HomeMy WebLinkAbout20192075.tiffCOLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
May 28, 2019
Dear Sir or Madam:
RECEIVED
JUN 0 3 2019
COMMISSIONERS
On May 30, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Bison
Oil &t Gas II, LLC - Hunt 8-60 6C. 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
John W. Hickenlooper, Governor
Co11OI 1°1
Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
vPVL(.J'c),
Pko OMIeRloticw)
Co/�31 tot
2019-2075
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Bison Oil Et Gas II, LLC - Hunt 8-60 6C - Weld County
Notice Period Begins: May 30, 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: Bison Oil Et Gas II, LLC
Facility: Hunt 8-60 6C
Oil and Gas Exploration Et Production Well Pad
SESE Quadrant of Section 6, Township 8N, Range 60W
Weld County
The proposed project or activity is as follows: The Hunt 8-60 6C Production Facility is an exploration and
production (EEtP) well site with two producing wells. Sources requiring an air permit at this facility include
liquid loadout (covered under GP07), crude and produced water storage (covered under GP08) and VRT gas
venting during VRU downtime (covered under 18WE1005.CP1).
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 18WE1105.CP1 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:
James Ricci
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
18WE1105 105 Issuance:
XX
Bison Oil a Gas III LLC
Facility Name: Hunt 8-60 6C
Plant AIRS ID: 123/A003
Physical Location: SESE Quadrant of Section 6, Township 8N, Range 60W
County: Weld County
General Description: Well Production Facility
Equipment or activity subject to this permit:
AIRS
Point
Equipment Description
Emissions Control
Description
006
Two (2) Vapor Recovery Towers (VRT)
Enclosed Combustor
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit 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
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.)
AIRS ID: 123-A003-006 Page 1 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.)
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:
Note: See "Notes to
calculate limits.
AIRS
Point
Tons per Year
Emission
Type
VOC
006
5.0
Point
Permit Holder" for information on emission 1
actors and methods used to
Compliance with the annual limits for criteria 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 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.)
AIRS
Point
Control Device
Pollutants
Controlled
006
Emissions from the (2) VRTs are routed to
an Enclosed Combustor during Vapor
Recovery Unit (VRU) downtime
VOC and HAPs
AIRS ID: 123-A003-006
Page 2 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
PROCESS LIMITATIONS AND RECORDS
8. 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
AIRS
Point
Process Parameter
Annual Limit
006
Liquid Throughput
during VRU downtime
37,700 bbl/yr
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.
9. The owner or operator shall continuously monitor and record Vapor Recovery Unit (VRU)
downtime while emissions are routed to the control device.
10. The owner or operator must use monthly VRU downtime records, monthly condensate/crude oil
throughput records, calculation methods detailed in the OEtM Plan, and the emission factors
established in the Notes to Permit Holder to demonstrate compliance with the process and
emissions limits specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. 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,
12. This source is subject to the odor requirements of Regulation Number 2. (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.16; 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 separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only).
On or after August 1, 2014, gas coming off a separator, produced during normal operation from
AIRS ID: 123-A003-006 Page 3 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
any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either
be routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
combustion device is used, it -must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING £t MAINTENANCE REQUIREMENTS
15. 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 OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator 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 XVII.B.2. and XVII.A.17)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) 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 NOX 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
AIRS ID: 123-A003-006 Page 4 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
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
19. Federal regulatory program requirements (i.e. PSD, NANSR) shall 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 shall not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
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:
Permit
Number
AIRS
Point
Equipment Description
Pollutant
Emissions - tons per
year
Threshold
Current
Permit
Limit
GP07
001
Liquid Loadout
VOC
100
10.0
GP07
002
Liquid Loadout
VOC
100
10.0
GP08
003
Crude Storage Tanks
VOC
100
5.9
GP08
004
Produced Water Storage Tanks
VOC
100
5.9
GP08
005
Crude Storage Tanks
VOC
100
5.9
18WE1105.CP1
006
VRT gas venting during VRU downtime
VOC
100
5.0
SUM
V0C
100
42.7
AIRS ID: 123-A003-006
Page 5 of 10
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
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self -Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof 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.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
AIRS ID: 123-A003-006 Page 6 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
By: DRAFT
James Ricci
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Bison Oil Et Gas II for venting (2) VRTs
during VRU downtime at a synthetic minor
facility in the non -attainment area.
