HomeMy WebLinkAbout20191839.tiffPub1� c Plev‘e
COLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
May 8, 2019
Dear Sir or Madam:
RECEIVED
MAY 1 3 2019
WELD COUNTY
COMMISSIONERS
On May 9, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Summit
Midstream Niobrara, LLC - Brahma Compressor Station. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
'Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health 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
Cr.; PLGTP),1%L-U O,
PW(Lki CHicYi)
5120J►Ct 5/13/1CA
2019-1839
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Summit Midstream Niobrara, LLC - Brahma Compressor Station - Weld County
Notice Period Begins: May 9, 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: Summit Midstream Niobrara, LLC
Facility: Brahma Compressor Station
Compressor Station
SW SEC 28 T12N R63W
Weld County
The proposed project or activity is as follows: Tanks, Dehy, Engines, Blowdowns associated with natural gas
compressor station
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
The 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 19WE0169 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:
Timothy Sharp
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLOFiADd
tto-annacmuimnreana
Summary of Preliminary Analysis - NG RICE
Company Name
Facility Name
Facility Location
Facility Equipment ID
Summit Midstream Niorbrara, LLC
Brahma Compressor Station
SW SEC28 T12N R63W
GE -01
Permit No.
AIRS
Review Date
Permit Engineer
19WE0169
123/A029/005
03/17/2019
Timothy Sharp
Requested Action
Issuance No.
New permit/newly reported emission
1
Emission Point Description
One (1) Caterpillar, Model G3512B, Serial Number To Be Determined, natural gas -fired, turbo -charged, 4SLB reciprocating
internal combustion engine, site rated at 1035 horsepower. This engine shall be equipped with an oxidation catalyst and air -
fuel ratio control This emission unit is used for natural gas compression.
Natural Gas Consumption
Requested (mmscf/yr)
58.10
Requested (mmscf/m)
4.93
Fuel Heat Value (btu/scf)
1134
BSCF (Btu/hp-hr)
7268
Emission Factor Sources
Hours of Operation
PTE Calculated at (hpy)
Permit limits calculated at (hpy)
8760
8760
Uncontrolled
Controlled
NOx
manufacturer
manufacturer
VOC
manufacturer
manufacturer
CO
manufacturer
manufacturer
Formaldehyde
manufacturer
manufacturer
SOX
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
TSP
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
PM10
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
PM2.5
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
Other Pollutants
Point Summary of Criteria Emissions (t
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
NOx
5.0
5.0
5.0
0.0%
VOC
13.8
7.0
13.8
49.0%
CO
26.4
1.8
26.4
93.0%
SOx
0.0
0.0
0.0
0.0%
TSP
0.3
0.3
0.3
0.0%
PM10
0.3
0.3
0.3
0.0%
PM2.5
0.3
0.3
0.3
0.0%
Total HAPs*
0.0
0.0
5.8
73.2%
*Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de
minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.
Point Summary of Hazardous Air Pollutants (lb/yr
HAP Name
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
Formaldehyde
10392
2494
10394
76.0%
Acetaldehyde
551
275
551
50.0%
Acrolein
339
169
339
50.0%
Methanol
165
50.0%
n -Hexane
*
*
73
50.0%
Benzene
*
*
29
50.0%
Toluene
*
*
27
50.0%
*Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED
UNCONTROLLED is greater than de minimus
Permitting Requirements
Ambient Air Impacts
Source is not required to model based on Division Guidelines/No NAAQS violations expected
Public Comment
Public Comment Required
MACT ZZZZ
-
Reg 7 XVII.E
Standards (g/hp-hr)
NOx: NA CO: NA VOC: NA
Reg 7 XVI.B (Ozone NAA
requirements) applies?
No
MACT ZZZZ (area source)
Is this engine subject to MACT ZZZZ area
source requirements?
Yes
NSPS JJJJ
Is this engine subject to NSPS JJJJ?
Yes
Note: JJJJ requriements are not currently included as permit conditions because the reg has not
been adopted into Reg 6.
Comments/Notes
-Initial test required to verify emission factor.
Summary of Preliminary Analysis - NG RICE
Company Name
Facility Name
Facility Location
Facility Equipment ID
Summit Midstream Niorbrara, LLC
Brahma Compressor Station
SW SEC28 T12N R63W
CE -01
Permit No.
AIRS
Review Date
Permit Engineer
19WE0169
123/A029/006
03/17/2019
Timothy Sharp
Requested Action
Issuance No.
New permit/newly reported emission
1
Emission Point Description
One (1) Caterpillar, Model G3608, Serial Number XH70092, natural gas -fired, turbo -charged, 4SLB reciprocating internal
combustion engine, site rated at 2500 horsepower. This engine shall be equipped with an oxidation catalyst and air -fuel ratio
control This emission unit is used for natural gas compression.
Natural Gas Consumption
Requested (mmscf/yr)
131.00
Requested (mmscf/m)
11.13
Fuel Heat Value (btu/scf)
1134
BSCF (Btu/hp-hr)
6757
Emission Factor Sources
Hours of Operation
PTE Calculated at (hpy)
Permit limits calculated at (hpy)
8760
8760
Uncontrolled
Controlled
NOx
manufacturer
manufacturer
VOC
manufacturer
manufacturer
CO
manufacturer
manufacturer
Formaldehyde
manufacturer
manufacturer
SOX
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
TSP
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
PM10
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
PM2.5
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
Other Pollutants
Point Summary of Criteria Emissions (t
Uncontrolled
Requested
Controlled
Requested
. PTE
Proposed Control
Efficiency
NOx
12.1
12.1
12.1
0.0%
VOC
25.4
17.0
25.3
33.0%
CO
61.3
4.3
61.1
93.0%
SOx
0.0
0.0
0.0
0.0%
TSP
0.7
0.7
0.7
0.0%
PM10
0.7
0.7
0.7
0.0%
PM2.5
0.7
0.7
0.7
0.0%
Total HAPs*
0.0
0.0
7.0
70.7%
*Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de
minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.
Point Summary of Hazardous Air Pollutants (lb/vr
HAP Name
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
Formaldehyde
11148
2675
11105
76.0%
Acetaldehyde
1242
621
1237
50.0%
Acrolein
764
382
761
50.0%
Methanol
371
186
370
50.0%
n -Hexane
*
164
50.0%
Benzene
*
*
65
50.0%
Toluene
*
*
60
50.0%
*Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED
UNCONTROLLED is greater than de minimus
Permitting Requirements
Ambient Air Impacts
Source is not required to model based on Division Guidelines/No NAAQS violations expected (see
details of modeling analysis)
Public Comment
Public Comment Required
MACT ZZZZ
-
Reg 7 XVII.E
Standards (g/hp-hr)
NOx: NA CO: NA VOC: NA
Reg 7 XVI.B (Ozone NAA
requirements) applies?
No
MACT ZZZZ (area source)
Is this engine subject to MACT Z777 area
Yes
source requirements?
NSPS JJJJ
Is this engine subject to NSPS JJJJ?
Yes
Note: JJJJ requriements are not currently included as permit conditions because the reg has not
been adopted into Reg 6.
Comments/Notes
-stack tests are required to verify claimed emission factors.
Summary of Preliminary Analysis - NG RICE
Company Name
Facility Name
Facility Location
Facility Equipment ID
Summit Midstream Niorbrara, LLC
Brahma Compressor Station
SW SEC28 T12N R63W
CE -02
Permit No.
AIRS
Review Date
Permit Engineer
19WE0169
123/A029/007
03/17/2019
Timothy Sharp
Requested Action
Issuance No.
New permit/newly reported emission
1
Emission Point Description
One (1) Caterpillar, Model G3608, Serial Number TBD, natural gas -fired, turbo -charged, 4SLB reciprocating internal
combustion engine, site rated at 2500 horsepower. This engine shall be equipped with an oxidation catalyst and air -fuel ratio
control This emission unit is used for natural gas compression.
Natural Gas Consumption
Requested (mmscf/yr)
131.00
Requested (mmscf/m)
11.13
Fuel Heat Value (btu/scf)
1134
BSCF (Btu/hp-hr)
6757
Emission Factor Sources
Hours of Operation
PTE Calculated at (hpy)
Permit limits calculated at (hpy)
8760
8760
Uncontrolled
Controlled
NOx
manufacturer
manufacturer
VOC
manufacturer
manufacturer
CO
manufacturer
manufacturer
Formaldehyde
manufacturer
manufacturer
SOX
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
TSP
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
PM10
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
PM2.5
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
Other Pollutants
Point Summary of Criteria Emissions (tpy)
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
NOx
12.1
12.1
12.1
0.0%
VOC
25.4
17.0
25.3
33.0%
CO
61.3
4.3
61.1
93.0%
SOx
0.0
0.0
0.0
0.0%
TSP
0.7
0.7
0.7
0.0%
PM10
0.7
0.7
0.7
0.0%
PM2.5
0.7
0.7
0.7
0.0%
Total HAPs*
0.0
0.0
7.0
60.4%
*Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de
minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.
Point Summary of Hazardous Air Pollutants (lb/yr
HAP Name
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
Formaldehyde
11148
2675
11105
76.0%
Acetaldehyde
1242
1242
1237
0.0%
Acrolein
764
764
761
0.0%
Methanol
371
371
370
0.0%
n -Hexane
*
164
0.0%
Benzene
*
*
65
0.0%
Toluene
*
*
60
0.0%
*Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED
UNCONTROLLED is greater than de minimus
Permitting Requirements
Ambient Air Impacts
Source is not required to model based on Division Guidelines/No NAAQS violations expected
Public Comment
Public Comment Required
MACT Z777
#VALUE!
Reg 7 XVII.E
Standards (g/hp-hr)
NOx: NA CO: NA VOC: NA
Reg 7 XVI.B (Ozone NAA
requirements) applies?
No
MACT ZZZZ (area source)
Is this engine subject to MACT ZZZZ area
source requirements?
Yes
NSPS JJJJ
Is this engine subject to NSPS JJJJ?
Yes
Note: JJJJ requriements are not currently included as permit conditions because the reg has not
been adopted into Reg 6.
Comments/Notes
-stack tests are required to verify claimed emission factors.
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Timothy Sharp
Package #: 393317', .,
Received Date: 2/12/2019
Review Start Date: 3/20/2019
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility: P curalGasCompressorStation
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? No
If yes, for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM)
Summit Midstream Niobrara, LLC
123
A029
Brahma Compress.
sw quadrant of Section 28, Township 12n, Range 63wW
Weld County
Section 02 - Emissions Units In Permit Application
Quadrant
Section
Township
Range
63w
SW
28
12n
Ozone (NOx & VOC)
AIRs Point
Emissions Source Type
Equipment Name
Emissions
Control?
Permit 9
Issuance 9
Self Cert
Required?
Action
Engineering
Remarks
001
Condensate Tank
TK-Q1
Yes
19WE0169
1
-
Yes
Permit Initial
Issuance
002
Produced Water Tank
TK02-05
Yes
19WE0169
1
Yes
Permit Initial
Issuance
003
Maintenance Blowdowns
BD -01
No
19WE0169
1
Yes
Permit Initial
Issuance
004
Dehydrator
DU -01
Yes
19WE0169
;'
1
Yes
Permit Initial
Issuance
005
Natural Gas RICE
GE -01
:-- Yes
19WE0169
_
1
a Yes
Permit Initial
' Issuance
006
Natural Gas RICE '
CE -01
: Yes
19WE0169
1
-
Yes
Permit Initial
Issuance.
007
Natural Gas RICE
CE 02
Yes
19WE0169
1
yes
Permit Initial
Issuance
Section 03 - Description of Project
Natural Gas compressor station in the ozone attainment maintenance area.
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Greater than 50 tons per year in an Attainment Area
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? INo
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? No
Is this stationary source a synthetic minor? Yes
If yes, indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ Q ❑ ❑
Title V Operating Permits (OP) O O 2 O ❑ ❑ ❑ O
Non -Attainment New Source Review (NANSR) ❑ ❑
Colorado Air Permitting Project
Is this stationary source a major source?
If yes, explain what programs and which pollutants henso2
Prevention of Significant Deterioration (PSD) ❑
Title V Operating Permits (OP) ❑
Non -Attainment New Source Review (NANSR)
NOx
O
CO VOC PM2.5 PM10 TSP HAPs
❑ El ❑ ❑
❑ O ❑ ❑ ❑ ❑
Condensate Storage Tank(s) Emissions Inventory
001 Condensate Tank
'Facility Al Rs ID:
County
,r'Ap,9 s=001 .s.f
Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit 1-400/>bl fixed roof condensate storage tank
Description:
Emission Control Device VRO with 5% downtime
Description:
Requested Overall VOC & HAP Control _
Efficiency %:
95
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput =
Requested Permit Limit Throughput =
Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating
Requested Monthly Throughput =
3,466, Barrels (bbl) per year
0' Barrels (hbl) per year
310 Barrels (bbl) per month I
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 = sef/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
49 Barrels (bbl) per year
Btu/scf
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04- Emissions Factors & 0lethodologies
Will this storage tank emit flash emissions?
0 MMBTU per year
0 MMBTU per year
0 MMBTU per year
Pollutant
Uncontrolled
Controlled
(Ib/bbl)
(lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
Emission Factor Source
ISaiMMIMISIMEBBEIMIEICIMD
Pollutant
0.000
0.000
0.000
0.000
0.000
Control Device
Uncontrolled Uncontrolled
(6/MMBtu)
(waste heat
combusted)
(lb/bbl)
ENESIMMil
(Condensate
Throughput)
0.0000
0,0000
0.0000
0.0000
Emission Factor Source
Section 05 - Emissions Inventory
&P Tanks (tpy)
0.006
0.001
4.646
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
PM10
PM2.5
NOx
CO
45.0
37.5
3.7
37.5
1.9
318
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0,0
0
0.0
0.0
0.0
0.0
0.0
0
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
14
12
1
12
1
2
2
0
2
0
0
0
0
0
0
0
0
0
0
0
11150
9292
906
9292
465
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XII.C, D, E, F
Storage Tank is not subject to Regulation 7, Section XII,C-F
Regulation 7, Section XII.G, C
Storage Tank is not subject to Regulation 7, Section X11 -G
Regulation 7, Section XVII.B, C.7, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & CO
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, NIPS Subpart 0000
Storage Tank is not subject to NIPS 0000
Regulation B, Part E, MACT Subpart HH
Storage Tank is not subject to MACE HH
(See regulatory applicability worksheet for detailed analysis)
3 of 16
K:\PA\2019\19 W E0169.CP1xlsm
Condensate Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodicnampling 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 05-0
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 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
Section 08 - Technical Analysis Notes
Applicant used an, unverified sample to request emission factors that are greater than the state default emission factors This methodology is conservative according to current policy specifying state'
default factors as a starting point. Since using either state-defalut or the suggested emission factors does not exceed 80tpy.VOC uncontrolled emissions, the division will not require a site -specific
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point # Process # SCC Code
001 01
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons condensate throughput
PM2.5 0.00 0 lb/1,000 gallons condensate throughput
NOx 0.00 0 lb/1,000 gallons condensate throughput
VOC 489.2 95 lb/1,000 gallons condensate throughput
CO 0.00 0 lb/1,000 gallons condensate throughput
Benzene 0.08 95 lb/1,000 gallons condensate throughput
Toluene 0.01 95 lb/1,000 gallons condensate throughput
Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput
Xylene 0.00 95 lb/1,000 gallons condensate throughput
n -Hexane 60.61 95 lb/1,000 gallons condensate throughput
224TMP 0.00 95 lb/1,000 gallons condensate throughput
4 of 16
K:\PA\2019\19 W E0169.CP1.xism
Condensate Tank Regulatory Analysis Worksheet
Colorado Regulation 3 Parts Aand B -APEN and Penult Requirements
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greaterthan 2TPY(Regulation 3, Part A, Section ll.Dl.a)7
(Source Is in the Attainment Area
2. Is the construction date (service date) priorta 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 112 and1.14 and Section 2foradditional guidance on grandfather applicability)?
