HomeMy WebLinkAbout20191291.tiffCOLORADO
Department of Public
Health is Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
March 25, 2019
RECEIVED
APR 01 2019
WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On March 28, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for
Cureton Front Range, LLC - Black Creek Compressor Station. 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 a 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
pubC Pvav \C
14181 t q
4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
CC: PL(1'c ) Wtl-3 T ),
PAXSM leelev I&5
2019-1291
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Cureton Front Range, LLC - Black Creek Compressor Station - Weld County
Notice Period Begins: March 28, 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: Cureton Front Range, ,LLC
Facility: Black Creek Compressor Station
Natural gas compressor station
SWSW Sec. 4, T3N, R62W
Weld County
The proposed project or activity is as follows: Applicant proposes to operate two (2) triethylene glycol
natural gas dehydration units, each with a design capacity of 20 MMSCF per day.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE1154 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:
Brad Eades
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
1:117W
COLORADO
1 I
�.0
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
eradfey',�Eades I.
3895531
10/30/2018
2/5/2019
Section 01- Facility Information
Company Name: Cureton Front Range LLC
County AIRS ID: 123
Plant AIRS ID: A006
Facility Name: Black Creek Com(iressoi Station
Physical Address/Locatio SWSW quadrant of Section 4, Township 3N, Range 62W, in Weld County, Colorado
Type of Facility: Natufa om re
What industry segment? OIL
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? on Monoxide (CO)
Weld
Section 02 - Emissions Units In Permit Application
Quadrant
SWSW
Section I Township
Range
62
culate Matter (PM) Ene (NOn & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance
Self Cart
Required?
Action
Engineering
Remarks
00
tEC, T h1'rtli o, ,
.;
Il ::
... �,-TE
i63.: Y+ets
-:18W51154
1
��
! Y 5 -M
R iJn�a�
V1 ," .. �"p,,
002
E be)tyc�O '
.3«:
:L=G2
� `�'eS��..m
1'$WE1154
1
/,
Section 03 - Description of Project
Applicant has submitted application to obtain a contructilor, permit
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why?
or two (21
TEG dehydrate
new natural gas compressor utatia
Section 05 -Ambient Air Impact Analysis Requirement
Was a quantitative modeling 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
502 NOx CO VOC PM2.5 PM10 TSP HAPs
Is this stationary source a major source?
If yes, explain what programs and which pollutants her SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
No
NOx
CO
VOC
PM2.5
PM10
TSP
❑ ❑
HAPs
El El
Glycol Dehydrator Emissions Inventory
Section 01 -Administrative Information
(Facility AIRS ID:
123
County
A006
Plant
001.......
Point
Section 02 - Equipment Description Details
Dehydrator Information
Dehydrator Type:
Make:
Model:
Serial Number:
Design Capacity:
Recirculation Pump Information
Number of Pumps
Pump Type
Make:
Model:
Design/Max Recirculation Rate:
Dehydrator Equipment
Flash Tank
Reboller Burner
Stripping Gas
Dehydrator Equipment Description
gallons/minute
, flash tank,
and reboiler burner
One (1) Triethylene glycol (T£G) natural gas dehydration unit (Malta: TBD, Model: TOD, Serial Number: TBD) With a design
capacity of 20 MMscf per day. This emissions unit is equipped with one (1) (Make: TOD, Model: TBD) electric dnivenglycol
pump with a design capacity of 3.5 gallons per minute. This dehydration unit is equipped with a still vent, flash tank, and
reboller burner.
Emissions from the still vent are routed to a liquids knockout vessel, and then to the Enclosed Flare. Emissions from the flash
Emission Control Device Description: tank are routed to the liquids knockout vessel and then to the Enclosed Rare.
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions- Dehydrator Still Vent end Fland FlashT k (if pt)
Requested Penult Um 0Throughput= 311-'.)�3i't 31]PAy'MMscf per year
Potential to Emit (PTE) Throughput = 7,300.0 MMscf per year
Secondary Emissions- Combustion Device(s) for Air Pollution Control
Still Vent Control
Condenser/Dqukis Knockout:
Condenser emlaslon reduction claimed:
Primary control device:
Primary control device operation:
Secondary control device:
Secondary control device operation:
Still Vent Gas Heating Value:
Still Vent Waste Gas Vent Rate:
Flash tank Control
Primary control device:
Primary control device operation:
Secondary control device:
Secondary control device operation:
Flash Tank Gas Heating Value
Flash Tank Waste Gas Vent Rate:
Secondary Emissions - Combustor Fuel Emissions
Pilot Fuel Flow
Pilot HHV
TOTAL PILOT FUEL
Section 04- Emissions Factors & Methodologies
Input Parameters
Inlet Gas Pressure
Inlet GasTemperature
Requested Glycol Recirculate Rate
f`36211.f MMscf per month
66.67 scfh
12ti8.. btu/scf (based on worst case)
1.5 MMscf/yr
STILL VENT
Control Scenario
Primary
Secondary
Pollutant
Uncontrolled (Ih/hr)
Controlled (lb/hr)
Controlled (lb/hr)
VOC
-.9,9834
0.49917
0
Benzene
1.8527
0,093135
0
Toluene
1.8S09
0.092545
0
Ethylbenzene
0.5242
0.02621
0
Xylenes
1.2088
0.06044
0
n -Hexane
9.1045
0.005245
0
224 -IMP
0
0
0
FLASH TANK
Pollutant
Uncontrolled (lb/hr)
Control Scenario
Primary
Controlled (Ib/hr)
Secondary
Controlled (lb/hr)
VOC
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
224-TMP
10.1974;.. i=
0.509871096
0.00286
0.001885
0.00031
0.000485
0.00464
0
0
0
0
0
0
u OOt0052" : -='i
I �f₹:0097 :tlil3:,
0
Wet Gas Processed:
Still Vent Primary Control: 7,300.0 MMscf/yr
Still Vent Secondary Control: 0.0 MMscf/yr
Waste Gas Combusted:
Still Vent Primary Control: 15.2 MMscf/yr
Still Vent Secondary Control: 0.0 MMscf/yr
Wet Gas Processed:
Flash Tank Primary Control: 7,300.0 MMscf/yr
Flash Tank Secondary Control: 0.0 MMscf/yr
Waste Gas Combusted:
Flash Tank Primary Control: 2.4 MMscr/yr
Flash Tank Secondary Control: 0.0 MMscf/yr
Glycol Dehydrator Emissions Inventory
Emission Facto
Section 05 - Emissions Inventor(
Dld operator request a buffer?
Requested Buffer (96):
Pollutant
Benzene
Toluene
Ethylbenze
Xylene
n -Hexane
Pollutant
Pollutant
Glycol Dehydrator
Uncontrolled
(Wet Gas
Throughpulj
Controlled
(Ib/MMscf) Emission Factor Source
(Wet Gas Throughput)
3.18E-02
1.19E-02
Flash Tank Primary Control Device
Uncontrolled
(Ib/MMBtu)
(Waste Heat
Combusted)
ECD Pilo
Uncontrolled
lib/MMEtu)
(Waste Heat
Combusted(
Uncontrolled
(Ib/MMsef) Emission Factor Source
(Waste Gas
Combusted)
10.6854
Uncontrolled
)Ib/MMscf)
(Waste Gas
Combusted(
9.4478
0.7459
Emission Factor Source
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)
PM10
PM2.5
5Ox
NOX
CO
VOC
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
0.2
0.2
0.2
0.24
0.24
1.1
1.1
1.1
1.08
1.08
88.4
88.4
4.4
88.39
4.42
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
Ohs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Umits
Uncontrolled Controlled
(Ibs/year) (Nos/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224TMP
16,818
16,818
841
16,818
841
16,541
16,541
827
16,541
827
4.646
4,646
232
4,646
232
10,674
10,674
534
10,674
534
1,732
1,732
87
1,732
87
-
-
-
-
-
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Section XVII.B,D
Regulation 7, Section XV11.8.2.0
Regulation 7, Section XII.H
Regulation 8, Part E, MAC' Subpart HH (Area)
Regulation 8, Part E, MAR Subpart HA (Major)
Regulation 8, Part E, MACE Subpart HHH
(See regulatory appllrabllity worksheet for detailed analysis)
Source requires a permit
Dehydrator is subject to Regulation 7, Section XVII, 8, 0.3
The control device for this deh drator Is not subject to Regulation 7, Section XVO.B.2.e
Dehydrator Is subject to Regulation 7, Section XII.H
The dehy unit meetsthe benzene exemption
You have indicated that this facility is not subject to Major Source requirements of MAR Hit
You have indicated that Iris facility is not subject to MAC( HHH.
