HomeMy WebLinkAbout20193766.tiffa
COLORADO
Department of Public
Health & Environment
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
August 14, 2019
Dear Sir or Madam:
RECEIVED
AUG 1 9 2019
WELD COUNTY
COMMISSIONERS
On August 22, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for SRC
Energy, Inc. - Greeley -Rothe Federal 16-1 Pad. 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: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director
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2019-3766
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: SRC Energy, Inc. - Greeley -Rothe Federal 16-1 Pad - Weld County
Notice Period Begins: August 22, 2019
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: SRC Energy, Inc.
Facility: Greeley -Rothe Federal 16-1 Pad
Exploration a Production Well Pad
SESE Sec. 1 T5N R67W
Weld County
The proposed project or activity is as follows: This application request is for an exploration and production
well pad facility which began production 1/15/2019. The six condensate storage tanks are being requested
to have individual permit coverage. Also included in the application package was a GP08 application
(produced water storage tanks), GP07 application (hydrocarbon loadout), and 3- GP02 applications (natural
gas fired reciprocating internal combustion engines). This facility is a synthetic minor facility for VOC's
(NANSR a Operating Permit) and CO (Operating permit).
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):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• 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 19WE0404 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.Qov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Lauraleigh Lakocy
(COLORADO
Department of Public
Health it Environment
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
Health b Environment
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0404
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 1
SRC Energy, Inc.
Greeley -Rothe Federal 16-1 Pad
123/A040
SESE SEC 1 T5N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK 1'-6
00 l
Six (6) 400 barrel fixed roof storage vessels
used to store condensate
Enclosed Combustion
Device
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to 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. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
Page 1 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
compliance as required by this permit may be obtained online at www.colorado.Rov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as 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 shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall 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
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
TK 1-6
001
---
---
15.7
2.9
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Compliance with the annual limits, for criteria air pollutants, 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.
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
Page 2 of 10
a
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
8. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
TK 1-6
001
Enclosed Combustion Device
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4)
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
TK 1-6
001
Condensate
throughput
2,188,
504 barrels
The owner or operator shall monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits shalt 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 mmonhtand
keep a compliance record on site or at a local field office with, site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. 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)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all
applicable requirements of Section XII and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for condensate storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
Page 3 of 10
a
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Section XII.C.) (State only enforceable)
13. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.17; 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 following schedule:
• All combustion devices installed on or after. May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first
14. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall 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 is design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized, by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.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.
15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVIIC.2.
OPERATING a MAINTENANCE REQUIREMENTS
16. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&tM plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen -minute period during normal
operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.17)
Page 4 of 10
a
M
Y=rM
u
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health ft Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO), per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted, or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
21. 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.
Page 5 of 10
COLORADO
Air Pollution Control Division
Department of Public Health ft Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
22. 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.
23. 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.
24. 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.
25. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any' time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission'(AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
26. 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.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Lauraleigh Lakocy
Permit Engineer
Page 6 of 10
a
COLORADO
Air Pollution Control Division
Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to SRC Energy, Inc.
Page 7 of 10
a
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder 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.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
001
Benzene
71432
1582
79
Toluene
108883
1598
80
Ethylbenzene
100414
103
5
Xylenes
1330207
648
32
n -Hexane
110543
12,584
629
2,2,4-
Trimethylpentane
540841
51
3
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 8 of 10
a
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
5.76E-04
5.76E-04
AP -42,
Chapter 13.5
CO
2.61 E-03
2.61 E-03
VOC
0.286
1.43E-02
ProMax
simulation based
on a site -specific
pressurized
liquid sample
taken 3/6/2019
71432
Benzene
7.23E-04
3.62E-05
108883
Toluene
7.30E-04
3.65E-05
100414
Ethylbenzene
4.72E-05
2.36E-06
1330207
Xylene
2.96E-04
1.48E-05
110543
n -Hexane
5/5E-03
2.88E-04
540841
2'2'4-2.31E-05
Trimethylpentane
1.16E-06
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
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) 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.