3. Are total facilityummntrolled VOC emissions greater than 5 TPY, NO0 greater than lOTPY or CO emissions greaterthan 30 TPY (Regulation 3, Part 0, Section ILD.3)?
'source requires a permit
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutantsfrom this individua l source greaterthan l TPY (Regulation 3, Part A, Section ll.D.1.a)?
2. Is the construction date (service date) priort012/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and114 and Section 2for additional guidance on grandfather applicability)?
3. Aretotal facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5TPY or CO emissions greater than 10 TPY (Regulation 3, Part B,Section 3.D.2)7
'you have indicated that source Is in the Attainment Area
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 thh storage tank located at an an and gas exploration and production operation', natural gas compressor station or natural gas drip station?
3. Is thb storage tank located upstream of a natural gas proc sing plant?
'Storage Tank is not su Neck to Regulation 7, Section 011.e -E
Section X0.0.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Section XII.C.2—Emission Estimation Procedures
Section 00.0 —Emissions Control Requirements
Section XII.E—Monitoring
Section XII.F—Recosdkeeping and Reporting
Colorado Regulation 7.5ection XII.G
1. Is this storage tank boated 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 thb storage teak exhibit "Flash" (e.g. storing nun -stabilized liquids) emssions and have uncontrolled actual emissions greaterthan or equal to 2tons per year VOL?
IStorageTank is not subject to Regulation 7, Section 00.0
Section X8.G.2 - Entssions Control Requirements
Section XII.0.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Section XII.O.2—Emission Estimation Procedures
Colorado Regulation 7, Section MI
1. Is this tank located at a transmission/storage facility?
2. Is thb 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 sforagetank a fixed roof storage tank?
4. Are uncontrolled actual emissions" of this storageta nk equal to or greaterthan 6 tons peryear VOC?
'Storage tank is subject to Regulation 7, Section XVII, 0, 01 a C.3
Section 551re—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section IMI.C.1- Emssions Control and Monitoring Provisions
Section XVII.C3-Recordkeeping Requirements
5. Does the condensate storage tank contain only "stabilized" liquids?
IStoragetank is subject to Regulation 7, Section 000.0.2
Section 1MI.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 greaterthan or equal to 75 cubic meters (m') (-472 BBB)?
2. Dom thestorage vessel meet the following exemption m 60.111b(d)(4)?
a. Does the vessel has a deign capacity lass than or equal to 1589.874 m' (-10,000 BBL] used for petroleum or condensate stored, processed, ortreated priorta custody transfer' as defined in 50.1110?
3. Was this condensase storage tank constructed, reconstructed, or modified( see definitions 40 CFR, 60.2) after July 23, 1984?
4. Dos the tank meetthe definition of "storage vessel"' in 60.11lb?
5. Dos the storage vase(store a "volatile organic liquid (VOL). as defined in 60.1110?
6. Dos the storagevssel meet any one 0fthe fallowing additional exemptions:
a. Is the ssnrage vessel a pressure vssel designed to operate in excess Of 204.9 Spa [29.7 psi] and without emissions to the atmosphere (o0.110b(d)(2))?; or
b. The design capacity is grsterthan or equal in 151 m' ['950 BBL] and stores a liquid with a maximum true vapor pressure° less than 35 kPa (6o.11ob(b))?; or
c The design capacity u greaterthan or equal to 75 M° [-472 BBL] but less than 151 m' r950 BBL] and storm a liquid with a maximum true vapor pressures less than 15.0 kPa(60.11ob(b))?
W 0????
np"si/n"GNipii
No
Yes
YIM
No
No
Yes
X
ounce Req
Go to next,
Source Regr
Storage Tar
Source is so
SttrageTar
Storage Tar
Continue
Go to the m
Go to then
Source 550
ff4p i'ritleT?mnnurce Isau
Storage Tar
StorageTank Is not subject to SOPS Kb
Subpart A, GeneralProvisions
§60.1126- Emisioas ContmlStandards for VOC
§601130 -Tasting and Procedures
46011Sb- Reporting and Recordkeeping Requirements
§60.1160- Monitoring of Operations
40 CFR, Part60, Subpart 0000, Standards of Performance far Crude On and Natural Gas Pmductlon.Transmission and Distribution
1. Is thh condensate storage vessel located at a facility In the onshore nil 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, to1)between August 23, 2011 a nd September 18, 2015?
3. Are potential VOC emissions' from the individual storagevessel greaterthan or equal to 6 tans per year?
4. Domthy condensate storage vessel meet the definition of "storage vessel" per 60.5430?
5. Is the storage vessel subjectnc 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
Subpart', General Provisions per 4605425 Table 3
460.5395 - Emissions Control Standards for VOC
460.5413-Testing,and Procedures
460,5395(g) -Notification, Reporting and Recordkeeping Requirements
4605416(c) -Cover and Closed Vent System Monitoring Requirements
0605417 - Controtfesce Monitoring Requirements
[Note: If a stoagevessel is previously determined to he subject to N5050000 due to emissions above 6 tons per year VOC on the applicability determination date, ft should remain sublectto NSP50000 per 60.5365(0)(2) even if
potential VOC emkslons drop below 6 tons per year)
40 CFR. Part 63. Subpart MALT Hu. 00 and Gas Production Facilities
1. Is the storage tanklocated at an oil and natural gas production facility that meets either ofthe following criteria:
a. Afacility that processes, upgrades or storm hydrocarbon liquids' (63.750(')(2)); OR
b. A facility that processes, upgrades or storm natural gas priorta the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end users (63.760(a)(3))?
2. Is theta nk locatedlat a facility that Is major' for HAPs?
3. Does the tank meet the definition of "storage vessel"° In 63.7617
4. Dos the tank meet the definition of"storage vessel with the potential forflash emissions' per 63.761?
5. Is the tank subjectto control requirements under 40 CFR Part 50, Subpart Kb or Subpart 0000?
'Storage Tank is not subject to MALT HH
Subpart A, General provisions per 463.764 (a) Table 2
§63.766- Emissions Control Standards
463.773 Monitoring
§63.77$- Recordkeeping
§63.775 -Reporting
RACT Review
RACT review Is required If Regulation 7 does not apply AND lithe tank is In the ran -attainment area. If the tank meets both criteria, then review RACT requirements.
Disclaimer
This oftcument assists operators with determining applicability of certain iequirements of the Clean Air Act, its implementing regulations, and Air Duality 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 otherlegal& binding requirement and is not legally enforceable. In the event of anyconilict between the language of this document and the language of the Clean Air Act, its implementing regulations,
andAr 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 APCO interpreta6'ons 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 ['liftoff
Yes
forage Tar
'Yes 'Continue
storage Tar
Produced Water Storage Tank(s) Emissions Inventory
002 Produced Water Tank
Facility AIRs ID:
County
Plant Point
Section 02- Equipment Description Details
Detailed Emissions Unit 4x400bb1 fixed roof storage vesseles for produced water storage.
Description:
Emission Control Device rVRU with 5% annual downtime
Description:
Requested Overall VOC & HAP Control
Efficiency %:
95
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Produced Water Throughput =
:Requested Permit Umit Throughput=
Potential to Emit (PTE) Produced Water
Throughput =
150 Barrels (bbl) per year
Actual Produced Water Throughput While Emissions Controls Operating =
WPM
3410 Barrels (bbl) per month
40,150 Barrels (bbl) per year Requested Monthly Throughput=
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of
liquids produced = acf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Barrels (bbl) per year
Btu/scf
0 MMBTU per year
0 MM BTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 0 MMBTU per year
Section 04- Emissions Factors& Methodologies
Will this storage tank emit flash emissions?
Pollutant
Pollutant
Produced Water Tank
Uncontrolled
Controlled
(Ib/bbi)
(lb/bbl)
(Produced Water
Throughput)
0.110
0.000
0.000
0.000
0.002
(Produced
Water
Throughput)
Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu)
(lb/bbl)
(waste heat
combusted)
Section 05 - Emissions Inventory
(Produced
Water
Throughput)
0.0000
0.0000
0.0000
0.0000
Emission Factor Source
Emission Factor Source
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
PM10
PM2.5
NOx
CO
2.6
2.2
0.2
2.2
0.1
19
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
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
8
6
1
6
0
2
1
0
1
0
0
0
0
0
0
0
0
0
0
0
96
80
8
80
4
0
0
0
0
0
Section 06 Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, C.1, C.3
Storage Tank is not subject to Regulation 7, Section XVII
Regulation 7, Section XVII.C.2 _
Storage Tank is not subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
(See regulatory applicability worksheet for detailed analysis)
6 of 16
K:\PA\2019\19 W E0169.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 maybe 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. 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
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
002
Process # SCC Code
01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons liquid throughput
PM2.5 0.00 0 lb/1,000 gallons liquid throughput
NOx 0.00 0 1b/1,000 gallons liquid throughput
VOC 2.6 95 lb/1,000 gallons liquid throughput
CO 0.00 0 lb/1,000 gallons liquid throughput
Benzene 0.00 95 lb/1,000 gallons liquid throughput
Toluene 0.00 95 lb/1,000 gallons liquid throughput
Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput
Xylene 0.00 95 lb/1,000 gallons liquid throughput
n -Hexane 0.05 95 lb/1,000 gallons liquid throughput
224 TMP 0.00 95 lb/1,000 gallons liquid throughput
7 of 16 K:\PA\2019\19WE01'69.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 uirernents
Source is in the Attainment Area
ATTAINMENT
1. Are uncontrolledactual emissions from any criteria pollutants from this Individual source greater than 2TPY (Regulation 3, Part A,Sectlon ll.onel7
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 0, Section II.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 10TPY or CO emissions greater than 1OTPY (Regulation 3, Part B, Section 11.0.3)7
'Source requires a permit
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutantsfrom this individual source greater than 1TPY (Regulation 3, Part A, Section ll.D.1.a)?
2. Is the operator claiming less than 1% crude oil and is the tank located eta non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part e, Section II.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 2TPY, NOx greater than 5TPY or C0 emissions greater than 10 TPY (Regulation 3, Part B, Section 11.D.2)7
'You lave indicated that source Is In the Attainment Area
Colorado Regulation 7, Section %VII
1. Is this tank located ate 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 station' or natural gas processing plant?
3. Is this produced water storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions°of this storage tank equalto or greater than 6 tons peryear VOC?
'Storage Tank Is not subject to Regulation 7, Section KVII
Section XVILB —.General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Scones 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.
'Storage Tank is not subject to Regulation 7, Section XVII.e.2
Section XVIl.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CPR, Part RD. Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production. Transmission and Distribution
1. Is this producedwater storage vessel located ate 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 40CFR,60.2) between August 23, 2011 and September 18, 20157
3. Are potential VOCemissions' 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?
'Storage Tank is not subject to NSPS 0000
Subpart A, General Provisions per §605425 Table
§60.5595 - Emissions Control Standards for VOC
§60.5413 -Testing and Procedures
§00.5395(g)- Notification, Reporting and Remrdkeeping 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 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subjectto NSPS 0000 per 60.5365(e)(2)
even If potential VOC emissions drop below 6 tons per year]
RACE Review
PAR 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„ ds implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use ofnon-mandatory language such as
ecommend," '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
vs,
No
Yes
tiONSTil
Yes
Source Req
Go to next i
Source Req
Continue-`
Continue-`
Go to then
Storage Tar
¢IS
Continue
Storage Tat
Section 01- Adminstrative Information
Facility AIRs ID:
123
County
Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Natural gasventing from compressor blowdowos. Emissions from thisnource are ventedto tha
Description;
Emission Control Device
Description:
Requested Overall VOC & HAP Control Efficiency %:
bma3phaYe ( xt ' '.•
Entissronsfrom this. pour
Section 03 - Processing Rate Information for Emissions Estimates
'1.00EOZ MMscf
104:events/year
`8: events/year
0 MMscf per year
1.04E+00 MMscf per year
1.04E+00 MMscf per year
Compressor Blowdown Volume=
Requested Compressor Blowdown Events=
Actual Compressor Blowdown Events=
Actual Gas Throughput =
Requested Permit Limit Throughput =
Potential to Emit (PTE) Throughput =
ontralled.
Actual Gas Throughput While Emissions Controls Operating =
Section 04 - Emissions Factors & Methodologies
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q* MW *Xx/C
Ex = emissions of pollutant x
4= Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 6OF and 1 atm
Throughput (CO
MW
1.04E+00
MMscf/yr
Ib/Ib-mol
1.19E+02
scf/yr
MMscf/d
23.9
0.002849315
mole %
MW
Ibx/Ihmol
mass fraction
lb/hr
lb/yr
tpy
Helium
. +^'.'»y', 0:00
!4.0026
0.000
0.000
0.00
0.00
0.00
CO2
. r. 2.68
: `;: 44.01
1.179
0.049
0.37
3236.53
1.62
N2
S�:y aa:'•'^3 .*, -.1.21
;;, 28.013
0.339
0.014
0.11
930.12
0.47
methane
(:'..'`"1' hhg 69.96
Ss�'"16.041
11.222
0.470
3.52
30794,66
15.40
ethane
10.76
' - 30.063
3.235
0.135
1.01
8876.44
4.44
propane
9.21
44.092
4.061
0.170
1.27
11143.29
5.57
isobutane
0.94
'.58.118
0.546
0.023
0.17
1499.11
0.75
n -butane
3.21
58.118
1.866
0.078
0.58
5119.29
2.56
isopentane
0.57
::; 72.114
0.411
0.017
0.13
1127.95
0.56
n -pentane
0.67
72.114
0.483
0.020
0.15
1325.83
0.66
cyclopentane
0.00
. '. 70.13
0.000
0.000
0.00
0.00
0.00
n -Hexane
'/ 's;1 0.42
':„86.18
0,362
0.015
0.11
993.23
0.50
cyclohexane
').::+' ,' 0.07
''_ 84.16
0.059
0.002
0.02
161.66
0.08
Other hexanes
- .',. 0:00
86.18
0.000
0.000
0.00
0.00
0.00
heptanes
'' 0.07
i<'s100.21
0.070
0.003
0.02
192.49
0.10
methylcyclohexane
0 00
°""98.19
0.000
0.000
0.00
0.00
0.00
224-TMP
0.00
:' 114.23
0.000
0.000
0.00
0.00
0.00
Benzene
t *;z 0.02
78.12
0.016
0.001
0.00
42.87
0.02
Toluene
0.01
92.15
0.009
0.000
0.00
25.29
0.01
Ethylbenzene
0.00
106.17
0.000
0.000
0.00
0.87
0.00
Xylenes
0.00
~.;'106.17
0.000
0.000
0.00
0.29
0.00
C8+ Heavies
0.01
114
0.016
0.001
0.00
43.48
0.02
VOC mass fractic 0.3309
MW 23.875
Total VOC(Uncontrolled)
10.84
Notes
Mole %, MW, and mass fractions are based on a representative gas sample .
Emissions are based on 104 blowdown events per year.
