HomeMy WebLinkAbout20200322.tiffpubI C ReV.e )
01 12'112.0
COLORADO
Department of Public
Health & Environment
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
January 15, 2020
Dear Sir or Madam:
On January 16, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
Western Operating Company - Busy Bee Production Facility. A copy of this public notice and the
public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health &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
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
Cc: pi.(rP), HL.(L-K), pw(sKiER/c$f►c),
Otl2.'412O
2020-0322
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Western Operating Company - Busy Bee Production Facility - Weld County
Notice Period Begins: January 16, 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: Western Operating Company
Facility: Busy Bee Production Facility
Exploration Et Production Well Pad
SESE Sec 6, T3S, R60W
Weld County
The proposed project or activity is as follows: The applicant proposes to construct a new separator venting
source at an existing true minor facility. Applicant is requesting synthetic minor limits for facility.
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 19AD0876 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:
Ben Fischbach
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
Health Et Environment
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical
Address/Location: SE -SE quadrant of Section 6, Township 35, Range 60W
County:
Type of Facility:
What industry segment? QIF[
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? Carbon Monoxide (CO)
Adams County
Section 02 - Emissions Units In Permit Application
Quadrant
Particulate Matter (PM) 2 Ozone (NOx & VOC)
Section
Township
Range
SE
eCI
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance it
Self Cert
Required?
Action
Engineering
Remarks
602
.�• e`�
Spoa sVenting,
�a ,.
19AD0876
1
Yes.,,
Section 03 - Description of Project
Flaring of produced natural gas. Company is requesting a synthetic minor permit with this application; therefore this point will `have to undergo a publi
before issuance,
Section 04 - Public Comment Requirements
Is Public Comment Required?
If why? , esein S
Y Y• r�„ .8 yntYieticMiro""Per
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? o
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?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New5ource Review (NANSR)
Is this stationary source a major source?
If yes, explain what programs and which pollutants here SO2
Prevention of Significant Deterioration (PSD) _
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
HR
PM2.5 PM10 TSP
❑ ❑
HAPs
❑ ❑
Separator Venting Emissions Inventory
002 Separator Venting
!Facility Al Rs ID:
005,
Plant
Point
Section 02 - Equipment Description Details
Limited Process Parameter
Gas meter
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions -Separator
Actual Throughput v'f# %'EP1MMsniperyear
Requested Permit Limit Throughput ,: ','142; MMscf
Potential to Emit (PTE[ Throughput
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
13 MMscf per year
Secondary Emissions - Combustion Devices) for Air Pollution Control
Separator Gas Heating Value: r ;144'k_-BYu/scf
Volume ofwaste gas emitted per BBL o
liquids throughput: 2449.88': scf/bbl
Helium,
CO2
N2
methane
ethane
abutane
n -butane
opentane
n -pentane
n -Hexane
cyclohexane
Other hexenes
heptanes
methylcydohexane
224-TMP
Benzene
Toluene
Ethylbenzene
Vilenes
CB+Heavies
0'.
55.941
Total
AOC Wt °b
47.`4
lb/lb-mot
Requested Monthly Throughput=
MMscf per month
Sice 5peufic em sson fa¢onoare based on agas sample from the sepamt However, gas flow meta has not yet been nstalled at this faolity Volume¢f waste gas emitted Per BBL of liquids threbghpuO
(GOR}vc'aseskimaied by dNdngtheannual gas production by the-annual<ander ...prodii lonatxh�sfaclM1y fortheyear of2017[({7;769 Msd/yrJ/(31,159 hh1(yr}} 2,449.8: enf/bbi is The GOR
estimatedbasedan Yh se operatorpnnded valties. ag (wthm these er.euhnh:iheGORestimated us ngihe Gas,znd oil pr¢iluctiup record values (2057)In COGISfot one 4f thewelis:.associated
WithYhsfanlley, Forth rtn wells have been reported with these APE°submittals and t:s likely xhatwell"ded ine" hasoauseda':d cr nch s:GOR since the20u79 arfrom wliidh the 005,
re, no new. ase i
is ert mated. TBeref¢re believe [tats temporary GOR will be cone 0 0 a forth separators.