8) This source is subject to 40 CFR, Part 60, Subpart 0000a - 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 2,
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 at the Office of the Federal Register
website at: https://www.federalregister.gov/documents/2016/06/03/2016-11971 /oil -and -
natural -gas -sector -emission -standards -for -new -reconstructed -and -modified -sources
9) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, CO
NANSR
Synthetic Minor Source of: VOC
PSD
True Minor
MACT HH
Area Source Requirements: Not Applicable
Page 9 of 10
-di
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
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
MAC
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 10 of 10
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Lauraleigh I_alkocy
Package #: 396083
Received Date: 4/15/2019
Review Start Date: 6/7/2019
Section 01 - Facility Information
Company Name: SRC Energy, Inc.
County AIRS ID: 123
Quadrant
Section
Township
Range
SESE
5N
67W
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility:
A040
Greeley-Rother Federal 16-1 Pad
SESE quadrant of Section 1, Township 5N, Range 67WW
Weld County
Exploration & Production Well Pad
What industry segment? Oil a Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? n Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
Yes
Particulate Matter (PM)
Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
Condensate Tank
TK 1-6
Yes
19WE0404
Yes
Permit Initial
Issuance
Section 03 - Description of Project
This application request is for an exploration and production well pad facility which began production 1/15/2019. The six condensate storage tanks are being requested to
have individual permit coverage. Also included in the application package was a GP08 application (produced water storage tanks), GP07 application (hydrocarbon loadout),
and 3- GP02 applicatiors (natural gas fired reciprocating internal combustion engines). This facility is a synthetic minor facil ity for VOC's (NANSR & Operating Permit) and CO
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement:
Yes
Was a quantitative mode ing analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
No
Yes
SO2 NOx
Is this stationary source a major source?
If yes, explain what programs and which pollutants herE SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
fr _
NOx
CO VOC PM2.5 PM10 TSP HAPs
J J1 Li _
CO VOC PM2.5 PM10 TSP HAPs
A
•
Condensate Storage Tank(s) Emissions Inventory
001 Condensate Tank
Facility AIRs ID:
123
County
Plant
001
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Six -400 barrel fixed roof storage tanks for the storage of condensate
Emission Control Device 4- enclosed combustion devices. 96" IES
Description:
Requested Overall VOC & HAP Control
Efficiency %:
95
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput =
1,823,741 Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
1,823,741 Barrels (bbl) per year
Requested Permit Limit Throughput =
2,188,504 Barrels (bbl) per year Requested Monthly Throughput =
185873 Barrels (bbl) per month
Potential to Emit (PTE) Condensate Throughput
2,626,205 Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas= 2333 Btu/scf
Volume of waste gas emitted per BBL of liquids
produced =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
2.755065009 scf/bbl
•
11,722 MMBTU per year
14,067 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 16,880 MMBTU per year
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors
Condensate Tank
Uncontrolled Controlled
Emission Factor Source
Pollutant
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
0.286
1.43E-02
- Specific LE. (Ittctu:des;flasy:;
:R Specific E.F. (includes flash)
=: Specific E.F. (includes flash)
,• Specific ES. (includes fi?shh`,
Benzene
7.23E-04
3.62E-05
Toluene
7.30E-04
3.65E-05
Ethylbenzene
4.72E-05
2.36E-06
Xylene
2.96E-04
1.48E-05
::, Specific E,F. (includes V_::_
•a Specs is FS. (includes ilaci%
:ec::"
n -Hexane
75E-03
2.88E-04
224 TMP
2.31E-05
1.16E-06
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
;Ib/MMBtu) (lb/bbl)
;waste heat
:ombusted)
(Condensate
Throughput)
PM10
0.0075
0.0000
/ •N :7M 10/PM.2.5)
' 42'l'a..:_ a.4-2(PM10/PINA.2.S)
. 42 Chapter 133 Industrial Pares (NO:>:;
:"1 "raptor 1:3,5 Induslrwal Flares (CO)
PM2.5
0.0075
0.0000
NOx
0.0680
0.0004
CO
0.3100
0.0020
Section 05 - Emissions Inventor/
Criteria Pollutants
Pctential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
PM10
PM2.5
NOx
CO
375.5
260.8
13.0
313.0
15.6
2658
0.1
0.0
0.0
0.1
0.1
9
0.1
0.0
0.0
0.1
0.1
9
0.6
0.4
0.4
0.5
0.5
81
2.6
1.8
1.8
2.2
2.2
370
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
1899
1319
66
1582
79
Toluene
1917
1331
67
1598
80
Ethylbenzene
124
86
103
5
Xylene
777
540
27
648
32
n -Hexane
15101
10487
524
12584
629
224 TMP
61
42
2
51
3
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XII.C, D, E, F
Storage tank is subject to Regulation 7, Section XII.C-F
Regulation 7, Section XII.G, C
Storage Tank is not subject to Regulation 7, Section XII.G
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart OOOO
Storage Tank is not subject to NSPS 0000
Regulation 8, Part E, MACT Subpart HH
Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
2of7
K:\PA\2019\19W E0404.CP1
Condensate Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions? No
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? No
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company use a site specific emissions factor to estimate emissions? V?s.
