HomeMy WebLinkAbout20194820.tiffCOLORADO
Department of Public
Health b Environment
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
November 6, 2019
Dear Sir or Madam:
RECEIVED
NOV 18 2019
WELD COUNTY
COMMISSIONERS
On November 7, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for
Cureton Front Range, LLC - Tiger 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 &t Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive 5., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govlcdphe
Jared Polls, Governor I Jilt Hunsaker Ryan, MPH, Executive Director
Pvbl i G Rev:ec.. cc: Pt-(rP),IiL(W),Pc4(TM/ER/cH/c)c)
l L/�5/19 OG(sn)
•
2019-4820
IF
CDPHE
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Cureton Front Range, LLC - Tiger Compressor Station - Weld County
Notice Period Begins: November 7, 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: Tiger Compressor Station
Natural gas compressor station
NWSE Sec. 19, T1 N, R64W
Weld County
The proposed project or activity is as follows: Applicant proposes to construct and operate a 40 MMSCFD
natural gas dehydration unit at an existing natural gas compressor station.
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 18WE0036 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.cotorado.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:
Bradley Eades
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
Health ft Environment
Permit number:
Date issued:
Issued to:
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
CONSTRUCTION PERMIT
18WE0036
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 2
Cureton Front Range, LLC
Tiger Compressor Station
123/9F89
NWSE SEC 19 T1N R64W
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) Trethylene glycol (TEG) natural gas
dehydration unit (Make: Trans Tex, Model: N/A,
Serial Number: N/A) with a design capacity of
40 MMscf per day. This emissions unit is
equipped with one (1) (Make: Kimray, Model:
9020V) glycol pump with a design capacity of 7
gallons per minute. Unit is also equipped with a
backup pump (Make: Kimray, Model: 45020PV).
This dehydration unit is equipped with a stilt
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
005
One (1) Methylene glycol (TEG) natural gas
dehydration unit (Make: TBD, Model: TBD, Serial
Number: TBD) with a design capacity of 40
MMscf per day. This emissions unit is equipped
with one (1) (Make: TBD, Model: TBD) glycol
pump with a design capacity of 7 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.
COLORADO
Air Pollution Control Division
Depsmrdnzt of P,ylic Neatly L• Err ironmelt
Page 1 of 11
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. Point 005: 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 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/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
3. Point 005: 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. Point 005: The following information shall be provided to the Division within fifteen (15) days of
the latter of commencement of operation or issuance of this permit.
• The dehydrator manufacturer name, model number and serial number
• The glycol circulation pump manufacturer name and model number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation Number 3, Part B, III.E.)
6. 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
7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
!COLORADO
Air Pollution Control Division
Dap%srtme"Sc.f Put,ft 3 t orsrier,t
Page 2 of 11
Monthly Limits:
Facility
Equipment ID
AIRS Point
Pounds per Month
Emission
Type
PM2.5
NO,
VOC
CO
TEG1
001
---
---
1,499
---
Point
TEG2
005
---
---
1,499
---
Point
Note: Monthly limits are based on a 31 -day month.
The owner or operator shall calculate monthly emissions based on the calendar month.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 1,359 pounds
per month.
Facility -wide emissions of total hazardous air pollutants shall not exceed 3,398 pounds per
month.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Annual Limits:
Facility
ui ment ID
Equipment
E
AIRS Point
Tons per Year
Emission
Type
yP
PM2.5
NO,
CO
TEG1
001
---
---
8.9
---
Point
TEG2
005
---
---
8.9
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
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. Point 001 and 005: Compliance with the emission limits in this permit shall be demonstrated by
running the GRI GlyCatc model version 4.0 or higher on a monthly basis using the most recent
extended wet gas analysis and recorded operational values for each dehydration unit, including:
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. 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
;COLORADO
IAir Pollution Control Division
Department of Health b Envvoronent
Page 3 of 11
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.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
TEG1
001
Still Vent: Enclosed Flare
VOC and
HAP
Flash Tank: Enclosed Flare
TEG2
005
Still Vent: Enclosed Flare
VOC and
HAP
Flash Tank: Enclosed Flare
PROCESS LIMITATIONS AND RECORDS
10. 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
Monthly Limit
(31 days)
TEG1
001
Dry Gas Throughput
14,600 MMscf/yr
1,240 MMscf/month
TEG2
005
Dry Gas Throughput
14,600 MMscf/yr
1,240 MMscf/month
The owner or operator shall monitor monthly process rates based on the calendar month. The
volume of dry gas processed shall be measured by gas meter.