Requested Permit Limits
Uncontrolled Controlled
(lb/month) (lb/month)
4.4
4.4
4.4
4.4
0.3
0.3
40.4
40.4
184.0
184.0
15014.5
750.7
Glycol Dehydrator Emissions Inventory
sls N des
he still vent waste gas is processed througha l,qu Ict knockout vessel to remove execs
enelsslyn s099%Yi directed to the ECO. The calculations above use raw data (i.e. pre-kno
" scf/inns higherwith the incigs'"on of water cite. the HHV on a bt / cf9, is
Section 07 - Initial and Periodic Sampling and Testing Requirements
Was the extended wet gas sample used in the GlyCalemodel/Process model site -specific and collected within a year
of application submittal? ..
If no, the permit will contain an "Initial Compliance" testing requirement to demonstrate compliance with emission limits
Does the company request a control device effidency greater than 95%for e 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
Seri 00
rata this de
AIRS Point 0
001
te-specific sample was
Section 09 - Inventory SCC Coding and Emissions Factors
table at time of appliratioR: Therefore;
bastion owlssions from both dehydrators covered under Point 001 and: Point 002 Emissions from each dehyaror are rnntedtoa oateton' noosed
m'mfiut< aofpilotg swhi<htsoelyr preseytcd on the analysisfor Pant 001. 'Since emssionsof too CO PM and$fhtarealih taw-A'fENrgpn
hop gntt.The sum of emirs ons # om Goth di0di.-ator is 0.41 p N0s and 1.88 tpy GO.
Process t SCC Code
01
combustion device: Tire emission
tingthrestjolds, Finn far the sail
Uncontrolled
Pollutant Emissions Factor Control % Units
PM10 0.007 0.0 b/MMscf
PM2.5 0.007 0.0 b/MMscf
5ox 0.001 0.0 b/MMscf
NOx 0.065 0.0 b/MMscf
VOC 24.2 95.0 b/MMscf
CO 0.297 0.0 b/MMscf
Benzene 2.304 95.0 b/MMscf
Toluene 2.266 95.0 b/MMscf
Ethylbenzene 0.636 95.0 b/MMscf
Xylene 1.462 95.0 b/MMscf
n -Hexane 0.237 95.0 b/MMscf
Dehydrator Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
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. 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)?
'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. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)?
'Source requires a permit
Colorado Regulation 7, Section XII.H
1. Is this glycol natural gas dehydrator located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Reg 7, Section XII.H.1 and 2)?
2. Is this glycol natural gas dehydrator located at an oil and gas exploration and production operation', natural gas compressor station, natural gas drip station or gas -processing plant (Reg 7 Section
3. Is the sum of actual uncontrolled emissions of VOC from any single dehydrator or group of dehydrators at a single stationary source equal to or greater than 15 tpy (Reg 7, Section XII.H.3.6)?
4. Are actual uncontrolled emissions of VOC from the individual glycol natural gas dehydrator equal to or greater than 1 tpy (Reg 7, Section XII.H.3.a)?
Dehydrator is subject to Regulation 7, Section XII.H
Source is in the Non -Attainment Area
Section XII.H — Emission Reductions from glycol natural gas dehydrators
MACT Analysis
1. Is the dehydrator 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 liquids' (63.760(a)(2)); OR
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
b. user' (63.760(a)(3))?
2. Is the dehydrator located at a facility that is a major source for HAPs?
IGe to MACT HH Area Source Requirement section to determine MACT HH applicability
40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities
Area Source Requirements
1. Is the dehydrator a triethylene glycol (TEG) dehydration unit (63.760(b)(2))?
Exemptions -
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.764(e)(1)(I)?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit procass vent to the atmosphere less than 1,984.2 lb/yr (63.764(e)(1)(ii)?
3. Is the unit located inside of a UA plus offset and UC boundary area?
The dehy unit meets the benzene exemption
Subpart A, General provisions per §63.764 (a) Table 2
§63.765 - Emissions Control Standards Do Not Apply
§63.773 - Monitoring Standards Do Not Apply
§63.774 - Recordkeeping
§63.775 - Reporting Standards Do Not Apply
Yes
Yes
Yes
Yes
Major Source Requirements
1. Does the facility have a facility -wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility -wide actual annual average hydrocarbon liquid throughput less than 249.7
Small or Large Dehv Determination
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.761)?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.761)?
Small Dehv Requirements
3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.760(b)(1)(i)(B) and (C )?
4. For this small dehy, is a control device required to meet the BTEX emission limit given by the applicable equation?
'You have indicated that this facility is not subject to Major Source requirements of MACT HH.
Subpart A, General provisions per §63.764 (a) Table 2
§63.765 - Emissions Control Standards
§63.773 - Monitoring
§63.774 - Recordkeeping
§63.775 - Reporting
40 CFR, Part 63, Subpart MACT HHH, Natural Gas Transmission and Storage Facilities
1 Is the facility wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the only HAP emission source (63.1270(f))?
Small or Large Dehv Determination
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per day (63.1270(b)(2))?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.1270(b)(2))?
Small Dehv Requirements
3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.1270(b)(2) and (3) )?
4. For this small dehy, is a control device required to meet the BTEX emission limit (standard?) given by the applicable equation?
L
'You have indicated that this facility is not subject to MACE HHH.
Subpart A, General provisions per §63.1274 (a) Table 2
§63.1275 - Emissions Control Standards
§63.1281 -Control Equipment Standards
§63.1283 - Inspection and Monitoring
§63.1284 - Recordkeeping
§63.1285 - Reporting
Colorado Regulation 7, Section XVII.D
1. Is the dehydrator subject to an emissions control requirement under MACT HH or HHH (Regulation 7, Section XVII.B.5)?
2. Is this dehydrator located at a transmission/storage facility?
3. Is this dehydrator located at an oil and gas exploration and production operation , natural gas compressor station or gas processing plant (Reg 7, Section XVII.D.3)?
4. Was this glycol natural gas dehydrator constructed before May 1, 2015 (Reg 7 Section XVII.D.4.b)?
If constructed prior to May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 6 tons per year VOC or 2 tpy VOC if the
4a. dehydrator is located within 1,320 feet of a building unit or designated outside activity area (Reg 7, Section XVII.D.4.b)?
5. If constructed an or after May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 2 tpy VOC (Regulation 7, Section XVII.D.4.a)?
