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Home My WebLink About20191148COLORADO Department of Public Health b 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 March 11, 2019 Dear Sir or Madam: RECEIVED MAR 202019 WELD COUNTY COMMISSIONERS On March 14, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Great Western Operating Company, LLC. - Raindance FD Pad. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 3125/Iq 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 rc.PLc-cc NLCiTS, PINI0MIERIcH IcK) 3I2oIiq 2019-1148 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Great Western Operating Company, LLC. - Raindance FD Pad - Weld County Notice Period Begins: March 14, 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: Great Western Operating Company, LLC. Facility: Raindance FD Pad Exploration Et Production Well Pad NESE S30 T6N R67W Weld County The proposed project or activity is as follows: This project is the construction of a new well pad facility. Because the gas pipeline capacity for the produced gas at this site is limited, the produced gas will be processed through a series of separators (Vaporcatches and Flareatchers) and will be combusted in an enclosed combustion device. The facility has requested coverage for 2-500 bbl condensate tanks under the GP08 application, hydrocarbon liquid loading under the GP07 application, 2- 500 bbl produced water tanks under the GP05 application and 5 -generators (4SRB RICE) under individual GP02 applications. The facility is synthetic minor for NOx, VOC's, and CO. 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 18WE0445 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: ,COLORADO Lauraleigh Lakocy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 2G js GO LORA DO +W1.A Mr Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: "Great WesternOperatTh foepany, LLC County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: NESE quadrant of Section 30, Township 6N, Range 67W County: Type of Facility: What industry segment? Is this facility located in -a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) (Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range 3NESE Particulate Matter (PM) El Ozone (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit it Issuance it Self Cert Required? Action Engineering Remarks ' X101. Se;aaraforVenttng Flareeatcher Yes 1$WE04d5 ftlM? F E Section 03 - Description of Project This p'r,-ojecttstheconstruct€o b#one+ through a series o#separat ©"r"s;(4Xap©rcat The facility has requested coverage for 2-500 hb[condensate tanks undi water.t>an'kis under the Gib application and S -generators (4SRB Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? pa ed gas v4- ill 2 504 bb[ produced and CO. Section 05 -Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No 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) 502 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants hers SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO 2 .7 VOC PM2.5 PM10 ❑ ❑ TSP HAPs ❑ ❑ Separator Venting Emissions Inventory 001 Separator Venting Facility AIRs ID: Coin Plant Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates €larecut plpe0n"e 5apa 10)#####001061111:,.„ Primary Emissions - Separator Actual Throughput= ` 81 MMscf per year Requested Permit Limit Throughput = -319,4 MMscf per year Requested Monthly Throughput= 27 MMscf per month Potential to Emit (PTE) Throughput = 319 MMscf per year Equipped with a VRU oimegovamili Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04- Emissions Factors & Methodologies Description The,enclasod cot thepipels`ner „,,t .;;.11311 Btu/scf Ib/Ib-mol Displacement Equation Ex=Q*MW*xx/C MW Weight % Helium CO2 Oxygen/Argon N2 methane ethane propane isttutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224 -TM P Benzene Toluene Ethylbenzene Xylenes C0* Heavies Total VOC Wt % 100.00 10.27 scf/bbl arecatcher. The uoi Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMsd) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 5654.4090 282.7205 Benzene Toluene 1.9820 1.3214 0.1652 1.3764 7.3225 0.7708 0.0991 0.0661 0.0083 0.0688 0.3661 0.0385 Ethylbenzene Xylene n -Hexane 224 TMP Emission Factor Source Emission Factor Source Pollutant Primary Control Device Uncontrolled Uncontrolled (lb/MMBtu) Ib/MMsd (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 8.423 8.423 0.664 76.874 350.455 500 NOx CO 2 of 7 K:\PA\2018\18W E0445.CP1 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 PM2.5 SOx NOx VOC CO 1.35 1.35 1.35 1.35 1.35 228 1,35 1.35 1.35 1.35 1.35 228 0.11 0.11 0.11 0.11 0.11 18 12.28 12.28 12.28 12.28 12.28 2085 902.95 902.95 45.15 902.95 45.15 7669 55.96 55.96 55.96 55.96 55.96 9506 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year). (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224TMP 633 633 ' 32 633 32 422 422 21 422 21 53 53 - 3 53 3 440 440 22 440 22 2339 2339 117 2339 117 246 246 12 246 12 Section 06 - Regulator/ Summary Analysis Regulation 3, Parts A, 6 Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2w (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source is subject to Regulation 7, Section XVII.B,2, G The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it maybe appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to,the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit Will contain: - -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. ruu`tr', -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days).This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and Initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer 3 of 7 K:\PA\2018\18WE0445.CP1 Separator Venting Emissions Inventory Section 08 - Technical Anagysis Notes Source calculates emissions and emission factor limits shown above. Permit will reflect the requestedlerr AIRS Point# 001 Ctlenand uses Can/eMi I8ctursto determi4 C,emfsslonfaii and permit limits as: reported on the APEN. Process # SCC Code 01 ..3-10-001-60 Flares Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions Pollutant Factor Control % Units • PM10 8.42 0 Ib/MMSCF PM2.5 8.42 0 Ib/MMSCF SOx 0.67 0 Ib/MMSCF NOx 76.87 0 lb/MMSCF VOC 5654.41 95 lb/MMSCF CO 350.46 0 ib/MMSCF Benzene 1.98 95 lb/MMSCF Toluene 1.32 95 lb/MMSCF Ethylbenzene 0.17 95 Ib/MMSCF Xylene 1.38 95 Ib/MMSCF n -Hexane 7.32 95 Ib/MMSCF 224 TMP 0.77 95 Ib/MMSCF 4 of 7 K:\PA\2018\18WE0445.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Re: elation 3 Parts A and B - APEN and Permit Requirements 'Suume 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 IID.1.a)7 2. Are total facilty uncontrolled VOC emissions greater than 5 TPY, Boo greater than 10TPY or C0 emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? 'Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1TPY (Regulation 3, Part A, Section Il.D.t.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, N0x greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.21? '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? 'Source is subject to Regulation 7, Section XVII.B.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) Is fits separator controlled by a back-up or altemate 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 Ad, Its implementing regulations, and Air Quality Control Commission regulations. This document is not a 'rile 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 ado 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 Ad and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Source Req Source Req The centre COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Great Western Operating Company 123 9FB8 Raindance FD Pad LLC History File Edit Date Ozone Status 2119/2019 Non -Attainment EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.D 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.D 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE0445 Natural Gas Venting 1.4 0.1 12.3 901.7 56.0 2.1 1.4 0.1 12.3 45.1 56.0 0.1 New Request 002 GPDB Condensate Tanks (2)- 500 bbl 0.1 12.5 0.3 0.3 0.1 5.9 0.3 0.0 New GP08 Request WI SSEF 003 GP07 Hydrocarbon Liquid Loading 0.0 3.2 0.0 0.1 0.0 10.0 0.0 0.0 New GP07 Request 004 GP05 Produced Water (2)- 500 bbl 0.1 17.7 0.4 2.0 0.1 10.0 0.4 0.1 New GP05 Request 005 GP02 Doosan 303 HP 4SRB RICE 0.2 0.2 23.8 2.1 39.0 0.3 0.2 0.2 2.9 2.1 5.9 0.3 New GP02 Request 006 GP02 Doosan 303 HP 4SRB RICE 0.2 0.2 23.8 2.1 39.0 0.3 0.2 0.2 2.9 2.1 5.9 0.3 New GP02 Request 007 GPD2 Doosan 303 HP 4SRB RICE 0.2 0.2 23.8 2.1 39.0 0.3 0.2 0.2 2.9 2.1 5.9 0.3 New GP02 Request 008 GPM Generac 238 HP 4SRB RICE ' 0.2 0.2 23.9 1.6 39.2 0.2 0.2 0.2 2.3 1.6 4.6 0.2 New GP02 