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Home My WebLink About20202105.tiff COLORADO Department of Public Health Es Environment Weld County - Clerk to the Board RECEIVED 1150O St PO Box 758 MAY 2 2 2020 Greeley, CO 80632 WELD COUNTY May 13, 2020 COMMISSIONERS Dear Sir or Madam: On May 14, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Kerr- Mcgee Oil and Gas Onshore LP - 36112551. 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 &t 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 C. Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director * ,* R,1O1 i C Cc.: PLCTP), Hc.CY ), al 1�© 0'10 P _cJ-m, ER IC 4-I rct4) 2020-2105 07/lr-1 I(DO .40r:4M> Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public iln CDPHE Comment Website Title: Kerr-Mcgee Oil and Gas Onshore LP - 36112551 - Weld County Notice Period Begins: May 14, 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: Kerr-Mcgee Oil and Gas Onshore LP Facility: 36112551 Exploration and Production Well Pad NENE Section 26 T3N R66W Weld County The proposed project or activity is as follows: This source completed initial sampling per the initial permit issuance and received sampling that showed the emissions factors originally established were potentially underestimating the emissions at this point. Since the original issuance, the source has updated operating conditions which likely impacted the emissions profile. This permit update is requested updated emissions limits and emissions factors. This source is a synthetic minor source for VOC. 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 19WE0642 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Lauraleigh Lakocy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO 1 I Department of Public ac*,RJ Health b En+rirorunent COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0642 Issuance: 2 Date issued: Issued to: Kerr-Mcgee Oil and Gas Onshore LP Facility Name: 36112551 Plant AIRS ID: 123/2315 Physical Location: NENE Section 26 T3N R66W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID Point Equipment Description Description LPGFL 007 Low Pressure Stage of Six (6) 2-Stage Enclosed Combustion Separators Device 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. 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 www.colorado.gov/cdphefair-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. 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.) 3. 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. Page 1 of 9 COLORADO Air Pollution Control Division Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado EMISSION LIMITATIONS AND RECORDS 4. 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 LPGFL 007 --- --- 2.2 --- 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 air 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. 5. 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. 6. 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 LPGFL 007 Emissions from the Separator are routed to VOC and HAP an Enclosed Combustion Device PROCESS LIMITATIONS AND RECORDS 7. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Equipment ID AIRS Process Parameter Annual Limit Point LPGFL 007 Liquids Throughput 26,500 bbl/yr 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 Page 2 of 9 Cary.ii�:,x COLORADO 40 -'%i%I.tigielyiir Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 9. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Et MAINTENANCE REQUIREMENTS 12. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (0&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 0&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 13. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 9, 40 C.F.R. Part 60, Appendix A, to measure opacity from the flare for one continuous hour. (Regulation Number 1, Section II.A.5) Periodic Testing Requirements 14. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 15. All previous versions of this permit are cancelled upon issuance of this permit. 16. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: Page 3 of 9 COLORADO 10 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO),) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 17. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization Page 4 of 9 C COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Lauraleigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 August 9, 2019 Issued to Kerr-McGee Oil and Gas Onshore LP Issuance 2 This Issuance Issued to Kerr-McGee Oil and Gas Onshore LP Updated emission factors based on updated Page 5 of 9 COLORADO itivAir Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado sampling, added synthetic minor requirements. Page 6 of 9 C --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 Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 634 32 Toluene 108883 836 42 LPGFL 007 Xylenes 1330207 380 19 n-Hexane 110543 4,404 220 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 7 of 9 COLORADO 10 -.44-Ntirf Air Pollution Control Division Department of Public Health b Environment 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: Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/bbl) (lb/bbl) VOC 3.35 1.675E-01 ProMax 71432 Benzene 0.0239 1.195E-03 Reversipator 108883 Toluene 0.0315 1.575E-03 Simulation based 1330207 Xylene 0.0143 7.15E-4 on Site-Specific Low Pressure 110543 n-Hexane 0.1662 8.31 E-03 Sample (Taken 12/18/2019) Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The emission factors listed above are based on modeled separator temperature of 105 °F and separator pressure of 19 psig. 