IDehydrator is subject to Regulation 7, Section XVII, B, O.3
Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.D.3 - Emissions Reduction Provisions
Alternative Emissions Control (Optional Section'
6. Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
IThe control device for this dehydrator 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
No
Yes
Glycol Dehydrator Emissions Inventory
Section 01 -Administrative Information
(Facility AIRS ID:
Plant Point
Section 02- Equipment Description Details
Dehydrator Information
Dehydrator Type:
Make:
Model:
Serial Number:
Design Capacity:
Recirculation Pump Information
Number of Pumps
Pump Type
Make:
Model:
Design/Max Recirculation Rate:
Dehydrator Equipment
Flash Tank
Reboiler Burner
Stripping Gas
Dehydrator Equipment Description
Emission Control Device Description:
MMscf/day
gallons/minute
'lash tank,
nd reb1r burner
One (1) Triethyiene glycol (TEG) natural gas dehydration unit (Make: TOD, Model: TBD, Serial Number: TBD) with a design
• capacity of 20 MMscf per day. This emissions unit is equipped with one (1) (Make: TOD, Model: TBD) electric driven glycol
pump with a design capacity of 3.5 gallons per minute. This dehydration unit is equipped with a still vent, flash tank, and
reboiler burner.
Emissions from the still vent are routed to a liquids knockout vessel, and then to the Enclosed Flare. Emissions from the flash
tank are routed to the liquids knockout vessel and then to the Enclosed Flare.
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emlsslons- Dehydrator Still Vent end Fland FlashT k (if p t)
" ll a MMscfper year
Requested Permit Limit Throughput- jll net.,.,,,,,;„„t��„p
Potential to Emit (PIE) Throughput = 7,300.0 MMscf per year
Secondary Emissions - Combustion Devices) for Alr Pollution Control
Still Vent Control
Condenser/liquids knockout:
Condenser emission reduction claimed:
Primary control device:
Primary control device operation:
Secondary control device:
Secondary control device operation:
Still Vent Gm Heating Value:
Still Vent Waste Gas Vent Rate:
Flash tank Control
Primary control device:
Primary control device operation:
Secondary control device:
Secondary control device operation:
Flash Tank Gas Heating Value
Flash Tank Waste Gas Vent Rate:
FV
Secondary Emissions -Combustor Fuel Emissions
Pilot Fuel Flow
Pilot HHV
TOTAL PILOT FUEL
Section 04 - Emissions Factors & Methodologies
hr/Yr
1,434.10 Btu/scf
272.0 sclh
1000
120
Control Efficiency %
Control Efficiency%
OAO'. scih Pilot emissions ar
0 btu/scF ecmbustar.
C.J MMscf/y:
degF
gpm
MMscf.per month
Wet Gas Processed:
Still Vent Primary Control: 7,300.0 MMscf/yr
Still Vent Secondary Control: 0.0 MMscf/yr
Waste Gas Combusted:
Still Vent Primary Control: 15.2 MMscf/yr
Still Vent Secondary Control: 0.0 MMscf/yr
Wet Gas Processed:
Flash Tank Primary Control: 7,300.0 MMsci/yr
Flash Tank Secondary Control: 0.0 MMscf/yr
Waste Gas Combusted:
Flash Tank Primary Control: 2.4 MMsct/yr
Flash Tank Secondary Control: 0.0 MMscf/yr
ported with Point CO1 Pomt 001 and 002 share a common
STILLVENT
Control Scenario
Primary
Secondary
Pollutant
Uncontrolled (1b/hr)
Controlled (Ib/hr)
Controlled (Ih/hr)
VOC
9.9834
0.49917
0
Benzene
1:5627
0.093135
0
Toluene
......1:8509 :'.
0.092545
0
Ethylbenzene
0.5242
0.02621
0
Xylenes
%%1:ZOB8 /�:'.
0.06044
0
n -Hexane
51119.11149Prfita1
0.005245
0
224-TMP
1 i1i 0 �,.. ,,.
0
0
FLASH TANK
Control Scenario
Primary
Secondary
Pollutant
Uncontrolled (Ib/hr)
Controlled (lb/hr)
Controlled (lb/hr)
VOC
1Q1974
0.509971096
0
Benzene
0:0572
0.00266
0
Toluene
0.0073
0.001065
0
Ethylbenzene
0:0062
0.00001
0
Xylenes
0.0097
0.000465
0
n -Hexane
00928
0.00464
0
224-TMP
:0
0
0
Glycol Dehydrator Emissions Inventory
SectIan 05 - Emissions Inventory
Did operator request a buffer?
Requested Buffer (%):
PM10
PM2.5
SOx
NOx
CO
Pollutant
PM10
PM2.5
500
Pollutant
Pollutant
PM10
PM2.5
SOx
NOx
CO
0,64
1.46
0.24
0.00
1.13E-01
3.18E-02
7.31E-02
1.19E-02
0.00E+00
Still Vent Primary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/MMscf)
(Waste Heat (Waste Gas
Combusted) Combusted)
0:0075 0.8415
0:0075 0.8415
0.0006 0.0664
0.0680 7.6797
0.3100 ';;[: 35.0104
Still Vent Secondary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) (Ib/MMscf),
(Waste Heat (Waste Gas
Combusted) Combusted(
0.0000
0.0000
0.0000
0.0000
Flash Tank Primary Control Device
Uncontrolled Uncontrolled
(lb/MMBtu) (lb/MMscf)
(Waste Heat (Waste Gas
Combusted) Combusted),
0.0075 10,6854
10,6854
0.0006 0.8436
97.5187
0,3100 444.5704
Flash Tank Secondary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) (Ib/MMscf)
(Waste Heat (Waste Gas
Combusted) Combusted)
ECU Pilot
Uncontrolled
(Ib/MM Btu)
(Waste Heat
Combusted)
0,0075
0-:0006
0.0680:.
6.3100.. .,APP
0.0000
0.0000
0.0000
Uncontrolled
(Ib/MMsct)
(Waste Gas
Combusted)
0.0000
0.0000
0.0000
0.0000
0.0000
Emission Factor Source
Emission Factor Source
Emission Factor Source
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Umits
Uncontrolled Controlled
(tons/year) (tons/year)
PM10
PM2.5
SOx
NOx
CO
VOC
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
0.2
0.2
0.2
0.17
0.17
0.8
0.8
0.8
0,80
0.80
88.4
88.4
4.4
88.39
4.42
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year(
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylem
n -Hexane
224TMP
16,818
16,818
841
16,818
841
16,541
16,541
827
. 16,541
827
4,646
4,646
232
4,646
232
10,674
10,674
534
10,674
534
1,732
1,232
87
1,732
87
Section 06 - Regulatory Sommery Analysis
Regulation 3, Parts A, B
Regulation 7, Section XVII.B,D
Regulation 7, Section )0/11.3.2.0
Regulation 7, Section XII.H
Regulation 8, Part E, MACTSubpart HH (Area)
Regulation 8, Part E, MACT Subpart HH (Major)
Regulation 8, Part E, MACT Subpart HHH
(See regulatory applicability worksheet far detailed analysis)
Source requires a permIt
Dehydrator is subject to Regulation 7, Section XVII, 1,113
The control device for this dehydrator is not subject to Regulation 7, Section XVIi.R.2.e
Dehydrator Is subject to Regulation 7, Section 111.6
The deity unit meets the benzene exemption
You have indicated that this facility is not subject to Major Source requirements of MALT HH,
You have indicated that this facility is not subject to MACI HHH.
Requested Permit Limits
Uncontrolled Controlled
(lb/month) (lb/month)
ma
9,3
03
3.3
13
0,3
29.7
29.7
135.3
135,3
15014.5
750.7
Glycol Dehydrator Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Was the extended wet gas sample used in the GlyCalc model/Process model site -specific and collected within a year
of application submittal?
