HomeMy WebLinkAbout20192505.tiffB
COLORADO
Department of Public
Health 8Environment
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
June 25, 2019
Dear Sir or Madam:
RECEIVED
JUL 01 2019
WELD COUNTY
COMMISSIONERS
On June 27, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for SRC
Energy, Inc. Harvesters State 7-15 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
Jared Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director
P�bC;
oT51BCD/ l9
c.ctPLCTP), 1-tLCJT), OC,C5 n),
PtwC 5enf2 R/CH/Chi
x/19/19
2019-2505
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: SRC Energy, Inc. - Harvesters State 7-15 Pad - Weld County
Notice Period Begins: June 27, 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: SRC Energy, Inc.
Facility: Harvesters State 7-15 Pad
Oil and gas well production facility
SWNE Sec. 15, T6N, R66W
Weld County
The proposed project or activity is as follows: Applicant proposes to operate a new well production facility
which includes six (6) 400 barrel fixed roof storage tanks with emissions controlled by an enclosed flare.
Facility also operates produced water tanks, hydrocarbon liquid loadout and natural gas engines covered
under GP02.
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 19WE0179 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.Rov/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
1
COLORADO
Department of Public
Health is Environment
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Bradley Eades
Package #: 393617
Received Date: 2/15/2019
Review Start Date: 4/11/2019
Section 01 - Facility Information
Company Name: SRC Energy, Inc
County AIRS ID: 123
Quadrant
Section
Township
Range
SWNE
16
6N
66
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
A02C
Harvesters State 7-15 Pad
SWNE quadrant of Section 16, Township 6N, Range 66W
Weld County
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant?
Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
Particulate Matter (PM)
Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
001
Condensate Tank
TK 1-6
Yes
19WE0179
1
Yes
Permit Initial
Issuance
002
Produced Water Tank
PW 1-2
Yes
19WE0180
1
Yes
Permit Initial
Issuance
003
Liquid Loading
LOAD -1
Yes
19WE0181
1
Yes
Permit Initial
Issuance
004
Natural Gas RICE
ENG-1
Yes
GP02
NA
Yes
GP Approval
Pkg 393494
005
Natural Gas RICE
ENG-2
Yes
GP02
NA
Yes
GP Approval
006
Natural Gas RICE
ENG-3
Yes
GP02
NA
Yes
GP Approval
007
Natural Gas RICE
ENG-4
Yes
GP02
NA
Yes
GP Approval
008
Natural Gas RICE
ENG-5
Yes
GP02
NA
Yes
GP Approval
Section 03 - Description of Project
This project is for a new well pad production facility (12 wells) that began operation 11/2018 and is located in the ozone non -attainment area. In addition to condensate storage tanks,
produced water tanks and hydrocarbon liquid loadout, source is requesting five (5) GP02 approvals for NG fired engines. The facility is a synthetic minor for NANSR for NOx and VOC with
facility -wide permitted limits of 36.3 tpy VOC.
Only permt 19WE0179 has synthetic minor limits and therefore will require public notice.
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement:
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2
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)
No
Yes
NOx
No
NOx
CO VOC PM2.5
4
PM10
TSP
HAPs
CO VOC PM2.5 PM10 TSP HAPs
•
Condensate Storage Tank(s) Emissions Inventory
001 Condensate Tank
'Facility AIRs ID:
123 AO2C
County Plant
001
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Six (6) 400 barrel fixed roof condensate storage vessels connected via liquid manifold.
Enclosed Flare (bank of 4 combustors)
95
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput =
789,276 Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
789,276 Barrels (bbl) per year
Requested Permit Limit Throughput =
947,138.5 Barrels (bbl) per year Requested Monthly Throughput =
80442 Barrels (bbl) per month
Potential to Emit (PTE) Condensate Throughput
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquids
produced
947,139 Barrels (bbl) per year
Btu/scf
scf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
2162.4 bbl/d is what model is based on
9.435622457 scf/bbl is what I calculate for flash+w&b
HHV is based on weighted average of modeled HHV for flash & w&B vapors
18,141 MMBTU per year
21,770 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 21,770 MMBTU per year
Heat content of pilot fuel = 1248 Btu/scf
50 scfh
0.438 MMscf/yr
Requested heat content of pilot gas routed to combustion device =
Section 04- Emissions Factors & Methodologies
Pilot fuel use rate =
Will this storage tank emit flash emissions?
547 MMBTU per year
Emission Factors
Condensate Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
0.8191
0.0410
Site Specific E.F. (includes flash)
Benzene
2.19E-03
1.10E-04
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Toluene
1.98E-03
9.92E-05
Ethylbenzene
1.34E-04
6.71E-06
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Xylene
7.15E-04
3.57E-05
n -Hexane
1.62E-02
8.11E-04
224 TMP
7.15E-05
3.58E-06
Control Device (waste gas)
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (lb/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM10
0.0075
0.0002
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Chapter 13.5 industrial Flares (NOx)
AP -42 Chapter 13.5 industrial Flares (CO)
PM2.5
0.0075
0.0002
NOx
0.0680
0.0016
CO
0.3100
0.0071
Control Dev ce (pilot)
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(Ib/MMBtu) (Ib/MMSCF)
(pilot gas
combusted)
(Pilot gas
combusted)
PM10
0.0075
9.25.,.
