HomeMy WebLinkAbout20191836.tiffPubv c S;`).eii\fAK)
5/20l 1Q
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
1150 0 St
PO Box 758
Greeley, CO 80632
May 7, 2019
Dear Sir or Madam:
RECEIVED
MAY 1 3 2010
WELD COUNTY
COMMISSIONERS
On May 9, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Cureton
Front Range, LLC - Front Range Gas Plant . 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 Ft 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
c,c:PLUVP',aL(r'-r),
pUXJMI 1ottcvi)
51%3llci
2019-1836
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Cureton Front Range, LLC - Front Range Gas Plant - 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: Cureton Front Range, LLC
Facility: Front Range Gas Plant
Natural gas processing plant
SENE Section 19, T2N, R64W
Weld County
The proposed project or activity is as follows: Source proposes to construct a 200 million standard cubic
feet per day (MMscfd) natural gas processing train at an existing 60 MMscfd plant. Source is requesting
synthetic minor limits for Title V, Nonattainment New Source Review (NANSR), and Prevention of Significant
Deterioration (PSD)
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 17WE1090 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:
Bradley Eades
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
1 I k
'. naxinn�,vim3.mani.
Colorado Air Permitting Project
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility: Natural Gas Processing Plant
What industry segment? Oil &Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? El Carbon Monoxide (CO) ❑ Particulate Matter (PM) E Ozone (NOx & VOC)
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package d:
Received Date:
Review Start Date:
Brad Eades
390924
12/10/2018
2/19/2019
Section 01- Facility Information
Company Name: Cureton Front Range'. LLC
123
9F67
Front Range Gas Plaant Ali,
SENE quadrant of Section 19, Township 2N, Range 64W
Weld County
Quadrant
Section
Township
Range
SENE
19
2N
64`
Section 02 - Emissions Units In Permit Application
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
002
-
Fugitive Component Leaks
FUG1
No
17WE1090
2
Yes
Permit
Modification
003
NG Heater
HTR2
No
17WE1090
2
Yes
No Action r; .
Requested
20 MMBtu/hr
004
NG Heater
HTR3
No
17WE1090
2
Yes
No Action
Requested
11 MMBtu/hr
005
Maintenance Blowdowns
PIGGING
No
17WE1090
2
Yes
Permit - -
Modification
Pigging
Receivers
013
Natural Gas RICE
ENG1-
Yes
17WE1090
2
Yes
Permit Initial
Issuance
014
Natural Gas RICE
ENG2
Yes
17WE1090
2
Yes
Permit Initial
Issuance
015
Natural Gas RICE
ENG3
Yes
17WE1090
2
Yes
Permit Initial
Issuance
016
Amine Sweetening Unit
Amines
Yes
17WE1090
2
Yes
Permit Initial
Issuance
:.
017
Amine Sweetening Unit
Amine2-
Yes
; 17WE1090
.. 2
:: Yes
Permit initial
Issuance
CA NCELLLED
DURING
PROCESSING....
018
NG Heater
HTR4,.
No
17WE1090
2
Yes
Permit Initial
Issuance
20 Mmbtu/hr
019 ..
._ NG Heater
HTR-6
... No
17WE1090:
- 2
Yes
Permit Initial
- Issuance
55 Mmbtu/hr.
020
NG Heater
HTR7
No
17WE1090
2
Yes
Permit Initial
issuance
55 Mmbtu/hr
021
- ..
NG Heater
HTR-8
..
2
-
Yes
APEN Exempt
CANCELLLED
DURING
PROCESSING:
022
Condensate Tank
TK-1-4
Yes
17WE1090
2
Yes
Permit Initial
Issuance
Stabilized Cond.
023
Liquid Loading
LOAD2
Yes
17WE1090
2
Yes
Permit Initial
Issuance
Stab. Cond.
Loadout
024
Other (Explain)
_
TK-11
No
: 17WE1090
-2
Yes
Permit Initial
Issuance
Methanol tank
025
' Liquid Loading
LOAD1
No
17WE1090.
2
Yes
Permit Initial
Issuance
Pressurized,
NGL loadout
026
Process Flare
FLARE
.. Yes
-.17WE1090
2
Yes
Permit Initial
Issuance
Emergency
Flare (purge
gas)
Colorado Air Permitting Project
Section 03 - Description of Project
Front Range Gas Plant is an existing synthetic minor plant with 60 MMSCFD processing capacity. With this application. Cureton is requesting two (2) additional gas
processing trains of 200 MMSCFD and 20 MMSCFD respectively . The source is requesting new synthetic minor limits.
I Source is modifying existing Points 002 and 005 based on accommodation for new processing trains along with the addition of new equipment.
The addition of engines Point 013, 014, 015 were not included with this project since they were submitted as GP02 and are being permitted to replace the engines
previously permitted as 006, 007,'008 associated with the initial processing train permitted with issuance 1. However, facility emissions were permitted to exceed 90 tpy
VOC with this mod and source converted 013-015 to the facility -wide permit from GP02.
On 4/3/19, Cureton Front Range indicated that they were no longer requesting to permit equipment associated with the 20 MMSCFD plant. As such, Point 017, was
cancelled and revised calculations with revised throughputs were received for the 200 MMSCFD plant and existing 60 MMSCFD plant.
, A draft permit was sentto the applicant for review on 4/9/19. On 4/15/19 comments were received in the form of pdf comments. A summary of the relevant comments
received and their outcome are summarized below:
-Applicant provided the make model and serial number for Point 003 and 004 as Point 003: HeatecHCl 10010-50-G, sn: H117-195 & Point 004: Tulsa Heaters ASME. I added
these details to the equipment description.
-Applicant requested that the equipment description for Point 016 be updated to reflect Point. 019 (HTR-6) or Point 020 (HTR 7) as a potential heat source for the amine
regenerator. I added Point 020 to the equipment process description.
-Applicant indicated that the NOS was previously submitted for Points 002, 003, 004. However, since I could not locate the NOS in RM at this time, and self-cerfication is
needed for the rest of the equipment on this issuance, I notified the applicant that I will leave the condition as is and that any NOS submitted prior to issuance will satisfy
this requirement.
-Applicant requested to remove monthly limits from Point 016 (amine unit) for H2S and 502. The basis for this request is that the H2S is expected to fluctuate and the.
facility is not synthetic minor for either pollutant. I informed the applicant that it is Division policy to include monthly limits for any reportable pollutant that does not have
12 months of actual data.The highest expected H2S concentrations should be considered when requesting permit limits. Therefore, the monthly limits will remain in the
permit. I also gave the operator the option of re-evaluating H2S concentration and revising the process simulation submitted with the application but applicant agreed to
the monthly limits at the current requested levels.
-Applicant requested removal of the VOC limit for Point 016 (amine unit ), Process 02 (combustion of assist and pilot fuel). I communicated that since this is from a single
emission point, I will include a limit since the Point 016 is reportable for VOC. Furthermore, a compliance test will be conducted on 016 and the outlet flow of VOC shall
demonstrate compliance with both process 01 and 02. This gets complicated if there is not a limit for process 02. As such, the VOC limit for process 02 will remain in the
permit.
-Applicant requested that the permit include clarification that fugitive emission sources are not to be considered in the requirement to track insignificant activities. I agree
with this evaluation and added clarification that only pointsources are to be considered for the purposes of this condition.
-Applicant requested relaxation of thermal oxidizer temperature monitoring from hourly to daily so that the requirement aligns with the default O&M requirement. I
indicated that this is a more stringent requirement that has been included in response to the thermal oxidizer requirement to control at 98% . Furthermore, efficient
operation of the control device and continuous monitoring is warranted since facility wide VOC is> 97tpy. Therefore, I will not modify the requirement as written (hourly
temperature monitoring). - -Applicant requested removal of sulfur dioxide as a pollutant tested in the initial compliance test (stack test) for Point 016 on the basis that SO2 is calculated assuming 100%
conversion of H2S (as measured at the thermal oxidizer inlet), and SO2 is not a pollutant for which the facility is synthetic minor, I agree to remove SO2 from the pollutant
list associated with this test. This was based on the justification provided by the applicant in conjunction with the inclusion of the initial compliance demonstration included
in the preceding condition (condition #43) for which compliance with SO2, based on 100% conversion of measured H2S in the acid gas, will be demonstrated.
-Applicant requested removal of initial testing for residue gas being used as fuel for the open flare and thermal oxidizer since emissions from combustion of the fuel gas, by
itself, results in de miminis emissions of VOC. I communicated to the appicant that we are relying on the simulated residue gas composition for fuel to be used in both the
open flare and thermal oxidizer. Although this is a relatively small source of VOC, the proximity to facility -wide NNSR thresholds increases the importance of its accuracy.
Furthermore, we generally see residue gas in the range of 3% by weight VOC, whereas this site's model indicates 0.5%. I don't believe that it is overly burdensome for the
operator to obtain a residue gas analysis upon startup, and use that analysis to ensure the representations in the application were accurate. I can remove Point 026 from
this requirement since it is currently below reporting thresholds for VOC, but the TO fuel gas combustion is reportable. Therefore, I will retain the testing requirement for
Point 016.
*Applicant requested removal of the initial site -specific stable oil analysis and emission factor analysis for the condensate storage tank since the oil is stabilized and there is
no flash expected. I' agree to remove this testing condition based on the operators justification and since a stable oil RVP similar to what is reported at similar plants was
used to develop the emission factor used in the application.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic Minor Permit
Section 05 -Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
5O2 NOx CO VOC PM2.5 PM10 TSP HAPs
Is this stationary source a major source?
If yes, explain what programs and which pollutants hers SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
No
NOx CO
VOC
PM2.5 PM10
TSP HAPs
❑ ❑
Fugitive Emissions Inventory
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Fugitive Emissions Inventory
sawn a-RewlatanSummary Analysis
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component type component type Standard FFa FPza53/R.95017Tahex<
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Separator Venting Emissions Inventory
Section 01- Administrative Information
Facility AIRs ID:
County
9167 y
Plant
VIMSIM
Point
Section 02 -Equipment Description Details
4.e
Detailed Emissions Unit Description:
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
2
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Length of pig receivers (each):
Pressure of pig receivers:
Atmospheric pressure:
Vented volume from 6" receiver:
Volume calculated by applicant:
Vented volume from 8" receiver:
Volume calculated by applicant:
Vented volume from 10" receiver:
Volume calculated by applicant:
Vented volume from 16" receiver:
Volume calculated by applicant
Primary Emissions - Separator
Requested Volume Vented Ma'
Section 04- Emissions Factors & Methodologies
Description
Emissions ate estimated using inlet
9.5 feet
300 psig
312.12 psia
12.12 psi
1.865320638 cf/event
48.03662356 scf/event
49.89742042 scf/event
3.316125579 cf/evert
85.39844189 scf/event
95.97782318 scf/event
5.181446217 cf/event
133.4350654 scf/event
158.96358 scf/event
13.26450232 cf/event
341.5937671 scf/event
449.3517332 scf/event
MMscf per year
93
Requested Monthly volume vented =
ompositian as calculated. using ProMa%simulation with projected plant operating parameter
MW
22.28
Weight 36
Helium
_: 0.00
CO2
4.57.
N2
0.35
methane
- 52.3].
ethane
'17;780
propane
_ 17.70
isobutane
;. 1.54
n -butane
'1%. 3.86
isopentane
0.66
n -pentane
0./0
cyclopentane
0.03
n -Hexane
0.24
cyclohexane
t' 0.07
Other hexanes
- 0.02
heptanes
'': 0.04
methylcyclohexane
0.04
224-TMP
0.02
Benzene
0.00
Toluene
0.01
Ethylbenzene
;, - 0.00
Xylenes
C80 Heavies
'..:...; :k. 0.01'
Total
VOC Wt %
100.00
25.03
Ib/Ib-mol
Displacement Equation
Ex=0u MW`Xx/C
0 MMscf per month
5 of 42
K:\PA\2017\17 W E109t.CP2.xlsm
Separator Venting Emissions Inventory
mission Factors Gas Venting (TOTAL)
Pollutant
Uncontrolled
(Ib/MMscf) ' (Ib/MMscf)
Controlled Emission Factor Source
VOC 14712.2071
Benzene 0.9406
Toluene 7.6422
Ethylbenzene 1.2
Xylene 1.8812
n -Hexane 140.264
224 TMP 10.1700
4712.2071
0.9406
7,6422
1.2345 Ex₹ended gas ana
1.8612
0.1700
Emission Factors Gas Venting (6" receiver)
Pollutant
VOC
Benzene
Toluene
Uncontrolled
Controlled Emission Factor Source
(lb/Event) (lb/Event)
0.7341 0.7341
0.0000 0.0000
0.0004 0.0004
0.0001 0.0001
0.0001 0.000
0.0070 0.0070
0.0005 0.0005
Ethylbenzene
Xylene
n -Hexane
224 TMP
Emission Factors Gas Venting (8" receiver)
Pollutant
Uncontrolled
Controlled Emission Factor Source
(lb/event) (lb/event)
VOC 1.412
Benzene 0,000
Toluene 0.0007
Ethylbenzene 0.0001
Xylene 0.0002
n -Hexane 0.013
224 TMP 0.0010
1.4120
0.000
0.0007
0.0001
0.0002
0.0135
0.0010
Emission Factors Gas Vent ng (10" receiver)
Pollutant
Uncontrolled Controlled
(lb/event) (lb/event)
VOC
2.3387 2.3387
0.0001 0.0001
0.0012 0.0012
0.0002 0.0002
0.0003 0.0003
0.0223 0.0223
0.0016 0.0016
Benzene
Toluene
Ethylbenzene
Xylene
n -He
224 TMP
Emission Factors Gas Vent ng (16' receiver)
Pollutant
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
Section OS - Emissions Inventory
Uncontrolled
Emission Factor Source
Controlled Emission Factor Source
(lb/event) (lb/event)
6.6110 6.6110
0.0004 0.0004
0.0034 0.00
0.0006 0.0006
0.0008 0.0008
0.0046
'no actual data Provided on APES.
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Uncontrolled
(tons/year)
Actual Emissions'
Controlled
(tons/war)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
6.07
I
6.07
I 6.07
1032
Potential to Emit
Actual Ernimions"
Requested Permit Limits
Hazardous Air Pollutants
Uncontrolled
Unccntrolled r_mtrolled
Uncontrolled Controlled
(Ibs/year)
, nslyea•I :ILu/rear}
(lbs/year) (lbs/year)
Benzene
1
REF?
4REFI
1
1
Toluene
6
115 F!
MCI
6
6
Ethylbenzene
1
#BEFI
4REE!
1
1
Xylene
2
#lREFt
cREFI
2
2
n -Hexane
116
#BEE!
9REF!
116
116
224 TMP
8
ilREFl
SREFI
8
8
6" Receiver
Criteria Pollutants
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
0.4
I
0,4
68
8" Receiver
Criteria Pollutants
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Corrtrolled
(lbs/month)
VOC
0.8
I
0.8
131
10" Receiver
Criteria Pollutants
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
1.3
I
1.3
217
16" Receiver
Criteria Pollutants
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
3.6
I
3.6
615
6 of 42
K:\PA\2017\17 W E1090.CP2.xlsm
Separator Venting Emissions Inventory
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B (Source requires a permit
(See regulatory applicability worksheet for detailed analysis)
Section 07 -Technical Analysis Notes
*composition is based on plant inlet gas. Although process design includes some portMn of gas is routed to the stab s rei overheads, the remainder
entirety is vented to atmosphere,
it *Permit will include separate limits for each diameter of p g receiver ( e 6''', R', 13",16) Notes to permit holder will contain factors for each limit on alb/event ha
events per receiver per year.
Section 09 -Inventory SCC Coding and Emissions Factors
AIRS Point # Process # SCC Code
005 01 3-10-002-11 Pipeline Pigging (releases during pig removal)
etch to the atmosphere. Applicant is conservatively calculating emissions assuming the
Operator is requesting 3eve
per day perrere ver for a total' of 10S0
Uncontrolled
Emissions
Pollutant Factor Control% Units
VOC 14712.21 0 lb/MMSCF
Benzene 0.94 0 Ib/MMSCF
Toluene 7,64 0 lb/MMSCF
Ethylhenzene 1.23 0 Ib/f0IMSCF
Xylene 1,88 0 lb/MMSCF
n -Hexane 140,26 0 Ib/MMSCF
224 TMP 10,17 0 lb/MMSCF •
7 of 42 K:\PA\2017\ 17WE1090.CP2.xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B- APEN and Permit Requirements
Source is in the Non -Attainment Area
ATTAINMENT
L Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPV(Regulation 3, Part A, Section ll.D.1.a)7
2. Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TPY or CO emissions greater than 10TPY (Regulation 3, Part B, Section 11.0,3)?
(Not enough information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than O TPY (Regulation 3, Part A, Section 11.0.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part 0, Section 11.0.2)?
'Source requires a permit
Disclaimer •
This document assists operators with determining applicability of certain requirements of the Clean Air Act, Its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute orreguladon will control. The use ofnon-mandatory language such as 'recommend," 'may,' "should,"and "oan,"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.
Yes. Source Requires an APEN. Go. the next question
YE sti ,a Source Requires a permit
RICE Enesstoess Inventory
o<I gw�rnma:s
oraevny nm
Fntlne �q+nua
PIPSPOIXT
Manehetwer
leltelelNkenhen
eneeneFundien
d
22.33,23,622
6,42,3-6111,
66,63623136221. ,
Cna�lne Mimm"c vmHnae wermaa
seewutl escr€tmxluel6�WnaM�
ren
otterearameten
ri
Requited Houma Operator.
PieepurselOperalen
Mbno
urvntnnn:a oven
. "' X01 "r n . umrd/n
312X2222MitelAnneelfuelfensumatbn
I '5,3 tan..
2236 leNeedimente
WEICETEM _ _
O 4.wyssa�®
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® 00
MC/2 MEM= fI21= ®'MEZ"b-vt
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: . ."v=vA==MMNIME=E2
MIZEMEMMUEZME
=WNWgy
ermen 0332663164
0.22.4652 21.642622.31
02112260 2.1662.2572 21616.166,
222.6.02
m pt 2261.2 152E-03 A.
T562.03 1.313 ptµ
m pph
1222.3 EIDE. PM
120.04 con. PM
1.2363,60 m pee*
292241 1292.06
e.�c-w a.mem ynpn
RICE EnhIssions Inventory
VOL
Imnr/wwl
mn,/y..n lan„k.n
ono
Una:mated Controlled
Imnr/yeao lmnrMM
Requested Fyamit
nepuened mmmhu ControllpeYmenrmaM1,
7050
20,0
036
47,
0.35
1547
2201
000
090
mat
muU,tae
Fngtwer<
xUwe
IlmNmrl IIaMeN
U OM. 0,Mmml
3.
366
60
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01Meernumw meuummem seen meumv lmcr0.rsnw,swalta,16 094,p atia tanrotYtmn
PesuletIonn
{RIM In an atlaInnant wIth emntm ee earl emmmn clew per you ormom of any lndNleurl atem
nntlwpmi
ppnonmrnaeemnle an AMIN ence wlydowe.mma lmn per rvvot,mamxm.
Repoadm
m...mmma: inneapne:nner dnlp ate mmatertrn wwrlrepoad ea75011, u.ennon,theyare
'anon NUMAccordlnem Regulation Inedlnn xnl.B.M InternalmmM1temlen Unermatan rubpnmrn
ry RnR'lum rrdl'Nsrs�w
NO;Mant.otm CO and 0. ✓wn vanamuto-d art.dune tm,uoo and mwontmmalwdmyl,vosoAsmte
Par wbpnmmeeollwneemtwmmnalmem 101>M1+ Nm,16tply mama
w eR<Nrvaltmnomd awNne 1},N'6 a d manWea.eelxtetuMt"mml
untentreMea
0.010
ODOI, ROAM.
MOO, IYMMEMa
lommom
ROOM
SILOOM
Amine Sweetening Unit Emissions Inventory
Section 01 - Administrative Information
'Facility AIDS ID:
Sean 02- Equipment Description Deaths
Amine Unitlnformafion
Amine UnitType:
Make:
Model:
Serial Number:
Design Capacity:
Recirculation Pump Information
Number of Pumps
Make:
Model:
Design/Max Recirculation Rate:
Amine Unit Equipment
Hash Tank
Regenerator Heat Source
Canty
967 016
Plant Point
MMuf/day
gallons/minute
and regenerator with heat supplied from RIMS (Point 019)
One (1)tethyldiethanolamine(PADEA) natural gas sweetening unit(Make: MD, Model:THD, Serial Number:Tea) with a design capacity of260MMscf per day. This emissions unit Is equipped with 2(Make: TVD, Model: ISM)
Amine Unit Equipment Description amine pumps with a total rapacity of 1000 gallons perminute. This natural gas sweeb'ngin unit isequippedwith a still ventand regenemlorwith heatsupplied from 1110E (Paint 012).
Emission Control Device Description: Emissions from the still vent are routed fo the Thermal Oxidfirer. Emisstons from the flash tank are routed directly to the closed -loop system.
How WIII Source Demonstrate Compliance;
Metered Parameters
Still Vent/ Hash Tank Outlet
Supplemental Fuel
Gas Inlet
Section 03 -Processing Rate Information forEmissions Estimates
Primary Emissions -Amine UnitSRll Ventand FlashTank(If present)
'Requested Permit UmitThroughput 447, 9 23,000.0
Potential to EmltlPTEl Throughput= 73,000
MMscf per year Requested Monthly Throughput= 6200 MMscf per month
MMscf per year
Secondary Emissions -Combustion Devices) for Alr Pollution Control
Still Vent Control
Primary controldevke:
Primary control device operation:
Secondary control device:
Secondary control device operation:
Still Vent Gas Heating Value:
still Vent Waste Gas Vent Rate:
Rah tank Control
Primary control device:
Primary control device operation:
Secondary control device:
Secondary control device operation:
Flash Tank Gas Healing Value
Flash Tank Waste Gas Vent Rate:
Prlmaty Control Devke
Dasls for Control Devlin process Iie,
Control Device Design Rating
Pilot Fuel Use Rate:
Assist Gas Rate:
Pilot Fuel Gas Heating Value:
Assist Gas Heating Value:
Pilot & Assist Gas %eating Value:
Total Heat Row to TO:
Assist Gas MW:
Assist G as VOC weight 5:
Therma10e28er
$d MMetu/h
0 ufh
21000 scih
Btu/scf
P3// Btu/scf
1030.0 etu/uf
242 WARtu/hc
u5na Iu/Ibmol
0.9F%
0.0 MMuf/yr
18396 MMuf/yr
Requested Permit Process Limi6
Monthly Limit
Annual Unit
(31 day)
Process Parameter
'MMscf/yA
'MMscf/month)
InletSourGasThrsughput
73100.00
6200.00
Still VentWaste Gaate Thermal Oxidizer
181524
1.64.17
Rah Ta nk Waste Gas to closed -loop system
500
0
Combustion of PAM and Supplemental Fuel atThermal Oxidher
6
11900
15.62
Glycol Recrculatipn Rate
(Gallons Per Mlnute)
Section 04-Emksions Factors 8 MethodoMuies
Amine Unit
d averagcgeid gas cempesitfon.'ffiemafeiwas
Input Parameters
Inlet Gas Pressure
Inlet Gas Temperature
Requested Lean Amine Recirculation Rate
Lean Amine Pressure
an Amine Temperature
Lean Amine Weight%
Rash Tank Pressure
Rash Tank Temperature
Inlet H2T Concentration
Inlet VOC Cancent2Hon
STILL VENT
Control Scenario
primary
Secondary
Pollutant
Uncontrolled(lb/kr)
Ca.rolled lib/hrl
Controlled lib/hrl
VOC
':..:. .' $6.T! n":"' ..
1.135413>4
0
Benzene-
e. SSA608' ..., •'
0.322212
0
Toluene
0.1212476
Ethylbenlene
41ON 6:3.11194+/ :..'.x
0.02;1398
0
%ylenes
2 v �,: 4.477234n .4,-)4444E-', r
1104954078
0
mHexane
- -
0.00264898
224-TMP
- i ' 2126E-05
2.5192E-07
0
H:S
,94)). 46)4444,0.222016,4 ,0.722019
061454038
0
Methanol
, <0-�-: : Al
0
0
Waste Gas...Med:
Still Vent Primary Control: 1,815.2 MMscf/yr
Still venoSemndaryControl: oA MMscf/yr
Waste Gas o mbusted:
Rash Tank Primary Control: 0.0 MMuf/yF
Rash Tank Secondary Central: 0.0 MMuf/ae
Amine Sweetening Unit Emissions Inventory
FLASH TANN
.ntroiscenado
Primary
Secondary
POIludnt
Uncontrolled(Ib/hr)
Controlled Ilb/hrl
Controlled 1Ib/hrl
VOC
06.4720555^1n""an'0
0
Toluene
220056.
0
Ethylbenzene
6.46268
0
XVleree
0.0352593 .{'7
n -Hexane
"0:653156. ..a"'_-1
224-TMP
.30E -o4
Hrs
OOIo5143
Methanol
'-:%^s',':' d.'5'`-^'4 ° .: "'-'T'<"..
0
0
SOU Emission Calcola000m
MalealerWeight of SO,
Molecular Weight aF H.
64.D66
Ib/Ibmd
Ib/Ibmd
Ibs/rear
tpy
34.08088
5Ox Emission
Did operator request buffer, or Is the
operator using emission factors from Promo
as andal compliance demonstration?