AIRS ID: 123-A003-006 Page 7 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
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 #
Uncontrolle
d Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
006
Benzene
71432
411
21
Toluene
108883
80
4
Ethylbenzene
100414
13
1
Xylenes
1330207
57
3
n -Hexane
110543
3746
187 •
2,2,4-Trimethylpentane
540841
29
1
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.
AIRS ID: 123-A003-006 Page 8 of 10
COLORADO
Air Pollution Control Division
Department of Pubhc Health & 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:
Point 006:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/bbl)
Controlled
Emission
Factors
(lb/bbl)
Source
NOx
8.80 x 10-3
AP -42
CO
4.01 x 102
AP -42
VOC
5.13 x 10°
2.57 x 10"1
Extended Gas
Analysis
71432
Benzene
1.09 x 10-2
5.45 x 10"4
108883
Toluene
2.12 x 10.3
1.06 x 10-4
100414
Ethylbenzene
3.43 x 10"4
1.72 x 10"5
1330207
Xylene
1.50 x 10-3
7.51 x 10-5
110543
n -Hexane
9.94 x 10-2
4.97 x 10-3
540841
2,2,4-Trimethylpentane
7.60 x 10-4
3.80 x 10-5
Note: The controlled emissions factors for this point are based on the enclosed combustor
control efficiency of 95%.
The emission factors listed above are based on modeled VRT temperature of 115.8°F and VRT
pressure of 2.0 psi.
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 facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
AIRS ID: 123-A003-006
Page 9 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
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
AIRS ID: 123-A003-006 Page 10 of 10
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer
Package #
Received Date
Review Start Date
James Riccl
589109 -
10/19/2018
2f15/2019
Section 01- Facility Information
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Location
County Weld County
Type of Facility [tuplorations& Production Well Padi 47,,,in,,+-r�•5,r
What industry segment?jOd&,N tu`ralGessPProduction,&prge smg_
Is this facility located in a NAAQS non attainment area?
If yes, for what pollutant? 0 Carbon Monoxide (CO) 0
Bison Oil Gas II,LLC ,t
123?-vk�_ _r
Anos ,
SESE Quadrant of Section 6Township SN, Range 60W
Section 02 - Emissions Units In Permit Application
a
Particulate Matter (PM)
O
Quadrant
Section
Township
Range
SESE
6
8N
60 ,
Ozone (NOx a. VOC)
AIRS Point #
Emissions Source Type
Equipment Name
Emissions
Control',
Permit 9
Issuance
Self Cert
Required?
Action
Engineering
Remarks
006 _
��
Se orator`) nting,'t�,—,
„T
"� j r
,PYes r',";‘,"
I
18WE1105 CP1
1__
— `4 ,
i'� e
,,`� ` 7.3a `"
Permit Indial�
'+Issuances
_
Section 03 - Description of Project
The Hunt 8,60 6C production Facility is an exploration and production (E&P) well site with two producing wells Production fluid from each wellhead flows to a three phase separator (one
separator p`e"r wellhead) Natural gas flow's from each separator to a common `sales gas headerthat allows gas to be either diveiYed togas injectlon'atthe wellhead orflow to th"e'salesrlirie `'
Produced water flows from the separator Into a commomllquid header for all wells at the facility and then into a bank of produced watectanks Water Is pumped from these tanks to a ,
pipeline for disposal Crude oil flows from ttie separator to a vapor recovery tower (VRT) operating at 2 psi (one VRT per separator) Vapors`from the VRT flow to a grid powered elec'tnc "
compressor vapor" recovery unit (VRU) where they are compressed and sent to the sales gas header Bison Oil &Gasyl, LI,C ,i , _ ,
_
Vapors fromlthe VRT can be diverted to the existing bank of combustors in the event of VRU downtime "
y ry
Section 04 - Public Comment Requirements
Is Public Comment Required? �<�(i Yes
If yes, why? �: r -� ' Requesting Synthetic_Mmor Permit , °� � ' .__4
Section 05 -Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required? No t>`
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)
34 cg�YeL.1 ens
502 NOx CO VOC
COCO
❑ ❑ ❑ O
0 O
Is this stationary source a major source? �.