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PM10/PM 2.5)
PM2.5
0.0075
9.2983
AP -42 Chapter 13.5 industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
NOx
0.0680
84.8646
CO
0.3100
386.8800
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
387.9
323.2
16.2
387.88
19.39
3294
PM10
0.1
0.1
0.1
0.08
0.08
14
PM2.5
0.1
0.1
0.1
0.08
0.08
14
NOx
0.7
0.6
0.6
0.76
0.76
129
CO
3.4
2.8
2.8
3.46
3.46
588
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
2077
1730
87
2077
104
Toluene
1879
1566
78
1879
a-1
Ethylbenzene
127
106
5
127
Xylene
564
28
34
677
677
n -Hexane
15361
12800
640
15361
768
224 TMP
68
56
3 _
68
3
Section 06 - Reeulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XII.C, D, E, F
Storage tank is subject to Regulation 7, Section XII.C-F
Regulation 7, Section XII.G, C
Storage Tank is not subject to Regulation 7, Section XII.G
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, 8, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is subject to NSPS 0000a (based on construction date after September 18, 201.5
Regulation 8, Part E, MACT Subpart HH
Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
2 of 14
K:\PA\2019\19WE0179.CP1.xlsm
Condensate Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
NA
Does the company use a site specific emissions factor to estimate emissions?
Yes
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? This sample should be considered representative which generally means site -specific and
collected within one year of the application received date. However, if the facility has not been modified (e.g., no new
wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
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
Yes
Section 08 - Technical Analysis Notes
*These tanks receive condensate from a 2 -phase seaprator ("Gas Buster"). A pressurized liquid sample was pulled from the "Gas Buster"on 4/15/19 by Alliance Source Testing at 19psig and 108F. Applicant
modeled flash, working and breathing losses using ProMax, the pressurized liquid sample composition and average operating co nditions of separators.
*A sample collected and analyzed by SPL labs was modeled using ProMax resulting in 7.44 lb/bbl VOC. This sample was collected from a separator at 20 psig 122F, on 2/4/19.
LT environmental submitted a new sample analyses collected and analyzed by Alliance Source Testing collected on 4/15/19 from separator at 19 psig and 108F. The Promax resulted in 0.819 lb/bbl VOC. The
more recent sample analysis is being used to develop the emission factors and limits used in this permit. I was able the cl osely replicate the ProMax results from either pressurized liquid sample using the
software. Therefore, the variation in the sample analyses may be based on sample integrity. The more recent analysis provided by Alliance Source Testing includes a phase diagram of the pressurized liquid
with the observed field conditions of the pressurized sample plotted. The diagram indicates that the pressurized liquid sample pressure is within 12% of the calculated bubble point pressure based on
sample composition. Although there is no published Division guidance on acceptable difference for pressurized liquids analy ses used in conjunction with a process simulator, PS Memo 17-01 indicates that
a difference of +/- 30% is acceptable demonstration of sample integrity for sources using Flash liberation analysis. Therefore, it has been deteremined that the submitted bubble point analysis supports the
assumption that the hydrocarbon sample was obtained correctly in the field and has not been compromised prior to testing.
Based on the discussion above I will include an initial sampling requirement to obtain a new site -specific pressurized liquid sample to verify compliance with the emission factors used in this permit. This was
discussed with the operator who is confident that the most recent sample is representative and agrees to the initial sampling requirement.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
001
Process # SCC Code
01
4-04-003-11 Fixed Roof Tank, Condensate, working+breathing+flashing losses `' `"l^ "."-"M
Pollutant
PM10
PM2.5
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Uncontrolle
d Emissions
Factor
0.00
0.00
0.04
19.5
0.17
0.05
0.05
0.00
0.02
0.39
0.00
Control % Units
0
0
0
95
lb/1,000 gallons condensate
lb/1,000 gallons condensate
lb/1,000 gallons condensate
lb/1,000 gallons condensate
0 lb/1,000 gallons condensate
95 lb/1,000 gallons condensate
95 lb/1,000 gallons condensate
95 lb/1,000 gallons condensate
95 lb/1,000 gallons condensate
95 lb/1,000 gallons condensate
95 lb/1,000 gallons condensate
throughput
throughput
throughput
throughput
throughput
throughput
throughput
throughput
throughput
throughput
throughput
3 of 14 K:\PA\2019\19WE0179.CP1.xlsm
Condensate Tank Regulatory Analysis Worksheet
Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements
Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo OS -0l Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than S 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 II.D.1.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Source requires a permit
Colorado Regulation 7, Section XII.C-F
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station?
3. Is this storage tank located upstream of a natural gas processing plant?
Storage tank is subject to Regulation 7, Section XiI.C-F
Yft%
No
V
Yes
Yes
Yes:
Section XII.C.1 — General Requirements for Air Pollution Control Equipment — Prevention of Leakage
Section XII.C.2 — Emission Estimation Procedures
Section XII.D— Emissions Control Requirements
Section XII.E — Monitoring
Section XII.F — Recordkeeping and Reporting
Colorado Regulation 7. Section XII.G
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at a natural gas processing plant?
3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC?
