit Throughput = 4.4 MMscf per year Requested Monthly Throughput = 0.4 MMscf per month
Potential to Emit (PTE) Throughput = 4.4 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value: 1825.4 Btu/scf
Volume of waste gas emitted per BBL of
liquids throughput: 86.596 scf/bbl
Control Device
Number of pilot lights 1
Pilot Fuel Use Rate: 200 scfh 1.752 MMscf/yr
Pilot Fuel Gas Heating Value: 1825.42 Btu/scf 3198.13584 MMBtu/yr
Section 04 - Emissions Factors & Methodologies
Description
A commingled liquid stream flows from the wellhead to one (1) HLP separator. The condensate from the HLP separator is sent to one (1) vapor recovery tower for additional two phase separation. The high pressure gas
from the HLP separator is sent to a sales pipeline. The low pressure gas from the HIP separator and vapor recovery tower is commingled and sent directly to the onsite enclosed combustors. The operator obtained a site-
specific pressurized liquid sample on 06/11/2019. The sample temperature and pressure are 119°F and 57.6 psig respectively. This sample was used as the input for a ProMax simulation. The ProMax simulation was used
to determine the molecular weight and composition of the combined low pressure separator and vapor recovery tower waste gas streams. The molecular weight and weight % values from the ProMax simulation in
conjunction with the displacement equation (EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10) were used to develop emission factors and estimate emissions.
MW 32.6865 Ib/Ib-mol Displacement Equation
Ex = Q MW • Xx / C
Weight %
Oxygen/Argon 0.00000
CO2 3.27708
N2 0.77842
methane 19.51351
ethane 21.58192
propane 25.43653
isobutane 3.99257
n-butane 12.60360
isopentane 2.91909
n-pentane 3.86281
cyclopentane 0.33933
n-Hexane 1.12095
cyclohexane 0.39632
Other hexanes 1.92442
heptanes 1.14893
methylcyclohexane 0.00000
224-TMP 0.00316
Benzene 0.16624
Toluene 0.15851
Ethylbenzene 0.01405
Xylenes 0.04175
CS+ Heavies 0.72081
Total 100.0
VOC Wt % 54.84907
2 of 5 C:\Users\hslaught\Desktop\123A06B\19WE0737.CP1
Separator Venting Emissions Inventory
Emission Factors Separator Venting
Uncontrolled Controlled
Emission Factor Source
Pollutant (lb/MMscf) (Ib/MMscf)
(Gas Throughput) (Gas Throughput)
VOC 47286.5410 2364.3270 Extended gas analysis
Benzene 143.3173 7.1659 Extended gas analysis
Toluene 136.6507 6.8325 Extended gas analysis
Ethylbenzene 12.1158 0.6058 Extended gas analysis
Xylene 35.9935 1.7997 Extended gas analysis
n-Hexane 966.3962 48.3198 Extended gas analysis
224 TMP 2.7225 0.1361 Extended gas analysis
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
PM10 0.0075 13.6012 AP-42 Table 1.4-2 (PM10/PM.2.5)
PM2.5 0.0075 13.6012 AP-42 Table 1.4-2 (Ph110/PM.2.5)
SOx 0.0006 1.0738 AP-42 Table 1.4-2 (SOx)
NOx 0.0680 124.1286 AP-42 Chapter 13.5 Industrial Flares (NOx)
CO 0.3100 565.8802 AP-42 Chapter 13.5 Industrial Flares (CO)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Pilot Gas Throughput)
PM10 0.0075 13.6012 AP-42 Table 1.4-2 (PM10/PM.2.5)
PM2.5 0.0075 13.6012 AP-42 Table 1.4-2 (PM10/PM.2.S)
SOx 0.0006 1.0738 AP-42 Table 1.4-2 (SOx)
NOx 0.0680 124.1286 AP-42 Chapter 13.5 Industrial Flares (NOx)
CO 0.3100 565.8802 AP-42 Chapter 13.5 Industrial Flares (CO)
VOC 0.0054 9.8430 AP-42 Table 1.4-2 (VOC)
n-Hexane 0.0018 3.2213 AP-42 Table 1.4-3 (n-Hexane)
Section 05 - Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month)
PM10 0.042 0.037 0.037 0.042 0.042 7
PM2.5 0.042 0.037 0.037 0.042 0.042 7
SOx 0.003 0.003 0.003 0.003 0.003 1
NOx 0.382 0.335 0.335 0.382 0.382 65
VOC 104.039 86.307 4.324 104.039 5.210 885
CO 1.741 1.528 1.528 1.741 1.741 296
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 630.60 523.11 26.16 630.60 31.53
Toluene 601.26 498.78 24.94 601.26 30.06
Ethylbenzene 53.31 44.22 2.21 53.31 2.67
Xylene 158.37 131.38 6.57 158.37 7.92
n-Hexane 4257.79 3532.99 182.01 4257.79 218.25
224 TMP 11.98 9.94 0.50 11.98 0.60
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B Source requires a permit
Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
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? MEI
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 90 tons per year? RUMIRISI
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? No
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 2 CC p y q greater than 95% for a flare or combustion device. . ... _ -�..