If yes, explain what programs and which pollutants here SO2 NOx CO
Prevention of Significant Deterioration (PSD) 0 0 0
Title V Operating Permits (OP) 0 0 0
Non Attainment New Source Review (NANSR) 0
0
V0C
0
PM2 5
0
0
PM2 5
0
0
PM10 TSP HAPs
0
❑ ❑ ❑
PM10 TSP HAPs
❑ ❑ ❑
Separator Venting Emissions Inventory
006 Separator Venting
Facility AIRs ID:
123
County
A003
Plant
006
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Descript on:
Two (2) VRTs, Crude oil flows from the separator to a vapor recovery tower (VRT) operating at 2 psi (one VRT per separator)
Emission Control Device Description: Enclosed Combustion Device, Cimarron 48" HV ECD
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Liquid Throughput
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput = 37,700.0 Barrels (bbl) per year
Requested Permit Limit Throughput = 37,700.0 Barrels (bbl) per year Requested Monthly Throughput = 3202 bbl per month I
Potential to Emit (PTE) Throughput = 37,700 Barrels (bbl) per year
Process Control (Recycling)
Equipped with a VRU: Yes
Is VRU process equipment: Yes
Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare)
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Max Gas Rate
Max Vented Rate
Vented gas per bbl of throughput:
Section 04 - Emissions Factors & Methodologies
Description
2551 Btu/scf
22957849 scf/year
1913154 scf/year
50.75 scf/bbl
From the 5-6 Well (Highest HHV)
1394 scf/hr from the 5-6 Well and 12:6.759 scf/hr for the 5-10 Well, Modeled in Winsim
730 hours of VRU downtime assumed
Based on permited throughput of crude tanks, 730 hours of VRU downtime assumed
A sample of gas was taken from the Hunt 8-60 6C 5-10 well and the Hunt 8-60 6C 5-6 well at this facility. All calculations were based off the Hunt 8-60 6C 5-6 sample which contained a higher percentage of VOCs. The sample was
taken by zedi on 8/31/2018 at 2 psi and 115.8 deg F. An extended gas anaylysis was performed on 9/11/2018 which resulted in the %Weights below.
Displacement Equation
Ex = Q * MW * Xx / C
MW (lb/lb-mol)
45.82
Weight %
Helium
0.00
CO2
0.84
N2
1.35
methane
4.20
ethane
9.88
propane
30.65
isobutane
6.62
n -butane
24.94
isopentane
6.74
n -pentane
8.47
cyclopentane
0.43
n -Hexane
1.62
cyclohexane
0.37
Other hexanes
2.14
heptanes
1.23
methylcyclohexane
0.10
224-TMP
0.01
Benzene
0.18
Toluene
0.03
Ethylbenzene
0.01
Xylenes
0.02
C8+ Heavies
0.16
Total
100.00
VOC Wt %
83.73
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
Emission Factor Source
(lb/bbl) (lb/bbl)
(Liquid Throughput)
(Liquid Throughput)
VOC
5.13E+00
2.57E-01
Extended gas analysis
Extended gas analysis
Extended gas anal ysis
Benzene
1.09E-02
5.45E-04
Toluene
2.12E-03
1.06E-04
Ethylbenzene
3.43E-04
1.72E-05
Extended gas anal ysis
Xylene
1.50E-03
7.51E-05
Extended gas analysis
Extended gas analysis
n -Hexane
9.94E-02
4.97E-03
224 TMP
7.60E-04
3.80E-05
Extended gas analysis
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) lb/bbl
(Waste Heat Combusted)
(Gas Throughput)
PM10
0.0075
0.001
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PM1O/PM.2.5)
AP -42 Table 1.4-2 (SOx)
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
0.001
SOx
0.0006
0.000
NOx
0.0680
0.009
CO
0.3100
0.040
1 of 5
K:\PA\2018\18WE1105.CP1.xlsm
Separator Venting Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential 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)
PM10
0.02
0.02
0.02
0.02
0.02
3
PM2.5
0.02
0.02
0.02
0.02
0.02
3
SOx
0.00
0.00
0.00
0.00
0.00
0
NOx
VOC
0.17
0.17
0.17
0.17
0.17
28
96.72
96.72
4.84
96.72
4.84
821
CO
0.76
0.76
0.76
0.76
0.76
128
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
411
411
21
411
21
Toluene
80
80
4
80
4
Ethylbenzene
13
13
1
13
1
Xylene
57
57
3
57
3
n -Hexane
3746
3746
187
3746
187
224 TMP
29
29
1
29
1
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
You have indicated above the monitored process parameter is Liquid Througput. The following question does not require an answr.