During the first twelve (12) months of operation, compliance with both the monthly and annual
throughput limitations is required. After the first twelve (12) months of operation, compliance
with only the annual limitation is required.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
11. Point 001 and 005: Each unit shall be limited to the maximum lean glycol circulation rate of 7.0
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 (Loft) provisions under MACT HH. (Reference: Regulation Number
3, Part B, II.A.4)
12. Point 001 and 005: On a monthly basis, the owner or operator shall monitor and record
operational values including: flash tank temperature and pressure, wet gas inlet temperature
and pressure. These records shall be maintained for a period of five years.
COLORADO
Air Pollution Control Division
er,w6r.rnent
Page 4 of 11
STATE AND FEDERAL REGULATORY REQUIREMENTS
13. Point 001 and 005: 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)
14. Point 001 and 005: This source is subject to the odor requirements of Regulation Number 2.
(State only enforceable)
15. Point 001 and 005: This source is subject to Regulation Number 7, Section XII.H. The operator
shall comply with all applicable requirements of Section XII and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for 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.)
16. Point 001 and 005: 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;
• Alt 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.
17. Point 001 and 005: 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 flash separator or flash tank on a glycol natural gas dehydrator located at an
oil and gas exploration and production operation, natural gas compressor station, or gas -
processing plant subject to 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.
18. Point 001 and 005: The glycol dehydration unit at this facility is subject to National Emissions
Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production
Facilities, Subpart HH. This facility shall be subject to applicable area source provisions of this
regulation, as stated in 40 C.F.R Part 63, Subpart A and HH. (Regulation Number 8, Part E,
Subpart A and HH)
COLORADO
Air Pollution Control Division
Depertrner t or Pbulk... Here t'n a Emiror,r,ert
Page 5 of 11
MACT HH Applicable
Requirements
Area Source
Benzene emissions exemption
§63.764 - General
Standards
§63.764 (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.
§63.772 - Test
Methods, Compliance
Procedures and
Compliance
Demonstration
§63.772(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).
§63.772(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.
§63.772(b)(2)(i) - The owner or operator shall determine actual average
benzene emissions using the model GRI-GLYCaIc TM, Version 3.0 or higher,
and the procedures presented in the associated GRI-GLYCaIc TMTechnical
Reference Manual. Inputs 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 Gas Research Institute (GRI) report
entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator
Emissions" (GRI-95/0368.1); or
§63.772(b)(2)(ii) - The owner 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 §63.7(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.
§63.774 -
Recordkeeping
Requirements
§63.774 (d)(1) - An owner or operator of a glycol dehydration unit that
meets the exemption criteria in $63.764(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 this section, 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 £t MAINTENANCE REQUIREMENTS
19. Point 001 and 005: Upon startup of these points, the owner or operator shall follow the most
recent operating and maintenance (0&M) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements of this
permit. Revisions to the O&M plan are subject to Division approval prior to implementation.
(Regulation Number 3, Part B, Section III.G.7.)
OLORADQ
I Air Pollution Control Division
i V�dd;C lies"t iJ L"rno)nrrwnl
Page 6 of 11
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
20. Point 005: 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.16)
21. Point 005: 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
22. Point 001 and 005: 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
23. All previous versions of this permit are cancelled upon issuance of this permit.
24. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (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.
• 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.