Storage Tank Is not subject to Regulation 7, Section XII.G
Yes
No
Section XII.G.2 - Emissions Control Requirements
Section XII.C.1 — General Requirements for Air Pollution Control Equipment — Prevention of Leakage
Section XII.C.2 — Emission Estimation Procedures
Colorado Regulation 7. Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant?
3. Is this condensate storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions` of this storage tank equal to or greater than 6 tons per year VOC?
Storage tank Is subject to Regulation 7, Section XVII, B, C.1 & C.3
Section XVII.B —General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XV►I.C.1- Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5. Does the condensate storage tank contain only "stabilized" liquids?
Storage tank is subject to Regulation 7, Section XVII.C.
2
Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) ("472 BBLsj?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 (10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer2 as defined in 60.11lb?
3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984?
4. Does the tank meet the definition of "storage vessel"3 in 60.111b?
5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.111b?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate In excess of 204.9 kPa ["29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or
b. The design capacity is greater than or equal to 151 m3 [-950 BBL] and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.110b(b))?; or
c. The design capacity is greater than or equal to 75 M3 ["472 BBLJ but less than 151 m3 (950 BBLJ and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))?
No
Yes
Yes
Y
Source Requires an APEN. Go to the next question
Go to next question
Source Requires a permit
Continue - You have indicated the site attainment status on the project summary sheet.
Continue - You have indicated the facility type on the project summary sheet.
Source is subject
Continue - You have determined facility attainment status on the Project Summary sheet.
Storage Tank is not subject to Regulation 7, Section XII.G - You have indicated facility type on project summary sheet.
Continue - You have indicated the source category on the Project Summary sheet.
Go to the next question - You have indicated facility type on project summary sheet.
Go to the next question
Source is subject to parts of Regulation 7, Sections XVII.B&C. Go to the next question
Source is subject to all provisions of Regulation 7, Section XVII, Subsections B & C
Storage Tank is not subject NSPS Kb - The storage vessel capacity is below the applicable threshold.
Storage Tank Is not subject to NSPS Kb
Subpart A, General Provisions
§60.112b - Emissions Control Standards for VOC
§60.113b - Testing and Procedures
§60.115b - Reporting and Recordkeeping Requirements
§60.116b - Monitoring of Operations
40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions? from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430?
5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH?
Storage Tank is not subject to NSPS 0000 _
Yes
Nu
No
Yes
Subpart A, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§60.5395(g) - Notification, Reporting and Recordkeeping Requirements
460.5416(c) - Cover and Closed Vent System Monitoring Requirements
§60.5417 - Control Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even
if potential VOC emissions drop below 6 tons per year)
40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities
1. Is the storage tank 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
b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))?
2. Is the tank located at a facility that is major' for HAPs?
3. Does the tank meet the definition of "storage vessel"4 in 63.761?
4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
Storage rank is not subject to MACE HH
Subpart A, General provisions per 563.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitoring
§63.774 - Recordkeeping
§63.775 - Reporting
No
Yes
No
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RAG requirements.
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
Continue - You have indicated the source category on the Project Summary sheet.
Storage Tank is not subject NSPS 0000 - This tank was constructed outside of the applicability dates.
Continue - You have indicated the source category on the Project Summary sheet.
Storage Tank is not subject MACT HH - There are no MACT HH requirements for tanks at area sources
Produced Water Storage Tank(s) Emissions Inventory
002 Produced Water Tank
Facility AIRs ID:
123
County
A02C
Plant
002
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Two (2) 400 barrel fixed roof produced water storage vessels connected via liquid manifold.
Enclosed Flare
95
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Produced Water Throughput =
319,047 Barrels (bbl) per year
Actual Produced Water Throughput While Emissions Controls Operating =
Requested Permit Limit Throughput =
382,885 Barrels (bbl) per year
Requested Monthly Throughput =
32519 Barrels (bbl) per month
Potential to Emit (PTE) Produced Water
Throughput=
Secondary Emissions - Combustion Device(s)
Heat content of waste gas =
Volume of waste gas emitted per BBL of liquids
produced =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
382,885 Barrels (bbl) per year
1028 Btu/scf
2.66398527 scf/bbl
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Yes
874 MMBTU per year
1,049 MMBTU per year
1,049 MMBTU per year
Emission Factors
Produced Water Tank
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
Pollutant
(Produced Water
Throughput)
(Produced
Water
Throughput)
VOC
0.0504
0.0025
Site Specific E.F. (includes flash)
Benzene
0.0000
0.0000
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Toluene
0.0000
0.0000
Ethylbenzene
0.0000
0.0000
Xylene
0.0000
0.0000
n -Hexane
1.73E-03
8.64E-05
224 TMP
0.0000
0.0000
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (lb/bbl)
(waste heat
combusted)
(Produced
Water
Throughput)
PM10
0.0075
0.0000
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
0.0000
NOx
0.0680
0.0002
CO
0.3100
0.0008
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
9.7
3.0
0.4
9.65
0.43
32
PM10
0.0
0.0
0.0
0.0
0.0
1
PM2.5
0.0
0.0
0.0
0.0
0.0
1
NOx
0.0
0.0
0.0
0.0
0.04
6
CO
0.2
0.1
0.1
0.2
0.16
28
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
12
10
1
12
1
Toluene
9
7
0
9
0
Ethylbenzene
0
0
0
0
0
Xylene
3
2
0
3
0
n -Hexane
662
551
23
662
33
224 TMP
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
319,047
Regulation 3, Parts A, B
Source requires APEN, is permit exempt
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, 6, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart OOOO
Storage Tank is not subject to NSPS OOOO
(See regulatory applicability worksheet for detailed analysis)
6 of 14
K:\PA\2019\19W E0179.CP1.xlsm
Produced Water Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn
at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered
representative which generally means site -specific and 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.