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 Page 8 of 9 COLORADO 110 . Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 )00000( Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Lauraleigh Lakocy Package#: 424304 Received Date: 1/13/.20 Review Start Date: 3/412020 Section 01-Facility Information Company Name: lterr-tV.cgee"i':and.Gas Onshore_P Quadrant Section Township Range County AIRS ID: 123 N_NE 25 3N " Plant AIRS ID: ?315 . Facility Name: 36112551 Physical Address/Location: County: Weld County Type of Facility: Exploration&Production We 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(NOv&VOC) Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only Permit# AIRS Point# Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks has already assigned) assigned) Permit has not completed self- Permit certification 007 Separator Venting LPGFL '?es 19'0./64642.' 2 yes Modification requirements Section 03-Description of Project This source completed initial sampling per the initial permit issuance and received sampling that showed the emissions factors originally established were potentially underestimating the emissions at this point.Since the original issuance,the source has updated operating conditions which likely impacted the emissions profile. This'permit update is requested updated emissions limits and emissions factors.This source is a synthetic minor source for V 00. Historically,the division has req-shed sources that are obtaining synthetic minor limits,wherein by obtaining federally enforceable limits on potential emissions in order to keep yearly emissions low enought to not trigger other regulatory requirements(i.e.T€₹le V and NANSR).Previously this facility was a true minor facility. With this permitting action,the facility is decreasing the emissions;however,due to the nonattainment redesignation,this facility is now a synthetic minor facility (uncontrolled emissions>50 tpy total),so by modifying this permit,you are avoiding regulatory requirements of a major fac ility status,which per the division, requires public comment, PS Memo 99-06,which was just updated 2/2019,addresses this requirement through point#1(bullet point#6). L Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? "Yes If yes,why? Requesting Synthetic M not Permit - - Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? Nu 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) 0 0 0 0 0 O Title V Operating Permits(OP) O O O O O O O O Non-Attainment New Source Review(NANSR) O LJ 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) O O O O O O Title V Operating Permits(OP) O O O O O O O O Non-Attainment New Source Review(NANSR) O O S a ator'Venting g Emissions Enyentoi Section 01-Administrative Information Facility AIRS ID: 123' - 2315 947 County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit Description Low pressure separator` - Emission Control Device Description: Rpcfosed'Coesbustiu5}EfnFce., ", Requested Overall VOC&HAP Control Efficiency%: 955 Limited Process Parameter #"ft$, '$ 4 v Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput=` 1:13 Barrels(bbl)per year ' Requested Permit Limit Throughput= 26,sG=.0 Barrels(bbl)per year Requested Monthly Throughput= ,...:.7 Barrels(bbl)per month Potential to Emit(PTE)Throughput= _ i Barrels(bbl)per year Secondary Emissions-Combustion Devices)for Air Pollution Control Separator Gas Heating Value: 2450.5:Btu/saf Volume of waste gas emitted per BBL of`. liquids throughput 7.o'scf/bhl Control Device Pilot Fuel Use Rate: 1Z scfh 0.1 MMscf/yr Pilot Fuel Gas Heating Value: 1105 Btu/scf Section 04-Emissions Factors&Methodologies Description MW I. .,.3 Ih/Ib-mol Displacement Equation Ex=Q'MW°Xo/C Weight% Helium CO2 1,7 N2 methane -..s ethane 114 propane sobatano .__ n-butane isopentane n-pentane _. cydppentane ,., n-Hexane ,, cydohexane nn Other hexanes heptanes _.., methylcyclohexane 224-TM P Benzene ,._; Toluene Ethylbenzene Xylenes CS+Heavies Z, Total VOC Wt% 2 of 9 C:\Users\Ilakocy\Desktop\Remote Working Docs\Package#424304\19WE0642.CP2 Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/bbl) (lb/bbl) (Liquid Throughput) (Liquid Throughput) VOC Benzene . .__ Toluene ._ G c,,,IS Ethylbenzene _ Xylene _ _ n-Hexane r' 224 TMP _ _, .... ,.. .... Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/bbl Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 _ ' Al'421566.54,2JPPt110/olc'25,k PM2.5 0.307S. __. s+`r'-42 a8nrat S 42 P.h2L0IP ,7.51 SOx 0.0006 ,'FEPx4?tls 1n 1,4 2(SOo3 NOx 0.0601 ._ AP-92&hapte 1':!t€nds;strma(F,sPes(1Oy)', CO 0.3300 AP-42thaptdr S3 industrial Vales(CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0075 4AP'42''34!51,1,8-2;{PM10/PM.2.S): PM2.5 .0.0075 - , AP.42'Fat&Z,0-2(PMi0/Pti4.Z.5} 500 0.0006 OP-411"6r9 10-2(Sox) NOx 0.0680. . - -47-Chapter 13.5.loafo0riat Flares(MONT CO 0.3100 _ AP-47 Chaapter 13,Sfssdostnal}'laces(CO) 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) (Ibs/month) PM10 PM2.5 SOx NOx VOC ..,_ - _ _ _ ., 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 ... >. Toluene _.. Ethylbenzene Xylene n-Hex _ .._ 224 IMP Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Regulation 7,Section XVII.B,G _ Regulation 7,Section XVII.B.2.e :r-, :;.: _ (See regulatory applicability worksheet for detailed analysis) 3 of 9 C:\Users\Ilakocy\Desktop\Remote Working flocs\Package#424304\19WE0642.CP2 Section 07-Initial and Periodic Sampling and Testing Requirements Y.'� s;�/ira„' sh•�, :s �u twr>I a, m>� ur:r+far.. :a: " ;, ≥:a�" .49,4 .,.✓:fs94:9,9.99. ,IIIMIIIa'r R.,r�:mil.' ` e.�•:vv�,� ;.>'.E�F�ifiJ ''C' f�:»%9i"Y ✓' 6a ,,a-f a°"''•t''' '3• ee ,:6 ., 4 z. '- '•,,r'-:.-az,' ;" ,a r•:., :; . r :s taigitildP"svy' ,f-r Egainai)gPigtkiligitlitlilOWIMPIPPYRIAlffringitarb " ",yr(,, '�vryz: , r i rw , ,.;-F , s�r> i' /F✓ "i1R""i 43 r49.'�'''' "'y6 ;vyr d•;"lv`iaa' 'avaii£'�%,Nsr. _ mmo 'i` r/ 66.4,011645,46 :3"214:4"4"41. � 33 E ,,.51vrc._..a�3u :-s.: ✓ .. .>-::f 3)� ''�Fu3�i•.v3. .Unl �::2:r'„"e .a�✓ / , .,i ',a ._ , - % 6'� /6.� 'ilk' Y4 iiw,et, lai lam,0 .r' ,. ,3.,�`.".. ./r.'.:,r_ v s. y 'iMi. i rf 1r.:.:..� ":,b$:.e1�>4"f Y .,r,..- ." ':r��- .If p / ✓ e„ v 'W s. :.:,r � � ✓ r .. -,. :,,dry,: .��'•;• �� t S ;c ajta " p , % f. <,: s ,�,:,.; a ,;; '' X,i„'e::s �3.iu;:' l�r .%" r,ti ./i EL_. /sr r2�s:.: -" .F ,• ., l ,4,, H"'✓ r ..yam: f,ig e.<."s. sy<.,.:: .g✓py..sr:.: .e✓."wl,.rsYz:9'.e. Fy'�';r i✓' i a' ,:sr..,,s .:,:v yi syt ':-o-.: ;,;v>n:i'a'a:'4 ai:" ..4..: ..1 wI11!uuIIaea11S1 i , " a,r:s.< //' . ..,s ��55 :I ' e.rdtiL. is " ; ""./d'. r yr % •V �'% sue MialE:>:;-,;e•,.. <.;::.:. E :�•,.z'�,o,'✓fili N `�:;, .'�","",•A,:s:--,a::.-, - :✓','gra" 'r� �.�Yr�f� .,i'i'i � ,.. ., .._._.. �rr:. Using Liquid Throughput to Monitor Compliance Does the company use site specific emission factors based one pressurized liquid sample(Sampled upstream of the equipment covered under this AIRS ID)and process simulation to estimate emissions? This sample 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 maybe appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Compliance"testing requirement to collect a site-specific liquid sample 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. Does the company request a control device efficiency greater than 95%fora flare or combustion device? > ''-=I4 If yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08-Technical Analysis Notes Source did not submit self-certification documents,so this permit will be issued as an initial approval with self-certification requirements Source did submit a notice of start-up recieved by the division 12/17/2019. According to the source,none of the wells at this facility have been newly constructed,hydraulically fractures,or recom pleed since August 1,2014.While this is a newer separator venting point than the wells,this source is not subject to Regulation 7 no visible emissions requirements as previously determined. The emission factors developed within the permit will reflect the emission factors that the source listed in the calculation sheet,which provided more significant figures than those listed in the APEN The source reviewed and approved the draft permit. When compared with ProMax simulation from the initial issuance,the sample parameters changed from 81F/36 psig to 10SF/19psig Upon inquiring with the source why the sampling parameters for a single source changed so dramatically,the source responded in the email from 4/6/2020(shown on APEN redline document),that the source has since converted to a tackles design and that flaring the LP gas is driving the decrease in pressure.The original sample was taken before that conversion,and it appeared that the heating unit in the separator was not en during the previous sampling period.The source confirmed that it appears the sample used for this submission was taken while the separator burner was turned on Source was reminded via phone call that sampling should occur during typical operating conditions. The source has now sampled 2 of the 6 separators(Camp 365-26HZ and Camp 38N-26H2)to formulate the emission factors.5 of the separators that are routed to the ECD are normally operated within 10 F and lOpsig of each other and services individual horizontal wells.The 6th separator has not been operational between 1/1/2020 and 05/01/2020 and servicesa vertical well.Based on the similarities of operations between the separators and the usage of the more conservative of the samples taken to determine facility emissions,this sample will be accepted as a representative sample fcc these 6 separators. Section 09-Inventory SCC Coding and Emissions Factors AIRS Point# Process# SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 007 01 s'1,e, __,. ,>4 ' ' _ - PM10 2.