!COLORADO
Pollution Control Division
ri.ry Of N.tblr.Fi t:th er ir;;irorrnent
Page 7 of 11
25. 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
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
26. 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.
27. 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.
28. 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.
29. 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.
30. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
31. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
32. 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.
COLORADO
Air Pollution Coritral Division
Depart,,wit r✓u.ik I e Environment
Page 8 of 11
By:
Bradley Eades
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
July 2, 2018
Issued to Cureton Front Range, LLC
Issuance 1
This issuance
Issued to Cureton Front Range, LLC
Modification to add one (1) 40 MMSCFD TEG
Dehydrator (point 005).
;COLORADO
Air Pollution Control Division
Di pfml`"k of of Public f ieli th Environmeo,t
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 wilt be issued after the permit is issued. The permit holder shall pay the invoice within 30 days
of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
TEG1
001
Benzene
71432
33,637
1,682
Toluene
108883
33,082
1,654
Ethylbenzene
100414
9,293
465
Xylenes
1330207
21,347
1,067
n -Hexane
110543
3,465
173
TEG2
002
Benzene
71432
33,637
1,682
Toluene
108883
33,082
1,654
Ethylbenzene
100414
9,293
465
Xylenes
1330207
21,347
1,067
n -Hexane
110543
3,465
173
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) Point 001 and 005: 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 the enclosed
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
C t t iktatz i i� En.rza..*net;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, formaldehyde, benzene, toluene, xylenes, Total HAP
NANSR
Synthetic Minor Source of:
VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Applicable
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
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
'COLORADO
Mr Pollution Control Division
ptsrr-y t4th i Enkirr?rmtc,rt
Page 11 of 11
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Bradley Eades
Package 4: 414225
Received Date: 8/15/2019
Review Start Date: 10/24/2019
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID: 9F893.
Facility Name: TigO1`
Physical Address/Locatio NWSE quadrant of Section 19, Township 1N, Range 64WW, in Weld County, Colorado
Type of Facility:
What industry segment?)GY )
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? Caron Monoxide (CO) Pa culate Matter (PM) gne (NOx & VOC)
Section 02 - Emissions Units In Permit Application
Weld
ii Front Range LLC;;.
Quadrant
Section
Township
Range
64W.
N
AIRS Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance ₹t
Self Cart
Required?
Action
Engineering
Remarks
EJOv"s
InLT.
005
,T
TEG2
yes
18WE0036
2
Yes
rmitlnitial
Issuance
New Pont
Section 03 - Description of Project
Applicant has submitted application to obtain a cont. tion permit for an additional 40 MMSCFD dehydration unit at an existing compressor st
this dehydrator are controlled using an enclosed combustor. Equipment permitted with Issuance 1 (TES1) began operation 12/24(2018
Section 04 - Public Comment Requirements
IS Public Comment Required?
If yes, why? r eafstng es
•
.new synthetic minor limits on Point 005
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? L
If yes, for what pollutants? F i
If yes, attach a copy of Technical Services Unit modeling results summary.
ion- Emissions from
. )„, aF'ta'i
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)
Is this stationary source a major source?
If yes, explain what programs and which pollutants herr sot NOx co_
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
S
SO2 NOx
CO VOC PM2.5 PM10 TSP HAPs
8
PM2_5
PM10
TSP
El El
HAPs
l C ❑
Glycol Dehydrator Emissions Inventory
Section 01- Administrative Information
'Facility AIRS ID:
County 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 Desorption
MMsd/day
gallons/minute
flash tank,
and reboller bumer
One )T) Triethyrene glycol [TEG) neterai gas dehydration unit (plot.: TID, Model: TDD. Serial Number: TIID) teak a design
capacity of 40 MMsef per day. This emissions unit is equipped scith one (1) (Make: TED. Model: TOO) gas driven glycol pomp
with a design cepacity of 7 gallons per minute. This dehydration unit is equipped with a still vont. f€ h tank, and reboil.:
burner.