Requested Buffer l%l:
Emission Factors
Pollutant
Beraelle
Toluene
Ethylbenzene
Xylene
n -Hexane
Hz5
Methanol
Pollutant
PMio
NOR
Pollutant
PMto
PM2.5
SOx
NOx
000
.99912
5.985999561
Section OS -Emissions Inventor,
AmineUnit
Uncontrolled
(lb/MMsc5
(Sour easThroughput)
2427
r'antroked
(Ib/MMsci)
Thmuehputl
0.15
2.04611496 0.03950544
1.06419256 0.020555]12
6394006 0.002668776
0.3014]5796 0.005944894
0.0992726 0.000317878
1.75844E-05 3.0.2359E-08
0.08]368449 0.061744846
Uncontrolled Uncontrolled
(Ib/MMBtu) (I6/MMsc0
(Waste HeatCon*usted)
(Waste Gas
Combusted)
0.0921
0.0921
NA
1.2117
1-0139
Supplemental Fuelto Still Vent PrimaocContrel
Uncontrolled Uncontrolled
(Ib/MMBtq) Ob/IVINiscf)
ANaste Gas
(Waste Heat Combusted) Combusted)
0.0980
0:0820
,6795
].6]45
100.9400
84.4609
Still Vent Primary Control Device
Emission Factor Source
Emission Factor Source
Emission Factor Source
Requested PermR Monthly Emission Lim.
cees ProParameter
Pollutant
PM1O
(Ibs/month)
PM25
(Ibs/month)
Sox
(lbs/month)
5,5
(Ibs/momth)
NOx
(ibs/month)
CO
(Els/month)
VOC
(Ibs/month)
Still Vert Waste Gas loThermal Oxidizer
14.20
14.20
1016.80
10.82
186.81
156.31
844.70
Supplemental Fuel Sent to Thermal Oxidizer
11931
119,91
0.00
-
.151709
1319.60
61.89
Still VentWameGas.Thermal 0xldherand Supplemental Fuel Sea.Thermal Oxidizer
134.11
134.11
103680
1092
1763.90
14]5.91
906.65
Still VentWaste Gas to Not applicable
0
0
0
0
0
0
0
sab
Supplemental Fuel Sent to Notapplile
0
0
0
-
0
0
-
SLIT Vent Waste Gas to Notapplicable and Supplemental Fuel Sent toNot applicable
0
0
0
0
0
0
0
Flash Tank Waste Gas to closed -loop system
0
0
0
0
00
Flash Task Waste Gass Notepplkable
0
0
0
0
0
0
00
Requested Permit Annual Emission Limits
Process Parameter
Pollutant
PM10
(tons/year)
PM25
(cons/year)
SOR
(550.10 cur)
Has
(tons/year)
NOR
(tons/veal
CO
(tons/year)
voc
(tons/yeas)
Still Vent Waste Gas hi Thermal 06dlzer
Supplemental Fuel Sent to Thermal Oxidizer
000
0.08
5.99
096
1.100
0.92
4.97
671
0.71
000
9.284
7.77
0.36
StIll VentWaste Gas to Thermal ',Wirer and Supplemental Fuel Sea. Thermal Oxidizer
0.79
0.]9
5.99
O.W
1038
8.69
534
0 Jrl'Nn4r'aa° tr tri.3unll.,hi.
a
L
a .;.ri to l_El . n t_,:: eli.t a::
5 11VeatVvastn GattmNoi aneikehio and Seenlenenaal Fuel Sent to No t auelit,ahi,,
Flab TaNtwaste Nato closed -loop system
00
0
81291Tseal5-asze Gaa to Nctaa99898 e
c
u
0
0
�.
Criteria Pollutants
0000700100 Emit
Uncontrolled
(tors/year)
Actual Em09ons
Uncontrolled Controlled
(tord/Yea4 (mns/year)
Requested Permit limits
Uncontrolled Controlled
(tom/year) (mm/year)
Requesssd Monthly Limits
Controlled
Pbs/month)
PM10
PM2.5
SOx
5,6
NOx
CO
VOC
0.8
ELS0.00.79
0.79
134
0.8
0.8
0.8
0.79
0.79
134
6.0
6.0
5.99
.17
3.2
3.2
0.]
3.19
0.06
I1
106
19.4
30.4
10.38
1038
3764
8.7
8'.]
8.7
8.69
8.69
34]6
885.8
885.8
53
885.83
5.34
907
Hazardous Air Polluter
Potential to Fink
Uncontrolled
(ibs/year)
Actual Emissions
Uncontrolled Controlled
(ibs/year) llbs/year)
Requested Permit Umlts
Uncontrolled Controlled
Ilbs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
mHaane
224TMP
Has
Methanol
149366
149366
2884
149366
28.
76956
]6956
1501
]6956
1501
995]
9957
195
9957
105
22008
22608
434
22008
434
6882
6=2
23
6882
23
1
0
6370
6378
127
5378
12]
0
0
0
0
0
Amine Sweetening Unit Emissions Inventory
sectim 96 -Regulate or Summary /Malya'.
Regulation?. Pars A. B
40 CM Part 6o,5ubpart LLL
40 CFR, Part 60, Subpart 0000
40 CFR, Part6o,Subpart 0000a
(See regulatory applicability worksheet for detailed analysis)
Source requires a permit
You base Indicated thatthis facility isnot wiriest to NSPS LLL
You hale Indirmedthatthiz facility is not subject. NSPS OOOO.
Facility Is sut(ectto NSP50000a - fecordhcepinn and Reporting Requirements per603423a(c)
Section 07 -Initial and Periodic Sampling and Testing Reaulremen6
Was the extended inlet (sour) gassample used In the ProMax(Hy5Y5/VMGSim) simulation site -specific and collec0d within a year of application
submittal?
If no, lie permit will contain an Initial Compliance'testing requlremeMtodemonstrate compliance.. emission IImi6
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
Ifyes, thepermitwlll contain and initial compliancetestaondition to demonstrate the destruction enxleng of the combustion device based on Inletand ...concentration sampling
If the corep ylas requested'Control device efficiercy greater than 95%, is a thermal oxidizer or regenerativethedrmal oxidizer being used toao5000 Rot yes
for
Is the mmpany using a thermal oxidizer AND requesting a minimum combustion chamber temperature lower than 1,400 degrees F?
If yes, the permitwlll Pont. an 'Initial Compliance" testing requirement ALO a permit condition specifying the minimum combustion chamber temperature for the thermal oxidizer.
Is the company using a process model to demonstrate compliance with permitlimi0, or regularsampling?
Monthly waste gas sampling£ertlres0ll vent and/or Rash tank should be included ass periodicsampteg requirement
Section 08 -Technical Analysts Notes
0p 10TlRdcato lot f�alf fik p ., h h pi
the ppbontobObe d GI arY11`d ph e Op to ndiat thatr aj
•thato
outlet Flow Meter(.) & Gas Sampling
S1 00 ref va closed loop hats, all flash tank va Il be eo bsted fuelburngq aria be rou
Ill not be operational In the event thtthe thermal oxidizernot avalabl it common thermal oxidizer controls Amnel (Po nt 0161 and Mme2(Point 017)
tor the volume of'supplemental fuel connbusted in thethermalond zer.
the t gasstro., downstream of the amine unt, and therefore bar negligible amounts of sulfur. As such, the emissions of 602 from combustion of the supplemental fuel is considered negligible Ernisslons of 502 result
1 talc, lateden 0/bVotap,fmm vie co burtan'oIsupplemental lve (e pplementallueimrbor, la) 11.ibs ngamazsbal eha[azsume % dstcf/yra of CTOO0alculate asf01owsand rb¢don r"'"'''"'"""0
evdueg mp0st0nh0predcted nth¢ fa
ProMax model tbn 10/18/18andas Included,n IM1eapplira nzup0ocr nOtrat P rtha<do00 /1O go loll/3791bmol/scftx(10^6sf/MMscflxll&l o MMscf/yc asst Iloor(x 1198,'Regr ested DPEI
se2an09-Inventory S.... and Emissions Factors
AIRS Polntk
016
Pr raceme
CC Code
Pollutant
PM10
PM15
50z
Hss
NOx
VOL
CO
Benzene
Toluene
Ethylbenuene
Xylem
n -Hexane
224 TMP
Methanol
Uncontrolled
Emissions Factor
0.022
0.022
0419
0087
0.284
24.3
0.238
2.046
1054
0.136
0.301
0.094
0.000
0.000
Control %
0.0
0.0
0.0
98.0
0.0
99.4
0.0
98.1
98.1
98.0
98.0
99,7
99.8
PHM/01
Onits
b/MMscf
b/MMscf
b/MMscf
b/MMsc
b/MMscf
b/MMscf
b/MMscf
b/MMscf
b/MMscf
h/MMscf
b/MMscf
b/MMscf
b/MMscf
b/MMscf
Amine Sweetening Unit Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
'Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section lI.D.3)?
You have indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section I I.D.1.a)7
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
'Source requires a permit
NSPS Analysis
1. Is the sweetening unit located at an onshore natural gas processing plant that processes natural gas produced from either onshore or offshore wells? 'Source is subject to Yes 'You have indicated the facility type on the Project Summary Sheet
NSPS - Continue to determine applicable sections
40 CFR, Part 60, Subpart LLL, Standards of Performance for SO2 Emissions from Onshore Natural Gas Processing
1. Did construction or modification (see definitions 40 CFR 60.2) of the sweetening unit commence after January 20, 1984 and on or before August 23, 2011 (60.640(d))?
2. Does facility have a design capacity less than 2 long tons per day (LT/D) of hydrogen sulfide (HzS) in the acid gas (expressed as sulfur) (60.640(b))7
3. 'You have indicated that this facility is not subject to NSPS LLL.
Subpart A, General Provisions
§60.642 - Standards for sulfur dioxide
§60.646 - Monitoring of emissions and operations
§60.647- Recordkeeping and reporting requirements
40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Did construction, modification or reconstruction (see definitions 40 CFR 60.2) of the sweetening unit commence after August 23, 2011 and on or before September 18, 20157
2. Does facility have a design capacity less than 2 long tons per day (LT/D) of hydrogen sulfide (HzS) in the acid gas (expressed as sulfur) (60.5365(g)(3))?
'you have indicated that this facility is not subject to NSPS 0000.
Subpart A, General Provisions per §60.5425 Table 3
§60.5405 - Standards for sulfur dioxide
§60.5407 - Monitoring of emissions and operations
§ 60.5423 - Notification, Recordkeeping and reporting requirements
40 CFR, Part 60, Subpart OOOOa, Standards of Performance for Crude Oil and Natural Gas Facilities
1. Did construction, modification or reconstruction (see definitions 40 CFR 60.2) of the sweetening unit commence after September 18, 20157
2. Does facility have a design capacity less than 2 long tons per day (LT/D) of hydrogen sulfide (HzS) in the acid gas (expressed as sulfur) (60.5365a(g)(3))?
'Facility is subject to NSPS 00OOa - Recordkeeping and Reporting Requirements per 60.5423a(c)
Source Requires an APEN. Go to the next question
Source Requires a permit
Subpart A, General Provisions per §60.5425a Table 3
§60.5405a -Standards for sulfur dioxide Do Not Apply
§60.5407u - Monitoring of emissions and operations Do Not Apply
§60.5423a(c) - Recordkeeping and reporting requirements
Colorado Regulation 3 Parts B, Section III.D.2.a - RACT
'Source Is subject to RACT
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control
Commission regulations. This document is note 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 anylaw, regulation, or any other legally binding requirement and is not legally enforceable. In the event
of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control
Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as `recommend,"'may,""should,"and 'can," is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and required" are intended to describe controlling
requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in
and of itself.
The unit is not subject - Go to Subpart 0000
60.642 Standards for sulfur dioxide
60.646 Monitoring of emissions and operations
60.847 Recordkeeping and reporting requirements
The unit is not subject- Go to Subpart OOOOa
60.5405 Standards for sulfur dioxide
60.5407 Monitoring of emissions and operations
60.5423 Recordkeeping and reportin g
The unit is subject- Go to question 2
Natural Gas Heater Emissions Inventory
018 NG Heater
Facility AIRS ID:
County Plant Point
Egipment ID
Section 02 - Equipment Description Details
Heater Information
Fuel Type
Number of Heaters
Purpose
Make:
Model:
Serial Number:
Design Heat Input Rate:
Equipped with Low-NOx burners:
Equipped with Add -On Control Equipment:
Natural Gas
One (1) natural gas heater(s) (Make: TBD, Model: TBD, Serial Number: TBD) each with a design heat input rate of 20
MMBtu/hr. Each unit is equipped with low -000 burners. Each unit isa molecular sieve regeneration heater.
Detailed Emissions Unit Description:
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency H:
Section 03 - Processing Rate Information for Emissions Estimates
Design Heat Input Rate=
Heat content of waste gas=
Actual Hours of Operation =
Requested Hours of Operation =
Requested heat input rate =
Actual Fuel Consumption =
No add-on control equipment
Low NOx combustion system is considered an integral control device.
20.0 MMBtu/hr
Il)30' Btu/scf
760, hrs/year
.§78O, hrs/year
175,200.00 MMBTU per year
170.10 MMscf/year
Requested Fuel Consumption =
170.10 MMscf/year Requested Monthly Throughput = 14.45 MMscf per month
Potential to Emit (PTE) Fuel Consumption =
Section 04 - Emissions Factors & Methodologies
170.10 MMscf/year
Emission Factors
Pollutant
PM10
PM2.5
505
NOx
CO
VOC
Formaldehyde
Benzene
Toluene
n -Hexane
Uncontrolled
lb/MMBtu
(Fuel Heat
Combusted)
0.007378641,.;
0.0073786414.-
0.000582524:
0.048543689
0.04
0.005339806
7.28155E OS
.94175E-06
3.3009.7E-06
0.001747573.
Uncontrolled
lb/MMscf
(Fuel
Consumption)
Emission Factor Source
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
SOx
NOx
CO
VOC
0.65
0.65
0.65
0.65
0.65
110
0.65
0.65
0.65
(3.65
0.65
110
0.05
0.05
0.05
0.05
0.05
9
4.25
4.25
4.25
4.25
4.25
722
3.50
350
3.50
3.50
3.50
595
0.47
0.47
0.47
0.47
0.47
79
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
gin/year) (Ibs/year)
Requested Permit limits
Uncontrolled Controlled
(lbs/year) (Ibs/year)
Formaldehyde
13
13
13. ,
13
13
Benzene
0
0
0
0.3
0.3
Toluene
1
1
1
1
1
o -Hexane
306
306
306
306
306
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 1, Section VI
Based on the requested emissions and emission factor, compliance is presumed.
Regulation 1, Section III & Regulation 6, Part B, Section II
Based on the design heat input rate, the source is subject to Regulation 1 Section III.A.1.b. and Regulation 6, Part B, Section II.C.2. and 3. Based on the
requested emission factor, compliance is presumed.
Regulation 6, Part A, Subpart Db, 502 Standards
Source is not subject to NSPS Db.
Regulation 6, Part A, Subpart Db, NOx Standards
Source is not subject to NSPS Db.
Regulation 6, Part A, Subpart Dc
Source is subject to NSPS Dc.
Regulation 7, Section XVI.D
Source Is not subject to Regulation 7, Section XVI.D.
Regulation 8, Part E, MACE Subpart DDDDD
Source is not subject to MACE 00050.
15 of42
K:\PA\2017\17 W E1090.CP2.xlsm
Natural Gas Heater Emissions Inventory
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Is the project close to the 40 tpy modeling/ NANSR threshold for NOx?
If yes, stack -testing should be required for NOx, as well as for CO.
Is the operator limhingtheir heat input rate below the design rate?
If yes, stack -testing should be required for NOx, as well as for CO.
Is the project close to the 5 tpy modeling threshold for PM 2.5?
If yes, stack -testing should be required for PM 2,5 .
Does the company use AP -42 emission factors (or more conservative factors)?
If no and testing hasn't already been required due to proximity to modeling thresholds, testing should be required for any pollutants for which altemative emission factors
have been used. If testing is being done for only NOx or only CO, the other should be included as well.
Section 08 - Technical Analysis Notes
'Any of the heaters that use AP 42, Chapter 1 factors to calculate emissions should be corectng the emission factor based ens rano of the heat content of the proposed fuel gas (1030btu/acf)and the avg heat content of
natural gas used to develop the factors (1020btu/scf see Table 141, footnote al In this case, the correctondoesn't result in asgnifcant change in emissions Furthermore, it appears that the emission factors were not
corrected for the HHV reported with issuance 1 for Points 003& 004 Therefore, I will moe ferwarl assuming the lb/AIN/sof factors listed inAP-42 table 14-2: The operator: was made aware of this adjustment for future
epicat.uns' It should further he noted that the at umed heating value of the fuel gas at to s facility (10300tc/scf) is based on process models. Therefore, I believe that the factors based on the average heating value of 1020
btu ,'sun sac2eotable.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
018
Uncontrolled
Emissions
Process # SCC Code r Pollutant Factor Control% Units
01 3-10-004-04: Industrial Process; Oil & Gas Production; Process Heaters; Natural Gas (MMscf) PM10 7.60 0 lb/MMscf Burned
PMZ.5 7.60 0 lb/MMscf Burned
508 0.60 0 lb/MMscf Burned
NOx 50.00 0 lb/MMscf Burned
CO 41.20 0 lb/MMscf Burned
VOC 5.50 0 lb/MMscf Burned
Formaldehyde 7.50E-02 0 lb/MMscf Burned
Benzene 2.00E-03 0 lb/MMscf Burned
Toluene 3.40E-03 0 lb/MMscf Burned
n -Hexane 1.8 0 lb/MMscf Burned
16 of 42 K:\PA\2017\17W E1090.CP2.xlsm
Natural Gas Heater Regulatory Analysis Worksheet
Bated on the heater purpose selection In the Inventory, this unit qualifies as fuel burning equipment per Colorado Regulations 1 & 6, a steam generating unit per NSPS Oh & Da and
a industrial, commercial or institutional boiler or process heater per MALT 1511000
'This unit fires natural gas as defined by NSPS Oh & Dc 4ndfor Is designed to burn gas 1 fuels as defined by MAC( 0001)0
�Colorado Re ulanon3Par0Aand B-APENand Peeni[�ulrements
Sourre isle the Namhttxinmont Met
ATTAINMENT
1. Are uncontrolled actual emissions of any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)7
2. Does the heater have a design heat Input rate less than or equal to5 MMBtu/hr? (Regulation 3, Part A, Section11.0.1.k.)
3. Does the heater have a design heat input rate less than or equal to 10 MMBtu/hr?(Regulation 3, Part B, Section ll.D,l.e.)
4. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.31?
INot enough information
NON -ATTAINMENT
1. Are uncontrolled emissions of any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II o tel?
2. Does the heater have a design heat Input rate less than or equal to 5 MMBtu/hr? (Regulation 3, Part A,Section 11.0.1.0.1
3. Does the heater have a design heat Input rate less than or equal to 10 MMBtu/hr? (Regulation 3, Part B, Section II.D.1.e.)
4. Aretota l facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than S Yes or CO emissions greeter than 10TPY (Regulation 3, Part B, Section 5.D.21?
(Source requires a permit
Colorado Regulation 1, Section VI
1. Are sulfur dioxide emissions from the heater greater than 2 tons per day? (Regulation 1, Section VI.B.S.a.)
loused on the requested emissions and emission factor, compliance is presumed.
Section 01.8.0- Emission Limits
Section VI.B.6 and 7 - Recordkeeping, Reporting, Data Retention
Colorado Regulation 7. Sectich Ill and Colorado Regulation 5, Pert B. Section II, Standards of Performance for New. Fuel-Rurolne E9uloment
1. What is the design heat input rate of the heater? (Regulation 1, Section M.A. and Regulation 6, Part B, Section ll.C.)
2 Does the source discharge particulate matter in excess of 0.516/Mmbtu heat input? (Regulation 1, Section ill.A.1.a. and Regulation6, Part B, Section l l.C.1.)
3. Does the source discharge particulate matter in excess of the following equation: PE. 0.5(Fil1-1Bl? (Regulation 1, Section lll.A.l.b. and Regulation 6, Part 5, Section ll.C.2.l
4. Does the source discharge particulate matter in excess of 0,llb/Mmbtu heat input? (Regulation 1, Section lll.A.l.c.)
Based on the design heat input rate, the source Is subject ro Regulation 3 Section III,A.0.b. and Regulation 6, Part R, Section II,C.2. and 3. Based on the requested emission factor,
compliance is presumed.
Colorado Regulation 7, Section XVI.D.
1. Did the natural gas fired heater exist ate major source of NO0 as as othune 3,2016? (Regulation 7 Section10/1.0.1.1
2. Does the natural gas fired heater have uncontrolled actual emissions of NOx equal to or greater than 5 Spy? (Regulation 7 Section XVI.D.6.a.)
lSource Is notsubject to Regulation 7, Sem€on XVI.D.
Section XVI.e.6.b.—Combustion Process Adjustment
Section XVI,D.7.— Recordkeeping
NSPS Analysis
1. Does the natural gas fired heater nave maximum design heat input capacity of 29 megawatts (MW)(100MMbtu/hr) or less, but greater than or equal to 2.9 MW(10MMbtu/hr)? (460.40c(a))
2. Does the natural gas fired heater have a maximum design heat input capacity greater than 29 megawatts (MW) (100 MMBtu/hrl? (460.40b(a))
Evaluate questions in NSPS Da section below,
40 CFR, Part 60. Subpart Dc, Standards of Performance for Small Industrial -Commercial -Institutional Steam Generating Units
1. Did construction, modification or reconstruction of the steam eneratin unit commence after June 9, 19897 460,40c(a
Source Is subject. NSPS DA
Subpart A, General Provisions
loo sus- Reporting and Recordkeeping Requirements
4a/��
6fJ1fYX.prudi "
s
Na
No
Go to the next question.
Au to the next question.
Source Requires an APEN. Go to the next question
Go to the next question.
Go to the next question.
urce Requires n. permit
No leased on the requested emissions and emission factor, compliance is presumed.
Btu/
Yes
No
40 CFR, Part 60, Subpart Db, Standards of Performance for Industrial-Commerdailnstitutlonel Steam Generating Units
1. Did construction, modification, or reconstruction of the steam generating unit commence afterlune 19, 1984? (460.40b(a))
502 Standards
2. Does the natural gas fired heater have a potential 502 emission rate of 140 ng/J(0.321b/MMBtu) heat Input or less? (460.42b(k)(211
3. Did the affected facility commence construction, reconstruction or modification after February 28, 20057 (460.42b(kl(1))
'Source A not subject to NSPS Oh.
NOR Standards
4. Does the natural gas fired heater have a heat Input capacity of73MW (250 MMBtu/hr) or less? (050.44h(5()
5. Does the heater meet alt of the following criteria? (460.44b(k))
5a. Combust, alone or In combination, only natural gas, distillate oil, or residual oil with a nitrogen content of 0.3 weight percent or less (460.44b(I)(1));
513. Have a combined annual capacity factor of 10 percent or less for natural gas, distillate all, and residual oil with a nitrogen content of 0.30 weight percent or less (460.44b(j)(21); and
Are subject to a federally enforceable requirement limiting operation of the affected facility to the firing of natural gas, distillate oil, and/or residual all wRh a nitrogen content of 0.30
weight percent or less and limiting operation of the affected facility to a combined annual capacity factor of 10 percent or less for natural gas, distillate oil, and residual oil with a nitroge,
5c. content of 0.30 weight percent or less. (060.441(7)(311
6. Did the effected facility commence construction, reonfiatruStlan Or modification after luly 09, 1997? (460.44b(1))
Is the natural gas fired heater subject to and in compliance wieh a federally enforceable requirement that limits operation of the facility to en annual rapacity factor of 10 percent (0.10) or less for
7. coal, oil, and natural gas (or any combination of the three)? (460.44b(I)(1))
Does the natural gas fired heater have low heat release rate and combust natural gas or distillate oll In excess of 30 percent of the heat input on a 30 -day rolling average from the combustion of all
8. fuels? (460.44b(11(211
Source Is not subject to COPS Db.
Go to queSElon 3.
Based on the requested emission factor, compliance Is presumed.
Based on the requested emission factor, compliance is presumed.
Rated on the requested emission factor, compliance Is presumed.
urea is not subject to Regulation 7, Section XVI.D.
Go to NSPS Uc applicability section
Source A not subject to NSPS Db.
aurae is subject to NSPS Dc.
Go to question 45.
Go to next question.
MACT Analysis
40 CFR, Part 63, Subpart MACT MOOD, NESHAP for Malor sources: Industrial. Commercial, and Institutional Boilers and Process Heaters
1. Is the heater located at a facility that is a major source for HAPs? (§63.7485)
2. Did construction (363.7490(b)) or reconstruction (463.7490(c)) of heater commence after lune 4, 2010?
3. Is the heat Input capacity less than or equal to 5 MMBtu/hr7 (463.7500(e))
4. Is the heat Input capacity greater than 5 MMBtu/hr but less than or equal to 10 MMetu/hr7 (§63.7500(0))
'Source is not subject to MACT 09060,
§63.7500 (e) and Table 3 -Work practice standards
§63.7505(a) -General requirements
§63.7510 (e) - Initial requirements for existing sources OR 63.7510 (g) for new sources
(63.7515(d) -Subsequent tests, fuel analyses or tune-ups
§63.7539: le) and (f) -Demonstrating initial compliance
§63.7540 (a)(10) and (a)(13) -Demonstrating continuous compliance
§63.7546 (a), lb -for existing or c - for new), (e), (e)(1), e(6), e(7), ale) - Notifications
463.7550(a), (b), (c), (c)(1), 6(3) -Reporting
§63.7555 (a), (a)(1) and (2) and 63.7560 (a), (b) and (c)-Recordkeeping
Disclaimer
This document assists operators 554th determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control
Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts
and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the
event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control
Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,"'inlay,""should,"and "can,
"is
intended to describe APCD interpretations and recommendations. Mandatory terminology such es "must"and 'required' are intended to describe controlling
requiremen(5 undefthe f®rmp of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in
and of itself.