If no, the permit will contain an "Initial Compliance" testing requirement to demonstrate compliance with emission limits
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
Sects •• 08 T, h i I A I SIs N i s
as notbegun open
re this dehydrator
e gas is processed througha liquid knock°,
earn directed Co the HCD. The calculations a
ohvstgf (iln thef-fl-tV on a btu/sc
Soares calculated secondary comb ustton emissions from bothdehydfat r c d under Pont 601 and e
NOx and CO nclude emissions fromthe combust on ofplot g as which is only represented on the analysis ft
pollutants Will not be included in theparrnd. The sum of emissions from both dehydrators is 0.41 tpy0
AIRS Point if
001
Process # SCC Code
01
Section 09 - inventory SCC Coding and Emissions Factors
rates applicant has calculated
e eEf4Oeand -CO omissionsly
3inee:Water is;0 bt0/set'
nPoCelnlvslnn
mbu.ti n de., Tho em.siens of
ortog thresholds-, limits for the sad
Uncontrolled
Pollutant Emissions Factor
PM10 0.005
PM2.5 0.005
SOx 0.000
N0x 0.048
VOC 24.2
CO 0.218
Benzene 2.304
Toluene 2.266
Ethylbenzene 0.636
Xylene 1.462
n -Hexane 0.237
Control % Units
0.0 b/MMscf
0.0 b/MMscf
0.0 b/MMscf
0.0 b/MMscf
95.0 b/MMscf
0.0 b/MMscf
95.0 b/MMscf
95.0 b/MMscf
95.0 b/MMscf
95.0 b/MMscf
95.0 b/MMscf
Dehydrator Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
'Source 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. 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)?.
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. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)?
(Source requires a permit
Colorado Regulation 7, Section XII.H
1: Is this glycol natural gas dehydrator located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Reg 7, Section XII.H.1 and 2)?
2. Is this glycol natural gas dehydrator located at an oil and gas exploration and production operation', natural gas compressor station, natural gas drip station or gas -processing plant (Reg 7 Section
3. Is the sum of actual uncontrolled emissions of VOC from any single dehydrator or group of dehydrators at a single stationary source equal to or greater than 15 tpy (Reg 7, Section XII.H.3.b)?'
4. Are actual uncontrolled emissions of VOC from the individual glycol naturalgas dehydrator equal to orgreater than 1 tpy ? f g Y Y q (Reg 7, Section XILH.3.a).
'Dehydrator is subject to Regulation 7, Section XII.H
Section XII.H — Emission Reductions from glycol natural gas dehydrators
MACT Analysis
1. Is the dehydrator 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 liquids' (63.760(a)(2)); OR
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
b. user' (63.760(a)(3))?
2. Is the dehydrator located at a facility that is a major source for HAPs?
Go to MACT HH Area Source Requirement section to determine MACT HH applicability
40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities
Area Source Requirements
1. Is the dehydrator a triethylene glycol (TEG) dehydration unit (63.760(b)(2))?
Exemptions -
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.764(e)(1)(i)?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.764(e)(1)(ii)?
3. Is the unit located inside of a UA plus offset and UC boundary area? J
The deity unit meets the benzene exemp
Subpart A, General provisions per §63.764 (a) Table 2
§63.765 - Emissions Control Standards Do Not Apply
§63.773 - Monitoring Standards Do Not Apply
§63.774 - Recordkeeping
§63.775 - Reporting Standards Do Not Apply
Yes
Yes
Yes
Yes
Major Source Requirements
1. Does the facility have a facility -wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility -wide actual annual average hydrocarbon liquid throughput less than 249.7
Small or Large Dehv Determination
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.761)?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.761)?
Small Dehv Requirements
3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.760(b)(1)(i)(B) and (C )?
4. For this small dehy, is a control device required to meet the BTEX emission limit given by the applicable equation?
IYou have indicated that this facility is not subject to Major Source requirements of MACT HH.
Subpart A, General provisions per §63.764 (a) Table 2
§63.765 - Emissions Control Standards
§63.773 - Monitoring
§63.774- Recordkeeping
§63.775 - Reporting
40 CFR, Part 63, Subpart MACT HHH, Natural Gas Transmission and Storage Facilities
1 Is the facility wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the only HAP emission source (63.1270(f))?
Small or Large Dehv Determination
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per day (63.1270(b)(2))?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.1270(b)(2))?
Small Dehv Requirements
3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.1270(b)(2) and (3) )?
4. For this small dehy, is a control device required to meet the BTEX emission limit (standard?) given by the applicable equation?
IYou have indicated that this facility is not subject to MACT HHH.
Subpart A, General provisions per §63.1274 (a) Table 2
§63.1275 - Emissions Control Standards
§63.1281 -Control Equipment Standards
§63.1283 - Inspection and Monitoring
§63.1284 - Recordkeeping
§63.1285 - Reporting
Colorado Regulation 7, Section XVII.D
1. Is the dehydrator subject to an emissions control requirement under MACT HH or HHH (Regulation 7, Section XVII.B.5)?
2. Is this dehydrator located at a transmission/storage facility?
3. Is this dehydrator located at an oil and gas exploration and production operation , natural gas compressor station or gas processing plant (Reg 7, Section XVII.D.3)?
4. Was this glycol natural gas dehydrator constructed before May 1, 2015 (Reg 7 Section XVII.D.4.b)?
If constructed prior to May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 6 tons per year VOC or 2 tpy VOC if the
4a. dehydrator is located within 1,320 feet of a building unit or designated outside activity area (Reg 7, Section XVII.D.4.b)?
5. If constructed on or after May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 2 tpy VOC (Regulation 7, Section XVII.D.4.a)?
IDehydrator is subject to Regulation 7, Section XVII, B, D.3
Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.D.3 - Emissions Reduction Provisions
Alternative Emissions Control (Optional Section)
6. Is this glycol natural gas dehydrator 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 dehydrator is not subject to Regulation 7, Section XVII.B.2.e
Section XVI I.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
No
Yes
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Cureton Front Range LLC
123
A006
Black Creek
History File Edit Date I 2/14/2019
Ozone Status Non -Attainment
r year
..l —....___.__ __-__ _-_. __. _
JIUa- IIUl Ullcu tuna pc. ycr_
M CL7IVVV1 an
POINT
AIRS
ID
PERMIT
Description
PM1D
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
New Facility - No Previous Total
Previous FACILITY TOTAL
Previous
Permitted Facility
total
DehydratorTEG1
0.2
88.2
1.1
25.2
0.2
4.5
1.1
1.3
NewCP
001
18WE1154
TEG
TEG Dehydrator TEG2
0.2
88.2
0.8
25.2
0.2
4.5
0.8
1.3
New CP
002
18WE1154
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
0.0
0.0
FACILITY
TOTAL
0.0
0.0
0.0
0.0
0.4
176.4
0.0
1.9
50.4
0.0
0.0
0.0
0.0
0.4
9.0
0.0
1.9
2.5
VOC: Syn Minor (NANSR and OP)
NOx: Minor (NANSR and OP)
CO: Minor (PSD and OP)
HAPS: Syn Minor B,T,X, Total HAP
HH: affected area source
7777: Area Source
0.0
0.0
0.0
0.0
0.4
176.4
0.0
1.9
50.4
0.0
0.0
0.0
0.0
0.4
9.0
0.0
1.9
2.5
Excludes units exempt from permits/APENs
Permitted Facility Total
(5) Change in Permitted Emissions
0.0
0.0
0.0
0.0
0.4
9.0
0.0
1.9
PubCom will be completed since 18WE1071
contains new synthetic minor limits
Note 1
Total VOC Facility Emissions (point and fugitive)
(5) Change in Total Permitted VOC emissions (point and fugitive)
9.0
Facility is eligible for GP02 because < 9D tpy
Project emissions less than 25 tpy
9.0
Point 001 and 002
share a common combustor. Emissions
from combustion of pilot are included with Point 001 (row 10).