Emissions from the still venture routed to the Enclosed Flare, 6ntssiens from the flash tank ere rusted thready to the
Emission Control Device Description: Enclosed Fier.,
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions- Dehydrator Still Vent and Flash Tank (If present)
Requested Permit Limit Throughput= ; -.SA OD4.pd whcf per year
Potential to Emit (PTE) Throughput= 14,500.0 MMsd per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Still Vent Control
Condenser:
Condenser emission 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
Flesh Tank Waste Gas Vent Rate:
f0; MMsdper month
0.14
Control Efficiency %
hr/yr
4:0333 Btu/scf
d,: sdh
Wet Gas Processed:
Still Vent Primary Control: 14,600.0 MMsCf/yr
Still Vent Secondary Control Sit MMscf/yr
Waste Gas Combusted:
Still Vent Primary Control: 50.5 MMscf/yr
Still Vent Secondary Control: 0.0 MMsct/yr
Wet Gas Processed:
Flash Tank Primary Control: 14,560.0 MMscf/yr
Flash Tank Secondary Control: 6.0 MMscf/yr
Waste Gas Combusted:'
Flash Tank Primary Control: 4.3 MMscf/yr
Flash Tank Secondary Control: 0.0 MMscf/yr
Glycol Dehydrator Emissions Inventory
Section 04- Emissions Factors &Methodolceles
STILL VENT
Pollutant
Uncontrolled (lb/hr)
Control Scenario
Primary
Controlled (lb/hr)
Secondary
Controlled (lb/hr)
VOC
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
224-TMP
1.01558
0.05572
0.00073
0.00062
0.000985
0.00928
-004111,1:411:31-14411,-1,.•.0
07.1111300.07400031.111
a
0
_ .
FLASH TANK
Control Scenario
Primary
Secondary
Pollutant
Uncontrolled (lb/hr)
Controlled (lb/hr)
Controlled (lb/hr)
VOC
g 199fifiUUv.•''>.
0.99834
0
Benzene
kP' 37254'2 v^T''..
0,18627
0
Toluene
,•37934n,"`• ,.,30
0.159095
0
Ethylbenzene
'1,. gL 0.x484`1
0,05242
0
Xylenes
;eF ;. 2,4176-: 3.7
0.12088
n -Hexane -
.'-0,2094;3.r
0,010495
224TMP
0 U
0
mission Facto
Pollutant
VOC
Ben
Toluene
Ethylbenzene
Glycol Dehydrator
Uncontrolled
(lb/MMscf( (Ib/MMscf(
(Wet Gas
Throughput)
Controlled
24
Xylene 1.4
n -Hexane 0.24
224 TMP 0
(Wet Gas Throughput)
02
0
0.00E100
Uncontrolled Uncontrolled
Still Vent Primary Control Device
"Uncontrolled
Ibihr
Emission Factor Source
Pollutant (Ib/MMBtu( (Ib/MMacf) Emission Factor Source
(Waste Heat
Combusted)
PM10 -- 0.0075::
PM2.5 ..............:0:0075
SOx
NO
CO 0.3100'.
Pollutant
Pollutant
PM10
PM2.5
(Waste Gas
Combusted(
0.8418
0.8418
0.0665
7.6829
35.0248
Still Vent Secondary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu( (Ib/MMscf)
(Waste He (Waste Gas
Combusted) Combusted)
0.0050
0.0000
0.0000
0.0000
0.0900
Flash Tank Primary Control Device
Uncontrolled Uncontrolled
(lb/MMBtu( (Ib/MMecf)
(Waste Heat (Waste Gas
Combusted) Combusted(
0 0075 -. 10.6849
0,0075:::..'..... 10.6849
59x *. .,:0:606
NO ':..... 00680.::,
Pollutant
0.8435
97.5137
444.5478
Flash Tank Secondary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu( (Ib/MMscf(
(Waste Heat (Waste Gas
Combusted( Combusted(
0.0000
0.4000
NOx %/QG'zV42f:e.: _ _. O.