- __3..b_e PM2.5 :,,__JC9b) SOx .. 0 '))/iv.)isu. NOx c . VOC 33,7 2 SS 1=3,10'„,nb CO F,3 5 tb,,1^6.,.y Benzene 2,rl Cs f*,>70t-b1 , Toluene 33.G .o Ethylbenzene i 4 .5 a,1.3,7,1-3," Xylene .,3 45 13,,::3Gas - n-Hexane lb.4 41 It,0104b4 224 TMP „_ 9 '15 V,T[`437 4 of 9 C:\Users\Ilakocy\Desktop\Remote Working Docs\Package#424304\19WE0642.CP2 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. • �Colorado Re ulation 3Parts A and B-APEN and Permit Requirements S>_._..iy.r.rte..,....a.r.,._,r�,r,a ATTAINMENT .„< ..`.. 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section Il.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10TPY(Regulation 3,Part 5,Section RDA? -?..0,.sae zndisaieul that A-i__,s io -_,,,r o,r-h ,t'z_ ._..-r=s NON-ATTAINMENT < 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than S TPY(Regulation3,Part A,Section II.D.S.a)? 'Ins !Source Re 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)? Source Re Colorado Regulation 7,Section XVII 1. Was the well n ly constructed,hydraulically f ct d completed on or after August 1,2014? IriO (Source is Section XVII.R.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G-Emissions Control Alternative Emissions Control(Optional 5ectlon( `y a. Is this separator controlled by a back-up or alternate combustion device(Le.,not the primary control device)that is not enclosed? :.'pTM.r,me{I The conin Section XVII.R.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 if 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. 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 Received from Source May 5, 2020 36112551 Separator Temperatures 160.00 14000 120.00 100.00 E I Camp 38N-26HZ n v c 80,00x Camp 38C-26HZ a - Camp 37N-26HZ v 60.00 }' Camp 15N-26HZ 40.00 r Camp 36N-25HZ 20.00 0.00 21-Dec-191 : a:- E»-J IDID1N}i bE l.QilONW02:030 €1D1BOt. UCT.09 ',f4 EO 00:00:00 Date Received from Source May 5,2020 36112551 Oil API Gravity 70.00 60.00 50,00 m 4f3.00 Vie---"." ---berresl vCP 'g -5eries2 30.00 -Series4 20.00 '�.. 10,00 0.00 21-Dec-1900:00:00 10-Jan-2000:00:00 30-Jan-2000:00:00 19-reb-2000:00:00 10-Mar-2000:00:00 30-Mar-20 00:00:00 19-Apr-2000:00:00 09-May-2000:00:00 Date COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT • AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Kerr-McGee Oil and Gas Onshore LP County AIRS ID 123 History File Edit Date 518/2020 Plant AIRS ID 2315 Ozone Status Non-Attainment Facility Name 36112551 Last Modified By: Lauraleigh Lakocy 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 0.0 0.0 0.0 0.0 2.0 64.4 0.6 2.3 _ 3.5 0.0 0.0 0.0 0.0 2.0 , 3.2 0.6 2.3 0.2 From July 2019 Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.1 63.6 0.0 0.7 3.3 0.0 0.0 0.0 0.0 0.1 3.2 0.0 0.7 0.2 001 18WE0 161.CE Condensate Tanks(151 0.0 0.0 Cancellation notice recd 052,6/2019 002 Cancelled RICE,135 HP Cummins G8.3L Cancellation notice recd 4/16113 003 GP02 CN RICE.135 HP GM 80-GC6NL Cancellation notice reed 12/13/12 004 13WE1437.CN RICE Zenith 78 SAE 11349 Cancellation notice recd 4/22/15 005 13WE1438.XP Prod water tanks,420 bbl 0.8 0.1 0.0 0.0 From January 2020 Form APCD 102 006 19WE0374 VRT 0.0 0.0 0.0 14.4 0.1 0.6 0.0 0.0 0.0 0.7 0.1 0.0 No change 007 19WE0642 LP Separator Gas 0.1 44.4 0.4 3.1 0.1 2.2 0.4 0.2 Updating Emission Factors APEN-Exempt/Insignificants Fugitive component leaks 0.6 0.0 0.6 0.0 From January 2020 Form APCD 102 Seven(7)0.5 MMBtu/hr heaters 1.9 1.5 0.0 1.9 1.5. 0.0 From January 2020 Form APCD 102 FACILITY TOTAL 0.0 0.0 0.0 0.0 2.0 59.6 0.6 2.1 3.9 0.0 0.0 0.0 0.0 2.0 2.9 0.6 2.1 0.2 VOC: Syn Minor(NANSR and OP) NOx:True Minor(NANSR and OP) CO: True Minor(PSD and OP) HAPS: True Minor Permitted Facility Total 0.0 0.0 0.0 0.0 0.1 58.8 0.0 0.5 3.7 0.0 0.0 0.0 0.0 0.1 2.9 0.0 0.5 0.2 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions 0.0 0.0 0.0 0.0 0.0 -0.3 0.0 -0.2 Pubcom is required because new syn minor limit. Modeling not required based on division guidelines. J Total VOC Facility Emissions(point and fugitive) 3.5 Facility is eligible for GP02 because<45 tpy (A)Change in Total Permitted VOC emissions(point and fugitive) -0.3 Project emissions less than 25 tpy Note 1 Note 2 Page 8 of 9 Printed 5/12/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Kerr-McGee Oil and Gas Onshore LP County AIRS ID 123 8/7/2019 Plant AIRS ID 2315 Facility Name 36112551 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 18WE0161 CN Condensate Tanks(15) 002 _Cancelled RICE, 135 HP Cummins G8.3L 003 GP02.CN RICE, 135 HP GM 80-GC6NL 004 13WE1437.CN RICE,Zenith 78 SAE J1349 005 13WE1438.XP Prod water tanks,420 bbl 42 137 0.1 006 19WE0374 VRT 122 182 2 40 852 0.6 007 19WE0642 LP Separator Gas 635 836 23 380 4404 Cl 3.1 APEN-Exempt/Insignificants Fugitive component leaks 3 9 2 23 24 0.0 Seven(7)0.5 MMBtu/hr heaters 0.0 TOTAL(tpy) 0.0 0.0 0.0 0.4 0.5 0.0 0.2 2.7 0.0 0.0 0.0 0.0 3.9 `Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text: uncontrolled emissions<de minimus Emissions with controls (lbs per ear) 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 18WE0161.CN Condensate Tanks(15) 002 Cancelled RICE, 135 HP Cummins G8.3L 003 GP02.CN RICE, 135 HP GM 80-GC6NL 004 13WE1437.CN RICE,'Zenith 78 SAE J1349 005 13WE1438.XP Prod water tanks,420 bbl 3 8 0.0 006 19WE0374 VRT 3 c, 2. 