Using Liquid Throughput to Monitor Compliance
Does the company use site specific emission factors based on a pressurized liquid sample (Sampled upstream of the
equipment covered under this AIRs ID) and process simulation to estimate emissions?
This sample should have oeen 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 collect a site -specific liquid sample and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Yes
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
Site specifc gas sample used to develop emissison factors. Site
specific liquid used to develop venting rate needed.
No
3 of 5 K:\PA\2018\18WE1105.CP1.xlsm
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
The applicant will use liquid throughput as the process limitation for this permit. Since uncontrolled VOC emissions are estimated to be less than 100 tons, using liquid throughput is acceptable.
Liquid samples at this facility were modeled in WinSim to estimate the quantity of gas coming off the VRTs, 22,957,849 scf/year. This gas off the VRT is sent to a VRU, however, it is assumed there will be 730 hours of VRU downtime per year.
Based on 730 hours of downtime, it is estimated that 1,913,154 scf/year of gas will be vented. Using the same WinSim model used to estimate vented gas, the liquid throughput plus estimated VRU downtime estimated was used to estimate
the equivalent throughput during VRU downtime.
The site specific gas sample analysis was combined with the equivalent liquid throughput during VRU downtime to develop site specific emissions factors on a lb/bbl basis.
APEN reported emissions were rounded to the nearest whole number, this was accepted as a conservative approach.
Per the applicant, hours of VRU downtime are tracked based on a flowmeter on the VRU discharge line. Liquid throughput during periods of VRU downtime is taken from the crude oil flow meters at each individual separator (immediately
upstream of VRT's) during those periods of VRU downtime.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
006
Process #
01
SCC Code
3-10-001-29 Oil & Gas Production: Gas/liquid separation
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.96 0 Ib/1000bbl
PM2.5 0.96 0 Ib/1000bbl
SOx 0.08 0 Ib/1000bbl
NOx 8.80 0 lb/1000bbl
VOC 5131.27 95 Ib/1000bbl
CO 40.13 0 Ib/1000bbl
Benzene 10.91 95 Ib/1000bbl
Toluene 2.12 95 Ib/1000bbl
Ethylbenzene 0.34 95 Ib/1000bbl
Xylene 1.50 95 Ib/1000bbl
n -Hexane 99.37 95 Ib/1000bbl
224 TMP 0.76 95 lb/1000bbl
4 of 5 K:\PA\2018\18WE1105.CP1.xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is in the Non -Attainment Ares
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.O.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
Not enough information
Yes
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. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part 8, Section II.D.2)?
Yes
Source requires a permit
Colorado Regulation 7. Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
Yes
Source is subject to Regulation 7, Section XVII.S.2, G
Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
Section XVII.B.2.e - Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply 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
No
Source Req
Source Req
Source is si
The control
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and aF
updates. An application with m
longer application processing ti
incorrectly or is missing inforrr
This APEN is to be used for gas
casing, pneumatic pumps, blov
category, there may be a more
loading, condensate storage to
specialty APEN options will not
Air Pollution Control Division (...