Displacement Equation
Eec 5°MW°Xx/C
APE° LBtied-Emission Pantee „1011::
uncftliSs/A2Mscf}
Ltri.(Ib(MR1Ecf)
35495:33
45.70
5.87: `.:.....
37
2
431,92:
2008
K:\PA\2019\19400876.0,1
Separator Venting Emissions Inventory
Section OS- Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions -
Uncontrolled Controlled
(tons/yearl (tam/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/Veer)
Requested Monthly Umits
Controlled
(Ibs/month)
PMU0
PMZS
3OG
NOx
VOC
CO
O.1K)
0.00
0.00
0,00
9.00
0
0.00
0.00
0.00
0.00
0:00
0
0.03
0.00
040
0.00
0,00
0
0.65
0.54
d54
0.65
0.05
310
2.33.21
154.34
9,72
733.2.1.
11,66
3301
2.94
745
2.49
2.84
2.94
5911
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Em sinro
Uncontrolled Controlled
(Ibs/year) (lbs/yearl
Requested Permit limits
Uncontrolled Controlled
Iles/year) Ilbs/yearl
Benzene
Toluene
Ethylbenzene
Itylene
It -Hexane
224IMP
601
.300
25
690
32
730
525
31
750
37
7?
64
3
,.
4
473
393
20
475
24
5176
4700
236
.5676
254
12
10
Section 06- Regulatory Summary Analysis
Regulation 3, Parts A, 5
Regulation 7, Section XVILS, G
Regulation 7, 5ection 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
Source requires a permit
Somme is nut 001,1001 to Regulation 7, Seutlon XVI10,2, fi
The control device for this separator is not subject to Regulation 7, Section XV3.5.2.a
Does the company use site specific emission factors based on a gas sample to estimate emissions?g'
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-spedffc sample.
H no, the permit will contain an "Initial Testing Requirement" to coiled 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 greeter than or equal to 90 tans per year?
H yes, the permit will contain:
-An "Initial Testing Regalrement" to collect a site -speck gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emisslon factors are less than or equal to the emissions factors established with this application.
-A "Periodic Testing Requirement" to collect a site-spedffc gas sample from the equipment being permitted and conduct an emission factor analysis to demonatrae 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 operatorto alculate gas throughput using the liquid throughput until the meter is installed and operational (not to
exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95%for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling
3 of 8 K:\PA\2019\29A00876.CP1
Separator Venting Emissions Inventory
section 09- Technical Analysis Notes
Opatltprusfflsl8[r5tyddf rer$ cat
AIRS Point#
002
Section 09 - Inventory SCC Coding and Emissions Factors
-Process # SCC Code-
01 3-10-001-80 Flares
Uncontrolled
Pollutant Emissions Factor Control % Units
PM10 0.00 0 h/MMSCF
PM2.5 0.60 tE 4/MMSCF
500 0.00 0 bjMMSCF
NIX 58.4.9 0 is/141.0100
VOC 05435.03 95 1/MM5O0
CO 447.84 0 b/Mh45CF
Benzene 4045 90 6/Mi4500
Toluene 57.04 95 }MN45CF
Ethylbenzene 5.66 95 4/1414500
Xylene 08.07 95 /MMSCF
n -Hexane 411.43 99 4/M141CF
714 TMP 0.90 95 h/MMSCF
4 of 8 K/PA\2019\194008]6.CP1
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
[Source is In the Non -Attainment Arm
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2TPY (Regulation 3, Part A, Section 11.0.1.0)7
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than lO TPY (Regulation 3, Part B, Section ll.D.3)7
'You have indicated that source Is In the Nom -Attainment Area
NON -ATTAINMENT .