43 0.0 007 19WE0642 LP Separator Gas 32 42 1 19 220 0 0.2 APEN-Exempt/Insignificants Fugitive component leaks 2 ?t .:> 0.0 Seven(7)0.5 MMBtu/hr heaters 0.0 TOTALitpy) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.0 0.0 0.0 0.0 0.2 9 19WE0642.CP2 5/12/2020 f A Jq y1 3 2020 ��I.�:,;g,�I Gas Venting APEN - Form APCD-211 41. Air Pollutant Emission Notice (APEN) and CDPHE 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-2OO)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: 19WE0642 AIRS ID Number: 123 /2315 /007 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 - Administrative Information Company Name': Kerr-Mcgee Oil and Gas Onshore LP Site Name: 36112551 Site Location Site Location: NENE Sec. 26 T3N R66W County: Weld NAICS or SIC Code: 1311 Mailing Address: PO Box 173779 (Include Zip Code) Denver, CO 80217-3779 Contact Person: Carissa Krey Phone Number: 720-929-6916 E-Mail Address1: carissa_krey@oxy.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. 4243Q2 api.COLORADO Form APCD-211 - Gas Venting APEN - Revision 12/2019 1 I 1 j Permit Number: 1 9WEO642 AIRS ID Number: 123 /2315/007 [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) O Change fuel or equipment O Change company name3 O 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 Et Notes: Modifying emissions factors to reflect new site-specific sample 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. Red-line per attached Section 3 - General Information 6-LP Separators email and • Gas venting from LP separator General description of equipment and purpose. revised P APEN recd controlled by an ECD. 4/6/2020. LPGFL -LL Company equipment Identification No. (optional): For existing sources, operation began on: 8/20/2019 For new, modified, or reconstructed sources, the projected start-up date is: r❑ Check this box if operating hours are 8,76O hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Will this equipment be operated in any NAAQS 0 Yes ❑ No nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of(HAP)Emissions? O Yes No Is this equipment subject to Colorado Regulation No. 7, Yes O No Section XVII.G? e'COLOR:J:40 Form APCD-211 Gas Venting APEN - Revision 12/2019 2 I A0 d � 1 / Permit Number: 19WE0642 AIRS ID Number: 123 /2315/007 [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 0 Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown 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 ❑r No Vent Gas 2050 BTU/SCF Gas Venting Heating Value: Process Parameters5: Requested: MMSCF/year Actual: MMSCF/year -OR- Liquid Throughput 5 Requested: bbl/year Actual: 26,500 bbl/year Process Parameters5: Molecular Weight: 40.28 VOC(Weight%) 66.34 Benzene (Weight%) 0.47 Vented Gas Toluene(Weight%) 0.62 Properties: Ethylbenzene(Weight%) 0.02 Xylene(Weight%) 0.28 n-Hexane(Weight%) 3.29 2,2,4-Trimethylpentane(Weight%) 0.00 Additional Required Documentation: O Attach a representative gas analysis(including BTEX 13 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. as.COLORADO Form APCD-211 - Gas Venting APEN - Revision 12/2019 3 1 ."�1 Permit Number: 19WE0642 AIRS ID Number: 123 /2315/OO7 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.2016257/-104.7371202 ❑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. Discharge Height operator Temp .flow Rate t Velocity -Above Ground Level Stack ID No {Feet} { !_) = {ACFA#) . IN?- er) ECD-02 25 500 3.19 Indicate the direction of the stack outlet: (check one) ✓❑ Upward O Downward O Upward with obstructing raincap ❑ Horizontal O Other(describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): 48 ❑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. Pollutants Controlled: Size: Make/Model: ❑ VRU: Requested Control Efficiency: % VRU Downtime or Bypassed: % Pollutants Controlled: VOCs, HAPs Rating: 0.5 MMBtu/hr Type: Enclosed Flare Make/Model: 48" Leed Q Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: Waste Gas Heat Content: 2050 Btu/scf Constant Pilot Light: LI Yes ❑ No Pilot burner Rating: MMBtu/hr Pollutants Controlled: O Other: Description: Requested Control Efficiency: % COLORADO Form APCD-211 Gas Venting APEN - Revision 12/2019 4 I �' :a� r Permit Number: 19WE0642 AIRS ID Number: 123 /2315/007 [Leave blank unless APCD has already assigned a permit ft and AIRS ID] I 