The URL can be used to link to this page

Browse Search

Home My WebLink About20191149COLORADO Department of Public Health Ft 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 12, 2019 Dear Sir or Madam: RECEIVED MAR 2 0 2019 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 - Simpson 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 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 Put: c,YEK)1-eLJ 3I25/ta CC: Pt SM IER CN ICY-%) 31201 ►9 2019-1149 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Great Western Operating Company, LLC - Simpson 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: Simpson FD Pad Exploration Et Production Well Pad SENE Sec 15 T6N R67W Weld County The proposed project or activity is as follows: This project consisted of the addition of several wells at the Simpson FD Pad. As a result, the facility has added an enclosed combustion device for use to flare produced gas during periods of pipeline restrictions (AIRS Point: 010). This is a synthetic minor facility for VOC's and HAPs (Total, Toluene, n -hexane). 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 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: Lauraleigh Lakocy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 1 -. CO L 0 !IA 00 , wxaoue,yp,.azsnmmceree Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: tauraIeightvkocy ;r Package #: 38136 .. Received Date: 5/15/2t1 t Review Start Date: 12/18/2018 Section 01- Facility Information Company Name: teat Western Operating Company, LLC County AIRS ID: #23 Plant AIRS ID: SERB Facility Name: Simpson FD Pad Physical Address/Location: County: liWeld County Type of Facility: "e What industry segment?iii Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) SENE quadrant of Section 15, Township 6N, Range 67WW Section 02 - Emissions Units In Permit Application Quadrant Section Township Range 57W ' 5 6N ❑J Ozone (NOx &VOC) AIRS Point # Emissions Source Type 010 Separator Venting Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks COND 16W E045, Process Flare 18 W E0554 .. `•'Per€ftit • Issuance New wells, new emission factors & production • Section 03 - Description of Project 18WE0555 Point was requested initially, but was ciil=i3r:�;; eaestled prior 33 ho isShsuahcet:and. was neve€» constructed Verb Additi synthetic ddition of several wells,` at theiSimpson PD Pad, resu'ing in new fuel heating capacity values in addition t o new site specific emission factors. The rsfactors:-for the condensafefanksvvril be updated;as an final approval modification, while ire hydrocarbon loadou* and produced water tanks were era[ permits. The facility,;ias added>an enclosed combustion devise for use to flare produced gas during periods of pipeline restrictions (AIRS Point: 010f Ilj lifiks.added three{3)-total 4SRB RIGS, one of which is requesting G P02 coverage and the othertwo are catagorically exempt -from permitting. This is a i's and NAPs jTotal, Toluene in hexane), Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? e mit ; Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? ,;,,,;;,,;, ,;,, ;, j,[llE ? •� �� rim If yes, attach a copy of Technical Services Unit modeling results summary. Yes 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) SO2 NOx Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 TSP HAPs VOC CO ❑ ❑ PM2.5 PM10 TSP •HAPs ❑ ❑ Separator Venting Emissions Inventory 010 Separator Venting Facility AIRs ID: County IE Plant iB! 010: Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: - Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Actual Throughput = 89.4s MMscf per year Requested Permit Limit Throughput . 