1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1 TPY (Regulation3, Part A, Section lI.D.1.a)7
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, riot greater than 5 PT or CO emissions greater than 10 TPY (Regulation 3, Part R, Section 11.0.2)7
ISaurce requites a permit -
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,20147
(source is not subject to Regulation 7, Section XVB.B.2, G
Section XVII.B2- General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G- Emissions Control
Altemative Emissions Control (Optional Sectlopl
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 foe thie separator is not subject to Regulation 7, Section XVB.B.2.e
Section XVII.B.2.e-Alternative emissions control equipment
Disclaimer
'This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply toa 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. Mandatoryterminology such as 'must' end 'required -are intended to describe controlling requirements under the terms of the Clean Air
Ant and Air Qualfty Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Source Req
Source Req
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Western Operating Company
001
1413
Busy Bee Production Facility
History File Edit Date
Ozone Status
11/27/2019
Non -Attainment
EMISSIONS - Uncontrolled (tons per year)
EMISSIONS With Controls (tons per year)
POINT
AIRS
ID
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
0.0
0.0
0.0
0.0
0.0
15.7
0.0
0.0
0.3
0.0
0.0
0.0
0.0
0.0
5.9
0.0
0.0
0.0
Previous Permitted Facility total
0.0
0.0
0.0
0.0
0.0
15.7
0.0
0.0
0.3
0.0
0.0
0.0
0.0
0.0
5.9
0.0
0.0
0.0
001
GP08
Seven 300 bbl Condensate Storage
Tank
0.0
15.7
0.1
0.3
0.0
5.9
0.1
0.0
APEN Update/Mod - Submitted to reflect addition
of new control devices.
002
19AD0876
Separator Venting
0.7
233.2
3.0
3.8
0.7
11.7
3.0
0.2
NEW
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
APEN Exempt/Insignificants
0.0
0.0
XA
Fugitives
0.4
0.0
0.4
0.0
XA
Produced Water Tank
0.1
0.0
0.1
-
0.0
XA
Truck Loadout
0.5
0.0
0.5
0.0
0.0
0.0
FACILITY TOTAL
•
0.0
0.0
0.0
0.0
0.7
249.9
0.0
3.1
4.1
0.0
0.0
0.0
0.0
0.7
18.6
0.0
3.1
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
0.7
248.9
0.0
3.1
4.1
0.0
0.0
0.0
0.0
0.7
17.6
0.0
3.1
0.2
Excludes units exempt from permits/APENs
(A) Change in Permitted Emissions
0.0
0.0
0.0
0.0
0.7
11.7
0.0
3.1
Pubcom & modeling not required for GP
Note 1
Total VOC Facility Emissions (point and fugitive)
(A) Change in Total Permitted VOC emissions (point and fugitive)
18.6
Facility is eligible for GP02 because < 90 tpy
Project emissions less than 25/50 tpy
11.7
Note 2
Page 6 of 8
Printed 1/9/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Western Operating Company
County AIRS ID 001
Plant AIRS ID 1413
Facility Name Busy Bee Production Facility
Emissions - uncontrolled (Ibs per year
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
GP08
Seven 300 bbl Condensate Storage Tank
29
22
2
8
502
4
0.3
002
19AD0876
Separator Venting
600
750
77
478
5676
12
3.8
0.0
0.0
0.0
0.0
0.0
APEN Exempt/Insignificants
0.0
XA
Fugitives
0.0
XA
Produced Water Tank
6
19
0.0
XA
Truck Loadout
2
16
0.0
0.0
TOTAL (tpy)
0.0
0.0
0.0
0.3
0.4
0.0
0.2
3.1
0.0
0.0
0.0
0.0
4.1
otal Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
Emissions with controls (Ibs per year
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
GP08
Seven 300 bbl Condensate Storage Tank
1
1
0
0
25
0
0.0
002
19AD0876
Separator Venting
30
37
4
24
284
1
0.2
0.0
0.0
0.0
0.0
0.0
APEN Exempt/lnsignificants
0.0
XA
Fugitives
0.0
XA
Produced Water Tank
6
19
0.0
7
19AD0876.CP1
1/9/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Western Operating Company
County AIRS ID 001
Plant AIRS ID 1413
Facility Name Busy Bee Production Facility
XA
Truck Loadout
2
16
0.0
0.0
TOTAL (tpy)
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.2
0.0
0.0
0.0
0.0
0.2
8
19AD0876.CP1 1/9/2020
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19AD0876 Issuance: 1
Western Operating Company
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Busy Bee Production Facility
001/1413
SESE Section 6 T3S R60W
Adams County
Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID '
AIRS
Point '
Equipment' Description
Emissions Control
Description
Separator
Venting
002 '
Two (2) Heater -treater separators
Enclosed Combustor
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 (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section 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 9
COLORADO
Air Pollution Control. Division
Department of Pubitc Health E Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
www.colorado.Qov/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 (180) after issuance of this permit, the operator must
install a flow meter to monitor and record volumetric flow rate of natural gas vented from
each separator 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 2449.83 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:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOx
VOC
CO
Separator
Venting
002
---
---
11.7
3.0
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Compliance with the annual limits must be determined on a rolling twelve (12) month total.