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? EJ Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies(report the overall,or combined, values if multiple emission control methods were identified in Section 6): Collection Efficiency Control Efficiency Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured by control equipment) emissions) PM SO. NOx CO VOC Enclosed Flare 100 95 HAPs Enclosed Flare 100 95 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)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, 6 Emissions Emissions Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOx NOx 0.068 Ib/MMBTU AP-42 0.09 0.09 CO 0.31 lb/MMBTU AP-42 0.40 0.40 VOC 3.35 Ibrbbl ProMax 43.87 2.19 44.44 2.22 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 O No 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 Emission Factor Actual Annual Emissions Abstract Source Uncontrolled Controlled Chemical Name Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions6 Basis Number Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 0.02 lb/bbl PmMax 626 61 Toluene 108883 0.03 lb/bbl ProMax 825 41 _ Ethylbenzene 100414 0.0009 IbIbbl ProMax 23 1 Xylene 1330207 0.01 lb/bbl ProMax 375 19 n-Hexane 110543 0.17 Ib/bbi ProMax 4348 217 2,2,4-Trimethylpentane 540841 0.00 15/601 ProMax 0 0 Other: __ 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. COLORADO Form APCD 211 Gas Venting APEN Revision 12/2019 5 IO' a r Permit Number: 19WE0642 AIRS ID Number: 123 /2315/007 [Leave blank unless APCD has already assigned a permit a 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. WAN tj 2O Signature of Legally Authorized Person (not a vendor or consultant) Date Carissa Krey Air Quality Manager Name (print) Title Check the appropriate box to request a copy of the: ❑Draft permit prior to issuance o 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 $191.13 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 APCD-SS-B1 OR 4300 Cherry Creek Drive South (303)692-3148 Denver, CO 80246-1530 APCD Main Phone Number Make check payable to: (303)692-3150 Colorado Department of Public Health and Environment COLORADO Form APCD 211 Gas Venting APEN Revision 12/2019 6 ISO' Raft\ tomboruneel 4/10/2020 State.co.us Executive Branch Mail-Kerr-Mcgee Oil and Gas Onshore-36112551 -Permit 19WE0642 Modification Request ::;744;\'''' STATE OF }) , COLORADO Lakocy -CDPHE, Lauraleigh<lauraleigh.lakocy@state.co.us> t Kerr-Mcgee Oil and Gas Onshore - 36112551 - Permit 19WE0642 Modification Request Stephen_Tartaglia@oxy.com <Stephen_Tartaglia@oxy.com> Mon, Apr 6, 2020 at 3:48 PM To: "lauraleigh.lakocy@state.co.us"<lauraleigh.lakocy@state.co.us> Cc: Carissa_Krey@oxy.com Hi Lauraleigh, Please see our response to your comments below in blue.Would it be possible to schedule a meeting to discuss the need for public comment? If you provide me with a few potential meeting time options I would be happy to schedule a call. Thank you, Stephen Tartaglia Air Permitting Support Occidental Petroleum Corporation Direct: 720-929-6019 Dxv %op, From: Lakocy-CDPHE, Lauraleigh <lauraleigh lakocy@state.co.us> Sent: Tuesday, March 24, 2020 9:27 AM To: Stephen_Tartaglia@oxy.com Cc: Carissa_Krey@oxy.com Subject: [EXTERNAL] Re: Re: Kerr-Mcgee Oil and Gas Onshore-36112551 - Permit 19WE0642 Modification Request Dear Stephen, Regarding the ProMax simulation, I see that the previous sample which was taken and used for the initial issuance had a temperature and pressure of 81F and 36 psig, whereas this sample is at 105F and 19 psig. This seems like a decent change in operating pressure. Was there an operational change to modify those pressures of operation or do they vary? While it is standard for temperatures and pressures to very based on different flow conditions, in this instance the operational change of converting the facility to a tankless design and flaring LP gas is driving the decrease in pressure. https://mail.google.com/mail/u/0?ik=44f88835c3&view=pt&search=all&permmsgid=msg-f%3A1663261763916408799&simpl=msg-f%3A16632617639... 1/3 4/10/2020 State.co.us Executive Branch Mail-Kerr-Mcgee Oil and Gas Onshore-36112551 -Permit 19WE0642 Modification Request The original sample was taken before the facility was converted, and the sample for the self-cert was taken after the conversion had taken place and operations resumed. It appears the heating unit in the separator was not on when the original sample was drawn. When the sample was taken for the self-cert it appears that we had the separator burner on. Additionally, I did see that this source submitted a notice of start-up 12/17/2019, which stated that this point is not a single 2-stage separator, but is 6 x 2-stage separators. Is that the case?This information really needs to be included in the general description of the equipment in section 3 of the APEN as it should be listed in the permit. Can you please provide clarification on where the sample that was used to calculate emissions was taken?Was that