HomeMy WebLinkAbout20203640.tiff C.
*44;40°-
X�: COLORADO
4lit
4;4 Department of Public
Health&Environment
RECEIVED
NOV 3 0 2020
WELD COUNTY
Weld County - Clerk to the Board COMMISSIONERS
1150O St
PO Box 758
Greeley, CO 80632
November 23, 2020
Dear Sir or Madam:
On November 24, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
Outrigger DJ Operating LLC - Makena Gas Plant. A copy of this public notice and the public comment
packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
9gt -,
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ,_tw 7 S'.
Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director '', !,!
i
Pub I:G Re 1/4(:e(--) cc:Pt-0-P. HL(DS),pw(:M/ER/cN/c1O 2020-3640
oG(S )
12/i /2012
12/09 /20
C4-141 Air Pollution Control Division
YouNotice of a Proposed Project or Activity Warranting Public
CDPHE Comment
Website Title: Outrigger DJ Operating LLC - Makena Gas Plant - Weld County
Notice Period Begins: November 24, 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: Outrigger DJ Operating LLC
Facility: Makena Gas Plant
Natural Gas Processing Facility
NESE of Section 25, Township 8N, Range 62W
Weld County
The proposed project or activity is as follows: Outrigger DJ Operating LLC is requesting to modify an
existing synthetic minor natural gas processing facility located in the ozone non-attainment area. With this
application, the operator is requesting to modify the amine sweetening unit, plant flare and fugitives. The
requested modifications are a result of initial sampling and testing results from the first issuance of this
permit. The operator is also requesting to permit new pressurized NGL loadout and compressor blowdown
sources.
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 18WE0503 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:
Harrison Slaughter, P.E.
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
... ,,,. .t. COLORADO
Department of Public
1 Ig c'''' Health Environment
Denver, Colorado 80246-1530
COLORADO
Department of Public
2 ! _ocz,e Health Es Envirosunent
.,,,.. j COLORADO
.&. Air Mlution Control D ivision
C[SPNE
DepaltIlent 0 Pubis'..Health&Ertauiatrrte,1
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 1 8WE0503 Issuance: 2
Date issued:
Issued to: Outrigger DJ Operating LLC
Facility Name: Makena Gas Plant
Plant AIRS ID: 123/9FC0
Physical Location: NESE SEC 25 T8N R62W
County: Weld County
General Description: Natural Gas Processing Plant
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment ID Point Equipment Description Description
One (1)Methyldiethanolamine (MDEA) natural
gas sweetening unit (Make: Dickson Process
Systems, LLC, Model: Custom, SN: 1552)for
acid gas removal with a design capacity of 60 Emissions from the
MMscf per day. This emission unit is equipped flash tank are used as
with two (2) (Make: PumpWorks, Model: fuel for the amine
Amine HP538-5500) electric driven amine reboiler or sent to the
Sweetening 001 recirculation pumps with a limited capacity of plant fuel system. The
Unit 146 gallons per minute of lean amine. Only one acid gas stream from
(1) amine recirculation pump will be operated the still vent is routed
at any given time. The second amine to a condenser and
recirculation pump serves as a back-up only. then to a thermal
This amine unit is equipped with a natural oxidizer.
gas/amine contactor, condenser, flash tank,
still vent and amine regeneration reboiler
covered under point 123/9FC0/004.
Emergency One (1) open flare
Plant Flare 002 Flaring of residue gas during residue (Make: BCCK, Model:
(FS-1761) compressor downtime. EEF-U-24)
One (1) (Make: TBD, Model: TBD, SN: TBD)
Amine natural gas fired amine regeneration heater
Reboiler 004 with a design heat input rate of 10.9 None
MMBtu/hr.
Page 1 of 24
a ' COLORADO
Air Pollution Control Division
Gf:%,1rrle'71 C Putiff'F{e,lth 8::nvirui int'§
Dedicated to protecting and improving the health and environment of the people of Colorado
Leak Detection and
Fugitives 006 Fugitive emission component leaks from a Repair Program per 40
natural gas processing plant. CFR Part 60 Subpart
0000a
Two (2) 400 barrel fixed roof storage vessels
Slop Tanks 009 connected via liquid manifold. These vessels Enclosed Combustion
are used to store crude oil, water and slop oil Device
from compressors.
Pressurized natural gas liquid (NGL) loadout
NGL Loadout 012 from one (1) 60,000 gallon pressurized bullet None
tank to pressurized tank trucks.
Equipment Natural gas venting from blowdowns of four (4)
Slowdowns 013 natural gas driven compressors. Emissions from None
this source are vented to the atmosphere.
This permit is granted subject to all rules and regulations'of the Colorado Air Quality Control Commission and
the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and
conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. Point 012 Et 013: YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen
days after commencement of operation under this permit by submitting a Notice of Startup (NOS)
form to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup
of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180)of the latter of commencement of operation or issuance of this
permit, compliance with the conditions contained in this permit must be demonstrated to the Division.
It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to
demonstrate compliance within 180 days may result in revocation of the permit. A self certification form
and guidance on how to self-certify compliance as required by this permit may be obtained online at
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does
not commence construction/modification or operation of this source within 18 months after either, the
date of issuance of this construction permit or the date on which such construction or activity was
scheduled to commence as set forth in the permit application associated with this permit; (ii)
discontinues construction for a period of eighteen months or more; (iii) does not complete construction
within a reasonable time of the estimated completion date. The Division may grant extensions of the
deadline. (Regulation Number 3, Part B, Section III.F.4.)
4. 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.)
I.E.)
5. Point 004: The following information shall be provided to the Division within fifteen (15) days of the
latter of commencement of operation or issuance of this permit.
Page 2 of 24
COLORADO
Air Pollution Control Division
COM
Ciewtrit,,it Putila_ Neer£r timeInvingirneea
Dedicated to protecting and improving the health and environment of the people of Colorado
• Manufacturer
• Model Number
• Serial Number
This information shall be included with the Notice of Startup submitted for the equipment. (Regulation
Number 3, Part B, III.E.)
6. The operator 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 shall not exceed the following limitations. (Regulation Number 3, Part B,
Section II.A.4.)
)
Monthly Limits:
Facility AIRS Pounds per Month Emission
Equipment Process
ID Point PM2.5 PM,o SOX H2S NO. VOC CO Type
NGL Loadout 012 01 --- --- --- --- --- 354 --- Point
Note: Monthly limits are based on a 31-day month.
The owner or operator shall calculate monthly emissions based on the calendar month.
Facility-wide emissions of each individual hazardous air pollutant shall not exceed 1,359 pounds per
month.
Facility-wide emissions of total hazardous air pollutants shall not exceed 3,398 pounds per month.
The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted emission
units at this facility.
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment Process
ID Point PM2.5 PMto SOX H2S NO. VOC CO Type
Amine 01 --- --- 4.0 0.1 1.2 6.6 1.0
Sweetening 001 Point
Unit 02 --- --- 0.1 --- 5.0 11.0 4.2
Emergency
Plant Flare 002 01 --- --- --- --- 2.5 7.8 11.1 Point
(FS-1761)
Amine 004 01 --- --- --- --- 4.7 --- 4.0 Point
Reboiler
Fugitives 006 01 --- --- --- --- --- 3.9 --- Fugitive
Slop Tanks 009 01 --- --- --- --- --- 1.8 --- Point
NGL 012 01 _ --- --- --- --- --- 2.1 --- Point
Loadout
Page 3 of 24
•- ' COLORADO
Mr Pollution Control Division
C6FHE 11
Deoan vent %WK.Ue0Jth fr trnircrvne=A
Dedicated to protecting and improving the health and environment of the people of Colorado
Equipment 013 01 --- --- --- --- --- 1.2 --- Point
Blowdowns
Note:
1. See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
2. Process 01 and 02 for the amine unit covered under point 001 are as follow:
a. Process 01: Still vent waste gas routed to the thermal oxidizer.
b. Process 02: Combustion of assist gas and pilot fuel by the thermal oxidizer.
Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year.
Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted emission
units at this facility.
During the first twelve (12) months of operation, compliance with both the monthly and annual emission
limitations is required. After the first twelve (12) months of operation, compliance with only the annual
limitation is required.
Compliance with the annual limits, for criteria and hazardous air pollutants, shall be determined on a
rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based
on the previous twelve months' data.The permit holder shall calculate actual emissions each month and
keep a compliance record on site or at a local field office with site responsibility for Division review.
8. The owner or operator must use the emission calculations methods and emission factors found in the
Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this
permit. 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 owner or operator must track emissions from all insignificant activities at the facility on an annual
basis to demonstrate compliance with the facility emission limitations as indicated below. An
inventory of each insignificant activity and associated emission calculations must be made available to
the Division for inspection upon request. For the purposes of this condition, insignificant activities are
defined as any activity or equipment, which emits any amount but does not require an Air Pollution
Emission Notice (APEN) or is permit exempt. (Regulation 3, Part C. II.E.)
Total potential emissions from the facility, including all permitted emissions and potential to emit from
all insignificant activities, must be less than:
• 50 tons per year of VOC
Page 4 of 24
4.4.11
"7., COLORADO
Mr Pollution Control Division
EDP
De ftrn nit Put' He31[11&Eri ree rne'c
Dedicated to protecting and improving the health and environment of the people of Colorado
10. Point 001: For Process 01, compliance with the emission limits in this permit shall be determined by
using the monthly measured still vent waste gas sample composition and monthly measured waste gas
flow volumes. The owner or operator shall calculate uncontrolled VOC, HAP, and H2S emissions on a
monthly basis using the most recent measured waste gas sample composition and monthly measured
waste gas flow volume. A control efficiency of 95%, based on operating the control device in accordance
with the O&M Plan, shall be applied to the uncontrolled VOC, HAP and H2S emissions.
11. Point 001: 100% of emissions that result from the flash tank associated with the amine unit shall be
recycled and used as fuel for the amine reboiler (AIRS Point 123/9CF0/004) or sent to the plant fuel
system.
12. Point 002: The owner or operator shall calculate uncontrolled VOC emissions on a monthly basis using
the most recent measured gas composition and most recent monthly measured flow volume of gas routed
to the flare. The measured gas composition shall be representative of all gases routed to the flare,
including routine maintenance gases when applicable, purge gas and pilot gas. A control efficiency of
95% for VOC shall be applied to the uncontrolled VOC emissions based on operating the flare in
compliance with requirements specified in this permit.
13. Point 006: The owner or operator must calculate actual emissions from this emissions point based on
the most recent component counts for the facility and with the most recent gas analysis, as required in
the Compliance Testing and Sampling section of this permit. The operator must maintain records of the
results of component counts and sampling events used to calculate actual emissions and the dates that
these counts and events were completed. These records must be provided to the Division upon request.
14. The owner or operator shall operate and maintain the emission points in the table below with the
emissions control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment ID Point Control Device Controlled
Amine
Sweetening 001 Still Vent: Thermal Oxidizer (TO) VOC& HAP
Unit
Emergency
Plant Flare 002 Open Flare VOC & HAP
(FS-1761)
Slop Tanks 009 Enclosed Combustion Device VOC & HAP
PROCESS LIMITATIONS AND RECORDS
15. This source shall be limited to the following maximum processing rates as listed below. Monthly records
of the actual processing rates shall be maintained by the owner or operator and made available to the
Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.)
Process Limits
Facility AIRS Process Process Parameter Annual Limit Monthly Limit
Equipment ID Point (31 days)
Amine Processing of natural
Sweetening 001 ___ gas through the 21,900 MMSCF ---
Unit amine unit gas
contactor
Page 5 of 24
.•� ,� COLORADO
4441 601. Air Pollution Control Division
CDP
Dr4.,arttrien 0'%W.Heart'&cr rcnm u
Dedicated to protecting and improving the health and environment of the people of Colorado
Still vent waste gas
01 routed to the 503.4 MMSCF ---
thermal oxidizer
Combustion of assist
02 gas and pilot gas by 69.6 MMSCF ---
the thermal oxidizer
Combustion of
Emergency residue gas during
Plant Flare 002 01 residue compression 49.3 MMSCF ---
(FS-1761) downtime, purge gas
and pilot fuel
Amine 004 01 Consumption of 87.8 MMSCF ---
Reboiler natural gas as a fuel
Slop Tanks 009 01 Crude Oil 23,480 barrels ---
Throughput
Pressurized NGL
NGL Loadout 012 01 2,190 events 186 events
Loadout Events
Blowdown events
Equipment 013 01 associated with four 75 events ---
Blowdowns (4) natural gas driven
compressors
The owner or operator shall monitor monthly process rates based on the calendar month.
During the first twelve (12) months of operation, compliance with both the monthly and annual
throughput limitations is required. After the first twelve(12) months of operation, compliance with only
the annual limitation is required.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total.
By the end of each month a new twelve-month total is calculated based on the previous twelve months'
data. The permit holder shall calculate throughput each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review.
16. Point 001: The owner or operator shall continuously monitor and record the following amine unit
emission streams using continuous operational flow meters:
• Total amine unit still vent waste gas volume routed to the thermal oxidizer,
• Total assist gas volume routed to the thermal oxidizer.
The flow meters must be capable of accurately measuring and recording the maximum and minimum
potential flow rates routed to the thermal oxidizer. The owner or operator shall use monthly throughput
records to demonstrate compliance with the process limits contained in the permit and to calculate
emissions as described in this permit.
17. Point 001: The owner or operator shall continuously monitor and record the volumetric flow rate of
natural gas processed by the amine unit contactor using an operational continuous flow meter at the
inlet to the amine contactor. The owner or operator shall use monthly throughput records to demonstrate
compliance with the process limits contained in this permit and to calculate emissions as described in
this permit.
18. Point 001: This unit shall be limited to the maximum lean amine recirculation pump rate of 146 gallons
per minute. The lean amine recirculation rate shall be recorded weekly in a log maintained on site and
made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4)
Page 6 of 24
. �- COLORADO
Mr Pollution Control Division
CDPHE
DetaliMent cr'Putnlr_'f{aaltt-� ��rvirtr+rt7 )3
Dedicated to protecting and improving the health and environment of the people of Colorado
19. Point 002: The owner or operator shall continuously monitor and record the following emission streams
associated with the open flare using continuous operational flow meters at the inlet to the open flare:
• Total gas volume routed to the open flare including but not limited to residue gas,
• Total purge gas volume routed to the open flare.
The flow meters must be capable of accurately measuring and recording the maximum and minimum
potential flow rates routed to the flare. The owner or operator shall use monthly throughput records to
demonstrate compliance with the process limits contained in the permit and to calculate emissions as
described in this permit.
20. Point 004: The owner or operator shall continuously monitor and record the volumetric flow rate of
natural gas combusted as fuel by the amine regeneration heater using an operational continuous flow
meter at the inlet to the amine regeneration heater.The owner or operator shall use monthly throughput
records to demonstrate compliance with the process limits contained in this permit and to calculate
emissions as described in this permit.
21. Point 012: On a monthly basis, the owner or operator shall monitor and record the total number of
pressurized NGL loadout events. By the end of each month, the total number of events associated with
each pressurized NGL loadout for the previous months' data shall be calculated, and a new twelve month
total shall be calculated and recorded based on the previous twelve months' data. The owner or operator
shall use monthly records to demonstrate compliance with the process limits and to calculate emissions
as described in this permit.
22. Point 013: On a monthly basis,the owner or operator shall monitor and record the total number of
compressor blowdown events. By the end of each month, the total number of events associated with
each compressor blowdown for the previous months' data shall be calculated, and a new twelve month
total shall be calculated and recorded based on the previous twelve months' data. The owner or operator
shall use monthly records to demonstrate compliance with the process limits and to calculate emissions
as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
23. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be
marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.)
(State only enforceable)
24. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
25. 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
26. This source is located in an ozone non-attainment or attainment-maintenance area and subject to the
Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, Section
III.D.2.B. The following requirements were determined to be RACT for this source:
Facility AIRS Point RACT Pollutants
Equipment ID
Page 7 of 24
je .. 4,,..r...t, , COLORADO
i Air Pollution Control Division
CDI' 1 j
Dep£rinle,11 o Public Ffe3lUi&=rlylrl.filr5e i
Dedicated to protecting and improving the health and environment of the people of Colorado
Flash Tank: Recycled and used as amine
Amine 001 _ reboiler fuel or in the plant fuel system. VOC
Sweetening Unit Still Vent: Thermal Oxidizer
Emergency Plant 002 Open Flare VOC
Flare (FS-1761)
Amine Reboiler 004 Natural gas as fuel and good combustion VOC, NOx
practices
Fugitives 006 LDAR as provided at 40 CFR Part 60 Subpart VOC
0000a
Slop Tanks 009 Enclosed Combustion Device VOC
Pressurized NGL loading to tank trucks shall
NGL Loadout 012 be conducted by loading from a pressurized VOC
storage tank to a pressurized tank truck
using a vapor balance system
(i) Use best management practices to
minimize hydrocarbon emissions during, or to
reduce the frequency of, compressor
blowdown emission events. (ii)Perform
routine or predictable compressor blowdown
emissions activities between October 1 and
Equipment April 30,when practicable. (iii) Avoid
Blowdowns 013 performing compressor blowdown emissions VOC
activities on Ozone Action Days, when
practicable. Ozone Action Day advisories are
published by the Colorado Department of
Public Health and Environment. (iv) Where
feasible, the owner or operator must avoid
blowing down the equipment completely to
ambient pressure.
27. Point 001, 004, 006, 012 Et 013: Visible emissions shall not exceed twenty percent (20%)opacity during
normal operation of the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty
consecutive minutes. (Regulation Number 1, Section II.A.1. Et 4.)
28. Point 002: No owner or operator of a smokeless flare or other flare for the combustion of waste gases
shall 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.)
29. Point 004: This source is subject to the Particulate Matter and Sulfur Dioxide Emission Regulations of
Regulation Number 1 including, but not limited to, the following (Regulation Number 1, Section III.A.1):
a. No owner or operator shall cause or permit to be emitted into the atmosphere from any fuel-
burning equipment, particulate matter in the flue gases which exceeds the following (Regulation
Number 1, Section III.A.1.):
(i) For fuel burning equipment with designed heat inputs greater than 1x106 BTU per hour,
but less than or equal to 500x106 BTU per hour, the following equation will be used to
determine the allowable particulate emission limitation.
Page 8 of 24
I PLORAD114.41 Ai Pot nol1
vision
6PHF
Publr_Health&am-Lorne-A
Dedicated to protecting and improving the health and environment of the people of Colorado
PE=0.5(FI)-0.26
Where:
PE = Particulate Emission in Pounds per million BTU heat input.
Fl = Fuel Input in Million BTU per hour.
b. Emissions of sulfur dioxide shall not emit sulfur dioxide in excess of the following limitations.
(Heat input rates shall be the manufacturer's guaranteed maximum heat input rates).
(i) Limit emissions to not more than two (2) tons per day of sulfur dioxide (Regulation
Number 1, Section VI.B.5.a.)
30. Point 004: This source is subject to the New Source Performance Standards requirements of Regulation
Number 6, Part B including, but not limited to, the following (Regulation Number 6, Part B, Section II.C.):
a. Standard for Particulate Matter- On and after the date on which the required performance test
is completed, no owner or operator subject to the provisions of this regulation may discharge,
or cause the discharge into the atmosphere of any particulate matter which is:
(i) For fuel burning equipment generating greater than one million but less than 250 million
Btu per hour heat input, the following equation will be used to determine the allowable
particulate emission limitation:
PE=0.5(FI)-°.26
Where:
PE is the allowable particulate emission in pounds per million Btu heat input.
Fl is the fuel input in million Btu per hour.
If two or more units connect to any opening, the maximum allowable emission rate shall
be the sum of the individual emission rates.
(ii) Greater than 20 percent opacity.
31. Point 004: This source is subject to the New Source Performance Standards requirements of Regulation
Number 6, Part A, Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units including, but not limited to the following:
• §60.48c Reporting and recordkeeping requirements:
o $60.48c(a) - The owner or operator of each affected facility shall submit notification of
the date of construction or reconstruction and actual startup, as provided by $60.7 of
this part. This notification shall include:
■ $60.48c(a)(1) - The design heat input capacity of the affected facility and
identification of fuels to be combusted in the affected facility.
o §60.48c(g)(1) - Except as provided under paragraphs (g)(2)and (g)(3)of this section, the
owner or operator of each affected facility shall record and maintain records of the
amount of each fuel combusted during each operating day.
o §60.48c(g)(2) - As an alternative to meeting the requirements of paragraph (g)(1) of this
section, the owner or operator of an affected facility that combusts only natural gas may
elect to record and maintain records of the amount of each fuel combusted during each
calendar month.
o §60.48c(i) - All records required under this section shall be maintained by the owner or
operator of the affected facility for a period of two years following the date of such
record.