By the end of each month a new twelve month total is calculated based on the previous
twelve months' data. The permit holder must calculate actual emissions each month and
keep a compliance record on site or at a local field office with site responsibility for Division
review.
Page 2 of 9
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
8. 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.
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
ID
AIRS
Point
Control Device
Pollutants
Controlled
Separator
Venting ,
002
Emissions from the Separator are routed to
an Enclosed Flare
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,
It.A.4. )
Process Limits
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Separator
Venting
002
Natural Gas Venting
13.1 MMSCF
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
11. Upon installation of the flow meter, the owner or operator must continuously monitor and
record the volumetric flow rate of natural gas vented from the separator(s) using the flow
meter. The 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)
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
13. 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.)
14. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
OPERATING £t MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (atM) 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 OitM 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
16. 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
17. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (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 4 of 9
COLORADO
Air Pollution Control Division
Department of Public Wealth b 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.
19. 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
20. 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.
21. 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.
22. 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,
Page 5 of 9
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
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.
23. 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.
24. 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.
25. 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
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement ' actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
Ben Fischbach
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Western Operating Company.
Synthetic Minor Facility.
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & 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 MalfunctionsThe 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
D
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)'
Separator
Venting
002
Benzene
71432
600
30
Toluene
108883
750
37
Ethylbenzene
100414
77
4
Xylenes
1330207
478
24
n -Hexane
110543
5,676
284
2,2,4-
Trimethylpentane
540841
12
1
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportab e and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 7 of 9
COLORADO
Air Pollution Control Division
Department of Public Health Fr 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:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMscf)
Controlled
Emission
Factors
(lb/MMscf)
Source
NOx
98.19
98.19
AP -42
CO
447.64
447.64
VOC
35,495.33
1,774.77
Engineering
71432
Benzene
45.70
2.29
108883
Toluene
57.05
2.85
100414
Ethylbenzene
5.87
0.29
1330207
Xylene
36.37
1.82
Calculation
110543
n -Hexane
431.92
21.60
540841
2,2,4-
Trimethylpentane
0.90
0.045
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
The emission factors listed above are based on an extended gas analysis of a gas sample taken from a heater -
treater separator servicing the Linnebur #1 well on 11/29/2018, at a separator pressure of 18 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
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC
Page 8 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 9 of 9
JUN 2 4
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
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.govIcdphe/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:
AIRS ID Number: 001 / 1413 /
E. S, N:. ., r.r L
Section 1 - Administrative Information
Company Name':
Site Name:
Site Location:
Western Operating Company
Busy Bee Production Facility
SESE Sec. 6 T3S-R60W
Mailing Address:
p Code1165 Delaware Street, Suite 200
(Include Zip Code)
Denver, CO 80204
Site Location
County: Adams
NAICS or SIC Code: 1311
Contact Person: Steven D. James
Phone Number: 303-893-2438
E -Mail Address2: steve@westernoperating.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form AP.,.;. .. - C14,: l 7'2.018
401373
COLORADO
1I
Permit Number: AIRS ID Number:
001 /1413 /
Section 2 - Requested Action
2 NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
o Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below)
-OR-
❑ ADEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS
O Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
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: Produced natural gas routed to three control devices:
Leed VGI Flare, Cimarron 24" enclosed combustor, and Cimarron 48" enclosed combustor.