The MW of C8+ used for calculations is based on the operator designated value of 114. This is within the expected range and therefore acceptable.
Section 05 - Emissions Inventory
Emissions Summary Table
Pollutant
Uncontrolled Emission Factor
Controlled Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
VOC
208.42
lb/event
208.42 lb/event
10.84 tpy
10.84 tpy
Gas Analysis
Benzene
0.412
lb/event
0.412 lb/event
42.9 lb/yr
42.9 lb/yr
Mass Balance
Toluene
0.243
lb/event
0.243 lb/event
25.29 lb/yr
25.29 lb/yr
Mass Balance
Ethylbenzene
0.008
lb/event
0.008 lb/event
0.87 lb/yr
0.87 lb/yr
Mass Balance
Xylenes
0.003
lb/event
0.003 lb/event
0.29 lb/yr
0.29 lb/yr
Mass Balance
n -Hexane
9.550
lb/event
9.550 lb/event
993,23 lb/yr
993.23 lb/yr
Mass Balance
2,2,4-TMP
0.000
lb/event
0.000 lb/event
0.00 lb/yr
0.00 lb/yr
Mass Balance
Section 06 - Regulatory Summary Analysis
AQCC Regulation 1
19WE0169.CP1.xlsm
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in
excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions
measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation.
AQCC Regulation 2
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable
odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has
been diluted with seven (7) or more volumes of odor free air." _
Section 07 - Technical Analysis Notes
1. To demonstrate compliance with blowdown permit limits, each blowdown event will be recorded and emissions will be estimated by multiplying the number of events by the
emission factor provided in the notesto permit holder (lb/event). This supports the use of an event basis for the process limit contained in the permit.
19WE0169.CP1.xlsm
Glycol Dehydrator Emissions Inventory
004 Dehydrator
'Facility AIRS ID:
123
county
A029
Plant
004
Point
Section 02- Enulpmeot Description Details
Dehydrator Information
Dehydrator Type:
Make:
Model:
Serial Number:
Design Capacity:
Recirculation Pump reformation
Number of Pumps
Pump Type
Make:
Model:
Design/Max Recirculation Rate:
Dehydrator Equipment
Flash Tank
Reboiler Burner
Stripping Gas
Dehydrator Equipment Description
Emission Control Device Description:
MMscf/day
gallons/minute
, flash tank,
and reboller burner
One (1) Triethylene glycol (TEG) natural gas dehydration unit (Make: tbd, Model: 30MMSCFD TEG DEHn, Serial Number: tbd) with a design capacity 0030 MMscf per day.
This emissions unit is equipped with tbd (Make:tbd, Model: tbd) electric driven glycol pump with a design capacity of 12 gallons per minute. This dehydration unit Is
equipped with a still vent, flash tank, and reboiler burner.
Emissions from the still vent are routed so an air-cooled condenser, and then to the Enclosed Flare. As a secondary cemrol device, still vent emissions are routed to the
Enclosed Flare . Emissions from the flash tank ere routed directly to the closed -loop system.
Section 03 - Processire Rate Information for Emissions Estimates
Primary Emissions -Dehydrator Still Vent and Flash Tank (if present}
Requested Permit Limit Throughput=
Potential to Emit (PTE) Throughput=
MMscf per year Requested Monthly Throughput= 930 MMscf per month
10,550 MMscf per year
Secondary Emissions- Combustion Device(s) for Air Pollution Control
Still Vent Control
Condenser:
Condenser emission reduction claimed:
Primary control device:
Primary control device operation:
Secondary control device:
Secondary control device operation:
Still Verit Gas Heating Value:
Still Vent Waste Gas Vent Rate:
Flash tank Control
Primary control device:
Primary control device operation:
Secondary control device:
Secondary control device operation:
Flash Tank Gas Heating Value
Flash Tank Waste Gas Vent Rate:
AtvroatOtriVfiZt4.;•
Requested Condenser Outlet Temperature:
95%Control Efficiency %
hr/yr Requested TO Temp
'^ 3 .100% Control Efficiency %
322 hr/yr
.Btu/scf
scfh
a
Section 04- Emissions Factors & Methodologies
Dehydrator
Input Parameters
Inlet Gas Pressure
Inlet Gas Temperature
Requested Glycol Recirculate Rate
hr/yr
hr/yr
Btu/scf
scfh
pig
deg F
gym
10096 Control Efficiency %
Control Efficiency%
STILL VENT
Control Scenario
Primary
Secondary
Pollutant
Uncontrolled (lb/hr)
Controlled (lb/hr)
Controlled (R/hr)
VOC
44.7317.
2.236505-..
, d
Benzene
AY1.545Q'.'
0:57725
.,. `la . .
Toluene
3.896
0.1948
"0 -
Ethylbenzene
201498..
,0
Xylenes
` 0,173&"'
0.00869
0
n -Hexane
3.6307
0,181535
224-TMP
....,
.::' 0 ..
0
FLASH TANK
Control Scenario
Primary
Secondary
Pollutant
Uncontrolled (lb/hr)
Controlled (lb/hr)
Controlled (lb/hr)
VOC
45.3042
,0
" 41.3042 '
Benzene
...0.3699=
0
0.3699
Toluene
"`0.0059;
.7`0
0.0859.'.
Ethylbenzene
0.0041 -.
0
0.0041
Xylenes
"'0,0017'
"`.-.0 -
0.0017 ,
n -Hexane
2.7451
0
224-TMP
..
.: 0 ..
... 9
160 Degrees F
Degrees F
Dry Gas Throughput:
Still Vent Primary Control: 10,950.0 MMscf/yr
Still VentSecandary Control: 10,902.5 MMscf/yr
Waste Gas Combusted:
Still Vent Primary Control: 0.0 MMscf/yr
Still Vent Secondary Control: 0.0 MMscf/yr
Dry Gas Throughput:
Flash Tank Primary Control: 10,950.0 MMscf/yr
Flash Tank Secondary Control: 0.0 MMscf/yr
Waste Gas Combusted:
Flash Tank Primary Control: 0.0 MMscf/yr
Flash Tank Secondary Control: e.g MMscf/yr
930.0
0.0
Glycol Dehydrator Emissions Inventory
Section 05 - Emissions Inventory
Did operator request a buffer?
Requested Buffer (%):
Emission Factors
Still Vent Primary Control Device
Pollutant
Benzene
Toluene
Ethylbenzene
Xyfane
Hens
224TMP
Pollutant
PM2.5
Sox
NO
CO
Pollutant
PM10
CO
Pollutant
PM10
Pollutant
0800
CO
Glycol Dehydrate
Uncontrolled
(Ib/MMsct) (Ib/MMscf) Emission Factor Source
(Dry Gas
Throughput) (Dry Gas Through put)
Controlled
0.24296
0.006952
0.145228
Uncontrolled Uncontrolled
(Ib/MMBtu) (Ib/MMscf) Emission Factor Source
(Waste Heat
Com busted)
0.0000
0.0000
(Waste Gas
Combusted)
0.0000
0.0000
0.0000
0.0000
Still Vent Secondary Control Devic
Uncontrolled Uncontrolled
(Ib/MMBtu)
(Waste Heat
Combusted)
(Ib/MMscf)
(Waste Gas
Combusted)
0.0000
0.0000
0.0000
0.0000
0.0000
Flash Tank Primary Control Device
Uncontrolled Uncontrolled
(Ib/MM6tu) (Ib/MMscf)
(Waste Heat
Combusted)
0`0000,
(Waste Gas
Combusted)
0.0000
0.0000
0.0000
Flash Tank Secondary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu)
(Waste Heat
Combusted)
(Ib/MMscf)
(Waste Gas
Combusted)
0.0000
0.0000
0.0000
0.0000
Emission Factor Source
Emission Factor Source
Emission Factor Scums
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
CO
VOC
0.0
0.0
0.0
0.0
0.0
_ 0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
376.8
376.8
9.8
376.8
9.8
1664
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Etlsylbenzene
0(ylene
rFHexane
224 IMP ,
104375
104375
5057
104375
5057
34881
34881
1706
34881
1706
20060
2660
131
2660
131
1537
1537
76
1537
76
55852
55852
1590
55852
1590
0
0
0
0
0
Section 06 - Regulatory Summary Anal 5,15
Regulation 3, PartsA, 8
Regulation 7, Section XVII.B,D
Regulation 7, Section XVII.B.2.e
Regulation 7, Section X11.11
Regulation 8, Part E, MACT Subpart HH (Area)
Regulation 8, Part E, MACT Subpart OH (Major)
Regulation 8, PartE, MACT Subpart HHH
(See regulatory applicability worksheet for detailed analysts)
Source requires a permit
Dehydrator is subject to Regulation 7, Section XVII, 0, 0.3
The control device for this dehydrator Is not subject to Regulation 7, Section X011.8.2.5
Dehydrator is not subjectto Regulation 7, Section 011.0
Oehy is subject to area source MACT HH, per the requirements in 63,764(d)(1(
You have indicated that this facility is not subject to Major Source requirements of MACT OH.
You have indicated that this facility'is not subject to MALT HHH,
Glycol Dehydrator Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Was the extended wet gas sample used in the Olycaic model/Process model site -specific and collected within a
year of application submittal? ts.
If no, the permit will contain an "Initial Compliance" testing requirement to demonstrate compliance with emission limits
Does the company request a control device efficiency greater than 95%for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
If the company has requested a control device efficiency greater than 95%, is a thermal oxidizer or regenerative thermal oxidizer being used to achieve it?
If yes, the permit will contain a condition specifying the minimum combustion chamber temperature for the thermal oxidizer
Is the company using a thermal oxidizer AND requesting a minimum combustion chamber temperature lower than 1,400 degrees F?
If yes, the permit wlllcontaln en "Initial Compliance" testing requirement AND a permit condition specifying the minimum combustion chamber temperature for the thermal oxidizer.
No
w -
Section CS - Technical Analysis Notes
-Applicant has requested condenser credit.. Applicant has also requested VRU control with downtime (5/) as primary control VRIJ do time monitoring will b roqu red.
enclosed flan selection for still vent control has been used instead ot VFW selection, not available.
Section 09 - Inventory 5CC Coding and Emissions Factors
AIRS Point #
004
Process # SCC Code
01
Uncontrolled
Pollutant Emissions Factor Control% Units
PM10 0.000 0.0 b/MMscf
PM2.5 0.000 0.0 b/MMscf
SOX 0.000 0.0 b/MMscf
N0x 0.000 0.0 b/MMscf
VOC 68.8 97.4 b/MMscf
CO 0.000 0.0 b/MMscf
Benzene 9.532 95.2 b/MMscf
Toluene 3.186 95.1 b/MMscf
Ethylbenzene 0.243 95.1 b/MMscf
Xylene 0.140 95.0 b/MMscf
n -Hexane 5.101 97.2 b/MMscf
224 TMP 0.000 #DIV/OI b/MMscf
Dehydrator Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
'Source is in the Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Sec
'Source requires a permit
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Pat
'You have indicated that source is in the Attainment Area
Colorado Regulation 7, Section XII.H
1. Is this glycol natural gas dehydrator located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Reg 7, Sec
2. Is this glycol natural gas dehydrator located at an oil and gas exploration and production operations, natural gas compressor station, natural gas drip
3. Is the sum of actual uncontrolled emissions of VOC from any single dehydrator or group of dehydrators at a single stationary source equal to or greater tt
4. Are actual uncontrolled emissions of VOC from the individual glycol natural gas dehydrator equal to or greater than 1 tpy (Reg 7, Section XII.H.3.a)?
'Dehydrator is not subject to Regulation 7, Section XII.H
Section XII.H — Emission Reductions from glycol natural gas dehydrators
MACT Analysis
1. Is the dehydrator located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids1 (63.760(a)(2)); OR
A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage
b. source category or is delivered to a final end user2 (63.760(a)(3))?
2. Is the dehydrator located at a facility that is a major source for HAPs?
'Go to MACT HH Area Source Requirement section to determine MACT HH applicability
40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities
Area Source Requirements
1. Is the dehydrator a triethylene glycol (TEG) dehydration unit (63.760(b)(2))?
Exemptions
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.764(e)(1)(i)?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.7
3. Is the unit located inside of a UA plus offset and UC boundary area?
Dehy is subject to area source MACT HH, per the requirements in 63.764(d)(2)
Subpart A, General provisions per §63.764 (a) Table 2
§63.765 - Emissions Control Standards Do Not Apply
§63.773 - Monitoring Standards Do Not Apply
§63.774 - Recordkeeping
§63.775 - Reporting
Major Source Requirements
1. Does the facility have a facility -wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility -wide actual annual average
Small or Large Dehy Determination
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.761)?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.7
Small Dehy Requirements
3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.760(b)(1)(i)(B) and (C )?
4. For this small dehy, is a control device required to meet the BTEX emission limit given by the applicable equation?
IYou have indicated that this facility is not subject to Major Source requirements of MACT HH.
Subpart A, General provisions per §63.764 (a) Table 2
§63.765 - Emissions Control Standards
§63.773 - Monitoring
§63.774 - Recordkeeping
§63.775 - Reporting
40 CFR, Part 63, Subpart MACT HHH, Natural Gas Transmission and Storage Facilities
1. Is the facility wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the only HAP emission source (6.
Small or Large Dehy Determination
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per day (63.1270(b)(2))?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.1
Small Dehy Requirements
3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.1270(b)(2) and (3) )?
4. For this small dehy, is a control device required to meet the BTEX emission limit (standard?) given by the applicable equation?
IYou have indicated that this facility is not subject to MACT HHH.
Subpart A, General provisions per §63.1274 (a) Table 2
§63.1275 - Emissions Control Standards
§63.1281 -Control Equipment Standards
§63.1283 - Inspection and Monitoring
§63.1284 - Recordkeeping
§63.1285 - Reporting
Colorado Regulation 7, Section XVII.D
1. Is the dehydrator subject to an emissions control requirement under MACT HH or HHH (Regulation 7, Section XVII.B.5)?
2. Is this dehydrator located at a transmission/storage facility?
3. Is this dehydrator located at an oil and gas exploration and production operation , natural gas compressor station or gas processing plant (RE
4. Was this glycol natural gas dehydrator constructed before May 1, 2015 (Reg 7 Section XVII.D.4.b)?
•
tons per year VOC or 2 tpy VOC if the dehydrator is located within 1,320 feet of a building unit or designated outside activity area (Reg 7,
4a. Section XVII.D.4.b)?
5. If constructed on or after May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 2 tpy VOC (F
IDehydrator is subject to Regulation 7, Section XVII, B, D.3
Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.D.3 - Emissions Reduction Provisions
Alternative Emissions Control (Optional Section)
6. Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not en
'The control device for this dehydrator is not subject to Regulation 7, Section XVII.B.2.e
Section XVII.B.2.e — Alternative emissions control equipment
Disclaimer
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
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0169
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Summit Midstream Niobrara, LLC
Brahma Compressor Station
123/A029
SW SEC 28 T12N R63W
Weld County
Natural Gas Compressor Station
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK-01
001
One (1) 400 barrel fixed roof storage vessel
used to store condensate
Vapor Recovery Unit
TK 02-05
002
Four (4) 400 barrel fixed roof storage
vessel(s) used to store produced water
Vapor Recovery Unit
BD -01
003
Natural gas venting from facility blowdowns.
Emissions from this source are vented to the
atmosphere.