59.4-MMscf per year Requested Monthly Throughput= MMscf per month Potential to Emit (PIE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: tl' 89 MMscF per year Separator Gas Heating Value: 1392i Btu/scf Volume of waste gas emitted per BBL of liquids throughput: Ib/Ib-mol Displacement Equation Ex=Q•MW'Xx/C Weight % Oxygen/Argon CO2 N2 methane ethane 1 4 propane isobutane n -butane isopentane n -pentane cydopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224 -TM P Benzene Toluene Ethylbenzene Xy ynes C8+ Heavies 2.4 2.08: 0'.t# 0.63 0.40 Total VOC Wt % 100.00 32.48 scf/bbl Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 20843.0000 1042.1500 Benzene Toluene 49.2500 45.4900 4.4800 18.1600 376.9100 2.4625 2.2745 0.2240 Ethylbenzene Xylene 0.9080 18.8455 0.0060 n -Hexane 224 TMP 0.1200 Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) Emission Factor Source lb/MMscf Emission Factor Source PM10 PM2.5 500 NOx CO 75? (Gas Throughput) 10.372 10.372 0.819 94.656 431.520 2 of 7 K:\PA\2018\18W E0554.CP1.xlsm Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 5Ox NOx VOC CO 0.46 0,46 0.46 0.46 0.46 79 0.46 0,46 0.46 0.46 0.46 79 0.04 0.04 0.04 0.04 0.04 6 4.23 4.23 4.23 4.23 4.23 719 931.99 931.99 46.60 931.99 46,60 7916 19,30 19.30 19.30 19.30 19.30 3278 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Umits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TM 4404 4404 220 4404 220 4068 4068 203 4068 203 401 401 20 401 20 1624 1624 81 1624 81 33707 33707 1685 33707 1685 11 11 1 11 1 Section 06 - Re ' ulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (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 may be 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. -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 installedand 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\18WE0554.CP1.xlsm Separator Venting Emissions Inventory Section 08 -Technical Analysis Notes E�hlsan�t� s�rao�I��flannga€producedgas:7! gasfl6 iq a� # h i ed producedgos uoli than the f 6'dAf Il3ing�w3aight percentagessl Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 010 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 10.37 0 Ib/MMSCF PM2.5 10.37 0 Ib/MMSCF 5Ox 0.82 0 Ib/MMSCF NOx 94.66 0 Ib/MMSCF VOC 20843.00 95 Ib/MMSCF CO 431.52 0 Ib/MMSCF Benzene 49.25 95 lb/MMSCF Toluene 45.49 95 lb/MMSCF Ethylbenzene 4.48 95 Ib/MMSCF Xylene 18.16 95 lb/MMSCF n -Hexane 376.91 95 lb/MMSCF 224 TMP 0.12 95 Ib/MMSCF 4 of 7 K:\PA\2018\18W E0554.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Re - elation 3 Parts A and B - MIEN and Permit Requirements Source is in the Nan -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 110.1.5)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOxgreater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? INot enough Information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1TPY (Regulation 3, Part A, Section Hata)? l l.$)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)? ISource requires a permit _ Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recomplenod an or after August 1,2014? 'Source is subject to Regulation 7, Ssction)(Vll.B.2, G Section XVII.O.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Sassiest Is this separator controlled by a back-up or altemate combustion device (i.e., not the primary control device) that is not enclosed? The centrel'device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such ass "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. Source Req Source Req 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 9E6B Simpson FD Pad LLC History File Edit Date Ozone Status 2/14/2019 Non -Attainment EMISSIONS - Uncontrolled (tons per year) PM2.5 EMISSIONS With Controls (tons per year) PM2.5 POINT AIRS ID PERMIT Description PM10 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 36.7 34.6 1,324.5 1,323.4 0.0 0.0 44.8 42.5 24.8 24.7 D.