OCr19
new and existing facilities, including APEN,
d incomplete and may be returned or result, n`
nal APEN fee if the APEN is filled out
missions from gas/liquid separators, well head
r your emission unit does not fall into this
Amine sweetening unit, hydrocarbon liquid
[PEN (Form APCD-200) is available if the
f all available APEN forms can be found on the
/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:
qw t o AIRS ID Number: (7-5 (.,`0 / 0O
[Leave blank unless APCD has already assigned a permit # and AIRS ID] F �
Section 1 - Administrative Information -
Company Name:
Site Name:
Site Location:
Bison Oil & Gas II, LLC
Hunt 8-60 6C
SESE Sec. 6 T8N R60W
Mailing Address: 518 17th Street, Suite 1800
(Include Zip Code)
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 211120
Contact Person: Abigail Wenk
Phone Number: (720) 644-6997 x4
E -Mail Address2: awenk@bisonog.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.
Form APCD-211 - Gas Venting APEN - Revision 7/2018
389107
®VICOLORADo
2018
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
O NEW permit OR newly -reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
O Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership's ❑ 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 a Notes: Enclosed burners to control venting emissions are the same as used for tanks.
This APEN requests additional emissions beyond what is calculated for combustion of tank emissions.
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: Enclosed combustion device to control emissions from
vapor recovery towers during VRU downtime. Operating hours are intermittent (730 hrs/year).
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
7/23/2018
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:
24
Will this equipment be operated in any NAAQS
nonattainment area?
hours/day 7
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?`."
days/week 52 weeks/year
Yes
Yes
Yes
❑ No
▪ No
❑ No
Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I AV
COLORADO
of Pcm
bNN two Envltenmmt
Permit Number: AIRS ID Number:
[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:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑✓ No
Vent Gas
- Heating Value:
2371
BTU/SCF
Requested:
2
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
3 1)1 0 0
bbl/year
Actual:
bbl/year
Molecular Weight:
y 5.g
VOC (Weight %)
%3.}
Benzene (Weight %)
O. 1-1.1
Toluene (Weight %)
0.0 .o3 -lb
Ethylbenzene (Weight %)
0.0osb
Xylene (Weight %)
o .k)195
n -Hexane (Weight %)
).1,)._
2,2,4-Trimethylpentane (Weight %)
0.0 l I' -
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX & n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX & n -Hexane, temperature, and
pressure)
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-211 - Gas Venting APEN - Revision 7/2018
� COLORADO
3 I e
naw�a�u o� n,nm
Haai�hb FSNrtNuwft
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.687544, -104.141119
Operator
Stack ID No.
e
AboveDischargGroundHeight Level
(Feet)
Temp,
('F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular
❑ Other (describe):
Interior stack diameter (inches):
❑ Upward with obstructing raincap
48"
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.
❑ VRU:
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Make/Model:
❑ Combustion
Device:
Pollutants Controlled:
Rating:
Type:
VOC, BTEX
7.9
Enclosed Combustion Device
MMBtu/hr
Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 99 %
Minimum Temperature: 650 F
Cimarron 48" HV ECD
Waste Gas Heat Content: 2371 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-211 - Gas Venting APEN - Revision 7/2018
41
COLORADO
tivatll En5of f
vit,--nrtml
Permit Number:
AIRS ID Number:
[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
efficiency (% reduction ):
"" Pollutant
Description of Control Method(s)
Overall Requested.
Control Efficiency
(% reduction in emissions)
PM
SOX
NOx
CO
VOC
Enclosed combustion device
95
HAPs
Enclosed combustion device (STEX)
95
Other:
From what year is the following reported actual annual emissions data?
N/A
Criteria Pollutant Emissions Inventory
Pollutant...
.T._.__,.__..._
. w---_�:�-:�:'Uncontrolled.
' Emission Factor . _.Actual
Annual Emissions
Requested Annual.Permit =
Emission Limit(s)5.