No
No
the unit is not subject to MAR.
Go to next question.
The source must conducta tune-up annually.
Natural Gas Heater Emissions Inventory
019 NG Heater
Facility AIRS ID:
123 9F67 019
County Plant Point
HTR-6
Section 02 - Equipment Description Details
Heater Information
Fuel Type
Number of Heaters
Purpose
Make:
Model:
Serial Number:
Design Heat Input Rate:
Equipped with Low-NOx burners:
Equipped with Add -On Control Equipment:
One (1) natural gas heater(s) (Make: TBD, Modet TBD, Serial Number: TBD) each with a design heat input rate of 55
MMBtu/hr. Each unit is equipped with low-NOx burners. Each unit isa hot oil heater.
Detailed Emissions Unit Description:
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Section 03- Processing Rate Information for Emissions Estimates
Design'Heat Input Rate=
Heat content of waste gas =
Actual Hours of Operation =
Requested Hours of Operation
Requested heat input rate =
Actual Fuel Consumption =
No add-on control equipment
Low NOx combustion system is considered an integral control device.
55 MMBtu/hr
1030' Btu/scf
8760 hrs/yea.r
8760; hrs/year
481,800.00 MMRTU per year
467.77 MMscf/year
Requested Fuel Consumption =
467.77 MMscf/year Requested Monthly Throughput= 39.73 MMscf per month
Potential to Emit (PTE) Fuel Consumption =
Section 04- Emissions Factors & Methodologies
467.77 MMscf/year
Emission Factors
Pollutant
PM10
PM2.5
500
NOx
CO
VOC
Formaldeh de
Benzene
Toluene
n -Hexane
Uncontrolled
Ib/MMBtu
(Fuel Heat
Combusted)
0.007378641
0.007378641
0.000582524`
0.048543689:::
0.005339806"s'-'.
Uncontrolled
lb/MM
Emission Factor Source
(Fuel
Consumption)
IMEM
MMIZM
1.94175E-06
3.30097E-06
0001747573'..;.
0.002
0.0034
Section 05- Emissions Inventory
0
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
1.78
1.78
1.78
1.78
1.78
302
1.78
1.78
1.78
1.78
1.78
302
0.14
0.14
0.14
0.14
0.14
24
11.69
11.69
11.69
11.69
11.69
1986
9.64
9.64
9.64
9.64
9.64
1637
1.29
1.29
1.29
1.29
1.29
219
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ihs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (Ibs/year)
Formaldehyde
35
35
35
35
35
Benzene
1
1
1
1
1
Toluene
2
2
2
2
2
n -Hexane
842
842
842
842
842
Section 06 - Regulatory SummanAnalysis
Regulation3, Parts A, B
Not enough information
Regulation 1, Section VI
Based on the requested emissions and emission factor, compliance is presumed.
Regulation 1, Section III & Regulation 6, Part B, Section II
Based on the design heat input rate, the source is subject to Regulation 1 Section M.A.1.6. and Regulation 6, Part B, Section II.C.2. and 3. Based on the requ
Regulation6, Part A, Subpart Dia, SO2 Standards
Source is not subject to NSPS Ob.
Regulation 6, Part A, Subpart Db, NOx Standards
Source is not subject to NSPS Db.
Regulation 6, Part A, Subpart Dc
Source is subject to NSP5 Dc.
Regulation 7, Section XVI.D
Source Is not subject to Regulation 7, Section XVI.D.
Regulation 8, Part E, MACTsubpart DDDDD
Source is not subject to MAR 00000.
19 of 42
K:\PA\2017\171N E1090.CP2.xlsm
Natural Gas Heater Emissions Inventory
Section 071 Initial and Periodic Sampling and Testing Requirements
Is the project closeto the 40 tpy modeling/ NANSR threshold for N050
If yes, stack -testing should be required for NOx, as well as for CO.
Is the operator limiting their heat input rate below the design rate?
Ifyes, stack -testing should be required for NOx, as well as for CO.
Is the project close to the 5 tpy modeling threshold for PM 2.5?
If yes, stack -testing should be required for PM 2.5
Does the company use AP -42 emission factors (or more conservative factors)?
If no and testing hasn't already been required due to proximity to modeling thresholds, testing should be required for any pollutants for which alternative emission factors
have been used. If testing is being done for only NOx or only CO, the other should be included as well.
Section 08 -Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
019
Process # 5CC Code
Uncontrolled
Emissions
Pollutant Factor Control % Units
01 I3-10-004-04: Industrial Process; Oil & Gas Production; Process Heaters; Natural Gas (MMscf) PM10 7.60 0 6/MMscf Burned
PM2.5 7.60 0 lb/MMscf Burned
SOx 0.60 0 6/MMscf Burned
NOx 50.00 0 6/MMscf Burned
CO 41.20 0 6/MMscf Burned
VOC 5.50 0 6/MMscf Burned
Formaldehyde 7.50E-02 0 6/MMscf Bumed
Benzene 2.00E-03 0 t,/MMscf Burned
Toluene 3.40E-03 0 6/MMscf Burned
n -Hexane 1.8 0 Ib/MMscf Burned
20 of 42 K:\PA\2017\17hVE1090.CP2.xlsm
Natural Gas Heater Regulatory Analysis Worksheet
Rased on the hearer purpose selection In the inventory, this unit qualifies as fuel burning equipment per Colorado Regulations 1 & 6, a steam generating unit per NSPS Ob & dr end
a Industrial, commercial or institutional boiler or process heater per MALT 00000
'This unit fires natural gas as defined by NSPS Oh & Ito end/or is designed to hum gas 1 fuels as dented by MACE 00000
Colorado 1----3M
Iaaeeon 3 Parts A and B-APEN and Permit Re• ulrements
I Source is in the Nun -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions of any criteria pollutants from this indrvldualsource greater than 2 TPY (Regulation 3, Part A, Section I1.D.1.a)?
2. Does the heater have a design heat input rate less than or equal to 5 MMBtu/hr? (Regulation 3, Part A, Section 11.0.1.k.)
3. Does the heater have a design heat input rate less than or equal to 10 MMBtu/hr7 (Regulation 3, Part B, Section II.D.1.e.)
4. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOY greater than 10 TPY or CO emissionsgreamr than lO TPY (Regulation 3, Part B, Section 11.0.3)?
Not enough information
NON -ATTAINMENT
1, Are uncontrolled emissions of any criteria pollutants from this Individual source greater than l TPY (Regulation 3, Part A, Section lLD.1.a)?
2. Does the heater have a design heat input rate less than or equal to 5 MMBtu/hr? (Regulation 3, Part A, Section 11.0.1.k.)
3. Does the heater have a design heat input rate less than or equal to 10 MMBtu/hr7 (Regulation 3, Part El, Section II.D.1.e.)
4, Are totalfacil uncontrolled VOC emissions neater than 2 TPY NOx reeterthan 5TPY or CO emissions neater than 10TPY Regulation 3, Part B, Section 0.0.2)7
Not enough information
No
No
Colorado Regulation 1. Section VI
1. Are sulfur dioxide emissions from the heater greater than 2 tons per day? (Regulation 1, Section Vl.e.S.e.)
'Based on the requested emissions end emission factor, compliance 0 breabteo.
Section AIRS - Emission Limns
Section VI.0.6 and 7- Recordkeeping, Reporting, Data Retention
Colorado Regulation 1, Section III and Colorado Regulation 6, Part B. Section II, Standards of Performance for New Fuel -Burning Equipment
1. What is the design heat input rate of the heater? (Regulation 1, Section M.A. and Regulation 6, Part B, Section ll.C.)
2 Does the source discharge particulate matter In excess of 0.5lb/Mmbtu heat input?(Regulation 1, Section 11i.A.t.a. and Regulation 6, Part 0,Section lI.C.1.)
3. Does the source discharge particulate matter In excess of the following equation: PE=0.5)ml)501?(Regulation 1, Section III.A.1.b. and Regulation6, Part B, Section II.C.2.)
4. Does the source discharge particulate matter In excess of 0.1 lb/Mmbtu heat input? (Regulation 1, Section ill.AC.r.)
Based on the design heat input rate, the source is subject to Regulation 1 Section IIt,A.l.b. and Regulation 6, Part B, Section Il.C.2, and 3. Based on the requested emission factor,
compliance is presumed.
Colorado Regulation 7. Section XVI.D.
1. Did the natural gas fired heater exist ate major source of Nat as as erlune 3, 20167 (Regulation 7 Section Cvioi.)
2. Does the natural gas fired heater have uncontrolled actual emissions of NOx equal to or greater than 5 tpy? (Regulation 7 Section XVl.D.6.a.)
'Source is not subject to rtegulation 7, Section XVI.D.
Section XVI.D.6.b. —Com bustion Process Adjustment
Section XVI.D,7.—Recordkeeping
NSPS Analysis
1. Does the natural gas fired heater have a maximum design heat Input capacity 0120 megawatts (MW)(100 MMBtu/hr) or less, but greater than or equal to 2.9 MW(10MMBtu/hr)7(§60.40c(a))
2. Does the natural gas fired heater have a maximum design heat input rapacity greater than 2e megawatts (MW)(100 MMBtu/hr)? (§60.40b)a))
Evaluate quesdnns in NSPS On section below,
40CFR, Part60, Subpart Dc, Standards of Performance for Small industrial.Commerdal.learl tional Steam Generating Units
1. Did construction, modification, or reconstruction of the steam generating unit commence after June 9,1989? 1460.40c(a))
'Source is subject to NSPS OS
Sub part A, General Provisions
§00.400- Reporting and Recordkeeping Requirements
40 CFR, Part 60, Subpart Ob. Standards of Performance for rndustrlaKemmercial-Institutional Steam GeneretfngUnlis
1. Did construction,modification, or reconstruction of the steam generating unit commence after June 19, 19847 (460.40b(a))
502 Standards
2. Does the natural gas fired heater have a potential 502 emission rate of 140 ng/J(0.32 lb/MMBtu) heat input or less? 1460.42b(k)(2))
3, Did the affected facili commence construction, reconstruction or modification after Februa 28,20057§60.42bk(1)
Source Is not subject to NSPS Oh,
Noe Standards
4. Does the natural gas fired heater have heat input capacity of 73 MW (250 MMetu/hr) or less? (§60.44b(k))
5. Does the heater meet 311 of the following criteria? (§60.44b(k))
5a. Combust, alone or in combination, only natural gas, distillate oil, or residual oil with a nitrogen content of 0.3 weight percent or less(460.4460)(1)B
to the next question.
sa to the next question.
Go to the next question.
Go to the next question.
No I Based on the requested emissions and omission factor, compliance Is presumed.
No
56. Have a combined annual capacity factor of 10 percent or less for natural gas, distillate oil, and residual oll with a nitrogen content of 0.30 weight percent or less (§60.4460)(2)), and
Are subjectto a federally enforceable requirement limiting operation of the affected facility to Merging of natural gas, distillate oil, and/or residual oil with a nitrogen content of 0.30
weight percent or less and limiting operation of the affected facility toe combined annual capacity factor of 30 percent or less for natural gas, distillate oil, and residual oil with a nitrogen
Sc. content of 0.30 weight percent or less, (§60.44b0)(3))
6. Old the affected facility coo construction, reconstruction or modification afterluly 09,1997? (§60.44b9))
lathe natural gas fired heater subject to and in compliance with a federally enforceable requirement that limits operation of the facility to an annual capacity factor of to percent (0.10) or less for
7. oal, oil, and natural gas (or any combination of the three)? 1§60.444)(1))
Does the natural gas fired heater have low heat release rate and combust natural gas or distillate ail in excess of30 percent of the heat input on a 30 -day rolling average from the combustion of all
8. fuels?(§60.446(0)2))
Source is notsublent to NSPS Oh.
Yes
Go to question 3.
Based wt the requested emission factor, compliance Is presumed.
Bused on the requested emission factor, cOmpllunce Is presumed.
Based on the requested emission factor, compliance is presumed.
Source Is not subject to Regulation 7, Section XVI.D.
Go to NSPS De applicability section
Source Is not subject to NSPS Db.
rblect to NSPS Dc
Go to question Its.
00 to next question.
MACT Analysis
40 CFR, Part 63, Subpart MAR 00000. NESHAP for Motor sources: Industrial, Commercial, and Institutional Boilers and Process Heaters
1. Is the heater located at a facility that is a major source for HAPS? (453.7485)
2. Did construction (453.7490(b)) or reconstruction (463.7490(0) of heater commence afterlune 4, 2010?
3. Is the heat input capacity less than or equal to 5 MMBtu/hr? (463.7500(e))
4. Is the heat input capacity greater then 5 MM Btu/hr but less than or equal to 30 MMatu/hr? (463.7500(e))
ISource Is not subject to MACT ODDOO,
403.7500 (e) end Table 3 -Work practice standards
463.7505 (a) -General requirements
§63.7510 (e)- Initial requirements for existing sources OR 63.7510 (g) for new sources
463.7515(d)- Subsequent tests, fuel analyses or tune-ups
463.7530 (e) and (f) - Demonstrating initial compliance
§63.7540 (a)(10) and (0)(13) -Demonstrating continuous compliance
063.7545 (a), lb -for existing or c - for new), (e), (e)(1), e(6), e(7), eta) - Notifications
§63.7550 (e), (b), (c), (c)(1), h(3) -Reporting
463.7555 (e), (e)(1) and (2) and 63.7565 (a), (b) and (c)-Recordkeeping
Disclaimer
This document assists operators 04th determining applicability of certain requirements of the Clean Air Act, its implementing regulations, end Air Quality Control
Commission regulations. This document is not 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, crony 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 AlrAct„ 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 es'recommend,""may,""should,"and "can,"ls
intended to describe APCD interpretations and recommendations. Mandatory terminology such as "moot" and 'required"are intended to describe controlling
requirements under the terns of the Clean Air Act end Air Quality Control Commission regulations, but this document does not establish legally binding requirements in
end of itself _
The unit is not subject to MACT.
Go to next question,
The source must conducts tuna -up annually.
Natural Gas Heater Emissions Inventory
@o NO Neater
County
Section trz- Emsloment OeanlpHon wo-ip
Neater
Information
Feel
umber&Heaters
Purpose
Make:
Meal Number.
Seams Heat Input Rate:
EsluMPed with Low -NOT burners:
Equipped with Ad.. Control Equipments
na In nebula ga.heated+)IMakes reo, Med. T90. sera, Numbers TED) each g P ram .55
MMatu/hr. Earn unit m equipped with 1ow.No. burners. Each unit e a hot ell noare„a a
oetaned Emislmts Unit Des.pdon:
Emission Control De.Ite OesalFtiom
Requested Overallroc& Hu Control EMclencyx
Section
03-Na Naomi,
Wm Information for Emissions Estimates
Design
Heat content of vsastegase
Actual Mousse Operation=
Requested Nam of Operation.
Requested Mat hoot ate=
Actual Fuel Consumption=
'Requested Fuel Conumpton=
law NOT combustion system Is considered an Integral mood device
467.77 MMscf/year
P tentlal t4 Emlt (IME) Fuel Comumpnpn=
Section 09 -.lesions Faeces & Motbodoloeles
467.77 MMsd/yar Recosested Momthly7Maghpm=
467.77 MMsefHear
Section es - Emissions bamtory
Miter. Pollutants
Potential m Emlt
Uncontroged
(tons/year)
(tons/year) ROM/year)
em*UM6
Uncontrolled trolled
lo,rn l (mp/rear)
Hequmted Monthly Um.
trolled
(Ms/rnonth)
PNITO
69625
NO8
wt
1.78
176
178
1.76
1.78
302
1.78
1.78
178
1.78
302
11.69
11.69
1129
11.69
11.69
1986
129
129
129
1.29
1.29
219
HamNous Alr Pollutants
Ptidto Emlt
Uncontrolled
(lb5./seer1
Actual...a
Uncontrolled
Ubs/year) (Ibs/yar)
Permit Um.
Uncontrolled Controlled
(ibs/year) Ilbs/year)
Formaldehs.•
35
35
Dentana
n-Nesone
842
642
642
$92
692
39.73 MMsd per mmth
egu.tiam3. Pares A.
eguladon 1, section M
RegulatIon 1. Section ...Sefton 6. PartDoll
ewlaaam 6. PartA, Subpart 06,502 Standards
eauladm 6. Part A, Subpart Oh, NOT standards
Regulation 6.Part 0...artOn
egulallon7,Sectlen%ND
Regulation 8, Part E, MACTSubpert DOOM
Soma rests... a Porn
and ant. requested emissions and emission factor, consonance Is presumed.
Based an tie design Ilea -tine. ram. the source Is subject to Regumtimi 1 smlon M.A.I., and Reeutacbn 6. Part %Seaton II.C.2. and 3. Muni on the moo
Source nansubjers to N5P5 Ob.
Source le nat subject -to N5P5 Ob.
Source Is subka to asps De
Source Is not subjectb narvhtbn 7. salvo n %V I.O.
Source Is not subject So MACT00000.
'sea nry.ry.ppliablihywodoheet ford etaaea analysb)
Seeelpn m-Inh41 and ...din semolina and nestles Rmmuimmamr
is emdec... to me4otpy modeBng/ NANsn threshaunrNOsa
If yes, Mack-I...should be rectired Mr NOT, as well as for CO.
Is the operator Ilmhingthein heat input rte Mlow the design prep
If yes, stacktestIng should he repined for NOM, as well as la ter.
lathe project close to they Spy modeling th..Id for PM 2.82
If yes, sack-W.6m shMBM required for PM 25
Does the bsbn factors (or mom conservative ors), (Manufacturer rate for CO)
If roar. testingivsntlr already required due to pvrimity b modeling thresholds. testing Medd be requtrei for any pollutants for Moll alternative emission hews
have been used. If testing beIng donator only NOT or only CO, Me other aheUd be included as well.
AIRS Petro q
020
Process!, WC Cade
Uncontrolled
Pogrom Factor Course", Units
of 13-1enw-o4. Indmetlelpmoa: AI80as Production: Process nema s:mural PM10 720 0 /MMof Mimed
P6425 7.60 0b/MM.Bumed
50x 0.60 0b/MMxf Burned
b/MMrefBurned
CO 41.20 /MMrof gumed
b/MMscf Burned
rmaldeh6de b/MMscf Burned
germane 200E-03 0 bNM., Burned
Toluene b/10MMut Burned
01Msane 18 0 b/MMScf Burned
23 of 42
%:\P \2017 17W61090.CP2.T6m
Natural Gas Heater Regulatory Analysts Worksheet
Based on the heater purpose selection in the Inventory, this unit qualifies as fuel burning equipment per Colorado Regulations 1 & 6, a steam generating unit per fins Ob & Dc and
a industrial, commercial or institutional boiler or process heater per MALT PROUD
This unit tires natural gas as defined by NSPS Ob & Dc and/or Is designed to burn gas S fuels as defined by MACT Deane
Colorado Regulation 3 Parts A and B -APEN and Permit Requirements
'Source ,5 in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions of any criteria pollutants front this Individual source greater than 2 TPY (Regulation 3, Part A, Section Il.D.1.a)?
2. Does the heater have a design heat input rate less than or equal to MMBtu/hr? (Regulation 3, PartA,5ecdon 11.D.1k.)
3. Does the heater have a design heat input rate less than or equal to 10 MMBtu/hR(Regulation 3, Part B, Section ll.D.1.e.)
4. Are total faclllt uncontrolled VOC emissions greater than C ITV Ni3x reater than lO TPY or CO emissions :rester than 10 Try Revelation 3, Part B, Section ll.D.3
Not enough information
NON -ATTAINMENT
1. Are uncontrolled emissions of any criteria pollutants from this Individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Does the heater have a design heat Input rate lesslher or equal to 5 MMBtu/hr? (Regulations, Part A, Section ll.D.1.k.)
3. Does the heater have a design heat Input rate less than or equal to 10 MMBtu/hr? (Regulation 3, Part B, Section Ii.D.1.e.)
4. Are total facility uncontrolled VOC emissions greater than 2TPY, NOx greater than 5TPY or CO emissions greater ihan 10 TPY (Regulation 3, Part B, Section ll.D.2)?
'Source requires a permit
No
Colorado Regulation 1, Sectlan VI
1. Are sulfur dioxide emissions from the heater greater than 2 tons per day? (Regulation 1, Section Vl.8.5.a.)
'Based en the requested emissions and emission factor, Wmpilatee Is presumed.
Section VI.B.5 -Emission Limits
Section VI.B.6 and 7- Recordkeeping, Reporting, Data Retention
Colorado Regulation 1, Section Ill and Colorado Regulation 6, Part B. Section II, Standards of Performance for New Fuel -Burning Equipment
1. What Is the design heat input rate of the heater? (Regulation 1, Section lll.A. and Regulation 6, Part B, Section ll.C.)
2 Does the source discharge particulate matter In excess of 0.5 Ib/Mmbtu heat input? (Regulation 1, Section III.A.1.a. and Regulation 6, Part B, Section II.C.1.)
3. Does the source discharge particulate matter In excess of the following equation: PE=0.5(FIi1'�61?(Regulation 1, Section lll.A.1.b. and Regulations, Part B, Section Il.C.2.)
4. Does the source discharge particulate matter in excess of 0.1 Ib/Mmbtu heat Input? (Regulation 1, Section III.A.1.c.)
Based on the design heat input rate, the soursw is subject to Regulation 15ectlon 'A.A.B.h. and Regulation 6, Part 0, Section 11.C,0. and 3. Based on the requested emission factor,
compliance Is presumed.
Colorado Regulation 7. Section XVI.D.
1. Dld the natural gas fired heater exist at a major source of NOY as as of lune 3, 2016? (Regulation 7 Section XVI.D.1.)
2. Does the natural gas fired heater have uncontrolled actual emissions of NOx equal to or greater than 5 tpy? (Regulation 7 Section XVI.D.6.a.)
'Source is not subject to Regulation ',Section XVI.D.
Section XVI.D.6.b.-Combustion Process Adjustment
Section XVI.o.7.-Recordkeeping
NIPS Analysis
1. Does the natural gas fired heater have a maximum design heat Input capacity of 29 megawatts (MW) (100 MMBtu/hr) or less, but greater than or equal to 2.9 MW(10MMBtu/hr)? (§60.40c(a))
2. Does the natural gas fired heater have a maximum design heat Input capacity greater than 29 megawatts (MW) (100 MMBtu/hr)?(§6040b(a))
)Evaluate questions In NSPS Dc secton below.
40 CFR. Part 60, Subpart sc. Standards of Performance for Small Industrial -Commercial -institutional Steam Generating Units
1. Did construction, modification, or reconstruction of the steam generating unit commence after June 9,1909? (§6D.4Dc(a))
'Source is subject to NSPS Dc.
Subpart A, General Provisions
§60.48c -Reporting and Recordkeeping Requirements
40 CFR. Part 60, Subpart Db, Standards of Performance for Industrial -Commercial -Institutional Steam Generating Units
1, Old construction,modification, or reconstruction of the steam generating unit commence after June 19,1984?(§60.40biai)
502 Standards
2. Does the natural gas fired heater have a potential 502 emission rate of 140 ng/J(0.30 ib/MMBtu) heat input or less? (460.42b(k)(2))
S. Did the affected facill commence construction, reconstruction or modification after Fehruar 28,2005? (560.42b k)(1))
Source is not subject to NSPS Oh.
505 Standards
4. Does the natural gas fired heater have a heat Input capacity of 73 MW (250 MMBtu/hr) or less?(§60.44b(k))
5. Does the heater meet ajt of the following criteria? (460.44b(k))
5a. Combust, alone or in combination, only natural gas, distillate oil, or residual oil with a nitrogen content of 0.3 weight percent or less (§60.4465)(1));
5b. Have a combined annual capacity factor of 10 percent or less for natural gas, distillate oil, and residual oil with a nitrogen content of 0.30 weight percent or less (460.44b))(2)); and
Are subject to a federally enforceable requirement limiting operation of the affected facility to the firing of natural gas, distillate oil, and/or residual oil with a nitrogen content of 0.30
weight percent or less and limiting operation of the affected facility to a combined annual capacity factor of 10 percent or less for natural gas, distillate oil, and residual oil with a nitrogen
Sc. content of 0.30 weight percent or less. (460.44b(j)(3))
6. Did the affected facility commence construction, reconstruction or modification after July 09,1997? (460.446(1))
Is the natural gas fred heater subject to and In compliance with a federally enforceable requirement that limits operation of the facility to an annual capacity factor of 10 percent (0.10) or less for
7. coal,oil, and neturalgas(or any combination of the three)? I460.44b(I)(1))
Does the natural gas fired heater have low heat release rate and combust natural gas or distillate oil in excess of30 percent of the heat Input on a 30 -day rolling average from the combustion of all
8. fuels? 060.446(0(2))
Go to the next question.
Go to the next question.
Snume Regniros an SPEW, Go to the next question
Go to the next question.
Go to the next question.
Source Requires a permit
No 'Based on the requested emissions and emistlon factor, compliance Is presumed.
Yes
'Source is not subject to NSPS Db.
Yas
Go to question 3.
Rased on the requested omission factor, compliance is presumed.
Rased on the requested emission factor, compliance Is presumed.
Based on the requested emission factor, compliance Is presumed,
Source is not subject to Regulation 7, Section XVI.D.
Go to NSPS Dc appiicebillty section
Source Is not subject to N5P5 Db.
Source is subject to NIPS Dc.
Go to question 85.
n to next question.