Note 2
Printed 3/25/2019
Page 14 of 16
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Cureton Front Range LLC
County AIRS ID 123
Plant AIRS ID A006
Facility Name Black Creek
Emissions - un
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
'Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
18WE1154
TEG Dehydrator TEG1
16818
16541
4646
10674
1732
25.2
002
18WE1154
TEG Dehydrator TEG2
16818
16541
4646
10674
1732
25.2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
TOTALi(tpy)
0.0
0.0
0.0
16.8
16.5
4.6
10.7
1.7
0.0
0.0
0.0
0.0
50.4
— all HAPs where uncontrolled emisslons > de minlmus values
Red Text: uncontrolled emissions < de minimus
15
18WE1154.CP1.xlsm 3/25/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Cureton Front Range LLC
County AIRS ID 123
Plant AIRS ID A006
Facility Name Black Creek
CIIIIb IUIIb W[LII ',VIM t.ri ‘.va r/�. row.,
TOTAL
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
(tpy)
TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
Previous
FACILITY
TEG Dehydrator TEG1
841
827
232
534
87
1.3
001
18WE1154
TEG Dehydrator TEG2
841
827
232
534
87
1.3
002
18WE1154
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
0.8
0.8
0.2
0.5
0.1
0.0
0.0
0.0
0.0
2.5
TOTAL (tpy)
16
18WE1154.CP1.xlsm 3/25/2019
Permit number:
Date issued:
Issued to:
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
CONSTRUCTION PERMIT
18WE 1154 Issuance: 1
Cureton Front Range, LLC
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Black Creek Compressor Station
123/A006
SWSW SEC 4 T3N R62W
Weld County
Natural Gas Compressor Station
Equipment or activity subject to this permit:
Facility
Equipment ID
AIRS
Point
Equipment Description
Emissions Control
Description
TEG1
001
One (1) Triethylene glycol (TEG) natural gas
dehydration unit (Make: TBD, Model: TBD, Serial
Number: TBD) with a design capacity of 20
MMscf per day. This emissions unit is equipped
with one (1) (Make: TBD, Model: TBD) electric
driven glycol pump with a design capacity of 3.5
gallons per minute. This dehydration unit is
equipped with a still vent, flash tank, and
reboiler burner.
Emissions from the still
vent and flash tank are
routed to a liquid knock
out vessel and then to
an enclosed flare.
TEG2
002
One (1) Triethylene glycol (TEG) natural gas
dehydration unit (Make: TBD, Model: TBD, Serial
Number: TBD) with a design capacity of 20
MMscf per day. This emissions unit is equipped
with one (1) (Make: TBD, Model: TBD) electric
driven glycol pump with a design capacity of 3.5
gallons per minute. This dehydration unit is
equipped with a still vent, flash tank, and
reboiler burner.
Emissions from the still
vent and flash tank are
routed to a liquid knock
out vessel and then to
an enclosed flare.
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.
COLORADO
Air Pollution Control Division
Page 1 of 11
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/pacific/cdphe/other-air-permitting-
notices. 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 1€i `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•oieradci.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III G.Z )
f :
�r.
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 orrthe date on which such
construction or activity was scheduled td Commence as\ set forth in the permit application
associated with this permit; (ii) discontinues construction fora period of eighteen months or
more; (iii) does not complete construction within areasonable time of the estimated completion
date. The Division may grant extensions of the deadline. '(Regulation Number j, Part B, Section
III.F.4.)
4. The operator shall complete all initial compliance testingand 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 TILE.)
5. Points 001, 002:The following tion informashall be prow ded, to the Division within fifteen (15)
days of the latter of commencement of operation or issuance of this permit.
• The dehydrator manufacturer name, model number and serial number
ycol circulation pump manufacturer name and model number
This information shall be •Included with the Notice of Startup submitted for the equipment.
I.E )
6. The Operator shall retain;, the permit final authorization letter issued by the Division, after
=(Reference: Regulation Number 3, Part B, II
completion of self -certification, with'the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
•
EMISSION LIMITATIONS AND RECORDS
7. Emissions of ai-iipbilytantEchall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
)
Monthly Limits:
Facility
Equipment ID
AIRS Point
Pounds per Month
Emission
Type
PM2.5
NO,
VOC
CO
TEG1
001
--
---
751
---
Point
TEG2
002
---
---
751
---
Point
Note: Monthly limits are based on a 31 -day month.
The owner or operator shall calculate monthly emissions based on the calendar month.
COLORADO
Air Pollution Control Division
Depr:rt°*x*x of pals„. He,,;a1 v Ermror:me:t
Page 2 of 11
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 1,359 pounds
per month.
Facility -wide emissions of total hazardous air pollutants shall not exceed 3,398 pounds per
month.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Annual Limits:
Facility
Equipment ID
AIRS Point
Tons per Year
PM2.5
NO,
V0C
CO
Emission
Type
TEG1
001
4.5
Point
TEG2
002
4.5
Point
Note: See "Notes to Permit Holder" for informati
limits.
on emission
act
s and methods used to calculate
Facility -wide emissions of each individual hazardous air pollutant shall, not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
During the first twelve (12) months of operation, compliance with both the monthly and annual
emission limitations is required. After the first twelve (12) months of operation, compliance with
only the annual limitation is required.
Compliance with the annual limits, for criteria and hazardous air pollutants, shall be determined
on a rolling twelve (12) month total. By the end of each month a new twelve month total is
calculated based on the previous twelve months' data. The permit holder shall calculate actual
emissions each month and keep a; compliance record on site or at a local field office with site
responsibility for Division review.
8. Points 001: Compliance with the emission limits in this permit shall be demonstrated by running
the'GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent extended
wetgas analysis and recorded operational values, including: dry gas throughput, lean glycol
recirculation rate, flash tank temperature and pressure, wet gas inlet temperature, and wet gas
inlet pressure. Recorded operational values, except for gas throughput, shall be averaged on a
monthly basis for input into the model and be provided to the Division upon request.
9. Points 002: Compliance with the emission limits in this permit shall be demonstrated by running
the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent extended
wet gas analysis and recorded operational values, including: dry gas throughput, lean glycol
recirculation rate, flash tank temperature and pressure, wet gas inlet temperature, and wet gas
inlet pressure. Recorded operational values, except for gas throughput, shall be averaged on a
monthly basis for input into the model and be provided to the Division upon request.
10. Points 001, 002: On a monthly basis, the owner or operator shall monitor and record operational
values including: flash tank temperature and pressure for each flash tank, wet gas inlet
temperature and pressure. These records shall be maintained for a period of five years.
11. The owner or operator shall operate and maintain the emission points in the table below with
the emissions control equipment as listed in order to reduce emissions to less than or equal to
the limits established in this permit. The owner or operator shall operate this dehydration unit
so as to prevent any emissions directly to the atmosphere. (Regulation Number 3, Part B, Section
III.E.)
COLORADO
Air Pollution Control Division
He ;c.: ErtiRorirAe^;c
Page 3 of 11
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
TEG1
001
Still Vent: Enclosed Flare
VOC and
HAP
Flash Tank: Enclosed Flare
TEG2
002
Still Vent: Enclosed Flare
VOC and
HAP
Flash Tank: Enclosed Flare
PROCESS LIMITATIONS AND RECORDS
12. 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 Nutil er 3, Part B, II.A.4.)