sample from a single separator or from a commingled stream from all of the separators? If the sample is from a single separator, can you clarify why you used this sample, versus collecting multiple samples from different separators? Regarding the gas that is sent to the enclosed combustion device (ECD), is the low pressure gas from all of the 2-stage separators sent to the same ECD? There are 6 2-stage separators that all send LP gas to the ECD. We pulled a sample from the oil outlet of one of the separators to estimate emissions. All of these separators operate at the same temperature and pressure, and therefore KMG believes that a sample from one of these separators can be used as representative of all the other separators at the facility. This follows the same methodology that has been used for all of the LPGFL and VRT permits that we have submitted, and the division has previously agreed with this determination. The attached APEN has a revised Section 3 to account for the total number of separators. While I understand that the uncontrolled VOC emissions from this point alone are under 50 tpy, the facility is now a synthetic minor facility as the total uncontrolled facility emissions are greater than 50 tpy. Any permit limit that is being established after the ozone nonattainment redesignation that limits the emissions to under the 50 tpy is a new synthetic minor limit. This facility was previously a true minor facility and did not have the requirements of a synthetic minor facility, including but not limited to having a required O&M plan and tracking compliance on a rolling 12-month basis. Even though this permit modification is decreasing the emissions limits, it is now a synthetic minor limit for the non-attainment new source review(NANSR) program and therefore needs to go to public comment per Regulation 3, Part B, Section III.C.1.d. I will mention that even facilities in the non-attainment area that previously had synthetic minor limits above 50 tpy that are now modifying to have synthetic minor limits under 50 tpy also do need to go to public comment again. Please let me know if you have any more questions on this- I know this may not be intuitive, but I would be happy to set-up a phone call to discus this further. Regarding the O&M plan,this source was not previously required to follow a division-approved O&M plan, per condition 15 of the original permit. Additionally,with the new redesignation, the division O&M plans have been updated to reflect new requirements, so this source will now be required to follow a division-approved O&M plan. Can you please submit an O&M plan for this point that reflects our most up to date version (Jan 27, 2020)? Please see the attached O&M plan. Please note that since none of the wells have been modified/added since August 1, 2014,this equipment is not subject to Regulation 7, Part D, Section II.F(previously XVII.G), so this was an error on my part for the first issuance. I do see that on the APEN in section 3, it was selected that this source was subject to this regulation, so please let me know if you would like to discuss this further. Once I receive the additional information about the separator set-up and sampling, I will be able to finalize the draft permit and send it over for your review. If you could please provide the requested information by Monday, April 6, that would be greatly appreciated. Sincerely, Lauraleigh Lakocy https://mai I.google.com/mai I/u/0?i k=44f88835c3&view=pt&sea rch=al I&permmsg id=msg-f%3A1663261763916408799&simpl=msg-f%3A16632617639... 2/3 4/10/2020 State.co.us Executive Branch Mail-Kerr-Mcgee Oil and Gas Onshore-36112551 -Permit 19WE0642 Modification Request Oil 8 Gas Permit Engineer Oil and Gas Program [Quoted text hidden] [Quoted text hidden] 2 attachments KMOGO_O&M Plan LPGFL_36112551.pdf 204K KMOGO_LPGFL_APEN_36112551.pdf 448K https://mai I.google.com/mai I/u/0?i k=44f88835c3&view=pt&search=al I&permmsgid=msg-f%3A 1663261763916408799&simpl=msg-f%3A16632617639... 3/3 Received April 6, 2020 For Red-line purposes RkeIt Gas Pollutant APEN - Form g APCD-211 Air (APEN) COP; 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 9WE0642 AIRS ID Number: 123 /2315 /007 [Leave blank unless APCD has already ass coned a permit and AIRS ID] Section 1 - Administrative Information Company Name': Kerr-Mcgee Oil and Gas Onshore LP Site Name: 36112551 Site Location: NENE Sec. 26 T3N R66W Site Location Weld County: NAICS or SIC Code: 1311 Mailing Address: PO Box 173779 (Include Zip Code) Denver, CO 80217-3779 Contact Person: Carissa Krey Phone Number: 720-929-6916 E-Mail Address2: carissa_krey@oxy.