Company equipment Identification No. (optional):
For existing sources, operation began on:
2018
For new, modified, or reconstructed sources, the projected start-up date is:
Q Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Will this equipment be operated in any NAAQS
nonattainment area?
hours/day
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
Ventinc A,.
days/week weeks/year
Yes
Yes
Yes
- sic. 7/2018 2 I
❑ No
Q No
• No
COLORADO
Permit Number: AIRS ID Number:
001 /1413 /
Section 4 - Process Equipment Information
j Gas/Liquid Separator
❑ Well Head Casing
O Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? O Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
0 No
Vent Gas
Heating Value:
� ,444
BTU/SCF
Requested:
13.14
MMSCF/year
Actual:
10.95
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
28.33
VOC (Weight %)
47.54
Benzene (Weight %)
0.0612
Toluene (Weight %)
0.0765
Ethylbenzene (Weight %)
0.0079
Xylene (Weight %)
0.0488
n -Hexane (Weight %)
0.5789
2,2,4-Trimethylpentane (Weight %)
0.0012
Additional Required Information:
O Attach a representative gas analysis (including BTEX It n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX 8 n -Hexane, temperature, and
pressure)
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
CflLORFD4
Foirn \PL.., a. Ga t entire 4P EN Remrs o J'2Ci<:
Permit Number:
AIRS ID Number: 001 / 1413 /
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
39.812206, -104.133175
plscargs
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
O Horizontal
❑ Downward
O Other (describe):
Indicate the stack opening and size: (check one)
Circular
❑ Other (describe):
Interior stack diameter (inches):
O Upward with obstructing raincap
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.
O VRU:
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Make/Model:
a
❑✓ Combustion
Device:
Pollutants Controlled: VOCs, HAPs
Rating: 2.17
Type: Flare & Enclosed Combustors
MMBtu / hr
Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature:
Cimarron 24" $N: 2067, Cimarron 48" SN:540-2335
Lead VGI 20.6 Flare
Waste Gas Heat Content: 1,444 Btu/scf
Constant Pilot Light: E Yes ❑ No Pilot burner Rating: MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
CO1.O84.DO
` Ventinc. OPEN Pei si n 7/2018
Permit Number:
AIRS ID Number: 001 / 1413 /
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):
Pollutant
Description of Control Method(s)
Overall Requested
Control Efficiency
(% reduction in emissions)
PM
SOX
NO.
CO
VOC
Enclosed Combustors & Flare
95%
HAPs
Enclosed Combustors & Flare
95%
Other:
From what year is the following reported actual annual emissions data?
2018
Criteria Pollutant Emissions inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfs., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SOX
NO.
0.068
lb/MMBtu
AP -42
NA
0.65
NA
0.65
CO
0.31
lb/MMBtu
AP -42
NA
2.94
NA
2.94
VOC
35,495.33
lb/MMscf
Engineering talc.
194.34
9.72
233.20
11.66
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Emission Factor
Actual Annual Emissions
Uncontrolled
ietc.)
Units
Source
(AP -42,
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions6
(pounds/year)
Benzene
71432
45.70
lb/MMscf
Engineering talc.
500.41
25.02
Toluene
108883
57.05
lb/MMscf
Engineering talc.
624.72
31.24
Ethylbenzene
100414
5.87
Ib/MMscf
Engineering talc.
64.33
3.22
Xylene
1330207
36.37
lb/MMscf
Engineering talc.
398.22
19.91
n -Hexane
110543
431.92
lb/MMscf
Engineering talc.
4,729.51
236.48
2'2'4-
Trimethylpentane
540841
0.909.89
lb/MMscf
Engineering talc:
0.49
Other:
_
5 Requested values wilt 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.
For"'. APCD.2 I - C a V E 4PE Re;isio . 7/7)018
i
COLORADO
5
;:"
Permit Number:
MRS ID Number:
001 /1413/
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
6/17/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Steven D. James
President
Name (please print) Title
Check the appropriate box to request a copy of the:
D 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:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: / / www.coiorado.gov/cdphe/apcd
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