32. Point 006: This source is subject to Regulation Number 7, Part D, Section I.G (State only enforceable).
For fugitive VOC emissions from leaking equipment, the leak detection and repair (LDAR) program as
Page 9 of 24
4644,4„ COLORADO
Air Pollution Control Division
DtoaTitne=5t tf Pub He91th&Er1Virvt ne
Dedicated to protecting and improving the health and environment of the people of Colorado
provided at 40 C.F.R. Part 60, Subpart 0000(July 1, 2017)applies, regardless of the date of construction
of the affected facility, unless subject to the LDAR program provided at 40 CFR Part 60, Subpart 0000a
(July 1, 2017). In addition, the operator shall comply with the General Provisions contained in Regulation
7, Part D, Section I.C.1.
33. Point 009: The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section 11.6.2. General Provisions (State only enforceable). If a flare or other combustion device is used
to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have
no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section
II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the
enclosed flare or combustion device, or by other convenient means approved by the Division, determine
whether it is operating properly. This flare must be equipped with an operational auto-igniter according
to the schedule in Regulation Number 7, Part D, Section II.B.2.d.
34. Point 009: The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion
device is used, it must have a design destruction efficiency of at least 98%for hydrocarbons except where
the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the
inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the
inspections for a period of two years, made available to the Division upon request. This control
requirement must be met within 90 days of the date that the storage tank commences operation.
35. Point 009:The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2.
36. Point 012: All pressurized NGL loading operations, regardless of size, shall be designed, operated and
maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum
extent practicable. (Regulation Number 3, Part B, Section III.E.)
OPERATING£t MAINTENANCE REQUIREMENTS
37. Points 001-002 ft 009: Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (0EtM) 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 0EtM
plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section
III.G.7.)
38. Point 001: The combustion chamber temperature of the thermal oxidizer used to control emissions from
the amine unit still vent shall be greater than 1400`F on a daily average basis. The approved daily
average minimum operating temperature shall be achieved at all times that any amine unit emissions
are routed to the thermal oxidizer in order to meet the emission limits in this permit. The combustion
chamber temperature shall be measured and recorded at least once every hour. If the combustion
chamber temperature value is measured more frequently than once per hour, the source shall record
either each measured data value or each block average value for each 1-hour period calculated from all
measured data values during each period.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
39. Point 009: The owner or operator shall complete site specific sampling including a compositional analysis
of the pre-flash pressurized crude oil routed to these storage tanks and for emission factor development,
a sales oil analysis to determine RVP and API gravity. Testing shall be in accordance with the guidance
contained in PS Memo 05-01. Results of testing shall be used to determine site-specific emissions factors
for VOC and Hazardous Air Pollutants using Division approved methods. Results of site-specific sampling
Page 10 of 24
4-4"..t- COLORADO
Air Pollution Control Division
6pHE
Littari unt O Put&Hekti b tntitrGrirrie-'.1
Dedicated to protecting and improving the health and environment of the people of Colorado
and analysis shall be submitted to the Division as part of the self-certification and used to demonstrate
compliance with the emissions factors chosen for this emissions point.
40. Point 013: The owner/operator shall complete an initial site specific extended gas analysis ("Analysis")
within one hundred and eighty days (180) after commencement of operation or issuance of this permit,
whichever comes later, of the natural gas vented during compressor blowdowns in order to verify the
VOC, benzene, toluene, ethylbenzene, xylenes, n-hexane, 2,2,4-trimethylpentane, methanol and
hydrogen sulfide content (weight fraction) of this emission stream. Results of the Analysis shall be used
to calculate site-specific emission factors for the pollutants referenced in this permit (in units of
lb/event) using Division approved methods. Results of the Analysis shall be submitted to the Division as
part of the self-certification and must demonstrate the emissions factors established through the Analysis
are less than or equal to, the emissions factors submitted with the permit application and established
herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor
developed through this Analysis is greater than the emissions factors submitted with the permit
application and established in the "Notes to Permit Holder" the operator shall submit to the Division
within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to
address this/these inaccuracy(ies).
Periodic Testing Requirements
41. Point 001:At a minimum frequency of once per calendar month, the owner or operator shall sample and
complete an extended gas analysis of amine unit still vent waste gas. This sample shall be analyzed for
gross (higher) heat content and total VOC, Benzene, Toluene, Ethylbenzene, Xylene, n-Hexane, 2,2,4-
trimethylpentane, methanol and H2S content (weight fraction). The sample shall be collected prior to
the inlet of the thermal oxidizer and prior to being combined with any other stream. The sampled data
wilt be used to calculate emissions specified in this permit. If an amine unit is not operated during a
calendar month, monthly sampling is not required.
42. Point 001: On an annual basis, the owner/operator shall complete a site specific extended gas analysis
("Analysis")of the residue gas combusted as assist gas and pilot fuel by the thermal oxidizer. The sample
shall be analyzed for gross (higher) heat content and total VOC, benzene, toluene, ethylbenzene,
xylenes, n-hexane, 2,2,4-trimethylpentane, methanol and hydrogen sulfide content (weight fraction) of
this emission stream. The sample shall be collected prior to the inlet of the thermal oxidizer and prior
to being combined with any other stream. Periodic sampling shall be conducted at a minimum of at least
one hundred and eighty (180) days apart. Results of the Analysis shall be used to calculate site-specific
emission factors for the pollutants referenced in this permit (in units of lb/MMSCF) using Division
approved methods. Results of the Analysis must demonstrate the emissions factors established through
the Analysis are less than or equal to, the emissions factors submitted with the permit application and
established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions
factor developed through this Analysis is greater than the emissions factors submitted with the permit
application and established in the "Notes to Permit Holder" the operator shall submit to the Division
within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to
address this/these inaccuracy(ies).
43. Point 001: The owner or operator shall sample the inlet gas to the plant on an annual basis to determine
the concentration of hydrogen sulfide (H2S) in the gas stream. The sample results shall be monitored to
demonstrate that this amine unit qualifies for the exemption from the Standards of Performance for
Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced
After September 18, 2015 (60.5365a(g)(3)).
44. Point 002: At a minimum frequency of once per calendar month, the owner or operator shall complete
an extended gas analysis of the gas routed to the plant flare. The sample shall be representative of all
gases routed to the flare, including routine maintenance gases when applicable, purge gas and pilot gas.
Each sample shall be analyzed for gross (higher) heat content and stream composition including VOC
Page 11 of 24
g -z ICOLORADO
Air Pollution Control Division
C6PNH
1 OtOairrIelt CO Publa..titan 6 Er v r“tmenl
Dedicated to protecting and improving the health and environment of the people of Colorado
content using EPA approved methods. The sampled data will be used to calculate emissions specified in
this permit.
45. Point 006: On an annual basis, the owner or operator shall complete an extended gas analysis of gas
samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP)
that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance
demonstration as required in the Emission Limits and Records section of this permit.
46. Point 006:Any time a physical change is made at the facility which increases the number of components,
and not to exceed a period of five years from the previous count, the operator must complete a physical
hard-count of facility components. This hard-count must distinguish between components in "gas
service", "light liquid service", "water/oil service", and "heavy liquid service". The hard-count and
running total of all additions and subtractions to the component count must be maintained and made
available for the Division upon request. This component count must be used in the compliance
demonstration as required in the Emission Limits and Records section of this permit
47. Point 013: On an annual basis, the owner/operator shall complete a site specific extended gas analysis
("Analysis") of the natural gas vented during compressor blowdowns. The sample shall be analyzed for
total VOC (weight fraction)of this emission stream. Periodic sampling shall be conducted at a minimum
of at least one hundred and eighty (180) days apart. Results of the Analysis shall be used to calculate
site-specific emission factors for the pollutants referenced in this permit (in units of lb/event) using
Division approved methods. Results of the Analysis must demonstrate the emissions factors established
through the Analysis are less than or equal to, the emissions factors submitted with the permit application
and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific
emissions factor developed through this Analysis is greater than the emissions factors submitted with the
permit application and established in the "Notes to Permit Holder" the operator shall submit to the
Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification
to address this/these inaccuracy(ies).
ADDITIONAL REQUIREMENTS
48. All previous versions of this permit are cancelled upon issuance of this permit.
49. A revised Air Pollutant Emission Notice(APEN) shall be filed: (Regulation Number 3, Part A, Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons
per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment
areas emitting less than 100 tons of VOC or NO,r 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.
Page 12 of 24
�-"•-"�' COLORADO
�°"` Air Pollution Control Division
CDPHE
Lk r'lrew•3l o Pubis:Ffealtli& avitcrcee-,1
Dedicated to protecting and improving the health and environment of the people of Colorado
• 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.
50. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary
source or modification becomes a major stationary source or major modification solely by virtue of
a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of
the source or modification to otherwise emit a pollutant such as a restriction on hours of operation
(Regulation Number 3, Part D, VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if emission
limits are modified to equal or exceed the following threshold levels:
Emissions -tons per year
Facility AIRS Equipment
Equipment tion Pollutant Current
ID Point Descrip Threshold Permit
Limit
Amine Amine
Sweetening 001 Sweetening
Unit Unit
Emergency
Plant Flare 002 Open Flare
(FS-1761)
H-781 003 Hot Oil Heater
Amine 004 Amine Reboiler
Reboiler
Mole Sieve
H-741 005 Regeneration
Heater NOx 50 29.9
C-1151 007 SI RICE VOC 50 41.1
C-1152 008 SI RICE
Slop Tanks 009 Storage Tanks
C-1153 010 SI RICE
C-1154 011 SI RICE
NGL Loadout 012 NGL Loadout
Equipment Equipment
Blowdowns 013 Blowdowns
Insignificant
Sources
Page 13 of 24
-r ' COLORADO
IAir Pollution Control Division
CDPHE I
0tt2atInlent 0'Pubtr tiealtii&Lnvtr.rv'rleni
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes: APEN exempt and Permit exempt sources do not have permit limits. However, the PTE of these
sources is still considered in the project increase when evaluating PSD and NANSR.
51. Point 006: MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and
Natural Gas Production Facilities major stationary source requirements shall apply to this stationary
source at any such time that this stationary source becomes major solely by virtue of a relaxation in any
permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH.
(Reference: Regulation Number 8, Part E)
52. Point 004: MACT Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for Major
Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters requirements shall apply
to this source at any such time that this source becomes a major source of hazardous air pollutants(HAP)
solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable
requirements of that Subpart on the date as stated in the rule as published in the Federal Register.
(Reference: Regulation Number 8, Part E)
GENERAL TERMS AND CONDITIONS
53. 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.
54. 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.
55. 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.
56. 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.
57. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to
or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such
occurrence, this permit shall be deemed denied ob 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.
Page 14 of 24
�z-� COLORADO
Air Pollution Control Division
CDPHE
Dee,N.Inleli[r'Put tieeltfl B l.rlvtrufmle'a
Dedicated to protecting and improving the health and environment of the people of Colorado
58. 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.
59. 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:
Harrison Slaughter, P.E.
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 March 18, 2019 Issued to Outrigger DJ Operating LLC
Permit for one (1) 60 MMscf/day MDEA natural gas
sweetening unit, one (1) plant flare, one (1) 10.9
MMBtu/hr amine regeneration heater, fugitives,
and two (2)400 barrel fixed roof storage vessels at
a new natural gas processing facility located in the
ozone non-attainment area.
Issuance 2 This Issuance Issued to Outrigger DJ Operating LLC
Point 001: Update throughput and emission limits.
Remove monthly limits. Update periodic testing
requirements.
Point 002: Update throughput and emission limits.
Remove monthly limits. Update emission
calculation methods and periodic sampling
requirements.
Point 006: Update emission limits based on
component counts and site specific sampling.
Add Points 012 £t 013 to the permit.
Page 15 of 24
O
.z ' M i�Luti R A tion of Division
CDPNB
DeOarimeit 6e Pubk Health tr crlvircn,'n 51
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees
will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A,
Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of the
owner or operator providing there is no exceedance of any specific emission control regulation or any ambient
air quality standard. A revised air pollution emission notice (APEN) and complete application form must be
submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision
for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction
condition which causes a violation of any emission limit or limits stated in this permit as soon as possible,
but no later than noon of the next working day, followed by written notice to the Division addressing all of
the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
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 source(s) operate at the permitted limitations.
Facility AIRS Uncontrolled Controlled
Equipment ID Point Pollutant CAS # Emissions Emissions
(Ib/yr) (Ib/yr)
Benzene 71432 30,772 1,539
Toluene 108883 13,872 694
Ethylbenzene 100414 817 41
Amine
Sweetening 001 Xylenes 1330207 2,986 149
Unit n-Hexane 110543 849 42
2,2,4-
540841 0.1 5.7x10-3
Trimethylpentane
Hydrogen Sulfide 7783064 4,208 210
Formaldehyde 50000 7 7
Amine Benzene 71432 0.2 0.2
004
Reboiler
Toluene 108883 0.3 0.3
n-Hexane 110543 169 169
Benzene 71432 141 19
Toluene 108883 101 14
Fugitives 006 Ethylbenzene 100414 13 2
Xylenes 1330207 34 5
n-Hexane 110543 803 110
Page 16 of 24
�«� COLORADO
Air Pollution Control Division
CDPHF
L1tt 3rarie+it ee Purim-HeaJU1&tri rcr r ie-v
Dedicated to protecting and improving the health and environment of the people of Colorado
2,2,4-
540841 1 0.1
Trimethylpentane
Methanol 67561 11 2
Benzene 71432 371 19
Toluene 108883 252 13
Ethylbenzene 100414 25 2
Xylenes 1330207 60 3
Slop Tanks 009 n-Hexane 110543 2,118 106
2,2,4-
540841 2 0.1
Trimethylpentane
Hydrogen Sulfide 7783064 1 0.1
Methanol 67561 9 1
Benzene 71432 16 16
Toluene 108883 12 12
Ethylbenzene 100414 2 2
NGL Loadout 012 Xylenes 1330207 4 4
n-Hexane 110543 91 91
2,2,4-
540841 0.1 0.1
Trimethylpentane
Methanol 67561 1 1
Benzene 71432 1 1
Toluene 108883 0.2 0.2
Equipment 013 Ethylbenzene 100414 0.02 0.02
Blowdowns
Xylenes 1330207 0.1 0.1
n-Hexane 110543 5 5
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Emissions from the amine unit result from venting of acid gas (still vent overhead). Additionally, emissions
result from the combustion of thermal oxidizer (TO) assist gas and pilot fuel.
Process 01: Still Vent Waste Gas Routed to the Thermal Oxidizer
Emissions from Process 01 include venting of acid gas (still vent overhead) and combustion of acid gas (still
vent overhead).
Controlled still vent acid gas emissions:
Actual VOC, HAP and H2S emissions from the venting of still vent acid gas shall be calculated based on the
most recent monthly still vent waste gas sampling and the most recent monthly measured still vent waste
Page 17 of 24
,, x}. ' COLORADO
I Air Pollution Control Division
CDPHE
DepaftMe,}t C'Publr:.f fealth Er trwr rne•"d
Dedicated to protecting and improving the health and environment of the people of Colorado
gas flow volume. The following equation shall be used in conjunction with the sample and flow volume data
to calculate actual emissions:
Weight%x Sample MW,lb lb—mole 1.0x106 scf Metered Still Vent Volume,MMscf
Emission Ratex= x
100 x lb—mole x 379 scf x 1 MMscf Month
Where:
*Emission Rate.= the actual monthly emissions of VOC, HAP and H25 in units of lb/month.
*Weight%.= VOC/HAP/H2S concentration based on actual sampled values of the amine unit still vent
waste gas stream.
*Sample MW = Molecular weight based on actual sampled values of the amine unit still vent waste gas
stream in units of lb/lbmole.
*Metered Still Vent Volume = the actual measured monthly flow volume of the amine unit still vent routed
to the TO in units of MMscf/month.
Controlled emissions are as follows:
Point Source Control Efficiency
Still vent controlled by thermal oxidizer 95%
Flash tank recycled and used as fuel for amine 100%
unit reboiler or in plant fuel system
SO2 emissions resulting from the combustion of H2S emissions in the still vent waste gas stream are based on
a mass balance. The mass balance utilizes molecular weights of 64.066 lb SO2/lb-mol and 34.08088 lb H25/lb-
mol. The calculation assumes 100% of uncontrolled H25 in the still vent waste gas stream is converted to SO2
when combusted by the thermal oxidizer. The following equation shall be used to calculate actual SO2
emissions:
lb ll H2S Still Vent Emission Rate,lb 64.066 lb SO2 lb -mol
SO2 Emission Rate (monthl = month x lb—mol x 34.08088 lb H2S •
Thermal oxidizer combustion of still vent acid gas:
Emissions associated with the combustion of still vent waste gas by the thermal oxidizer are calculated using
the following emission factors, the most recent monthly gross (higher) heat content, and the most recent
monthly metered volume of total still vent acid gas routed to the thermal oxidizer:
Uncontrolled
CAS# Pollutant Emission Factors Source
(lb/MMBtu)
NOx 9.8x10-2 AP-42 Chapter 1.4
Table 1.4-1
CO 8.24x10' AP-42 Chapter 1.4
Table 1.4-1
Note: Permitted combustion emissions are based on a gross(higher) heating value of 36.72 Btu/scf.
Page 18 of 24
°'_, ' COLORADO
Air Pollution Control Division
CDPNE
Deoa(Eme•110'Pubk ifealtti6 Errrtrurvrle-ii
Dedicated to protecting and improving the health and environment of the people of Colorado
Process 02: Combustion of assist gas and pilot fuel by the thermal oxidizer:
Uncontrolled Controlled
CAS# Pollutant Weight Emission Emission Source
Fraction (%) Factors Factors
(lb/MMSCF) (lb/MMSCF)
NOx --- 141.44 141.44 AP-42 Chapter 1.4
Table 1.4-1
CO 118.81 118.81 AP-42 Chapter 1.4
Table 1.4-1
SOx --- 8.49x10-1 8.49x10-1 AP-42 Chapter 1.4
Table 1.4-2
VOC 12.21 6308.98 315.45 Mass Balance
Note: NOx and CO emission factors in the table above are based on a residue fuel gas heat content of 1442.7312 Btu/scf.
The VOC emission factor in the table above was calculated based on a site specific residue fuel gas composition obtained
from the facility on 10/09/2019 in conjunction with the EPA Emission Inventory Improvement Program Publication: Volume
II, Chapter 10= Displacement Equation (10.4-3). The controlled VOC emission factor is based on the thermal oxidizer
control efficiency of 95%. Actual emissions are calculated by multiplying the emission factors in the table above by the
assist gas fuel volume for the thermal oxidizer(as measured by flow meter) plus the fuel volume of the thermal oxidizer
pilot tight (constant at 50 scf/hr).Monthly pilot light gas throughput shall be determined by multiplying the hourly pilot gas
throughput(50 scf/hr)by the monthly hours of operation of the thermal oxidizer.
Total actual emissions are obtained from the sum of emissions resulting from the venting of acid gas(still
vent overhead)and combustion of acid gas(still vent overhead)(process 01)and the combustion of assist
gas and pilot light gas by the thermal oxidizer (process 02).
Point 002:
Emissions associated with the open flare result from the combustion of residue gas during residue compressor
downtime (process gas), purge gas and pilot light gas. Total actual emissions are based on the sum of
emissions calculated for the combustion of residue gas, purge gas and pilot light gas(150 scf/hr).Total actual
emissions are calculated using the following emission factors and equations:
Uncontrolled
CAS# Pollutant Emission Factors Source
(lb/MMBtu)
NOx 0.068 AP-42 Chapter 13.5
CO 0.31 AP-42 Chapter 13.5
Note: NOx and CO emissions are calculated using the emission factors in the table above, the most recent monthly flare
gas higher heat content and the total monthly volume of residue gas (metered), purge gas(metered)and pilot light gas
(constant at 150 scf/hr) routed to the flare. Monthly pilot light gas throughput shall be determined by multiplying the
hourly pilot gas throughput(150 scf/hr) by the monthly hours of operation of the open flare.
Actual VOC emissions shall be calculated based on the most recent gas sampling and the most recent total
monthly volume of residue gas (metered), purge gas (metered) and pilot light gas (constant at 150 scf/hr)
routed to the flare. Monthly pilot light gas throughput shall be determined by multiplying the hourly pilot
gas throughput (150 scf/hr) by the monthly hours of operation of the open flare. Controlled emissions are
based on 95% control for VOC. Actual VOC emissions are calculated using the following equation:
Page 19 of 24
4..,..-.:r. COLORADO
Mr Pollution Control Division
GDP HE
n DK, trftni O'Ruble_Health&LrtwihxL r e',i
Dedicated to protecting and improving the health and environment of the people of Colorado lb VOC (month) VOC concentration(wt%) - 100 x Purge/Process/Pilot Gas ( scf
month)
En scf
x Gas Molecular Weight (lbmol) —379 (lbmol) x (1—95%control)
*VOC concentration and Gas Molecular Weight are based on actual monthly sampled values of
the gas streams routed to flare. The gas sample shall be representative of all gases routed to the
flare, including routine maintenance gases when applicable.
*Purge/Process Gas is the actual measured monthly flow volume of the gas routed to flare.