_:.. _.___
......
Y- _
...-.,.. .�..
, : ;Unitsw
, S9c::::
...:
.:mW (AP 42,...
Mfg ,_ etc.)
; Uncontrolled.
,..r._.__.
.._ Emissions -.:
(tons/year) -_
Controlled
v =_,
_...... .. ........_6.....
Emissions ::_-.
._
tons/Year):::-_,
... .. : .
-' "
: Uncontrolled_
. — Emissions.—. _
.._.(tons/year).-_ .
=,Controlled _
_d
:--- ----- w-
Basis
_....
Emissions..:: -,
(tons%yeai)
PM
SOX
NO),
0.06V
(qI"1lu1S¢,
AP -42
0.1
0.1
CO
O.
ill ivint k
AP -42
0•r6
0•q.
VOC
S. B
\1, i its\
Site -specific
1'4
S
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,.:
Mfg.; etc.)
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions6
(pounds/year)
Benzene
71432
b. o1O`i
jt-> I V,
i ii 1,1,1
Site -specific
91t
2
Toluene
108883
t. o 020-
Site -specific
Ethylbenzene
100414
O.OOO-S13 11, l 45l '
Site -specific
Xylene
1330207
0.001C0 1 1 55l
Site -specific
n -Hexane
110543
O. o `i`1' ll,1 t l p
Site -specific
- Ii `
( 81-
2,2,4-
Trimethylpentane
540841
1).00 6Q
�
11,\1.1)1
Site -specific
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.
Form APCD-211 - Gas Venting APEN - Revision 7/2018
COOADO
5 I �LR
- i1-a{115EEnNvonmcM
Permit Number:
AIRS ID Number:
[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.
tv.
Signature of Legally Authorized Person (not a vendor or consultant) Date
Abigail Wenk Regulatory Manager
Name (please 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 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
Form APCD-211 - Gas Venting APEN - Revision 7/2018
6 I AV'COLORADO
i Health. Enj en,
3/1/2019 State.co.us Executive Branch Mail - RE: APEN Review - Hunt 8-60-6C Facility AIRS ID 103/A003
sTATE OF
COLORADO
Ricci - CDPHE, James <james.ricci@state.co.us>
RE: APEN Review - Hunt 8-60-6C Facility AIRS ID 103/A003
1 message
Shannon McKibben <smckibben@quandaryconsultants.com>
To: "Ricci - CDPHE, James" <james.ricci@state.co.us>
Good morning James,
Mon, Feb 25, 2019 at 9:20 AM
I have attached a document including updated calculation worksheets, an updated Form APCD-102, and explanations of changes made to
calculations. Please redline the APENs as requested, based on this summary and our previous phone conversation. In summary:
While recalculating venting emissions, I realized that I had mistakenly applied the AP -42 combustion factors for small boilers instead of
the factors for flares to the combustion calculations for all AIRS points. This has been corrected, with requested updated emission factors
and emissions listed in the attached document.
Total emissions for the two (2) Crude Oil Tank APENs were updated to include all 3 vessels
For Venting, the most conservative gas analysis (VRT 6) was applied to both streams per prior APCD guidance to me (as we discussed
on the phone). I also recalculated the flow rates as you had indicated. In looking at the calculations I realized that I was mistakenly
adjusting an already standardized flow rate for the gas streams to standard conditions as if it were in acfh instead of scfh. This has been
corrected so that the flow rates shown in the WinSim simulation are simply multiplied by 379.4 scf/lb-mol since they're already in scfh.
Emission factors were also changed to be in a liquid throughput basis (lb/bbl) instead of a gas throughput basis (lb/mmscf), per our phone
discussion.
Please let me know if you have any additional questions, and thank you for your help.