None
DU -01
004
One (1) Triethylene glycol (TEG), natural gas
dehydration unit (make, model, serial
number: TBD) with a design capacity of 30
MMscf per day. This emissions unit is
equipped with one (1) electric -driven glycol
pump with a design capacity of 12 gallons
per minute. This unit is equipped with a
flash tank, reboiler and still vent.
Emissions from the
still vent are routed
to an air-cooled
condenser and then
to a VRU. Emissions
from the flash tank
are recycled to plant
inlet.
Page 1 of 28
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
GE -01
005
One (1) Caterpillar, Model G3512B, Serial
Number To Be Determined, natural gas -
fired, turbo -charged, 4SLB reciprocating
internal combustion engine, site rated at
1,035 horsepower. This emission unit is used
for power generation.
Oxidation catalyst
and air -fuel ratio
control.
CE -01
006
One (1) Caterpillar, Model G3608, Serial
Number: XH70092, natural gas -fired, turbo-
charged, 4SLB reciprocating internal
combustion engine, site rated at 2,500
horsepower. This emission unit is used for
natural gas compression.
Oxidation catalyst
and air -fuel ratio
control.
CE -02
007
One (1) Caterpillar, Model G3608, Serial
Number: TBD, natural gas -fired, turbo-
charged 4SLB reciprocating internal
combustion engine, site rated at 2,500
horsepower. This emission unit is used for
natural gas compression.
Oxidation catalyst
and air -fuel ratio
control.
Point(s) 005: This engine may be replaced with another engine in accordance with the temporary
engine replacement provision or with another Caterpillar G3512B engine in accordance with the
permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit
as Attachment A.
Point(s) 006, 007: This engine may be replaced with another engine in accordance with the temporary
engine replacement provision or with another Caterpillar G3608 engine in accordance with the
permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit
as Attachment A.
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
Page 2 of 28
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at www.colorado.gov/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.)
F.4. )
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. Point(s) 004: The following information shalt be provided to the Division within fifteen (15)
days of the latter of commencement of operation or issuance of this permit.
• The dehydrator manufacturer name, model number and serial number
The glycol circulation pump manufacturer name and model number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation Number 3, Part B, III.E.)
6. Point(s) 005, 006, 007: The following information shall be provided to the Division within
fifteen (15) days of the latter of commencement of operation or issuance of this permit.
manufacture date
• construction date
• order date
• date of relocation into Colorado
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
7. 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
8. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
)
Page 3 of 28
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Monthly Limits:
Facility
Equipment
ID
AIRS
Point
Pounds per Month
Emission
Type
PM2.5
N0X
V0C
CO
TK-01
001
---
---
318
---
Point
TK 02-05
002
---
---
19
---
Point
BD -01
003
---
---
1,840
---
Point
DU -01
004
---
---
1,664
---
Point
GE -01
005
---
849
1,195
314
Point
CE -01
006
---
2,058,
2,896
729
Point
CE -02
007
-
2,058
2,896
729
Point
Note: Monthly limits are based on a 31 -day month.
The owner or operator shall calculate monthly emissions based on the calendar month.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 1,359 pounds
per month.
Facility -wide emissionsof total hazardous air pollutants shall not exceed 3,398
month.
pounds per
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Annual Limits:
Facility
Equipment
ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
N0X
VOC
CO
TK-01
001
---
---
1.9
---
Point
TK 02-05
002
---
---
0.2
---
Point
BD -01
003
---
---
10.9
---
Point
DU -01
004
---
---
9.5
---
Point
GE -01
005
---
5.0
7.0
1.9
Point
CE -01
006
---
12.1
16.9
4.3
Point
CE -02
007
---
12.1
16.9
4.3
Point
Page 4 of 28
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Note: See "Notes to Permit Holder" for information on emission factors and methods used to
calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
During the first twelve (12) months of operation, compliance with both the monthly and annual
emission limitations is required. After the first twelve (12) months of operation, compliance
with only the annual limitation is required.
Compliance with the annual limits, for criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
9. Point(s) 004: Compliance with the emission limits in this permit shall be demonstrated by
running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent
extended wet gas analysis and recorded operational values, including: dry gas throughput, lean
glycol recirculation rate, vapor recovery unit (VRU) downtime, condenser outlet temperature,
flash tank temperature and pressure, wet gas inlet temperature, and wet gas inlet pressure.
Recorded operational values, except for gas throughput, shall be averaged on a monthly basis
for input into the model and be provided to the Division upon request.
10. Point(s) 004: On a monthly basis, the owner or operator shall monitor and record operational
values including: vapor recovery unit (VRU) downtime, condenser outlet temperature, flash
tank temperature and pressure, wet gas inlet temperature and pressure. These records shall
be maintained for a period of five years.
11. Point(s) 004: The condenser outlet temperature shall not exceed 160 degrees F, on a rolling
twelve month average. The owner or operator shall calculate the rolling twelve month average
temperature by averaging all recorded condenser outlet temperature values as specified in this
permit.
12. The owner or operator shall operate and maintain the emission points in the table below with
the emissions control equipment as listed in order to reduce emissions to less than or equal to
the limits established in this permit. The owner or operator shall operate this dehydration unit
so as to prevent any emissions directly to the atmosphere. (Regulation Number 3, Part B,
Section III.E.)
E. )
13.
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
TK-01
001
Vapor Recovery Unit
VOC and
HAPs
Page 5 of 28
COLORADO
Air Pollution Control Division
Department of Public Heath 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
TK 02-05
002
Vapor Recovery Unit
VOC and
HAPs
DU -01
004
Still Vent: Vapor Recovery Unit/Condenser
VOC and
HAPs
GE -01
005
Oxidation catalyst and air/fuel ratio
controller
VOC, CO,
HAPs
CE -01
006
Oxidation catalyst and air/fuel ratio
controller
VOC, CO,
HAPs
CE -02
007
Oxidation catalyst and air/fuel ratio
controller
VOC, CO,
HAPs
14. The owner or operator shall operate and maintain the emission points in the table below as a
closed loop system and shall recycle 100% of emissions as described in the table below.
(Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Emissions Recycling Description
Pollutants
Recovered
DU -01
004
Flash Tank: Recycled to Inlet
VOC and
HAP
PROCESS LIMITATIONS AND RECORDS
15. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Monthly Limit
(31 days)
TK-01
001
Condensate
Throughput
3,650 barrels
310 barrels
TK 02-05
002
Produced Water
Throughput
40,150 barrels
3,410 barrels
BD -01
003
Number of Events
104 events
---
DU -01
004
Dry Gas
Throughput
10,950 MMscf/yr
930
MMscf/month
GE -01
005
Consumption of
natural gas as a
fuel
58.1 MMscf/yr
5.0
MMscf/month
CE -01
006
Consumption of
natural gas as a
fuel
131.0 MMscf/yr
11.2
scf/month
Page 6 of 28
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Consumption of
11.2
CE -02
007
natural gas as a
fuel
131.0 MMscf/yrscf/month
During the first twelve (12) months of operation, compliance with both the monthly and annual
throughput limitations is required. After the first twelve (12) months of operation, compliance
with only the annual limitation is required.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
16. Point(s) 004: The owner or operator shall monitor monthly process rates based on the calendar
month. The volume of dry gas throughput shall be measured by gas meter at the outlet of the
dehydrator.
17. Point(s) 005, 006, 007: Fuel consumption shall be measured by one of the following methods:
individual engine fuel meter; facility -wide fuel meter attributed to fuel consumption rating and
hours of operation; or manufacturer -provided fuel consumption rate.
18. Point(s) 004: This unit shall be limited to the maximum lean glycol circulation rate of 12 gallons
per minute. The lean glycol recirculation rate shall be recorded weekly in a log maintained on
site and made available to the Division for inspection upon request. Glycol recirculation rate
shall be monitored by one of the following methods: assuming maximum design pump rate,
using glycol flow meter(s), or recording strokes per minute and converting to circulation rate.
This maximum glycol circulation rate does not preclude compliance with the optimal glycol
circulation rate (Loft) provisions under MACT HH. (Reference: Regulation Number 3, Part B,
II.A.4)
STATE AND FEDERAL REGULATORY REQUIREMENTS
19. 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)
20. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
21. Point(s) 001, 002: 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.
Page 7 of 28
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
22. Point(s) 001, 002: 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.
23. Point(s) 004: The glycol dehydration unit covered by this permit is subject to the emission
control requirements in Regulation Number 7, Section XVII.D.3. Beginning May 1, 2015, still
vents and vents from any flash separator or flash tank on a glycol natural gas dehydrator located
at an oil and gas exploration and production operation, natural gas compressor station, or gas -
processing plant subject to control requirements pursuant to Section XVII.D.4., shall reduce
uncontrolled actual emissions of hydrocarbons by at least 95% on a rolling twelve-month basis
through the use of a condenser or air pollution control equipment.
24. Point(s) 004: The glycol dehydration unit at this facility is subject to National Emissions
Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas
Production Facilities, Subpart HH. This facility shall be subject to applicable area source
provisions of this regulation, as stated in 40 C.F.R Part 63, Subpart A and HH. (Regulation
Number 8, Part E, Subpart A and HH)
Page 8 of 28
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
MACT HH Applicable
Requirements
Area Source
Benzene emissions exemption
863.764 - General
Standards
§63.764 (e)(1) - The owner or operator is exempt from the
requirements of paragraph (d) of this section if the criteria listed
in paragraph (e)(1)(i) or (ii) of this section are met, except that
the records of the determination of these criteria must be
maintained as required in §63.774(d)(1).
§63.764 (e)(1)(ii) - The actual average emissions of benzene from
the glycol dehydration unit process vent to the atmosphere are
less than 0.90 megagram per year, as determined by the
procedures specified in §63.772(b)(2) of this subpart.
§63.772 - Test
Methods,
Compliance
Procedures and
Compliance
Demonstration
§63.772(b) - Determination of glycol dehydration unit flowrate or
benzene emissions. The procedures of this paragraph shall be
used by an owner or operator to determine glycol dehydration
unit natural gas flowrate or benzene emissions to meet the
criteria for an exemption from control requirements under
§63.764(e)(1).
§63.772(b)(2) - The determination of actual average benzene
emissions from a glycol dehydration unit shall be made using the
procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this
section. Emissions shall be determined either uncontrolled, or
with federally enforceable controls in place.
§63.772(b)(2)(i) - The owner or operator shall determine actual
average benzene emissions using the model GRI-GLYCaIc TM,
Version 3.0 or higher, and the procedures presented in the
associated GRI-GLYCaIc`TM Technical Reference Manual. Inputs to
the model shall be representative of actual operating conditions
of the glycol dehydration unit and may be determined using the
procedures documented in the Gas Research Institute (GRI) report
entitled "Atmospheric Rich/Lean Method for Determining Glycol
Dehydrator Emissions" (GRI-95/0368.1); or
§63.772(b)(2)(ii) - The owner or operator shall determine an
average mass rate of benzene emissions in kilograms per hour
through direct measurement using the methods in §63.772(a)(1)(i)
or (ii), or an alternative method according to §63.7(f). Annual
emissions in kilograms per year shall be determined by
multiplying the mass rate by the number of hours the unit is
operated per year. This result shall be converted to megagrams
per year.
Page 9 of 28
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
§63.774 -
Recordkeeping
Requirements
§63.774 (d)(1) - An owner or operator of a glycol dehydration
unit that meets the exemption criteria in §63.764(e)(1)(i) or
§63.764(e)(1)(ii) shall maintain the records specified in paragraph
(d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate, for
that glycol dehydration unit.
§63.774 (d)(1)(ii) - The actual average benzene emissions (in
terms of benzene emissions per year) as determined in
accordance with §63.772(b)(2).
MACT HH Applicable
Requirements
Area Source
Outside UA/UC boundary
§63.760 -
Applicability and
designation of
affected source '
§63.760 (f) - The owner or operator of an affected major source
shall achieve compliance with the provisions of this subpart by
the dates specified in paragraphs (f)(1) and (f)(2) of this section.
The owner or operator of an affected area source shall achieve
compliance with the provisions of this subpart by the dates
specified in paragraphs (f)(3) through (f)(6) of this section.
Page 10 of 28
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
§63.764 - General
Standards
§63.764 (d)(2) -Each owner or operator of an area source not
located in a UA plus offset and UC boundary (as defined in
§63.761) shall comply with the provisions specified in paragraphs
(d)(2(i) through (iii) of this section.
§63.764 (d)(2)(i) - Determine the optimum glycol circulation rate
using the following equation:
LOFT =1.15*3.0gal TEG*(F*(I—O))
1b H2O 24hr/day
Where:
LOPT = Optimal circulation rate, gal/hr.
F = Gas flowrate (MMSCF/D)
I = Inlet water content (lb/MMSCF)
O = Outlet water content (lb/MMSCF)
3.0 = The industry accepted rule of thumb for a TEG-to water
ratio (gal TEG/lbH2O)
1.15 = Adjustment factor included for a margin of safety.
§63.764 (d)(2)(ii) - Operate the TEG dehydration unit such that
the actual glycol circulation rate does not exceed the optimum
glycol circulation rate determined in accordance with paragraph
(d)(2)(i) of this section. If the TEG dehydration unit is unable to
meet the sates gas specification for moisture content using the
glycol circulation rate determined in accordance with paragraph!
(d)(2)(i), the owner or operator must calculate an alternate
circulation rate using GRI-GLYCalcTM, Version 3.0 or higher. The
owner or operator must document why the TEG dehydration unit
must be operated using the alternate circulation rate and submit
this documentation with the initial notification in accordance
with §63.775(c)(7).
§63.764 (d)(2)(iii) - Maintain a record of the determination
specified in paragraph (d)(2)(ii) in accordance with the
requirements in §63.774(f) and submit the Initial Notification in
accordance with the requirements in §63.775(c)(7). If operating
conditions change and a modification to the optimum glycol
circulation rate is required, the owner or operator shall prepare a
new determination in accordance with paragraph (d)(2)(i) or (ii)
of this section and submit the information specified under
§63.775(c)(7)(ii) through (v).
Page 11 of 28
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
§63.774 -
Recordkeeping
Requirements
563.774 (b) - Except as specified in paragraphs (c), (d), and (f) of
this section, each owner or operator of a facility subject to this
subpart shall maintain the records specified in paragraphs (b)(1)
through (11) of this section §63.774 (b)(1)
563.774 (b)(1) - The owner or operator of an affected source
subject to the provisions of this subpart shall maintain files of all
information (including all reports and notifications) required by
this subpart. The files shall be retained for at least 5 years
following the date of each occurrence, measurement,
maintenance, corrective action, report or period.
§63.774 (b)(1)(i) - All applicable records shall be maintained in
such a manner that they can be readily accessed.
563.774 (b)(1)(ii) - The most recent 12 months of records shall be
retained on site or shall be accessible from a central location by
computer or other means that provides access within 2 hours
after a request.
§63.774 (b)(1)(iii) - The remaining 4 years of records may be
retained offsite.
§63.774 (b)(1)(iv) - Records may be maintained in hard copy or
computer -readable form including, but not limited to, on paper,
microfilm, computer, floppy disk, magnetic tape, or microfiche.
§63.774 (f) - The owner or operator of an area source not located
within a UA plus offset and UC boundary must keep a record of
the calculation used to determine the optimum glycol circulation
rate in accordance with §63.764(d)(2)(i) or §63.764(d)(2)(ii), as
applicable.