MAC! Analysis
40 CFR, Part63, Subpart MACE 00000, NESHAP for Maier neurces:Industrial, Commercial, and Institutional Boilers and Process Heaters
1. lathe heater located ata facility that Is a major source for HAPs? (463.7405)
2. Did construction (463.7490(bl) or reconstruction(563.7490(c)) of heater commence afterlune 4,2010?
3. lathe heat input capacity less than or equal to 5 MM9tu/hr? (563.7500(e))
4. Is the heat input capacity greater than 5 MMBtu/hr but less than or equal to 10 MMRtu/hr? (563.7500(e))
(Source Is not subject to MALT (MOOD.
563.7500 (e) and Table 3 -Work practice standards
563.7505(a) -General requirements
563.7510 (e)- Intel requirements for existing sources OR 63.7510 (g) for new sources
563.7515 (d) -Subsequent tests, fuel analyses or tune-ups
563.7530 (e) and (f( -Demonstrating Initial compliance
663.7540 (a)(10) and (a)(13) - Demonstrating continuous compliance
453.7545 (a), (b -for existing or c -for new), (e), (e)(1), e(6), e(7), e(8) - NotIOcatlons
553.7550 (a), (6), (a), (c)(1), h(3) -Reporting
463.7555 (a), (a)(1) and (2) and 63.7560 (a), (b) and (c)-Recardkeeping
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 note nub or regulation, and the analysts 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,"end °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 AlrQualifY Cenfrol Commission regulations, but this document does not establish legally binding requirements in
and of itself.
No
No
The unit is not subject to MACT.
Go to next question.
The source must conduct a tune-up annually.
Condensate Storage Tank(s) Emissions Inventory
022 Condensate Tank
Facility AIRs ID:
123 9F67
County Plant
022!
Poin
Section 02 - Equipment Description Details
Detailed Emissions Unit fodr(4)1000;hhl atmospheric fixed roof tanks for storage of stanli ed condensate
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency 46:
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions- Storage Tank(s)
Actual Condensate Throughput =
I Requested Permit Limit Throughput =
.f+igf,A' 0:+ ,.i. Barrels (bbl) per year
th n 455$ UOooF Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating = Barrels (bbl) per year
Requested Monthly Throughput= 217,000.00 Barrels (661) per month
Potential to Emit (PTE) Condensate Throughpu
,polio Barrels (bbl) per year
Secondary Emissions - Combustion Device(s) waste gas combustion
c 7- ,37
Heat content of waste gas=t4058'7;3s Btu/scf
Volume of waste
gas emitted per BBL of liquids
produced = 1.11 scf/bbl
Actual heat content of waste gas routed to combustion device
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Secondary Emissions - Combustion Device(s) pilot
scfh
Pilot Volume to ECD= „t 14- MMsd/yr
Pilot Fuel HHV=`i'a 1038 btu/scf
Requested heat content of pilot fuel routed to combustion device =
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
0 MMBTU per year
03,110 MMBTU per year
33,110 MMBTU per year
1,504 MMBTU per year
Pollutant
IMMEMEINIM
Pollutant
IMMEIMM
Pollutant
Uncontrolled
Controlled
(16/661)
(16/bbl)
(Condensate
Throughput)
0.1990
0.0031.
0.0013 '..
0.0002
0.0003
0.0000
0.0000
(Condensate
Throughput)
0.0100
0.0002
0.0001
8.92E-06
Emission Factor Source
0.0000
0.0000
Control Device
Uncontrolled Uncontrolled
(16/MMBtu)
(waste heat
combusted)
(16/661)
0.0075
,1:2-4^f, 0.0075
0.0680:
ifegt-6.31001 ",,.
(Condensate
Throughput)
Control Device Pilot
Uncontrolled Uncontrolled
(Fuel gas
combusted)
0.0075 ' ,61.':'
0.0075
0.0680
0.3100
(Fuel gas
combusted)
Site Specific E&P Tank W onimg and Breattnn: {
Site Specific E&P Tank Working and Breathing'O
Site Specific F&P Tank Worbiag and Breathing 0,
Site Specific I&P Tank Working and Breathing On
Site Specific E&P Tank W oeking end Breathing 001
Site 5pg4)ic E&PT gjEW tp and Breathing. Ohl
Site 5)IHc E&P T_ „, "&hd Breathing 0
Emission Factor Source
Emission Factor Source
Section 05 - Emissions Inventory
This MMbtu/yr includes gas from loadout. Since emissions from loadout
are balanced back to the storage tanks and subsequently to the
combustor, the applicant prefers toaccount for combustion emissions
resulting' from loadout vapors and tank vapors with this point (Point 022). '..
Values calculated in E23 are doubled since the source is conservatively
assuming the same gas flow from loadout as tanks. See email 3/26/19.
Potential to Emit
Actual Emissions
Requested Permit Limits
Requested Monthly Limits
Criteria Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
Controlled
(tons/year)
(tons/year) (tons/year)
(tonsjyear) (tons/year)
(lbs/month)
VOC
254.2
0.0
0.0
254.24
12.71
2159
PM10
- 0,1
0.0
0.0
0.09
0.09
16
PM2.5
0,1
0.0
0.0
0.09
0.09
16
NOx.
0.8
0.0
0.0
0,54
0.84
142
CO
3,8
0.0
0.0
332
3.82
648
26 of 42
K:\PA\2017\17 W E1090.CP2.xlsm
Condensate Storage Tank(s) Emissions Inventory
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
7896
0
0
7896
395
3384
0
0
3384
169
455
0
0
456
23
640
0
0
640
32
0
0
0
0
0
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section Xil.C, D, E, F
Storage Tank is not subject to Regulation 7, Section Xll.C-F
Regulation 7, Section )(ILO, C
Storage Tank is notsubject to Regulation 7, Section 811.5
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage Tank is not subject to Regulation 7, Section XVll.C.2
Regulation 6, Part A, NIPS Subpart Kb
Storage tank is subjectto NSPS Kb
Regulation 6, Part A, NIPS Subpart 0000
Storage Tank is notsubject to NSPS 0000
Regulations, Part E,MACT Subpart HH i
Storage Tank is not subject to MACF HH
(See regulatory applicability worksheet for detailed analysis)
Section 07- Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company use a site specific emissions factor to estimate emissions?
If yes andif there are flash emissions, are the emissions factors based on a pressurized liqud 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 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 based on guidelines in PS Memo 05-01.
Does the company request a control device efficiency greater than 95% fore flare or combustion device? ;k r
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 Analysts Notes
n(Riitlallytfferd are Issueswith undetermined tank configuration. A comp) cation that arses is thatthere's different State and Federal rule app l cab lity: (:specifically section XII) depending on the type of liquid stored and the relative em sobs ['..
of each tanh" (each group of liquid manifolded vessels).Furthermore, if the vessels: store different liquids, the throughputs are distinguishable and likely measured separately. -In email 3/1/19 they indicated that all will be manifolded
together and all will stare stabilized condensate.
*Since these storage vessels are greater. than 475 bbl (75 m*3), and furthermore, greater than 950 bbl (151m^3) and store a liquid with a: max true vapor pressure greater than 3.5 kPa'(0 5 psi), this tank is subject to NSPS Subpart Kb. For
vessels greater than 950bbl, those storing liquids with maximum true vapor pressure greater than 0.8 psi are subject to control requirements: This vessel will comply with NSPS Kb by use of a closed vent system and anenclosed combustor.
The EPA has indicated (ADI 0000019) that en enclosed flares not the type of flare that is regulated by the open flame flare specification at 40CFR Part 60 Subpart A, 60.18(b) through', (f) and therefore this device is not a flare. As such the
operator shall meet requirements for"control device other than aflare" in 10.113b(c). Section 60.113b(c)(1) indicates that the operator shall submit for approval by the administrator an operating plan. Based en internal dscussion, it has
been determined that compliance with the approved O&M plan for this point will onstitute an approvable "operating plan" per this section. As such, the operator filled out and submitted, as an attachment to the O&M plan for this point, a
questionnaire indicating that the O&M plan will act as the operating plan required.
Applieant used E&P Tank ,
to calculate working and breathing losses.
*I did not confirm the stabilized oil composition that was used as input to E&P tank, however, i instead ran EPA TANKS using gasoline RVP 10 as the stable oil composition(process description indicates that stabilizer will be designed to
produce a stabilized condensate product. with RVP 9). The' ,0C/b 7 )oduced by the TANKS simulation was less conservative (0.07516/bbl) than the value calculated by the applicant using E&P Tank (5.199 lb/bbl), so I will accept the
E&P Tank run submitted by the applicant.
c r rn
Section 09 - Inventory 5CC Coding and Emissions Factors
AIRS Point#
022
Process #
01
SCC Code
Uncontrolled
Emissions
Pollutant Factor
PM10 0.00
PM2.5 0.00
NOx 0.02
VOC - 4.7
CO 0.07
Benzene 0.07
Toluene 0.03
Ethylbenzene 0.00
Xylene 0.01
n -Hexane 0.00
224 TMP 0.00
Control% Units
O lb/1,000 gallons condensate throughput
0 lb/1,000 gallons condensate throughput
O 16/1,000 gallons condensate throughput
95 1b/1,000 gallons condensate throughput
O lb/1,000 gallons condensate throughput
95 lb/1,000 gallons condensate throughput
95 lb/1,000 gallons condensate throughput
95 lb/1,000 gallons condensate throughput
95 lb/1,000 gallons condensate throughput
95 lb/1,000 gallons condensate throughput
95 lb/1,000 gallons condensate throughput
27 of 42
K:\PA\2017\17 W E1090.C P2.xlsm
Condensate Tank Regulatory Analysis Worksheet
Colorado Regulation 3 Parts and 8 -ADEN and Permit Requirements
'Source Is In the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater then 2 TPY (Regulation 3, Part A, Section ll.D.1.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1,12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.2.3)?
You have Indicated that source is In the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than )TPY(Regulation 3, Part A, Section ll.D.1.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See P5 Memo 05-01 Definitions 1.12 and1.14 and Section 2 fofadditional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5TPY or CO emissions greater than 30 TPY (Regulation 3, Part B, Section 11,0.2)?
(Source requires a permit
Colorado Regulation 7, Section XII.C.F
1. Is this st0m00tank located in the B -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station?
3. Is this storage tank located upstream of a natural gas processing plant?
'Storage Tank Is not subject to Regulation 7, Section 011.0-F
Section 011.C.1 —General Requirements for Alr Pollution Control Equipment —Prevention of Leakage
Section XII.C,1—Emission Estimation Procedures
Section )(ILO —Emissions Control Requirements
Section RILE —Monitoring
Section %II.F—Recordkeeping and Reporting
Colorado Regulation 7, Section XII.G
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non-attalnment area or attainment/maintenance areal
2. Is this storage tank located at a natural gas processing plant?
3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than prequel to 2 tom per year VOC?
'Storage Tank is not subject to Regulation 7, Suction %11.0
Section 111.0.2 - Emissions Control Requirements
Section XII.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
section Xii.C.2—Emission Estimation Procedures
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressorstatlon'or natural gas processing plant?
3. Is this condensate storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions° of this storage tank equal to or greater than 6 tons per year VOC?
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & 1.3
Section 0011.1 —General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section.XV110.0 -Emissions Control and Monitoring Provisions
Section XVILC.3 - Recordkeeping Requirements
5. Does the condensate storage tank contain only "stabilized" liquids?
'Storage Tank is not subject to Regulation 7, Section XVIl.C.2
Section XVII.0.3- Capture and Monitoring for StorageTank5 fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the Individual storage vessel capacity greater than or equal to 75 cubic meters (m5)1-472 BBB)?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589,874 m5 [-10,000 BBL] used for petroleum' or condensate stored,processed, or treated prior to custody transfer' as defined in 60.111b?
3. Was this condensate storage tank constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1904?
4. Does thetank meet the definition of"storage vessel"' in 6D311b?
5. Does the storage vessel store a "volatile organic liquid (VOL)"s as defined In 60,1110?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate In excess of 204.9 kPa [^29.7 pal] and without emissions to the atmosphere (60.110b(d)(2))?; or
b. The design capacity is greater than or equal'. 151 m5 [-950 BBL) and stores a Squid with a maximum true vapor pressures less than 3.5 kPa (60.110b(h))?; or
c. The design capacity is greater than or equal to 75 M5 ("472 BBL) but less than 151 ma (-050 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110bib))?
'Storage tank is subject to NSPS Kb
Subpart A, General Provisions
960.1120 -Emissions Control Standards for WIC
960.1130 -Testing and Procedures
§60.1130 - Reporting and Recordkeeping Requirements
§60.116b - Monitoring of Operations
40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production. Transmission and Distribution
1. Is this condensate storagevessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was [Ms condensate storage vessel constauetttl, rde0111Lfuocod, dimbdifcd(see definitions 40 CPR, 00.2) between August 23, 2011 and September 30, 2015?
3. Are potential VOC emissionsfrom the Individual storage vessel greater than or equal to 6 tons pet year?
4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430?
5. Is the storage vesselsubiectto and controlled in accordance with requirements forstora a vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Sob art NH?
'stomgetank is not subject to NSPS 0000
[Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tonsper year VOC on the applicability determination date, It should remain subject to NSPS 0000 per 60.5666[e)[2) even
if potential VOC emissions drop below 6 tons per year]
Yes
Yes
Yet
ikitEAVA
Yes
Source Requires an OPEN. Go to the nett question
Go to next question
Source Requires a permit
Continue - You have indicated the site attainment status on the project summary sheet.
Storage Tank is not subject to Regulation 7, Section XII - You have indicated the facility type On the project summary sheet.
Continue - You have determined facility attainment status on the Project Summary sheet.
Go to the next question -You have Indicated facility type on project summary sheet.
Storage Tank Is not subject to Regulation 7, Section 311.0
Continue You have indicated the source category on the Project Summary sheet.
Go to the nett question -You have Indicated facility type on project summary sheet
Gone the next question
Source Is subject to parts of Regulation 7, Sections XVII.B&C. Go to the next question
°a' yitatorage Tank Is not subject to Regulation 7, Section )0/11.0.2
Yes
mew
Go to the next question
Go to the nextquesticn
Go to the next question
Go to the next question
Go to the next question
Source Is subject to NIPS Kb
Continue - You have Indicated the source category on the Project Summary sheet
Storage Tank is not subject NSPS 0000 -This tank was constructed outside of the gp?licgblllty dates.
40 CFR, Part G3, Subpart MARHH. Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR
b. Afacility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or Is delivered to a final end user' (63.760(a)(3))i
2. Is the tank located at a facility that Is major' for HAPs?
3. Does the tank meet the definition of "storage vessel"° in 63.7617
4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"'per used ?
5. Is the tank sublet[ to control requlrements under 40 CFR Part 60, Subpart Kb or Sub art 00007
IStnraee Tank Is not subject to MAR HH
Subpart A, General provisions per 463.764 (a) Table 2
§63.766- Emissions Control Standards
§63.773 - Monitoring
§63.714- Recordkeeping
§63.775 -Reporting
RACT Review
PACT review is required If Regulation 7 does not apply AND if the tank la in the non-attalnment area. If the tank meets both criteria, thee review RACT requirements.
Disclaimer
This document assists operators with determining applicabllity 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 binoing 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 °ecommend, "may, 'should,' and-can,"is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" em 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
(Yes 'Continue- You have Indicated the source category on the Project Summary sheet.
Storage Tank Is not subject MACT HH - There are no MACE HH requirements for tanks at area sources
Hydrocarbon Loadout Emissions Inventory
023 Liquid Loading
Facility AI Rs ID:
123 ,`9F6i - 023
County Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Collection Efficiency:
Control Efficiency:
'Loadoitotstabilhed condensate to tanktrucks by submergerffill..
'):be]osed combustor
Requested Overall VOC & HAP Control Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded =
Requested Permit Limit Throughput =
Potential to Emit (PTE) Volume Loaded =
oo
95.00
Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating=
'""2;555;000 Barrels (bbl) per year Requested Monthly Throughput=
217000 Barrels (bbl) per month
2555,000 Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per year =
Actual heat contest of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
0 Btu/scf
0 scf/year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04- Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Does the hydrocarbon liquid loading operation utilize submerged fill?
Barrels (bbl) per year
Combustion ernissionsare included with Pont 022 Since missi nsfrareftmlanced
back tathe t g to ks and subsequently tq the cmbust r„the applint pr fes4"o
0 MMBTU per year accou"ntfor combustion emissions re Itmgfrom'loadoutvapdkswth tkie stoY geyta %
0 MMBTU per year ttt fission p int (Point 022).
0 MMBTU per year
The state default emissions factors may be used to estimate emissions.
131213
Pollutant
MIIEMEINIM
Pollutant
Hydrocarbon Loadout
Uncontrolled
Controlled
(Ib/bbl)
(lb/bbl)
(Volume
Loaded)
(Volume Loaded)
4.10E-04
0.00E+00
0.00E+00
0.00E+00
3.60E-03
0.00E+00
Uncontrolled
Control Device
Uncontrolled
(Ib/MMBtu)
(Ib/bbl)
(Volume
Loaded)
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
(waste heat combusted)
•: r,,tiA00s
1680 r...,94a4;
Emission Factor Source
Emission Factor Source
Section 05- Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
sOx
NOx
VOC
CO
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
000
0.00
0
0.00
0.00
0.00
0.00
0.00
0
301.49
0.00
0.00
301.49
15.07
2561
0.00
0.00
0.00
0.00
0.00
0
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
rt-Hexane
224 IMP
1048
0
0
1040
52
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
9190
0
0
9190
400
0
0
0
0
0
30 of 42
K:\PA\2017\17 W E1090.CP2.xlsm
Hydrocarbon Loadout Emissions Inventory
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
RACE- Regulation 3, Part B, Section III.D.2.a
(See regulatory applicability worksheet for detailed analysis)
The loadout must operate with submerged fill and loudest emissions must be routed to flare to satisfy RACI.
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company request a control device efficiency greater than 95%for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 05 -Technical Analysis Notes
Section 09- Inventory SCC Coding and Emissions Factors
AIRS Poing #
023
Process#
01
SCC Code
4-06-00132 Crude Oil: Submerged Loading Normal Service (S=0.6)
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons transferred
PM2.5 0.00 0 lb/1,000 gallons transferred
SOx 0.00 0 lb/1,000 gallons transferred
NOx 0.00 0 lb/1,000 gallons transferred
VOC 5.6 95 lb/1,000 gallons transferred
CO 0.00 0 lb/1,000 gallons transferred
Benzene 0.01 95 Ib/1,000 gallons transferred
Toluene 0.00 95 Ib/1,000 gallons. transferred
Ethylbenzene 0.00 95 lb/1,000 gallons transferred
Xylene 0.00 95 lb/1,000 gallons transferred
n -Hexane 0.09 95 lb/1,000 gallons transferred
224 IMP 0.00 95 1b/1,000 gallons transferred
31 of 42 K:\PA\2017\ 17WE1090.CP2.xlsm
Hydrocarbon Loadout Regulatory Analysis Worksheet
Colorado Re: ulation 3 Parts A and B -APEN and Permit Requirements
Source is In the Non.Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY (Regulation 3, Part A, Section 11.01.0)?
2. la the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part F3, Section 11.0.1,1)?
3. la the loadout operation loading less than 10,000 gallons (238 BBIs) of crude oil per day on an annual average basis?
4. la the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. la the loadout operation loading less than 16,308 bib per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions greater than 5TPY, NOxgreaterthan l0TPY or CO emissions greater than 1OTP? (Regulation 3, Part B, Section 11.0.3)?
You have indicated that source is In the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from thls Individual source greater than 1 TPY (Regulation 3, Part A, Section I I.O.I.a)?
2. la the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part 0, Section 110.1.1(7
3. Is the loadout operation loading less than 10,000 gallons (238 His) of crude oil per day on en annual average basis?
4. la the loadout operation loading less than 6,750 bbls per year of condensate As splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate vle submerged fill procedure?
6. Are total facility uncontrolled VOC emissions from the greater than 2TPY, NOY greater than 5 TPY or CO emias(ani greateTthan EQTPY (Regulation 3, Part O, Section 110.2)?
(Source requires o permit
wOM
Ye
Go to next question.
Go to question 6
The loadout requires a permit
RACT-Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part 8, Section III.D.2.a)? AWN The loadout must operate with submerged fill and loadout emissions must be routed to control to satisfy RACT. If not controlled, a RACT
IThe loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACr. analysis Is required and provide discussion in Section e.
Disclaimer
This document essists operatom with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
note rule or regulation, end the analysis if contains may not apply to a pertioulersifuelion based upon the individual facts end circumstances. This document does not change or substitute for any law,
regulation, oreny 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"recernmend,""may,""should,"and"can,"is
intended to ddsdrlbe APCD Interprotaflons and recommendations. Mandatory tarnvnology such as "muse and "required' ere intended to describe oonfrelling requirements under the terns of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of ffself.
Condensate Storage Tank(s) Emissions Inventory
017 Methanol Tank
Facility AIRs ID:
County Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency%:
One(1) 750 bbl methanol storage tank
No control
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions- Storage Tank(a)
Actual Condensate Throughput=
Requested Permit Limit Throughput = TI ' 8872; Barrels (bbl) per year Requested Monthly Throughput= 754 Barrels (bbl) per month
Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
Potential to Emit (PTE) Condensate Throughput
0,072Barrels (bbl) per year
Secondary Emissions- Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquids
produced= � ' scf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Etu/scf
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04- Emissions Factors & Methodologies
Will this storage tank emitflash emissions?
MM BTU per year
MMBTU per year
MM BTU per year
Pollutant
Pollutant
Uncontrolled
Controlled
(lb/bbl)
(Ib/bbl)
(Condensate
Throughput)
X0.112;;71
(Condensate
Throughput)
Emission Factor Source
Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu)
(waste heat
combusted)
(Ib/bbl)
(Condensate
Throughput)
0.0000
0.0000
0.0000
0,0000
Emission Factor Source
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/Year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
0.50
0.00 I 0.00
0.50 I 0.50
84.67
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)
Methanol
997
0 I 0
997 I 997
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVILB, 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 Kb
Storage tank is subject to NSPS Kb, based on TVP less than 4 psi (27.6 kPa), only subject to recardkeeping per 60.116b(d)
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation 8, Part E, MACTSubpart HH
Storage Tank is not subject to MACF HH
(See regulatory applicability worksheet for detailed analysis)
Barrels (bbl) per year
NSPS Kb "Maximum True Vapor Pressure" determination
(based on Antoine Equation Parameters for Methanol as found on NISTwebsite: https://webbook.nist.gov/cgi/cbook.cgi?ID=C67561&Mask=}&Type=ANTOINE&Plot=on
For T range (288.1K to 35611)
A
C
Source
Ambrose and Sprake, 1970
Log(P) = A-(B/T+C)
5.20409
1581.341
-33.5
T(deg F
T (deg C)
TVP (bar)
NP (psi)
294.2611111
0.137962687
2.000983223
'.1748
296.4277778
0.154787177
2.245002263
,,,..M,I 410
296.4833333
0.155240674
2,251579693
... %D
297.0388889
0.159838523
2.318265972
-T80,0
299.8166667
0.184615371
2.677624424
For purposes of Kb, maximum NP is defined at the local maximum monthly average temperature as reported by NWS for VOL's stored at ambient temperature
July average temperature per NWS
https://w2.weather.gov/climate/index dhp?wfo=bou
2014
74.5
deg F
2014
71.6
deg F
2015
72.8
deg F
2015
72.9
deg F
2016
76.2
deg F
2016
75.0
deg F
2017
76.4
deg F
2017
75.5
deg F
2018
75.3
deg F
2018
74.4
deg F
5 yr AVG
75.0
deg F
5 yr AVG
73.9
deg F
Denver
Greeley Airport
33 of 42
K:\PA\2017\17 W E1090.CP2.xlsm
Condensate Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
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 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 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? 1. _
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 #
024
Process # SCC Code
01
nd isonlyAPEN required
Uncontrolled
Emissions
Pollutant Factor Control% Units
VOC 2.68 0 lb/1,000 gallons condensate throughput
Methanol 2.68 0 lb/1,000 gallons condensate throughput
34 of 42 K:\PA\2017\17WE1090.CP2.xlsm
Condensate Tank Regulatory Malysls Worksheet
Won. ...Ion 3 Pam a and a -PPM and Pam. Raqu Irnmrens
IB""ro 6lnuevon.nnea
ATTAMMENT
1. 333 unconlaolled actual emission from env criteria pollutants horn thI$Ind3iaualsourca greater than 2TIN (Peaalation 3, Part3acuon ll.p.l.a4?
am (sea,,aa data)ar..12/30/2002 and notmadinea arter13/iLmu233Psanemou2moannmma LuanaLta and section 2mradeatonal guidance on aranaraNu applkabmryl?
3. ketam fadnw umonoollm VOCem6ebm 33 areas, en5TPr,NO. grevmNan10T,moOembsbnsgreer,2an 'tart lReg.laton3. PartB,actlaa1233l?
Inotonoughdamadml
NONAITAltaaala
L Araurcad¢lkdembswm fromonyame3a pollusn¢ from Nisin0N103313 mugrearermanl177 ar37?333e Iva gradeanan25olb/wlxuulamn 3,PattA,xcb'on ILD.13)?
Isthe constmctlan date(service data) prior ref2/30/2003 and not mdllled after l2/31/2m2(See PS Mama 05moelinitlom 112and1.la and Sea. 2 far additlonalguidance on gradfa*er applbab*w)?
3. /Val.! Wiry uncontrolled VOC ernasIons from Ne greater man al, 2102 greater than s ITV 2,0emmlons greater than SI, IReaulaeon 3, Pan B,smtlon lln.212
urcocmtu
Cobra. Ragulalon?, Soseton nll.e
Is ails storage tank loam. In the 8 -hr ozone tonal area or a me 22one n on-analn montane or attalnmen timainaenence area?