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 6.2 4.1 79.1 78.0 0.0 0.0 15.8 13.5 1.7 1.6 001 003 00 GP02 15WP0354,CN GP07 16WE035ES GN Caterpillar G3306TA GM 4;3L Loadout Hei 0.1 0.1 32.5 a.r,5.::1:± 0.0 1.4 2.3 32.5 0.0 0.2 0.0 0.1 0.1 2.0 MEM 0.0 1.4 10.0 39 0,0 0.2 0.0 Updating serial number, fuel heating value, fuel aa'rldilalloi106:04•0$/102010K14,:'. Convert 16WE0355 to GP07 3s 005 006 007 008 009 010 16WE0357 GP05 GP02 18WE0551.XP 18WE0552.XP 18WE0554 18WE0555.CN Condensate Tanks Produced Water Tanks Cummins G855C 188 HP 4SRB RICE Compressco 46 HP 4SRB RICE Compressco 46 HP 4SRB RICE Process Flare (ECD) TEt OattycTraamBi (utr 71t 0.6 0.1 210.7 2.6 0.4 6.6 3.4 0.2 0.1 0.1 0.6 0.1 1.8 0.9 0.9 4.2 10.5 10.0 2.6 0.4 3.6 1.8 1.8 0.3 0.2 0.2 0.1 0.1 New SSEF. throughput Convert 16WE0358, update throughput New GP02 Request XP Request processed though pilot prog XP Request processed though pilot prog New Permit Request New Permit to is'su'ance 31.1 0.1 0.1 25.4 3.6 0.4 0.4 25.4 0.1 0.1 1.3 0.4 OA 7.3 7.3 4.2 931.90 8.3 8.3 19.3 22.1 0 46.90 19.3 • 1.1 �tl6ijti eveeca ru FACILITY TOTAL 0.2 0.2 0.0 0.0 77.4 1,181.8 0.0 96.8 32.8 0.2 0.2 0.0 0.0 10.5 80.9 0.0 33.4 2.2 VOC: Syn Minor (NANSR and OP) NOx: True Minor CO: True Minor HAPS: Syn Minor (Total & n -hexane) Excludes units exempt from permits/APENs Pubcom required based on new synthetic minor limits Facility is eligible for GP02 because < 90 tpy Project emissions not greater than 25 tpy Permitted Facility Total (d) Change in Permitted Emissions 0.2 0.2 0.0 0.0 62.8 1,181.0 0.0 80.2 32.6 0.2 0.2 0.2 0.2 0.0 0.0 0.0 0.0 8.7 4.6 80.1 2.1 0.0 0.0 29.8 16.3 2.0 Note 1 Total VOC Facility Emissions (point and fugitive) (4) Change in Total Permitted VOC emissions (point and fugitive) 80.9 2.1 Note 2 Page 6of7 Printed 2/19/2019 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 9E6B Facility Name Simpson FD Pad Emissions - uncontrolled (lbs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0.2 0.0 0.0 3.4 2.2 0.2 0.8 16.7 0.0 1.2 0.0 0.0 24.8 001 002 003 004 .. 005 006 007 008 009 010 011. GP02 16WE0354.CN GP07 11.0.N5036DTGiStkiii 16WE0357 GP05 GP02 18WE0551.XP 18WE0552.XP 18WE0554 18WE0555.CN? Caterpillar G3306TA GM 4.3L Loadout Heater Try Condensate Tanks Produced Water Tanks Cummins G855C 188 HP 4SRB RICE Compressco 46 HP 4SRB RICE Compressco 46 HP 4SRB RICE Process Flare (ECD) TEG Dehydration Unit .. 295 40 38 23 3 44 0.2 8 69 0.0 0.0 6.6 3.4 0.2 0.1 0.1 883 1660 691 38 154 11397 5218 77 291 40 12 12 37 11 11 22 43 13 13 89 89 7 7 2 2 1 1 4405 4068 401 1624 33705 22.1 0 0.0 32.8 TOTAL (tpy) 0.4 0.1 0.0 3.5 2.4 0.2 0.9 25.2 0.1 0.0 0.0 0.0 "Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) Formaldehyde POINT PERMIT Description Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S Previous FACILITY TOTAL 0.2 0.0 0.0 0.2 0.1 0.0 0.0 0.9 0.0 0.1 0.0 0.0 TOTAL (tpy) 1.7 001 002 003 0.04 005 006 007 008 GP02 1,6W E0354.CN i GP07 16W E0356.CN 16WE0357 GP05 GP02 18WE0551.XP 18WE0552.XP 18WE0554 i18WJ0555.CN Caterpillar G3306TA GM Loadout Heater Treat Condensate Tanks Produced Water Tanks Cummins G855C 188 HP 4SRB RICE Compressco 46 HP 4SRB RICE Compressco 46 HP 4SRB RICE Process Flare (ECD) TEG Dehydration Unit' 295 40 38 23 3 3 44 0.2 0.0 :. 0.0 0.0 0.3 0.2 0.2 0.1 0.1 1.1 0.0 0.0 2.2 009 010 011 TOTAL (tpy) 291 89 89 0.4 40 12 12 0.1 37 11 11 0.0 44 83 22 7 7 220 0.2 35 2 2 203 0.1 2 20 0.0 8 1 1 81 0.0 570 261 1685 1.3 43 13 13 0.1 4 0.0 0.0 0.0 7 18WE0554.CP1.xlsm 2/19/2019 ADO r Contro tic Healt CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0554 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Great Western Operating Company, LLC Simpson FD Pad 123/9E6B SENE SEC 15 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Process Flare 010 Flaring of produced gas during periods of pipeline restrictions 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, submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall COLORADO Air Pollution Control Division ;bl . NeaRn c F,.