Shannon McKibben
Environmental Engineer
Quandary Consultants
From: Ricci - CDPHE, James <james.ricci@state.co.us>
Sent: Friday, February 15, 2019 2:27 PM
To: awenk@bisonog.com; Shannon McKibben <smckibben@quandaryconsultants.com>
Subject: APEN Review - Hunt 8-60-6C Facility AIRS ID 103/A003
Hi Abigail, Shannon,
I am reviewing the APENs for the Hunt 8-60-6C Facility, below are a couple questions I was hoping you can help me with:
Condensate Tanks:
The emissions factors matched my calculations, but the total emissions were off. I think the calculation sheet may have been using
bbl/vessel instead of bbl/tank, everything was off by a factor of three.
Do you know why the molecular weight of the input stream in Winsim differs so much from the lab analysis? Is it because all Decanes+
are assumed to be Decanes? I don't know a lot about Winsim but I assume this is a conservative approach for the model?
Is there is a setting in Winsim to show which values are inputted by the user and which are calculated? Maybe this is just more for my
own curiosity!
Venting_
Are all the flowmeters listed on the process diagram already installed?
I'm not quite following the calculation methodology. Below is how I calculated emissions which resulted in higher values that listed on the
APEN. I assumed 1 MMMscf/well. From the looks of it, only VRT gas is requested to be vented and we have a direct sample of VRT gas
from both wells. Even assuming 1.06 MMscf from the 5-6 well and 0.94 MMscf from the 5-10 well (based on flow rates from the VRT), I
get even higher emissions than listed below. I know this may be hard to explain through text, feel free to call if you think it would be
easier.
https://mail.google.com/mail/u/0?ik=5517734b80&view=pt&search=all&permthid=thread-a%3Ar-114253675034398059&simpl=msg-M3A1626458451... 1/2
REQUESTED REDLINE CHANGES TO HUNT 8-60
6C WELL PRODUCTION FACILITY, INCLUDING
EXPLANATIONS FOR CHANGES
1. AIRS ID 123-A003-001 [Crude Loadout 8-60 6-5-10 Well]
1. Reason: Small Boiler AP -42 factor used in original APEN instead of Flare AP -42
factors for combustion emissions
1. NOxemission factor: change from 245 lb/mmscf to 0.068 lb/mmbtu
2. NOx emissions (tons/year): No change (0.1 tpy)
3. CO emission factor: change from 206 lb/mmscf to 0.31 lb/mmbtu
4. CO emissions (tons/year): Change from 0.1 tpy to 0.2 tpy
2. AIRS ID 123-A003-002 [Crude Loadout 8-60 6C-5-6 Well]
1. Reason: Small Boiler AP -42 factor used in original APEN instead of Flare AP -42
factors for combustion emissions
1. NOx emission factor: change from 259 lb/mmscf to 0.068 lb/mmbtu
2. NOx emissions (tons/year): No change (0.1 tpy)
3. CO emission factor: change from 218 lb/mmscf to 0.31 lb/mmbtu
4. CO emissions (tons/year): Change from 0.1 tpy to 0.3 tpy
-_-3.— AIRS ID 123-A003-003 [Crude Oil Tanks 8-60.6C-5-6 Well]
1. Reason: Small Boiler AP -42 factor used in original APEN instead of Flare AP -42
factors for combustion emissions
1. NOxemission factor: change from 259 lb/mmscf to 0.068 lb/mmbtu
2. NOx emissions tons ear Change from 0.2 tpy to 0.1 tpy
(tons/year): ) g -
3. CO emission factor: change from 218 lb/mmscf to 0.31 lb/mmbtu
4. CO emissions (tons/year): Change from 0.2 tpy to 0.5 tpy
2. Reason: Total VOC emissions incorrectly reported per vessel in APEN, not for tank
(three manifolded vessels)
1. Requested Annual Permit Emission Limit(s)
1. Change uncontrolled VOC emissions from 17 tpy to 49.3 tpy
2. Change controlled VOC emissions from 1 to 2.5 tpy
4. AIRS ID 123-A003-004 [Produced Water Tanks]