2. Istlds storage ankle.. eta nanral gas pnweasingphnt?
3. Dow Ws storage tank exhilattailas,leg.svrinanon-sabnbm rau tlsl embsbns and have uncontrolled actual emissions geeate'nan or equal m 2 tans per veer VOC2
IStararta tank Is aublatt1273nuado3*333tonwl.G
Sed1onM.G.,-Embslons Control Requirements
sa¢lonmu - General Peouiremen¢for.VrPoluo'on Central Equipment -Prevention afLeakage
Sanlanal.C2-ElWsbn Estlmatlan Procedures
1 Is. calk located ata transmkalanistoragehrllay?
conk )ore oration analprodumon operation. wet production f:piry',natural gas compressor smbn'ornatualgap Ingpbn,a
3. Is331 swagefanka need roof storage tank,
a. Me uncanirollad actual embsloni oftM112202rage tank equal to ar yeateran 6 tole per year VOC2
131aragrra. k not auaaaxto#amation7, saeianxvn
Section ka.2 -General ProvislonslorNlr Pollution CoadalEuuipmentand Prevention ...Ions
and Monimdng Provlsbns
Section %V ILC.3 • RsoMkeeping Requirements
3 ones e' onN'svbtued'tuaT,
sectionIMI.C2-Capare and 2422.0,00r for storage Tanksfled with Pk Pollutbn Control Equip ant
40 CFR Part.. subvert lan standards of or dLP. v le onank Lboraeavessata
the idIvl2ua storage avessel rapacitygr3 *31 than of3gml to75 Cubic meters (m'l l'4RSaLq,
2 Does thesmrap vessel meetme rolowing eu,p* Is6O.111b1d)141?
pad27less than area. mi.s®ar4m'1-10,a[D BBL]used for petrokum' orcmrdersate slorei.processed. or Ovate.] prior m osmdv transfer a denied In 2D.tub2
3. Was ta condemn. storage tankconstructed, etucted, ar ma tuned (s2* dean loons fro CFR, 60.21 altar l u w 23.2084?
a. Des Ile tank meetthedetlnidon or,tarapp vessel' In 60.112222
5. Dees thestarage vessellsmre a Nolahae prganbliqub (V002' ea defined In 60.1llb?
6, aNeatorage vmserneetany one ofne(clawing addldonateumptlans:
storage .rB.T psg and v3Nautembslmhs to the aNnspherel*o.110b1212p?:or
a The design capeaN is wester than rwual tosslm'I-930 BBL) and storm a lipoid with a mfrximumtruevaporyressurea lass Pa l6o.uablb111; or
apaCny nssrthanormueto25M3N./23B0bm1ms than331m'I-gs3B0L1 and storm a 11221210a maximum we vapor pressure` less thani30k2at6332eb(np2
I storage tankisaulgaetto mPS gb, Lau. an7Plm3 Lan 33n1226 kpal,ontvsubiaa to recardkoecne Ler®usa9
oral Provinons
4 W SiH- Monlm Ma of 3 peratlons
40 cog, Part 60. Subpart 3000, Standards of Padomlancetar Crud* oil arid Natural Gas Prmualen. Tanamlalon and Ma IAu .
Sao
Vas
stora,.nkh nataubjeam fle2tilatian 2,sectionrvll
es
Isiblz condensate storage vessel located ata adllty trine onshore oh anti natural ',production segment naval gas proaessbgsegmentoaatural gatransmbsbn aria storage segmentot theindastry2 +_. Continue- Youhaw vbeard Ole some rasow on the Pye:tswnm313Aces
Was Vs condensate storage vessel constructed, reconstructed, or mod.. (see tie nab'ons a0c2,2,60.2) 601) betswen August 23, 2032 and September 1&20132
3.Am potentbl VOL emisons' from the Individual storage vessel greeter Nan or equal to6 Cons per year?
a. Does 2M16 condensate stoats vessel meet the definition or esmrage v3s3P' per 6034302
5. Isbasbaragevassal subjeatto ancl contra. In accordancewdthr ulremm¢forstora vmseh M m CFR Part60Submat Kb on4oaR Part63abpart ml.
Ise
Subpart 0, there] Provjslons per 462.5425 Table
4503393- Emlasbns Control Standards far VCC
§603413-Tesdna and Procedures
§tasa3Na)-1atlnutlon,Repar3ng and Reaordkeeping Requirements
460sa1ycl-c MonlCodna Rmutrements
46038 Device Monitoring Feaurrremen¢
pear lg a stares* vaa.sta peNuwy 633367ned to basupaeteran OODoduataaniwansaboebtansparwrVOContheapplivbilkydataMMFon data, arhwM ramainvbfestm N3233000 per 6033¢3(8)12) awn
if pore natal 'MC ambsbm drop below u tons peryar]
fro cog, part 63,Subpart WO' Nit aB andma Production FacilNas
Isge storage tank btttea at an on and natuatga production facia hatrreets either ofthe following craerb:
a. A (baby Natprocmam, upgredes or storm hydrocarbon Nulds' Is336ob3211 OP
sonors.., upgraorsm ratualga prhrm wnba aantatnearal gas enters the natural gas eaamissian and storage source category oats demerea toe and tors end '133.26IXeN311?
2 1221e tank located' a facility matlsmater forNnn2
3. Don the tank meet the dean ltlon of 'storage vessel.' In 63.2612
a. me: mrmneet e deal.,omtaraaveasel with the potential for llasltentsslons''per
61.
S. Is the tankm sula entoutrcmen¢ under 4RPart60.6ubpartaborsub .00070007
lstn 2*net 2
Subprt General pray on: par §63.264 del 2013122§.3.5pEmbsbns Control Standards
§63.Tra-MONmdng
ordkeeping
§63775-R porting
MR Realm
RaR rwkw fs=Mr.. n Regulation does not.. AND inn. tank is inxna non-anain,nonx area_ It,. tank moots bah criteria, then Ionic. Pact requjromanu.
Ms document assists ope2lws yfith determiningappliwbilAy of cochin requ0emenls oflhe Clean ANAc1, ifs Implementing regi*Bans, and AirOualffy Conlrol Comnnssbn r600H(bns. Thistlaument
is not a rubor and the analysis2 contains mayml appy to a parlku/3,300a4an bay. goon the Individual facts and cimumslanca3. T. documentdeas not change or subsflfule for any
Iaw.Loo,..pn, or anyo11w1egallY..proVuirementar I is MEkgD'yen/ tole 7018 evept o'anYuonM1'st beluren lhelargvdre thisdocunvnt andlhe kmgrageof6x C*a2 Air Act, its
implemenfingregvbliara, aM A310530y Control mg..x,lhebrnpapao71he3aivle°tn...ibn vonconro] The used n.n*Maloybnpap3 snchas'rsanvre,,"may.•
'shoud; aM'ren,' Is inte7edtodescrlbe AM) lnregrelalgns antlremmmsld3*tins. Maro'atorylemdgobpy so. aa'm.W'.M'requiterPa2lMeMedlocbunLeconlmlling 2qul2rrenls under
Vac terms of the Clean Alr Ada, d Alr Quality Confml Commh'sbn. mgydal0ns, but Nis dccurrantdow not establish kgellybindh9,equueman(s Mande, ita
t
a' -'d19 naa
Iron rannnua-You haw baanesesaraeuxaowanne,aLLS tummy IaeL
Hydrocarbon Loadout Emissions Inventory
Section 01- Administrative Information
Facility AIRS ID:
123
County
9F67
Plant
025
Point
Section 02- Equipment Description Details
Unloading of condensate from pressurized tonics to pressurized tank trucks. Loadout occurs via vapor balance and emissions are
Detailed Emissions Unit Description: only released to the atmosphere during hose disconnect.
Emissions tram this source are not controlled.
Emission Control Device Description:
Is this loadout controlled?
Requested Overall VOC & HAP Control Efficiency %:
0.00
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Truck Loadout Capacity
30000 gallons/load
2,555,000.00 hbl/year 107,310,000
(Load outs/year
Loadouts/month
10,731.00 loadout/year
911.40 loadout/month
Section 04- Emissions Factors & Methodologies
Loadout Hose Parameters
Liquid Hose Diameter
0.25
feet
Vapor Hose Diameter
0.17
feet
Liquid Hose Length*
-
1.10
feet
Vapor Hose Length*
200
feet
Liquid Hese Volume
0.0736
cubic feet
Vapor Hose Volume
0.0436
cubic feet
Tank and Truck Pressure
Tank and truck pressure
49.8
62
PV=nRT
Where:
P = pressure in hose at time of disconnect = storage tank pressure (psia)
V. volume of hoses (cubic feet)
n = number of lb -moles of product in hoses
R = Universal gas constant =10.73 ft03 * psi / Ibmole / degR
T = average loadout temperature = 60 V = 519,670
Vapor Density
0.003485156
0.011118964
Ihmol
Ihmol/ft^3
n/V
MW
12,1
Ib/Ibmol
Ib/ft^3
Vapor Density
0.134650653
Notes:
1. All liquid lines contain liquid products at Individual specific gravity.
2. All vapor return lines contain products that behave as ideal gases at 60'F and storage tank pressure.
Uncontrolled VOC Emissions:
Vapor Emissions
63.05
Ih/year
0.03
spry
Liquid Emissions
23,190.47
lb/year
11.60
spy
Requested Total
11.63
tpy
MMBTU per year
MMBTU per year
Liquid Density
Liquid Density) 3.9237967911lb/gallon
29.35 lb/ft^3
5.35 lb/month
1,965.60 lb/month
Component
Mass Fraction
Source
Benzene
0.0as%
RepreseotativeSample (See Section
0afornotes)
Toluene
0.042%
Representative Sample (See Motion
War notes)
Ethylbenzene
0.007%
Representative Sample (SeeSection
08 for notes)
Xylene
0.009%
Representative Sample (See Section
06for notes)
n -Hexane
0.841%
RepresentatiVeSample (See Section
Oafor notes)
224TMP
9,000%
Representative3ampie (See 5ect050
oEfor notes)
0.98747792 total tons per month
36 of 42 K:\PA\2017\17W E1090.CP2.xlsm
Hydrocarbon Loadout Emissions Inventory
Pollutant
Hydrocarbon Loadout
Uncontrolled
Controlled
(lb/loadout
event)
(lb/loadout event)
(Volume Loaded)
(Volume
Loaded)
Emission Factor Source
2.1669E+00 MSEMEFs
a
MEMIEME 9.20E-04 IMMEI
IMMINEEMEMIll
SliEEIZIMIIIM
1.49E-04
2.00E-04
49E-04
Pollutant
1.00E-05
2.00E-04
00E-05
Control Device
Uncontrolled
(Ib/MMBtu)
Uncontrolled
Ob/bbl)
(Volume
Loaded)
0.00E+00
0.00E+00
0.00E♦00
0.00E+00
0.00E+00
(waste heat combusted)
mmmoni'7/
Emission Factor Source
liTes
Section 05 - Emissims Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
{tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
50x
NOx
VOC
CO
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.W
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
11.63
11.63
11.63
11.63
11.63
1975
0.00
0.00
0.00
0.00
0.00
0
Hazardous AG Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
Obs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/yearl
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
20.67
20.67
20.67
21
21
9.88
9.88
9.88
10
10
1.60
1.60
1.60
2
2
2.15
2.15
2.15
2
2
195.49
195.49
195.49
195
195
0.11
0.11
0.11
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, PertsA, B
RACT- Regulation 3, Part B, Section III.D.2.e
(See regulatory applicability worksheet for detailed analysis)
Source requires a permit
Tim loadout operation must satisfy RACT.
Section 07 - Initial and Periodic Sampling and Testing Requirements
You have indicated above the source is not controlled. The following question does not require en answer.
Section 08 Teicpnical Analysis Notes
The moleculailrelgh[ ftheg , densitttofth Ifq dend'mass fractions of HAPsused to estnietetheHAP missions were btarnedfirom representatve modeling. Compost oval data were obtained r om the permit applcation
•
18WE1052 for CitfelOnlaiwarby Tampa Compress or Station. The Tampa facility accepts pressur zed NGL (potentially from Front Range Gas Plant) and injects it into an NGL pipeline.
.txeszrxs,:
'This is a new ourcetame'.into senticeafter 11;20/071 located in the ozone non attainment area As a result this sources subject to RACE. Based on mf rmation provided, the loadout operation transfers fluid from pressurized
range vessels to pressurized tank trucks. As the icadout operation. conducted, the vapors displaced from the pressurized trucks is routed back to the pressurized storage vessels Asa result, emissions only occur when the liquid
and vapor hoses are tlsconnected after completion of the loadout operation. Based on this information, the operators using vapor balance with pressurized vessels.Thismethod of op at ons sansf es RAC+
Section 09 - Inventory 5CC Coding and Emissions Factors
AIRS Point
025
Process ft SCC Code
01
Uncontrolled
Emissions
Pollutant Factor Control% links
VOC 2.17E-01 0 Ih/1,1700 gallons transferred
n -Hexane 1.82E-03 0 lb/1,000 gallons transferred
37 of 42
K:\PA\2017\17 W E1090.CP2.xlsm
Flare Emissions Inventory
Iraraoramm, cnanr,
Volume of gas:
Ilea Content of Vs:
Requested volume &gas:
0Aluel volume of gas:
Requated heat content
onto, ohrous000O
Requested purtetppot
mad/year
o Mse/nar
t.nse 00.4753/lean
1759.4 MMewkur
Benuelted Pup..
Requested Not Gam
Purge/Pllot Gas LIMA
16,30
MW.
mu/se
Volume of gss:
Heat Content of gas
liegliWed volume of
RaA
Actual volume of gm:
PTEvalume oft=
ooquoaoctooat
G.zmes MMotu/nr content ol3as.
1.53636 MMscf/month
did
nos
M",,,,,,90.0.04,
n.00
lInn
AOn
TWene
.;raaeuux
MN
600
0.00
An0
045
,
,n000-000nototrx
00405moo
mo.
ono
oo
ro+nlwe
«eit
Goa
1w30
3v
Factors for Allot and Rum Gas 10esaue Ass mmponnoni
Ern.. iattors Plant lant
Uncordcolled rolled
m t Fd/Mm><+1 I4/mmrel
IGu
Crne. Pollutants
PINIO
fOx
VOL
CO
I ,003 0w
0,7
0 97
0.53
Paten. to Emit
Uncontrolled
ReoneStg:rocZY Limits
✓00051
GUoa+k0arll 0oo,k .00
0.07
0.07
1370 scf/hr
HES
000
OM
000
a
{
{ n.t,nuevA
n .nmau
ono
0.00
non
MOO
OM
0.00
xoenn
MONOMmli
00xenne
Osgmtiosooft
ow
Dap
0.00
TGruwG
F,N,, y ,
007
1vn.vu
norz
ArA
0.07
0.63
001
0.01
NA
Hazardous Air Pollutants
BIMICAU
Etnylmvene
X one
pan., tonna
Itonsknrl
Uncontrolled
IumMrrl
Controlled
Requested PernutUmIts
Uncontrolled dim
0.
0.
0.
0.
19 °IQ
Flare Emissions Inventory
Section m- gegumon summa m nn
Regulation
Sect. IIAS combo..ofwastenaeaabal anewmausee.mlwokmtoM aatmomnerteGases eornr.13wiutant.smokeless e sslao33ozaanvmma the
Ilegulatton
w.utatrnna
SectIon -No persc.n.whereverlaated.shall caoseoraltow the emission rotator., a, cont.... from an,lngle =mould, as tore..
In detectelieodors.ch are measured In excess of thefollowIng Wks: For areasused pretlomlnently for resklentLal or commercial purposes
Ube violation Valorsare detected after theadorous grhas been diluted with seven or mem volumes°, odor! roe
Crderld Pollutant. roe anmaae te. pollUtants. Pk Pollutant Ern.lon NotIca are required for: moll m
area mmwm nronemnn vearor more or vmn NO., pollutant not summed, for. tile area's Andbetbrenwrtredmma•eAPEX atm. ems>nme reed non oerrearme
pan Applunt Isrequ edt obbtnae permft since uncontrolled vae emission from Ws.. Ytyam:grerm dm theztp threshold laq.,Parte,
sedlonl AM.
seman N- In., and Per...mongol, Testing Nmulrements
"- $3xrltiSs,
If yes,the permItwIll contain and Init.! compllancete.condltIon to demonStrate thedatrudIan elltlency of the cofnbustion devlee based oo Inlet and outlet conantmtnn samollne
Uncontrolled
Factor Control%
PIPS M.P.
67
bluene 0.90
En9lbemene 90
nen
unns
WM.) fuel emmmbuAed
IbRgmsd fuel gas rnmbuAed
/MMaa fuel easmmbmhb
Ib/M Msd fuel gas mmbuued
Ib/MMW fuel gasmmbusted
Ib/Mrnd laud eas mmb uned
Ib/MMrd me gas combusted
IwMMad fun gasrombuMm
Ib/MMwmdemcornh.ea
Ib/MMw nragesmrewated
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Cureton Front Range LLC
123
9F67
Front Range Gas Plant
History File Edit Date
4/30/2019
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons per veer
EMISSIONS With Controls (tons per year
POINT
AIRS
ID
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACIUTY TOTAL
3.4
3.4
0.0
0.1
44.5
47.2
7.D
50.3
From October 2018 Tab minus emissions from
010-012 since those were removed 12/25/18 per
CN forms.
Previous Permdled Facilely total
3.4
3.4
0.0
0.1
44.5
47.2
7.0
50.3
001
17WE1089.XP
Heater(exempt)
D.2
0.2
1.5
0.2
2.6
0.0
3.2
0.2
1.5
0.2
2.6
0.0
No Change
002
17WE1090
Fugitives
91.2
5.9
18.6
1.1
Mod to increase component count
003
17WE1090
Boiler
57
0.7
4.4
0.5
7.4
0.2
5.7
0.7
4.4
0.5
7.4
0.2
No Change
004
17WE1090
Boiler
0.4
0.4
24
0.3
4.1
0.0
D.4
0.4
24
0.3
4.1
0.0
No Change
005
17WE1090
Pig machine
6.1
0.0
6.1
0.0
Mod to add receivers
r,.
Loi,lf le :
Cr,..-,e .4..5 stgolr ..,.':
<rC'.,
,:.5-tyc ter B,3,35' 33, HP xBE.
0s7
c
ehte,Cetit ,tte u;:, U=,
_
flit
009
OPUS
(3) Condensate Tanks
1.3
59
0.1
Applicant 0011 cancel upon issuance of permit but
needs coverage until then for existing tanks.
ao
Q.0
4,7:Vi; r.K ,2.,,,1,..,,-..,'sti,,r
_Iv
CC
..r r 1a
.,
013
17WE1090
Caterpillar 4SLB 2500 HP RICE
0.7
0.7
0.0
12.1
155
60.4
6.7
0.7
0.7
0.0
12.1
12.1
12.1
1.7
Comerting to CP {fee emissions >90tpy VOC)
014
17WE1090
Caterpillar 4SLB 2500 HP RICE
0.7
0.7
0.0
12.1
15.5
60.4
6.7
(1.7
0.7
5.0
12,1
12.1
12.1
1.7
Converting to CP f rac emissions 09Olpy VOC)
015
17WE1090
Caterpillar 4SLB 2500 HP RICE
0.7
0.7
D.O
12.1
15.5
60.4
6.7
0.7
0.7
0.0
12.1
12.1
121
17
Converting to CP (fac emissions >90toy VOC)
016
17WE1090
200 MMSCFD Amine Unit
0.790
0.790
3.190
6.D
10.4
885.8
8.7
1326
0.790
0.790
0.060
6.0
10.4
54
8.7
25
New Point
017
17W10091)
20MM, .13 Amide II It
==
Cancelletoin request recd 414/19(during
018
17WE1090
Reoen Heater 20 MMBtu/hr
asso
0.650
0.1
4.3
0.5
3.5
0.2
0.650
0.650
0.l
4.3
0.5
3.5
0.2
New Point
019
17WE1090
Hot Oil Heater 55 MMBtu/hr
1.780
1780
0.1
11.7
1.3
9.6
0.4
1.780
1780
al
11.7
1.3
9.6
0.4
New Point
020
17WE1090
Hot Oil Heater 55 MMBtu/hr
1780
1.780
0.1
11.7
1.3
9.6
0.4
1780
1.780
0.1
11.7
1.3
9.6
0.4
New Point
021
t7'/VE1093 `-:
Peden I le„ter StMMBtu/I r
-
0 h
V:0
Applicant WHill cancelbased: on categorical XA
022
17WE1090
Stabalized Cnd Tanks (4-100D bb')
0.090
0.090
0.8
254.2
3.8
6.2
0.090
0.090
0.6
12.8
3.0
0.3
New Point
023
17WE1090
Loadout of Condensate
301.5
5.1
15.1
0.3
New Point, note that NOx and CO are reposed
00th Point 022
025
17WE1090
pressurized loadout of NGL
11.6
0.1
11.7
0.1
New Point
024
17WE1090
Methanol Tank
as
0.5
as
0.5
New Point
026
17WE1090
Plant Flare (permitting purge gas)
0.070
0.070
0.0
0.6
0.1
2.9
0.0
0.070
0.070
0.0
0.6
0.1
29
0.0
New Point
APEN/Permit Exempt, Insignificant Sources
Propane compressor I blowdown
0.21
521
Propane compressor 2 blowdown
0.21
-
-
0.21
Inlet compressor 1 blowdown
aos
0.05
inlet colnpressor 2 blowdown
`.0.05
0 o5
Inlet compressor 3 blowdown
0.05
0.05
inlet compressor 4 blowdown
0.05
0 o5
Regen Gas compressor 1 blowdoozr
0.05
0 o5
'-
Regen gas, compressor 2: Slowdown
-0.05
; .005
FACILITY TOTAL
8.6
8.6
3.2
6.5
84.D
1,511.1
91.2
233.3
173.0
8.6
8.6
0.1
6.5
84.0
98.7
18.6
88.5
11.1
VOC: Syn Minor (NANSR and OP)
NO0: Syn Minor (NANSR and OP)
CO: Syn Minor (PSD and OP)
HAPS: Minor B, T, X HCHO 8. Total
HI -It Minor +Affected Area
7777: Minor
Permitted Facility Total
03
03
3.2
6.5
81.9
1,510./
91.2
227.8
173.0
84
8.4
0.1
65
825
978
18.6
85.9
11.1
Excludes undo exempt from perm0s/APENS
(A) Change in Permitted Emissions
4.9
4.9
0.1
64
300
50.6
11.6
356
Pubcom required based on new synthetic minor
limits. Modeling is not required based on change
in emissions less than modeling thresholds
Note 1
Total APEN reportable VOC Facility Emissions (point and fugitive)
1106
Facility is NOT eligible for GP02 because 0 90 tpy
Total VOC Facility Emissions (point and fugitive)
((A)) Change in Total Permitted VOC emissions (point and fugitive)
1173
Project emissions less than 25/50 tpy
62.1
This application was received 12/1008 and includes equipment added and modified to accommodate a new 200 mmsefd processing train.