Request 009. GPD2 Doosan 303 HP 4SRB RICE 0.2 0.2 23.8 2.1 39.0 0.3 0.2 0.2 2.9 2.1 5.9 0.3 New GP02 Request 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 2.4 1.0 0.0 0.1 131.6 945.1 0.0 251.9 5.9 2.4 1.0 0.0 0.1 26.4 81.0 0.0 84.9 1.7 VOC: Syn Minor (NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: True Minor Permitted Facility Total 2.4 1.0 0.0 0.1 131.6 945.1 0.0 251.9 5.9 2.4 1.0 0.0 0.1 26.4 81.0 0.0 84.9 1.7 Excludes units exempt from permits/APENs MOVS Vii MI (5) Change in Permitted Emissions 2.4 1.0 0.0 0.1 26.4 81.0 0.0 84.9 kiii,q..ui iy I'M` I VyM11,-11 guidelines. Public comment is required because requesting a new syn minor permit and project Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 81.0 Facility is eligible for GP02 because < 90 tpy Project emissions NOT less than 25 tpy - public comment required B1.0 Note 2 Page 6 of 7 Printed 3/6/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY- HAPs Company Name Great Western Operating Company, LLC County AIRS ID 123 Plant AIRS ID 9FB8 Facility Name Raindance FD Pad - uncontrolled (Ibs per year POINT 'PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE0445 Natural Gas Venting 658 386 89 447 2322 287 2.1 002 GP08 Condensate Tanks (2)- 500 bbl 41 32 3 8 681 0.3 003 GP07 Hydrocarbon Liquid Loading 11 97 0.1 004 GP05 Produced Water (2)- 500 bbl 943 2964 2.0 005 GP02 Doosan 303 HP 4SRB RICE 429 58 55 33 64 0.3 006 GP02 Doosan 303 HP 4SRB RICE 429 58 55 33 64 0.3 007 GP02 Doosan 303 HP 4SRB RICE 429 58 55 33 64 0.3 008 GP02 Generac 238 HP 4SRB RICE 432 0.2 009. GP02 Doosan 303 HP 4SRB RICE 429 58 55 33 64 0.3 0.0 0.0 0.0 TOTAL (tpy) 1.1 0.1 0.1 0.9 0.2 0.0 0.2 3.0 0.1 0.1 0.0 0.0 5.9 "Total Reportable•= all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus ns with controls (Ibs per year POINTIPERMIT 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 18WE0445 Natural Gas Venting 33 19 4 22 116 14 0.1 002 GP08 Condensate Tanks (2)- 500 bbl 2 2 0 0 29 0.0 003 GP07 Hydrocarbon Liquid Loading 1 5 0.0 004 GP05 Produced Water (2)- 500 bbl 47 148 0.1 005 GP02 Doosan 303 HP 4SRB RICE 429 58 55 33 64 0.3 006 GP02 Doosan 303 HP 4SRB RICE 429 58 55 33 64 0.3 007 GP02 Doosan 303 HP 4SRB RICE 429 58 55 33 64 0.3 008 GP02 Generac 238 HP 4SRB RICE 432 0.2 009. GP02 Doosan 303 HP 4SRB RICE 429 58 55 33 64 0.3 0.0 0.0 0.0 TOTAL (tpy) 1.1 0.1 0.1 0.1 0.0 0.0 0.0 0.1 0.1 0.0 0.0 0.0 1.7 7 18WE0445.CP1 3/6/2019 ADC? n Contro ltc Heal CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0445 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Great Western Operating Company, LLC. Raindance FD Pad 123/9FB8 NESE SEC 30 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Flarecatcher 001 Separation of natural gas liquids from both tank vapors after treatment with Vaporcatchers and produced gas when pipeline capacity is unavailable Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to 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, y 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. ;COLORADO Air Pollution Control Division Page 1 of 9 2. thin one : ' • red 'y days (18 R. of - latter o is i• ncement iperation pliance ',nditions �nta red in this ' mit shall on. It the ow or op .m'tor's responsibi to self- ailur - complia . • n 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO,t VOC CO Flarecatcher 001 --- 12.3 45.1 56.0 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits for criteria air pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The 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 II1.E.) COLORADO Air Pollution Control Division Ith fr En ironmfmt Page 2 of 9 Flarecatcher A P '!t 001 evice missions rom t e areca c er are routed to an Enclosed Combustion Device tants rolled VOC and HAP 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 Facility Equipment ID AIRS Point Process Parameter Annual Limit Flarecatcher 001 Natural Gas Venting 319.38 MMSCF 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 the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. 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. !COLORADO lair Pollution Control Division Demrtmen; ri Public Nenith b Er iacnxwnt. Page 3 of 9 13. a separat e: . ove permit is to Regul.` Section X . (State er s 014, gas a sepa r, •`oduced du ` g normal any ly tructe• ' ydraul ly frac ed, or recompla .