If yes, the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on
inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.
3 of 5 C:\Users\hslaught\Desktop\123A066\19WE0737.CP1
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
1. The operator obtained a site-specific pressurized liquid sample on 06/11/2019. The sample temperature and pressure are 119°F and 57.6 psig respectively. This sample was used as the input for a ProMax simulation. The ProMax
simulation was used to determine the molecular weight and composition of the combined low pressure separator and vapor recovery tower waste gas streams. The molecular weight and weight % values from the ProMax simulation in
conjunction with the displacement equation (EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10) were used to develop emission factors and estimate emissions. Since ongoing compliance is demonstrated
by tracking gas throughput, the operator will be required to obtain an initial sample that is representative of only low pressure separator and VRT gas in order to demonstrate the initially developed emission factors are accurate or
conservative.
2. According to the application, one (1) well produces to the HLP separator located at this facility. The well name and API number is as follows: (i) Pickaroon #7-14-2L (05-123-48022). According to COGCC data, tnis well was fractured in
December 2018 and began production in February 2019. As a result, the gas vented from the separators is subject to Regulation 7 Part D Section II.F.
3. The permit will not contain initial or periodic testing for opacity because the O&M plan addresses visible emissions observations that must be conducted on a weekly basis.
4. Pilot light emissions associated with the enclosed combustors contribute to the overall emission limits for this source. As a result, the permit contains a process limit for use of pilot fuel and emission factors for calculating emissions
associated with combustion of pilot fuel. It should be noted that the enclosed combustors also control emissions from the condensate storage vessels, produced water storage vessels and hydrocarbon loadout. According to engineer
guidance, pilot light emissions should be grouped with the highest emitting source that is covered by an individual permit. In this case, the highest emitting source is the separator venting source.
5. The operator indicated that the enclosed combustor used to control emissions from this source has a pilot fuel use rate of 200 scf/hr. The pilot light gas rate is sent to the enclosed combustor at a constant rate and is not metered. As a
result, the operator will be required to monitor the hours of combustor operation and use a constant pilot light gas rate of 200 scf/hr in order to track compliance with the pilot light gas combustion process limit contained in the permit.
6. Ethylbenzene, xylene and 2,2,4-TMP emissions are below APEN reporting thresholds. As a result, an emission factor for these pollutants will not be included in the permit.
7. Generally, HLP separators and vapor recovery towers are not allowed to be grouped for permitting purposes. This is due to the fact that the emissions profile for each source is drastically different. Further, the control scenarios for
these two units is typically different. In this case, it was determined that the low pressure gas vented from the HLP separator and VRT could be grouped for permitting for the following reasons: (i) The low pressure gas from the HLP
separator and low pressure gas from the VRT is sent to the enclosed combustors at all times. As a result, the total volume of low pressure waste gas vented from the HLP separator is indistinguishable from the total volume of waste gas
vented from the VRT. (ii) The operator is capable of obtaining and will be required to obtain an initial sample of commingled low pressure separator and VRT gas in order to demonstrate the emission factors established in this analysis are
either accurate or conservative. If this control scenario changes in the future (i.e. due to addition of a pipeline or vapor recovery units), this source grou ping may no longer be acceptable. The next engineer that evaluates this facility
must confirm the waste gas streams from the HLP separator and VRT remain indistinguishable in order to maintain the source grouping.
8. Engineering guidance indicates that NOx and CO emissions from each source controlled by a common control device need to be added together to evaluate APEN applicability. Total CO emissions from all sources at this facility that are
controlled by the enclosed combustor (produced water storage vessels, condensate storage vessels, separator venting and hydrocarbon loadout) are greater than APEN thresholds. Total NOx emissions from all sources at this facility that
are controlled by the enclosed combustor (produced water storage vessels, condensate storage vessels, separator venting and hydrocarbon loadout) are less than APEN thresholds. As a result, this permit will only contain a limit and
emission factors for CO.
9. The pressurized liquid sample was obtained from the outlet of the HLP separator at this facility. As a result, the ProMax simulation would normally be set up with the HLP outlet stream specified using the information from the sample.