Note 2
Page 40 of 42 Printed 4/30/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Cureton Front Range LLC
County AIRS ID 123
Plant AIRS ID 9F67
Facility Name Front Range Gas Plant
Emissions - uncontrolled (Ibs per year
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
Previous FACILITY TOTAL
0.0
0.0
0.0
0.2
0.2
0.2
0.2
0.5
0.0
0.0
0
1.3
001
17WE1089.XP
Heater (exempt)
0.0
002
17WE1090
Fugitives
2206
2238
2208
2211
2858
5.9
003
17WE1090
Boiler
314
0.2
004
17WE1090
Boiler
0.0
005
17WE1090
Pig machine
0.0
006
GP02.CN
Caterpillar 4SLB 690 HP RICE
0.0
007
GP02.CN
Caterpillar 4SLB 690 HP RICE
0.0
008
GP02.CN
Caterpillar 4SRB 400 HP RICE
0.0
009
GP08
(3) Condensate Tanks
263
2300
1.3
010
GP02
Caterpillar 4SLB 1380 HP RICE
0.0
011
GP02
Caterpillar 4SLB 1775 HP RICE
0.0
012
GP02
Caterpillar 4SLB 1775 HP RICE
0.0
013
17WE1090
Caterpillar 4SLB 2500 HP RICE
11105
1224
753
366
6.7
014
17WE1090
Caterpillar 4SLB 2500 HP RICE
11105
1224
753
366
6.7
015
17WE1090
Caterpillar 4SLB 2500 HP RICE
11105
1224
753
366
6.7
016
17WE1090
200 MMSCFD Amine Unit
149366
76956
9957
22008
6882
1
132.6
017
17WE1090
20 MMSCFD Amine Unit
0.0
018
17WE1090
Regen Heater 20 MMBtu/hr
13
306
0.2
019
17WE1090
Hot Oil Heater 55 MMBtu/hr
35
842
0.4
020
17WE1090
Hot Oil Heater 55 MMBtu/hr
35
842
0.4
021
17WE1090
Regen Heater 5 MMBtu/hr
0.0
022
17WE1090
Stabalized Cnd Tanks (4-1000 bbl)
7896
3384
456
640
6.2
023
17WE1090
Loadout of Condensate
1048
9198
5.1
025
17WE1090
pressurized loadout of NGL
21
10
2
2
195
0.1
024
17WE1090
Methanol Tank
997
0.5
026
17WE1090
Plant Flare (permitting purge gas)
0.0
0.0
TOTAL (tpy)
16.7
1.8
1.1
80.4
41.3
6.3
12.4
11.9
1.0
0.0
0.0
0.0
173.0
otal Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
41
17WE1090.CP2.xlsm
4/30/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Cureton Front Range LLC
County AIRS ID 123
Plant AIRS ID 9F67
Facility Name Front Range Gas Plant
Emissions with control
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
Previous FACILITY TOTAL
1.1
0.2
0.0
0.0
0.0
0.0
0.0
0.2
0.0
0.0
0.0
0
1.7
001
17WE1089.XP
Heater (exempt)
0.0
002
17WE1090
Fugitives
398
406
398
399
562
1.1
003
17WE1090
Boiler
314
0.2
004
17WE1090
Boiler
0.0
005
17WE1090
Pig machine
0.0
006
GP02.CN
Catepillar 4SLB 690 HP RICE
0.0
007
GP02.CN
Caterpillar 4SLB 690 HP RICE
0.0
008
GP02.CN
Caterpillar 4SRB 400 HP RICE
0.0
009
GP08
(3) Condensate Tanks
11
96
0.1
010
GP02
Caterpillar 4SLB 1380 HP RICE
0.0
011
GP02
Caterpillar 4SLB 1775 HP RICE
0.0
012
GP02
Caterpillar 4SLB 1775 HP RICE
0.0
013
17WE1090
Caterpillar 4SLB 2500 HP RICE
2221
612
376
183
1.7
014
17WE1090
Caterpillar 4SLB 2500 HP RICE
2221
612
376
183
1.7
015
17WE1090
Caterpillar 4SLB 2500 HP RICE
2221
612
376
183
1.7
016
17WE1090
200 MMSCFD Amine Unit
2884
1501
195
434
23
2.5
017
17WE1090
20 MMSCFD Amine Unit
0.0
018
17WE1090
Regen Heater 20 MMBtu/hr
13
306
0.2
019
17WE1090
Hot Oil Heater 55 MMBtu/hr
35
842
0.4
020
17WE1090
Hot Oil Heater 55 MMBtu/hr
35
842
0.4
021
17WE1090
Regen Heater 5 MMBtu/hr
0.0
022
17WE1090
Stabalized Cnd Tanks (4-1000 bbl)
395
169
23
32
0.3
023
17WE1090
Loadout of Condensate
52
460
0.3
025
17WE1090
pressurized loadout of NGL
21
10
2
2
195
0.1
024
17WE1090
Methanol Tank
997
0,5
026
17WE1090
Plant Flare (permitting purge gas)
0.0
0.0
TOTAL (tpy)
3.4
0.9
0.6
1.9
1.0
0.3
0.4
1.8
0.8
0.0
0.0
0.0
11.1
42
17WE1090.CP2.xlsm
4/30/2019
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE 1090
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 2
Cureton Front Range LLC
Front Range Gas Plant
123/9F67
SENE SEC 19 T2N R64W
Weld County
Natural Gas Processing Plant
Equipment or activity subject to this permit:
Facility
Equipment ID
AIRS
Point
Equipment Description
Emissions Control
Description
FUG1
002
Fugitive emission component leaks from a
natural gas processing plant. This point
includes components from the 200 MMSCFD
and 60 MMSCFD processing trains.
None
HTR2
003
One natural gas fired boiler (Make: Heatec,
Model: HCI-10010-50-G, SN: HI17-195). Design
rated at 20 MM Btu per hour. (H-781)
None
HTR3
004
One natural gas fired boiler (Make: Tulsa
Heaters, Model: ASME, SN: 7290). Design rated
at 11 MM Btu per hour. (H-716)
None
PIGGING
005
Venting of gas from four (4) pig receivers
during depressurization.
None
COLORADO
Air Pollution Control Division
Danartme t of Public flealth & Environment
Page 1 of 28
Faa y
uip nt k�,.•
IRS
in '
quip F nt Description
Emissions Control
Description
ENG1
013
One (1) Caterpillar Model: G3608LE-A4 SN:
XH700907 natural gas fired, turbocharged,
4SLB reciprocating internal combustion
engine, site rated at 2,500 HP. This engine
shall be equipped with a selective oxidation
catalyst and air -fuel ratio control. This
emission unit is used for residue gas
compression at the 60 MMSCFD processing
train.
Oxidation Catalyst and
Air -Fuel Ratio
Controller
ENG2
014
One (1) Caterpillar Model: G3608LE-A4 SN:
XH700903 natural gas fired, turbocharged,
45LB reciprocating internal combustion
engine, site rated at 2,500 HP. This engine
shall be equipped with a selective oxidation
catalyst and air -fuel ratio control. This
emission unit is used for residue gas
compression at the 60 MMSCFD processing
train.
Oxidation Catalyst and
Air -Fuel Ratio
Controller
ENG3
015
One (1) Caterpillar Model: G3608LE-A4 SN:
XH700909 natural gas fired, turbocharged,
4SLB reciprocating internal combustion
engine, site rated at 2,500 HP. This engine
shall be equipped with a selective oxidation
catalyst and air -fuel ratio control. This
emission snit is used for residue gas
compression at the 60 MMSCFD processing
train.
Oxidation Catalyst and
Air -Fuel Ratio
Controller
AMINE1
016
One (1) Methyldiethanolamine (MDEA) natural
gas sweetening unit (Make: TBD, Model: TBD,
SN: TBD) with a design capacity of 200 MMscf
per day. This emission unit is equipped with
two (2) (Make: TBD, Model: TBD) electric
driven amine recirculation pumps with a
limited capacity of 1,000 gallons per minute
of lean amine. This amine unit is equipped
with a natural gas/amine contactor, flash
tank, still vent and amine regenerator with
heat supplied from HTR-6 (Point 019) and/or
HTR-7 (Point 020). Supplemental fuel is
provided to the thermal oxidizer.
Emissions from the
flash tank are sent to
the plant fuel system
or recycled to the
plant inlet.
The acid gas stream,.
from the still vent is
routed to a thermal
oxidizer (this thermal
oxidizer controls
Points 016).
HTR-4
018
One (1) (Make: TBD, Model: TBD, SN: TBD)
natural gas fired heater with a design heat
input rate of 20 MMBtu/hr. This heater is
equipped with a low NOx combustion system
for minimizing emissions of nitrogen oxides.
This unit is used for molecular sieve
regeneration.
None
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Page 2 of 28
Faci = y
Dui nt °
IRS
.inr
quip nt Description
Emissions Control
Description
HTR-6
019
One (1) (Make: TBD, Model: TBD, SN: TBD)
natural gas fired heater with a design heat
input rate of 55 MMBtu/hr. This heater is
equipped with a low NOx combustion system
for minimizing emissions of nitrogen oxides.
This unit is a hot oil heater.
None
HTR-7
020
One (1) (Make: TBD, Model: TBD, SN: TBD)
natural gas fired heater with a design heat
input rate of 55 MMBtu/hr. This heater is
equipped with a low NOx combustion system
for minimizing emissions of nitrogen oxides.
This unit is a hot oil heater.
None
TK-1-4
022
Four (4) 1000 barrel fixed roof storage vessels
connected via liquid manifold. These vessels
are used to store stabilized condensate.
Enclosed Flare
LOAD2
023
Truck loadout of stabilized condensate by
submerged fill.
Enclosed Flare
TK-11
024
One (1) 750 bbl fixed roof storage vessel used
to store methanol.
None
LOAD1
025
Unloading of NGL from pressurized tanks to
pressurized tank trucks. Loadout occurs via
vapor balance and emissions are only released
to the atmosphere during hose disconnect.
None
FLARE
026
Combustion of purge gas and pilot fuel at one
(1) open flare (make/model: TBD). This flare is
used to control process streams during events
that qualify as a malfunction per Common
Provisions Regulation, Section II.E.
Open Flare
Points 013 - 015: These engines may be replaced with another engine in accordance with the temporary
engine replacement provision or with another Caterpillar G3608LE-A4 engine in accordance with the
permanent replacement provision of the Alternate Operating Scenario (A0S), 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/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
C D�*rPH E
COLORADO
Air Pollution Control Division
Department of Pbuto Ffeatth 8FlIVIlortment
Page 3 of 28
lation Number 3, Part B, Section III.G.1. and can result
2 f ith' , ,• a ays ( f the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall be demonstrated to
the Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section III.E.)
5. Point 016: The following information shall be provided to the Division within fifteen (15) days of
the latter of commencement of operation or issuance of this permit.
• The amine unit manufacturer name, model number and serial number
• The amine 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 003, 004, 018, 019, 020: 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.
• Manufacturer
• Model Number
• Serial Number
This information shall be included with the Notice of Startup submitted for the equipment.
(Regulation Number 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 I I .A.4. )
Monthly Limits:
Facility
Equipment
ID
AIRS
Point
Process
Pounds per Month
Emission
Type
PM2.5
PM10
SO,
H2S,
NO,
VOC
CO
FUG1
002
01
---
---
---
---
---
3,153
---
Fugitive
COLORADO
Air Pollution Control Division
Departmrnt of PubtHealth b Environment
Page 4 of 28
F • "
qu rn t
•int
Pr• ; s ;
_
Pounds per Month
Emission
Type
P .°
PM10
SO.
H2S
NO.
V0C
CO
PIGGING
005
01
---
---
---
---
---
1,032
---
Point
02
03
04
ENG1
013
01
---
---
---
---
2,050
2,050
2,050
Point
ENG2
014
01
---
---
---
---
2,050
2,050
2,050
Point
ENG3
015
01
---
---
---
---
2,050
2,050
2,050
Point
AMINE1
016
01
---
---
1,017
11
187
845
157
Point
02
---
---
---
---
1,577
62
1,320
HTR-4
018
01
---
---
---
---
722
---
595
Point
HTR-6
019
01
302
302
---
---
1,986
219
1,637
Point
HTR-7
020
01
302
302
---
---
1,986
219
1,637
Point
TK-1-4
022
01
---
---
---
---
---
2,159
649
Point
L0AD2
023
01
---
---
---
---
---
2,561
---
Point
L0AD1
025
01
---
---
---
---
---
1,975
---
Point
FLARE
026
01
---
---
---
---
---
---
491
Point
Note:
1. Monthly limits are based on a 31 -day month.
2. Process 01 - 04 for the pigging operation covered under Point 005 are as follows:
a. Process 01: Depressurization of 6" pig receiver
b. Process 02: Depressurization of 8" pig receiver
c. Process 03: Depressurization of 10" pig receiver
d. Process 04: Depressurization of 16" pig receiver
3. Process 01 and 02 for the amine unit covered under Point 016 are as follows:
a. Process 01: Still vent waste gas routed to the thermal oxidizer.
b. Process 02: Combustion of assist gas by the thermal oxidizer.
4. Process 01 for the condensate tank covered under Point 022 includes secondary combustion
emissions (PM, SOx, NOx, and CO) from truck loadout vapors that are directed to the storage tank
prior to being combusted in the enclosed flare.
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.
COLORADO
Air Pollution Control Division
Department of Puf ot Health , Environment
Page 5 of 28
emission units at this facility.
Annual Limits:
ous air pollutants shall not exceed 3,398 pounds per
itati hazardous air pollutants shall apply to all permitted
Facility
Equipment
ID
AIRS
Point
Process
Tons per Year
Emission
Type
PM2.5
PM10
SO,
H2S
NO,
V0C
CO
FUG1
002
01
---
---
---
---
---
18.6
---
Fugitive
HTR-2
003
01
---
---
---
---
4.4
---
7.3
Point
HTR-3
004
01
---
---
---
---
2.4
---
4.1
Point
PIGGING
005
01
---
---
---
---
---
6.1
---
Point
02
Point
03
Point
04
Point
ENG1
013
01
---
---
---
---
12.1
12.1
12.1
Point
ENG2
014
01
---
---
---
---
12.1
12.1
12.1
Point
ENG3
015
01
---
---
---
---
12.1
12.1
12.1
Point
AMINE1
016
01
---
---
6.0
0.1
1.1
5.0
1.0
Point
02
---
---
---
---
9.3
0.4
7.8
HTR-4
018
01
---
---
---
---
4.3
---
3.5
Point
HTR-6
019
01
1.8
1.8
---
---
11.7
1.3
9.7
Point
HTR-7
020
01
1.8
1.8
---
---
11.7
1.3
9.7
Point
TK-1-4
022
01
---
---
---
---
---
12.8
3.9
Point
L0AD2
023
01
---
---
---
---
---
15.1
---
Point
L0AD1
025
01
---
---
---
---
---
11.7
---
Point
FLARE
026
01
---
---
---
---
---
---
2.9
Point
Note:
1. See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
2. Process 01 - 04 for the pigging operation covered under Point 005 are as follows:
a. Process 01: Depressurization of 6" pig receiver
b. Process 02: Depressurization of 8" pig receiver
c. Process 03: Depressurization of 10" pig receiver
COLORADO
Air Pollution Control Division
Department of Ribtic Health Er Environment
Page 6 of 28
n of 16" pig receiver
t covered under point 016 are as follow:
entas routed to the thermal oxidizer.
b. Process 02: Combustion of assist gas and pilot fuel by the thermal oxidizer.
4. Process 01 for the condensate tank covered under Point 022 includes secondary combustion
emissions (PM, SOx, NOx, and CO) from truck loadout vapors that are directed to the storage tank
prior to being combusted in the enclosed flare.
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. The owner or operator shall track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility potential emission limitations as
indicated below. An inventory of each insignificant activity and associated emission calculations
shall be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
(Reference: Regulation 3, Part C. II.E.)
Total emissions from the facility, including all permitted emissions and potential to emit from
all insignificant activities, shall be less than:
• 100 tons per year of VOC (fugitive emissions shall not be considered)
10. Point 002: The owner or operator shall calculate actual emissions from this emissions point based
on representative component counts for the facility with the most recent inlet gas analysis, as
required in the Compliance Testing and Sampling section of this permit. The owner or operator
shall maintain records of the results of component counts and sampling events used to calculate
actual emissions and the dates that these counts and events were completed. These records shall
be provided to the Division upon request.
11. Point 016: Compliance with the emission limits in this permit shall be determined by using the
monthly measured still vent waste gas sample composition and monthly measured waste gas flow
volumes. The owner or operator shall calculate uncontrolled VOC, HAP, and H2S emissions on a
monthly basis using the most recent measured waste gas sample composition and monthly
measured waste gas flow volume. A control efficiency of 98%, based on operating the control
device in accordance with the O&M Plan, shall be applied to the uncontrolled VOC, HAP and H2S
emissions.
12. Point 016: 100% of emissions that result from the flash tank associated with the amine unit shall
be recycled to the plant inlet or sent to the plant fuel system.
CDPHE
COLORADO
Air Pollution Control Division
Department at Publ:c Health b Environment
Page 7 of 28
d maintain the emission points in the table below with
d in order to reduce emissions to less than or equal to
ulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
ENG1
013
Oxidation Catalyst and Air -Fuel Ratio Controller
VOC, CO,
HAP
ENG2
014
Oxidation Catalyst and Air -Fuel Ratio Controller
VOC, CO,
HAP
ENG3
015
Oxidation Catalyst and Air -Fuel Ratio Controller
VOC, CO,
HAP
AMINE1
016
Still Vent: Thermal Oxidizer (TO)
VOC £t HAP
TK-1-4
022
Enclosed Flare
VOC Et HAP
LOAD2
023
Enclosed Flare
VOC a HAP
PROCESS LIMITATIONS AND RECORDS
14. 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, Section
II.A.4. )
Process Limits
Facility
Equipment ID
AIRS
Point
Process
Process Parameter
Annual Limit
Monthly Limit
(31 days)
HTR2
003
01
Consumption of
Natural Gas as Fuel
174.2 MMscf
---
HTR3
004
01
Consumption of
Natural Gas as Fuel
95.8 MMscf
---
PIGGING
005
01
Depressurization
Events
1,095 events
93 events
02
1,095 events
93 events
03
1,095 events
93 events
04
1,095 events
93 events
ENG1
013
01
Consumption of
Natural Gas as fuel
145.53 MMscf
12.36 MMscf
ENG2
014
01
Consumption of
Natural Gas as fuel
145.53 MMscf
12.36 MMscf
ENG3
015
01
Consumption of
Natural Gas as fuel
145.53 MMscf
12.36 MMscf
COLORADO
Air Pollution Control Division
Departn1er t of Pubto E{eatth b Environment
Page 8 of 28
ty
q t ID ,'
' S
Ptg, t
.r cess
Process Parameter
Annual Limit
Monthly Limit
(31 days)
AMINE1
016
---
Natural Gas
Throughput
73,000 MMSCF
6,200 MMSCF
01
Still vent waste gas
routed to the
thermal oxidizer
1,815.3 MMSCF
154.2 MMSCF
02
Combustion of assist
gas and pilot gas by
the thermal oxidizer
184.0 MMSCF
15.7 MMSCF
HTR-4
018
01
Consumption of
natural gas as a fuel
170.10 MMSCF
14.45 MMSCF
HTR-6
019
01
Consumption of
natural gas as a fuel
467.77MMSCF
39.73 MMSCF
HTR-7
020
01
Consumption of
natural gas as a fuel
467.77MMSCF
39.73 MMSCF
TK-1-4
022
01
Throughput of
stabilized
condensate
2,555,000
barrels
217,000
barrels
L0AD2
023
01
Loadout of Stabilized
Condensate
2,555,000
barrels
217,000
barrels
TK-11
024
01
Throughput of
methanol
8,872 barrels
754 barrels
L0AD1
025
01
Pressurized NGL
loading events
10,731 events
912 events
FLARE
026
01
Combustion of purge
and pilot gas
18.09 MMSCF
1.54 MMSCF
Note:
1. Process 01 - 04 for the pigging operation covered under Point 005 are as follows:
a. Process 01: Depressurization of 6" pig receiver
b. Process 02: Depressurization of 8" pig receiver
c. Process 03: Depressurization of 10" pig receiver
d. Process 04: Depressurization of 16" pig receiver
2. Process 01 and 02 for the amine unit covered under Point 016 are as follow:
a. Process 01: Still vent waste gas routed to the thermal oxidizer.
b. Process 02: Combustion of assist gas and pilot fuel by the thermal oxidizer.
3. In addition to pilot and purge gas, gas will be routed to the flare covered under Point 026 during
any events that qualify as a malfunction per Common Provisions Regulation, Section II.E.
The owner or operator shall monitor monthly process rates based on the calendar 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.
15. Point 003, 004, 018, 019, 020: The owner or operator shall continuously monitor and record
the volumetric flow rate of natural gas combusted as fuel for each heater using an operational
continuous flow meter at the inlet of each heater. The owner or operator shall use monthly
COLORADO
Air Pollution Control Division
Department o: Public Health b Environment
Page 9 of 28
pliance with the process limits contained in this permit
in this permit.
sum 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.
17. Point 016: The owner or operator shall continuously monitor and record the following amine unit
emission streams using continuous operational flow meters:
• Total amine unit still vent waste gas volume routed to the thermal oxidizer,
• Total assist gas volume routed to the thermal oxidizer.
The owner or operator shall use monthly throughput records to demonstrate compliance with the
process limits contained in the permit and to calculate emissions as described in this permit.
18. Point 016: The owner or operator shall continuously monitor and record the volumetric flow rate
of natural gas processed by the amine unit contactor using an operational continuous flow meter
at the inlet to the amine contactor. The owner or operator shall use monthly throughput records
to demonstrate compliance with the process limits contained in this permit and to calculate
emissions as described in this permit.
19. Point 016: This unit shall be limited to the maximum lean amine circulation rate of 1,000 gallons
per minute. The lean amine recirculation rate shall be recorded daily in a log maintained on
site and made available to the Division for inspection upon request. (Regulation Number 3, Part
B, Section II.A.4)
20. Point 026: The owner or operator shall continuously monitor and record the volumetric flow rate
of purge gas routed to the flare using flow meters. The owner or operator shall use monthly
throughput records to demonstrate compliance with the process limits contained in this permit
and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
21. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
22. This source is located in an ozone non -attainment or attainment -maintenance area and subject
to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3,
Part B, III.D.2. The following requirements were determined to be RACT for this source:
Facility
Equipment ID
AIRS Point
RACT
Pollutants
FUG1
002
LDAR as provided at 40 CFR Part 60 Subpart
0000a
VOC
HTR2
003
Natural gas as fuel, low NOx burners, good
combustion practices
NOx, VOC
HTR3
004
Natural gas as fuel, low NOx burners, good
combustion practices
NOx, VOC
ENG1
013
Oxidation Catalyst and Air -Fuel Ratio
Controller
VOC
ENG2
014
Oxidation Catalyst and Air -Fuel Ratio
Controller
VOC
ENG3
015
Oxidation Catalyst and Air -Fuel Ratio
Controller
VOC
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Page 10 of 28
1 =
-�.
lash nk: Recycled to plant inlet or routed
to the plant fuel system.
VOC
ill Vent: Thermal Oxidizer
HTR-4
018
Natural gas as fuel, low NOx burners, good
combustion practices
NOx, VOC
HTR-6
019
Natural gas as fuel, low NOx burners, good
combustion practices
NOx, VOC
HTR-7
020
Natural gas as fuel, low NOx burners, good
combustion practices
NOx, VOC
TK-1-4
022
Enclosed Flare
VOC
L0AD2
023
Submerged Fill and Enclosed Flare
VOC
L0AD1
025
Loading using pressurized vessels and vapor
balance
VOC
23. Point 003, 004, 013, 019, 020, 022, 024, 026: 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)
24. Point 002, 003, 004, 005, 013, 014, 015, 016, 018, 019, 020, 024, 025: Visible emissions
shall not exceed twenty percent (20%) opacity during normal operation of the source. During
periods of startup, process modification, or adjustment of control equipment visible emissions
shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes.
(Regulation Number 1, Section II.A.1. Et 4.)
25. Point 002: This source is subject to Regulation Number 7, Section XII.G.1 (State only
enforceable). For fugitive V0C emissions from leaking equipment, the leak detection and repair
(LDAR) program as provided at 40 CFR Part 60, Subpart KKK (July 1, 2016) shall apply, regardless
of the date of construction of the affected facility, unless subject to applicable LDAR program
as provided at 40 CFR Part 60, Subparts OOOO or 0000a (July 1, 2016). The operator shall comply
with all applicable requirements of Section XII.
26. Point 003, 004, 018, 019, 020: This source is subject to the Particulate Matter and Sulfur
Dioxide Emission Regulations of Regulation 1 including, but not limited to, the following
(Regulation 1, Section III.A.1 and VI.B.5. ):
a. No owner or operator shall cause or permit to be emitted into the atmosphere from any
fuel -burning equipment, particulate matter in the flue gases which exceeds the following
(Regulation 1, Section III.A.1):
(i)
For fuel burning equipment with designed heat inputs greater than 1x106 BTU
per hour, but less than or equal to 500x106 BTU per hour, the following equation
will be used to determine the allowable particulate emission limitation.
PE=0.5(FI)-0.26
Where:
PE = Particulate Emission in Pounds per million BTU heat input.
Fl = Fuel Input in Million BTU per hour.
b. New sources of sulfur dioxide shall not emit or cause to be emitted sulfur dioxide in
excess of the following process -specific limitations:
(i)
Limit emissions to not more than two (2) tons per day of sulfur dioxide.
(Regulation 1 Section VI.B.5.a.)
COLORADO
Air Pollution Control Division
Department of Public Health b Er vironrnont
Page 11 of 28
27. � , t 't �., "104, IF S 19, `'� This s rce is subject to the New Source Performance Standards
N ber Part B including, but not limited to, the following
Section .C.):
to M. ""- - On and after the date on which the required
performance test is completed, no owner or operator subject to the provisions of this
regulation may discharge, or cause the discharge into the atmosphere of any particulate
matter which is:
(i)
For fuel burning equipment generating greater than one million but less than 250
million Btu per hour heat input, the following equation will be used to determine
the allowable particulate emission limitation:
PE=0.5(FI)-0.26
Where:
PE is the allowable particulate emission in pounds per million Btu heat input.
Fl is the fuel input in million Btu per hour.
If two or more units connect to any opening, the maximum allowable emission
rate shall be the sum of the individual emission rates.
(ii) Greater than 20 percent opacity.
28. Point 003, 004, 018, 019, 020: This source is subject to the New Source Performance Standards
requirements of Regulation Number 6, Part A, Subpart Dc, Standards of Performance for Small
Industrial -Commercial -Institutional Steam Generating Units including, but not limited to the
following:
• §60.48c Reporting and recordkeeping requirements:
o §60.48c(a) - The owner or operator of each affected facility shall submit
notification of the date of construction or reconstruction and actual startup, as
provided by §60.7 of this part. This notification shall include:
■ §60.48c(a)(1) - The design heat input capacity of the affected facility
and identification of fuels to be combusted in the affected facility.
o §60.48c(g)(1) - Except as provided under paragraphs (g)(2) and (g)(3) of this
section, the owner or operator of each affected facility shall record and maintain
records of the amount of each fuel combusted during each operating day.
o §60.48c(g)(2) - As an alternative to meeting the requirements of paragraph (g)(1)
of this section, the owner or operator of an affected facility that combusts only
natural gas may elect to record and maintain records of the amount of each fuel
combusted during each calendar month.
o §60.48c(i) - All records required under this section shall be maintained by the
owner or operator of the affected facility for a period of two years following the
date of such record.
29. Points 013, 014, 015: This equipment is subject to the control requirements for stationary and
portable engines in the 8 -hour ozone control area under Regulation No. 7, Section XVI.B.2. For
lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required.
30. Point 022: 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.
COLORADO
Air Pollution Control Division
Department o: Pub1`:C }I6alth b Environment
Page 12 of 28
31ce c. -red by this permit is subject to Regulation Number 7,
v ions ate only enforceable). If a flare or other combustion
lc u' t. ont }fie A,,g ions of latile organic compounds to comply with Section XVII, it
shall . - en .`` - 4- . ible e ssions during normal operations, as defined under
Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual
observation from the outside of the enclosed flare or combustion device, or by other convenient
means approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto -igniter upon installation of the combustion device.