=d oil and st ei gath. - -strolled fro-• •te 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 a MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O8M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M 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 15. 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 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30`h 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 (NOX) 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 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. 'COLORADO Air Pollution Control Division NErMrenrierli Page 4 of 9 nge in th ow `; or opera y facility, •cess, or ver n-'- contra •ui• nt is ins -d, or enever a differ type of control eq r - " rep . _ . - °fisting • - • quipment, • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. 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). GENERAL TERMS AND CONDITIONS 19. 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. 20. 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. 21. 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. 22. 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. 23. 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 'COLORADO Air Pollution Control Division rienarSment o1 Pic. Health b F.nvironmerr Page 5 of 9 on a per ontested • -•wner or rator, or the own tor of a rc ay reque ' . hearing the Div 24. -7-114. �,;; ,..�;C.R. �:� that . e .;-d to file . _ lution 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. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Lauraleigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Great Western Operating Company, LLC. COLORADO Air Pollution Control Division [Y.rarment,,1 'ubtx; Hna₹Cn o Enrrr:mera Page 6 of 9 Notes t: 'ermit Hol=, at t .•- °'"this perm ice: 1) Th ` rmit hold s r- • ed ` ay fees f e p -ssing ti for his permit n invoice forr se fee l'_ ed el the mit is is. d Th permit holder s pay the in 30 dap... ice ' he invoic- "' ult in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https: //www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Flarecatcher 001 Benzene 71432 657 33 Toluene 108883 388 19 Ethylbenzene 100414 89 4 Xylenes 1330207 447 22 n -Hexane 110543 2,321 116 2,2,4- Trimethylpentane 540841 288 14 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. ;COLORADO Air Pollution Control Division RZlic. Health 6 Erwircnmert. Page 7 of 9 5) Th-:, ission le Poi 001: is permi - fed on th g emissio ;:; ctors: CAS # Pollutant ed Emission Factors (lb/MMSCF) Emission Factors (lb/MMSCF) .,:. Source NOx 77.0 77.0 AP -42 CO 350.7 350.7 PM 8.454 8.454 VOC 5,646.7 282.3 Extended Gas Analysis taken 3/20/2018 71432 Benzene 2.06 0.10 108883 Toluene 1.21 0.06 100414 Ethylbenzene 0.28 0.01 1330207 Xylene 1.40 0.07 110543 n -Hexane 7.27 0.36 540841 2'2'4-0.90 Trimethylpentane 0.05 Note: The controlled emissions factors for this point are based on the enclosed combustion device control efficiency of 95%. The combustion emissions (NOx, CO, and PM) are based on a separator gas heating value of 1130.5 BTU/scf. 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: CO, NOx, and VOC NANSR Synthetic Minor Source of: NOx and VOC PSD Synthetic Minor Source of: CO 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 COLORADO Air Pollution Control Division Dewrtrnerg ,1 ?tat -Ac 4ea;:n c Envimnrae,rst. Page 8 of 9 MACT 63.1200-63.1439 Subpart EEE - Subpart PPP ous Air •.a,• s for Sou 3.59 ubpar A - Subp Z 63.600- •'`' - Su 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 COLORADO Air Pollution Control Division Page 9 of 9 Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. 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.Rovicdphe/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: \% W e O 41LK AIRS ID Number: , Z /9 g/ 6 b [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: Flarecatcher [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Great Western Operating Company, LLC Site Name: Raindance FD Pad Site Location: NESE S30 T6N R67W Mailing Address: (Include Zip Code) 1801 Broadway, Suite 500 Denver, CO 80202 E -Mail Address2: bhuggins@gwogco.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Ben Huggins Phone Number: (303) 398-0302 '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. 