Page 12 of 28
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
563.775 - Reporting
Requirements
563.775 (c) - Except as provided in paragraph (c)(8), each owner
or operator of an area source subject to this subpart shall submit
the information listed in paragraph (c)(1) of this section. If the
source is located within a UA plus offset and UC boundary, the
owner or operator shall also submit the information listed in
paragraphs (c)(2) through (6) of this section. If the source is not
located within any UA plus offset and UC boundaries, the owner
or operator shall also submit the information listed within
paragraph (c)(7).
563.775 (c)(1) - The initial notifications required under
§63.9(b)(2) not later than January 3, 2008. In addition to
submitting your initial notification to, the addressees specified
under §63.9(a), you must also submit a copy of the initial
notification to EPA's Office of Air Quality Planning and Standards.
Send your notification via e-mail to CCG-ONG®EPA.GOV or via
U.S. mail or other mail delivery service to U.S. EPA,' Sector
Policies and Programs Division/Coatings and Chemicals Group
(E143-01), Attn: Oil and Gas Project Leader, Research Triangle
Park, NC 27711.
563.775 (c)(7) - The information listed in paragraphs (c)(1)(i)
through (v) of this section. This information shall be submitted
with the initial notification.
§63.775 (c)(7)(i) - Documentation of the source's location relative
to the nearest UA plus offset and UC boundaries. This information
shall include the latitude and longitude of the affected source;
whether the source is located in an urban cluster with 10,000
people or more; the distance in miles to the nearest urbanized
area boundary if the source is not located in an urban cluster with
10,000 people or more; and the names of the nearest urban
cluster with 10,000 people or more and nearest urbanized area.
§63.775 (c)(7)(ii) - Calculation of the optimum glycol circulation
rate determined in accordance with §63.764(d)(2)(i).
563.775 (c)(7)(iii) - If applicable, documentation of the alternate
glycol circulation rate calculated using GRI-GLYCalcTM, Version
3.0 or higher and documentation stating why the TEG dehydration
unit must operate using the alternate glycol circulation rate.
§63.775 (c)(7)(iv) - The name of the manufacturer and the model
number of the glycol circulation pump(s) in operation.
§63.775 (c)(7)(v) - Statement by a responsible official, with that
official's name, title, and signature, certifying that the facility
Page 13 of 28
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
will always operate the glycol dehydration unit using the optimum
circulation rate determined in accordance with §63.764(d)(2)(i) or
§63.764(d)(2)(ii), as applicable.
§63.775 (f) - Notification of process change. Whenever a process
change is made, or a change in any of the information submitted
in the Notification of Compliance Status Report, the owner or
operator shall submit a report within 180 days after the process
change is made or as a part of the next Periodic Report as
required under paragraph (e) of this section, whichever is sooner.
The report shall include:
§63.775 (f)(1) - A brief description of the process change;
§63.775 (f)(2) - A description of any modification to standard
procedures or quality assurance procedures
§63.775 (f)(3) - Revisions to any of the information reported in
the original Notification of Compliance Status Report under
paragraph (d) of this section; and
§63.775 (f)(4) Information required by the Notification of
Compliance Status Report under paragraph (d) of this section for
changes involving the addition of processes or equipment.
OPERATING &r MAINTENANCE REQUIREMENTS
25. Point(s) 001, 002, 004, 005, 006, 007: Upon startup of these points, the owner or operator
shall follow the most recent operating and maintenance (0&tM) 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 0&tM 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
26. Point(s) 001, 002: 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.
27. Point(s) 004: The owner or operator shall complete the initial extended wet gas analysis within
one hundred and eighty days (180) of the latter of commencement of operation or issuance of
Page 14 of 28
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
this permit. The owner or operator shall use this analysis to calculate actual emissions, as
prescribed in the Emission Limitation and Records section of this permit, to verify initial
compliance with the emission limits. The owner or operator shall submit the analysis and the
emission calculation results to the Division as part of the self -certification process. (Reference:
Regulation Number 3, Part B, Section III.E.)
28. Point(s) 005, 006, 007: A source initial compliance test shall be conducted to measure the
emission rate(s) for the pollutants listed below in order to demonstrate compliance with the
emission limits in this permit. The test protocol must be in accordance with the requirements
of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the
Division for review and approval at least thirty (30) days prior to testing. No compliance test
shall be conducted without prior approval from the Division. Any compliance test conducted to
show compliance with a monthly or annual emission limitation shall have the results projected
up to the monthly or annual averaging time by multiplying the test results by the allowable
number of operating hours for that averaging time (Reference: Regulation No. 3, Part B.,
Section III.G.3)
Oxides of Nitrogen using EPA approved methods.
Carbon Monoxide using EPA approved methods.
Periodic Testing Requirements
29. Point(s) 004: The owner or operator shall complete an extended wet gas analysis prior to the
inlet of the dehydration unit on an annual basis. Results of the wet gas analysis shall be used
to calculate emissions of criteria pollutants and hazardous air pollutants per this permit and be
provided to the Division upon request.
30. Point(s) 005, 006, 007: This engine is subject to the periodic testing requirements as specified
in the operating and maintenance (0&tM) plan as approved by the Division. Revisions to your
0&M plan are subject to Division approval. Replacements of this unit completed as Alternative
Operating Scenarios may be subject to additional testing requirements as specified in
Attachment A.
ADDITIONAL REQUIREMENTS
31. 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
Page 15 of 28
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 •
sexisting APEN expires.i
Within 14 calendar days of commencing operation of a permanent replacement engine
under the alternative operating scenario outlined in this permit as Attachment A. The
APEN shall include the specific manufacturer, model and serial number and horsepower
of the permanent replacement engine, the appropriate APEN filing fee and a cover letter
explaining that the owner or operator is exercising an alternative -operating scenario
and is installing a permanent replacement engine.
GENERAL TERMS AND CONDITIONS
32. 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.
33. 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.
34. 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.
Page 16 of 28
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
35. 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.
36. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
37. 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.
38. 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.
Timothy Sharp
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Summit Midstream Niobrara, LLC.
Page 17 of 28
COLORADO
Air Pollution Control Division
Department of Pubf c Health Er 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 lI.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)
TK-01
001
Benzene
71432
12
1
n -Hexane
110543
9,292
906
TK 02-05
002
Benzene
71432
6
1
n -Hexane
110543
80
8
BD -01
003
Benzene
71432
43
43
n -Hexane
110543
994
994
DU -01
004
Benzene
71432
104,380
5,000
Toluene
108883
34,880
1,660
Ethylbenzene
100414
2,660
120
Xylenes
1330207
1,540
80
n -Hexane
110543
55,860
1,580
GE -01
005
Formaldehyde
50000
10,394
2,543
Acetaldehyde
75070
551
275
Acrolein
107028
339
169
Page 18 of 28
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
Methanol
67561
165
82
n -Hexane
110543
73
37
Benzene
71432
29
14
CE -O1
006
Formaldehyde
50000
11,105
2,665
Acetaldehyde
75070
1,237
619
Acrolein
107028
761
380
Methanol
67561
370
186
n -Hexane
110543
164
82
Benzene
71432
65
33
CE -02
007
Formaldehyde
50000
11,105
2,665
Acetaldehyde
75070
1,237
619
Acrolein
107028
761
380
Methanol
67561
370
186
n -Hexane
110543
164
82
Benzene
71432
65
33
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates
above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on
the most recent Air Pollution Emission Notice.
5) Point(s) 001:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
VOC
20.55
1.03
E&tP Tanks
110543
n -Hexane
2.546
0.127
EEtP Tanks
Note: The controlled emissions factors for this point are based on a control efficiency of 95%
due to 5% annual VRU downtime.
Point(s) 002:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
VOC
0.110
0.01
ProMax
Note: The controlled emissions factors for this point are based on a control efficiency of 95%
due to 5% annual VRU downtime.
Page 19 of 28
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Point(s) 003:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/MMscf
Source
VOC
20842
ProMax
110543
n -Hexane
955
ProMax
Point(s) 004:
The emission levels contained in this permit are based on information provided in the application
and the GRI GlyCalc 4.0 model. Controlled emissions are based on a condenser control of 95% and
VRU annual operation -minus -downtime of 95%. Flash tank emissions are rerouted to inlet at
assumed 100% collection.
No combustion emissions are expected from this point.
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF)
Source
VOC
68.83
GlyCalc
71432
Benzene
9.53192
GlyCalc
108883
Toluene
3.18552
GlyCalc
100414
Ethylbenzene
0.24296
GlyCalc
1330207
Xylenes
0.1404
GlyCalc
110543
n -Hexane
5.10064
GlyCalc
Point 005:
CAS
Pollutant
Emission
Uncontrolled
lb/MMBtu
Factors -
g/bhp-hr
Emission
Controlled
lb/MMBtu
Factors -
g/bhp-hr
NOx
0.1517
0.50
0.1517
0.50
CO
0.8008
2.64
0.0561
0.18
VOC
0.4186
1.38
0.2135
0.70
50000
Formaldehyde
0.1577
0.52
0.0379
0.12
75070
Acetaldehyde
0.0084
0.03
0.0084
0.03
107028
Acrolein
0.0051
0.02
0.0051
0.02
67561
Methanol
0.0025
0.01
0.0025
0.01
110543
n -Hexane
0.0011
0.00
0.0011
0.00
71432
Benzene
0.0004
0.00
0.0004
0.00
108883
Toluene
0.0004
0.00
0.0004
0.00
Page 20 of 28
COLORADO
Air Pollution Control Division
Department of Public Health t Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Emission factors are based on a Brake -Specific Fuel Consumption Factor of 7268 Btu/hp-hr, a
site -rated horsepower value of 1035, and a fuel heat value of 1134 Btu/scf.
Emission Factor Sources:
CAS
Pollutant
Uncontrolled EFSource
Controlled EF Source
NOx
manufacturer
Catalyst
CO
manufacturer
Catalyst
VOC
manufacturer
Catalyst
50000
Formaldehyde
manufacturer
Catalyst
75070
Acetaldehyde
AP -42; Table 3.2-2
(7/2000); Natural Gas
No Control
107028
Acrolein
AP -42; Table 3.2-2
(7/2000); Natural Gas
No Control
67561
Methanol
AP -42; Table 3.2-2
(7/2000); Natural Gas
No Control
110543
n -Hexane
AP -42; Table 3.2-2
(7/2000); Natural Gas
No Control
71432
Benzene
AP -42; Table 3.2-2
(7/2000); Natural Gas
No Control
108883
Toluene
AP -42; Table 3.2-2
(7/2000); Natural Gas
No Control
Point 006 &t 007:
CAS
Pollutant
Emission
Uncontrolled
lb/MMBtu
Factors -
g/bhp-hr
Emission
Controlled
lb/MMBtu
Factors -
g/bhp-hr
NOx
0.1631
0.50
0.1631
0.50
CO `
0.8255 '
2.53
0.0578
0.18
VOC
0.3426
1.05
0.2295
0.70
50000
Formaldehyde
0.0750
0.23
0.0180
0.06
75070
Acetaldehyde
0.0084
0.03
0.0084
0.03
107028
Acrolein
0.0051
0.02
0.0051
0.02
67561
Methanol
0.0025
0.01
0.0025
0.01
110543
n -Hexane
0.0011
0.00
0.0011
0.00
71432
Benzene
0.0004
0.00
0.0004
0.00
108883
Toluene
0.0004
0.00
0.0004
0.00
Emission factors are based on a Brake -Specific Fuel Consumption Factor of 6757 Btu/hp-hr, a
site -rated horsepower value of 2500, and a fuel heat value of 1134 Btu/scf.
Emission Factor Sources:
CAS
Pollutant
Uncontrolled EFSource
Controlled EF Source
NOx
manufacturer
Catalyst
CO
manufacturer
Catalyst
VOC
manufacturer
Catalyst
50000
Formaldehyde
manufacturer
Catalyst
Page 21 of 28
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CAS
Pollutant
Uncontrolled EFSource
Controlled EF Source
75070
Acetaldehyde
AP -42; Table 3.2-2
(7/2000); Natural Gas
No Control
107028
Acrolein
AP -42; Table 3.2-2
(7/2000); Natural Gas
No Control
67561
Methanol
AP -42; Table 3.2-2
(7/2000); Natural Gas
No Control
110543
n -Hexane
AP -42; Table 3.2-2
(7/2000); Natural Gas
No Control
71432
Benzene
AP -42; Table 3.2-2
(7/2000); Natural Gas
No Control
108883
Toluene
AP -42; Table 3.2-2
(7/2000); Natural Gas
No Control
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) Point(s) 004: This permit fulfills the requirement to hold a valid permit reflecting the glycol
dehydration unit and associated control device per the Colorado Oil and Gas Conservation
Commission rule 805b(2)(B) when applicable.
8) Point(s) 005, 006, 007: This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of
Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008
Federal Register posting - effective March 18, 2008). This rule has not yet been incorporated into
Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is
available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ja08.pdf
9) Point(s) 005, 006, 007: This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission
Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January
18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments
to include requirements for area sources and engines < 500 hp located at major sources have not
yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of
the complete subpart is available on the EPA website at:
http://www.epa.gov/ttn/atw/area/fr18ja08.pdf Additional information regarding area source
standards can be found on the EPA website at: http://www.epa.gov/ttn/atw/area/arearules.html
Page 22 of 28
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
10) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs, CO
PSD or NANSR
Synthetic Minor Source of: VOC
MACT HH
Area Source Requirements: Applicable
MACT ZZZZ
Major Source Requirements: Not Applicable
Area Source Requirements: Applicable
11) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT `
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 23 of 28
COLORADO
Air Pollution Control Division
Department of Public Health 5 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
October 12, 2012
2. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired
reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part
A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and
Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has
been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a
Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be
allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction
Permit.
2.1 Engine Replacement
The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance
and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine.
"Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as
in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the
engine is in operation. If the engine operates only part of a day, that day shall count, as a single day towards the 90 day total.
The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance
demonstrations or periodic monitoring required by this permit.
All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including
monitoring and record keeping).
The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar
days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT
requirements.
Results of all tests shall be kept on site for five (5) years and made available to the Division upon request.
The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine
replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are
replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement
engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section
2.1.2 and make them available to the Division upon request.
2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this
permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or
horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with
all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary
replacement engine shall be made as set forth in section 2.2.
2.1.2 The owner or operator may permanently replace the existing engine with another engine with the same manufacturer,
model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all
Page 24 of 28
COLORADO
Air Pollution Control Division
Department of Public Health S Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the
replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable
emission limitations shall be made as set forth in section 2.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower
of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar
days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing
fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a
permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example
Applicability Reports can be found at www.colorado.gov/cdphe/air/AOS. This submittal shall be accompanied by a
certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry,
the statements and information included in the submittal are true, accurate and complete".
This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is
not subject to emission limits.
The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted
to the Division in regard to any permanent engine replacement.
2.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable
Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing
requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit
for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS
will serve as the quarterly test and an additional portable analyzer test is not required for another three months).
The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if
approved in advance by the Division.
The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the
replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the
replacement engine.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring
Protocol (ver March 2006 or newer) as found on the Division's web site at: www.colorado.gov/cdphe/portable-analyzer-
monitoring-protocol
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be
converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to
monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum
number of hours in the month or year (8760), whichever applies.
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based
(ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the
test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol
document.
Page 25 of 28
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
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible
evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations
for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer
results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out
of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX
and CO emission limitations or until the engine is taken offline.
2.3 Applicable Regulations for Permanent Engine Replacements
2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2
All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment
must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance
or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions
of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows:
In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX
and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion
engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NOX: The emission limitations in NSPS JJJJ
SO2: Use of natural gas as fuel
PM10: Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of
total sulfur per 100 standard cubic feet.