1. Reason: Small Boiler AP -42 factor used in original APEN instead of Flare AP -42
factors for combustion emissions
1. NOxemission factor: change from 146.7 lb/mmscf to 0.068 lb/mmbtu
2. NOx emissions (tons/year): Change from 0.4 tpy to 0.2 tpy
3. CO emission factor: change from 123.2 lb/mmscf to 0.31 lb/mmbtu
4. CO emissions (tons/year): Change from 0.4 tpy to 1.1 tpy
5. AIRS ID 123-A003-005 [Crude Oil Tanks 8-60 6C-5-10 Well]
1. Reason: Small Boiler AP -42 factor used in original APEN instead of Flare AP -42
factors for combustion emissions
1. NOxemission factor: change from 245 lb/mmscf to 153 lb/mmscf (includes
pilot emissions for burners)
2. NOx emissions (tons/year): Change from 0.2 tpy to 0.1 tpy
3. CO emission factor: change from 205 lb/mmscf to 608 Ib/mmscf (includes
pilot emissions)
4. CO emissions (tons/year): Change from 0.2 tpy to 0.5 tpy
2. Reason: Total VOC emissions incorrectly reported per vessel in APEN, not for tank
(three manifolded vessels)
1. Requested Annual Permit Emission Limit(s)
1. Change uncontrolled VOC emissions from 15 tpy to 42.4 tpy
2. Change controlled VOC emissions from 1 to 2.1 tpy
6. AIRS ID 123-A003-006 [VRT Venting]
1. Reason: Small Boiler AP -42 factor used in original APEN instead of Flare AP -42
factors for combustion emissions
1. NOx emission factor: change from 246 Ib/mmscf to 0.068 Ib/mmbtu
2. NOx emissions (tons/year): Change from 0.3 tpy to 0.2 tpy
3. CO emission factor: change from 207 Ib/mmscf to 0.31 lb/mmbtu
4. CO emissions (tons/year): Change from 0.2 tpy to 0.8 tpy
2. Reason: Calculation methodology for overall venting emissions changed as follows
(items 1-3):
1. Gas analysis changed from a separate analysis for each stream to the most
conservative (highest VOC content - VRT 6) stream representing both
streams, to be more conservative. Based on previous APCD guidance for a
similar well.
2. Flow rates recalculated correctly based on use of standard condition ideal
gas conversion rate (previously, temperature and pressure adjustments had
been applied inappropriately to a gas stream that had already been adjusted
from actual to standard conditions)
3. Emission factor requested to be changed from a gas -based factor to a liquid -
based factor for ease of calculation_
4. Changes Requested:
1. Section 4 - Process Equipment Information
1. Remove data from "Gas Venting Process Parameters" section
2. In "Liquid Throughput Process Parameters" section, add a
requested throughput of 37700 bbl/year
3. In Vented Gas Properties section, change data as follows to
match analysis data for most conservative stream (VRT-6):
1.
2. Criteria Pollutant Emissions Inventory
1. Change VOC emission factor from 79848 Ib/mmscf to 5.13
lb/bbl f
Motecular Weight:
45.8
voc (Weight %)
83.7
Benzene (Weight %)
0.178..
Toluene (Weight %)
0.0346
Ethylbenzene (1/41,/eight )
0.0058
Xytene Meight %)
0.02245.
n -Hexane (Weight %)
1_62
2,2,4 -Trip thylpentane (Weight %)
0.01124
2. Change uncontrolled VOC emissions from 77 tpy to 97 tpy "*"
3. Change controlled VOC emissions from 4 tpy to 5 tpy
3. Non -Criteria Reportable Pollutant Emissions Inventory
1. Change all emission factors from lb/mmscf basis to lb/bbl
basis as listed below:
1. Benzene: 0.0109,lb/bbl (est. max uncontrolled
emissions 411`16/y)
2. Toluene: 0.00212 Ib/bbl f
3. Ethylbenzene: 0.000343 lb/bbl
4. Xylene: 0.00150 lb/bbl "
5. N -Hexane: 0.0994 lb/bbl (est. max uncontrolled ✓
actual emissions 3746` 6/yr)
6. 224-TMP: 0.000760 lb/bbl V
Hello