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Monthly Limit
(31 days)
TEG1
001
DryGas Throughput
7,300 MMscf
620 MMscf
TEG2
Dry Gas Througle
7,300 MMscf
620 MMscf
The owner or operator shalt -monitor monthlyyprocess rates based on the calendar month. The
volume of dry gas throughput shall be measured by gas meter at the outlet of the dehydrator.
During the first tw( required.
12) months; of operation, compliance with both the monthly and annual
throughput limitations is " After Ahe first twelve (12) months of operation, compliance
with'only the annual_limitaon is required'.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total " :By the end of each month anew 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 orat a local field office with site responsibility, for Division review.
13. Points 001 This;,unit shall l:t'j limited to the maximum lean glycol circulation rate of 3.5 gallons
per minute. The lean glycol recirculation rate shall be recorded weekly in a log maintained on
site and made available to the Division for inspection upon request. Glycol recirculation rate
shall be monitored by oneof the following methods: assuming maximum design pump rate, using
glycol flow meter(s), or recording strokes per minute and converting to circulation rate. This
maximum glycol circulation rate does not preclude compliance with the optimal glycol circulation
rate (Loot) provisions under MACT HH. (Reference: Regulation Number 3, Part B, II.A.4)
14. Points 002: This unit shall be limited to the maximum lean glycol circulation rate of 3.5 gallons
per minute. The lean glycol recirculation rate shall be recorded weekly in a log maintained on
site and made available to the Division for inspection upon request. Glycol recirculation rate
shall be monitored by one of the following methods: assuming maximum design pump rate, using
glycol flow meter(s), or recording strokes per minute and converting to circulation rate. This
maximum glycol circulation rate does not preclude compliance with the optimal glycol circulation
rate (Lops) provisions under MACT HH. (Reference: Regulation Number 3, Part B, II.A.4)
!COLORADO
z Air Pollution Control Division
t*po[7'aerrt vseeiri, G E:'^rirnrr= e t
Page 4 of 11
STATE AND FEDERAL REGULATORY REQUIREMENTS
15. Points 001, 002: 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)
16. Points 001, 002: This source is subject to the odor requirements of Regulation Number 2. (State
only enforceable)
17. Points 001, 002: This source is subject to Regulation Number 7, Section XII.H. The operator shalt
comply with all applicable requirements of Section XII and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for glycol natural gas dehydrators; and
• Ensure uncontrolled actual emissions of volatile organic compounds from the still vent
and vent from any gas -condensate -glycol (GCG) separator (flash separator or flash tank),
if present, shall be reduced by at least„90 "percent on a rolling twelve-month basis
through the use of a condenser or air pollution control; equipment. (Regulation Number
7, Section XII.H.1.)
18. Points 001, 002: 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 noffital 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 theenclosed 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 grater 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 f thecombustion 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.
19. Points 001, 002: The glycol dehydration unit covered by this permit is subject to the emission
control requirements in Regulation Number 7, Section XVII.D.3. Beginning May 1, 2015, still vents
and vents from any Mash separator or flash tank on a glycol natural gas dehydrator located at an
oil and gas exploration and <droduction operation, natural gas compressor station, or gas -
processing plant subject:4o control requirements pursuant to Section XVII.D.4., shall reduce
uncontrolled actual emissions of hydrocarbons by at least 95% on a rolling twelve-month basis
through'the use of a condenser or air pollution control equipment.
20. Points 001, 002: The glycol dehydration units at this facility are subject to National Emissions
Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production
Facilities, Subpart Hl. This facility shall be subject to applicable area source provisions of this
regulation, as stated in AO C.F.R Part 63, Subpart A and HH. (Regulation Number 8, Part E,
Subpart A and HH)
COLORADO
Air Pollution Control Division
•G?:r xn t I }�cd+ii HWY,.& Erriw rr ert
Page 5 of 11
MACT HH Applicable
Requirements
Area Source
Benzene emissions exemption
563.764 - General
Standards
§63.772 - Test
Methods, Compliance
Procedures and
Compliance
Demonstration
§63.774 -
Recordkeeping
Requirements
563.764 (e)(1) - The owner or operator is exempt from the requirements of
paragraph (d) of this section if the criteria listed in paragraph (e)(1)(i) or (ii)
of this section are met, except that the records of the determination of
these criteria must be maintained as required in §63.774(d)(1).
§63.764 (e)(1)(ii) - The actual average emissions of benzene from the glycol
dehydration unit process vent to the atmosphere are less than 0.90
megagram per year, as determined by the procedures specified in
§63.772(b)(2) of this subpart.
563.772(b) - Determination of glycol dehydration unit flowrate or benzene
emissions. The procedures of this paragraph shall be used by an owner or
operator to determine glycol dehydration unit natural gas flowrate or
benzene emissions to meet the criteria for an exemption from control
requirements under §63.764(e)(1) ,
563.772(b)(2) - The determination of actual average benzene emissions
from
a glycol dehydration unit shall be made using the procedures of either
paragraph
(b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be determined
either uncontrolled, or ' with federally enforceable controls in place.
563.772(b)(2)(i) - The own ,or operator; shall determine actual average
benzene emissions using the model. GRI-GLYCalc TM, Version"0 or higher,
and the procedures presented in the hail
GRI GLYCalc T"^Technical
Reference ManualInputs to the model, shall be representative of actual
operating conditions"of,the glycol dehydration unit and may be determined
using the procedures documented in the GasResearch Institute (GRI) report
entitled "Atmospheric Ruh/LeanMethod forrDetermining Glycol Dehydrator
missic ns" (GRI-95/0368 1); or
563.772(b)(2)(ii) - Theowtner or operator shall determine an average mass
rate of benzene emissions in kilograms per hour through direct measurement
using the methods in §63.772(a)(1)(i) or (ii), or an alternative method
according to 563.7(f), Annual emissions in kilograms per year shall be
determined by multiplying the mass rate by the number of hours the unit is
operated, per year. This result shall be converted to megagrams per year.
563.774 (d)(1) - An owner or operator of a glycol dehydration unit that
meets the exemption criteria in 663.764(e)(1)(i) or §63.764(e)(1)(ii) shall
maintain the records specified in paragraph (d)(1)(i) or paragraph (d)(1)(ii)
of thissection, as appropriate, for that glycol dehydration unit.
§63 774' (d)(1)(ii) - The actual average benzene emissions (in terms of
benzene emissions per year) as determined in accordance with
=§63.772(b)(2).
OPERATING Et MAINTENANCE REQUIREMENTS
21. Points 001, 002: Upon startup of these points, the owner or operator shall follow the most
recent operating and maintenance (OEM) 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.)
'COLORADO
Air Pollution Control Division
tiviii;i"#_".'i Pbitiic l eit tiY
Page 6 of 11
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
22. Points 001, 002: 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)
23. Points 001, 002: The owner or operator shall complete the initial extended wet gas analysis
within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit. The owner or operator shall use this analysis to calculate actual emissions, as
prescribed in the Emission Limitation and Records section of this permit, to verify initial
compliance with the emission limits. The owner or operator shall submit the analysis and the
emission calculation results to the Division as part of the self -certification process. (Reference:
Regulation Number 3, Part B, Section III.E.)
Periodic Testing Requirements
24. Points 001, 002: The owner or operator shall complete an extended wet gas analysis prior to
the inlet of the dehydration unit on an annual basis. Results of the wet gas analysis shall be used
to calculate emissions of criteria pollutants and hazardous air pollutants per this permit and be
provided to the Division upon request.
ADDITIONAL REQUIREMENTS
25. 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:
s..