*Pilot gas volume (scf/month) is determined by multiplying the hourly pilot gas throughput (150
scf/hr) by the monthly hours of operation of the open flare
*Purge/Process/Pilot gas is the sum of the metered purge/process gas and the calculated pilot
light gas volume.
Point 004:
Uncontrolled
CAS# Pollutant Emission Factors Source
lb/MMscf
NOx 106.61 AP-42 Chapter 1.4
CO 89.56 Table 1.4-1
Note: The emissions factors for this point are based on a rated heat input of 10.9 MMBtu/hr, a higher heating value
of 1,087.47 Btu/scf and 8,760 hours of operation per year.
Point 006:
Component Gas Service Heavy Oil Light Oil Water/Oil
Service
Connectors 2,241 --- 1,019 81
Flanges 586 --- 370 42
Open-ended Lines 5 --- 3 1
Pump Seals 29 --- 14 1 .
Valves 660 --- 380 37
Other* 2 --- 3 1
VOC Content (wt. %) 23.09 --- 100 100
Benzene Content (wt. %) 7.79x10-3 --- 3.86x10-' 3.86x10-'
Toluene Content (wt. %) 2.13x10-3 --- 2.85x10-' 2.85x10-'
Ethylbenzene (wt. %) 2.13x10-4 --- 3.77x10-2 3.77x10-2
Xylenes Content (wt. %) 6.4x10-4 --- 9.58x10-2 9.58x10-2
n-Hexane Content (wt. 5.05x10-2 2.18 2.18
%)
2,2,4-Trimethylpentane """--- 1.3x10 3 1.3x1O3
Content (wt. %)
Methanol (wt. %) --- --- 3.04x10-2 3.04x10-2
*Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump
arms, hatches, instrument meters, polish rods and vents
TOC Emission Factors (kg/hr-component):
Page 20 of 24
is„ :„.„ CO
ft' Mr Luti R A D Control Division
ivision
CDPHE
• DesNaq r ent a'PuLt>_Health b_r5wcurrie-,1
Dedicated to protecting and improving the health and environment of the people of Colorado
Component Gas Service Heavy Oil Light Oil Water/Oil
Service
Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04
Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06
Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04
Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05
Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05
Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02
Source: EPA-453/R95-017 Table 2-4
Control Percentages Granted for Compliance with LDAR Program:
Component Gas Service Heavy Oil Light Oil Water/Oil
Service
Connectors 81% 81% 81% 81%
Flanges - - - -
Open-ended Lines - - - -
Pump Seals - - 88% -
Valves 96% - 95% -
Other - - - -
Note that the emission limits included in this permit are derived by multiplying the equipment counts in the
table above by a factor of 1.25 to accommodate other minor changes to the facility and to provide a
conservative estimate of facility-wide emissions.
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed.
in the table above with the most recent site specific component counts, multiplied by the VOC content from
the most recent extended gas analysis.Controlled emissions are based on the efficiencies for each component
type in the table above.
Point 009:
Uncontrolled Controlled
CAS# Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
VOC 3.04 1.52x10-1
71432 Benzene 1.58x10-2 7.9x10-4 ProMax Et EPA
108883 Toluene 1.07x10-2 5.35x10-4 - Tanks 4.09d
110543 n-Hexane 9.02x10-2 4.51x1O3
Note: The controlled emissions factors for this point are based on the enclosed combustion device control efficiency
of 95%. The site specific VOC and HAP emission factors in the table above were developed using ProMax for
flash emissions and EPA Tanks 4.09d for working and breathing emissions. The ProMax simulation is based
on a representative sales gas sample obtained from an upstream facility (Hemberger 3-26-34-8-60) on
Page 21 of 24
' COLORADO
An Pollution Control Division
CZPHE
C Tirne•t o'Put'h_"Haattii Et Z, rirene—d
Dedicated to protecting and improving the health and environment of the people of Colorado
September 13, 2012. The EPA Tanks simulation uses crude oil RVP 5 for the fluid basis and Denver as the
location.
Point 012:
Uncontrolled
CAS# Pollutant Emission Factors Source
lb/loadout event
VOC 1.903 Engineering
Calculation
Note: Emission factors are based on a liquid line volume of 0.0491 ft3/loadout and a vapor line volume of 0.175 ft3/loadout
venting directly to atmosphere and a liquid density of 34.21 lb/ft3 and a vapor density of 1.28 lb/ft3. Actual emissions are
calculated by multiplying the monthly recorded number of pressurized NGL loadout events by the emission factors in the
table above.
Point 013:
Uncontrolled
Emission Factors
CAS# Weight Fraction of Pollutant lb/blowdown
Source
Gas (%) event
21.6338 VOC 31.36 Engineering
Calculation
Note: Emission factors are based on a site specific inlet gas sample obtained from the facility on 05/21/2019. The
molecular weight(21.9746 lb/lbmol) and weight fraction from the gas sample along with the EPA Emission Inventory
Improvement Program Publication: Volume II, Chapter 10-Displacement Equation (10.4-3)were used to develop the
emission factor.Actual emissions are calculated by multiplying the monthly recorded number of compressor blowdown
events by the emission factors in the table above.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit
is valid for a term of five years from the date it was received by the Division. A revised APEN shall be
submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual
fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For
any questions regarding a specific expiration date call the Division at (303)-692-3150.
7) Point 001: This source is subject to 40 CFR, Part 60, Subpart OOOOa—Standards of Performance for Crude
Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After
September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 02, 2016). This rule has
not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the
complete subpart is available on the EPA website at: https://www.gpo.gov/fdsys/pkq/FR-2016-06-
03/pdf/2016-11971.pdf This unit is subject to requirements including, but not limited to the following:
• 860.5365a-Applicability and Designation of Affected Facilities
o 560.5365a(g)(3) - Facilities that have a design capacity less than 2 long tons per day
(LT/D) of hydrogen sulfide (H2S) in the acid gas (expressed as sulfur) are required to
comply with recordkeeping and reporting requirements specified in §60.5423a(c) but are
not required to comply with 5560.5405a through 60.5407a and §§60.5410a(g) and
60.5415a(g).
• §60.5423a- Record keeping and reporting Requirements
o §60.5423a(c) -To certify that a facility is exempt from the control requirements of these
standards, for each facility with a design capacity less that 2 LT/D of H2 S in the acid gas
(expressed as sulfur)you must keep, for the life of the facility, an analysis demonstrating
that the facility's design capacity is less than 2 LT/D of H2 expressed as sulfur.
Page 22 of 24
je4440
COLORADO
Mr Pollution Control Division
C8FHE
De. erne t c Pubh_tieeeh Er r nrk.c rnc
Dedicated to protecting and improving the health and environment of the people of Colorado
8) Point 006: This source is subject to 40 CFR, Part 60, Subpart OOOOa—Standards of Performance for Crude
Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After
September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 02, 2016). This rule has
not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the
complete subpart is available on the EPA website at: https://www.gpo.gov/fdsys/pkg/FR-2016-06-
03/pdf/2016-11971.pdf
9) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control
device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable.
10) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, NOx, CO, benzene and total HAPs
NANSR Synthetic Minor Source of: VOC and NOx
PSD Synthetic Minor Source of: VOC, NOx and CO
MACT HH Major Source Requirements:`Not Applicable
Area Source Requirements: Not Applicable
MACT DDDDD Not applicable
NSPS Dc Applicable to point 004
NSPS Db Not applicable
NSPS Kb Not applicable
NSPS KKK Not applicable
NSPS LLL Not applicable
NSPS OOOO Not applicable
NSPS 0000a Applicable
11) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
•
http://ecfr.gpoaccess.gov/
Page 23 of 24
g , COLORADO
Air Potlntion Control Division
cim,
L' artrnent ot Pubic F( airhi 6 Ervor.::mile-i
Dedicated to protecting and improving the health and environment of the people of Colorado
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A- Subpart UUUU
NSPS Part 60, Appendixes Appendix A-Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A- Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 24 of 24
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details- For Division Use Only
Review Engineer. Harrison Slaughter
Package#: 420637_
Received Date: 9/27/2019 Updated application submitted on 08/28/2020
Review Start Date: 19/23/2020
Section eD-Facility Information
Company Name: Outrigger Dl Operating LLC Quadrant Section Township Range
County AIRS ID: 123 - NESE 25 I 8N I. 62
Plant AIRS ID. SFC0
Facility Name: Makena Gas Plant $.
Physical
Address/Location: _. rnhlp gie,Lee,62W
County: Weld County
Type of Facility: Natural Gas Processing Plant
What industry segment?Oil&Natural Gas Production&Processing
Is this facility located In a NAAQSnon-attainment area? Yes
if yes,for what pollutant? Ozone(NOx'&VOC)
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use only
AIRS Point# Permit#
(Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering
APCD has already Emissions Source Type Equipment Name control? APCD has already # Required? Action Remarks
assigned) assigned)
Amine Sweetening Permit
001 --Amine Unit Unit Yes 18WE0503 2 Yes Modification
Emergency Plant Flare -Permit
002 Process Flare -; (F5-1761) No 18WE0503 2 - Yes Modification
No Action
003 NG Heater H-781 No 18WE0504.XP -- No Requested
No Action
004 - NG Heater Amine Reboiler No 18WE0503 2 No Requested
NO Action
005 NG Heater H-741 No 18WE0505.XP -- No Requested
Permit
006 Fugitive Component Leaks Fugitives No 18WE0503 2 Yes Modification
No Action
007 .,Natural Gas RICE C-1151 Yes. GP02 -- No Requested
No Action
008 NaturaiGas RICE C-1152 Yes GP02 -- No Requested
No Action
009 Storage Tank - Slop Tanks Yes. 18WE0503 2 Yes Requested
No Action
010 '-Natural Gas RICE C-1153 Yes GP02 -- No Requested
No Action 1
011 Natural.Gas RICE I C-1154 Yes GP02 -- No Requested
Permit
012 '- Liquid Loading - NGL Loadout No 18WE0503 2 Yes Modification New Source
Equipment - Permit
01.3 Maintenance Blowdowns elowdowns No 18WE0503 2 Yes Modification New Source
Section 03-Description of Project
Outrigger DJ Operating LLC(Outrigger)submitted an application to modify an existing synthetic minornaturalg s processing facility located in the ozone non
attainment area.With this application,the operator is request rig to:modify existing equipment and add new sources to the facility.The changes requestedwith this
application areasfollows: -
1.Amine Sweetening Unit(Point 001):The operator is requesting to update the throughput and emission limits for this source due to higher than expected VOC
concentrations In the sampled still vent waste gas and fuel gas streams.The ongoing sampling and testing requirements were also updated for this source.
2.Plant Flare(Point 002):Decrease requested throughput from 154.5 MMSCF/year to 49,3 MMSCF/year.increase the VOC emission limits based on higher than.
expected VOC concentrations in the initial samples.The ongoing compliance demonstration for this source was updated due to potential variability in the gas
vented tothe plant flare for combustion.
3.Fugitives(Point006):Update emission limits based on actual component counts and initial gas sampling.
4.Add two(2)new sources to the facility wide permit.These sources include pressurized NGLloadout and equpmentbiowdow Self-certification is required for
these new sources.
The self-certification for the first issuance of the permit was received by the Division.on 09/30/2019.Initial stack testing was completed and approved for points
004,007,008 and 010.As a result,the initial testing for point 004 will be removed from the permit The operator completed the site speck pressurized liquid
sampling required for point 009;however,:the operator did not develop site specific:emisslon factors to confirm the originally established values are either accurate
or conservative.Ate result,the initial testing for point 009 will remain in the permit.The operator completed the tial site specific sampling of still vent waste gas
and thermal oxidizer assist gasrequired for point 001.These initial testing requirements were removed from the permit.The operator also completed the residue
gas sampling required for point 002.As a result,the initial testing for point 002 was removed from the permit.Finally,the operator completed the Initial gas
sampling and component counts for point 006.These requirements have been removed from this issuance of the permit.
Public comment is requ'redfor this permit action because new synthetic minor limits are being established for point 002...:
Sections 09,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? Requesting Synthetic Minor Permit
Section 05-Ambient Air Impact Analysis Requiremen
Was a quantitative modeling analysis required? No
If yes,far what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stati,enarySaurce Classification
Is this stationary source a true minor? 9f4
isthlsstationerysourceasyntheticminer?
if yes,Indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration IPSO) 0 ❑2 0 D ❑ ❑
Title V Operating Permis(OP) 0 2 02 O ❑ ❑ ❑+
Non-Attainment New Source Review(NANSR) ❑+ ❑+
Isthls stationary source a major source? No
If yes,Indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TOP HAPs
Prevention of significant Deterioration(POD) 0 O O 0 ❑ ❑
Title V Operating Permits(OP) O O O O O ❑ O O
Non-Attainment New Source Review(NANSR) ❑ ❑
Amine Sweetening Unit Emissions Inventory
Imm num• omx,a.rv.mdm.a.n uwn �- .m wn,4Ra*vr on ` n2e gAgAN
kh P rq",ttc
omancn M� Sn m�ala.v
o.aan/m.+.n...uu.nmrz:',7°,2:7",-7"`""-
1-4,-J: _ a=n+/min.
mnx=ant[wFm=m
n.+x r.nt a
».m.,,En�>ym.-Mnlnamn:m�.mt.nan.mr.:tnro,=,mu Ici• xrenn,i am.+nn�xew
.m=.+ Rewated
x.�na.ntwam s+vm:tx= w ,�, r<ro - mmM
+a S __ MM,e/n
,MM n=m ntrmm=nt w m
I I CI
m+aM
Mot.G.HeatIngvIlkurxvt vn N1L13 �W><r - -mmN/vr to # vM/N n mm�aNr
nlmswnc.,x..xnay.i.. i��-.Blu/H rii.tcunnc.,x.nuay.n,.. .x mho
mmr a, mame.m t ... _
m em uml,Annuol Imm,n/vrlt ImM m:nl NImmetlPerun.lai
nl=txmoe,rmwenwt .,nv._ i,.:i.
mmeu.aw anmuaMwaxmsm.aia.e ., ,}gyYb ess,_s
m.l x
ix .,:.,mnnm..�n :.p....ner,:�, r am,.u.=��,,.,a maKw;;a,+,mr.oti m� ma,a<,n:naaasoammavuaou �mm„�m�m �e nom,.mm.aame
s:rl.» anen,o-
,arn, m+n.,m, ,n:�.
ea 4rt; el mn t�l.eomr mw methane aaw„=mm.m`�nun.,,.�w„t
m�*Imoilnxt na.
• w.�;ntxl.ro.�ana
met voc
mua/nn Ce'trolled i hid
rmm� <,n m.
VOC
glasne
Zene
-�._' a�nnnnm an,nn „n milama �n .e nemn
WIMP
nee maWk.xl. 9
Amine Sweetening Unit Emissions Inventory
imw zomtao..wreai w.p.,Inm. ... :liens....)
ma envoy.
roe
anzazo-'I®®
Rota.�®i
mm
na. sxw®-
za®®
Istudo
IM
.0000
nont=tv mow.
o®-
Li!
mwioft
Boo. Ita
oo
nvz--
rrz i®
;ntAnZnovoe zoom
W0000 we
oo
man...1 om0000.. azm�®
vocmolx vocu�x®
Utttattt.td cont..
oak.. Pum+m,al I m•e c.l.lmr.adsw�
Iso.i v.. o rM
wpm. „Sntimo
moo
Mme
PAW,
mal
11171.
tam., PeMmae,l zmxxw,mne.sa.,..
Iw..0 x.ncw,ie.n cal
vuot
[a
tww
mos
onon
rtttam et witotte4
Px.,nx.ace.eu•cal �e..,ml
vrc roueamm r, sys.au.cts
ralm.nt Pbzmmewl
jwa ma.. wwwv
IREMENUMEMPRIEREPRERN
NERIIw.nell..,cwnuu• co
MMIERMINIMM
Amine Sweetening Unit Emissions Inventory
ova.pehannu upa:v�.l rode EelnA ul.o. IWA..a ImW
MILS .
SON
NOx
ittenti•No Enot Paquette perry...
:aa areotlwna i
pmabe,tme
h .
wcE0.lanw;sabmrtaaooe
yeereew.yu ub rywenrnee,tveemleiaeetsetal
s.m r-ea Jrdo<.I.m.sem,umena..,nn....,...m..a
un
.mpnre xemm xm Y wnu rmv Rene
saw.mnnm rae rnxntew ab. x., - .., "..
tamp
ryldiur with
:<avem�mml cmdel paw emab.m,ma+n x.wmtmea.dm,:„opwamn baw.umn
•
semmw*endow nn.ma .
avah
uewawae retl:tlbr. :vmum-t
mhmwrenn.xaem neMdnnaic
lemnmeatner <wntnr,Jnb w.pa�e,eamwn names mdmmn.wm nn emmpwnenvnmta.mmpana«Il�.n.a.rm.mnemmendn, pmt ma,mn.mm.pwwmnepa wem,3,IntAa curator.... nexaa,ten wroenb
men.pla ;gi:ageo e.b,hn
mrn.hm b:rl re d he n heemd .m. n
m.nva.nmmetM en ....5.1[111vent Mal.rne stanched controleklegovigoeoted by the W.A.re vend
03/13,111....4.1.011.411itopentor wed
ern~ .em w`°ietImNrier1400oR e,mr:n" �.empa toe!wtOsorn In
WM.)tho-ornareNO,Try, F.<rwmn:arr�.tt ,imroroeMrco gal
Utuatbnx.,nmwa.tie..,m.plongm,".",4emaamae:emmeuen.neYvar
n.:mono« w.gola.arona:.....Ue.mrytr tedbvnbronrngoeraartw.need...natYRo-:bea:n.ewata:llv...steu..nem.n.
r mkary:tim.flohro ulatmnwx:eme.mpmeeanbeaa.o.erQru1n.rgmoon.erretree,Ualeoeemmrowmuneamammte,gemaannaw:n tneanlaentwnmw
le theewealrptmnaname.wlvmrw„tog..wrw,enUpnaa,eab.taewoMa.mnaet
mnh
n.donwento<nvradvR erennteto th.na3w tlh epemn a..
''a he xmappmw:m avax MMmWnnm x rtm:amu...z perrwmdana.w mroa
n toa nnefr..lem vn .rmu F p reclulatlryretleto145.6
p mlwkw.md56zemmdevm.x'neaa mb newaepsw ng m.mbe a<Imvmm manzsr.m e acu.tmavro
swssyssgsfazes.ubxzy0n.0•Roubsm»Neenorl/Aaaensa rirzsxeeme4=naetselesvt/Y.a.psspvr.
,.wwr•xmmmtmtb„e.aebn.ewmYmwrta ne,omwrananoleroes:nsneowUmxrmm..w.exusuede..olmnanrep,.nam<nW.wreoeenn,a:w:ewal:.:e,w:emenoo
*firy.ua 3..Us,omenmpmwtnmmwwdba!v.uwa,b:une..maa:asw.s.,mw.naw.u,row.
e aary awaw,n brood z m.. .mezee wrw.ry w wd mmmeanPeN wzatas R.wppmlwwanntbxmnwmwtomge twnr mlxz I emz.,
hitom ve.a hMumxno RmngmMuapm.F t,re.l4ssaar+l.p.sv anotnmxzsleey
N zzcnnmmmM1eammP mndrclwv aed n,he purnit.
vny.naryhz I Rm9 epgeip:euel .er ae
ie me
ampudig.eappikatbni.lemenserathrecogryntrationryfY0c*ncifarnrytotlieluel,ample vannie..a..4 p5,./.9, oft em.ova net
rypalyaaymea w z m�mWa ye,vnssmweeemwrammMo-dtclnoerz eemlvw.hmrvp5.smlM Wwmonmmvllee.ne
AlUamigtheok‘rytionsaboryemtww,.mvarywm awmanweae.:ee maven me.vent aroma..U.,..9.!i parr aewntrer hwwmvin I.pwr,mlMmmeratM,na
taletenrya:etetlonoo rep .nap/yyutlle,, endhan:e:vme.pm.aemmm
mmmaaxronwwkawimuehatmtvemweav munmMexa aepv:mJtei:n,re tnq v MnmNpdmeia:te.v o e Imwmn
!.. v tnehrmoreenenoneu mo,txyFm:vn v.
e peumeR.pan emNo m pMueh4vpa Ye r
z - - atwie.xe wo ,omepmcesi newnm nom.rwe u.
rrou.me [,btpran teat maµpo�ss zMM.Uve.wa:m eeey deievvbu dM emrt.mtnrw Mrtrafrynr
tine wbefu:tha�nolry
ox0 while.metea(;.evarertce,t.n.h.me da/wrnkma,en-
m.;ae„wed sna.tanktlrnerymrtlMrnrepealawu:P.Mitnmvxmnywwtra.eam. tti anVotrm°`4mn.ro ns'en :erw.w,.riaewrnw.r mlq...w.r��5,sryontatex for...U. 4rylkellan are W e*-m,.e,.mpe.awn ween„w.,war
6orl tMOOarpmN.,,Imiargnearronkpom...mood.'Ix.Monttelakr:mYmrcpmaeetawe.pwvaetemnneetmeeaeavteaepwmermabmew..com..neand
.crw b or e..v aenxmnnbandapExre.ne riarte acmuullleowntermw,wtlbt meteyrm.Naeyhea vemmmem.npN,ngtheanme e n
Semen ps-s¢<mlmma Finaanne Fauerelpor lnvm,ervuxeoma
alxswlma Code ororwaptoo••v.moot fa,m .rv. amen
EMylhvene b/MMss
•
Amine Sweetening Unit Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B-APES and Permit Requirements
< _
ATTAINMENT
1, Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY(Regulation 3,Part A,Section ll.D.1.a)?