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? This sample should be considered representative which generally means site -specific and
collected within one year of the application received date. However, if the facility has not been modified (e.g., no
new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company request a control device efficiency greater than 95% for a flare or combustion device? Yes
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
Site specific emission factors were based off of a ProMax simulation which used a site -specific pressurized liquid sample taken 3/6/2019 and included the usage of a working/breathing stencil to
calculate working/breathing emissions. The calculations and determination of the emission factors were confirmed.
The fuel heat rating is slightly higher than the value calculated in ProMax and is assumed to be a conservative estimate. The gas to oil ratio was calculated from the ProMax simulation. The permit
requested higher limits for the combustion limits than those reflected in this permit analysis to account for the pilot fuel usage and associated emissions.
For NSPS Kb determination, this is a tank batter of 6- 400 bbl liquid manifolded vessels. If replaced by a single vessel, that vessel would be greater than 472 bbls; however, due to the total volume, the
a
.i “s'
tank battery meets x an exemption lion from being applicable. :`;;tt�t;
Y P PP s ;.'
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
001
Process # SCC Code Co01 4-C4-003-11 Fixed Roof TankT C
•:ins mx.r... s:xrx::sxx••x.y 2i ->i. F'x Rr "'i`). s H:4a..tF. t'cii ut?4.ths. :4tis� M s ii. s,., is ,
7?r'�5•:..+ y�-x..xs.r.,>c .?t x It.t Y +3 74,055154141t7414;:".q ::%.i sa> 's.: g.," � StJn :x..nt:$P, t.x.'sxfsx
ivy: ,...e .... ..........«..�v....t......:c.....Y.r.:.v,x..x.. �..1_R t� 146/.R>�x. CJt;sc..iF
...w,nx::5eA:::�
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons condensate throughput
PM2.5 0.00 0 lb/1,000 gallons condensate throughput
NOx 0.01 0 lb/1,000 gallons condensate throughput
VOC 6.8 95 lb/1,000 gallons condensate throughput
CO 0.05 0 lb/1,000 gallons condensate throughput
Benzene 0.02 95 Ib/1,000 gallons condensate throughput
Toluene 0.02 95 lb/1,000 gallons condensate throughput
Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput
Xylene 0.01 95 lb/1,000 gallons condensate throughput
n -Hexane 0.14 95 lb/1,000 gallons condensate throughput
224 TMP 0.00 95 Ib/1,000 gallons condensate throughput
3 of 7 K:\PA\2019\19WE0404.CP1
Condensate Tang Regulatory Analysis Worksheet
Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements
urc:, is in the Non Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility Lncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 WY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source is In the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)?
Source requires a permit
Yes
No
Colorado Regulation 7, Section XII.C-F
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station?
3. Is this storage tank located upstream of a natural gas processing plant?
Storage tank is subject to Regulation 7, Section XII.C-F
Yes
Yes
Yes
Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage
Section XII.C.2 - Emission Estimation Procedures
Section XII.D - Emissions Control Requirements
Section XII.E - Monitoring
Section XII.F - Re:ordkeeping and Reporting
Colorado Regulation 7, Section XII.G
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at a natural gas processing plant?
3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC?
Storage Tank is not subject to Regulation 7, Section XII-G
Yes
Yes
`Jo
Section XII.G.2 - Emissions Control Requirements
Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage
Section XII.C2 - Emission Estimation Procedures
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant?
3. Is this condensate storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions" of this storage tank equal to or greater than 6 tons per year VOC?