16.8251
3.1352
2.4509
0.2048
1.1259
0.3197
0.0003
'Uncontrolled
Ic4tr
17.0298
0.090;
0.0455
0.0032
0.0085
0.20008
0(003
'Data born
GlyCalc
mulacon with
sda-specific 509
analys0.
(sampled B/5:19)
Emission Factor Source
Glycol Dehydrator Emissions Inventory
Section 05 - Emissions Inventory
Did operator request a buffer?
Requested Buffer (96):
aaa-
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled.
(tans/year) (tans/year)
- PM10
PM2.5
5Ox
500
CO
VOC
OA
0.0
11.0
0,0
0,0
0.0
0.0
0,0
0.9
0,0
0.0
0.11
11.0
0,0
0.0
0.4
0.4
0,4
0,45
0.41
1.9
1.9
1.9
5,$8
1,88
176.4
1766.4
8.8
176.42
0,82
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
33,637
53.907
1,582
39,837
•1,88'2
95,082
13,057
LOU?
30,082
1,6.54
9,70?
9.293
465
9,299
465
'3.1,34??
21:347
1,957
25,047
0,007
3,485
3.465
173
1,405
175
-
-
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Section XVII.B4O
Regulation 7, Section XVII.8.2.e
Regulation 7, Section XII.11
Regulation. e, Part E, MACT Subpart HH (Area)
Regulation 8, Part E, MACT Subpart HH (Major)
Regulation 8, Part E, MAR Subpart HHH
(See regulatory applicability. worksheet for detailed analysts)
Source requires -0 permit
Dehydrator Is subject to Regulation 7, Seddon XVII, El. 5.3
The control device for ibis dehydrator's not subject to Repletion 7, Section XVi1,0.1.
Dehydrator is subject to Regulation 7.Seddon 011.11
Dolly is sublet: to area. source MAC' Htl, per the require:nerds.in 63,704141(2)
You have indicated then this facility Is not nut:feet to Ma(ar Source requirements of Mt
You have indicated that this f-acliity Is not eob)ect to MACS' HHH,
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? 11
If no, the permit will contain en "Initial Compliance" testing requirement to demonstrate compliancewith emission limi
*Inlcudes Pilot at 1851 mmbtu/yr
*Inlcudes Pilot at 1851 mmbtu/yr
Doesthe company request a control device efficiency greater than 95% for a flare or combustion device? ymLL�'
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based an inlet and outlet concentration sampling
Section 08- Technical Analysis Notes
Applicant:nacates that the still vent .uost „as is processed through a liquid knockout ve se, toremove excesswb tezprtortecomhastinrhihi.
aopifcao has calculated z Nh\' of 1720₹or he comhineA mi*s,00 tream directed loche e00 The coteVtabons above userav),datafrom Glyn
lbe aleulatiny of NT'
and co ent5sion is a urate ?Inc¢ n15,54176
s (hr is h gher th the mm�sion of water (x.e. the HV on f i JS;fbaslsu Hid
M MGtu/fir remains tthe_ }re since watersObtu(saf),'.