2. Are total 500133 uncontrolled VOCemissions greaterthen 5 TPY,NOx greater than 1OTPY or CO emissions greater than 1OTPY(Regulation 3,Part B,Section 11.0.31?
Simisourss isin the Non-A0ivm,'ent I nc
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than STPY(Regulation 3,Part A,Section ll.D.l.a)7 Source Requires an APES.Go to the next question
2. Aretotel facility uncontrolled VOC emissions from the greater than 2TPY,NOx greater than 5TPY or CO emissions greater than lOTPY(Regulation 3,Part B,Section 11.0.2)? — Source Requires a permit
'St:r__requires a permit
NSPS Analysis
1. Is the sweetening unit located at an onshore natural gas processing plant that,processes natural gas produced from either onshore or offshore wells? +e, (You have Indicated the facility type on the Project Summary Sheet
I5... is rimier-it, ss iirsturtuius usiisiirusiiusertioui
40 CFR,Part 60,Subpart LLL,Standards of Performance for SO2 Emissions from Onshore Natural Gas Processing
1. Did construction or modification(see definitions 40 CFR 60.2)of the sweetening unit commence after January 20,1984 and on or before August 23,2011(60.640(d))7 .The unit is not subject-Gott Subpart 0000
2. Does facility have design p ty less than 2 longi per dy(LT/D)of hydrogen sulfide(HZS)in the and gas(expressed as sulfur)(6o.640(b))7
•
Subpart A,General Provisions
§60.642-Standards for sulfur dioxide
§60.646-Monitoring of emissions ernissions and operations
§60.647-Recordkeeping and reporting requirements
40 CFR,Part 60,Subpart 0000.Standards of Performance for Crude Oil and Natural Gas Production.Transmission and Distribution •
1. Did construction,modification or reconstruction(see definitions 40 CFR 60.2)of the sweetening unit commence after August 23,2011 and on or before September 18,20157 j The unit is not subject-Coto Subpart 0000e
2. Does facility have a design capacity less than 2 long tons per day(LT/D)of hydrogen sulfide(HOS)in the acid gas(expressed as sulfur)(60.5365(g)(3))7
Subpart A,General Provisions per§60.5425 Table 3
§60.5405-Standards for sulfur dioxide
§60.5407-Monitoring of emissions and operations
§60.5423-Notification,Recordkeeping and reporting requirements
40 CFR.Part 60,Subpart 0000,Standards of Performancefor Crude Oil and Natural Gas Facilities
1. Did construction,modification or reconstruction(see definitions 40 CFR 60.2)of the sweetening unit commence after September 18,20157 The unit is subject-Go to question2
2. Does facility have a design capacity less than 2 long tons per day(LT/D)of hydrogen sulfide(H25)In the acid gas(expressed as sulfur)(60.5365a(g)(3))? _
e,th,ctth hses shoce-he,,rasecnicci s:,d aco,ii.s P-e4iiiuurisuuis tisui_._._
Subpart A,General Provisions per§60.5425a Table 3
§60.5405a-Standards for sulfur dioxide Do Not Apply
§60.5407a-Monitoring of emissions and operations Do Not Apply
§60.5423a(c)-Recordkeeping and reporting requirements
• Colorado Regulation 3 Parts B.Section III.D.2.a-RACT
Sovrce 1:m rt;o RA^'
Disclaimer
this document assists operators with determining applicability of certain requirements of the Clean Air Act,Its implementing regulations,and Air gaamy Control
Commission regulations.This document is not a rule or regulation,and the analysis g 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"mbsf"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.
•
•
r-:lt F -1 s5. -(1 r_ _Cry
Section 01-Administrative Information
'Facility AIRS ID: 123 9FC0 002
County Plant Point
Section 02-Equipment Description Details
Ffaring of residue gas d g residue pees.or downtime.
Detailed Emissions Unit Desorption
Em ss'on Control Device Description: One(1)open flare(fvlak S C•,:Mode.:EEFU24)
Requested Overall VOC&HAP Control Efficiency%: 95
Limited Process Parameter TC+ re°r,
Ar
Gas meter '1r-_ r01 ,
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Separator
Actual Throughput y 39.4 MMscf per year
Requested Permit Limit Throughput ',43,60473}MMscf per year Requested Monthly Throughput= 3.770 MMscf per month
Potential to Emit(PTE)Throughput= 04 MMscf per year
Purge Gas Flow Rate y✓f,, �,1 SR cf/hr
Pilot Light Flaw Rate=x4.x.,gtry.+t,.:.T0,`'R cf/hr
Purge&Pilot Light Throughput= 6._94 MMscf per year
Process Control(Recycling)
Equipped with a VRU
Is VRU process equipment: 0'1');,',0, 0
Secondary Emissions-Combustion Device(s)for Air Pollution Control
Separator Gas Heating Value: . 1443 Btu/scf
Volume of wastages emitted per BBL of tlIMMOVICal
liquids throughput: WEINMAN scf/bbl
Section 04-Emissions Factors&Methodologies
Description
This flare is used to ontrol residue gas during residue gas compression downtime.Emissions for hr source were calculated based on the composition(mole%)and heat content obtained from a fuel gas temple obtained from the
Makena Gas Plant on 10/09/2019.1he mole%values from the sample were converted to weight%using the molecular Weighty of each component as shown below.The calculated xveigh.V and molecular weight values were
used in the Displacement Equation(shown below)to calculate site specific emission factors and emissions.
MW Ib/Ib-mol Displacement Equation
EeoQeMW`lx/C
___Moe% Molecular Weight Ibx/Ibmole Weight%
Helium _ 0.000000 4:00
CO2 0.029270 44.01
N2 1.137160 28.01
Hydrogen 0.000000:' 2.00
Oxygen 0.000000 32.00
Hydrogen Sulfide 0.000000 34.08 _
methane 80.330110 16.04
ethane 13.238930 30.06 ._ ...
propane 4.792740 44.09
isabutene 0.161020 .58.12
n-butane i 0.284340 08.12
Isopentane 0.014450' -72.11
n-Pentane 0.011970 72.11
cycle pentane 0.000000 70.01 ..
n-Hexane 0.000000. 86.18
cyclehexane 0.000000 84.16 :
Other hexanes 0.0001300" 86.18 ..
heptanes 0.000000 100.21 0
methylcyclohexane 0.000000- 98.19 0 0
224-TMP 0.000000 114.29 0 0
Benzene 0.000000 7812 0 0
Toluene ..0.000000 92.15 9 C•
Ethylbenzene 0.000000 106.17 ..
Xylenes 0.000000, _ 106.17 0 0
Methanol 0.000000 32.04 2 0
CB+Heavies 0.000000 116:.00 a 1
Total Total r 01.__
VOC Mol% _._.-. VOCwt% 12.307
Emission Factors Separator Venting
Uncontrolled Controlled
Emission Factor Source
Pollutant (lb/MMscf) (lb/MMscf)
(Gas Throughput) (Gas Throughput)
VOC 54,,_ 3< 315,9b*.v t
Benzene 9.90995-9,, '4:''''''`'e
Toluene ,. 99,E+0=0 .
Ethylbenzene 0,-0001,0 _00B
XYlene 1.99939.90 9.9999,9-9.9
n-Hexane 9.903999,9ii 0 ,00E-90
224 TMP 9.95909-,99, 9,099994;9 44. -
Methanol E ow:,_r:9, __:
Hydrogen Sulfide _ s -
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu( lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
PM25 vfh(075 22 750.t $+yet
sox p:B006 3?t3 _
NOx be10s0680 99.15.6 C`--, tr c.
CO ''0.3100 4479,9r q:.};i
6 of 16 C:\Users\hslaught\Desktop\1239FC0\18WE0503.CP2
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) (Ins/month)
PM10 3.26 11.21 5,22 _ 025 5.2265.Oi
PM2.5 _ 0 26 221 0.21 0..2.66 >.25
SOx 2-22 0.02 2.02 0.322 0.02 3.55
NOx 2.52 _.03 1.3 2 512 2.€2 410.7£
VOC 15552 125..25 - 66.22 155 52 7.7€ 1320.82
CO 11.02 U.S. 502 11.02 _ 1a72.as
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) (Ibs/year) (Ibs/Year) (Ibs/year) (Ibs/year)
Benzene 30011 0.•1000 0 0_„- .000'0 0.vuCO
Toluene x;.6000 0.551205
Ethylbenzene 2.0006 0.5300 0 2-5-2 ..
Xylene OG2.0 003,30
n-Hexane - 53 3.603`0 ,..
224 TMP 5,{;0,30 1,0020 r 551: 0,005.5,00 3.00E555
Methanol ?31' 33052 0,0 0.02E,551 6.625,00
Hydrogen Sulfide 2,w.ca .r»u _., 5.0-cno 0.6205
Section 06-Regulatory Summary Analysis
Section lI.A.1-Except as provided in paragraphs 2 through 6 below,no r operator of a source shall allow or cause the emission into the atmosphere of any
air pollutant which is in excess of 20%opacity.This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes.The
approved reference test method for visible emissions measurement is EPA Method 9(40 CFR,Part 60,Appendix A(July,1992))in at subsections of Section H.A and
Regulation 1 B of this regulation.
Section 11.6.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity fare period or periods aggregating more than six
minutes in any sixty consecutive minutes.
Section l.A-No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable
Regulation 2 odors which are measured in excess of the following limits:For areas used predominantly for residential or commercial purposes it is a violation if odors are
detected after the odorous air has been diluted with seven(7)or more volumes of odor free air.
Part A-APEN Requirements
Criteria Pollutants:For criteria pollutants,Air Pollutant Emission Notices are required for:each individual emission point in a non-attainment area with
Regulation uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant(pollutants are not summed)for which the area is non-attainment.
Applicant is required to file an APEN since emissions exceed 1 ton per year VOC
Part B—Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPYthreshold(Reg.3,Part B,Section 11.0.2.5)
Part D,Section 11.8.2:Based on the information provided by the operator,this source is not intended to control emisssians from any equipment subject to
Regulation 7 Regulation 7,Part 0,Section R.Asa result,the flare is not subject to this portion of the Regulation.
(See regulatory applicability worksheet far detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Requirements
Using Gas Throughputte Monitor Compliance
1,15
Does the company use site specific emission factors based one gas sample to estimate emissions?
Thissample 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 en older site-specific sample.
If ea,the permit will contemn en"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct en emission factor analysis to
demonstrate that the emission factors are less than or equal to the emissions faders established with this application.
Are facility-wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonetteinment area
OR are emissions greeter than or equal to 90 tans per year in the ozone attainment area?
If yes,the permit will contain:
-An"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
-A"Periodic Testing Requirement.'to collects site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than for 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? 2es
If no,the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational(not to
exceed 180 days).This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03.
Does the company request a control device efficiency greater than 95%for a flare or combustion device?
If yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on
inlet and outlet concentration sampling
y.:
e :, 0000 _,...O,
��wvY X fn v,�vx �Yrar9arta' .,IW.'
;j I r. vqa 0001 e. ,
w _ .A . M
iii Vigi4igiPg'1*- VVANVAX.40-7,W,Y20500=4*Pr'20MPLA*M400110Pw.„iqui-F 2/#255:55%,2555,,,,5522,8,5
- 3' .'rya.
�'r . 'x 84.5550454a445155P‘;155,2405.2'55.55%284.,A,W2,85/2854555A52,5042252,22A
O(42148 5." 5 ,tome O5 i, i
7 0016 C:\Users\hslaught\Desktop\1239FC0\18WE0503.CP2
Section 08-Technical Analysis Notes
1.According to the operator,this flare is intended to be used to combust reside gas during residue compression downtime.The flare MD also be used to combust gasfrom-the plant during upsets or emergencies.However,the operator is
only permitting foreseeable events associated with residue compression downtime Based on this information,it was determined the site specific fuel gas composition obtained on 10/09/2019 wet appropriate for estimating emissions
associated with the combustion of esldue gas.It should be noted that the HOC weight%tend n the application more conservative than.the HOC weight%,n the flare gas:sample(05/21/2019)provided in thyself certification for the first
issuance of thispermit.
2.The previous issuance of the permit for this source established emission factors the operator would use in conjunction with the metered gas a demonstrate ongoing compliance.Intial sampling demonstrated that the composition of the
gas routed to the flares variable and the VOC concentration substantially higher than originally expected.Additionally,the total permitted HOGemissions at this facility are greater than 40tpy.For these reasons,the erosion factors for
u
this source have been removed from the permit and the operator H required to use monthly g samples in conjunction with the metered gesto demonstrate ongoing compliance.This methodology will provide a more accurate
representation of actual emissions from this source This is important due to the fact that permitted emissions at this facility aren close proximity to major source thresholds and the initial sampling has shown variability in the gas
composition.It was determined that initial sampling would not be required again for the source because the p rmt now requires monthly sampling
3.The operator provided the following information regarding the flow meters used for this source.h There y o purge gas meter and a total stream rooter forthe flare.Purge g s is metered separately before entering the total/lore stream
where iris also counted in the flared total Since there is a single flow meter that is capable of measuring the total range of:flow routed to the flare from purge gas and waste gas,the permit will contain a single process limit for the purge
gas,pilot gas and waste gas combusted by the flare
4.Emissions for this source were calculated based on the composition(hole%)and heat content obtained from a fuei gas sample obtained from the.Makena Gas Plant on 10/09/2019.The mole%values from the sample were converted
to.weight%using the molecular weights of each component as shown below.The calculated:weight%and molecular weight values were used in the Displacement Equation(shown in Section 04)to calculate site specific emission factors
and emissions.It should be noted that the hoc concentration in the fuel gas sample aced in the application(12.21%by weight)ismore conservative than the VOC concentration in the sample of flare gas(9.02%by weight)provided in the
self-certification that was received on 09/30/19 Additionally,the fuel gas sample in the application does not any HAPs whereas the sample provided in the self certification has a weight%of 00002 xylene.While the sample in the self-
certification is more conservative with regards to HAPs(xylene only),the xylene emissions are below APEN reporting thresholds when calculated using the weight%.fro,the self-certification.Since these emissions are negligible,it was.
deemed ac eptable to usethe fuel gas sample provided in the application for caculat ng HAP.emissions.
S.As discussed in the regulatory summary analysis section,this flare is not subject to Regulation 7,Part y,Section II because it is not intended to control emissions from any equipment that is subject to this portion of the Regulation.
However,the operator still provided the altem t e emission control equipment re uest form This form rovide,some additional details regarding this flare including:I The flare hose manufacturer guaranteed destruction efficiency P pQ P g B g:j�} g .of
98%.(')The op n flare ie deeded to operate with no visiblee emissions during normal operation. i)The flares adequately designed and sized to achieve the control efficiency rated and handle foreseeable fluctuations in emissions of VOC
and hydrocarbons during normal operation.(v)The flare will be designed such that an observer can,by means of visual observation from the outside of the flee,determine whether t'is operating properly.{v)The flare will be equipped
with an auto-igniter
6.According to the operator,the pilot fuel use rate is constant at 150 acf/hr.Asa result,the operator wilt track the hours of operation in order to determine the total pilot gas volume This total volume will be included with the metered
purge and residue gas in order to demonstrate compliance wrth the permitted process limit of 49.3 MMscf/year.
7.It should he noted that pilot light emissions are not typically assigned a control efficiency.ln this case,the.controlled"emission rate of 31545 b/MMscf is very conservative compared to the AP-42 Chapter 1.4 emission factor of 55
lb/MMscf.Asa result,the assumption of uncontrolled and controlled pilot light emissions rs very conservative and therefore acceptable for permitting.
8.The source has operated for more than one year.As a result,monthlylmits will be removed from the permit for the source.
9.The annual sampling included in the permit only requires the operator to provide an ongoing compliance demonstration for VOC.This determination was made because the facitywide HAP emissions are not within 20%of the major
source thresholds(i.e.S spy for individual HAP and 20 spy for Total HAP).As a result ongoing sampling requirements for HAPs at this facility would provide minimal benefit at this time.
10.The operator was provided with e draft permit and APEN redline to review pier to public comment.The operator reviewed the documents and expressed they had no comments regarding the plant flare in the permit and that they
agreed with.the OPEN redlines.
Section 09-Inventory SCC Coding and Emissions Factors
Uncontrolled
Emissions
AIRS Point 4 Process f! SCC Code Pollutant Factor Control% Units
002 01 PM10
PM2.5 _ _=
SOO
NOx 22,_ ..
VOC 2: Wi1C1
-
CO
Benzene ,222 2.1 z1-2213-13
Toluene
Ethylbenzene ._' 3, :yr ,2v
Xylene
n-Hexane
224 TMP _ _z, ._ .__-7
Methanol 22,32
Hydrogen Sulfide _v
8 of 16 C:\Users\hslaught\Desktop\1239FC0\18WE0503.CP2
Section 01-AdminstratNe Information
'Facility AIRS ID: 323 9rL0 006
County Plant Point
Section 02-Equipment Description Details
Detailed Emissions Unit Fuit(teatrlission cum leaks from a nature( processing plant•
Description: _ ponen[ gaz
Emission Control Device Nona
Description:
Section 03-Processing Pate Information for Emissions Ertlmates
ThlOsedlonis not appliabletcfugitives.
Section 04-Emissions Factors&Methodologies
Regulation 7 Information
Operating Hours: . 8760 hoursyear
EmIssion Factor Source 'i$fntidei[5.F'?-EPP445OR-95-Dt7i'ablee2-
Control Efficiency Source: ' ',b1a 8OT4100DePi
Calculations Inlet Gas Sample(05/21/2019):
Emission Factor(kg/hr-
service Component Type Count source) Control(%)Pollutant Mass Fraction Uncontrolled Controlled Pollutant Weight%Normalized Wetght%
Table 24 Table 2-6 Emissions(tpy) Emissions(Wy) H2S 0
Connectors 2241 2.00804 L00E-05 81.0% VOC ,, . . CO2 . 53474
Flanges 404 3.90E-04 5.70E-06 0.0% Benzene N2 0.9304
Open-Ended Lines 5 200E-03 150E-05 00% Toluene Methane 57.3400
Gas Pump Saab .28 2.40E-03 3.50E04 0.0% Ethylbenzene Ethane 18.7321.
Valves 004 4.50E-03 2.50E-05 96.0% Xylenes • ._ Propane 14.6683
Other 2 8.80E-03 1.20E-04 0.0% n4lexane ,. - i-Butane
Relief Valves 0 8.80E-03 120E-04 0.0% 2,2,4-TOP n-Butane 4108
— - — — — Methanol 0 i-Pentane 0.5538 s
Connectors 9 7.505.06 7.50E-06 61.0% VOC • n-Penane
Flanges 44 3.90E-07 3.90E-07 00% Benzene - Cycopentane 0.0319 .. ,
Open-Ended Lines 6 1.40E-04 7.20E-06 60% Toluene n.Hexane "0.0473
Heavy OPPump Steals .0 0.00E+00 0.00E+00 0.0% Ethylbenzene Lyclohexane 0,0085
Valves 0 8,40E-06 8.40E-06 00% Xylenes Other Hexanes 0:1
Other 0 3.20E-05 3,20E-05 60% n-Hexane Hepdnas 0.0129 - ^
Relief Valves 0 — — — 2,2,4-TOP MMykyzlohexane 0,0042 e
— — — — — Methanol 224-TOP -0
Connectors 101@ 2.105.04 9.70E-06 81.0% VOC T - ..,:.1 + Benzene ..0.0073
Flanges 370 110E-04 2.40E-06 60% Benzene -- Toluene -0,002 1.tt',.s.',
OpenEnded lines 1 1408.03 1.40E-05 0.0% Toluene - - ,- Ethylbenzene 0:0002
Light Oil Pump Seals 14 130E-02 5.10E-04 886% Ethylbenzene "— ., Xylene 0:0066
Valves 380 250E-03 190E-05 95.0% Xylenes ". Octanes 0.0053
Other 3 7,50E-03 1.10E-04 0.0% n-Hexane Nonarces 0.0096
Relief Valves 0 7,10803 1,10E-04 0.0% 2.2,4TMP Cecanes 0,0161 '
— —, — — — Methanol •, , 02/Argon .0.0109
Connectors 81 110E-04 1.00E-05 816% VOC
Flanges 42 290E-06 2.90E-06 e.O% Benzene ' -- - Total
Open-Ended Lines >1 250E-04 3.50E-06 00% Toluene VOC
Walerl011 Pump Seals 1 240805 2.40E-05 0.0% Ethtdbenzene • • ' Total HC •+
VaNas 37 9,80E-05 9.70E-06 0.0% Xylenes '
Other 4 1,40E-02 5.90E-05 0.0% n-Hexane _„.