2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State -Only conditions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable
control requirements specified in Regulation No. 7, section XVI, as specified below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective catalyst and air fuel
controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce
emissions.
The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained
according to manufacturer specifications.
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
Emission Standards: Section XVII E — State -only requirements
Page 26 of 28
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
Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in
the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to
the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the
entire life of the engine so that it achieves the emission standards required in the table below:
Max Engine HP
Construction or
Relocation Date
Emission Standards in G/hp-hr
NOx
CO
VOC
January 1, 2008
2.0
4.0
1.0
100<Hp<500
January 1, 2011
1.0
2.0
0.7
500≤Hp
July 1, 2007
July 1,2010
2.0
1.0
4.0
2.0
1.0
0.7
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60 Subpart JJJJ
A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008
for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or
equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350
hp are subject to the requirements of 40 CFR Part 60, Subpart JUL An analysis of applicable monitoring, recordkeeping, and
reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under
Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required
by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division,
provided that such test is conducted within the time frame specified in Condition 2.2.
Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of
Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the
date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the
applicability of NSPS JJJJ requirements).
However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to
NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to
the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § I.B (which is referenced in Part A), any
engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to
the requirements of NSPS JJJJ.
2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ
A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63,
Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine
replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT
is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by
this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time
frame specified in Condition 2.2.
2.4 Additional Sources
The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit,
not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The
Page 27 of 28
COLORADO
Air Pollution Control Division
Department of Public Health ft Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission
point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate
Construction/Operating permitting process prior to installation.
Page 28 of 28
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 res
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.
RECEIVED
FEB 1 2 r�2019
1PCD
StatioQury
Scrurcc.,5
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.Rov/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: 1g we.
o AIRS ID Number: 3 /' 1 Q Z1/ 00 t
2.
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name:
Site Name:
Site Location:
Summit Midstream Niobrara, LLC
Brahma Compressor Station
SW 1/4 Sec 28 T12N R63W
Mailing Address:
(Include Zip Code) 999 18th Street, , Suite 2500S
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person:
Phone Number:
E -Mail Address2: aparisi@summitmidstream.com
Andrew Parisi
(303) 626-8269
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.
393310
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 1
"c t.oR:A DO
tiimitOMEitelioNniie
I
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
El NEW permit OR newly -reported emission source
❑✓ Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 ❑ 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 & Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-1O6) 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: Condensate Storage
Company equipment Identification No. (optional): TK-01
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 07/01/2019
Normal Hours of Source Operation: 24
hours/day 7 days/week 52
weeks/year
Storage tank(s) located at: 0 Exploration Et Production (E&P) site El Midstream or Downstream (non E&P) site
Will this equipment be operated in any NAAQS nonattainment area?
■
Yes
SI
No
Are Flash Emissions anticipated from these storage tanks?
12
Yes
•
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
IN
Yes
I5I
No
If "yes", identify the stock tank gas -to -oil ratio:
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
•
0
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualIN
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
■
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
21
COLORADO
MAUI b GreUarmml
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual °Annual Amount
(bbllyear)
Requested Annual Permit'Limit5
:Condensate Throughputso
3,650
From what year is the actual annual amount?
Projected
Average API gravity of sales oil: 80.16 degrees
❑ Internal floating roof
Tank design: ❑✓ Fixed roof
RVP of sales oil: 10.48
❑ External floating roof
,Storage
Tank ID
of Liquid Manifold Storage
,essels in Storage Tan
Tdtal Volume of
Storage,Tank
(bbl)
ista{lation Date -of Most
Recent Storage Vessel in
Storage Tank (month/ year)
Dateof First
Production `.
(month/year),::;
TK-01
1
400
TBD
TBD
111 Number,
Wells Serviced t y this Storage Tank or Tank Battery6 (E&P Sites Only)
Name of Well
Newly Reported Well
0
0
0
0
0
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The EFtP 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
Geographical Coordinates
(Latitude/Longitude or' UTM)
40.9801601, -104.4285920
Operator; Stack
ID No
Discharge Height Above
,,.Ground Level (feet) _
Temp.
9
- (F);: w .
Flow Rate
'(ACFM) i .
,Velocity.,
(ft/sec):
Indicate the direction of the stack outlet: (check one)
❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Square/rectangle
❑ 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
COLORADO
IiBatiMjiEnvU W tmtinl
Permit Number: AIRS ID Number:
[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.
Pollutants Controlled: VOC & HAPs
Vapor
❑✓ Recovery
Unit (VRU):
Size: TBD
Make/Model: TBD
Requested Control Efficiency: 95
VRU Downtime or Bypassed (emissions vented): 5
❑ Combustion
Device:
Pollutants Controlled:
Rating: MMBtu/hr
Type: Make/Model:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature: Waste Gas Heat Content:
Constant Pilot Light: ✓❑ Yes ❑ No Pilot Burner Rating:
Btu/scf
MMBtu/hr
hr
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig
Describe the separation process between the well and the storage tanks:
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 4
COLOR A
Wwinfar 4i xn .e
Permit Number:
AIRS ID Number:
[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):
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
VRU
95
NOx
CO
HAPs
VRU
95
Other:
From what year is the following reported actual annual emissions data?
Criteria Pollutant Emissions Inventory,
Pollutant
Emission Factor 7
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5:
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
.(Tons/year)
Controlled
Emissionss
(Tonslyear).
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
.(Tons/year),,,
VOC
20.546
lb/bbl
E&P Tanks
37.50
1.87
NOx
CO
Non -Criteria Reportable Pollutant Emissions Inventory . .
Chemical Name
. ..
Chemical
Abstract
Service (CAS)
Number `
Emission Factor? :
Actual Annual Emissions
Uncontrolled
Basis
Units ,
Source
(AP -42,
Mfg, etc)
Uncontrolled
Emissions
(Pounds/year)
Controlled
Emissions 8
(Pounds/year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
2.546
lb/bbl
E&P Tanks
9,293
465
2,2,4-
Trimethylpentane
540841
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 5
ICOLORADO=
�fi at hBkn MtA�ilcnt
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all 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.
02/11/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Zak N. Covar
Vice -President HSE&R
Name (print) Title
Check the appropriate box to request a copy of the:
j✓ Draft permit prior to issuance
Q✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
43OO Cherry Creek Drive South
Denver, CO 80246-153O
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 6
COLORADO
DcpwarsziorPulac
tc.n: s anvirenmaet
RECEIVED
FEB 1 2 2019
Produced Water Storage Tank(s)
APEN - Form APCD-207
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, inclu
updates. An application with missing information may be determined incomplete and may be returned or res
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.
APCD
Stationary
3n1B B'ti per„„�.
This APEN is to be used for tanks that store produced water 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, condensate 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.Qov/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.
AIRS ID
Permit Number: �
lei U�t E O I (.Q Number: 123 IA.02q/ 2Q" L 002'
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name1:
Site Name:
Site Location:
Summit Midstream Niobrara, LLC
Brahma Compressor Station
Site Location
SW 1/4 Sec 28 T12N R63W County: Weld
Mailing Address:
(Include Zip Code) 999 18th Street, Suite 2500S
Denver, CO 80202
NAICS or SIC Code: 1311
Contact Person: Andrew Parisi
Phone Number: (303) 626-8269
E -Mail Address2: aparisi@summitmidstream.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
393311
COLORADO
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 1 I
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
❑✓
Request coverage under traditional construction permit
❑ Request coverage under a General Permit
0 GP05 ❑ 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 ❑ Change company name3
❑ Change permit limit ❑ Transfer of ownership4 0 Other (describe below)
- OR
• APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
▪ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air, Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info & Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Company equipment Identification No. (optional):
For existing sources, operation began on:
Produced Water Storage
TK 02-05
For new or reconstructed sources, the projected start-up date is: 07/01/2019
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week 52
❑ Exploration & Production (E&P) site
weeks/year
❑✓ Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
•
Yes
A
No
Are. Flash Emissions anticipated from these storage tanks?
Ol
Yes
■
No
Are these storage tanks located at a commercial facility that accepts oil production
wastewater for processing?
❑
Yes
No
✓
Do these storage tanks contain less than 1% by volume crude oil on an annual average basis?
151
Yes
❑
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series wrest 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
✓
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018
21
COLORADO,
of Public
}bath 6 bovlmnment
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbll year)
Produced Water Throughput:
Requested Annual Permit Limits
(bbl /year)
40,150
From what year is the actual annual amount?
Tank design:
❑ Fixed roof
Projected
❑ Internal floating roof
❑ External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in .
Storage Tank.(month/year)
ate of First
Production
(monthlyear)
TK 02-05
4
1600
TBD
TBD
Wells Serviced by this Storage Tank or Tank Batter/ (EttP Sites On y)
API Number
Name of Well
Newly Reported Well
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The EfrP 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
Geographical Coordinates
(Latitude/Longitude or UTM)
40.9801601, -104.4285920
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F);=
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
❑ Upward
❑ Horizontal
❑ Downward
['Other (describe):
0 Upward with obstructing raincap
Indicate the stack opening and size: (check one)
O Circular Interior stack diameter (inches):
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
['Other (describe):
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018
3I
coL0RAno<
Hontii siRa�i9renent
Permit Number:
AIRS ID Number:
[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: VOC & HAPs
Size: TBD
Make/Model: TBD
Requested Control Efficiency: 95
VRU Downtime or Bypassed (emissions vented): 5
❑ Combustion
Device:
Pollutants Controlled:
Rating:
Type:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature:
MMBtu/hr
Make/Model:
Waste Gas Heat Content:
Constant Pilot Light: ❑ Yes ❑ No Pilot Burner Rating:
Btu/scf
MMBtu/hr
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
0/0
Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig
Describe the separation process between the well and the storage tanks:
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 4
COLORADO.
5 h0F.0J lluncnk
keulllsBF ui�rtnmrtmt
Permit Number:
AIRS ID Number:
[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):
Pollutant
Description of Control Method(s) :
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
VRU
95
NOx
CO
HAPs
VRU
95
Other:
From what year is the following reported actual annual emissions data?
Criteria PollutantEmissions Inventory
Pollutant
VOC
Emission Factor7.
Actual Annual Emissions
Requested Annual Permit
Ernission:Limit(s)s
Uncontrolled
Basis
0.11
Units
lb/bbl
• Source
(AP -.42,
':Mfg., etc.)
Eng. Est.
Uncontrolled
Emissions_
(tons/ year) ,,:
Controlled
Emissions
,(tons/year)
Uncontrolled
Emissions
(tons/year).
2.21
Controlled
Emissions -
ftonsiyear).;
0.11
NOx
CO
Non -Criteria Reportable Pollutant Emissions Inventory . .
Chemical Nellie'
Chemical
Abstract
Service (CAS)
Number
Emission Factor?
Actual Annual Emissions,..
Uncontrolled
Basis
Units
Source
(AP -42,
mfg., etc.
g )
Uncontrolled
Emissions
(pounds/year)
y )
Controlled
Emissions$' .. .
(pounds/year):
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
2,2,4-
Trimethylpentane
540841
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
7 Attach produced water 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-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 5
COLD Rfl DO
MCA=
wa�c��w�,��: n
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
02/11/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Zak N. Covar Vice -President HSE&R
Name (print) Title
Check the appropriate box to request a copy of the:
✓❑ Draft permit prior to issuance
�✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.Rov/cdphe/apcd
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018
6j
COLORADO.
..._.m sE„wemOwni
cI1UEI)
Fro 2 2019
iP r
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separator
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.colorado.aov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: `a vvE--'Q DI AIRS ID Number: t 23 /p-02.1/ C70 3
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Namet: Summit Midstream Niobrara, LLC
Site Name: Brahma Compressor Station
Site Location:
SW1/4 Sec 28 T12N R63W
Mailing Address: 999 18th Street, Suite 2500S
(Include Zip Code)
Site Location
County: Weld
NAICS or SIC Code: 1311
Denver, CO Contact Person: Andrew Parisi
Phone Number: (303) 626-8269
E -Mail Address2: aparisi@summitmidstream.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-211 - Gas Venting APEN - Revision 7/2018 1
333303
COLO:RAD'O-
o.p.,®,eaPublic
xwroscnm,.n
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 0 Add point to existing permit
❑ Change permit limit 0 Transfer of ownership' 0 Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: Facility blowdown emissions
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: Natural gas venting during facility downtime
Company equipment Identification No. (optional): BD -01
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
07/01/2019
O Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
TBD hours/day TBD days/week TBD weeks/year
Will this equipment be operated in any NAAQS
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
Yes
Yes
Yes
Form APCD-211 - Gas Venting APEN - Revision 7/2018 2
❑✓ No
❑✓ No
❑✓ No
COLORADO
wtOvum. Nftsn nM
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
❑ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
Compressor Rod Packing
Serial #:
Capacity: gal/min
Make: Model: # of Pistons: Leak Rate: Scf/hr/pist
❑✓ Blowdown Events
# of Events/year: 104 Volume per event: 0.01 MMscf/event
❑✓ Other
Description: Maintenance, Startup, Shutdown, Upset, and Emergency Conditions
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy?
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑ Yes ❑✓ No
Vent Gas
Heating Value:
1,221
BTU/SCF
Requested:
1.04
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
23.95
VOC (Weight %)
32.99
Benzene (Weight %)
0.08
Toluene (Weight %)
0.02
Ethylbenzene (Weight
%1
0.0013
Xylene (Weight %)
0.0006
n -Hexane (Weight %)
1.52
2,2,4-Trimethylpentane
(Weight %)
0.00
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 Et n -Hexane, temperature, and
pressure)
E
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-211 - Gas Venting APEN - Revision 7/2018
31
:CO L0:St;k'C Q,
uq�raums, �P,.]2ic
ht�il Ssr.Nx9vnitC
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
e®raphical Coordinate:
(Latitude/Longitude or LITM)
40.9801601, -104.4285920
k • a
®
w�
�
C
n
Indicate the direction of the stack outlet: (check one)
❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Other (describe):
Interior stack diameter (inches):
❑ Upward with obstructing raincap.
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.
❑ VRU:
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Make/Model:
❑ Combustion
Device:
Pollutants Controlled:
Rating:
Type:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature:
MMBtu/hr
Make/Model:
Waste Gas Heat Content: Btu/scf
Constant Pilot Light: ❑ Yes ❑ No Pilot burner Rating: MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-211 - Gas Venting APEN - Revision 7/2018
AVM L ItA Any?,
4 I MYm
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - 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):
Pollutant
Description of Control Method(s)
Overall Requested
Control Efficiency
(X reduction in emissions) .
PM
SOX
NO.
CO
VOC
HAPs
Other:
From what year is the following reported actual annual emissions data? Projected
Criteria Pollutant Emissions Inventory ..
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual.Perniit
Emission Lim
Uncontrolled
Basis
Units
Source
(AP 42,
Mfg., etc.)
Uncontrolled
Emissions'
(tons/year)
Controlled
Emissionss.
(tons/year),
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tonslyear)
PM
SOX
NO.
CO
VOC
20.827
Ib/Mscf
Promax
10.83
10.83
Non-CriteriaReportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service(CAS)
Number
Emission Factor :.
Actual Annual Emissions.
Uncontrolled
Basis
Units
source
(AP -42;
Mfg., etc.)
Uncontrolled
Emissions .