Yes
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing.
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
Section 08 - Technical Analysis Notes
*Applicant pulled a pressurized liquid sample of produced water from the inlet 3 -phase HP separators at 289 psig 90F and flash liberation analysis was performed (sampled 2/4/19). Applicant used
ProMax to recombine the measured flash gas composition with water upstream of the tank and subsequently modeled flash, working and breathing losses from the tank. The FLA (correctly analyzed
using GPA 2286) reports a GWR of 2.83 ft^3/bbl. This value must be converted to scf/bbl using the ideal gas law as follows:
V1 = actual laboratory conditions (no data was provided, so the below values are approximate)
V2 = Standard conditions
V2 = P1*V1*T2/(T1*P2) = (12.12 psi)*(2.83 scf/bbl)*(520 deg R) / ((510R)*(14.696 psi)) = 2.3797 scf/bbl
Comparing this value to the value calculated from ProMax (flash + w&B) = 2.64192 scf/bbl. Therefore, I will assume the calculation methodology in ProMax is providing a gas -to -water -ratio result that is
at least conservative compared to considering the flash gas only (there is no prescribed methodology for calculating working and breathing losses for produced water tanks). It should further be noted
that in order to arrive at the lb/bbl factor from the GWR, the following equation may be used:
lb VOC/bbl = (VOC wt%) *MWgas * GWR / 379. Using the liberated gas properties from the lab provided gas analysis:
lb VOC/bbl = (21.754%) * (27.117 lb/Ibmol) * 2.3797 scf/bbl / 379 scf/lbmol = 0.0370 lb/bbl.
The resulting emission factor from the ProMax report is 0.0504 lb/bbl. Therefore, I will move forward with the results from the ProMax report.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
002
Process #
01
SCC Code
4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses
Pollutant
PM10
PM2.5
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Uncontrolled
Emissions
Factor
0.00
0.00
0.00
1.2
0.02
0.00
0.00
0.00
0.00
0.04
0.00
Control %
0
0
0
95
0
95
95
95
95
95
95
Units
Ib/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
Ib/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
liquid throughput
liquid throughput
liquid throughput
liquid throughput
liquid throughput
liquid throughput
liquid throughput
liquid throughput
liquid throughput
liquid throughput
liquid throughput
7 of 14 K:\PA\2019\19WE0179.CP1.xlsm
Produced Water Storage Tank Regulatory Analysis Worksheet
Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb.
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source is in the Non -Attainment Area
Yes
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Source requires APEN, is permit exempt
Yes
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station3 or natural gas processing plant?
3. Is this produced water storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions4 of this storage tank equal to or greater than 6 tons per year VOC?
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Yes
No
Yes
Yes
Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1 - Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply.
Yes
No
Storage tank is subject to Regulation 7, Section XVII.C.2
Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions2 from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430?
Yes
No
No
Storage Tank is not subject to NSPS OOOO
Subpart A, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§60.5395(g) - Notification, Reporting and Recordkeeping Requirements
§60.5416(c) - Cover and Closed Vent System Monitoring Requirements
§60.5417 - Control Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2)
even if potential VOC emissions drop below 6 tons per year]
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements.
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
Source Req
Source is Al
Source is Al
Continue -'
Continue -'
Go to the n
Source is st
Source is si
Continue -'
Storage Tar
Storage Tar
Hydrocarbon Loadout Emissions Inventory
003 Liquid Loading
Facility AIRs ID:
123
County
A02C
Plant
003
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Collection Efficiency:
Control Efficiency:
Loadout of codensate to tank trucks during LACT unit downtime.
Enclosed Flare
Requested Overall VOC & HAP Control Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded =
Yes
100.0
95
78,928 Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating =
78,928 Barrels (bbl) per year
Requested Permit Limit Throughput =
94,714 Barrels (bbl) per year Requested Monthly Throughput =
Barrels (bbl) per month
Potential to Emit (PTE) Volume Loaded =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas =
Volume of waste gas emitted per year =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
94,714 Barrels (bbl) per year
2732.65 Btu/scf
156640 scf/year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility
being permitted?
Loading Loss Equation
L = 12.46*S*P*M/T
230,000.00
357 MMBTU per year
428 MMBTU per year
428 MMBTU per year
ne stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors.