Relief Valves 0 — — — 2,2,4-TMP
— — — — — Methanol 9 . .. s 0385667394
0.284693202
Section OS-Emissions Invento, 0.037684342
Did operator request a buffer? "T`wl-W A 0.095750467
Requested Buffer(16): -26 2.176682099
0001296672
Pollutant Uncontrolled Emissions Controlled Emissions Source 0.030445154
VOC . ip0 4:'toy Standard EFs-EPA-45318-95-017 Table 2-4 WY
Benzene tlb/yr 1.i Mt Standard EFs-EPA-453/8-95-017 Table 24 0.070566234 00096735
Toluene : Iblyr - lb/yr Standard EFs-EPA453/R-95017 Tab1e2-4 0.050456224 0.0069098
Ethybenzena /ILJyr Ih/yr Standard EFs-EPA453IR-95At7TaNe24 0.003647849 0.0009102
Xylenes -''IWyr •,4,Fyr Standard EFs-EPA4531R-95-0t7 Table 2-4 0.01693551 0.002319
n-Hexane It lbryr 'I1$ Standard EFs-EPA-453/0-95-017 Table 2-4 0.401224385 0.0650140
2.2,4-TOP solblyr Iblyr Standard EFs-EPA-45318-95.017 Table 24 0.000225426 3,085E-05
Methanol ,'6 lMyr NW,. Standard EFs-EPA-45318.95-017 Table 2.4 O005292875 O0007243
Section 06-Regulatory Summary Analysis
Reg,3 Review Regulation 3,Part m.Section III.D.2 to determine is RACT is required! Y
Review.CFR.Part60.Subpart KKK to determine if applicable to this source? 6b
Reg.fi
Review 40 CFR,Part 60.Subpart 0000 to determine if 60.5380 and/or 60.5385 is applicable? No
Reg,7 Review Section XVI I.F to determine is/DAR Is applicable? No
Additional Requlabsry Considerations
Section 5.4.1-Except as provided in paragraphs 2 through 6 below.no owner on operator of a source shall
allow or cause the emission ino the atmosphere of any air pollutant which is in excess of 20%opacity.This
Regulation 1 Manodb is based en 24 corseculNe opacity readngs taken at 15.second Marvels fur se minutes.The
approved reference test method for visible emissions measurement Is EPA Method 9(40 CFR.Part 60,
AppendixA(July,1992))in all subsections of Section II.A and B oft.regulation.
Section LA-No person,wherever located,shall cause or allow the emission of odorous air contaminants from
any single source such asks result in detectable odors which are measured In excess of the following limits,
Regulation 2 For areas used predominantly for residential or oommemial purposes it is a violation if odors are detected after
the odorous Br has been diluted with seven(7)or more volumes of odor[meek.
Part A-APEN Requirements
Criteria Pollutants:For criteria pollutants,Air Pollutant Emission Notices are required for:each indivdual
emission point In a non-attainment area with uncontrolled actual emissions of one ton per year or more of any
individual criteria pollutant(pollutants are not summed)for which the area is non-attainment,
Applicant is required to file an APEN since emissions exceed 1 Mn per year VOC
Part 8—Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater
than the 2.0 TPY threshold(Reg.3,Part B,Section IID,2,a)
Is th's source located in an ozone non-aRzlnmevl area or attainment maintenance area? Y
Ifyeo.is this source subject to leak detection and repair(LOAR)reglrirements per Regulation 7.Part D Section
Regulation 3 II.E or I.0 or 40 CFR,Part W,Subparts KKK,0000,or 0000a? on
Part 6,III.D.2-RACY requirements for new or modified minor sources
This section of Regulation 3 requires FACT for new or modified minor sources located in
nonattainment orattainmentlmaintenance areas.This source is located in the 8-hour ozone
nonattainment area
The date of interest for determining whether the source is new or modified is therefore November 20,
2008(the date of the efiour ozone NA area deslgnadon).Since the fugitives will be in service after the
date above,this source Is considered"new or modified"
This facility is subject to NSPS 0000.Following the leak detection and repair program per NSPS
0000a satisifies the RACT requirements of Regulation 3.The permit will contain a condition
reflecting this determination.
Is this source at an onshore itiatural gas processing plant"as defined In 40 CFR,Part 60.631? Yes
Did this construct.,reconstruction o modification agar January 20,1984,and on or
before August 23,2011?es No
This source is not subject to NSPS KKK because the equipment covered by this fugitive source will
commence construction after August 23,2011.
Regulation 6
Did this source commences construction,reconstruction,or modification after August 23.2011 and on or
before September 18,2015? No:.
Source is not subject to NSPS 0000 because the equipment covered by this fugitive source will
commence construction after September 18,2015.
Is tn.source located in an ozonanon-attainment area or attainment maintenance arm? Yes
Is tills source at an onshore"natural gas processing plant.as defined in 40 CFR,Part 60.631? Yes
Faciity is classified as a natural gas processing plant Therefore,this source is subject to Regulation
Regulation 7 7,Part 0,Section LG.
Is tre facility classified as a wall production facility or natural gas compressor station? No
Since this facility is not classified as a well production facility or natural gas compressor station,it is
not subject to Regulation 7,Part D,Section II.E.
Is Ms source at a"natural gas processing plant"as defined in 40 CFR,Part 63.761? hes
Is this facility considered a"major source"of HAP as specifically defined In 40 CFR,Pad 63.761 for sites that
are not pmdcutisn field faciliia7 Np......
Regulation 8 If you repond"yes"to both questions above,further review if the provisions.f 40 CFR,:Part 63.769"Equipment
Leek Standards"apply?
Source Is not subject to MACT HH because the facility is classified as a synthetic minor source of
HAP5.
Did this source commence construction,reconstruction,or modification after September 16 2015! Yes
Is this source at a well site compressor station or onshore natural gas processing plant.as defined in 40 CFR,
Part 00.54305?
NSPS 0000a yes
• This facility meets the definition of Onshore"natural gas processing plant"as defined by 40 CFR Part
60.6430.Therefore,the fugitive emissions at this facility are subject*RSPB 00005.
e ion 07-Technical Analysis Notes
1 Theoperatorc mplete4 a hard c.rat ofcnmponents at this lac lilybetween August 20 and August 22 2019 The results of the hard munt were submitted with the self
certification received by the Division on 09/30/2019 and ss were used to estimate emissions with[his application.As a*suit,the initial hard required th in l t an.
of the permit will he removed.this issuenceofthe permit However,the permit will be updated to include periodic hard taunts to ensure the initial counts remain
2.The emissions associated with the gas serace are estimated usinge site specific inlet gas sample.Asa result,the initial compliance testing included In the foot issuance of
the permit has been oved.Ongoing gas sampling will remain In thepermhbecause the operator hes estimated emissions in the gas Ce based on a 00 content less
than 100%An extended MUM analy*(remesentative of light liquid homy a and watef/4it seams)is still not be ql d because the'peratar is assunlng 000%00C in
light liquid and Water/oil service,which is the most conservative estimate.It should be further noted that testingto determine ectua(NAP concentrations inthe light liquid,
heavy oil and water/oil services is not Included in the permit because the facility is classified as synthetic minor fox lines and the controlled HMIs are not close to the major
source thresholds(i.e.within KM).
3.As discussed above,thssourcesubject to NIPS 0000a.However,Mis NIPS has not yet b n adopted into Colorado Regulation 6:As a result,the condition referencing
NSPS 00000 will be ddressed inthe notes to permit holder section°idle permit It should be further noted that£oilovvine the Ieagd t tion and repair program in NIPS
0000azatisfies the RACY requirements rvquirements for this source.
4.TheVOC and HAP weight%values used to est'mateemissions fromthe gas service were obtained from a site specific inlet gas analysts taken from the iniettOMefrdle',
onuS/21/2019.The mass fractions were corrected to remove carbon dioxide,nitrogen,hydrogen sulfide and oxygen.This was done.order to assume the entire sample is
composed of hydrocarbons.The operator expressed this calculation was done becausethe emissions factors in the EPA Protocol for Equipment Leak Emission Estriates are
for total organic compound emission rates(see note b under table 2-4)Miscalculation cesudta in a conservative estimate of 00C and HAP weight%values Mee the Division
typerailyaccepes the VOC and HAP values reported directly on the sampleanalysls.As a result,these values were deemed acceptable for calculation purposes The
calculations used to determine Cre values used fee permitting are avallaAlefor reference lr Section 04 above,
5.The HAP weight%values used to estimate emissions from the fight liquid and oil/water service were obraitiedfrom the NOL stream predicted by thefecigty wide ProMax
simulation included in the original application for this facility(see ProMme Process Steam tebeted"NGL"in the"PRMTAPPL RL"document dated 05/09/2011 io OnBase
(Document Handle:4056538j).The nags fractions were corrected to remove carbon dioxide,nitrogen,water,hydrogen sulfide,helium,hydrogen and oxygen.This was done
n otderto assume the entire sample is composed of hydrocarbons.The operator expressed this calculation was done because the emissionstaetms in the EPA Protocol for
Iqufpme ALeak 6rttission Estimates are for total organic compound emission rates(see no le A under table 2-4).This calcusstion onresult,in a conservssive estirna.of VOC
and MP weight%values s nde.the DN Ion typically accepts the MX and HAP values reported directly predicted by the simulation,M a result,these Yalu swere deemed
acceptable for calculation purposes.An example of the calculation used.determine the benzene weight%Isas follows:
it should be fiat noted thatthe total hydrocarbon content(all components exdudingcarbon dioxide,nitrogen,water,hydrogen sulfide,helium,hydrogen and oxygen)In
the original sample was determined,be 990932206%using this value,along with the benzene weight%of0.385664388587169%,the corrected tier ermwssgirt%was
determined as follows:became weight
%raloea from
the
664388581166/99.baitg corrected
=0.3856674%.areas This calculation was conducted for the remaining RAP %
0mime.03u For reference,the HAP weight%values from the Ito,prior tab g corrected are follow:(i)Toluene:0.284690983354568%,till Eth00u4ene:...
00376840164870842%(th)Xylene:0.0957497%,(ivl n-Hexane 2.17666513431194%,M 2,2,4,7MP 000129666172906973%,and(vij Methanol:0.0304445169171456%.
6.Thesample usedto estimate the agtrive emissions associated with the gas streams an inlet gas analyss fraote pa lion Since fugitive leaks may also r0ultfrom
oompunena that contain residue gas,the use of the!Merges sample for all gas fugitive emissions is conservative because the VOC content is higher in the iret steam
compared to residue gas.
7.The operator calculated cannoned emissions based.the control values listed on the APEN for sources following monthly monitoring under NSP50000a.The values
listed on the APEN are 96%for valves in gasservce,95%for VaIVesn light liquid service,88%for pump seals1101,t udservice and 1 for connectors nail services.
These default values have been approved by the 4)IVSiOn for sources xubleci to and following Month.monitorIngunder*PS 0000a
e.Thssourse has been Opereungfarmore than one year.Ma result,the monthly limits have been removed from the permit for Ms source.
9.The operator was provided with a draft permit and APEN rediineto review prior to publiccvmmeut The operator reviewed bothddduments and expressed they had no
comments regarding thefugitive source i the permit and agreed with the redlines.
Section OB-Inventory SCC Coding and Emissions Factors
Uncontrolled
AIRS Mint Process SCC Code Pollunod Emissions Factor Central% Source
Varies by Varies by
006 ...,", face - VOC component type component type Standard EFR-EPA.453/R-95-017 Table 24
Varies by Varies by
Benzene componenttype component type Standard EFs-EPA-453/RA5-017 Table 24
Varies by Varies by
Toluene component type component type Standard EFs-EPA-453/R-95-017 Table 24
Varies by Varies by
Ethylbenzene component type component type Standard EFs-EPA-453/RH5-017 Table 2-4
Varies by Varies by
Xylene component type component type Standard EFs-EPA-053/R.sn.a17 Table 24
Varies by Varies by
n-Hexane component type component type Standard EFs-EPA-453/R-95-017 Table 24
Varies by Varies by
224 TMP component type component type Standard EFs-EPA-453/R-95-017 Table 2-4
Pressurized NGL Loadout Emissions Inventory
Section 01-Administrative Information
'Facility AIRS ID: 123 9FC0 012 '
County Plant Point
Section 02-Equipment Description Details
Oete led Em ssipns Un t ' " e " 'm
Pressurized natural gas liquid(NGL)loadout from one(1)60,000 gallon pressurized bullet tank to pressurized tank trucks.
Description:
Emission Control Device Emissions from this source are not controlled.
Description:
Is this loadout controlled? ' -a No
Requested Overall VOC&HAP Control Efficiency%:
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Hydrocarbon Loadout
Actual Loadout Events= "Loadouts per year
(Requested Permit Limit Loadout Events= 2,190 Loadouts per year Requested Monthly Throughput= 156 Barrels(bbl)per month
Potential to Emit(PTE)Loadout Events= 2,190 Loadouts per year
Secondary Emissions-Combustion Device(s)
MMBTU per year
MMBTU per year
MMBTU per year
Control Device Pilot Fuel Use Rate: scfh 0.3 MMscf/yr
Pilot Fuel Gas Heating Value: Btu/scf 0.?MMBTU/yr
Section 04.-Emissions Factors&Methodologies
Does the company use the state default emissions factors to estimate emissions? z '
Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being y irk
permitted? .ka The ,.a_edcydrecarbon liquid samcieisva;.dfor developing site soecv-c n•husadns factors.
•
Loadout Hose Parameters
Liquid Hose Diameter 0.25 feet
Vapor Hose Diameter 0.166666667 feet Notes:
Liquid Hose Length* i.. 1 feet 'Length accounts for length of Isolation valve on pressurized hose.
Vapor Hose Length° 8 feet There are two hoses connected to each truck during loadout.
Liquid Hose Volume cubic feet
Vapor Hose Volume ":,25 cubic feet
Tank and Truck Pressure
Tank and truck pressure 120 psig
Ambient Pressure 14.7 psia
PV=nRT
Where:
P=pressure In hose at time of disconnect=storage tank pressure(psia)
V=volume of hoses(cubic feet)
n=number of lb-moles of product in hoses
R=Universal gas constant=10.73 ft^3•psi/Ibmole/degR
T.average loudest temperature=50°F=510R
Vapor Density Liquid Density
e 0,004232/07 Ibmol SG 0.549011414
Density of
n/V =9 lbmol/ft^3 Water 8.33 lb/gallon
MW 52.0255 Ib/Ibmol lb/gallon
Liquid DensityVapor Density Ib/ft^3
Notes:
1 All liquid lines contain liquid products at individual specific gravity.
2.All vapor return lines contain products that behave as ideal gases at 50°F and storage tank pressure.
VOC Emissions:
VOC Wt% .100%
` lb/year
Vapor Emissions
tpy
lb/year
Liquid Emissions - -
..3e tpy
Total Emissions ...,.8 tpy
Emission Factor _-V3 lb/event
11 of 16 C:\Users\hslaught\Desktop\1239FC0\18WE0503.CP2
Pressurized NC-!Loadout Emissions Inventory
Component Mass Fraction Emission Factor Units Source
Benzene 0.003894644 lb/event ProMax
Toluene 0.00284691 lb/event ProMax
Ethylbenzene 0.00037684:. lb/event ProMax
Xylene 0.000957497. : lb/event ProMax
n-Hexane 0.021766,651 lb/event ProMax
224 TMP 1.29666E-05 lb/event ProMax
Methanol 0.000304449 ..-„ lb/event ProMax
Emission Factors Hydrocarbon Loadout
Uncontrolled Controlled
Pollutant Emission Factor Source
(lb/event) Ph/event)
(Volume Loaded) (Volume Loaded)
VOC _99 Other(See Notes In Section 08)
Benzene _ .1.. Other(See Notes in Section 08)
Toluene 9 999-9-3 Other(See Note.in Section 08)
Ethylbenzene _:. Other(See Notes in Section 08)
Xylene __ - :-13 Other(See Notes in Section 08)
',Hexane .. _.. ......9-. Other(See Notes M Section 08)
224 TMP 21.7E-0 _ Other(See Notes in Section 08)
Methanol 5.79E 999 1.F JS Other(See Notes in Section 08) t
Control Device
Uncontrolled Uncontrolled
Pollutant Emission Factor Source
(Ib/MMBtu) (lb/bbl)
(waste heat combusted) (Volume Loaded)
PM10 _._,
PM2.5 ...,c
50x
_ NOx
CO
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (lb/MMscf) Emission Factor Source
(Pilot Gas
(Waste Heat Combusted( Throughput)
PM10 b hn"# `5�•'t", K
500 a a; ,s 7.-
NOx
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) (tans/year) (tons/year) (tons/year) (Ibs/month)
PM10 2., .9 99 _ G.00 _ =
PM2.5 C.CO 0.00 ._.
5Ox 09_99 0 tt9 0.00 ,. 0
NOx 0.00 030 0.13 _ 0
VOC 230 2 GAO 2.CS 2...z; 9s 3:i.30
_
..CO .__ .,.v.. 0.00 .200 0-e0-
Potentialto Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) (Ibs/year) (Ibs/year) (Ibs/year) (Ibs/year)
Benzene ..1 0.0 16.'1 15-_
Toluene 11.1 .-_ OA 11.9 ._.,.
Ethylbenzene 0.6 1.6
Xylene ..0 __ _ 4.0 ._
n-Hexane 53.7 -_ ._ °?u'
224 TMP 0.1 T.--T. —.
Methanol 1.3 _.. _._
Section 06-Regulatory Summery Analysis
Regulation 3,Parts A,B Scosce-ennecs3 permit
Regulation 7 Part D Section II.C.5. I_,,—.scar—c,1 iiqu ids.o do, .__is not 01.5iect r.. :;.,,on t n ,-�,.0.5
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Requirements
You have inllcSt dabo'aet'e urce is,ndt=ontrolled-The aio;i.g4'ooS5inn does not require an 3n>,ver.
12 of 16 C:\Users\hslaught\Desktop\1239FC0\18WE0503.CP2
'ressurized NGL Leado_ Fissions
Section 08-Technical Analysis Notes
1.Based on the information providedin the application,emissions only occur from a pressurized loadout operation when the hoses used to transfer fluids(both liquid and gas)are disconnected and exposed to the atmosphere.In order to calculate
emissions,the operator has assumed both the liquid hose and vapor return hose are completely filled with emissions at the time of disconnection and the entirety of these emissions are vented to the atmosphere.As such,the entire volume of each
hose was calculated and used in the emission estimate.Further,the calculation assumes all the liquid in the liquid hose is converted to a gas and vented to the atmosphere.It is also assumed that the liquid and vapor are 100%VOC.These two
assumptions likely result in a conservative estimate of emissions,
2.The density of the gas vented from the vapor hose is determined by the ideal gas law.These calculations are shown above in Section 04.The absolute pressure in the ideal gas law assumes an ambient pressure of 14,7 psia.The ambient pressure for
the Denver area is approximately 12.2 psia.However,the use of the standard ambient pressure of 14.7 psia results in a conservative estimate of emissions and istherefore acceptable for permitting purposes,
3.The molecular weight of the gas,density of the liquid and mass fractions of HAPs used to estimate the HAP emissions were obtained from the NGL stream predicted by the facility wide ProMax simulation included in the original application for this
facility(see ProMax Process Stream labeled"NGL"in the"PRMTAPPL RL"document dated 05/09/2018 in OnBase(Document Handle:4056538)).While the data is based on a facility wide simulation that is based on a representative sample,it was
determined an initial compliance test requiring a site-specific sample be obtained was not required for the following reasons,
(i)As discussed in#1 above,the operator assumed both the liquid and vapor hoses are completely filled with liquid/gas at thetime of disconnection and the entirety of these emissions are vented to the atmosphere.According to the operator,this is a
conservative estimate of emissions since any remaining Squid in the liquid hose is routed back toe storage vessel and not allowed to evaporate.
(ii)Also discussed above,the operator assumes the liquid and vapor are 100%VOC.This is the most conservative estimate for VOC content,
(iii)In most cases oil will have a specific gravity lessthan that of water.Asa result,the most conservative estimate of specific gravity for oil is 1(i.e.water has a specific gravity of 1).Using this value results in total overall VOC emissions of 3.59 tpy.This is
the most conservative estimate for the liquid portion of emissions and does not result in a change in facility status or additional requirements for the loadout operation.
Based on the information provided above,it was determined requiring an Initial site specific sample be obtained and used to estimate emissions from this source would not have a significant impact on the permit or emissions and is not warranted at this
time.