Stowe tank is subject to Regulation 7, Section XVII, B. C l & C.3
Yes
No
Yes
Yes
Section XViI.B - General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1 - Emissions Control and Monitoring Provisions
Section XVII.C3 - Recordkeeping Requirements
5. Does the condensate storage tank contain only "stabilized" liquids?
`;tcraee tank is subject to Regulation 7, Section XVII.C.2
Section XVII.C2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (in') ["472 BBLs]?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)?
a. Does tie vessel has a design capacity less than or equal to 1,589.874 m3 (`10,000 BBL) used for petroleum' or condensate stored, processed, or treated prior to custody transfer2 as defined in 60.111b?
3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984?
4. Does the tank meet the definition of "storage vessel"3 in 60.11lb?
5. Does the storage vessel store a "volatile organic liquid (VOL)"s as defined in 60.111b?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ("29.7 psi) and without emissions to the atmosphere (60.110b(d)(2))?; or
b. The design capacity is greater than or equal to 151 m3 (-950 BBL] and stores a liquid with a maximum true vapor pressure6 less than 3.5 kPa (60.110b(b))?; or
c. The design capacity is greater than or equal to 75 M3 (-472 BBL] but less than 151 m3 ["950 BBL) and stores a liquid with a maximum true vapor pressure6 less than 15.0 kPa(60.11ob(b))?
No
Yes
Yes
Source Req
Go to next
Source Req
Continue -'
Continue -'
Source is st
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Storage Tar
Source is st
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Source is st
Source is st
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Storage Tar
Storage Tank is not subject to NSPS Kb
Subpart A, General Provisions
§60.112b - Emissions Control Standards for VOC
§60.113b - Testing and Procedures
§60.115b - Reporting and Recordkeeping Requirements
§60.116b - Monitoring of Operations
40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430?
5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH?
Storage tank is not subject to NSPS 0000
Yes
No
Subpart A, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§60.5395(g) - Not fication, Reporting and Recordkeeping Requirements
§60.5416(c) - Cover and Closed Vent System Monitoring Requirements
§60.5417 - Contro Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, It should remain subject to NSPS 0000 per 60.5365(e)(2) even
if potential VOC emissions drop below 6 tons per year]
40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids2 (63.760(a)(2)); OR
b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))?
2. Is the tank located at a facility that is major' for HAPs?
3. Does the tank meet the definition of "storage vessel" in 63.761?
4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
Storage Tank is not subject to MACT HH
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitoring
§63.774 - Recordkeeping
§63.775 - Reporting
S
RACT Review
RACT review is recuired if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements.
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 Air Act
and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Continue -
Storage Tar
Continue -'
Storage Tar
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
SRC Energy, Inc.
County AIRS ID
123
Plant AIRS ID
A040
Facility Name
Greeley -Rothe Federal 16-1 Pa
History File Edit Date
8/6/2019
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons per year
EMISSIONS With C
- - - - \ - - I- - J -
POIN
T
AIRS
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous
FACILITY TOTAL
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
New Facility - No Previous Total
Previous
Permitted Facility
total
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
•
001
19WE0404
Condensate Tanks (6)- 400 bbl
0.1
0.1
0.6
313.4
2.9
8.3
0.1
0.1
0.6
15.7
2.9
0.3
Newly requested
point
002
GP08
Produced Water Tanks (2) -
0.4
33.6
1.6
2.9
0.4
5.9
1.6
0.1
Newly requested
point
003
GP07
Condensate Loadout
0.0
25.8
1.3
0.4
0.0
10.0
1.3
0.0
Loadout
only
expected
during LACT unit
004
GP02
Caterpillar G3516J,
1380
HP
0.5
0.5
6.7
11.3
27.1
6.6
0.5
0.5
6.7
6.2
1.9
2.0
ENG-1
005
GP02
Doosan D219L
550 HP 4SRB
0.3
0.2
38.8
3.7
65.3
0.5
0.3
0.2
5.3
3.7
10.6
0.5
ENG-2
006
GP02
Doosan D219L 550 HP 4SRB
0.3
0.2
38.8
3.7
65.3
0.5
0.3
0.2
5.3
3.7
10.6
0.5
ENG-3
0.0
0.0
0.0
0.0
APEN
Exempt/Insignificant
0.0
0.0
Heaters (26)
0.5
0.5
6.1
0.3
5.1
0.1
0.5
0.5
6.1
0.3
5.1
0.1
Per Form APCD-102,
grouped for file only
Fugitives
0.3
0.0
0.3
0.0
Per Form APCD-102
0.0
0.0
FACILITY
TOTAL
1.7
1.5
0.0
0.0
91.4
391.8
0.3
168.6
19.4
1.7
1.5
0.0
0.0
24.4
45.5
0.3
34.0
3.7
VOC: Syn Minor (NANSR
NOx: True Minor
CO: Syn Minor (OP),
HAPS: True Minor
and OP)
True Minor (PSD)
Permitted
Facility Total
1.2
1.0
0.0
0.0
853
391.5
,
0.0
163.5
19.3
1.21
1.0 I
0.01
0.0 I
18.31
45.2
0.0
28.91
3.6
Excludes units exempt from
(A)
Change
in Permitted
Emissions
1.2
1.0
0.0
0.0
18.3
45.2
0.0
28.9
Pubcom required
minor permit.