Factor
Meaning
Value
Units
Source
S
Saturation Factor
0..5
s. �f,,��
AP -42 Chapter 5.2 Table 5.24 Submerged Loading: Dedicated Normal Service (S=0.6)
P
True Vapor Pressure
7.31
psia
AP -42 Table 7.1-2 (RVP 11.5)
M
Molecular Weight of Vapors
48.43
Ib/Ib-mol
Based on molecular weight of Working vapors estimated in ProMax simulation
T
Liquid Temperature
526
Rankine
L
Loading Losses
5.031707587
lb/1000 gallons
0.211331719 lb/bbl
Component
Mass Fraction
Emission Factor
Units
Source
Benzene
1.66E-03
0.000350811
lb/bbl
ProMax W&B losses stream composition
Toluene
1.46E-03
0.000308544
lb/bbl
ProMax W&B losses stream composition
Ethylbenzene
1.06E-04
2.24012E-05
lb/bbl
ProMax W&B losses stream composition
Xylene
7.29E-04
0.000154061
lb/bbl
ProMax W&B losses stream composition
n -Hexane
1.69E-02
0.003571506
lb/bbl
ProMax W&B losses stream composition
224 TMP
0
0
lb/bbl
ProMax W&B losses stream composition
Emission Factors
Hydrocarbon Loadout
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Volume Loaded)
(Volume
Loaded)
VOC
0.2113
0.010&
Site Specific - AP -42: Chapter 5.2, Equation 1
Benzene
3.51E-04
1.75E-05
Toluene
3.09E-04
1.54E-05
Ethylbenzene
2.24E-05
1.12E-06
Xylene
1.54E-04
7.70E-06
n -Hexane
3.57E-03
1.79E-04
224 TMP
0.00E+00
0.00E+00
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (lb/bbl)
(waste heat combusted)
(Volume
Loaded)
PM10
0.0075
3.37E-05
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (SOx)
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
3.37E-05
SOx
0.0006
2.66E-06
NOx
0.0680
3.07E-04
CO
0.3100
1.40E-03
9of14
K:\PA\2019\19WE0179.CP1.xlsm
Hydrocarbon Loadout Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.01
0.01
0.01
0.01
0.01
2
10.01
8.34
0.42
10.01
0.50
85
0.07
0.06
0.06
0.07
0.07
11
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
28
1
33
2
29
24
1
29
1
2
2
0
2
0
15
12
1
15
1
338
282
14
338
17
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Not enough information
RACT - Regulation 3, Part B, Section III.D.2.a
The loadout must be operated with submerged fill to satisfy RACT.
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
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
Section 08 - Technical Analysis Notes
*Loadout vapor heat content is based on the working and breathing stream in Pro Max.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point U
003
Process tt
01
SCC Code
4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6)
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons transferred
PM2.5 0.00 0 lb/1,000 gallons transferred
SOx 0.00 0 lb/1,000 gallons transferred
NOx 0.01 0 lb/1,000 gallons transferred
VOC 5.0 95 lb/1,000 gallons transferred
CO 0.03 0 lb/1,000 gallons transferred
Benzene 0.01 95 lb/1,000 gallons transferred
Toluene 0.01 95 lb/1,000 gallons transferred
Ethylbenzene 0.00 95 lb/1,000 gallons transferred
Xylene 0.00 95 lb/1,000 gallons transferred
n -Hexane 0.09 95 Ib/1,000 gallons transferred
224 TMP 0.00 95 lb/1,000 gallons transferred
10 of 14 K:\PA\2019\19WE0179.CP1.xlsm
Hydrocarbon Loadout Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source Is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)?
3. Is the loadout operation loading less than 10.000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.0.3)?
Yr,u have indicated that source is in the Non Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. 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 II.D.2)?
Not enough information
Yes
Yes
NA
NA
No
Yes
7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)?
The loadout must be operated with submerged fill to satisfy RACT.
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," "may, " "should," and 'can," is intended to
describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and "required" are intended to descnbe controlling requirements under the terms of the Clean Air Act and Air Quality
Control Commission regulations, but this document does not establish legally binding requirements in and of itself
No
Go to next question.
Go to the next question
Go to next question
The loadout requires a permit
The loadout must be operated with submerged fill to satisfy RACT.
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
SRC Energy, Inc.