4.This is a new source(came into service after 11/20/07)located in the ozone non-attainment area.Asa result,this source is subjectto RACT.Based on information provided,the loadout operation transfers fluid from pressurized storage vessels to
pressurized tank trucks.As the loadout operation is conducted,the vapors displaced from the pressurized tracks Is routed back to the pressurized storage vessels.Ave result,emissions only occur when the liquid and vapor hoses are disconnected after
completion of the loadout operation.Based on this information,the operator Is using vapor balance with pressurized vessels.This method of operations satisfies RACT.
S.Regulation 7,Part D,Section II,C.5.lists requirements.for"Storage tank hydrocarbon liquids loadout requirements at well production facilities,natural gas compressor stations,and natural gas processing plants."The applicability for this section goes
onto further state that"Owners or operators of well production facilities,natural gas compressor stations,and natural gas processing plants with a hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to 5,000 barrels
per year on a rolling 12-month basis must control emissions from the loadout of hydrocarbon liquids from controlled storage tanks to transport Vehicles by using(a)submerged fill and(b)a vapor collection and return system and/or air pollution control
equipment,"It was determined that this pressurized loadout.source is not subject to the requirements of Regulation 7,Part D,Section II.C.5.for the following reasons,(i)Storage tank is defined as follows In Regulation 7,Part D,Section II.A"means any
fixed roof storage vessel or series of storage vessels that are manifolded together via liquid line.Storage tanks maybe located at a well production facility or other location."Storage vessels are defined asfollows:"means a tank or other vessel that
contains an accumulation of hydrocarbon liquids or produced water and is constructed primarily of nonearthen materials(such as wood,concrete,steel,fiberglass,or plastic)which provide structural support.A well completion vessel that receives
recovered liquids from a well after commencement of operation fora period which exceeds 60 days is considered a storage vessel.Storage vessel does not include vessels that are skid-mounted or permanently attached to something that is mobile(such
as trucks,railcars,barges,or ships)and are intended to be located at the site for less than 180 consecutive days;process vessels such as surge control vessels,bottom receivers,or knockout vessels;or pressure vessels designed to operate in excess of
204.9 kilopascals and without emissions to the atmosphere."The pressurized bullet tank is designed to operate in excess of 204.9 kPa(29.72 psia)without emissions to atmosphere.Therefore it does not meet the definition of storage vessel or storage
tank.(ii)Since the pressurized bullet tank is designed to operator without emissions,it is not controlled.Based on this discussion,the pressurized NGL loadout does not occur from a storage tank that is controlled.
6.HAP emissions from this source are below APEN reporting.thresholds(i.e.<2501b/year).As a result,the permit will not contain emission factors for HAPs.
7.Since this isa newly permitted source,the permit will contain monthly limits.
B.The operator was provided with a draft permit and APES redline to review prior to public comment The operator reviewed the documents and expressed they had no comments regarding the pressurized NGL loadout in the permit and that they
agreed with the APEN redlines.
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
Uncontrolled
Emissions
AIRS Paint# Process# SCC Code Pollutant Factor Control% Units
012 01 -rnel 5e; S PM10 ..,i lb/1,000 gallons transferred
PMZ.5 0._,, lb/1,000 gallons transferred
500 0 lb/1,000 gallons transferred
NOx 1.51. lb/1,000 gallons transferred
VOC 0 lb/1,000 gallons transferred
CO 0.CS 0 lb/1,000 gallons transferred
Benzene 1.05E-!;3 r lb/1,000 gallons transferred
Toluene 7.:=�e-0. 0 Ib/1;000 gallons transferred
Ethylbenzene 1.nJt.r.4 U lb/1,000 gallons transferred
Xylene '.CC0-3h 0 lb/1,000 gallons transferred
n-Hexane .,.92[-3 3 Ih/1,000 gallons transferred
224 TMP 3. -g 0 lb/1,000 gallons transferred
Methanol ,.._S"-v3 _ lb/1,000 gallons transferred
13 of 16 C:\Users\hslaught\Desktop\1239FC0\18WE0503.CP2
•
Hydrocarbon Loadout Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions and throughput.
Colorado Re ulatien 3 Parts A and B-APEN and Permit Re eirements
Sour,a hr the Non-Alt'aivmcnt Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants front this individual source greater than 2TPY(Regulation 3,Part A,Section II.D.1.a)?
2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section 11.0.1.1)?
3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fin?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled V0C emissions greater than 5TPY,N0x greater than Sl TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section lI.D.3)?
IYce,hues indicated Chat.source Is in t:d'te IVon-Attoinmiiiii Ares
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1 TPY(Regulation 3,Part A,Section II.D.1.a)? Yes Go to next question.
2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section 11.0.1.1)? No Go to question 6
3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled V0C emissions from the greater than 2 TPY,N0x greater than 5 TPY or CO emissions greater than 10 WY(Regulation?,Part B,Section 11.D.2)? Yes The loadout requires a permit
(Source requires n permit
Colorado Regulation 7 Part D Section II.C.S.
1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility,natural gas compressor station or natural gas processing plant? two ?:IGo to next question.
2. Does the facility have a throughput of hydrocarbon liquids loadout to transport vehicles greater than or equal to 5,000 barrels? ti.' Source is not subject to Regulation 7 Part D Section
1141,1itydp..,0410,1lki,,uls load e vur'cc^is net whit,t frI Rs lciion 1 Vari D
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is
not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law,
regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act„its
implementing regulations,and Air Quality Control Commission regulations,the language of the statute 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 Alr Act and Alr Quality Control Commission regulations,but this document does not establish legally binding requirements in and ofitselr
SeNon 01-Administrative Information
123 9PCO
FaciIiN AIRS ID: CountyPoint Plant
Section 02-Equipment Description Detalls
Detailed Emissions Unit Descripton: Igas venting ham bl0wd0wnz of(ow(4}namralgazddven cc eszors_ ,
Emission Control Device Description: "`ne - r
Requested Overall VOC&HAP Control Efficiency%: o
Limited Process Parameter glaturaiGaz Vented :6,
SeNon 03-Process,.Rate Information for Emissions Estimates
Primary Emissions-Separator
Compressor Blow down Volum. • 0.0025 MMscf
Requested Compressor((lowdown
Events= 7S events/year
Actual Compressor((lowdown Events= • 55 events/year
Actual Throughput •11 MMscfPer year
Requested Permit LlmitThroughput= ..9 MMscf Per War Requested Monthly Throughput= MMscf per month
Potential to Emit(PTO Throughput= I.MMscf per year
Secondary Emissions-Combustion Devlce(s)forAir Pollution Control
Separator Gas Heating Value: Btu/scf
Volume of wastages emitted per BBL of
liquids throughput: - scf/bbl
section 06-Emisslons Factors&Methodologies
Description
Omit/on3;fsaetmtc4',W(t(YmprO$rip tlwriW Were Calculated based on a site spttiflc inlet gas analysis obtained from the faciliNlnlet 05/21/2019.111isanalysist6.used along with the displ entequaHonshown below in orderto estimate emission
facto.
`MW 1.. 2L9746IIb/Ib-mol Displacement Equation
Ex=O'MW•Xx/C
Weight%
Oxygen/Argon tlL309
• 36]9
N2 2 5d19304
methane 53.3955.
ethane 18.]321
propane -
isobutane I.5o50'
n-butane 4:1080
isopentane --0.5536
0.5630
cyxlopentane 0319
trftexane 0.0673
cyclohelane - 0.0085
Otherhexanes 0.20W
heptanes .0.0129
methylcyclohexane 0.00.
226-IMP 0.0000
Benzene
0.00]3
Toluene :,0.0020
Ethylbenzene .0002
Xylenes 0,0006
CBE Heavies 0.0210
Total
VOC Weight 55 _.
Emission Factors Compressor Slowdowns Emission Factors Compressor Slowdowns
Uncontrolled Controlled Uncontrolled Controlled
pb/MMscf) (Ib/MMscf) Emission Factor... Ib/event lb/event
Pollutant Polluant
(Compressor (Compressor
(GasThroughput) (GasThroughput) Slowdown) Slowdown)
VOC .t• 8": _ • Friend dga VOC
Benzene Extended gm nabs` Benzene
Toluene ended gas analysis Toluene 6 0333
Ethylbenzene i - Extended gasanalysis Ethylbenzene
Xylene .. Extended gm analysis xNene _ .a
n.Heaane Enended XXnilysls n-Hexane
224TMP • r £...: Extender.eagshalystr 224 TMP ..• ,.. z
Primary Control0evice
Uncontrolled U ncmrtrolfed
Polluant ob/MM9tu) lh/MMscf Fmisslon Factor Source
(Waste Heat
Combusted) (Gas Throughput(
pm.
PM2,5
503
NOx G u33
CO
SectionsS-Emfsetonslnvenery
Potsntial to Emit Actual Emissions Requested Permit Untits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncomrolied Controlled Controlled
(tors/year) (tom/year) (tons/year) Imm/year( (tons/year) (Ibs/month)
FM10 " •-
PM2.5
Sox
NOx
VOC
Potential.
tial Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) fibs/yead (lbs/yearl IIUs/yearl (Ibs/year) •
Benzene • .- .. ...
Toluene
Ethylbenzene
Xylene ..
n-Hcone - ..
226TMP
•
15of16 C:\Users\hslaught\Desktop\1239FC0\1BWE0503.CP2
COCO,pie,.
Section 06-Renulatow summary analysis
Section II.A.1-Ex®p as provided in paragraphs 2 through 6 below,no owner'separator of a source shall allow or cause the emission into the atmosphere of any air pollutant which
Re latloni An assessor
20pacity.This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes.The approved reference less method for visible
Bumeasurementis EPA Method 5(40 CFR.Part SO.Appendix A(July,1992))in all subsections of Section ILA and B of this regulation.
Section LA-No person,wherever loraled,shall cause swallow the emission of odorous air contaminants from any single slums such as to resin in detectable edorswhich are
Regatb5an2 measured in excess of Me following limes For areas used predominantly for resident®lor commercial purposes it A e violagon if odors are defected alter the odorous air has been
diluted with seven(7)or more volumes of odor free air.
Part AAPEN Requirements
Criteria Pollulanls:Far criteria pollutants,Alr Pollutant Emission Notices are required for eachlndividuai emission point in a nonattainmenl area with uncontrolled actual emissions of
one an per year or more of any individual criteria pollutant(pollutants are not summed)for which the area Is non-atdinmeM.
Applicant Is required to file an APEN since emissions exceed 1 ton per year VOC
Part B—Construction Permit Exemptions
Applicant Is recoiled.obtain a permit since uncontrolled BCC emissions from this facility are greater than the 2.0 TPA'Mreshold(Reg.3,Part%Secgan g022)
Regulatlon3 Part B,1120.2 RACT requirements for new or modified minor sources
This section of Regulation 3 requires RACT far new or modified minor sources located In nonattainment or attainment/maintenance areas.This source Is located In the 8-
hour ozone nonattalnment area.
The date of interest far determining whether the source Is new or modified is therefore November 20,2007(Me date of Me 8-hour ozone NA area designation).Since the
turbine compressor Slowdowns will be in service after the date above,this source is considered"new or modified"
According to PS Memo 20.06,the RACT requirements for compressor Slowdowns include the fallowing:(0 Use best management practices to minimize hytlrecarbon
emissions durieg,or to reduce the frequency of,routine or predict.N.gas venting emissions even.,(ii)Peaeomr routine at predictable gas venting emissions activities
between October a and April 30,when practicable,(ill)Avoid pedarmtng routine or predictable gas venting emissions activities on Ozone Action Days,when practicable.
Ozone Action Day advisories are published by the Colorado Department of Public Heats and Environment,and(tv)where feasible,the owner or operator must avoid
Section 07-Initial and Periodic Sampling and Testing Requirements
Using Gas Throughputto Monitor Compliance
Tes the company use site specific emission factors based on a gas sample to estimate emissions?
his 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 online),then it maybe appropriate e0 use an alder site-specific sample.
if no,the permit will contain an"Initial Testing Requirement"to collect a site-spedficgas 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.
47-1
Are facility-wide permitted emissions of VOC greater than or equal to 40 tans per year to the ozone runattainment area
OR are emissions greater than or equal to 90 tons per year in the ozone attainment area?
Ifyes,the permit will co.ain:
-An"Initial Telling Requirement"to collect a slte.specllic gas sample from the equipment being permitted and conduct en emission factor analysis to demonstrate that the emission,
factors are less than or equal to the emissions factors established with this application.
-A"Periodic Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission
factors are less than or equal to the emissions factors established with this application an an annual basis.
Does the companyrequst a control deviceemdsrey greater than 55%{ore flare or combustion deuce? {j" N/A sources not controlled
If yes,the permit will conmin and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet
and outlet concentration sampling
r
r...
teissiielfeleyspifassif467416,666.066460i646410.6676}146,4664666;j136666,646.66.4.66,66606161.46.636464466066S60,644011.66166KM*666galif&N6M
Fifes' - 5 "
Section 03 Technical Analysis Notes
1.The perator used ass.specific inlet gas sample to develop emission factors and esgmele emissions for this source.This sample was obtained from theimlet oftf:e faclty on May 21;20'16.Aed abovenSection 07,permitted foci*wideVOC emsos are greater
'than 40 taw,.a result the operator will be required to conduct initial and ongoing sampling for this source norder to confirm the emssion factors developed through this analysis are either accurate or conservaMe.
2.The operator Indicated that the calculation of the volume for each compressor blowdown(0.0020 MMscf(blowdownitakes into the physical volume oldie compresses plus a 25%buffer.This volume calculation aim takes into account an operating pressureof993psia.The
operators calculations were deemed conservative end acceptable for permitting purposes.The volume calculations conducted by the operator are available in the email record for the applcabon that has been uploaded to On9ase.
3.In order to calculate actual emissians,ttre operator will track the number of events and multiply the events by the emission factors.The emission factors have been nverted to inks oflb/evenland are available for reference...on o4 above.
6.Since total emissions from thtsiaurce are relatively small,it was determined that installation of a flow meter M nackdie volume of gas vented was not warranted.The operator prodded the fdlow ginformation which further supports this determination:erhe compressors
aft are spaced and do oat feed Into a common header which makes metering of blowdownsverydifficult Additionally.os noted above,Outrigger hos recently added compesslan which largely alleviatesthe need for ormospherrc Wawdowns."
5.The operator iodated that three of the four compressors that are blown down at this facility handle residue gas.The florin compressor handles inlet gas In order to provide a conservative estimate of emissions,the operator utilized an inlet gas sampfetocalculate the
emissions resutngfromthe btowdown of all four compressors.
S.According to PS Memo 20404 Emissions from Slowdowns of facility equipment orppng,where the physical volume between Isolation valves's less than 50 cubic feet and Is not required to bet racked and reported for the purpose of Regulation 7,Part 0,Section v C2 d,are
t to lie grouped with routne or predictable gas venting emissions.Soresoo n or predictable gasentngsources Maass listed n Regulation?,Part D,Section V C2.must be reported grouped,and permitted as appropriate,even if the physical volume of the vend space
IS less than 50dubic feet I)themes equipment.or piping greater then60 cubic feet the operator is required to group those emssoss for evaluation aganstAPEN thresholds and p it the emissions accordingly.The operator provided the f Ilowng response when asked
about other routine or predictable emissions that may need to be permitted at the 12020'I confirmed with ours engineers i that we don't have any addleonal vessels(including pigreceivers)greater than.ACF that are blown down to atmosphere at the facility.'
7.Compressor Slowdowns are not evenly distributed across the year.As a resin,the operator could potentially exceed the monthly limit while remaining incompliance with the erauel limit for the source. o this,t is standard prattle o monthly limits from
mat e tmove m
sources that operate m this manner,especially maintenance Slowdown sources.further,this prov des the operator with operational OexlNlitytomnduct tin ma n[etiaree Slowdowns as needed white fling compliance with the annual traits
e.HAP emissions from this source are below APEN reports%thresholds(i.e.v 2501b/year).As afew's the pemutwillmt contain emission factors for NAPs
9.Colorado Regulation.),Part,,Section it requires storage tanks)produced wafer/vudeoil/condensate)with uncontrolled actual VOC emissions greater than icy to be controlledwlth en enciosed bston device This control requirement saharonsidered to be FACT for
storage tanksnthe mentarea.There are regrsiremertn for rompreswr Slowdowns Colorado's regulations.However,the control requiremen.for storage vessels In Regulation 7,Part D,section a maybe used as asurrogate for determining PACT for this
lee.In this instance, trolled actual VOC emissions the Coinpreasor slowdowns are less than 2lpy.Since storage vessels covered under Regulation 0,Part D.Section)we ...red to be controlled uNessemssions exceed 2 spy,tins source will also not be
regr uncontrolled twl
required to be controlled',MCP purposes due to the level of emirs ons.As discussed above,PS Memo 20.04 ristabes[managementrequlremen6 that satisfy PAR equirements for this source.Them requirements will be listed In the permit.
10.The annual sampling included in the perm only requires the operator to:provide en ongoing compliance demonstration for CDC.This d t m made because Cie HAP ems twithin 2096 of the major:source thresholds Ire 9tpy for
was are tm
individual HAP and Mips,for Total HAP).As a result ongoing sampling recutemenm far HAps at this facltywoold provide minimal benefit at this time.
11.The operator was proyidedwith a draft permit and APEN redline toreviewp o pubtia comment The operant wed the documents and expressed theyhdo.comments regarding compressor blowdownsln Me permit and that they agreed with APEN
r operator a co s s
iedlines.
Section 09-Inventory SCC Cndinz and Emissions Pastors
Uncontrolled Emissions
AIRS Point. Processd SCC Code Pollutant Factor Control% Units
013 02 ds'70zsJI1 ,. 4 PM3o
Sax
NOx
VOD
CO
Benzene
Toluene
Ethylberuene _
Bylen
n-Hexane ,
224 TMP li, _ .101ivlstl
16 of 16 CiUsers\hslaught\OeskoapU23SPCOUSWE0503.CP2
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
•
•
Company Name Outrigger DJ Operating LLC
County AIRS ID 123 History File Edit Date 11/11:202G
Plant AIRS ID 9FC0 Ozone Status Non-Attainment
Facility Name Makena Gas Plant •
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 H25 • 502 NOx VOC Fug CO Total REMARKS •
AIRS ID VOC HAPs VOC HAPs
Previous FACILITY TOTAL 4 0 Aft4�P', 856', _I,4 4.6 4 5 0,3 4 C .10 33 i 1,a "_i?.5 a,rtS 001 nil)oc#udc'd II,0 000100 tote:
2.2J.!�
Previous Permitted Facility total V 1 A i :r 2 4 5 --. - 0 850 6 1 i e t:L a 8 0 r,- _ -..,.. <;,nas 001-002 004 8 005-033;ro.tudezt v:pe01 004
ntat.
•
004 1SWE,0503 One(1)M00A naturres gas 0.5 O-0 2.'1 4..'I 0.2 351.3 5.2 20.8 0.5 0.0 0:1 4.i 0.2 ,€'. !S.2 1.3 Modification-Update eion:slow and throughput
sweetening tluit'N/design capacity limits for ste41 vent and assrst/pilot light gas.
of GO MMSCFD - -
002 350/05503 One(1)open hare(Make:BOCK. 0.3 0.3 0.0 2.5 155.5 13.1 0.0 0.3 0.3 0.3 -... '11.1 0.0 Modiitcation-update throughput and enussion
Model:EEF-U-24)used to control limos.Update ougomg compliance requirements.
residue gas duranll lnisttl¢aai
cart„p10540r downtime.
003 18WE0504.XP One(1)10.0 MMBtu/hr natural gas 0.3 0.3 0.0 4.3 0.2 3.6 0.1 0.3 0.3 0.0 4.3 0.2 3.6 0,1 No Change-APEN required/Permit exempt per Reg
fired hot oil heater 3,Part B,Section II.D.1.e.