.Thisaaltly has not began operatic, te'speafics
potentialem ion rates from .his dehydrator
Section 09 - Inventory SCC Coding and Emissions Fadors
AIRS Point It
WaS not 011able atYone'of application. Therefor
Requested Permit Limits
Uncontrolled Controlled
lb/month) . (lb/month)
6.5
6,5
6,5
6,5
0,5
0,5
70,0
70.0
319,3
319,1
3957,1
1498.4
sltil'gyf ft&, I hf� to lino: i f T 91 . 7/1/ 11 plc t APte-specificg analysts ₹inletg w quire
sg,F dope�i�ngPammeters andth : p fic gasry b t th self -certification ( d0 /21/13)enddetermined that the
5(/ ) e pser{i3$WeShigher VOC and NAP) than what is estimated using tne site-specificanalysis_ A., such, I soil approve the use of the
jypj#t js lsS6dR�"Co4J`�f�lls'equ omen:. Emissions of VOC using thto specific gas nalysis yr s76tpy Cl..Vas opposed tthe 8.9 tpyVOCL
Process N SCC Code
005 01
Pollutant
PM10
PM2.5
50x
NO%
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
Uncontrolled
Emissions Factor
0.005
0.005
0.000
0.056
24.2
0.258
2.304
2.266
0.636
1.462
0.237
Control %
0.0
0.0
0.0
0.0
95.0
0:0
95.0
95.0
95.0
900
95.0
Units
b/MMscf
b/MMscf
b/MMscf
b/MMsd
b/MMscf
b/MMscf
b/MMscf
b/MMscf
b/IMMscf
b/MMscf
b/MMscf
Dehydrator Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
ISource 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 lI.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 ll.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 (Regulation3, PartB, Section 11.O.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 Xi4H
Section )R l.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
b. end user' (63.760(a)(3))?
2. Is the dehydrator located at a facility that is a major source for HAPs?
IGo to MALT 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(6)(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. Areactual 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?
I Dehy is subject to area source MACT HH, per the requirements in 63.764(d)(2)
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
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 lets than 249.7
Small or Large Dehy 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 Dehy 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 CAR, 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 Dehy 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 Dehy Requirements
3. Did construction of the small glycol dehydration unit commence± on or before August 23, 2011 (63.1270(6)(2) and (3) )?
4. Forthis small dehy, is a control device required to meet the BTEX emission limit (standard?) given by the applicable equation?
Yes
Yes
Yes
Yes
O
You 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.a)?
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 2tpy 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.h)?
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)?
Dehydrator is subject to Regulation 7, Section XVII, 5, 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?
No
No
Yes
The control device for this dehydrator is not subject to Regu€ation 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.
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
9F89
Tiger Compressor Station
History File Edit Date
12/24/2018
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons Der year
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
New Facility - No Previous Total
Previous Permitted Facility total
001
18WE0036
TEG Dehydrator (TEG1)
0.4
176.4
1.9
50.4
0.4
8.9
1.9
2.5
No change
002
GP02
ENG-1 Caterpillar 3516B
6.7
12.1
32.3
5.8
6.7
9.4
20.0
1.4
No change
003
GP02
ENG-2 Caterpiillar 3516B
6.7
12.1
32.3
5.8
6.7
9.4
20.0
1.4
No change
004
GP0B
Produced water tanks
1.2
0.1
5.9
0.0
No change
005
18WE0036
TEG Dehydrator (TEG2)
0.4
176.4
1.9
50.4
0.4
8.9
1.9
2.5
New Point
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
14.2
378.2
0.0
68.4
112.5
0.0
0.0
0.0
0.0
14.2
42.6
0.0
43.8
7.9
VOC: Syn Minor (NANSR and OP)
NOx: Minor (PSD/NANSR and OP)
CO: Minor (PSD and OP)
HAPS: Syn Minor Total
HH: Syn Minor + affected Area
ZZZZ: Syn Minor
Permitted Facility Total
0.0
0.0
0.0
0.0
14.2
378.2
0.0
68.4
112.5
0.0
0.0
0.01 0.0
14.2
42.5
0.01
43.8
7.9
Excludes units exempt from permits/APENs
(A) Change in Permitted Emissions
_
0.0
0.0
0.0 0.0
14.2
42.5
0.0
43.8
Pubcom & modeling not required based on (A
change in emissions)
Note 1
Total VOC Facility Emissions (point and fugitive)
(A) Change in Total Permitted VOC emissions (point and fugitive)
42.5
Facility is eligible for GP02 because < 90 tpy
Project emissions less than 25/50 tpy