In this case, the operator specified the sample as the inlet to the low pressure separator in the ProMax simulation. This was done in order to obtain the composition of the low pressure gas vented from the HLP separator. Since the
operator demonstrated this simulation design was conservative for the storage vessels, it was accepted for developing emission factors and emissions for this source as well. As discussed above, the operator will be required to obtain an
initial commingled low pressure separator and vapor recovery gas sample in order to demonstrate the emission factors developed through this analysis are either conservative or accurate. This initial compliance demonstration further
supports the decision to accept the simulation design for initial permitting purposes.
10. The operator was provided with a draft permit and APEN redline to review prior to public comment. The operator reviewed both documents and expressed they had no comments.
Section 09 - Inventory SCC Coding and Emissions Factors
Uncontrolled Emissions
AIRS Point # Process # 5CC Code Pollutant Factor Control % Units
001 01 3-10-001-60 Flares PM10 13.6 0 lb/MMSCF
PM2.5 13.6 0 Ib/MMSCF
SOx 1.1 0 lb/MMSCF
NOx 124.1 0 lb/MMSCF
VOC 47286.5 95 lb/MMSCF
CO 565.9 0 lb/MMSCF
Benzene 143.3 95 Ib/MMSCF
Toluene 136.7 95 Ib/MMSCF
Ethylbenzene 12.1 95 lb/MMSCF
Xylene 36.0 95 lb/MMSCF
n-Hexane 966.4 95 Ib/MMSCF
224 TMP 2.7 95 Ib/MMSCF
02 PM10 13.6012 0 Ib/MMSCF
PM2.5 13.6012 0 Ib/MMSCF
SOx 1.0738 0 Ib/MMSCF
NOx 124.1286 0 lb/MMSCF
CO 565.8802 0 Ib/MMSCF
VOC 9.8430 0 Ib/MMSCF
n-Hexane 3.2213 0 lb/MMSCF
'Process 02 represents emission factors used for pilot light combustion.
4 of S C:\Users\hslaught\Desktop\123A06B\19WE0737.CP1
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado lotion a A and B•AP and Permit R ukemen
Source is In the Non-Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 WY(Regulation 3, Part A,Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than S WY, NOx greater than 10 TPY or CO emissions greater than 10 WY (Regulation 3, Part B,Section 11.0.3)?
You have indicated that source Is in the Non-Attainment Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A,Section II.D.1.a)? y Source Requires an APEN. Go to the next question
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 WY (Regulation 3, Part B,Section 11.0.2)? es' Source Requires a permit
Source requires a permit
Colorado Regulation 7.Section XVII
1. Was the well newly constructed, hydraulically fractured,or recompleted on or after August 1,2014? yes r Source is subject,go to next question
Source is subject to Regulation 7, Section XV11.B.2, 6
Section XVII.B2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e.,not the primary control device)that is not enclosed? The control device for th s separator is not subject to Regulation 7,Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2 e
Section XV1I.B.2.e—Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of canal,requirements of the Clean Air Act, is implementing regulations, and Air Quality Control Commission regulations. This document is
not a rude or regulation, and the analysis 4 contains may not apply toe 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„ as
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 descnbe 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.
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name Confluence DI,LLC _
Courtly AIRS ID 123 History File Edit Date 5150020
Plant AIRS ID AO6B Ozone Status Non Attainment
Faalrty Name Pickaroon 7 South
EMISSIONS Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM25 H2S SO2 0100 VOC Fug CO Total PM10 PM25 H2S SO2 NO: VOC Fug CO Total REMARKS
AIRS ID VOC HAPs VOC HAPs
Previous FACILITY TOTAL 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 New Facility No Previous Total
Prances Pematted FaohlylOlal 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 New Facility No Previous Total
001 19WE0737 Lew pressure natural gas venteg horn 00 00 00 04 1040 18 29 00 00 00 04 53 18 01 New Source
one(11 HLP separator and one(1)
VRT
002 GP08 'three(3)538 barrel feed roof storage 01 300 0.3 O6 01 59 0.3 00 New Source GP08 approval letter issued SSEF
vessels — developed and approved