County AIRS ID
123
Plant AIRS ID
A02C
Facility Name
Harvesters State 7-15 Pad
History File Edit Date
4/11/2019
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons per year)
EMISSIONS With Controls (tons er year
POINT
AIRS
ID
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
0.0
0.0
0.0
0.0
0.0
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
New Facility - No Previous Total
Previous
Permitted Facility total
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
001
19WE0179
Condensate Tanks (6)- 400 bbl
0.8
387.9
3.5
10.1
0.8
19.4
3.5
0.5
New CP
002
19WE0180
Produced Water Tanks
0.0
9.7
0.2
0.3
0.0
0.5
0.2
0.0
New CP
003
19WE0181
Hydrocarbon Liquid Loadout
0.0
10.0
0.5
0.2
0.0
0.5
0.5
0.0
New CP
004
GP02
Caterpillar G3406TA (ENG-1)
0.2
0.2
40.9
1.7
40.9
0.3
0.2
0.2
2.4
1.7
4.7
0.3
New GP02
005
GP02
PSI 11.1L
0.2
0.2
26.1
1.8
43.9
0.4
0.2
0.2
2.7
1.9
5.3
0.4
New GP02
006
GP02
PSI 21.1L
0.4
0.4
43.9
3.7
73.9
0.6
0.4
0.4
3.8
3.8
8.0
0.6
New GP02
007
GP02
Cummins GTA855
0.1
0.1
26.3
1.5
6.3
0.3
0.1
0.1
2.2
1.6
4.4
0.3
New GP02
008
GP02
Caterpillar G3516J
0.0
0.0
6.7
12.1
32.4
6.5
0.0
0.0
6.7
6.7
2.3
1.9
New GP02
0.0
0.0
0.0
0.0
APEN Exempt/Insignificant Sources
0.0
0.0
Heaters (25)
0.4
0.4
0.0
5.2
0.29
4.4
0.0
0.4
0.4
0.0
5.2
0.3
4.4
0.0
From Form APCD-102
Fugitive Emissions
0.2
18.6
0.2
3.9
From
Form APCD-102
ECD Pilot
0.02
0.09
0.02
0.09
FACILITY TOTAL
1.3
1.3
0.0
0.0
149.9
428.7
0.2
206.0
37.3
1.3
1.3
0.0
0.0
23.8
36.3
0.2
33.2
7.8
VOC: Syn Minor (PSD, NANSR and OP)
NOx: Syn Minor (NANSR and OP)
CO: Syn Minor (OP), True Minor (PSD)
HAPS: Minor
Permitted Facility Total
0.9
0.9
0.0
0.0
144.7
428.4
0.0
201.5
18.6
0.91
0.9
0.0
0.01
18.5
36.1 1
0.01
28.7
3.9
Excludes units exempt from permits/APENs
(A) Change
in Permitted Emissions
0.9
0.9
0.0
0.0
18.5
36.1
0.0
28.7
Pubcom required on new synthetic minor limit
(point 001) Modeling not required based on
Division guidance.
Total VOC Facility Emissions (point and fugitive)
(A) Change in Total Permitted VOC emissions (point and fugitive)
36.5
Facility
_Project
is eligible for GP02 because < 90 tpy
emissions not less than 25 tpy
36.1
Note 1
Note 2
Page 12 of 14
Printed 6/21/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name SRC Energy, Inc.
County AIRS ID 123
Plant AIRS ID A02C
Facility Name Harvesters State 7-15 Pad
Emissions - uncontrolled
(lbs
per year)
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
MeOH
224 TMP
H2S
TOTAL
(tpy)
0
0
0
0
0
0
0
0
0
0
0
0
0.0
!Previous
FACILITY
TOTAL
001
19WE0179
Condensate
Tanks (6)- 400 bbl
2077
1879
677
15361
58
10.1
002
19WE0180
Produced
Water Tanks
12
9
662
0.3
003
19WE0181
Hydrocarbon
Liquid
Loadout
33
29
1
337
0.2
004
GP02
Caterpillar
G3406TA
(ENG-1)
363
49
47
28
54
0.3
005
GP02
PSI
11.1L
484
66
62
37
72
0.4
006
GP02
PSI
21.1L
814
111
104
63
122
0.6
007
GP02
Cummins GTA855
381
52
49
29
47
0.3
008
GP02
Caterpillar
G3516J
11450
752
462
40
223
6.5
0.0
0.0
APEN
E
0.0
Heaters (25)
0.0
TOTAL
(tpy)
6.7
0.5
0.4
1.2
1.0
0.1
0.3
8.2
0.3
0.0
0.0
0.0
18.6
*Total
Reportable
= all
HAPs where
uncontrolled
emissions > de
minimus values
Red Text: uncontrolled emissions < de minimus
Emissions with
controls
(lbs
per year)
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
224 TMP
H2S
TOTAL (tpy)
MeOH
0
0
0
0
0
0
0
0
0.0
0
0
0
0
IPrevious FACILITY
TOTAL
001
19WE0179
Condensate Tanks
(6)- 400 bbl
104
94
6
34
768
0.5
3
002
19WE0180
Produced
Water Tanks
0.24
0.18
0.008
0.06
13.24
0.0
003
19WE0181
Hydrocarbon
Liquid
Loadout
1.66
1.46
0.11
0.73
16.87
0.0
004
GP02
Caterpillar
G3406TA (ENG-1)
363
49
47
28
0.3
54
005
GP02
PSI
11.1L
484
66
62
37
72
0.4
006
GP02
PSI
21.1L
814
111
104
63
122
0.6
007
GP02
Cummins GTA855
381
52
49
29
47
0.3
008
GP02
Caterpillar
G3516J
2290
752
462
40
223
1.9
0.0
13
19WE0179.CP1.xlsm
6/21/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name SRC Energy, Inc.
County AIRS ID 123
Plant AIRS ID A02C
Facility Name Harvesters State 7-15 Pad
0.0
APEN 1
0.0
Heaters (25)
0.0
TOTAL (tpy)
2.2
0.5
0.4
0.2
0.0
0.0
0.0
0.4
0.3
0.0
0.0
0.0
3.9
14
.19WE0179.CP1.xlsm_ 6/-21/-2019
COLORADO
Air Pollution Control Division
Department of Public Heath & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0179
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Equipment or activi
Issuance: 1
SRC Energy, Inc.
Harvesters State 7-15 Pad
123/A02C
SWNE SEC 15 T6N R66W
Weld County
Well Production Facility.
subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK 1-6
001
Six (6) 400 barrel fixed roof condensate
storage vessels connected via liquid
manifold.