42.5
Points 001-004 began operation 12/24/2018
Note 2
Page 7 of 8
Printed 10/29/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Cureton Front Range LLC
123
9F89
Tiger Compressor Station
Emissions - 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
18WE0036
TEG Dehydrator (TEG1)
33637
33082
9293
21347
3465
50.4
002
GP02
ENG-1 Caterpillar 35166
10127
738
454
39
221
5.8
003
GP02
ENG-2 Caterpiillar 3516B
10127
738
454
39
221
5.8
004
GP08
Produced water tanks
64
201
0.1
005
18WE0036
TEG Dehydrator (TEG2)
33637
33082
9293
21347
3465
50.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
TOTAL (tpy)
10.1
0.7
0.5
33.7
33.1
9.3
21.3
3.6
0.2
0.0
0.0
0.0
112.5
otal Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
Emissions with controls (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
18WE0036
TEG Dehydrator (TEG1)
1682
1654
465
1067
173
2.5
002
GP02
ENG-1 Caterpillar 3516B
2025
369
227
39
221
1.4
003
GP02
ENG-2 Caterpiillar 3516B
2025
369
227
39
221
1.4
004
GP08
Produced water tanks
3
10
0.0
005
18WE0036
TEG Dehydrator tTEG2)
1682
1654
465
1067
173
2.5
0.0
0.0
0.0
0.0
0.0
0.0
0.0
TOTAL (tpy)
2.0
0.4
0.2
1.7
1.7
0.5
1.1
0.2
0.2
0.0
0.0
0.0
7.9
8
18WE0036.CP2.xlsm
10/29/2019
Glycol Dehydration Unit APEN
Form APCD-202
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
RECEfy
AUG 1.5 2019
CD
s#APtvne,�,
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require
payment for a new filing fee.
This APEN is to be used for 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 (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 18WE0036
AIRS ID Number: 123 / 9F89 / 06.5 -
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Namet CuretonFront Range LL -C
Site Name:
Site Location:
Tiger Compressor Station
Site Location
NWSE Sec. 19, R1 N, T64W County: Weld
Mailing Address:
(Include Zip Code) 518 17th Street, Suite 650
Denver, CO 80202
NAICS or SIC Code: 211111
Contact Person: Nick Holland
Phone Number: 303-324-5967
E -Mail Address': nick.holland@curetonmidstream.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
414223
COLORADO
Form APCD-202 - Glycol Dehydration Unit ADEN - Revision 3/2019 1 1.
Permit Number: 18WE0036
AIRS ID Number:
123/9m/
[Leave blank unless APCD has already assigned a permit it and AIRS ID]
Section 2 - Requested Action
O NEW permit OR newly -reported emission source
-OR-
❑✓ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment 0 Change company name3 ✓❑ Add point to existing permit
❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below)
- OR
▪ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info & Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 General Information
General description of equipment and purpose: 40 MMSCFD TEG Dehydration Unit
equipped with a combustor for 95% control (design DE of 98%)
Company equipment Identification No. (optional): TEG2
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
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
weeks/year
logthl
Form APCD-202- Gtycot Dehydration Unit APEN - Revision 3/2019 2
COLORADO
AIRS ID Number:
123 /9F89/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Dehydration Unit Equipment Information
Manufacturer:
TBD
Dehydrator Serial Number:
TBD
Model Number: TBD
Reboiler Rating: 0.5 MMBTU/hr
Glycol Used: O Ethylene Glycol (EG) O DiEthylene Glycol (DEG) ❑✓ TriEthylene Glycol (TEG)
Glycol Pump Drive: ❑✓ Electric O Gas If Gas, injection pump ratio: / Acfm/gpm
Pump Make and Model:
TBD - air driven, not electic
Glycol Recirculation rate (gal/min):
Lean Glycol Water Content:
Max: 7.0
1.5
Wt.%
Requested: 7.0
# of pumps: 1
Dehydrator Gas Throughput:
Design Capacity:
Requested5:
40 MMSCF/day
14600 MMSCF/year Actual:
MMSCF/year
Inlet Gas:
Water Content: Wet Gas:
Flash Tank: Pressure: 35 psig
Cold Separator: Pressure. psig
Pressure: 1000
psig
Temperature: 120
°F
lb/MMSCF ----❑ Saturated Dry gas: / :U lb/MMSCF
Stripping Gas: (check one)
❑✓ None ❑ Flash Gas O Dry Gas ❑ Nitrogen
Flow Rate:
scfm
Temperature:
Temperature: F
Additional Required Information:
D
Attach a Process Flow Diagram
Attach GRI-GLYCalc 4.0 Input Report Et Aggregate Report (or equivalent simulation report/test results)
Attach the extended gas analysis (including BTEX 8 n -Hexane, temperature, and pressure)
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-202 - Glycol Dehydration Unit APEN - Revision 3/2019
_OLORAOO
3 ',,,:,
❑r Upward
O Horizontal
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.036142/-104.594469
Operator
ID.NO...