32. Point 022: This source is subject to the New Source Performance Standards requirements of
Regulation Number 6, Part A, Subpart Kb, Standards of Performance for Volatile Organic Liquid
Storage Vessels for which construction, reconstruction or modification commenced after July 23,
1984, including, but not limited to, the following (Regulation Number 6, Subparts A and Kb):
• 40 CFR, Part 60, Subpart A - General Provisions
• §60.112b - Standard for volatile organic compounds (VOC)
o §60.112b(a) The owner or operator of each storage vessel with a....design capacity
greater than or equal to 151 m3 containing a VOL that, as stored, has a maximum true
vapor pressure equal to or greater than 5.2 kPa but less than 76.6 kPa, shall equip each
storage vessel with one of the following:
■ §60.112b(a)(3) A closed vent system and control device meeting the following
specifications:
• §60.112b(a)(3)(i) The closed vent system shall be designed to collect all
VOC vapors and gases discharged from the storage vessel and operated
with no detectable emissions as indicated by an instrument reading of
less than 500 ppm above background and visual inspections, as
determined in part 60, subpart W, §60.485(b).
• §60.112b(a)(3)(ii) The control device shall be designed and operated to
reduce inlet VOC emissions by 95 percent or greater. If a flare is used as
the control device, it shall meet the specifications described in the
general control device requirements (§60.18) of the General Provisions.
o §60.113b - Testing and procedures
■ The owner or operator of each storage vessel as specified in $60.112b(a) shall
meet the requirements of paragraph (a), (b), or (c) of this section. The
applicable paragraph for a particular storage vessel depends on the control
equipment installed to meet the requirements of §60.112b.
• §60.113b(c) The owner or operator of each source that is equipped with a closed
vent system and control device as required in §60.112b (a)(3) or (b)(2) (other
than a flare) is exempt from §60.8 of the General Provisions and shall meet the
following requirements.
• §60.113b(c)(1) Submit for approval by the Administrator as an attachment to
the notification required by §60.7(a)(1) or, if the facility is exempt from
§60.7(a)(1), as an attachment to the notification required by 560.7(a)(2), an
operating plan containing the information listed [in §60.113b(c)(1)(i) and
§60.113b(c)(1)(ii)].
• §60.113b(c)(2) Operate the closed vent system and control device and monitor
the parameters of the closed vent system and control device in accordance with
the operating plan submitted to the Administrator in accordance with paragraph
(c)(1) of this section, unless the plan was modified by the Administrator during
the review process. In this case, the modified plan applies.
COLORADO
Air Pollution Control Division
Department of PubItc Health ti Environment
Page 13 of 28
dkeeping requirements
fling control equipment in accordance with §60.112b
(3 (clos- ant system and control device other than a flare), the
owner or operator shall keep the following records.
• §60.115b(c)(1) A copy of the operating plan.
• §60.115b(c)(2) A record of the measured values of the parameters monitored in
accordance with §60.113b(c)(2).
o §60.116b - Monitoring of operations
• $60.116b(a) The owner or operator shall keep copies of all records required by
this section, except for the record required by paragraph (b) of this section, for
at least 2 years. The record required by paragraph (b) of this section will be kept
for the life of the source.
• §60.116b(b) The owner or operator of each storage vessel as specified in
$60.110b(a) shall keep readily accessible records showing the dimension of the
storage vessel and an analysis showing the capacity of the storage vessel.
• §60.116b(g) The owner or operator of each vessel equipped with a closed vent
system and control device meeting the specification of §60.112b or with
emissions reductions equipment as specified in 40 CFR 65.42(b)(4), (b)(5), (b)(6),
or (c) is exempt from the requirements of paragraphs (c) and (d) of this section
33. Points 023, 025: All hydrocarbon liquid loading operations, regardless of size, shall be designed,
operated and maintained so as to minimize leakage of volatile organic compounds to the
atmosphere to the maximum extent practicable.
34. Points 023, 025: The owner or operator shall follow loading procedures that minimize the
leakage of VOCs to the atmosphere including, but not limited to (Regulation Number 3, Part B,
III. E. ):
a) Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other
liquid or vapor loss during loading and unloading.
b) All compartment hatches at the facility (including thief hatches) shall be closed and
latched at all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
c) The owner or operator shall inspect onsite loading equipment during loading
operations to monitor compliance with above conditions. The inspections shall occur
at least monthly. Each inspection shall be documented in a log available to the
Division on request.
35. Point 023, 025: The owner or operator shall:
a. Install and operate the vapor collection and return equipment to collect vapors during
loading of tank compartments of outbound transport trucks.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in use.
c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless
the vapor collection equipment is in use.
d. Operate all recovery and disposal equipment at a back -pressure less than the pressure
relief valve setting of transport vehicles.
36. Point 026: No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess
of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
COLORADO
Air Pollution Control Division
Department of Pubto Health b Ernironmont
Page 14 of 28
37.="� is = 1 �' 14 15, 16, "_22, 023: ' pon startup of these points, the owner or operator shall
lo ecting ..R , . aintenance (O&M) plan and record keeping format
approved by the Division, in order to demonstrate compliance on an ongoing basis with the
requirements of this permit. Revisions to the OftM plan are subject to Division approval prior to
implementation. (Regulation Number 3, Part B, Section III.G.7.)
38. Point 016: The combustion chamber temperature of the thermal oxidizer used to control
emissions from the amine unit still vent shall be greater than 1400°F, or the temperature
established during the most recent stack test of the equipment that was approved by the Division,
on a daily average basis. The approved daily average minimum operating temperature shall be
achieved at all times that any amine unit emissions are routed to the thermal oxidizer in order
to meet the emission limits in this permit. The combustion chamber temperature shall be
measured and recorded at least once every hour. If the combustion chamber temperature value
is measured more frequently than once per hour, the source shall record either each measured
data value or each block average value for each 1 -hour period calculated from all measured data
values during each period.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
39. Point 002: Within one hundred and eighty days (180) of the latter of commencement of operation
or issuance of this permit, the owner or operator shall complete the initial extended gas analysis
of gas samples that are representative of volatile organic compound (VOC) and hazardous air
pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be
used in the compliance demonstration as required in the Emission Limits and Records section of
this permit. The operator shall submit the results of the gas analysis and emission calculations
to the Division as part of the self -certification process to ensure compliance with emissions limits.
40. Point 002: Within one hundred and eighty days (180) of the latter of commencement of operation
or issuance of this permit, the operator shall complete a hard count of components at the source
and establish the number of components that are operated in "heavy liquid service", "light liquid
service", "water/oil service" and "gas service". The operator shall submit the results to the
Division as part of the self -certification process to ensure compliance with emissions limits.
41. Point 005: The owner/operator shall complete an initial extended gas analysis ("Analysis") within
one hundred and eighty days (180) after commencement of operation or issuance of this permit,
whichever comes later, of the inlet gas vented during pigging depressurization in order to verify
the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used
to calculate emission factors for VOC (in units of lb/event), using methods provided in the "notes
to permit holder". Results of the Analysis shall be submitted to the Division as part of the self -
certification and must demonstrate the emissions factors established through the Analysis are
less than or equal to, the emissions factors submitted with the permit application and established
herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions
factor developed through this Analysis is greater than the emissions factors submitted with the
permit application and established in the "Notes to Permit Holder" the operator shall submit to
the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit
modification to address this/these inaccuracy(ies).
42. Points 013, 014, 015: 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
COLORADO
Air Pollution Control Division
Department of Public Health Et Ehvitonrrient
Page 15 of 28
time by multiplying the test results by the allowable
ging time (Reference: Regulation No. 3, Part B., Section
Oxides of Nitrogen using EPA approved methods.
Carbon Monoxide using EPA approved methods.
Formaldehyde
43. Point 016: The owner or operator shall complete the initial extended gas analysis of amine unit
still vent waste gas required by this permit and submit the results to the Division as part of the
self -certification process to ensure compliance with the emission limits. (Reference: Regulation
No. 3, Part B, Section III.E.) .
44. Point 016: A source initial compliance test shall be conducted on this emissions point to measure
the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the
emissions limits in this permit. The emission rate(s) shall demonstrate compliance with the sum
of emission limits from process 01 and process 02. The operator shall also demonstrate the
thermal oxidizer (TO) achieves a minimum destruction efficiency of 98.0% for VOC. The operator
shall measure and record, using EPA approved methods, VOC mass emission rates at the thermal
oxidizer inlet and outlet to determine the destruction and removal efficiency of the thermal
oxidizer. The natural gas throughput, assist gas throughput, lean amine recirculation rate, MDEA
concentration in lean amine stream, sulfur content of the sour gas entering the amine unit, and
thermal oxidizer combustion chamber temperature shall be monitored and recorded during this
test.
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 Number 3, Part B., Section III.G.3)
Oxides of Nitrogen using EPA approved methods.
Volatile Organic Compounds using EPA approved methods.
Carbon Monoxide using EPA approved methods.
45. Point 016: The owner/operator shall complete an initial site specific extended gas analysis
("Analysis") within one hundred and eighty days (180) after commencement of operation or
issuance of this permit, whichever comes later, of the residue gas combusted as assist gas for
the thermal oxidizer (i.e. Point 016, Process 02) in order to verify the VOC content (weight
fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific
emission factors for VOC (in units of lb/MMSCF gas vented) using Division approved methods.
Results of the Analysis shall be submitted to the Division as part of the self -certification and must
demonstrate the emissions factors established through the Analysis are less than or equal to, the
emissions factors submitted with the permit application and established herein in the "Notes to
Permit Holder" for this emissions point. If any site specific emissions factor developed through
this Analysis is greater than the emissions factors submitted with the permit application and
established in the "Notes to Permit Holder" the operator shall submit to the Division within 60
days, or in a timeframe as agreed to by the Division, a request for permit modification to address
this/these inaccuracy(ies).
46. Point 018, 019, 020 : A source initial compliance test shall be conducted on each heater to
measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance
with the emissions limits contained 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
COLORADO
Air Pollution Control Division
Department of Nubllc Health b Environment
Page 16 of 28
a monthly or annual emission limitation shall have the
nnual averaging time by multiplying the test results by
for that averaging time (Regulation Number 3, Part B.,
Oxides of Nitrogen using EPA approved methods.
Carbon Monoxide using EPA approved methods.
Periodic Testing Requirements
47. Point 002: On an annual basis, the owner or operator shall complete an extended gas analysis of
gas samples that are representative of volatile organic compounds (VOC) and hazardous air
pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be
used in the compliance demonstration as required in the Emission Limits and Records section of
this permit.
48. Points 013, 014, 015: These engines are subject to the periodic testing requirements as
specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to
your O&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.
49. Point 016: At a minimum frequency of once per calendar month, the owner or operator shall
sample and complete an extended gas analysis of amine unit still vent waste gas routed to the
thermal oxidizer. This sample shall be analyzed for total VOC, Benzene, Toluene, Ethylbenzene,
Xylene, n -Hexane, 2,2,4-trimethylpentane and H25 content. The sample shall be collected prior
to the inlet of the thermal oxidizer and prior to being combined with any other stream. The
sampled data will be used to calculate VOC, H25, and SO2 emissions specified in this permit. If
an amine unit is not operated during a calendar month, monthly sampling is not required.
ADDITIONAL REQUIREMENTS
50. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
COLORADO
Air Pollution Control Division
Department of Public Health E Environment
Page 17 of 28
ust be modified; or
existing APEN expires.
ithin calen.ar .ays 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.
51. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any
stationary source or modification becomes a major stationary source or major modification solely
by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980,
on the capacity of the source or modification to otherwise emit a pollutant such as a restriction
on hours of operation (Regulation Number 3, Part D, Section V.A.7.B).
GENERAL TERMS AND CONDITIONS
52. 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.
53. 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.
54. 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.
55. 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.
56. 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.
57. 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.
COLORADO
Air Pollution Control Division
Department oi PubLc Health S Environment
Page 18 of 28
By:
the provisions of the Colorado Air Pollution Prevention
e AQCC may result in administrative, civil or criminal
5-7-115 (enforcement), -121 (injunctions), -122 (civil
R.S.
Bradley Eades
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
February 5, 2018
Issued to Cureton Front Range, LLC
Issuance 2
This Issuance
Issued to Cureton Front Range, LLC
Modification to add one (1) gas processing train of
200 MMSCFD processing capacity. Source is adding
new points 016-025. Source is modifying Point 002
and 005 to accommodate new processing trains,
and source is converting Points 013-015 from GP02
to this construction permit.
COLORADO
Air Pollution Control Division
Depattmest of Pub Health Er Erniaonment
Page 19 of 28
No ° s to ' ` m .., _ der a �T,3.lme ,. s per t issuance:
1) ay fees f the processing time for this permit. An invoice for these
is iss The permit holder shall pay the invoice within 30 days
of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
FUG
002
Benzene
71432
2206
398
Toluene
108883
2238
406
Ethylbenzene
100414
2208
398
Xylenes
1330207
2211
399
n -Hexane
110543
2858
562
PIGGING
005
Benzene
71432
1
1
Toluene
108883
6
6
Ethylbenzene
100414
1
1
Xylenes
1330207
2
2
n -Hexane
110543
116
116
2,2,4-
Trimethylpentane
540841
8
8
ENG1, ENG2,
ENG3'
013
014
015
Formaldehyde
50000
11,105
2,221
Acetaldehyde
75070
1,224
612
Acrolein
107028
753
376
Methanol
67561
366
183
Benzene
71432
64
32
Toluene
108883
60
30
Ethylbenzene
100414
6
3
COLORADO
Air Pollution Control Division
[department of Pubic Health & EYtvironrrnt
Page 20 of 28
►• enes
1330207
27
13
-hexane
110543
163
81
AMINE1
016
Benzene
71432
149,366
2,884
Toluene
108883
76,956
1,501
Ethylbenzene
100414
9,957
195
Xylene
1330207
22,008
434
n -Hexane
110543
6,882
23
2,2,4-
Trimethylpentane
540841
1
<1
HTR-4
018
Formaldehyde
50000
13
13
Benzene
71432
<1
<1
Toluene
108883
1
1
n -Hexane
110543
306
306
HTR-6
019
Formaldehyde
50000
35
35
Benzene
71432
1
1
Toluene
108883
2
2
n -Hexane
110543
842
842
HTR-7
020
Formaldehyde
50000
35
35
Benzene
71432
1
1
Toluene
108883
2
2
n -Hexane
110543
842
842
TK-1-4
022
Benzene
71432
7,896
395
Toluene
108883
3384
169
Ethylbenzene
100414
456
23
Xylene
1330207
640
32
n -Hexane
110543
<1
<1
2,2,4-
Trimethylpentane
540841
<1
<1
L0AD2
023
Benzene
71432
1,048
52
n -Hexane
110543
9,198
460
TK-11
024
Methanol
67561
997
997
L0AD1
025
Benzene
71432
21
21
Toluene
1088.83
10
10
Ethylbenzene
100414
2
2
Xylene
1330207
2
2
COLORADO
Air Pollution Control Division
Departrr re of WMtc Health b Ernironn-ient
Page 21 of 28
ilk
�..:
---xane
110543
195
195
2,2,4-
hylpe
£
540841
<1
<1
ores:
1. Emission rates for Point 013, 014, and 015 represent emissions from each emission point individually.
2. All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 002:
Component
Gas Service
Heavy Oil
Light Oil
SOil
ervi
Service
Connectors
4,799
2,136
2,776
0
Flanges
2,337
1,086
1,526
0
Open-ended Lines
7
0
9
0
Pump Seals
0
46
49
0
Valves
2,327
1,099
1,535
0
Other*
213
51
56
0
VOC Content (wt.
fraction)
0.2630
1
1
1
Benzene Content
(wt. fraction)
1.60E-5
2.00E-2
2.00E-2
2.00E-2
Toluene Content
(wt. fraction)
1.30E-4
2.00E-2
2.00E-2
2.00E-2
Ethylbenzene (wt.
fraction)
2,10E-5
2.00E-2
2.00E-2
2.00E-2
Xylenes Content
(wt. fraction)
3.20E-5
2.00E-2
2.00E-2
2.00E-2
n -Hexane Content
(wt. fraction)
2,39E-3
2.00E-2
2.00E-2
2.00E-2
2,2,4-
Trimethylpentane
Content (wt.
fraction)
---
---
---
---
*Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms,
drains, dump arms, hatches, instrument meters, polish rods and vents
TOC Emission Factors (kg/hr-component):
Component
Gas Service
Heavy Oil
Light Oil
Water/Oil
Service
Connectors
2.0E-04
7.5E-06
2.1E-04
1.1E-04
Flanges
3.9E-04
3.9E-07
1.1E-04
2.9E-06
Open-ended Lines
2.0E-03
1.4E-04
1.4E-03
2.5E-04
Pump Seals
2.4E-03
NA
1.3E-02
2.4E-05
Valves
4.5E-03
8.4E-06
2.5E-03
9.8E-05
Other
8.8E-03
3.2E-05
7.5E-03
1.4E-02
Source: EPA -453/R95-017 Table 2-4
COLORADO
Air Pollution Control Division
Departm•rz of Public Health & Environment
Page 22 of 28
Point 005:
rmit will be demonstrated by using the T0C emission
resentative component counts, multiplied by the V0C
s analyses.
Process 01 (6" receiver)
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/event
Controlled
Emission Factors
lb/event
Source
V0C
0.7341
0.7341
Engineering
calculation
Note: Emissions are based on volumetric flow of 49.89 scf/event, vapor molecular weight of 22.3 lb/lbmol
and composition of 25.03% by weight VOC.
Process 02 (8" receiver)
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/event
Controlled
Emission Factors
lb/event
Source
V0C
1.4120
1.4120
Engineering
calculation
Note: Emissions are based on volumetric flow of 95.98 scf/event, vapor molecular weight of 22.3 lb/lbmol
and composition of 25.03% by weight VOC.
Process 03 (10" receiver)
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/event
Controlled
Emission Factors
lb/event
Source
V0C
2.3387
2.3387
Engineering
calculation
Note: Emissions are based on volumetric flow of 158.96 scf/event, vapor molecular weight of 22.3 lb/lbmol
and composition of 25.03% by weight VOC.
Process 04 (16" receiver)
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/event
Controlled
Emission Factors
lb/event
Source
V0C
6.6110
6.6110
Engineering
calculation
Note: Emissions are based on volumetric flow of 449.35 scf/event, vapor molecular weight of 22.3 lb/lbmol
and composition of 25.03% by weight VOC.
Points 013-015:
CAS
Pollutant
Emission
Uncontrolled
lb/MMBtu
Factors -
g/bhp-hr
Emission Factors
lb/MMBtu
- Controlled
g/bhp-hr
N0x
0.1649
0.50
0.1649
0.50
CO
0.8245
2.50
0.1649
0.50
V0C
0.2113
0.64
0.1649
0.50
50000
Formaldehyde
7.59 x10-2
0.23
1.52 x10-2
0.05
75070
Acetaldehyde
8.36x10-3
2.77x10-2
4.18x10-3
1.27x10-2
107028
Acrolein
5.14x10-3
1.7x10-2
2.57 x103
7.79x10-3
67561
Methanol
2.5x10-3
8.28x10-3
1.25x10-3
3.79x10-3
COLORADO
Air Pollution Control Division
Department of Fk bf s f fealth & Environrrront
Page 23 of 28
-Specific Fuel Consumption Factor of 6,685 Btu/hp-hr, a site -
heat value of 1,006 Btu/scf.
CAS
Pollutant
Uncontrolled EFSource
Controlled EF Source
NOx
Manufacturer
Manufacturer
CO
Manufacturer
Manufacturer
VOC
Manufacturer
Manufacturer
50000
Formaldehyde
Manufacturer
Manufacturer
75070
Acetaldehyde
AP -42 Chapter 3 Table 3.2-2
AP -42 Chapter 3 Table 3.2-2
107028
Acrolein
AP -42 Chapter 3 Table 3.2-2
AP -42 Chapter 3 Table 3.2-2
67561
Methanol
AP -42 Chapter 3 Table 3.2-2
AP -42 Chapter 3 Table 3.2-2
Point 016:
Process 01:
Emissions from the amine unit result from venting of acid gas (still vent overhead). Additionally,
emissions result from the combustion of thermal oxidizer (TO) assist gas. Actual VOC, HAP and H2S
emissions from the venting of still vent acid gas shall be calculated based on the most recent monthly
still vent waste gas sampling and the most recent monthly measured still vent waste gas flow volume
as required by the permit. The following equation shall be used to in conjunction with the sample
and flow volume data to calculate actual emissions:
Weight %x Sample MW, lb lb — mole 1.0x106 scf Metered Still Vent Volume, MMscf
Emission Ratex = x
100 x lb — mole x 379 scf x 1 MMscf
Controlled emissions are as follows:
Month
Point Source
Control Efficiency
Still vent controlled by thermal oxidizer
98%
Flash tank recycled to plant inlet or routed to
plant fuel system
100%
SO2 emissions resulting from the combustion of H2S emissions in the still vent waste gas stream are
based on a mass balance. The mass balance utilizes molecular weights of 64.07 lb SO2/lb-mol and
34.08 lb H2S/lb-mol. The calculation assumes 100% of H2S in the still vent waste gas stream is
converted to 5O2 when combusted by the thermal oxidizer. The following equation shall be used to
calculate actual SO2 emissions:
lb ll _ H2S Still Vent Emission Rate, lb 64.07 lb SO2 lb — mol
SO2 Emission Rate (monthl month x lb — mol x 34.08 lb H2S
Emissions associated with the combustion of still vent waste gas by the thermal oxidizer are
calculated using the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF waste
gas combusted)
Controlled
Emission Factors
(lb/MMSCF waste
gas combusted)
Source
NOx
1.212
1.212
Manufacturer
CO
1.014
0.014
Manufacturer
Note: Emission factors in the table above are based on a still vent waste gas heat content of 12.36 Btu/scf. Actual
emissions are calculated by multiplying the emission factors in the table above by the total metered amine unit
still vent waste gas routed to the thermal oxidizer.
COPHE
COLORADO
Air Pollution Control Division
Department of Rea le Health b Environment
Page 24 of 28
rmal oxidizer:
CAS #
Pollutant
ncontrolled
Emission Factors
(lb/MMSCF assist
and pilot gas
combusted)
Controlled
Emission Factors
(lb/MMSCF assist
and pilot gas
combusted)
Source
N0x
100.94
100.94
AP 42 Chapter 1.4
Table 1.4-1
CO
84.46
84.46
AP -42 Chapter 1.4
Table 1.4-1
V0C
3.96
3.96
Mass Balance
Note: NOx and CO emission factors in the table above are based on a residue gas heat content of 1,030 Btu/scf.
Actual emissions are calculated by multiplying the emission factors in the table above by the assist gas volume for
the thermal oxidizer (as measured by flow meter). The VOC emission factors in the table above were calculated
based on the residue gas composition in the ProMax simulation (0.45% VOC by weight, molecular weight of16.68
lb/lbmol), standard molar volume of 379 scf/lbmol and VOC destruction efficiency of 98% for the thermal oxidizer.
Point 018 - 020:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/MMscf
Source
PM10
7.60
AP -42 Chapter 1.4
Table 1.4-2
PM2.5
7.60
N0x
50.00
CO
41.20
Manufacturer
V0C
5.50
AP -42 Chapter 1.4
Table 1.4-1
110543
n -hexane
1.80
Note: The emissions factors for this point are based on a fuel higher heating value of 1,030 Btu/scf.
Point 022:
Tank waste gas:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
N0x
6.15x10-4
6.15x10-4
AP -42 Chapter
13.5
CO
2.80x10-3
2.80x10-3
V0C
0.1990
0.0100
ProMax if EPA
Tanks 4.09d
71432
Benzene
0.0031
0.0002
108883
Toluene
0.0013
0.0001
100414
Ethylbenzene
0.0002
8.9x10-6
1330207
Xylenes
0.0003
1.3x10-5
Note: The controlled emissions factors for this point are based on the enclosed combustion device control
efficiency of 95%. The site specific VOC and HAP emission factors in the table above were developed
a stable oil (stabilized condensate) compositions from ProMax and EPA Tanks 4.09d for working and
breathing emissions. NOx and CO emissions factors are based on a gas flow rate of 1.11 scf per
barrel of stabilized condensate throughput. This GOR (1.11 scf/bbl) includes gas flow from the
loadout Point 023 with conservative assumption that the throughput to Point 022 is loaded out with
Point 023.
COLORADO
Air Pollution Control Division
Def#trtmen of Public Health Et Environment
Page 25 of 28
CAS #
Pollutant
ntrolled
Emission Factors
lb/MMscf pilot gas
combusted
Source
NOx
70.04
AP -42 Chapter
13.5
CO
319.30
Note: The emission factors for combustion of pilot fuel are based on a fuel higher heating value of 1,030
Btu/scf
Point 023:
Pollutant
CAS #
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
VOC
2.36E-1
1.18E-2
CDPHE PS MEMO
14-02
Benzene
71432
4.10E-4
2.05E-5
n -Hexane
110543
3.60E-3
1.80E-4
Controlled emission factors are based on a combustor control efficiency of 95%. Combustion of waste gas at the
enclosed combustor are reported with Point 022.
Point 024:
CAS #
Pollutant
Emission Factors
Uncontrolled
Source
lb/bbl
67561
Methanol
0.112
EPA TANKS
Point 025:
Emissions associated with the pressurized loadout of NGL result from gasses that are released from
hoses during disconnect. Emission factors in the table below are based on vapor and liquid line
volumes and specific gravity of the liquid unloaded.