on Division guidance.
Modeling
because new synthetic
not required based
Total VOC Faci
ity Emissions (point and
fugitive
45.8
Facility is eligible for GP02 because < 90
;A) Change in Total Permitted VOC emissions (point
and fugitive
452
Project emissions not less than 25 tpy*
Note
1
Permit will go to
public comment.
_
Note
2
Page 5of7
Printed 8/14/2019
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
SRC Energy, Inc.
123
A040
Greeley -Rothe Federal 16-1 Pad
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Emissions - uncontrolled
(lbs
per year)
POIN1
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL
(tpY)
'Previous
FACILITY
TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
19WE0404
Condensate
Tanks
(6)- 400
bbl
1582
1598
103
648
12584
8.3
002
GP08
Produced
Water
Tanks
(2) -
400
bbl
2700
2293
93
703
„+
2.9
003
GP07
Condensate
Loadout
76
658
0.4
004
GP02
Caterpillar
G3516J,
1380
HP
4SLE
11460
827
508
44
40
110
247
6.6
005
GP02
Doosan
D219L
550
HP
4SRB
720
98
92
55
20
107
0.5
006
GP02
Doosan
D219L
550
HP
4SRB
720
98
92
55
20
107
0.5
0.0
I
0.0
APEN
Exempt/Insignificant
0.0
Heaters
(26)
218
0.1
Fugitives
6
�°
15
0.0
0.0
TOTAL
(tpy)
6.5
0.5
0.3
2.3
2.0
0.1
0.3
7.1
0.2
0.0
0.0
0.0
19.4
I
I
*Total
Reportable
= all
HAPs
where
uncontrolled
emissions > de
minimus values
Red Text: uncontrolled emissions < de minimus
Emissions
with
controls
(lbs
per
year)
POIN
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
224 TMP
Ethylbenzene
Xylenes
n -Hexane
McOH
H2S
TOTAL
(tpY)
!Previous
FACILITY
TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
19WE0404
Condensate
Tanks
(6)- 400
bbl
66
67
524
27
0.3
002
GP08
Produced
Water
Tanks
(2) -
400
bbl
135
115
35
0.1
003
GP07
Condensate
Loadout
4
i
0.0
33
004
GP02
Caterpillar
G3516J,
1380
HP
4SLE
2132
827
508
44
40
110
247
1
2.0
005
GP02
Doosan
D219L
550
HP
4SRB
720
98
92
55
20
107
0.5
006
GP02
Doosan
D219L
550
HP
4SRB
720
98
92
55
20
107
0.5
0.0
0.0
6
19WE0404.CP1
8/14/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name SRC Energy, Inc.
County AIRS ID 123
Plant AIRS ID A040
Facility Name Greeley -Rothe Federal 16-1 Pad
APEN
0.0
Heaters
(26)
_
218
0.1
Fugitives
15
0.0
0.0
1.8
0.5
0.3
0.2
0.1
0.0
0.0
0.5
0.2
0.0
0.0
0.0
3.7
TOTAL
(tpy)
19WE0404.CP1 8/14/2019
An atRnomtodeds See elf, �•►
aokiknct_o. rec+eued fsie�r.