(pounds/year)
Controlled
Emissions 6
(pounds%year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.961
lb/Mscf
Promax
1000
1000
2,2,4-
Trimethylpentane
540841
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-211 - Gas Venting APEN - Revision 7/2018
51
COLORADO
c�xm:mar ue:
3i Pntl M `m Ei1k1'mnmsnt
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
02/11/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Zak N. Covar
Vice -President HSE&R
Name (please print) Title
Check the appropriate box to request a copy of the:
ID Draft permit prior to issuance
El Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.Rov/cdphe/apcd
Form APCD-211 - Gas Venting APEN - Revision 7/2018
6J
COLORADO
Dup.:mantllatc
Warn, 6 EnaJtomnael
RECEIVED
FEB 1 2 2019
Glycol Dehydration Unit APEN
Form APCD-202
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, includin
updates. An application with missing information may be determined incomplete and may be returned o s
longer application processing times. You may be charged an additional APEN fee if the APEN is filled ou
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for glycol dehydration (dehy) units only. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.cotorado.i;ov/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.
AFCT)
Permit Number: iq Aja-c) ( ( AIRS ID Number: 23 /king/ (1Q4 -
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Summit Midstream Niobrara, LLC
Site Name: Brahma Compressor Station
Site Location: SW 1/4 Sec 28 T12N R63W
Mailing Address:
(Include Zip Code) 999 18th Street, Suite 2500S
Site Location
County: Weld
NAICS or SIC Code: 1311
Denver, CO 80202 Contact Person: Andrew Parisi
Phone Number:
(303) 626-8269
E -Mail Address2: aparisi@summitmidstream.com
' 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.
393312
Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 1 I
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit ft and AIRS ID]
Section 2 - Requested Action
El NEW permit OR newly -reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment O Change company name3 ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership' O Other (describe below)
OR -
▪ APEN submittal for update only (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: Flash tank emissions routed to facility inlet for 100% control
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: Dehydration of natural gas
Company equipment Identification No. (optional): DU -01
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
07/01/2019
✓❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Will this equipment be operated in any NAAQS
nonattainment area?
hours/day days/week
Is this unit located at a stationary source that is considered
a Major Source of (HAP) Emissions?
❑ Yes
Yes
l
Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 2
weeks/year
No
No
COLORADO.
Health 6 L` aimonnad
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Dehydration Unit Equipment Information
Manufacturer:
TBD
Dehydrator Serial Number:
Glycol Used:
Glycol Pump Drive:
TBD
Model Number: 30MMSCFD TEG Dehy
Reboiler Rating: 1 .5
❑ Ethylene Glycol (EG) O DiEthylene Glycol (DEG) 0
0 Electric O Gas
Pump Make and Model: TBD
If Gas, injection pump ratio:
MMBTU/hr
TriEthylene Glycol (TEG)
Glycol Recirculation rate (gal/min):
Lean Glycol Water Content:
Max: 12
1.0 Wt.%
Requested: 12
Acfm/gpm
# of pumps: TBD
Dehydrator Gas Throughput:
Design Capacity:
Requested5:
30
MMSCF/day
10,950 MMSCF/year
Actual: MMSCF/year
Inlet Gas:
Water Content:
Flash Tank:
Cold Separator:
Pressure: 800 psig
Wet Gas: 69.37 lb/MMSCF
Pressure: 60 psig
Pressure: psig
Stripping Gas: (check one)
O None ❑ Flash Gas O Dry Gas O Nitrogen
Flow Rate:
scfm
Temperature:
❑ Saturated
Temperature:
Temperature:
100
Dry gas:
160 °F
°F
5.0
°F
lb/MMSCF
❑ NA
❑✓ NA
Additional Required Information:
O Attach a Process Flow Diagram
O Attach GRI-GLYCaIc 4.0 Input Report a Aggregate Report (or equivalent simulation report/test results)
O Attach the extended gas analysis (including BTEX n -Hexane, temperature, and pressure)
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 3 1
Permit Number:
AIRS ID Number: / I
[Leave blank unless APCD has already assigned a permit €t and AIRS ID]
Section 5 - Stack Information
40.9801601, -104.4285920
- �L r
4,
" e - ci r
Indicate the direction of the stack outlet: (check one)
❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Square/rectangle
❑ Other (describe):
Interior stack diameter (inches):
O Upward with obstructing raincap
Interior stack width (inches): Interior stack depth (inches):
Section 6 - Control Device Information
O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
® Condenser:
Used for control of: Still Vent
Type: TBD
Make/Model: TBD
Maximum Temp: 160 °F Average Temp:
Requested Control Efficiency: Variable
°F
❑✓ VRU:
Used for control of: Condenser, Storage Tanks
Size: TBD Make/Model: TBD
Requested Control Efficiency: 95
VRU Downtime or Bypassed: 5
❑ Combustion
Device:
Used for control of:
Rating:
Type:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
MMBtu/hr
Make/Model:
Minimum Temperature: °F Waste Gas Heat Content: Btu/scf
Constant Pilot Light: O Yes O No Pilot Burner Rating: MMBtu/hr
Closed
❑ Loop
System:
Used for control of:
Description:
System Downtime:
O Other:
Used for control of:
Description:
Requested Control Efficiency:
Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 4
COLORADO
rom` em Daimm nsot t
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Emissions Inventory Information
Attach all emission calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction):
Pollutant
Description of Control Methods) :
0 I e uested
venal Requested
Control Efficiency.
(%.reduction in emissions)
PM
SOX
NO.
CO
VOC
VRU/Condenser
-97.5
HAPs
VRU/Condenser
-95.8
Other:
From what year is the following reported actual annual emissions data?
pollutant
PM
Source
(AP -42 =
Mfg., etc.)
Criteria Pollutant Emissions Inventory_
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5 ..
Uncontrolled
Basis
Units
Uncontrolled
Emissions'
(tonslyear)
Controlled
Emissions6
(tonslyear)
Uncontrolled
Emissions
(tonstyear)
Controlled.
Emissions
(tons/year)
SOX
NO.
CO
VOC
86.04
lb/hr
GRI-GLYcalc
376.84
9.44
Non -Criteria Reportable Pollutant Emissions. Inventory
Chemical Name
Chemical :
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions..
Uncontrolled
Bass `
Units
Source
AP -42,
(
Mfg., etc) .
Uncontrolled
Emissions _ .
(poundslyear)
Controlled
Emissions 6
(pbunds/year) .
5000
Benzene
71432
11.92
lb/hr
GRI-GLYcalc
104380
Toluene
108883
3.98
lb/hr
GRI-GLYcalc
34880
1660
Ethylbenzene
100414
0.3
lb/hr
GRI-GLYcalc
2660
120
Xylene
1330207
0.18
lb/hr
GRI-GLYcalc
1540
80
n -Hexane
110543
6.38
lb/hr
GRI-GLYcalc
55860
1580
2,2,4-
Trimethylpentane
540841
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018
5I
coLo_R A fin
ag . 7amm•.;e
Kw{�h bEF.vvtfwlment
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
02/11/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Zak N. Covar Vice -President HSE&R
Name (print) Title
Check the appropriate box to request a copy of the:
0✓ Draft permit prior to issuance
E✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
Form APCD-.202 - Glycol Dehydration Unit APEN - Revision 7/2018 6 I
COLORADO
Grtatthfr n5NP�: a
!`.oatlhfF .m,un S
Spark Ignition Engine APEN
Form APCD-201
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 A
updates. An application with missing information may be determined incomplete and may be returned or re
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 spark ignition (e.g. gas -fired) reciprocating internal combustion engines (RICE). If your
engine is a compression ignition engine (e.g. diesel -fired) or your emission unit does not fall into the RICE
category, there may be a more specific APEN for your source (e.g. compression ignition engine, mining operations,
asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty
APEN options do not meet your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD) website at: www.colorado.Qov/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.
4s
Permit Number: I q w e o q AIRS ID Number: I,25 0.02,q1 2!1/ 00
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Summit Midstream Niobrara, LLC
Site Name: Brahma Compressor Station
Site Location: SW 1/4 Sec 28 T12N R63W
Mailing Address:
(Include Zip Code) 999 18th Street, Suite 2500S
Portable Source
Home Base:
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Andrew Parisi
Phone Number: (303) 626-8269
E -Mail Address2: aparisi@summitmidstream.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
z Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 1
393313
COLORADO
Waft,° "`yam
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
O NEW permit OR newly -reported emission source (check one below)
O STATIONARY source O PORTABLE source
O Request coverage under a Construction Permit
O Request coverage under General Permit GP023 (Natural Gas Only)
If General Permit coverage is requested, the General Permit registration fee of $1,875 must be
submitted along with the APEN filing fee.
OR-
❑ MODIFICATION to existing permit (check each box below that applies)
O Change fuel or equipment O Change company name O
Add point to existing
permit
O Change permit limit O Transfer of ownerships O Other (describe below)
- OR
▪ APEN submittal for update only (Blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
▪ APEN submittal for permit-exempt/grandfathered source
❑ Notification of Alternate Operating Scenario (AOS) permanent replacement6
Additional Info Et Notes:
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary.
4 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
s For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
6 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements.
Section 3 - General Information
Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)?
If yes, provide the Company Equipment Identification No.
GE -01
Yes
General description of equipment and purpose: Power Generation
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
(http: //www.colorado.eov/cdphe/attainment)
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
07/01/2019
❑ Yes ✓❑ No
Seasonal user percentage: Dec -Feb: 25 Mar -May: 25
June -Aug: 25 Sept -Nov: 25
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018
21
COLORADO
DEparattans avaaie
Heal%b Lnairokune }t
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit ft and AIRS ID]
Section 4 - Engine Information
Engine Function:
❑✓ Primary and/or Peaking Power ❑ Emergency (max. 500 hrs/year) ❑ Compression
❑ Pump Jack ❑ Water Pump O Other:
What is the maximum number of hours this engine will be used for emergency back-up power? hours/year
Engine Make: Caterpillar Engine Model: G3512B Serial Number7: TBD
What is the maximum designed horsepower rating? 1035 hp
What is the maximum manufacturer's site -rating? 1035 hp 772 kW
What is the engine Brake Specific Fuel Consumption at 100% Load? 7268 BTU/hp-hr
Engine Features:
Cycle Type: ❑ 2 -Stroke ❑✓ 4 -Stroke Combustion: ❑✓ Lean Burn ❑ Rich Burn
Aspiration: O Natural ® Turbocharged
Is this engine equipped with an Air/Fuel ratio controller (AFRC)? 0 Yes O No
If yes, what type of AFRC is in use? ❑ OZ Sensor (mV) ❑NOx Sensor (ppm) ❑ Other:
Is this engine equipped with a Low-NOx design? p Yes O No
Engine Dates:
What is the manufactured date of this engine? TBD
What date was this engine ordered? TBD
What is the date this engine was first located to Colorado? TBD
What is the date this engine was first placed in service/operation? TBD
What is the date this engine commenced construction? TBD
What is the date this engine was last reconstructed or modified? TBD
Is this APEN reporting an AOS replacement engine? ❑ Yes ❑✓ No
If yes, provide the make, model, and serial number of the old engine below:
Engine Make:
Engine Model: Serial Number:
7 The serial number must be submitted if coverage under GPO2 is requested.
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 3 I :y
COLORADO
AeallhffiASWMnin6t
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
eographicaI Coordinates
Lotitude!Lor.2iWde or'1JT/A)
40.9801601, -104.4285920
t'. 3
t
'n•G`
C e
N
F
x
GE -01
TBD
980
6681
TBD
Indicate the direction of the Stack outlet: (check one)
O Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular
❑ Square/Rectangle
❑ Other (describe):
Interior stack diameter (inches):
Interior stack diameter (inches):
❑ Upward with obstructing raincap
TBD
Interior stack depth (inches):
Section 6 - Fuel Data and Throughput Information
6�"t�wlJ� i.
.;�� v,. I a-i
n...>i3£G��,F/ye
a.i+� F
4lx+ Gr
iPil ^5y��.�S'Y ..
i
_
5
:. 4
g..`
� 11fr
7375
S -e. d
From what year is the actual annual amount? Projected
Indicate the type of fuel used9:
❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf)
D Field Natural Gas Heating value: 1134 BTU/scf
❑ Propane (assumed fuel heating value of 2,300 BTU/scf)
❑ Landfill Gas Heating Value: BTU/scf
❑ Other (describe): Heating Value (give units):
� •`/ (-i/ifi z
8 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
9 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 4 I
COLORADO
0:Feranmtnt Pa He
e.emm sznmeanmani
Permit Number:
AIRS ID Number:
I /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Emissions Inventory Information
Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a
Natural Gas Fired Engines Calculator available to assist with emission calculations.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
Rul�utant
PrlrnaryfiControl Equi pent Description
Overall Requested Control
Efficiency
f�breduetipn in. emissions) .. _ .
TSP (PM)
PM 10
PM2.5
SOx
NOx
VOC
Oxidation Catalyst
49
CO
Oxidation Catalyst
93
Other:
Oxidation Catalyst (HCHO/iotal HAPs)
76 / 50
Use the following tables to report criteria and non -criteria pollutant emissions from source:
(Use the data reported in Section 6 to calculate these emissions.)
From what year is the following reported actual annual emissions data?
Vin.tens Polt0, 40 Ei*sian , Ti$:. )D
Pollutants
..
ELriissipp Factor
Actual Annual Emisstonsi°
`:.d "' pp. -t,, `` r
eLluested rntlal`p anti
ErnlSS1Un 1_lmil (s)
lnconed
Basis
Umts
Source
( P 42, .
Mfg ete)y.
Uncontrolled
d Emissions
v..(tons/year) ,
Controlled
Emissions
(tons/year)
Uncontrolled
Emissions
;:`(tons`/year)
i4iontrolle'd
emissions
(₹ons)yeai j
TSP (PM)
PM 10
PM2.5
SOx
NOx
0.5
g/bhp-hr
Manf.
5.00
5.00
VOC
1.38
g/bhp-hr
Manf.
13.79
7.00
CO
2.64
g/bhp-hr
Manf.
26.38
1.85
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 ® Yes ❑ No
lbs/year?
If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source:
Non Criteria Reportable Pollutant Emissions Inventory
nCheinical Name
Chemical
Abstract
� �
Sernc� (CAsj
umber
Emission Factor
Actual nnual Eni)sstons1°
Uncontrolled
Basis-
Units
rr
Source �
(AP-4�;
Mfg: etc)
U c nt
� n o rolled ��
s r
Ern�issioras`� #
(Pounds/year) .
� Cyonti Alled
Emissions
., fpounds/year)G ...
Formaldehyde
50000
0.52
g/bhp-hr
Manf.
10,394
2,543
- - Acetaldehyde - -
75070 --"
8.36E-03 -
lb/MMbtu
AP -42 -
-- - 551 -
-- -275 -
Acrolein
107028
5.14E-03
lb/MMbtu
AP -42
339
169
Benzene
71432
Other:
8 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
10 Annual emissions fees wilt be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018
51
LO:RR lib.
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP02, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP02.
02/11/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Zak N. Covar Vice -President HSE&R
Name (please print) Title
Check the appropriate box to request a copy of the:
p✓ Draft permit prior to issuance
E✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $1,875, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.Qov/cdohe/apcd
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018
6I
COLORADO,
Hain; (A Eaviemmr a
Spark Ignition Engine APEN
Form APCD-201
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 AP
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 spark ignition (e.g. gas -fired) reciprocating internal combustion engines (RICE). If your
engine is a compression ignition engine (e.g. diesel -fired) or your emission unit does not fall into the RICE
category, there may be a more specific APEN for your source (e.g. compression ignition engine, mining operations,
asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty
APEN options do not meet your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD) website at: www.colorado.Qov/cdohe/ancd.