003 GP07 Hydrocarbon Loadout 00 E0 01 01 00 100 01 00 New Source GP07 approval letter issued
004 GP02 SI RICE GMVodec 57L 4SRB 92 01 01 124 07 98 01 01 01 09 07 18 01 New Source engine used for compression GP02
HP,SN 10CHMM410510053 approval letter issued
OA Fugitives 01 00 01 O O Insignificant Source
OA One(1)0625MMBtuOu separator 00 00 04 00 03 00 00 00 04 00 03 O O Insgnrfirant Source
bumer
%A Pneumatic controllers 04 - 00 04 00 Insignificant Source
%A One(1)500 bblfxed roof produced 00 02 00 00 00 00 00 00 Insignificant Source
water storage vessel
00 00
00 00
00 00
00 00
FACILITY TOTAL 01 01 0O 00 133 1421 01 122 37 01 01 00 00 17 22.3 01 43 03VOC Syn Minor(NANSR and OP)
NOx True Minor IPSO NANSR and OP)
CO True Minor IPSO and OP)
HAPS True Minor
HO Area source no affected sources
2222 Area source
Penndled Facility Total 01 01 00 00 129 1415 00 119 37 01 01 00 00 14 219 00 39 03 Excludes ends exempt tram pemels/APENs
(A)Change in Permitted Emissions 01 01 00 00 14 21 9 0 0 39 Modeling not required based on A change in
emissions Pubcom Is required b/c new sr minor
limns am being established
Total VOC Facility Emissions(point and fugewe) 22.4 Faonty is enable for GP02 because<90 tpy CO
and<45 lay(NO: VOC)
(A)Change in Total Permitted VOC emissions(pomt and Waive) 219 Protect emissions less than 25 1py(Nox 8 VOC)and
less then 50 tpy
Note 1
Note 2
1
Page 1 oft Panted 5/3/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - !lAP,
Company Name Confluence DJ, LLC
County AIRS ID 123
Plant AIRS ID A06B
Facility Name Pickaroon 7 South
Emissions - uncontrolled (lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy)
Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 19W E0737 Low pressure natural gas venting from 631 602 54 159 4258 12 2.9
one (1) HLP separator and one (1) VRT
002 GP08 Three (3) 538 barrel fixed roof storage 121.3 98 7.8 24.2 978.1 2.4 0.6
vessels
003 GP07 Hydrocarbon Loadout 21.1 182.8 0.1
004 GP02 SI RICE GM Vortec 5.7L, 4SRB, 92 HP, 148.7 20.2 19.1 11.5 22.2 0.1
SN: 10CHMM410510053 .
XA Fugitives 1 4 0.0
XA One (1) 0.625 MMBtu/hr separator 0.0
burner
XA Pneumatic controllers 2.3 15.3 0.0
XA One (1) 500 bbl fixed roof produced 6.3 5.2 0.4 1.4 15 5 0.0
eater storage vessel
0.0
0.0
0.0
0.0
TOTAL (tpy) 0.1 0.0 0.0 0.4 0.4 0.0 0.1 2.7 0.0 0.0 0.0 0.0 3.7
'Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
Emissions with controls (lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy)
!Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 19WE0737 Low pressure natural gas venting from 32 30 3 8 219 1 0.1
one (1) HLP separator and one (1) VRT
002 GP08 Three (3) 538 barrel fixed roof storage 6.1 4.9 0.4 1.2 48.9 0.1 0.0
vessels
003 GP07 Hydrocarbon Loadout 1 1 9.1 0.0
004 GP02 SI RICE GM Vortec 5.7L, 4SR8, 92 HP, 148.7 20.2 19.1 11 .5 22 2 0.1
SN: 10CHMM410510053
XA Fugitives 1 4 0.0
XA One (1) 0.625 MMBtu/hr separator 0.0
burner
XA Pneumatic controllers 2.3 15.3 0.0
XA One (1) 500 bbl fixed roof produced 0.3 0 3 0.0 0.1 0.8 0.0
water storage vessel
0.0
0.0
0.0
0.0
TOTAL (tpy) 0.1 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.0 0.0 0.0 0.0 0.3
2 123A06B 5/5/2020
.MIM#1Control Div1 1 n
ll tl n s o
� r P
o u ®
Notice of a Proposed Project or Activity Warranting Public
CDPHE
TM Comment
Website Title : Confluence DJ , LLC - Pickaroon 7 South - Weld County
Notice Period Begins : May 8 , 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 : Confluence DJ , LLC
Facility : Pickaroon 7 South
Well Production Facility
NESE of Section 7 , Township 7N , Range 64W
Weld County
The proposed project or activity is as follows : Confluence DJ , LLC is requesting permit coverage for low
pressure natural gas flaring from one ( 1 ) high - low pressure separator and one ( 1 ) vapor recovery tower at a
new synthetic minor oil and gas well production facility located in the ozone non - attainment area .
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 19WE0737 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 wilt 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 . aov / 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 :
Harrison Slaughter , P . E .
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South , APCD - SS - B1
Denver , Colorado 80246 - 1530
,-:1 COLORADO
Department Public
1 I C°�' Health b Environofment
Hello