004 18WE0503 One(1)10.9 MMBtu/hr natural gas 0.4 0.4 0.0 4.7 0.3 4.0, 0.1 0.4 0.4 0.0 4.7 0.3 4.0 0.1 No Change
fired amine regeneration heater
• (Make/Model/SN:TBD)
005 1BWE0505.XP One(1)5.542 MMBtu/hr natural gas 0.2 0.2 0.0 2.4 0.1 2.0 0.0 0.2 0.2 0.0 2.4 0.1 2.0 0.0 No Change-APEN required/Permit exempt per Reg
fired molecular sieve regeneration - 3,Part B,Section II.D.1.e.
heater
006 18V4E0503 Fugitives 3.9 0.1 Modihcanoo-Update omission t.tsrzlale,s and
component counts based on initial sampling and
007 GP02 SI RICE Waukesha L-7044GSI,4SRB, 0.7 0.7 0.0 228.7 13.2 204.4 1.6 0.7 0.7 0.0 2.4 2.4 3.1 1.6 No Change
1680 HP,SN:5283705576
008 GP02 SI RICE Waukesha L-7044GSI,4SRB, 0.7 0.7 0.0 228.7 13.2 204.4 1.6 0.7 0.7 0.0 2.4 2.4 3.1 1.6 No Change
1680 HP,ON:5283705726
009 18WE0503 Two(2)400 bbl fixed roof crude oil 0,0 0.0 0.1 35.7 0.4 1.4 0.0 0.0 0.1 1.8 0.4 0.1 No Change
storage vessels
010 GP02 SI RICE Waukesha L-7044GSI,4SRB, 0.7 0.7 0.0 228.7 13.2 204.4 1.6 0.7 0.7 0.0 2.4 1.7 9.7 1.6 No Change
1680 HP,SN:5283704171
011 OP02 SI RICE Waukesha L-7044051,4SRB, 0.7 0.7 0.0 ..2287" 13.2 ' 204.4 1.6 0.7 0.7 0.0 2.4 2.4 3.1 1.6 No Change
1680 HP,SN:52837001.36
(312 1130005553 NC4L.Pressurized Lcadeut 2.'1 /1.1
093 /i1WE0;403 Compressor Blowdnwns - 3.2 0.0
XA Pigging 0.0 0.0 0.0 0.0 Insignificant Source
XA Slop Tank loadout 1.0 0.0 1.0 0.0 Insignificant Source
0.0 0.0
0.0 0.0
FACILITY TOTAL 4.4 4.4 2.1 4.4 934.9 600.2 27.8 843.9 35.3 4.4. 4.4 0.1 4.4 29.9 41.1 3.9 45.3 8.1 VOC:Syn b1 inol 1:2./c.NANSR and OP)
Non:Syn Minor IPSO,NANSR and OP)
CO: Syn Moor(POD and OP)
RAPS:,Syn Minor Benzene&Total
HI):Not applicable
770'3_: Area solace
Permitted Facility Total 3.9 3.9 2.1 4.3 928.3 598.8 27.8 838.3 35.1 3.9 3.9 0.1 4.3 23.2 39.7 3.9 39.6 7.9 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions . -0.2 -0.2 -0.1 -0.2 -0.4 23.4 -19.6 -12.6
0000Nrrcl uru required bove:3 0::0 ch,.sncie to
unnnr
-,,.point 00;2
Total VOC Facility Emissions(point and fugitive) 45.0
:e,y:-,l,,ea:u'o:::. :t.r,e.:Vert pew 10
:)':;27120'201
(A)Change in Total Permitted VOC emissions(point and fugitive) 3,8 )4o13003 en:~Sena 114,ti than 23/Ppy 30030 k,P
50 W0;130)
•
Note 1
Note 2
Pagel of 2 Printed 11/19/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
NIEPOLLUTION DIVISION
FACILITY EMISSION 311 MNRs-ILoPs
•
Company Nanny Outtigger DJ Operating LLC
County AIRS ID 123
Plant 428510 SFC0
Facility Name Makena Gas Plant .
Emissions-uncontrolled(lbs per year
POINT'PERMIT 'Description Fono2Nehydl Acetaldehyde Acroleln Benzene Toluene Ethylbenzene 0010500 n-Hexane McOH 229TMP H2O "'°"""TOTAL(tors
Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 .._Q Q „ 0 0 0.0
001 16WE0503 One(1)MDEA nahal gas sweetening 30772.0 13672.0 817.0 2986.0 849.0 01 4200.0 26.8
unit w/design capacity of 60 MMSCFD
•
002 18WE0503 One(1)open flare(Make:BCCK,Model: 00
EEF-U-24)used to control residue gas
during residue compressor downtime.
•
003 18WE0504.XP One(1)10.OMMOtuMr natural gas fired 04 02 01 1546 0.1
hot al heater
004 18WE0503 One(1)10.9 MMBtuilr natural gas fired 70 02 03 150.0 01
amine regeneration heater
(Make/ModeVSN:TBD) _
005 18WE0505.XP One(115.542 MMBtulhr natural gas fired 3.0 0.1 02 657 0.0
molecular sieve regeneration heater
006 180400603 Fugitives 141.0 1010 13.0 340 803.0 110 10 0.6
007 GP02 SI RICE Waukesha L-7044601,45 R0, 1622.3 367.2 346.2 20'19 734 03 257 , 402.7 673 1.6
1680 HP.SN:6283705576
008 GP02 SI RICE Waukesha L-7044051,400 B, 1622.3 367.2 346.2 2079 73,4 33 297 402.7 873 1.6
1680 HP.SN:5283705726
009 18WE0503 Two(2)400 bbl fixed toot crude oil 3710 2520 250 600 2118.0 00 20 1.0 1.4
storage vessels —
010 GPMSI RICE Waukesha L-7044GSI,45RB, t622.3 367.2 346.2 20:9 .114 33 257 402.7 873 1.6
1660 HP,09:5283704171
011 GPO2 Si RICE Waukesha L-7044GSi,408B, 1622.3 367/ 346.2 2079 734 02 25.7 402.7 673 1.6
1680 HP,SN:5283700136
O 12 18WE0503 NGL Pressurized Loadout 150 120 2.0 4,0 010 1.0 01 0.1
-013 1814E0503 Compressor Slowdowns 10 02 00 01 50
XA Pigging 00 00 00 00 01 0.0
XA Slop Tank l0ad0ut 104 7I , 07 I7 594 02 00 0.0
0.0
0.0
TOTAL Itpy) 3.3 0.7 0.7 16.1 7.3 0.4 1.6 2.2 0.8 0,0 2.1 0.2 35.3
'Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Rod Text uncontrolled em ssrons 0 de min'mua
Emissions with controls(Ibsper year)
POINT'PERMIT 'Description Formaldehyde Acetaldehyde Acroleln Benzene Toluene gthylbenaane Xylenes n.Haxane MOH 224 TMP H25 'w'°'"TOTAL Itpyl
Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
O 01 18WE0503 One(1)MDEA natural gas sweetening 1539.0 694.0 41.0 149.0 42.0 00 210.0 1.3
unit w/design capacity of 60 MMSCFD
002 18WE0503 One(1)open flare(Make:BCCK,Model: 0.0
EEF-U-24)used to control residue gas
during residue compressor downtime.
003 18WE0504.XP One(1)10.0MMBtWhr natural gas fired 64 02 03 154.E 0.1
hot of heater _
004 18WE0503 One(1)10.9MMBtu0lr natural gas fired 70 02 01 169.0 0.1
amine regeneration heater
(Make/ModeVSN.TBDI
005 18WE0505.XP One(1)5.542 MMBiWhr natural gas Bred 36 0.1 07 0'17 0.0
molecular sieve regeneration heater
006 18WE0503 Fugitives 15.0 '140 20 50 1100 20 01 01 °
007 0702 SI RICE Waukesha L-7044GS1,4066, 1622.3 367.2 346.2 2079 734 33 25.7 402.7 873 1.6
1680 HP.SN:5283705576
008 GP02 SI RICE Waukesha L-7044GS1,4566, 1622.3 367.2 346.2 2079 73.4 33 257 402.7 87.3 1.6
1680 HP 09:5283705726
009 18WE0503 Two(21400 bbl fixed roof 010300ll 19.0 13.0 20 30 106.0 10 0.1 (1,1 0.1
storage vessels
010 GP02 SI RICE Waukesha L-7044651,4580, 1622.3 3672 346.2 207.0 73 4 33 25 7 402.7 87 3 1.6
1680 HP,05:5203704171 _
011 GP02 SI RICE Waukesha L-7044001,45 R8, 16223 367.2 346.2 _070 054 33 25.7 402.7 6;3 1.6
1680 HP,SN:5283700135
012 18WE0503 NGL Pressurized Loadout 160 120 7.0 4,0 910 1.0 0.i 0.1
013 18WE0503 Compressor Slowdowns 1.0 02 0.0 0.1 60 0.0
XA Pigging 0.0 00 00 0.0 01 0.0 -
XA Stop Tankioedout 10.4 71 00 17 594 02 00 00
9.0
0.0
TOTAL(tpy) 3.3 0.7 0.7 1.2 0.5 0.0 0.1 0.4 0.0 0.0 0.1 0.2 8.1
•
2 1239FC9 11119/21120
Received 08/28/2020. This APEN supersedes the APEN received for this point on 09/27/2019.
CDPHE Amine Sweetening Unit - Form APCD-206
Air Pollutant Emission Notice (APEN) and
CO
• 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 amine sweetening units only. If your emission unit does not fall into this category,
there may be a more specific APEN available for your source (e.g. glycol dehydration unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200)is available if the
specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD)website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 18WE0503 AIRS ID Number: 123 / 9FCO / 001
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 1 - Administrative Information
Company Name': Outrigger DJ Operating LLC
Site Name: Makena Gas Plant
Site Location
Site Location:
NESE Sec 25 T8N R62W County: Weld
NAICS or SIC Code: 237120
Mailing Address:
(Include Zip Code) 1200 17th Street, Suite 900
Denver, CO 80202 Contact Person: Wade Janecek
Phone Number: 720-361-2549
E-Mail Address2: wjanecek@outriggerenergy.com
I Please 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-206 - Amine Sweetening Unit APEN - Revision 3/2019 1 I o =;-:T.,,.:'.,,.;R,
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/ 001
[Leave blank unless APCD has already assigned a permit it 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 ❑ Add point to existing permit
❑✓ Change permit limit ❑ 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 Et Notes: Update emissions to reflect richer inlet gas to amine system
as well as richer assist gas experienced during propane rejection operations.
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: H2S and CO2 Removal
Company equipment Identification No. (optional):
For existing sources, operation began on: 4/18/2019
For new 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
hours/day days/week weeks/year
Operation:
Will this equipment be operated in any NAAQS ® Yes ❑ No
nonattainment area?
Does this facility have a design capacity less than 2 long ® Yes ❑ No
tons/day of H2S in the acid gas?
Redlines per application. (HDS 11/05/2020)
COLORADO
Form APCD-206-Amine Sweetening Unit APEN - Revision 3/2019 2 ( 'v =,
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/ 001
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 4 - Amine Unit Equipment Information
Manufacturer: Dio1�°"PfOCessSystems,"° Model No.: Custom Serial Number: 1552
Absorber Column Stages: 20 stages
Amine Type: 0 MEA 0 DEA 0 TEA ❑✓ MDEA O DGA
Pump Make and Model: PumpWorks HP538-5500 #of pumps: 2
Design Capacity: 60 MMSCF/day
Sour Gas Throughput:
Requested5: 60 MMSCF/year Actual: MMSCF/year
Sour Gas: Pressure: 911 psig Temperature: 400 90 °F
Pressure: 805 psia Temperature: 110 °F
Lean Amine Flowrate: 145.6 gal/min Wt. %amine: 50% (MDEA); 3% (piperazine)
Stream:
Mole loading H2S: 0.0001% Mole Loading 0.054%
CO2:
Pressure: psia Temperature: °F
NGL Input:
Flowrate: Gal/min
Flash Tank: Pressure: 100 psia Temperature: 1 1 1 °F
0 No Flash Tank
Additional Required Information:,
❑✓ Attach a Process Flow Diagram
❑✓ Attach the simulation model inputs Ft emissions report
❑✓ Attach composition reports for the rich amine feed, sour gas feed, NGL feed, ft outlet stream (emissions)
❑✓ Attach the extended gas analysis(including BTEX Et n-Hexane, H2S, CO2, temperature, and pressure)
5 Requested values will become permit limitations. Requested limit(s)should consider future process growth.
Redlines per application. (HDS 11/18/2020)
_. COLORADO
Form APCD-206- Amine Sweetening Unit APEN - Revision 3/2019 3 I � ;;` ,
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/ 001
[Leave blank unless APCD has already assigned a permit#and AIRS ID
Section 5 - Stack Information
Geographical Coordinates
(LatitudelLongitude or UTM)
40.62922, -104.26171
Discharge Height
Operator Temp. Flow e Velocity
Above Ground Level
Stack ID - (°F) (ACFM) (ft/sec)
(feet)
TO 35 TBD TBD TBD
Indicate the direction of the stack outlet: (check one)
✓❑ Upward ❑ Downward 0 Upward with obstructing raincap
❑ Horizontal ❑ Other(describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches): 60
❑ 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.
Used for control of:
0 VRU: Size: Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed: %
Used for control of: Amine Vent
Rating: 7.504 MMBtu/hr
Type: Thermal Oxidizer Make/Model:MRW Technologies
Combustion
Device: Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: 1,400 °F Waste Gas Heat Content: 36.72 Btu/scf
Constant Pilot Light: El Yes 0 No Pilot Burner Rating: 0.07 MMBtu/hr
Supplemental Fuel Flow: 69.0945 MMscf/year
Supplemental Fuel Heat Content: 1,443 Btu/scf
Closed Used for control of: Flash gas
❑✓ Loop Description: Flash gas is used as fuel for reboiler or sent to plant's fuel system
System: 0
System Downtime:
Used for control of:
❑ Other: Description:
Requested Control Efficiency:
Form APCD-206 -Amine Sweetening Unit APEN - Revision 3/2019 4 I �°
Redlines per email. (HDS 11/18/2020)
Permit Number: 18WE0503 AIRS ID Number: 123 /9FC0/ 001
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 7 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined)control efficiency(%reduction):
Overall Requested
Pollutant Description of Control Method(s) Control Efficiency
(%reduction in emissions)
PM
SOX
H2S Still Vent Thermal Oxidizer/Flash Tank:Closed Loop System 95%/100%
NO.
CO
VOC Still Vent:Thermal Oxidizer!Flash Tank Closed Loop System 95%/100%
HAPs Still Vent Thermal Oxidizer!Flash Tank:Closed Loop System 95%/100%
Other:
From what year is the following reported actual annual emissions data?
Criteria Pollutant Emissions Inventory
Emission Factor Actual Annual Emissions Requested Annual Permit
Emission Limit(s)5
Pollutant
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
BascoS Units (AP-42, Emissions Emissions6 Emissions Emissions
Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
PM 7.6 Ib/MMscf AP-42 — -- 0.46 0.46
SOx 0.6/15.71 lb/MMscf FP avProMax -- -- 3.98 3.98
HZS 0.19 Ib/MMscf ProMax — — 2.1 0.11
NO„ 100 Ib/MMscf AP-42 -- -- 6.05 6.05
CO 84 Ib/MMscf AP-42 -- -- 5.08 5.08
VOC 32.08 Ib/MMscf ProMax -- — 351.27 17.56
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor Actual Annual Emissions
Abstract
Chemical Name Service(CAS) Uncontrolled Source Uncontrolled Controlled
Units (AP-42, Emissions Emissions
Number Basis Mfg.,etc.) (pounds/year)(P Sre ) (pounds/year)
Benzene 71432 1.41 lb/MMscf ProMax 30,772 1539
Toluene 108883 0.63 Ib/MMscf ProMax 13,872 694
Ethylbenzene 100414 0.04 Ib/MMscf ProMax 817 41
Xylene 1330207 0.14 Ib/MMscf ProMax 2,986 149
n-Hexane 110543 0.04 Ib/MMscf ProMax 849 42
2,2,4-
540841 5.19E-6 lb/MMscf ProMax 0.11 0.01
Trimethylpentane
Other:
5 Requested values will become permit limitations. Requested limit(s)should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Redlines per application. (HDS 11/18/2020)
COLORADO
Form APCD-2O6 Amine Sweetening Unit APEN - Revision 3/2019 5 I ;n *u:,a,
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/ 001
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
8/26/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Wade Janecek EHS Manager
Name (print) Title
Check the appropriate box to request a copy of the:
Q Draft permit prior to issuance
0 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 or(303) 692-3148
APCD-SS-B1
4300 Cherry Creek Drive South APCD Main Phone Number
Denver, CO 80246-1530 (303) 692-3150
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd
Lrigsgsr COLORADO
Form APCD-206 Amine Sweetening Unit APEN - Revision 3/2019 6 I 177Af :`";.;
Received 08/28/2020
- Gas Venting APEN Form APCD-211
Air Pollutant Emission Notice (APEN) and
COME 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: 18WE0503 AIRS ID Number: 123 / 9FCO /002
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 1 - Administrative Information
Company Name': Outrigger DJ Operating LLC
Site Name: Makena Gas Plant
Site Location: NESE Sec 25 T8N R62W Site Location Weld
County:
NAICS or SIC Code: 237120
Mailing Address: 1200 17th Street, Suite 900
(Include Zip Code)
Denver, CO 80202 Contact Person: Wade Janecek
Phone Number: 720-361-2549
E-Mail Address2: wjanecek@outriggerenergy.com
I Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
'COLORADO
Form APCD-211 - Gas Venting APEN - Revision 07/2020 1 I 'D"°"°"""""'°"`
Mufti.Environment
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/002
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
0 NEW permit OR newly-reported emission source
-OR-
❑✓ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment 0 Change company name3 ❑ Add point to existing permit
❑✓ Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
▪ Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info a Notes: Update emissions to reflect richer gas during
propane rejection operations.
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: Flaring during equipment venting
Company equipment Identification No. (optional):
For existing sources, operation began on: 4/18/2019
For new, modified, or reconstructed sources, the projected start-up date is:
O Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Will this equipment be operated in any NAAQS
HI Yes ❑ No
nonattainment area?
Is this equipment located at a stationary source that is ❑ Yes M1 No
considered a Major Source of(HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7, 0 Yes ® No
Section XVII.G?
Redlines per application (HDS 11/05/2020)
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 07/2020 2 ==
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/002
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 4 - Process Equipment Information
❑ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model: Serial#: Capacity: gal/min
❑ Compressor Rod Packing
Make: Model: #of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
#of Events/year: Volume per event: MMscf/event
❑✓ Other
Description: Site flare -
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:
1443 BTU/SCF
Gas Venting Heating Valuue::
Process Parameters5: Requested: 49.3 MMSCF/year Actual: 39.42 MMSCF/year
-OR-
Liquid Throughput
Requested: bbt/year Actual: bbl/year
Process Parameters5:
Molecular Weight: 19.09
VOC (Weight%) 12.2 Redlines per email.
Benzene (Weight%) 0 (HDS 11/05/2020)
Vented Gas Toluene (Weight%) 0
Properties: Ethylbenzene (Weight%) 0
Xylene (Weight%) 0
n-Hexane(Weight%) 0
2,2,4-Trimethylpentane (Weight%) 0
Additional Required Documentation:
❑✓ Attach a representative gas analysis(including BTEX Et n-Hexane, temperature, and pressure)
❑ Attach a representative pressurized extended liquids analysis(including BTEX Et n-Hexane, temperature, and
pressure)
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 07/2020 3 I AMP. Heatth :lament
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/002
l eave bear k Lriless APCD gas already assigneci a permit and ASPS ID:
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or'UTM)
40.62922,-104.26171
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.
Jprator Discharge let
A �te roun Le�teC Temp � F#o�date Vefioc��y
Stack lD No b� G(roued i6 _ (ACFM), (ft/sec
FS-1761 65 TBD TBD TBD
Indicate the direction of the stack outlet: (check one)
✓❑ Upward ❑ Downward O Upward with obstructing raincap
O Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches): 24
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑Other(describe):
Section 6 - Control Device Information
O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Size: Make/Model:
O VRU:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Pollutants Controlled: VOC, HAPs
Rating: 18.47 MMBtu/hr
Type: Open Flare Make/Model: BCCK/EEF-U-24
❑ Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: TBD Waste Gas Heat Content: 1447 Btu/scf
Constant Pilot Light: ❑✓ Yes O No Pilot burner Rating: 0 22 MMBtu/hr
Pollutants Controlled:
O Other: Description:
Requested Control Efficiency:
!COLORADO...
Form APCD-211 - Gas tenting,. Eti - Revision 07/2020 4 1 rat7; = •'t,
Redlines per email. HD 11/05/2020)
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/002
[Leave blank unless APCD has already assigned a permit A and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
If yes, describe the control equipment AND state the requested control efficiencies(report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Overall Requested
Pollutant Control Equipment Description Control Efficiency
(%reduction in emissions)
PM
SO.
NO.
CO
VOC Open Flare 95%
HAPs Open Flare 95%
Other:
From what year is the following reported actual annual emissions data?
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 (�"42' Emissions Emissionsb Emissions Emissions
Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
PM
SOX
NOx 0.068 Ib/MMBtu AP42 1.93 1.93 2.42 2.42
CO 0.31 lb/MMBtu AP42 8.82 8.82 11.02 11.02
VOC 6.38.98 Ib/MMscf Engineering Estimate 124.35 6.22 155.52 7.78
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.
Redlines per application. (HDS 11/05/2020)
Section 8 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria
pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? 0 Yes 0 No
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 Uncontrolled
Service(CAS) Units (AP-42, Emissions Emissions6
Basis Mfg.,etc.)fs (lbs/year) (ibslyear)
Benzene 71432
Toluene 108883
Ethylbenzene 100414
Xylene 1330207
n-Hexane 110543
2,2,4-Trimethylpentane 540841
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
COLORADO
Form APCD-211 Gas Venting APEN - Revision 07/2020 5 I SW �,y ,
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/002
[Leave blank unless APCD has already assigned a permit#and A'RS ID;
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
8/26/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Wade Janecek EHS 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 $216.00 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 07/2020 6 I > x E�ti ,
Este
CDPHE Fugitive Component Leak Emissions APEN
Form APCD-203
COv Air Pollutant Emission Notice (APEN)and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require
payment for a new filing fee.