^,tiiror>tnert. Page 1 of 9 d t• .Tsr "on. It is er or op� •.responsibi to self- nce h onditions demo ate ompliance ;,''thin 180 t in •cati4 -:•f the F.rmit. A f certi tion form and •ance on -certi ,r' •, ian, - ed b - y be obta -•ine 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. VOC CO Process Flare 010 0.5 4.2 46.6 19.3 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. Compliance with the annual limits, for both 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. COLORADO Air Pollution Control Division rnert Page 2 of 9 7. e emissio fissions co the limit acility Equipment ID oin of e tabli AIRS Point ble belo as listed i permi e opera maintain with the educe ;� ssio to less th ; or equal Numb < '3, Part B, Secti , III.E.) Control Device Pollutants Controlled Process Flare 010 Produced gas is routed to an enclosed combustion device during periods of pipeline restrictions 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 Process Flare 010 Natural Gas Venting 89.43 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: COLORADO Air Pollution Control Division Page 3 of 9 installed er May 1, ust be eqped with niter upo • n of th . =• m • stion devi before must be equi • f with an operation ''r"`.- ggnit- ''•" •' A ore M. ', + ., • ter the ne ° • •'ustion device planned shutdown, whichever comes first. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 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 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 COLORADO f Air Pollution Control Division ^e, sr mint „i zuii:r heafth e F,nt: rr.;rv;rt. Page 4 of 9 0 tons pe s per ye N sub in actual less, abov ssions of he level 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. 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. COLORADO Air Pollution Control Division mere r,{ Pubro tesaitit 6 Environment Page 5 of 9 23. is permit -' . erial par - •_ and is noverable. a conditio all cons to . ejection •' '_ e entire ce, th' permit 11 be d ; ed denied ab io. This e re .:• . an = • to se i nd final a ion 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. 24. 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. 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 Cepartmertt of ?uNlo. Hearth r'.n;;zGn.: onk. Page 6 of 9 Notes t 1) Th for this perm ".ace: ay fees f $ e p ssing ti for his permit : invoice the • ' mit is i ".. -d. Th:: ermit holder s pay the in 30 da. eip • =oice. 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) - Process Flare 010 Benzene 71432 4,404 220 Toluene 108883 4,068 203 Ethylbenzene 100414 401 20 Xylenes 1330207 1624 81 n -Hexane 110543 33,707 1,685 2,2,4- Trimethylpentane 540841 11 1 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. COLORADO Air Pollution Control Division ^r ittment cf Ft;btc Nea;th 'o F,hv2rcrrc, ear•,t Page 7 of 9 in this p sed on foil." ing emiss factors: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 93.928 - AP -42, Ch. 13.5 CO 431.622 - AP -42, Ch. 13.5 VOC 20,843 1,042.15 Extended Gas Analysis 71432 Benzene 49.25 2.46 108883 Toluene 45.49 2.27 100414 Ethylbenzene 4.48 0.22 1330207 Xylene 18.16 0.91 110543 n -Hexane 376.91 18.85 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. The emission factors listed above are based on the extended gas analysis sample taken 2/15/2018 taken with a sample temperature of 64°F and sample pressure of 109 psi. 5) 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. 6) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs (Total and n -Hexane) NANSR Synthetic Minor Source of: VOC 7) 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 Page 8 of 9 MACT 63.1200-63.1439 Subpart EEE - Subpart PPP ous Air s for Sou 63.59ubpar. A - Subpx Z 63.600-6 - 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 Pees o, 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.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: /BWE{65S11t AIRS ID Number. 123 I 9E6B/ D/o [Leave blank unless APCD has already assigned a permit n and AIRS ID] Company equipment Identification: Process Flare [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: Simpson FD Pad Site Location: SENE Sec 15 T6N R67W Mailing Address: (Include Zip Code) 1801 Broadway, Suite 500 Denver, CO 80202 E -Mail Address': 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. Form APCD-211 - Natural Gas Venting APEN - Rev 03/2017 3813€ 4 AW COLORADO Permit Number: TBD AIRS ID Number: 123 / 9E6B / XXX [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) ❑ Change fuel or equipment ❑ Change company name 0 Add point to existing permit ❑ Change permit