Condensate Storage Tank(s) APEN
Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, 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 and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/pacific/cdphe/air-permits.
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:
/d1WE tpll
AIRS ID Number: /23 IA 04-9s/ CO
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name1:
Site Name:
SRC Energy, Inc.
Greeley -Rothe Federal 16-1 Pad
Site Location: SESE Sec. 1 T5N R67W
Mailing Address:
(Include Zip Code) 5400 W. 11th Street, Suite C
Greeley, CO 80634
Site Location
County: Weld
NAICS or SIC Code: 211111
Contact Person:
Phone Number:
E -Mail Address2:
Brad Rogers
(970) 475-5242
brogers@srcenergy.com
1 Use the full, legal company name registered with the Colorado Secretary of Stare. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
/M� 'COLORADO
1 I A V Dewrmym of u.ic
Has. b EnviinnmeN
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
O Request coverage under traditional construction permit
O Request coverage under a General Permit
❑ GP01 0 GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment 0 Change company name3
❑ 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 -
❑ APEN submittal for permit exempt/grandfathered source
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Storage of condensate from production wells
Company equipment Identification No. (optional): TK 1-6
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 01/15/2019
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week 52
weeks/year
Exploration Et Production (EEtP) site 0 Midstream or Downstream (non EftP) site
Will this equipment be operated in any NAAQS nonattainment area?
17
Yes
•
No
Are Flash Emissions anticipated from these storage tanks?
12
Yes
•
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
19
Yes
■
No
If "yes", identify the stock tank gas -to -oil ratio:
0.00064
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
GI
■
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
O
•
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
.COLORADO
2 1 AV
Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbllyear)
Requested Annual Permit Limits
(bbllyear)
Condensate Throughput:
1,823,741
From what year is the actual annual amount?
Average API gravity of sales oil:
Tank design:
❑✓ Fixed roof
degrees
❑ Internal floating roof
2,188,504
RVP of sales oil:
❑ External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production'?
(month/year)
TK 1-6
6
2,400
12/2018
1/2019
Wells Serviced by this Storage Tank or Tank Batten" (EBP Sites On
y)
API Number
Name of Well
Newly Reported Well
05
- 123
- 40245
Greeley -Rothe Federal 32N -2B -L
12
05
- 123
- 40246
Greeley -Rothe Federal 12N -2A -L
05
- 123
- 40291
Greeley -Rothe Federal 33N -2C -L
GI
05
- 123
- 46447
Greeley -Rothe 34C -2-L
12
05
- 123
- 46448
Greeley -Rothe 34N -2B -L
12
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The EaP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM) .
40.424142/-104.833502
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
❑ Upward
0 Horizontal
❑ Downward
0 Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Square/rectangle
❑ Other (describe):
0 Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 3 AY --„Tr.:-„r-,:c,„
u-..n.omn
COLORADO
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit fi and AIRS ID]
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:
Vapor
El Recovery
Unit (VRU):
Size: Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed (emissions vented): %
❑ Combustion
Device:
Pollutants Controlled: VOCs and HAPs
Rating: 252.74 MMBtu/hr
Type: Enclosed Combustor Make/Model: (4) 96" I ES
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
98
98
%
Minimum Temperature: 1,076°F Waste Gas Heat Content: 2,333 Btu/scf
MMBtu/hr
Constant Pilot Light:❑ Yes ❑ No Pilot Burner Rating:
0.065
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 17.6 psig
Describe the separation process between the well and the storage tanks:
(24)- 36" Worthington 3 -phase separators, (6) 2 -phase vertical separators
(2)- 60" Worthington gas busters
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 4 I A
COLORADO
o,T
lkparrment E EllY .4fuelalei
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
•
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
Enclosed Combustor
98%
NOx
CO
HAPs
Enclosed Combustor
98%
Other:
From what year is the following reported actual annual emissions data? 201 9
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions 8
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
VOC
0.286
lbs/bbl
ProMax
261.18
5.22
313.42
6.27
NOx
0.068
lb/MMBtu
AP -42
N/A
0.52
N/A
0.63
CO
0.310
lb/MMBtu
AP -42
N/A
2.39
N/A
2.86
Non -Criteria _Reportable. Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
(CAS)
Service CAS
Number
Emission Factor?