For sources emitting 'less than 100 tons per year, a, change in actual emissions of five
(5) tonsper 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,t per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, `above the level, reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted, or
For anyrnon-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.
26. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any
stationary source or modification becomes a major stationary source or major modification solely
COLORADO
Air Pollution Control Division
uVirtene,.t c -t P bfi lief.:#tn s E:*.iror;r>trr:t
Page 7 of 11
by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980,
on the capacity of the source or modification to otherwise emit a pollutant such as a restriction
on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B).
GENERAL TERMS AND CONDITIONS
27. 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.
28. 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 ource. 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, PartxB, 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 the permit. Once self certification of all
points has been reviewed and approved by the lvision, it will provide written documentation of
such final authorization. Details for obtaining final authorizations operate are located in the
Requirements to Self -Certify for Final Authorization section of this`permit.
29. 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 operators agents."it is valid only for
the equipment and operations or activityspecifically identified on the permit.
30. Unless specifically stated otherwise theeneal and specific conditions contained in this permit
have been determined by the APCDto be necessaCyto assure compliance with the provisions of
Section 25 7-114 5(7 {}tea), C.R.S.
31. Each and every condition of this permit:is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof;shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ob initio. This permit may be revoked
at any time Prior to`self certification and final authorization by the Air Pollution Control Division
(APCii) Fin rounds set forth theColorado Air Quality Control Act and regulations of the Air
Quality Control ommi• ssion {AQCC), including failure to meet any express term or condition of
the permit. If the Di ision 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: he AQCC for review of the Division's action.
32. Section Z5 -7-114.7(2)(a), 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.
ti.
33. • 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:
Bradley Eades
Permit Engineer
;COLORADO
Air Pollution Control Division
usp::rtraer\t Gs Pubt C 3ie 'rt to i-�vixorrnent.
Page 8 of 11
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Cureton Front Range, LLC
COLORADO
Air Pollution Control Division
^,..2p?<r • nt, (ea i! v Enrira,rnter;E
Page 9 of 11
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 it, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owneor'operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in;Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Benzene"
71432
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
TEG1
002
6, 818
841
Toluene
1E0888"3
16,541
827
Ethylbenzene
i/0414
4,646
232
Xylenes
30207
10,674
534
:Hexane,*
9,543
1,732
87
Benzene
,,.71432
16,818
841
Toluene
108883
16,541
827
Ethylbernzene
100414
4,646
232
Xylenes
1330207
10,674
534
-Hexane
110543
1,732
87
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on information provided in the application
and the GRI GlyCalc 4.0 model. Controlled emissions are based on a combustor 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.
COLORADO
Air Pollution Control Division
Jep?:rtment v;3' Ptsbi i"il'r3th s Fnviral rtef;t
Page 10 of 11
7) This permit fulfills the requirement to hold a valid permit reflecting the glycol dehydration unit and
associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(B)
when applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
VOC, benzene, toluene, xylenes, Total HAP
NANSR
Synthetic Minor Source of:
VOC
MACT HH
Major Source Requirements Not Applicable
Area Source Requirements AppLc ble
9) 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
pendix A - Appendixl
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A Subpar
MACT
63.600'63.1199
Subpart,
Subpart DD?
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
T
3_6580-63.883O
Subpart 2222'Subpart MMMMM
MACT
63.8980 -End
Subpart aNNNNN - Subpart XXXXXX
[COLORADO
Air Pollution Control Division
- partmeru of `rutai'c He d h erii: mu,nt
Page 11 of 11
tio3s�21118
Glycol Dehydration Unit APEN - Form APCD-202
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 Glycol Dehydration (Dehy) Units only. If your emission unit does not fall into this
category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is
available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can
be found on the Air Pollution Control Division (APCD) website at: www.colorado.aov/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:
.4-
AIRS ID Number:
;� <�
[Leave blank unless APCD has already assigned a permit 4 and AIRS ID]
Company equipment Identification: TEG1
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Namel: Cureton Front Range LLC
Site Name: Black Creek Compressor Station
Site Location: SWSW Sec. 4, R3N, T62W
Mailing Address:
(Include Zip Code) 518 17th Street, Suite 650
Denver, CO 80202
E -Mail Address2: nick.holland@curetonmidstrem.com
Site Location
County: Weld
NAICS or SIC Code: 211 111
Permit Contact: Nick Holland
Phone Number: 303-324-5967
1Please 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 APCD via e-mail to the address provided.
iJ l,v.1550
r-
Form APCD-202 - Glycol Dehydration Unit APEN - Revision 02/2017 1 I h'
COLORADO
awr,Ite fi Eta '. mmn art[
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit tt and AIRS ID]
Section 2- Requested Action
✓❑ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment O Change company name O Add point to existing permit
❑ Change permit limit O Transfer of ownership' O Other (describe below)
OR-
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 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:
20 MMSCFD TEG Dehydration unit equipped
with a Combustor for 95% control (design destruction efficiency of 98%)
Facility equipment Identification:
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
TEG 1
/ /
TBD / /
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS nonattainment
area
Is this unit located at a stationary source that is considered a
Major Source of (HAP) Emissions
days/week
Yes
Yes
Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 2 I
O
weeks/year
No
No
COLORADO
i/i�ir Oea,art etc
YwhN b Enuarrmmor:+
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit ft and AIRS ID]
Section 4 - Dehydration Unit Equipment Information
Manufacturer:
Dehydrator Serial
Number:
Glycol Used:
TBD Model Number: TBD
TBD
Ethylene Glycol
(EG)
Glycol Pump Drive: ✓❑ Electric O Gas
Pump Make and Model: TBD
Reboiler Rating: 0.5
❑ (DEG)
DiEthylene Glycol
If Gas, injection pump ratio:
Glycol Recirculation rate (gal/min):
Lean Glycol Water Content:
Max: 3.5
Wt.%
MMBTU/hr
r
TriEthylene Glycol
(TEG)
Requested: 3.5
Acfm/ gpm
ft of pumps: 1
Dehydrator Gas Throughput:
Design Capacity: 20 MMSCF/day
Requested: 7300 MMSCF/year Actual:
MMSCF/year
Inlet Gas:
Water Content: Wet Gas:
Flash Tank:
Cold Separator: Pressure:
Pressure: 1000
Pressure: 35
psig Temperature:
lb/MMSCF
psig
psig
Stripping Gas: (check one)
❑� None O Flash Gas O Dry Gas ❑ Nitrogen
Flow Rate:
scfm
❑✓ Saturated
Temperature:
Temperature:
120
Dry gas:
130
°F
7.0
°F
°F
lb/MMSCF
❑ NA
0 NA
Additional Required Information:
O Attach a Process Flow Diagram
❑✓ Attach GRI-GLYCaIc 4.0 Input Report Et Aggregate Report (or equivalent simulation report/test results)
❑� Attach the extended gas analysis (including BTEX li n -Hexane, temperature, and pressure)
Form APCD-202-Glycol Dehydration Unit APEN - Revision 02/2017
COLORADO
3 a°�M°tom
Hw11,En°u°:+O
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and MRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.24657,-104.33688
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp.
('F)
Flow Rate -
(ACFM)
Velocity
(ft/sec)
Combustor
12
1000
6935
9.2
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
❑r Upward
O Horizontal
Indicate the stack opening and size: (check one)
0 Upward with obstructing raincap
❑✓ Circular Interior stack diameter (inches): 48
0 Square/rectangle Interior stack width (inches): Interior stack depth (inches):
O Other (describe):
Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017
� COLORADO
4 o.Pst7
iaolry� b Erxrrgnennnt.