-=Discharge. Height
Above Gro...
(feet)
Temp
- (`F) i -
Flow Rate
(ACFM) -
Velocity
.(ft/sec) ,.
.
Combustor
12
1000
22216
29.46
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
0 Upward with obstructing raincap
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches): 48
❑ Square/rectangle Interior stack width (inches):
❑ Other (describe):
Interior stack depth (inches):
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce_ emissions, and skip to the next section.
Condenser:
Used for control of:
Type: Make/Model: _
Maximum Temp: °F Average Temp: _
Requested Control Efficiency:
°F
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: 9c %
Manufacturer Guaranteed Control Efficiency: q? % ( r- .01+'"•
Minimum Temperature: NA °F Waste Gas Heat Content: Btu/scf
Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: —0.21 MMBtu/hr
ipI15Ii�
Closed
Loop
System:
Used for control of: _
Description: _
System Downtime:
Other:
Used for control of:
Description:
Requested Control Efficiency:
Form APCD-202 - Glycol Dehydration Unit APEN -Revision 3/2019
COLORADO
4 j °V' ,'.
Permit Number: 18WE0036
AIRS ID Number:
12319F"/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 -; Emissions Inventory Information
Attach all emission calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (%reduction):
Pollutant
Description of Control Method(s)
Overall. Requested
Control Efficiency
(% reduction in emissions)
PM
SOX
NO.
CO
VOC
t+,'eric) Combustor
95%
HAPsS()
Combustor
95%
Other:
From what year is the following reported actual annual emissions data? 2020
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg-, ' etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
—. PM __
SOx
NO.
0.068
Ib/MMBtu
AP -42
0.41
0.41
CO
0.31
lb/MMBtu
AP -42
1.88
1.88
VOC
24.17
Ib/MMscf
GLYCalc
176.42
8.82
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions 6
(pounds/year)
Benzene
71432
2.30
Ib/MMscf
GLYCaIc'
33637
1682
Toluene
108883
2.27
lb/MMscf
GLYCaIc
33082
1654
Ethylbenzene
100414
0.64
lb/MMscf
GLYCalc :
9293
465
Xylene
1330207
1.46
Ib/MMscf
GLYCaIc
21347
1067
n -Hexane
110543
0.24
lb/MMscf
GLYCaIc
3465
173
2,2,4-
Trimethylpentane
540841
Other:
Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported: If source has not yet started operating, leave
blank.
Form APCD-202 -: Glycol Dehydration Unit APEN - Revision 3/2019
COLORADO
5.1 9.<
Permit Number:
18WE0036
AIRS ID Number:
123 /9F89/
[Leave blank unless APCD has already assigned a permit tt and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that alt information conyined herein and information submitted with this application is complete,
true, and correct.
Signature of Legally Authorized Person (not a vendor or consultant)
Nick Holland
Date
Director of EHS&R
Name (print)
Title
Check the appropriate box to request a copy of the:
E✓ Draft permit prior to issuance
❑/ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-61
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
Form APCD-202 - Glycol Dehydration Unit APEN - Revision 3/2019
C0 OR,4DO
6 I ;4,z
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