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
g
Uncontrolled
Emissions
Pounds/ ear
( y )
Controlled
Emissions 8
(Pounds/year)
Benzene
71432
7.23E-04
lbs/bbl
ProMax
1,318.56
26.37
Toluene
108883
7.30E-04
lbs/bbl
ProMax
1,331.33
26.63
Ethylbenzene
100414
4.72E-05
lbs/bbl
ProMax
86.08
1.72
Xylene
1330207
2.96E-04
lbs/bbl
ProMax
539.83
10.80
n -Hexane
110543
5.75E-03
lbs/bbl
ProMax
10,486.51
209.73
2,2,4-
Trimethylpentane
540841
2.31 E-05
Ibs/bbl
ProMax
42.13
0.84
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
5 I AvOLORADO
Co,.,c
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit r 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. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
Lf
g / 20(5
Signature of Legally Authorized Person (not a vendor or consultant) Date
Brad Rogers Health and Environmental Manager
Name (print) Title
Check the appropriate box to request a copy of the:
E 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 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: / /www.colorado.gov/cdphe/aped
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 7/2018 6 I AT
COLORADO
r,- RECEI}
``s
4, APB
Condensate Storage Tank(s) APEN,s\�t,
Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, 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 and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/pacific/cdphe/air-permits.
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: 19WE0404
AIRS ID Number: 123 / A040 / 001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': SRC Energy, Inc.
Site Name: Greeley -Rothe Federal 16-1 Pad
Site Location: SESE Sec. 1 T5N R67W
Mailing Address:
(Include Zip Code) 5400 W. 11th Street, Suite C
Greeley, CO 80634
Site Location
County: Weld
NAICS or SIC Code: 211111
Contact Person: Brad Rogers
Phone Number: (970) 475-5242
E -Mail Address2: brogers@srcenergy.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 Pei-mits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 1 I
P.:
ttigNalc
P0,9 -e3
a 4- 3
N Q -{-
Rece i ved
Permit Number:
19WE0404
AIRS ID Number: 123 1A040/001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
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.
Vapor
❑ Recovery
Unit (VRU):
Pollutants Controlled:
Size: Make /Model:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Li Combustion
Device:
Pollutants Controlled: VOCs and HAPs
Rating: 252.74
Type: Enclosed Combustor
MMBtu/hr CC c
Make/Model: (4) 96" IES
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: 1,076°F
Waste Gas Heat Content: 2,333 Btu/scf
Constant Pilot Light: ❑� Yes ❑ No Pilot Burner Rating: 0.065 MMBtu/hr
9 Closed Loop System
Description of the closed loop system:
O Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (EFtP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 17.6
Describe the separation process between the well and the storage tanks:
psig
(24)- 36" Worthington 3 -phase separators, (6) 2 -phase vertical separators
(2)- 60" Worthington gas busters
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 4
COLORADO
a: Ur .
wawa .i
Permit Number:
19WE0404
AIRS ID Number: 123 /A040/001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - 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):
VOC
Enclosed Combustor
verall Requested Con
icienc''"
reduction :fin; emrsst o
95%
NOx
CO
HAPs
Enclosed Combustor
95%
Other:
From what year is the following reported actual annual emissions data? 201 9
ProMax
261.18
13.06
313.42
15.67
VOC
0.286
lbs/bbl
erta
tutartR Emission
tove€rtnr
NOx
0.068
ib/MMBtu
AP -42
N/A
0.52
N/A
0.63
CO
0.310
lb/MMBtu
AP -42
N/A
2.39
N/A
2.86
7.23E-04
lbs/bbl
ProMax
1,318.56
65.93
Benzene
71432
eportable.Patluta,
iuss ons inven
nuaf
mission
Toluene
108883
7.30E-04
Ibs/bbl
ProMax
1,331.33
66.57
Ethylbenzene
100414
4.72E-05
Ibs/bbl
ProMax
86.08
4.30
Xylene
1330207
2.96E-04
Ibs/bbl
ProMax
539.83
26.99
n -Hexane
110543
5.75 E-03
lbs/bbl
ProMax
10,486.51
524.33
2,2,4-
Trimethylpentane
540841
2.31 E-05
Ibs/bbl
ProMax
42.13
2.11
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
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