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
Page 1 of 10
COLORADO
Air Pollution Control Division
Department of Pubic Health Ei Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
in revocation of the permit. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division 'as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter' issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
TK 1-6
001
-
-
19.4
3.5
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Compliance with the annual 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 actual emissions each month and keep a
compliance record on site or at a local field office with site responsibility for Division review.
7. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
TK 1-6
001
Enclosed Flare
V0C and HAP
Page 2 of 10
COLORADO
Air Pollution Control Division
Department of Pubic Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
TK 1-6
001
Condensate throughput
947,139 barrels
The owner or operator shall monitor monthly process rates based on the calendar month.
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 basedon 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.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. 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)
10. This source is subject to the odor requirements of Regulation Number 2. ('State only
enforceable)
11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all
applicable requirements of Section XII and, specifically, shalt:°
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for condensate storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Section XII.C.) (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:
Page 3 of 10
COLORADO
Air Pollution Control Division
Department of Pubic Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate 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 except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.C.1.d. and maintain records of the inspections for a period of two years, made available
to the Division upon request. This control requirement must be met within 90 days of the date
that the storage tank commences operation.
14. The storage tanks covered by this, permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING a MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (OEM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the, requirements of this permit. Revisions to
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen -minute period during normal
operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16)
17. The owner or operator shall complete site specific sampling including a compositional analysis
of the pre -flash pressurized condensate routed to these storage tanks and, if necessary for
emission factor development, a sales oil analysis to determine RVP and API gravity. Testing
shall be in accordance with the guidance contained in PS Memo 05-01. Results of testing shall
be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants using
Division approved methods. Results of site -specific sampling and analysis shall be submitted to
the Division as part of the self -certification and used to demonstrate compliance with the
emissions factors chosen for this emissions point.
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
Page 4 of 10
COLORADO
Air Pollution Control Division
Department of Pubsc F3eatth b Envi?uriinent
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
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.
20. The requirements of Colorado Regulation No. 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
21. 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.
22. 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 -
Page 5 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
23. 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.
24. 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.
25. 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 shalt; constitute a rejection of the entire permit
and upon such occurrence, thispermit 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.
26. 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.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Bradley Eades
Permit Engineer
Page 6 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to SRC Energy, Inc.
New synthetic minor production facility
Page 7 of 10
COLORADO
Air Pollution Control Division
Department of Public Heath b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits -stated in this
permit as soon as possible, but no later than noon of the next working day, followed by Written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
ontrolled
Emissions ..
(lb/yr)
Controlled,
Emissions.'
(lb/yr)
Benzene
71432
.077
104
001
Toluene
108883
1,879
94
Ethylbenzene
100414
127
6
Xylenes
1330207
677
34
n -Hexane
110543
15,361
768
2,2,4-
Trimethylpentane
540841
68
3
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
0.0016
0.0016
AP -42 Chapter
13.5
CO
0.0071
0.0071
Page 8 of 10
COLORADO
Air Pollution Control Division
Department of Fubitc Heath b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
VOC
0.8191
0.0410
ProMax
71432
Benzene
2.19E-03
1.10E-04
108883
Toluene
1.98E-03
9.92E-05
1330207
Xylene
7.15E-04
3.57E-05
110543
n -Hexane
1.62E-02
8.11E-04
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Combustion emissions of NOx and CO are based on factors in AP -42 Chapter 13.5 and a
waste gas higher heating value of 2,436 btu/scf.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised ,APEN shall be submitted no later than 30 days before the,five-year ,term expires.; Please
refer, to=the Most recent annual fee invoice to determine the APEN expiration date for=each,
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at(303)-642-3150.;
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requiremen'
S?
atus
Operating Permit
Synthetic Minor Source of:
VOC, NOx, CO
Synthetic Minor Source of:
VOC, NOx
Synthetic Minor Source of:
VOC
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
NANSR
PSD
MACT HH
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
Page 9 of 10
COLORADO
Air Pollution Control Division
Department of Public Heath b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 10 of 10
k c- 3i3 t c
(2-e.x."-, 006 /9
Condensate Storage Tank(s) APEN
Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, 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 and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/pacific/cdphe/air-permits.
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: 19WE0179
AIRS ID Number: 123 / A02C. / 001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 Administrative Information
Company Name': SRC Energy, Inc.
Site Name: Harvesters State 7-15 Pad
Site Location: SWNE Sec. 15 T6N R66W
Mailing Address:
(Include Zip Code) 5400 VV. 11th Street, Suite C
Greeley, CO 80634
Site Location
County: Weld
NAICS or SIC Code: 211111
Contact Person:
Phone Number:
E -Mail Address2:
Brad Rogers
(970) 475-5242
brogers@srcenergy.com
I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 1
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Permit Number: 19WE0179
AIRS ID Number: 123 / Ao2C / 001
[Leave blank unless APCD has already assigned a permit ft and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
❑✓ Request coverage under traditional construction permit --
O Request coverage under a General Permit
0 GP01 0 GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment 0 Change company name3
❑ Change permit limit 0 Transfer of ownership4 ❑ Other (describe below)
- OR
• APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) .