limit 0 Transfer of ownership3 0 Other (describe below) OR ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info £t Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: pipeline restrictions Flaring of produced gas during periods of For existing sources, operation began on: / / For new or reconstructed sources, the projected start-up date is: 2 /12/ 2018 ❑ 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 equipment located at a stationary source that is considered a Major Source of (HAP) Emissions days/week weeks/year O Yes 0 No O Yes 0 No Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 COLORADO 2I Department MP -Abe E6 Fn L Permit Number: TBD AIRS ID Number: 123 / 9E6B / XXX [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information O Gas/Liquid Separator O Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: Serial #: # of Pistons: Capacity: Gal/min Leak Rate: Scf/hr/pist ❑ Blowdown Events # of Events/year: Volume per event: MMscf/event ✓❑ Other Description: Flaring of produced gas 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? I] Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 10 ZO8 SCF/hr Vent Gas Heating Value: 1 392.0 I BTU/SCF Requested: 89.43 MMSCF/year Actual: 89.43 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 %) 15.0209 VOC (Weight %) 32.4818 Benzene (mole %) 0.0239 Benzene (Weight %) 0.0768 Toluene (mole %) 0.0187 Toluene (Weight %) 0.0709 Ethylbenzene (mole %) 0.0016 Ethylbenzene (Weight %) 0.0070 Xylene (mole %) 0.0065 Xylene (Weight %) 0.0283 n -Hexane (mole %) 0.1660 n -Hexane (Weight %) 0.5874 2,2,4-Trimethylpentane (mole %) O 0000 2,2,4-Trimethylpentane (Weight %) o. 0002 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 Ft n -Hexane, temperature, and pressure) Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 COLORADO 3 I Permit Number: TBD AIRS ID Number: 123 / 9E6B / XXX [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.488319, -104.873692 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (•F) Flow Rate (ACFM) Velocity (ft/sec) Produced Gas Flare -40 Ambient -9 -1 Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Horizontal ❑ Downward O Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): O Other (describe): O Upward with obstructing raincap 144 Section 6 - Control Device Information O VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency % VRU Downtime or Bypassed ❑ Combustion Device: Pollutants Controlled: VOC, HAP Rating: 80.21 MMBtu/hr Type: ECD Make/Model: QTI Q5000 Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency 98 Minimum Temperature: Constant Pilot Light: ❑✓ Yes O No Pilot burner Rating Waste Gas Heat Content 1392 Btu/scf 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 I Lam= H•.e.y6 Gnrar�mar� Permit Number: TBD AIRS ID Number: 123 / 9E6B/ XXX [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑ 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 Annum Permit �misson Limit(s)s Uncontrolled (Tons/year) Controlled 6 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NOx 0.068 .. Ib/MMbtu AP -42 4.2 4.2 4.2 4.2 VOC 20843.0 - Ib/MMscf SSEF 931.9 ., 46.6 v 931.9 46.6 CO 0.31 Ib/MMbtu AP -42 19.3 V 19.3 19.3 19.3 Benzene 49.25 v Ib/MMscf SSEF 2.2 .- 0.1 s, 2.2 0.1 Toluene 45.49 ✓Ib/MMscf SSEF 2.0 0.1 ✓ 2.0 0.1 Ethylbenzene 4.48 . - Ib/MMscf SSEF 0.2 ✓ 0.0 0.2 0.0 Xylenes 18.16 ✓Ib/MMscf SSEF 0.8 0.0 -° 0.8 0.0 n -Hexane 376.91 f Ib/MMscf SSEF 16.9 '' 0.8 ✓ 16.9 0.8 Trimethylpentane 0.12 ✓Ib/MMscf SSEF 0.0 -, 0.0 ' 0.0 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 5 1 ACOLORADO - Permit Number: TBD AIRS ID Number: 123 /9E6B/ XXX [Leave blank unless APCD has already assigned a permit ft 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. 5/14/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Ben Huggins EHS Manager Name (please print) Title Check the appropriate box to request a copy of the: ❑� Draft permit prior to issuance j 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-B 1 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 1 i=re Hello