378768 Form APCD-211 - Natural Gas Venting APEN - Rev 03/2017 AW COLORADO 1 H..U. e LIMO ra, fl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ▪ NEW permit OR newly -reported emission source - OR - • MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name 0 Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 0 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 £t Notes: New well pad 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: Removal of natural gas liquids from produced gas; and tank vapors after treatment with Vaporcatchers For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 1 / 25 / 2018 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions Form APCD-211 -Natural Gas Venting APEN Rev 03/2017 0 Yes 0 Yes ❑ No ▪ No COLORADO 2 I Aar ='"`',.;17= el F.wLc Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID) It Section 4 - Process Equipment Information O Gas/Liquid Separator O Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events # of Events/year: Volume per event: MMscf/event ❑✓ Other Description: Natural gas processing using Vaporcatcher and Flarecatcher If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? EJ Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 36,458 SCF/hr Vent Gas Heating Value: 1130.5 BTU/SCF Requested: 319.38 MMSCF/year Actual: 319.38 MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: VOC (mole %) 4.6433 VOC (Weight %) 10.2700 Benzene (mole %) 0.0010 Benzene (Weight %) 0.0037 Toluene (mole %) 0.0005 Toluene (Weight %) 0.0022 Ethylbenzene (mole %) 0.0001 Ethylbenzene (Weight %) 0.0005 Xylene (mole %) 0.0005 Xylene (Weight %) 0.0025 n -Hexane (mole %) 0.0032 n -Hexane (Weight %) 0.0132 2,2,4-Trimethylpentane (mole %) 0.0003 2,2,4-Trimethylpentane (Weight %) 0016 Additional Required Information: • Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX & n -Hexane, temperature, and pressure) Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 3[ A COLORADO b t. ur..o ,..ml AIRS ID Number: Permit Number: [Leave blank unless APCD has already assigned a permit #i and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.45538, -104.92735 Operator Stack ID No- Discharge Height Above _ Ground Level (Feet) Temp. ('F) Flow Rate (ACFA4) Velocity (ft/sec) NA Indicate the direction of the stack outlet: (check one) ❑ Upward 0 Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Section 6 - Control Device Information 0 VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency % VRU Downtime or Bypassed % ❑ Combustion Device: Pollutants Controlled: VOC, HAP Rating: 80 Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: MMBtu/hr Make/Model: (1) QTI Q5000 95 % 98 % Waste Gas Heat Content 1130.5 Btu/scf Constant Pilot Light: ❑✓ Yes 0 No Pilot burner Rating 0.06 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 COLORADO 4.w ��wm� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit fi 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 El 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 SOX NOx VOC ECD 95 CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? Projected 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 Permits mission Limit(s)5 Uncontrolled (Tons/year) Controlled6 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM O. 00q -\5t lb h- MB -f, rip -`i2 1.35 1.35 l •35 1.35- 1. so. NOX 0.068 Ib/MMBtu AP -42 12.3 12.3 12.3 12.3 VOC 5646.7 lb/MMscf SSEF 901.7 45.1 901.7 45.1 CO 0.31 Ib/MMBtu AP -42 56.0 56.0 56.0 56.0 Benzene 2.06 lb/MMscf SSEF 0.3 0.0 0.3 0.0 Toluene 1.21 lb/MMscf SSEF 0.2 0.0 0.2 0.0 Ethylbenzene 0.28 Ib/MMscf SSEF 0.0 0.0 0.0 0.0 Xylenes 1.40 Ib/MMscf SSEF 0.2 0.0 0.2 0.0 n -Hexane 7.27 Ib/MMscf SSEF 1.2 0.1 1.2 0.1 2,2,4-0.90 Trimethytpentane ylp lb/MMscf SSEF 0.1 0.0 0.1 0.0 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 AV COLORADO 5 I m� Nu�ll)ti�b Envvcx�.�ryn:. N rnf Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit 1i 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. 4/25/2018 Signature of Legally Authorized Person (not a vendor or consultant) Ben Huggins Date EHS Manager Name (please print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) 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 Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 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 6 N+suB Fnr Hello