Additional Info Et Notes: New analysis performed. Combustor pilot light emissions have been added to
the requestedcontrolledemissions for_NOx and CO — -
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: Storage of condensate from production wells
Company equipment Identification No. (optional): TK 1-6
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 11/17/2018
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week 52
❑✓ Exploration If Production (ECtP) site
weeks/year
❑ Midstream or Downstream (non EaP) site
Will this equipment be operated in any NAAQS nonattainment area?
o
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
•
Yes
•
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
O
Yes
■
No
If "yes", identify the stock tank gas -to -oil ratio:
1.681E-03
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
•
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
O
■
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
21
cai oaAGt�
V-Enezerunant
TK
6
2400
Permit Number:
19WE0179
AIRS ID Number: 123 / A02C / 001
[Leave blank unless APCD has already assigned a permit # and MRS ID]
Section 4 - Storage Tank(s) Information
fnualAmdunl
X61 iedr
ueste<
�rinuaf Permit
hbtlyearj
.s,
Co
ensate
ougg
789,275.80
947,138.50
From what year is the actual annual amount?
2019
Average API gravity of sales oil: 42.9 degrees
❑ Internal floating roof
Tank design: ❑r Fixed roof
RVP of sales oil: 6.7
❑ External floating roof
nstaiCation Date of Most
lecen Storage vessel fri'
torajeTank (manthlyearj
11/2018
11/2018
r
05 - 123 - 46374
Y i his:•Stotge'Tan
ank Bati
Harvesters State 32N -16A -M
E'aP SitespOn
INlei ly.,
eported
El
05 - 123 - 46372
Harvesters State 4C -16-M
05 - 123 - 46375
Harvesters State 31 C -16-M
05 - 123 - 46358
Harvesters State 4N -16C -M
05 - 123 - 46373
Harvesters State 5N -16B -M
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
40.49123, -104.762506
Aerator Stack•.
1�4 ���
,sc3VI r" 02,Height Above
gun, eve eta
Temp
o�
( �-.
�
Flow Rate
CFM.v
. � (A 3�._
Velocity
t sec
�ff }
Indicate the direction of the stack outlet: (check one)
El Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
El Square/rectangle
El Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 3
7•LvA, R A.6
11'�6i;,
Arararim
Permit Number: 19WE0179
AIRS ID Number: 123 / A02C / 001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
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.
Vapor
❑ Recovery
Unit (VRU):
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented): %
❑ Combustion
Device:
Pollutants Controlled: VOCs and HAPs
Rating: 300.78 MMBtu/hr
Type: Enclosed Combustor Make/Model: (4) I ES 96"
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: 1000°F Waste Gas Heat Content: 2 436 Btu/scf
MMBtu/hr
h r
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating:
O _ Closed Loop System
❑ Other:
Description of the closed loop system: —
Pollutants Controlled:
Description:
Control Efficiency Requested:
0.061
Section 7 - Gas/Liquids Separation Technology Information (E&tP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 19 psig
Describe the separation process between the well and the storage tanks:
(12) 36" 3 -phase horizontal separators, (6) 36" 2 -phase vertical separators and (1) 60" gas busters
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 4
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Permit Number: 19WE0179
AIRS ID Number: 123 /A02C / 001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
- If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction):
VOC
Enclosed Combustor
Rec(tieste I
cienz ;,
reduction to emisSTDn
95%
NOx
CO
HAPs
Enclosed Combustor
95%
Other:
From what year is the following reported actual annual emissions data? 201 9
Ibs/bbl
323.23
16.16
387.88
19.39
VOC
0.819
ProMax
utartl
s ans InVentol
-NOS
CO
0.068
Ib/MMBtu
AP -42
N/A
6.172E-01
N/A - -
- 7.606E-01 --
0.310
Ib/MMBtu
AP -42
N/A
2.81
N/A
3.46
2.192E-03
Ibs/bbl
ProMax
1,730.09
86.50
Benzene
71432
Cnterr 4Rep
olutar fmtssons-1nventn
ni is
mission'
Toluene
108883
1.984E-03
Ibs/bbl
ProMax
1,565.92
78.30
Ethylbenzene
100414
1.342E-04
Ibs/bbl
ProMax
105.92
5.30
Xylene
1330207
7.149E-04
Ibs/bbl
ProMax
564.25
28.21
n -Hexane
110543
1.622E-02
Ibs/bbl
ProMax
12,800.28
640.01
2,2,4-
Trimethylpentane
540841
7.152E-05
Ibs/bbl
ProMax
56.45
2.82
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
5I
Permit Number: 19WE0179
AIRS ID Number: 123 /A02O /001
[Leave blank unless APCD. has already assigned a permit # and AIRS ID)
Section 9 - Applicant Certification
I hereby certify that ail information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
Signature of Legally Authorized Person (not a vendor or consultant)
Brad Rogers
Name (print)
(it/ Z4 tcic)
Date
Huth and Environmental Manager
Title
Check the appropriate box to request a copy of the:
El 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 $1.91.13 and the General Permit
registration fee of $31250, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-81
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) 692-31.48
APCD Main Phone Number
(303) 692-3150
Or visit the APCD. website at:
https://www.colorado.gpv/cdphe/apcd
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 7/2018
COLORADO
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