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 12/2019 1 I .' Permit Number: 19WE0642 AIRS ID Number: 123 /2315/007 [Leave blank unless APCD has already assigned a permit 4 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 0 Add point to existing permit 0 Change permit limit 0 Transfer of ownership4 0 Other(describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit (PTE) Additional Info£t Notes: Modifying emissions factors to reflect new site-specific sample 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: Gas venting from (X6) LP separator controlled by an ECD. Company equipment Identification No. (optional): LPGFL For existing sources, operation began on: 8/20/2019 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 days/week weeks/year Will this equipment be operated in any NAAQS Yes ❑ No nonattainment area? Is this equipment located at a stationary source that is ❑ Yes 0 No considered a Major Source of(HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, 0 Yes ❑ No Section XVII.G? ge COLORADO Form APCD-211 Gas Venting APEN Revision 12/2019 2 NeaIN 6 Enwenmant Permit Number: 19WE0642 AIRS ID Number: 1 23 /2315/007 [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 o Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist O Blowdown Events #of Events/year: Volume per event: MMscf/event ❑ 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? ❑ Yes ❑✓ No Vent Value: 2050 BTU/SCF Gas Venting Heating Valuue:: Process Parameters5: Requested: MMSCF/year Actual: MMSCF/year -OR- Liquid Throughput Process Parameters5: Requested: bbl/year Actual: 26,500 bbl/year Molecular Weight: 40.28 VOC (Weight%) 66.34 Benzene (Weight%) 0.47 Vented Gas Toluene (Weight%) 0.62 Properties: Ethylbenzene(Weight%) 0.02 Xylene (Weight%) 0.28 n-Hexane (Weight%) 3.29 2,2,4-Trimethylpentane (Weight%) 0.00 Additional Required Documentation: ❑ Attach a representative gas analysis (including BTEX It n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis(including BTEX ti 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. COLORADO Form APCD-211 Gas Venting APEN - Revision 12/2019 3 1 � Permit Number: 19WE0642 AIRS ID Number: 123 /2315/007 [Leav,. blank unless APCD has already assigned a permit and AIRS ID] Section 5 - Geographical/Stack Information Geographical Coordinates (LatitudelLongitude or UTM) 40.2016257/-104.7371202 O 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. Discharge Height Operator Temp. Flow Rate Velocity Above Ground Level •Stack ID No. (7) (ACFM) (ftlsec) (Feet) ECD-02 25 500 3.19 Indicate the direction of the stack outlet: (check one) ❑� Upward O Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑ Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): 48 ❑ 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. Pollutants Controlled: Size: Make/Model: ❑ VRU: Requested Control Efficiency: % VRU Downtime or Bypassed: % Pollutants Controlled: VOCs, HAPs Rating: 0.5 MMBtu/hr Type: Enclosed Flare Make/Model: 48" Leed ❑ Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: 2050 Btu/scf Constant Pilot Light: I] Yes O No Pilot burner Rating: MMBtu/hr Pollutants Controlled: O Other: Description: Requested Control Efficiency: % '.COLORADO 4 e Form APCD-211 Gas Venting APEN Revision 12/2019 Permit Number: 1 9WE0642 AIRS ID Number: 123 /2315/007 [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? ❑r Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Descri Description Collection Efficiency Control Efficiency p (%of total emissions captured (%reduction of captured by control equipment) emissions) PM SO. NO. CO VOC Enclosed Flare 100 95 HAPs Enclosed Flare 100 95 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)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions(' Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SO. NOx 0.068 Ib/MMBTU AP-42 0.09 0.09 CO 0.31 Ib/MMBTU AP-42 0.40 0.40 VOC 3.35 lb/bbl ProMax 43.87 2.19 44.44 2.22 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-criteria0 Yes ❑ No 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 Emission Factor Actual Annual Emissions Abstract Source Uncontrolled Controlled Chemical Name Service(CAS) Units Units (AP-42, Emissions Emissions(' Number Basis Mfg.,etc.) (lbs/year)Y ) (lbs/year) Benzene 71432 0.02 lb/bbl ProMax 626 61 Toluene 108883 0.03 lb/bbl ProMax 825 41 Ethylbenzene 100414 0.0009 lb/bbl ProMax 23 1 Xylene 1330207 0.01 lb/bbl ProMax 375 19 n-Hexane 110543 0.17 lb/bbl ProMax 4348 217 2,2,4-Trimethylpentane 540841 0.00 lb/bbl ProMax 0 0 Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. �,COLORADO Form APCD-211 Gas Venting APEN - Revision 12/2019 5 ft. Is e'ft..6 En�IronmeM Permit Number: 1 9WE0642 AIRS ID Number: 123 /2315/007 [L.eav blank unless APCD has already ass gned 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. Signature of Legally Authorized Person (not a vendor or consultant) Date Carissa Krey Air Quality Manager 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 $191.13 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 APCD-SS-B1 OR 4300 Cherry Creek Drive South (303) 692-3148 Denver, CO 80246-1530 APCD Main Phone Number Make check payable to: (303) 692-3150 Colorado Department of Public Health and Environment COLORADO Form APCD-211 Gas Venting APEN - Revision 12/2019 6 `HealNbEnrl.enmoal Hello