This APEN is to be used for fugitive component leak emissions only. If your emission source does not fall into this
category, there may be a more specific APEN for your source(e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200)is available if the
specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD)website at:www.colorado.gov/cdphe/apcd.
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/006
[Leave blank unless APCD has already assigned a permit»and AIRS ID]
Section 1 -Administrative Information
Company Name': Outrigger DJ Operating LLC
Site Name: Makena Gas Plant
Site Location: NESE Sec 25 T8N R62W Site Location Weld
County:
NAICS or SIC Code: 237120
Mailing Address: 1200 17th Street, Suite 900
(Include Zip Code)
Denver, CO 80202 Contact Person: Wade Janecek
Phone Number: 720-361-2549
E-Mail Address: wjanecek@outriggerenergy.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.
z Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.4-
r , .
& COLORADO
Form APCD-203 Fugitive Component Leak Emissions APEN Revision 3/2019 1 I `s-7:,'."'o
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/006
(Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
O NEW permit OR newly-reported emission source(check one below)
-OR-
❑✓ MODIFICATION to existing permit(check each box below that applies)
O Change process or equipment ❑ Change company name3 O Add point to existing permit
0 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-
E] APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info ft Notes: Updating fugitive counts
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
Company equipment Identification No. (optional):
For existing sources, operation began on: 4/18/2019
For new 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 hours/day days/week weeks/year
Operation:
Facility Type:
❑Well Production Facility5
❑Natural Gas Compressor Stations
0 Natural Gas Processing Plants
❑Other(describe):
5 When selecting the facility type, refer to definitions in Colorado Regulation No.7,Section XVII.
Av COLORADO
Form APCD-2O3 - Fugitive Component Leak Emissions APEN -Revision 3/2019 2 I OA
Permit Number: 18WE0503 AIRS ID Number: 123 /9Fco/006
[Leave blank unless APCU has already assigned a permit#and AIRS'DI
Section 4- Regulatory Information
What is the date that the equipment commenced construction? 11/15/2018
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes O No
Will this equipment be located at a stationary source that is considered a ❑Yes ❑✓ No
Major Source of Hazardous Air Pollutant(HAP)emissions?
Are there wet seal centrifugal compressors or reciprocating compressors 0 Yes ❑No
located at this facility?
Is this equipment subject to 40 CFR Part 60, Subpart KKK? ❑Yes 0 No
Is this equipment subject to 40 CFR Part 60, Subpart OOOO? O Yes 0 No
Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? 0 Yes O No
Is this equipment subject to 40 CFR Part 63, Subpart HH? O Yes ❑✓ No
Is this equipment subject to Colorado Regulation No. 7, Section XII.G? ❑✓ Yes O No
Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? ❑Yes ❑✓ No
Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? ❑Yes 0 No
Section 5 - Stream Constituents
0 The required representative gas and liquid extended analysis(including BTEX)to support the data below has
been attached to this APEN form.
Use the following table to report the VOC and HAP weight%content of each applicable stream.
VOC Benzene Toluene Ethylbenzene Xylene n-Hexane 2,2,4
Stream Trimethylpentane%) (wt%) (wt%) (wt%) (wt%) (wt%) (wt%)
(wt%)
Gas 23.09% 0.01% 0.0021% 0.0002% 0.0006% 0.0505% 0.00%
Heavy Oil
(or Heavy Liquid) 100% 0.3857% 0.285% 0.0377% 0.0958% 2.1767% 0.001%
Light oq 100% 0.3857% 0.285% 0.0377% 0.0958% 2.1767%
(or Light Liquid) 0,001
Water/Oil 100% 0.3857% 0.285% 0.0377% 0.0958% 2.1767% 0.001%
Section 6 - Geographical Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.62922, -104.26171
Attach a topographic site map showing location
COLORADO
Form APCD-203 - Fugitive Component Leak Emissions APEN -Revision 3/2019 3 [
Redlines per application. (HDS 11/09/2020)
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/006
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 7- Leak Detection and Repair (LDAR) and Control Information
Check the appropriate boxes to identify the LDAR program conducted at this site:
O LDAR per 40 CFR Part 60, Subpart KKK
❑Monthly Monitoring-Control: 88%gas valve, 76%light liquid valve, 68%light liquid pump
❑Quarterly Monitoring-Control: 70%gas valve, 61%light liquid valve, 45%light liquid pump
❑✓ LDAR per 40 CFR Part 60, Subpart OOOO/OOOOa
Monthly Monitoring-Control: 96%gas valve, 95%light liquid valve, 88%light liquid pump, 81%
connectors
❑LDAR per Colorado Regulation No. 7, Section XVII.F
❑Other6:
❑No LDAR Program
6 Attach other supplemental plan to APEN form if needed.
vii1O,1.4O;
Form APCD-203 -Fugitive Component Leak Emissions APEN - Revision 3/2019 4 I ;°,140
Permit Number: 1 8WE0503 AIRS ID Number: 123 /9FCO/006
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 8 - Emission Factor Information
Select which emission factors were used to estimate emissions below. If none apply, use the table below to
identify the emission factors used to estimate emissions. Include the units related to the emission factor.
X❑Table 2.4 was used to estimate emissions7.
Q-Table 2-8(< 10,000ppmv)was used to estimate emissions7.
Use the following table to report the component count used to calculate emissions.The component counts listed
in the following table are representative of:
❑Estimated Component Count
❑✓ Actual Component Count conducted on the following date: 8/20/2019
Equipment Type
Service Open-Ended
Connectors Flanges Lines Pump Seals Valves Other9
Gas
Count8 2241 586 5 29 660 2
Emission Factor 4.41E-4 8.60E-4 4.41E-3 5.29E-3 9.92E-3 _
1.94E 2
Units lbs/component/hr lbs/component/hr lbs/component/hr lbs/component/hr lbs/component/hr lbs/component/hr
Heavy Oil(or Heavy Liquid)
Count8 0 0 0 0 0 0
Emission Factor 1.65E-5 8.60E-7 3.09E-4 0.00E-0 1.85E-5 7.05E-5
Units lbs/component/hr lbs/component/hr lbs/component/hr lbs/component/hr lbs/component/hr lbs/component/hr
Light Oil(or Light Liquid)
Count8 1019 370 3 14 380 3
Emission Factor 4.63E-4 2.43E-4 3.09E-3 2.87E-2 5.51E-3 1.65E-2
Units lbs/component/hr lbs/component/hr lbs/component/hr lbs/component/hr lbs/component/hr lbs/component/hr
Water/Oil
Count8 81 42 1 1 37 1
Emission Factor 2.43E-4 6.39E-6 5.51E-4 5.29E-5 2.16E-4 3.09E-2
Units lbs/component/hr lbs/component/hr lbs/component/hr lbs/component/hr lbs/component/hr lbs/component/hr
7 Table 2-4 and Table 2.8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates(Document EPA-453/R-
95-017).
8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the"Actual
Calendar Year Emissions"below.
9 The"Other"equipment type should be applied for any equipment other than connectors,flanges,open-ended lines,pump
seals,or valves.
Redlines per AP-42 and application. (I-IDS 11/09/2020)
COLORADO
Form APCD-203 Fugitive Component Leak Emissions APEN - Revision 3/2019 5 1 AV COL,
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/006
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 9 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions and non-criteria pollutant(HAP)emissions from source:
(Use the data reported in Section 8 to calculate these emissions.)
CAS Actual Annual Emissions Requested Annual Permit Emission
Limit(s)11
O11
Chemical Name Number
Uncontrolled Controlled10 Uncontrolled Controlled
(tons/year) (tons/year) (tons/year) (tons/year)
VOC 761346 27.82 3.89
Does the emissions source have any actual emissions of non-criteria pollutants ®Yes ®No
(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:
Actual Annual Emissions Requested Annual Permit Emission
CAS Limit(s)11
Chemical Name
Number Uncontrolled Controlled70 Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 71432
Toluene 108883
Ethylbenzene 100414
Xylene 1330207
n-Hexane 110543 802.5 110
I
2,2,4 540841
Trimethylpentane
Other:
10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
11 Requested values will become permit limitations. Requested limit(s)should consider future process growth,component count
variability, and gas composition variability.
Redlines per application. (HDS 11/09/2020)
COLORADO
Form APCD-203 Fugitive Component Leak Emissions APEN - Revision 3/2019 6 I 19314
'" "
Permit Number: 18WE0503 AIRS ID Number: 1 23 /9FCO/006
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 10-Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
9/26/2019
Signature of Legally(Authorized Person(not a vendor or consultant) Date
Wade Janec& EHS Manager
Name(print) Title
Check the appropriate box to request a copy of the:
0 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 or(303)692-3148
APCD-SS-B1
4300 Cherry Creek Drive South APCD Main Phone Number
Denver, CO 80246-1530 (303)692-3150
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd
COLORADO
Form APCD-203 - Fugitive Component Leak Emissions APEN -Revision 3/2019 7 I AV
?
CDPHE Hydrocarbon Liquid Loading APEN
CO APCD-208
r Air Pollutant Emission Notice(APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs wilt 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 hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source(e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN
options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD)website at: www.colorado.gov/cdphe/aped.
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: 18WE0503 AIRS ID Number: J 2_,F, /9 FC.(t/
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 1 -Administrative Information
Company Name': Outrigger DJ Operating LLC
Site Name: Makena Gas Plant
Site Location
Site Location:
NESE Sec 25 T8N R62W County: Weld
NAICS or SIC Code: 237120
Mailing Address:
(Include Zip Code) 1200 17th Street, Suite 900
Denver, CO 80202 Contact Person: Wade Janecek
Phone Number: 720-361-2549
E-Mail Address2: w]anecek@outriggerenergy.com
I 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.
4
TRIT. COLORADO
Form APCD-208 Hydrocarbon Liquid Loading APEN -Revision 3/2019 1 I
Permit Number: 18WE0503 AIRS ID Number: 123 /9FC0 / 012
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
❑ NEW permit OR newly-reported emission source
❑ Request coverage under construction permit O Request coverage under General Permit GP07
If General Permit coverage is requested, the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
Q MODIFICATION to existing permit(check each box below that applies)
O Change fuel or equipment O Change company name3
0 Change permit limit O 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&Notes: Update to emissions unit
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: NGL Loadout
Company equipment Identification No. (optional):
For existing sources, operation began on: 4/18/2019
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No
Is this equipment located at a stationary source that is considered a Major Source of(HAP) O Yes 0 No
emissions?
Does this source load gasoline into transport vehicles? O Yes 0 No
Is this source located at an oil and gas exploration and production site? ❑ Yes 0 No
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual ❑ Yes O No
average?
Does this source splash fill less than 6750 bbl of condensate per year? O Yes O No
Does this source submerge fill less than 16308 bbl of condensate per year? O Yes ❑ No
pp COLORADO
Permit Number: 18WE0503 AIRS ID Number: 123 /9FC0 / 012
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 4- Process Equipment Information
Product Loaded: ❑ Condensate ❑ Crude Oil ❑✓ Other: NGL
L
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year
This product is loaded from tanks at this facility into:
(e.g. "rail tank cars"or"tank trucks")
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor: Average temperature of F
bulk liquid loading:
Molecular weight of
True Vapor Pressure: Psia @ 60 F Ib/lb-mol
• displaced vapors:
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following: 2190 events/year
Requested Volume Loaded5: 365,000 bbl/year Actual Volume Loaded: bbl/year
Product Density: 34.21 (liquid lb/ft;
1.28 (vapor)
Load Line Volume: 0.049 ft3/truckload Vapor Recovery Line Volume: 0.175 ft3/truckload
5 Requested values will become permit limitations. Requested limit(s)should consider future process growth.
Redlines per application. (HDS 11/10/2020)
COLORADO
Form APCD-208- Hydrocarbon Liquid Loading APEN- Revision 3/2019 3 I ��
Permit Number: 18WE0503 AIRS ID Number: 123 /9FC0 / 012
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.62922, -104.26171
Operator Discharge Height Above Temp. Flow Rate Velocity
Stack ID No. Ground Level CF) (ACFM) (ft/see)
(feet)
Indicate the direction of the stack outlet: (check one)
❑Upward O Downward 0 Upward with obstructing raincap
❑ Horizontal 0 Other(describe):
Indicate the stack opening and size: (check one)
❑Circular Interior stack diameter(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.
❑ Loading occurs using a vapor balance system: Requested Control Efficiency:
Used for control of:
Rating: MMBtu/hr
Type: Make/Model:
❑ Combustion
Device: Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency: %
Minimum Temperature: 'F Waste Gas Heat Content: Btu/scf
Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: MMBtu/hr
Pollutants Controlled:
0 Other: Description:
Requested Control Efficiency:
0
riy. COLORADO
Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 3/2019 4 I f ,"",
Permit Number: 18WE0503 AIRS ID Number: 123 /9FC0 /012
[Leave blank unless APCD has already assigned a permit n and AIRS ID]
Section 7- Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined)control efficiency(%reduction):
Overall Requested
Pollutant Description of Control Method(s) Control Efficiency
(%reduction in emissions)
PM
SO,'
NO.
CO
VOC
HAPs
Other:
❑ Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane
❑Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
❑Crude 0.104 Lbs/BBL, 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data?
Criteria Pollutant Emissions Inventory
Emission Factor Actual Annual Emissions Requested Annual Permit
Emission limit(s)5
Pollutant
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Basis Units (AP-42, Emissions Emissions Emissions Emissions
Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
PM
SOx
NO.
CO
VOC 1.903 lb/event I Engineering Estimate 2.08 2.08
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical ( Emission Factor Actual Annual Emissions
Abstract
Chemical Name Source Uncontrolled Controlled
Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions6
Basis asis Mf
g.,etc.) (pounds/year) (pounds/year)
Benzene 71432 7.34E-3 lb/event Engineering Estimate 16.1 16.1
Toluene 108883 5.42E-3 lb/event EngineeringEstmate 11.9 11.9
Ethylbenzene 100414 7.17E-4 lb/event Engineering Estimate 1.6 1.6
Xylene 1330207 1.82E-3 lb/event Engineering Estimate 4.0 4.0
n-Hexane 110543 4.14E-2 lb/event Engineer ngEetmate 90.7 90.7
2,2,4-
540841 2.47E-5 lb/event 0.1 0.1
Trimethylpentane F.nglneering Fsgmete
Other:
5 Requested values will become permit limitations. Requested limit(s)should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
p COLORADO
Form APCD-208- Hydrocarbon Liquid Loading APEN Revision 3/2019 5 I �� COLORADO
Redlines per email and application. (HDS 11/10/2020)
Permit Number: 18WE0503 AIRS ID Number: 123 I 9FCO/ 012
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 8 -Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source
is and wilt be operated in full compliance with each condition of General Permit GP07.C \\. L /
Signature of Legally Qul:horized Person (not a vendor or consultant) Date
t't---//4..c,[ .e. __..)-,.- et-e kr (-:HS' Mk ek ki f--
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.
I
Send this form along with $191.13 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148
Air Pollution Control Division
APCD-SS-B1 APCD Main Phone Number
4300 Cherry Creek Drive South (303)692-3150
Denver, CO 80246-1530
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/aped
MII7COLORADO
Form APCD-208- Hydrocarbon Liquid Loading APEN -Revision 3/2019 6 I "-7,17:,' `'"
Received 08/28/2020
0 464111.
Gas
tlVeutantnting APEN - Form Emission Notice (APEN) a APCD-211
CDPHEAir P nd
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 8WE05503 AIRS ID Number: 1 23 / 9FCO /013
[Leave blank unless APCD has already assigned a permit r and AIRS ID]
Section 1 - Administrative Information
Company Name': Outrigger DJ Operating LLC
Site Name: Makena Gas Plant
Site Location: NESE Sec 25 T8N R62W Site Location Weld
County:
NAICS or SIC Code: 237120
Mailing Address: 1200 17th Street, Suite 900
(Include Zip Code)
Denver, CO 80202 Contact Person: Wade Janecek
Phone Number: 720-361-2549
E-Mail Address2: wjanecek@outriggerenergy.com
1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
[COLORADO
Form APCD-211 Gas Venting APEN - Revision 07/2020 1 I ,1=1":""""`H Hh6Enviranmant
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/013
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly-reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
O Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
El Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit (PTE)
Additional Info It Notes: APEN submittal for blowdown operations
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: Equipment Blowdowns
Company equipment Identification No. (optional):
For existing sources, operation began on: 4/18/2019
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
nonattainment area? ® Yes ❑ No
Is this equipment located at a stationary source that is ❑ Yes ® No
considered a Major Source of(HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7, ❑ Yes El No
Section XVII.G?
Redlines per application. (HDS 11/11/2020j
COLORADO
Form APCD-211 Gas Venting APEN - Revision 07/2020 2 I x =a'm'„„
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/ 013
[Leave blank unless APCD has already assigned a permit ri and AIRS ID
Section 4 - Process Equipment Information
❑ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model: Serial#: Capacity: gal/min
❑ Compressor Rod Packing
Make: Model: #of Pistons: Leak Rate: Scf/hr/pist
❑✓ Blowdown Events
#of Events/year: 60 (Actual) Volume per event: 0.0025 MMscf/event
❑ Other 75 (Requested)
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:
Gas 1254.6 BTU/SCF
Gas Venting Heating Value:
Process Parameters5: Requested: 0.19 MMSCF/year Actual: 0.1 5 MMSCF/year
-OR-
Liquid Throughput
Process Parameters5 Requested: bbl/year Actual: bbl/year
Molecular Weight: 21.9746
VOC (Weight%) 21.6338
Benzene (Weight%) 0.0073
Vented Gas Toluene(Weight%) 0.002
Properties: Ethylbenzene(Weight%) 0.0002
Xylene (Weight%) 0.0006
n-Hexane (Weight%) 0.0473
2,2,4-Trimethylpentane (Weight%) 0
Additional Required Documentation:
❑✓ Attach a representative gas analysis (including BTEX Et n-Hexane, temperature, and pressure)
❑ Attach a representative pressurized extended liquids analysis (including BTEX Et n-Hexane, temperature, and
pressure)
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
5 [COLORADO
Form APCD-211 - Gas Venting APEN - Revision 07/2020 3 Redlines per updated application. (HDS 11/11/2020)
Permit Number: 1 8WEO55O3 AIRS ID Number: 1 23 /9FCO/ 013
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.62922,-104.26171
0 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, co (ACFM) (ftlsec):
BLDWN 20 TBD TBD TBD
Indicate the direction of the stack outlet: (check one)
❑✓ Upward 0 Downward 0 Upward with obstructing raincap
0 Horizontal 0 Other(describe):
Indicate the stack opening and size: (check one)
O Circular Interior stack diameter (inches): 12
o 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:
Rating: MMBtu/hr
Type: Make/Model:
❑ Combustion Requested Control Efficiency:
Device:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature: Waste Gas Heat Content: Btu/scf
Constant Pilot Light: 0 Yes 0 No Pilot burner Rating: MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Requested Control Efficiency: %
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 07/2020 4 I ne
Permit Number: 18WE0503 AIRS ID Number: 123 /9FCO/ 013
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑Yes ❑r No
If yes, describe the control equipment AND state the requested control efficiencies(report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Overall Requested
Pollutant Control Equipment Description Control Efficiency
(%reduction in emissions)
PM
SOX
NO.
CO
VOC
HAPs
Other:
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source:
Emission Factor Actual Annual Emissions Requested Annual Permit
Pollutant Emission Limit(s)5
Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (x'42. Emissions Emissions6 Emissions Emissions
Basis Mfg.,etc.) (tons/year)
(tons/year) (tons/year) (tons/year)
PM
SOx
NOx
CO
VOC 31 36 lb/event Engineering Estimate 0.94 0.94 1.18 1 18
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 ID 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 Uncontrolled
Service(CAS) Units (AP-42, Emissions Emissions6
Number Basis Mfg.,etc.)
(tbs/year) Os/year)
Benzene 71432
Toluene 108883
Ethylbenzene 100414
Xylene 1330207
n-Hexane 110543
2,2,4-Trimethylpentane 540841
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
�/�!► C..="".=
OLORADO
Form APCD-211 Gas Venting APEN - Revision 07/2020 5 11�i! " ,
Redlines per email. (HDS 11/11/2020)
Permit Number: 18WE0503 AIRS ID Number: 123 i 9FC0/ 013
[Leave blank unless APCD has already assigned a permit#and AIRS ID;
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
8/26/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Wade Janecek EHS Manager
Name (print) Title
Check the appropriate box to request a copy of the:
❑✓ Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $216.00 to: For more information or assistance call:
Colorado Department of Public Health and Environment 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
Jae COLORADO
Form APCD-211 Gas Venting APEN - Revision 07/2020 6 I Health ��Pukkr
Hello