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
Used for control of:
O Condenser:
Type: Make/Model:
Maximum Temp Average Temp
Requested Control Efficiency %
O VRU:
Used for control of:
Size: Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed %
❑
Combustion
- Device:
Used for control of: VOC, HAPs
Rating: MMBtu/hr
Type: Combustor Make/Model: TBD
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
95
98
%
%
Minimum Temperature: NA Waste Gas Heat Content Btu/scf
Constant Pilot Light: 0 Yes O No Pilot burner Rating —0.21 MMBtu/hr
Closed
❑ Loop
System:
Used for control of:
Description:
System Downtime
O Other:
Used for control of:
Description:
Control Efficiency
Requested
Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017
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COLORADO
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Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes O No
D state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SO,
NO,
CO
VOC
Combustor
95%
HAPs
Combustor
95%
Other:
From what year is the following reported actual annual emissions data? 2018
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Emission
Factor -
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
-
Actual Annual Emissions
:= ,
Requested Annual Permit
Emission L_mits � 4
_
Uncontrolled
(Tons/year)
Controlled5
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SO,
NO,
CO
VOC
24.22
Ib/MMSCF
Glycalc
88.39
4.42
Benzene
2.30
Ib/MMSCF
Glycalc
8.41
0.42
Toluene
2.27
Ib/MMSCF
Glycalc
8.27
0.41
Ethylbenzene
0.64
Ib/MMSCF
Glycalc
2.32
0.12
Xylenes
1.46
Ib/MMSCF
Glycalc
5.34
0.27
n -Hexane
0.24
Ib/MMSCF
Glycalc
0.87
0.04
2,2,4-
Trimethylpentane
Other:
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-2O2 -Glycol Dehydration Unit APEN - Revision 02/2017
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4NI�N 6 Enaem:�mnni
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.
Ag/
ir
Signature/of Legally Authorized Person (not a vendor or consultant) / Date
Nick Holland Director of EHS&R
Name (please print) Title
Check the appropriate box to request a copy of the:
❑r Draft permit prior to issuance
El Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 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
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
COLORADO
Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 7 i
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Glycol Dehydration Unit APEN - Form APCD-202
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 Glycol Dehydration (Dehy) Units only. If your emission unit does not fall into this
category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is
available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can
be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
AIRS ID Number: '7/?7,/..a(,/ _( L ---
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: TEG2
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Cureton Front Range LLC
Site Name: Black Creek Compressor Station
Site Location: SWSW Sec. 4, R3N, T62W
Mailing Address:
(Include Zip Code) 518 17th Street, Suite 650
Denver, CO 80202
E -Mail Address2: nick.holland@curetonmidstrem.com
Site Location
County: Weld
NAICS or SIC Code: 211111
Permit Contact: Nick Holland
Phone Number: 303-324-5967
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-202 - Gtycot Dehydration Unit APEN - Revision 02/2017
223551
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Permit Number: AIRS ID Number:
[Leave blank unless APED has already assigned a permit # and AIRS ID]
Section 2- Requested Action
✓❑ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment 0 Change company name 0 Add point to existing permit
❑ Change permit limit 0 Transfer of ownership3 0 Other (describe below)
OR
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
ID Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes:
3 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:
20 MMSCFD TEG Dehydration unit equipped
with a Combustor for 95% control (design destruction efficiency of 98%)
Facility equipment Identification:
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
TEG2
/ /
TBD / /
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS nonattainment
area
Is this unit located at a stationary source that is considered a
Major Source of (HAP) Emissions
Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017
0
days/week
Yes
Yes
0
weeks/year
No
No
COLORADO
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Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Dehydration Unit Equipment Information
Manufacturer:
Dehydrator Serial
Number:
Glycol Used:
TBD
TBD
Ethylene Glycol
(EG)
Glycol Pump Drive: 0 Electric O Gas
Pump Make and Model: TBD
Model Number:
TBD
Reboiler Rating: 0.5
DiEthylene Glycol
(DEG)
If Gas, injection pump ratio:
MMBTU/hr
TriEthylene Glycol
(TEG)
# of pumps:
Glycol Recirculation rate (gal/min):
Lean Glycol Water Content:
Max: 3.5
Wt.%
Requested: 3.5
Acfm/gpm
1
Dehydrator Gas Throughput:
Design Capacity: 20
MMSCF/day
Requested: 7300 MMSCF/year Actual:
MMSCF/year
Inlet Gas:
Water Content: Wet Gas:
Flash Tank:
Cold Separator: Pressure:
Pressure: 1000
Pressure: 35
psig Temperature:
lb/MMSCF
psig
psig
Stripping Gas: (check one)
O None ❑ Flash Gas O Dry Gas ❑ Nitrogen
Flow Rate:
scfm
O Saturated
Temperature:
Temperature:
120
°F
Dry gas: 7.0 lb/MMSCF
130 ° F
°F
NA
NA
Additional Required Information:
O Attach a Process Flow Diagram
0 Attach GRI-GLYCalc 4.0 Input Report a Aggregate Report (or equivalent simulation report/test results)
Attach the extended gas analysis (including BTEX Ft n -Hexane, temperature, and pressure)
COLORADO
Form APCD-202-Gtycot Dehydration Unit APEN - Revision 02/2017 3 1 H`,,,r.„ °,NuNvnin.°
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Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and MRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.24657,-104.33688
OperatorTemp.
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
('F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Combustor
12
1000
6935
9.2
Indicate the direction of the stack outlet: (check one)
0 Upward
O Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
O Upward with obstructing raincap
❑✓ Circular Interior stack diameter (inches): 48
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑ Other (describe):
Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017
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COLORADO
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Permit Number:
AIRS ID Number: /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
O Condenser:
Used for control of:
Type: Make/Model:
Maximum Temp Average Temp
Requested Control Efficiency %
❑ VRU:
Used for control of:
Size: Make /Model:
Requested Control Efficiency %
VRU Downtime or Bypassed %
❑ Combustion
Device:
Used for control of: VOC, HAPs
Rating: MMBtu/hr
h r
Type: Combustor
Make/Model: TBD
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency 98
Minimum Temperature: NA Waste Gas Heat Content Btu/scf
Constant Pilot Light: Yes O No Pilot burner Rating —0.21 MMBtu/hr
Closed
❑ Loop
System:
Used for control of:
Description:
System Downtime
O Other:
Used for control of:
Description:
Control Efficiency
Requested
0
Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017
V COLORADO
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Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach alt emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes O No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SO,
NO,
CO
VOC
Combustor
95%
HAPs
Combustor
95%
Other:
From what year is the following reported actual annual emissions data? 2018
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
--
Actual Annual Emissions
Requested, Annual' Permit;,
Emission Limrt(s)4
Uncontrolled
(Tons/year)
Controlled5
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SO,
NO,,
CO
VOC
24.22
lb/MMSCF
Glycalc
88.39
4.42
Benzene
2.30
lb/MMSCF
Glycalc
8.41
0.42
Toluene
2.27
Ib/MMSCF
Glycalc
8.27
0.41
Ethytbenzene
0.64
Ib/MMSCF
Glycalc
2.32
0.12
Xylenes
1.46
lb/MMSCF
Glycalc
5.34
0.27
n -Hexane
0.24
lb/MMSCF
Glycalc
0.87
0.04
2,2,4-
Trimethylpentane
Other:
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017
COLORADO
6 pe:ofPuc
,:I, e ma.,,,
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.
Signature of Legally Authorized Person(not a vendor or consultant) / Da>'e
g g Y
Nick Holland
Director of EHS&R
Name (please print) Title
Check the appropriate box to request a copy of the:
E✓ Draft permit prior to issuance
0✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 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
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017
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