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: I C V U u O AIRS ID Number: t 2:5 /�.� 2�/ 0069
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name1: Summit Midstream Niobrara, LLC
Site Name: Brahma Compressor Station
Site Location: SW1/4 Sec 28 T12N R63W
Mailing Address:
(Include Zip Code) 999 18th Street, Suite 2500S
Portable Source
Home Base:
Site Location
County: Weld
NAICS or SIC Code: 1311
Denver, CO 80202 Contact Person: Andrew Parisi
Phone Number: (303) 626-8269
E -Mail Address2: aparisi@summitmidstream.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
393314
COLORADO
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 1
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
0 NEW permit OR newly -reported emission source (check one below)
❑✓ STATIONARY source O PORTABLE source
El Request coverage under a Construction Permit
O Request coverage under General Permit GP023 (Natural Gas Only)
If General Permit coverage is requested, the General Permit registration fee of $1,875 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name ❑
Add point to existing
permit
O Change permit limit O Transfer of ownerships O Other (describe below)
- OR
APEN submittal for update only (Blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• APEN submittal for permit-exempt/grandfathered source
❑ Notification of Alternate Operating Scenario (AOS) permanent replacement6
Additional Info ft Notes:
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary.
4 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
5 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
6 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements.
Section 3 - General Information
Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)?
If yes, provide the Company Equipment Identification No.
CE -01
Yes
General description of equipment and purpose: Natural Gas Compression
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
(http://www.colorado.gov/cdphe/attainment)
Normal Hpurs of Source Operation: 24 hours/day 7
07/01/2019
❑ Yes ❑✓ No
Seasonal use percentage: Dec -Feb: 25 Mar -May: 25
days/week 52 weeks/year
June -Aug: 25 Sept -Nov: 25
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018
21
'COLORADO
WWII*WWII*
oer.eam
[mlKTmaM
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Engine Information
Engine Function:
❑ Primary and/or Peaking Power ❑ Emergency (max. 500 hrs/year) 0 Compression
❑ Pump Jack ❑ Water Pump ❑ Other:
What is the maximum number of hours this engine will be used for emergency back-up power? hours/year
Engine Make: Caterpillar Engine Model: G3608 Serial Number: XH70092
What is the maximum designed horsepower rating? 2500 hp
What is the maximum manufacturer's site -rating? 2500 hp kW
What is the engine Brake Specific Fuel Consumption at 100% Load? 6757 BTU/hp-hr
Engine Features:
Cycle Type: ❑ 2 -Stroke ❑✓ 4 -Stroke Combustion: 0 Lean Burn O Rich Burn
Aspiration: ❑ Natural 0 Turbocharged
Is this engine equipped with an Air/Fuel ratio controller (AFRC)? 0 Yes ❑ No
If yes, what type of AFRC is in use? ❑ Oz Sensor (mV) ❑NOX Sensor (ppm) ❑ Other:
Is this engine equipped with a Low-NOx design? 0 Yes ❑ No
Engine Dates:
What is the manufactured date of this engine? 05/2018
What date was this engine ordered? TBD
What is the date this engine was first located to Colorado? TBD
What is the date this engine was first placed in service/operation? TBD
What is the date this engine commenced construction? TBD
What is the date this engine was last reconstructed or modified? TBD
Is this APEN reporting an AOS replacement engine? ❑ Yes 0 No
If yes, provide the make, model, and serial number of the old engine below:
Engine Make: Engine Model: Serial Number:
7 The serial number must be submitted if coverage under GP02 is requested.
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 3
_COLO:e,k 0O
1YoaSu�5.fuaiecdnncat
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
raaphical Coordinate;
(Latitude1Laiig�tude pr liT
40.9801601, -104.4285920
rator
.,,t,.
'
Ti°1,
Di
r e
qy"
1 d�'i`{
J4?3�... �r�.`o
tpe
''fi
F
2,a
'
3
,"I�
.rr'
i' VII+.
CE -01
TBD
840
15958
TBD
Indicate the direction of the Stack outlet: (check one)
p Upward
O Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
E Circular Interior stack diameter (inches):
❑ Square/Rectangle Interior stack diameter (inches):
O Other (describe):
O Upward with obstructing raincap
TBD
Interior stack depth (inches):
Section 6 - Fuel Data and Throughput Information
RR
a;��...:£4.a...e�4
14897
131
From what year is the actual annual amount?
Indicate the type of fuel used9:
❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf)
❑✓ Field Natural Gas Heating value: 1 134 BTU/scf
❑ Propane (assumed fuel heating value of 2,300 BTU/scf)
❑ Landfill Gas Heating Value: BTU/scf
O Other (describe): Heating Value (give units):
8 Requested values wilt become permit limitations. Requested limit(s) should consider future process growth.
9 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 4
COLORADo.
ce en9=rucic
}I IAA tr F.r, Vinannoibt
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Emissions Inventory Information
Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a
Natural Gas Fired Engines Calculator available to assist with emission calculations.
Is any emission control equipment or practice used to reduce emissions? 0✓ Yes D No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Primary Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
TSP (PM)
PM10
PM2.5
Sox
NOx
VOC
Oxidation Catalyst
33
CO
Oxidation Catalyst
93
Other:
Oxidation Catalyst (HCHO/Total HAPs)
76 / 50
Use the following tables to report criteria and non -criteria pollutant emissions from source:
(Use the data reported in Section 6 to calculate these emissions.)
From what year is the following reported actual annual emissions data?
.Criteria Pollutant Emissions Inventory -
Pollutant
Emission Factor.
•
Actual Annual Emissions D
Requested Annual Permit
Emission Limit(s)e ...;
Uncontrolled
` Basis
,.
Units.
Source
' (AP -42, ,
Mfg. etc)
• Uncontrolled
Emissions .
(tons/year) •
Controlled:
Emissions
(tons/year) .
Uncontrolled
Emissions
(tons/year)
Controlled
,Emissions
(tons/year),
TSP (PM)
PM10
PM2.5
SOX
NOx
0.5
g/bhp-hr
Manf.
12.07
12.07
VOC
1.05
g/bhp-hr
JJJJ
25.35
16.90
CO
2.53
g/bhp-hr
Manf.
61.08
4.28
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 ❑✓ Yes ❑ No
lbs/year?
If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source:
Non -Criteria .. , l... .. . .
... Reportable. Pollutant Emissions Inventory .::
Chemical Name
Chemical :.
Abstract
(CAS)
t )
Number.
. Emission Factor
Actual Annual Emissions"
Uncontrolled
Basis
Units
Source .
(AP -42, :
Mfg. etc) _
� ....:.(poundal
Uncontrolled
Emissions
ear ..
(pounds/year)
Controlled
Emissions
(pounds/year)
2,665
Formaldehyde
50000
0.23
g/bhp-hr
Manf.
11,105
Acetaldehyde
75070 -
- 8.36E-03
Ib/MMbtu
AP -42
1,237 - -
- - -619
Acrolein
107028
5.14E-03
Ib/MMbtu
AP -42
761
380
Benzene
71432
Other:
Methanol: 67561
2.50E-03
lb/MMbtu
AP -42
370
185
8 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-201 - Spark ignition Engine APEN - Revision 7/2018
5J
COLO;&A1E3O
Y a tulT¢. 1' •
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP02, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP02.
02/11/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Zak N. Covar Vice -President HSE&R
Name (please print) Title
Check the appropriate box to request a copy of the:
E✓ Draft permit prior to issuance
0✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $1,875, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
' Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https://www.colorado.Rov/cdphe/apcd
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018
6I
COLORADO,
o.nrnallsm Fcl:ie'
HeAlhb F.Wremnael
Spark Ignition Engine APEN
Form APCD-201
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, includir EN
updates. An application with missing information may be determined incomplete and may be returned
longer application processing times. You may be charged an additional APEN fee if the APEN is filled o
incorrectly or is missing information and requires re -submittal.
RECEIVED
FEB 1 2 2019
APCD
Stss6i6490R1ry
��uurGv��
This APEN is to be used for spark ignition (e.g. gas -fired) reciprocating internal combustion engines (RICE). If your
engine is a compression ignition engine (e.g. diesel -fired) or your emission unit does not fall into the RICE
category, there may be a more specific APEN for your source (e.g. compression ignition engine, mining operations,
asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty
APEN options do not meet 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: IcWvO[(9 AIRS ID Number: 25 /4.02i/0o1
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Summit Midstream Niobrara, LLC
Site Name: Brahma Compressor Station
Site Location: SW1/4 Sec 28 T12N R63W
Mailing Address:
(Include Zip Code) 999 18th Street, Suite 2500S
Portable Source
Home Base:
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Andrew Parisi
Phone Number: (303) 626-8269
E -Mail Address2: aparisi@summitmidstream.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 1 I
393315
c,4l.oenDa-
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source (check one below)
❑✓ STATIONARY source O PORTABLE source
O Request coverage under a Construction Permit
❑ Request coverage under General Permit GP023 (Natural Gas Only)
If General Permit coverage is requested, the General Permit registration fee of $1,875 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
O Change fuel or equipment O Change company name ❑
Add point to existing
permit
❑ Change permit limit ❑ Transfer of ownerships O Other (describe below)
-OR-
❑ APEN submittal for update only (Blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El APEN submittal for permit-exempt/grandfathered source
❑ Notification of Alternate Operating Scenario (AOS) permanent replacement6
Additional Info Et Notes:
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary.
4 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
s For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
6 This does not apply to General Permit GPO2, as it does not contain a provision for AOS permanent replacements.
Section 3 - General Information
Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)?
If yes, provide the Company Equipment Identification No.
CE -02
Yes
General description of equipment and purpose: Natural Gas Compression
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
(http://www.colorado.Rov/cdphe/attainment)
Normal Hours of Source Operation: 24 hours/day 7
07/01/2019
❑ Yes ❑✓ No
Seasonal use percentage: Dec -Feb: 25 Mar -May: 25
days/week 52 weeks/year
June -Aug: 25 Sept -Nov: 25
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 2
® COLORADO
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Engine Information
Engine Function:
❑ Primary and/or Peaking Power ❑ Emergency (max. 500 hrs/year) ❑✓ Compression
❑ Pump Jack ❑ Water Pump ❑ Other:
What is the maximum number of hours this engine will be used for emergency back-up power? hours/year
Engine Make: Caterpillar Engine Model: G3608 Serial Number7: TBD
What is the maximum designed horsepower rating? 2500 hp
What is the maximum manufacturer's site -rating? 2500 hp kW
What is the engine Brake Specific Fuel Consumption at 100% Load? 6757 BTU/hp-hr
Engine Features:
Cycle Type: ❑ 2 -Stroke ❑✓ 4 -Stroke Combustion: ❑✓ Lean Burn O Rich Burn
Aspiration: ❑ Natural 0 Turbocharged
Is this engine equipped with an Air/Fuel ratio controller (AFRC)? ❑✓ Yes ❑ No
If yes, what type of AFRC is in use? ❑ OZ Sensor (mV) ❑NOx Sensor (ppm) ❑ Other:
is this engine equipped with a Low-NOx design? ❑✓ Yes O No
Engine Dates:
What is the manufactured date of this engine? TBD
What date was this engine ordered? TBD
What is the date this engine was first located to Colorado? TBD
What is the date this engine was first placed in service/operation? TBD
What is the date this engine commenced construction? TBD
What is the date this engine was last reconstructed or modified? TBD
Is this APEN reporting an AOS replacement engine? ❑ Yes ❑✓ No
If yes, provide the make, model, and serial number of the old engine below:
Engine Make: Engine Model: Serial Number:
7 The serial number must be submitted if coverage under GP02 is requested.
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 3
C:OLO;t3;A U'O,
NNFIhEEm4kiakip,t
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
40.9801601, -104.4285920
erator
t^ .u^
➢^
@ �'
"=�1
,}
yt
l .
bA
S��Y-,
'4,
i;
13
P
q �i.`
} 1Kvr
e ay w
CE -02
TBD
840
15958
TBD
Indicate the direction of the Stack outlet: (check one)
0 Upward
❑ Horizontal
O Downward
Other (describe):
Indicate the stack opening and size: (check one)
0✓ Circular Interior stack diameter (inches):
O Square/Rectangle Interior stack diameter (inches):
O Other (describe):
O Upward with obstructing raincap
TBD
Interior stack depth (inches):
Section 6 - Fuel Data and Throughput Information
14897
From what year is the actual annual amount?
Indicate the type of fuel used9:
Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf)
0✓ Field Natural Gas Heating value: 1134 BTU/scf
Propane (assumed fuel heating value of 2,300 BTU/scf)
Landfill Gas Heating Value: BTU/scf
Other (describe): Heating Value (give units):
131
8 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
9 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 4 I
C 0.1,9 RADO
Heanh B£ir#tiimam
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Emissions Inventory Information
Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a
Natural Gas Fired Engines Calculator available to assist with emission calculations.
Is any emission control equipment or practice used to reduce emissions? 0✓ Yes ❑ No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Primary Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
TSP (PM).
PM10
PM2.5
SOx
NOx
VOC
Oxidation Catalyst
33
CO
Oxidation Catalyst
93
Other:
Oxidation Catalyst (HCHO7rotal HAPs)
76 / 50
Use the following tables to report criteria and non -criteria pollutant emissions from source:
(Use the data reported in Section 6 to calculate these emissions.)
From what year is the following reported actual annual emissions data?
Pollutant
TSP (PM)
PM10
PM2.5
Source
,Mfg. etc);
Uncontrolled.
Basis
Units
Criteria Pollutant Emissions Inventory.'_
Actual Annual Emissions°.
Uncontrolled
Emissions
(tons/year) ,.
Controlled
Emissions
(tons/year)
Requested Annual Permit
Emission Limit(s)8
Uncontrolled
Emissions
(tons/year)
Controlled.
Emissions
(tons/year)
SOx
NOx
VOC
CO
0.5
g/bhp-hr
Manf.
12.07
12.07
1.05
g/bhp-hr
JJJJ
25.35
16.90
2.53
g/bhp-hr
Manf.
61.08
4.28
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 0 Yes ❑ No
lbs/year?
If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source:
Non Criteria Reportable Pollutant Emissions Inventory
Chemical Name
. Chemical
• Abstract•
Service (CAS)
Number
Emission Factor
Actual Annual-Emissions1D
Uncontrolled
Basis
Units
Source:
(AP -42,:
Mf
Mfg.. etc)
Uncontrolled
Emissions
,( oud year
p nsl )
Controlled
. Emissions:
(pounds/year)
2,665
Formaldehyde
50000
0.23
g/bhp-hr
Manf.
11,105
Acetaldehyde -
75070
8.36E-03
lb/MMbtu
AP -42
1,237
619
Acrolein
107028
5.14E-03
lb/MMbtu
AP -42
761
380
Benzene
71432
Other:
Methanol: 67561
2.50E-03
lb/MMbtu
AP -42
370.
185
8 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018
5I
cO Lo'rt'A no
ate%
xe-ims&rnwnmrm
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP02, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP02.
02/11/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Zak N. Covar Vice -President HSE&R
Name (please print) Title
Check the appropriate box to request a copy of the:
0✓ Draft permit prior to issuance
0✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $1,875, if applicable, 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
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303)692-3150
Or visit the APCD website at:
https: / /www. colorado. gov/cdphe/ apcd
Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018
6I
COLORADO,
'foam5FnrF[Rf(mmaT
Hello