CAS
Pollutant
Emission Factors
(lb/loadout event)
- Uncontrolled
Source
VOC
2.170
Engineering Calculation
Emission factors are based on depressurized liquid and vapor line volumes of 0.0736 ft /hose and
0.0436 ft3/hose respectively, vapor molecular weight of 12.1 lb/lbmol, and liquid density of 29.35
lb/ ft3. NGL liquid and vapor properties are based on facility ProMax simulation.
Point 026:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF purge
and pilot gas
combusted)
Controlled
Emission Factors
(lb/MMSCF purge
and pilot gas
combusted)
Source
NOx
70.04
70.04
AP -42 Chapter 13.5
CO
319.30
319.30
Note: NOx and CO emission factors in the table above are based on a residue gas heat content of 1,030 Btu/scf.
Actual emissions are calculated by multiplying the emission factors in the table above by the purge gas volume for
the flare (as measured by flow meter).
COLORADO
Air Pollution Control Division
Department of Pubf c Health 6 Eavironrnent
Page 26 of 28
4.1, eac it Pollutant Emission Notice (APEN) associated with this
rm ars fre 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) Points 013, 014, 015: These engines are 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
8) Point 013, 014, 015: These engines are 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
9) Point 002, : This source is subject to 40 CFR, Part 60, Subpart 0000a —Standards of Performance
for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction
Commenced After September 18, 2015 (See June 3, 2016 Federal Register posting - effective August
02, 2016). 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:
https://www.gpo.Rov/fdsys/pkg/FR-2016-06-03/pdf/2016-11971.pdf
10) Point 016 : This source is subject to 40 CFR, Part 60, Subpart 0000a —Standards of Performance
for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction
Commenced After September 18, 2015 (See June 3, 2016 Federal Register posting - effective August
02, 2016). 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:
https://www.gpo.gov/fdsys/pkg/FR-2016-06-03/pdf/2016-11971.pdf This unit is subject to
requirements including, but not limited to the following:
• §60.5365a - Applicability and Designation of Affected Facilities
o $60.5365a(g)(3) - Facilities that have a design capacity less than 2 long tons per
day (LT/D) of hydrogen sulfide (H2S) in the acid gas (expressed as sulfur) are
required to comply with recordkeeping and reporting requirements specified in
§60.5423a(c) but are not required to comply with 5S60.5405a through 60.5407a and
§560.5410a(g) and 60.5415a(g).
• §60.5423a - Record keeping and reporting Requirements
o §60.5423a(c) - To certify that a facility is exempt from the control requirements of
these standards, for each facility with a design capacity less that 2 LT/D of H2 S in
the acid gas (expressed as sulfur) you must keep, for the life of the facility, an
analysis demonstrating that the facility's design capacity is less than 2 LT/D of H2 S
expressed as sulfur.
11) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
12) This facility is classified as follows:
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 27 of 28
• : blew`
)Re_a it en
Status
Operating Permit
yn etic Minorource of: VOC, CO, HCHO, benzene, toluene,
xylenes, and total HAPs
PSD/NANSR
Synthetic Minor Source of: VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
MACT DDDDD
Not applicable
NSPS Dc
Applicable to point 018, 019, 020
NSPS Db
Not applicable
NSPS Kb
Applicable to point 022
NSPS KKK
Not applicable
NSPS LLL
Not applicable
NSPS OOOO
Not applicable
NSPS 0000a
Applicable
13) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ- Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
Department of Pub[S Health b ESnvi onrnent
Page 28 of 28
tess1),6 Oq/0ti /201(A
Fugitive Component Leak Emissions APEN
Form APCD-203
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 fugitive component leak emissions only. If your emission source does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: I7 W E 1090
AIRS ID Number:
123 /9F67/002
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name1: Cureton Front Range LLC
Site Name: Front Range Gas Plant
Site Location: SENE, Sec. 19, T2N, R64W
Mailing Address:
(Include Zip Code) 518 17th Street, Suite 650
Denver, CO 80202
Site Location
County:
Weld
NAICS or SIC Code: 1321
Contact Person: Nick Holland
Phone Number: 303-324-5967
E -Mail Address2: nick.holland@curetonrridstream.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-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 1 I
C,LQMADC3
mrctetc
Permit Number: I7W E 1090
AIRS ID Number. 123 / 9F67 / 002
[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)
-OR -
❑✓ MODIFICATION to existing permit (check each box below that applies)
✓❑ Change process or equipment ❑ Change company name3 ❑ Add point to existing permit
❑✓ Change permit limit ❑ Transfer of ownership4 ❑ 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 Et Notes: Modify to include components from additional
-- 200 MMSCF plant
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
Company equipment Identification No. (optional): FUG
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
TBD
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Facility Type:
❑ Well Production Facility5
❑ Natural Gas Compressor Stations
❑✓ Natural Gas Processing Plants
❑ Other (describe):
hours/day
days/week weeks/year
5 When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII.
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 2 I
Permit Number:
17WE1090
AIRS ID Number:
123 /9F671002
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Regulatory Information
What is the date that the equipment commenced construction?
TBD
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes
Will this equipment be located at a stationary source that is considered a Yes
Major Source of Hazardous Air Pollutant (HAP) emissions?
Are there wet seal centrifugal compressors or reciprocating compressors 0 Yes
located at this facility?
Is this equipment subject to 40 CFR Part 60, Subpart KKK? ❑ Yes
Is this equipment subject to 40 CFR Part 60, Subpart OOOO? O Yes
Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? 0✓ Yes
Is this equipment subject to 40 CFR Part 63, Subpart HH? ❑ Yes
Is this equipment subject to Colorado Regulation No. 7, Section XII.G? 0 Yes
Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? O Yes
Yes
Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3?
▪ No
0 No
No
• No
• No
No
❑✓ No
No
E] No
No
Section 5 - Stream Constituents
0 The required representative gas and liquid extended analysis (including BTEX) to support the data below has
been attached to this APEN form.
Use the following table to report the VOC and HAP weight % content of each applicable stream.
Gas
26.30
0.0017
0.01.37
0.0022
0.0033
0.2508
0.0146
Heavy Oil
(or Heavy Liquid)
100
2
2
2
2
2
Light Oil
(or Light Liquid)
100
2
2
2
2
2
Water/Oil
<1%
Section 6 - Geographical Information
40.127056/-104.586044
Attach a topographic site map showing location
A
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 3 I
Permit Number:
17WE1090
AIRS ID Number: 123 / 9F67/002
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Leak Detection and Repair (LDAR) and Control Information
Check the appropriate boxes to identify the LDAR program conducted at this site:
LDAR per 40 CFR Part 60, Subpart KKK
Monthly Monitoring - Control: 88% gas valve, 76% light liquid valve, 68% light liquid pump
❑ Quarterly Monitoring - Control: 70% gas valve,, 61% light liquid valve, 45% light liquid pump
0✓ LDAR per 40 CFR Part 60, Subpart OOOO/OOOOa
p Monthly Monitoring - Control: 96% gas valve, 95% light liquid valve, 88% light liquid pump, 81%
connectors
O LDAR per Colorado Regulation No. 7, Section XVII.F
O Other6:
O No LDAR Program
6 Attach other supplemental plan to APEN form if needed.
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 4 I
Permit Number:
17WE1090
AIRS ID Number:
123 /9F67/ 002
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emission Factor Information
Select which emission factors were used to estimate emissions below. If none apply, use the table below to
identify the emission factors used to estimate emissions. Include the units related to the emission factor.
Q✓ Table 2-4 was used to estimate emissions7.
▪ Table 2-8 (< 10,000ppmv) was used to estimate emissions7.
Use the following table to report the component count used to calculate emissions. The component counts listed
in the following table are representative of:
❑✓ Estimated Component Count
E Actual Component Count conducted on the following date:
Count8
2337
7
2327
213
4799
Emission Factor
-- —'Units
__Count8 _ .
2136 --- —
1086 - -
46
1099 —
Emission Factor
Units
Count8
2136
1526
9
49
1535
Emission Factor
Units
Count8
Emission Factor
Units
7 Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates (Document EPA -453/R-
95-017).
8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the "Actual
Calendar Year Emissions" below.
9 The "Other" equipment type should be applied for any equipment other than connectors, flanges, open-ended lines, pump
seals, or valves.
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 5
Benzene_..
71432
Uncontrolled Controlled"'
(lbs/year) fibs/year;
Permit Number:
17WE1090
AIRS ID Number: 123 /9F67/002
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
From what year is the following reported actual annual emissions data?
2019
Use the following table to report the criteria pollutant emissions and non -criteria pollutant (HAP) emissions from source:
Use the data reported in Section 8 to calculate these emissions.)
Chemtca[
_....,"
'a
_..
a'
,
���°�Ac
dVumber
<...,.. '.. ..
ua("Annual Emissions
``Re nested Annua Permit Emission ' s
q i�
Limit(s)
Uncontrolled
(tons/year)
Controlled
(tons/year}1
U
{toncontrons/year)lled
Controlled
tonsl ear
}�
VOC
91.16
18.56
Does the emissions source have any actual emissions of non -criteria pollutants
(e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
�✓ Yes ❑ No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
tal Requested Annual Permit Emission
Anndal Emissions
Ltmit(s)�i,
Uncontrolled
(ibsfyear)
Controlled'
(lbslyear):
398 -- _ -
Toluene
108883
4-3g 22.A
406
Ethylbenzene
100414
398
Xylene
1330207
6•)2t r
399
n -Hexane
110543
106b -AS
562
2,2,4
Trimethylpentane
540841
Other:
1° Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
11 Requested values will become permit limitations. Requested limit(s) should consider future process growth, component count
variability, and gas composition variability.
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 6 I
Permit Number:
17WE1090
AIRS ID Number: 123 /9F671002
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
Nicholas Holland
Digitally signed by Nicholas Holland
Date: 2019.04.04 10:07:53 -06'00'
4/4/19
Signature of Legally Authorized Person (not a vendor or consultant) Date
Nick Holland
Director EHS&R
Name (print)
Title
Check the appropriate box to request a copy of the:
❑✓ 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 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-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018
71
COLORADO
IIn . aof PaNk
mt ,v
RECEIVED
DEC 1 '0 J18
APCD
Gas Venting APEN — Form APCD-211 eTZ/oory
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 separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 17WE1090
AIRS ID Number: 123 /9F67 /005
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Cureton Front Range LLC
Site Name: Front Range Gas Plant
Site Location: SENE, Sec. 19, T2N, R64W
Mailing Address: 518 17th Street, Suite 650
(Include Zip Code)
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1321
Contact Person:
Phone Number:
E -Mail Address2: nick.holland@curetonmidstream.com
Nick Holland
303-324-5967
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.
390922
Form APCD-211 - Gas Venting APEN - Revision 7/2018
COLORADO
1 I AV'
IAnotAltsic
Permit Number: 17WE1090
AIRS ID Number:
123 /9F67/005
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
O NEW permit OR newly -reported emission source
-OR-
Q MODIFICATION to existing permit (check each box below that applies)
❑✓ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
✓❑ Change permit limit ❑ Transfer of ownership4 O 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: Add two recievers and update gas analysis
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: Pigging receivers
Company equipment Identification No. (optional): Pigging
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
TBD
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Will this equipment be operated in any NAAQS
nonattainment area?
hours/day
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?
Form APCD-211 - Gas Venting APEN - Revision 7/2018
days/week weeks/year
O Yes
❑ Yes
❑ Yes
❑ No
O No
O No
COLORADO
2
Permit Number: 17WE1090
AIRS ID Number: 123 / 9F67 / 005
[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
Make: Model:
❑ Blowdown Events
# of Events/year:
❑✓ Other
Serial #: Capacity: gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
Description: Depressurization of receiver to remove pig
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? ❑ Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑✓ No
Vent Gas
Heating Value:
BTU/SCF
Requested:
0.8
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
22.28
VOC (Weight %)
25.03
Benzene (Weight %)
0.0016
Toluene (Weight %)
0.0130
Ethylbenzene (Weight %)
0.0021
Xylene (Weight %)
0.0032
n -Hexane (Weight %)
0.2386
2,2,4-Trimethylpentane (Weight %)
0.0173
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-211 - Gas Venting APEN - Revision 7/2018
pp COLORADO
3 I mm�
rc«ano-€�,ouv
Permit Number: 17WE1090
AIRS ID Number:
123 19F67/005
[Leave blank unless APCD has already assigned a permit A and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.127056/-104.586044
O erator!,
p
Stack ID No.
Discharge. Height
Above Ground Level
(Feet)
Temp
(`F)
Flow Rate
(ACFM)
Velocity
{ft/sec)
Pigging
6
Ambient
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
O Horizontal
ElEl Downward
Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular
Other (describe):
Interior stack diameter (inches):
Upward with obstructing raincap
2
Section 6 - Control Device Information
0 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: p Yes No Pilot burner Rating: MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-211 - Gas Venting APEN - Revision 7/2018
4i
COLORADO
tigxiii�t F,nn�rgnn�Ynl
Permit Number: 17WE1090
AIRS ID Number: 123 / 9F67 /005
[Leave blank unless APCD has already assigned a permit f 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 Methods
Method(s)
Overall Requested
Control l Efficiency (% reduction in emissions)
PM
SOX
NO.
CO
VOC
HAPs
Other:
From what year is the following reported actual annual emissions data?
2019
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SOX
NO.
CO
VOC
0.0157
Ib/scf
mass balance
6.08
6.08
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
Emissions6
(pounds/year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
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
pp COLORADO
Hrunhy Rnnronrtw.l
Permit Number: 17WE1090
AIRS ID Number:
123 /9F671005
[Leave blank unless APCD has already assigned a permit ft and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
Signature 6 Legally Authorized Person (not a vendor or consultant)
Nick Holland
Date
Director EHS&R
Name (please print) Title
Check the appropriate box to request a copy of the:
ID Draft permit prior to issuance
❑✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-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/cdphe/apcd
Form APCD-211 - Gas Venting APEN - Revision 7/2018
6 I AV.COLOR A 06
Ir
Ott 161019
Reciprocating Internal Combustion acp
Engine APEN - Form APCD-201 Sources
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 reciprocating internal combustion engines (RICE). If your engine is a diesel compression
ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for
your source (e.g. diesel 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 will not satisfy your
reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: Ilk/6/090 AIRS ID Number: 123 /9F67 /013
[Leave blank unless APCD has already assigned a permit ft and AIRS ID]
Section 1 - Administrative Information
Company Name': Cureton Front Range LLC
Site Name: Front Range Gas Plant
Site Location: SENE, Sec. 19, T2N, R64W
Mailing Address:
(include Zip Code) 518 17th Street, Suite 650
Portable Source
Home Base:
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1321
Permit Contact: Nick Holland
Phone Number: 303-324-5967
E -Mail Address2: nickholland@curetonmidstream.com
1
Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
3Et48i5.
COLORADO
1 I �� Department el....VV H,atat Ty..upnmeet
Permit Number:
AIRS ID Number: 123 /9F67 /013
[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)
❑ STATIONARY source O PORTABLE source
❑ 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 $1,500.00 must be submitted along
with the APEN Filing fee.
OR -
O 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 ownership4 0 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
O Notification of Alternate Operating Scenario (AOS) permanent replacements
Additional Info Et Notes: Convert GP02 to construction permit
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
5 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)? yes
If yes, provide the Company Equipment Identification No.
General description of equipment and purpose: Compression
ENG1
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 Hours of Source Operation: 24
Seasonal use percentage: Dec -Feb: 25
TBD
Yes ❑ No
hours/day 7 days/week 52 weeks/year
Mar -May: 25 June -Aug: 25 Sept -Nov: 25
Form APCD-201 - Reciprocating internal Combustion Engine APEN - Revision 1/2017
•W COLORADO
2 I bap
aErvvir.0
Permit Number:
AIRS ID Number: 123 /9F67 /013
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Engine Information
Engine
Function:
❑ Primary and/or Peaking
O Pump O Water Pump
❑ Emergency Back-up
❑ Other:
✓❑ Compression
What is the maximum number of hours this engine will be used for emergency
back-up power? 0
Engine Make: Caterpillar
hours/year
Engine Model: 3608LE - A4 Serial Number': XH700907
What is the maximum designed horsepower rating? 2500 hp What is the engine displacement? 21.2 l/cyl
What is the maximum manufacturer's site -rating? 2500 hp kW
What is the engine Brake Specific Fuel Consumption at 100% Load? 6685 BTU/hp-hr
Engine Features:
Cycle Type: O 2 -Stroke 0 4 -Stroke Combustion: ❑✓ Lean Burn O Rich Burn
Ignition Source: 0 Spark O Compression Aspiration: O Natural 0 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? O O2 Sensor (mV) ❑NOx Sensor (ppm) ❑Q Other:
Is this engine equipped with a Low-NOX design? 0 Yes O No
Engine Dates:
What is the manufactured date of this engine? 4/13/2018
What date was this engine ordered? NA
What is the date this engine was first located to Colorado? 2018
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? NA
Is this APEN reporting an AOS replacement engine? O Yes 0 No
If yes, provide the make, model, and serial number of the old engine below:
Engine Make:
Engine Model: Serial Number:
6 The serial number must be submitted if coverage under GP02 is requested.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
3AY
Clapnrionntrof Public
COLORADO
NwNE bbrtrmoumni
Permit Number:
AIRS ID Number: 123 /9F67 / 013
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.127056/-104.586044
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp.
rF)
Flow Rate
(ACFM)
Velocity
(ft/sec)
ENG1
20
833
16088
151.7
Indicate the direction of the Stack outlet: (check one)
0 Upward
0 Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
0 Circular
❑ Square/Rectangle
❑ Other (describe):
Interior stack diameter (inches):
18
0 Upward with obstructing raincap
Interior stack diameter (inches): Interior stack depth (inches):
Section 6 Fuel Data and Throughput Information
Fuel Use Rate @ 100% Load
(SCF/hour)
Actual Annual Fuel Use
(MMSCF/year)
Requested Annual Permit Limit'
(MMSCF/year)
16,613
145.5
From what year is the actual annual amount? 2019
Indicate the type of fuel used8:
❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf)
0 Field Natural Gas Heating value: 1006 BTU/scf
❑ Propane (assumed fuel heating value of 2,300 BTU/scf)
❑ Landfill Gas Heating Value: BTU/scf
❑ Other (describe): Heating Value (give units):
7 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
8 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1 /2017 4 I E
COLORADO
Permit Number:
AIRS ID Number: 123 /9F67 /013
[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? 2 Yes O 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)
PM 10
PM 2.5
SOX
NOx
VOC
Oxidation Catalyst
22%
CO
Oxidation Catalyst
80%
Other:
HAPs - Oxidation Catalyst
80% HCOH, 50% all other HAPs
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?
2019
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions9
Requested Annual Permit
Emission Limit(s)7
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)
9.99E-3
lb/MMBtu
AP -42
0.73
0.73
PM10
9.99E-3
lb/MMBtu
AP -42
0.73
0.73
PM2.5
9.99E-3
lb/MMBtu
AP -42
0.73
0.73
SOX
5.88E-4
lb/MMBtu
AP -42
0.04
0.04
NOx
0.5
g/hp-hr
Manufacturer+
12.07
12.07
VOC
0.64
g/hp-hr
Manufacturer
15.47
12.07
CO
2.50
g/hp-hr
Manufacturer
60.35
12.07
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 lbs/year?
If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source:
❑✓ Yes O No
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service(CAS)
Emission Factor
Actual Annual Emissions9
Uncontrolled
Basis
Units
Number Mfg. etc) (Pounds/year)
Source
(AP -42,
Uncontrolled
Emissions
Controlled Emissions
(Pounds/year)
Pounds/
Formaldehyde
50000
0.23
g/hp-hr
Mfg.
11104.6
2220.9
Acetaldehyde
75070
8.36E-3
lb/MMBtu
AP -42
1223.9
612.0
Acrolein
107028
5.14E-3
lb/MMBtu
AP -42
752.5
376.3
Benzene
71432
Other:
Methanol
2.50E-2
Ib/MMBtu
AP -42
366.0
183.0
7 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
9 Annual emissions fees will be based on actual controlled emissions reported. If sourcehas not yet started operating, leave blank.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 5 LAY
COLORADO
b.prrwrewc
Nwlth a En...M.
Permit Number:
AIRS ID Number: 123 /9F67 /013
[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 02.
Nicholas Holland Digitally signed by Nicholas Holland
U Date: 2019.03.01 11:54:17 -07'W'
Signature of Legally Authorized Person (not a vendor or consukfant)
Nick Holland Director of EHS&R
Dg://1
at
Name (please print) Title
Check the appropriate box to request a copy of the:
O Draft permit prior to issuance
✓J Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
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 $152.90 and the General Permit For more information or assistance call:
registration fee of $1,500, 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
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
Make check payable to: https://www.colorado.gov/cdphe/apcd
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 6 I
A
COLOR A 00
�
aof o.
Reciprocating Internal Combustion
Engine APEN - Form APCD-201
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
RECSIVED
MAR1CIlilt
S
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 reciprocating internal combustion engines (RICE). If your engine is a diesel compression
ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for
your source (e.g. diesel 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 will not satisfy your
reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
7WE1090
AIRS ID Number: 123 /9F67 /014
[Leave blank unless APCD has already assigned a permit # and MRS ID]
Section 1 - Administrative Information
Company Name': Cureton Front Range LLC
Site Name: Front Range Gas Plant
Site Location: SENE, Sec. 19, T2N, R64W
Mailing Address:
(Include Zip Code) 518 17th Street, Suite 650
Portable Source
Home Base:
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1321
Permit Contact: Nick Holland
Phone Number: 303-324-5967
E -Mail Address2: nick.holland@curetonmidstream.com
1
Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
394816
AV COLORADO
I 1 rtd,�
Hw1:A 8 Gw�i(mm.nl
Permit Number:
AIRS ID Number: 123 /9F67 / 014
[Leave blank unless APCD has already assigned a permit # and MRS ID]
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source (check one below)
❑ STATIONARY source O PORTABLE source
❑ 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 $1,500.00 must be submitted along
with the APEN Filing fee.
-OR-
❑✓ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment O Change company name O Add point to existing permit
O Change permit limit ❑ Transfer of ownership4 • 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 replacements
Additional Info a Notes: Convert GP02 to construction permit
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
5 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)? yes
If yes, provide the Company Equipment Identification No.
General description of equipment and purpose: Compression
ENG2
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.govicdphe/attainment)
Normal Hours of Source Operation: 24
Seasonal use percentage: Dec -Feb: 25
TBD
❑� Yes ❑ No
hours/day 7 days/week 52 weeks/year
Mar -May: 25 June -Aug: 25 Sept -Nov: 25
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
AM COLORADO
2 i Ho
Dapnr 6rtnuwum,a.
Permit Number:
AIRS ID Number: 123 /9F67 /014
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Engine Information
Engine
Function:
❑ Primary and/or Peaking
O Pump O Water Pump
❑ Emergency Back-up
O Other:
p Compression
What is the maximum number of hours this engine will be used for emergency
back-up power? 0
Engine Make: Caterpillar
hours/year
Engine Model: 3608LE - A4 Serial Number': x O06703
What is the maximum designed horsepower rating? 2500 hp What is the engine displacement? 21.2 l/cyl
What is the maximum manufacturer's site -rating? 2500 hp kW y -r Pc. ?-er
What is the engine Brake Specific Fuel Consumption at 100% Load? 6685 BTU/hp-hr d�i`ta.4
Engine Features: 3/(3 ? / II
Cycle Type: O 2 -Stroke ❑✓ 4 -Stroke Combustion: ❑� Lean Burn O Rich Burn
Ignition Source: El Spark ❑ Compression Aspiration: O Natural ❑✓ Turbocharged 0'/ —
Is this engine equipped with an Air/Fuel ratio controller (AFRC)? ❑✓ Yes O No
If yes, what type of AFRC is in use? ❑ OZ Sensor (mV) ❑NOx Sensor (ppm)
Is this engine equipped with a Low-NOx design? Yes ❑ No
Engine Dates:
What is the manufactured date of this engine? 4/9/2018
What date was this engine ordered? NA
❑✓ Other:
What is the date this engine was first located to Colorado? 2018
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? NA
Is this APEN reporting an AOS replacement engine? O Yes 0 No
If yes, provide the make, model, and serial number of the old engine below:
Engine Make:
Engine Model: Serial Number:
6 The serial number must be submitted if coverage under GP02 is requested.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
COLORADO
3 AV Npastmant orPublir
11.1.bErtv.mor M
Permit Number:
AIRS ID Number: 123 /9F67 / 014
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.127056/-104.586044
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp.
('F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
ENG2
20
833
16088
151.7
Indicate the direction of the Stack outlet: (check one)
❑r Upward O Downward
O Horizontal
O Upward with obstructing raincap
O Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular
❑ Square/Rectangle
❑ Other (describe):
Interior stack diameter (inches):
18
Interior stack diameter (inches): Interior stack depth (inches):
Section 6 - Fuel Data and Throughput Information
Fuel Use Rate @ 100% Load `
(SCF/ hour)
Actual Annual Fuel Use
(MMSCF/year)
Requested Annual Permit Limit'
(MMSCF/year)
16,613
145.5
From what year is the actual annual amount? 2019
Indicate the type of fuel used':
❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf)
❑✓ Field Natural Gas Heating value: 1006 BTU/scf
❑ Propane (assumed fuel heating value of 2,300 BTU/scf)
❑ Landfill Gas Heating Value: BTU/scf
❑ Other (describe): Heating Value (give units):
7 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
8 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
W COLORADO
4 I AV b=..�uk
Hw1�T 66n»rq.uCm?.
Permit Number:
AIRS ID Number: 123 /9F67 /014
[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 0 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)
PM 10
PM2.5
SOX
NOx
VOC
Oxidation Catalyst
22%
CO
Oxidation Catalyst
80%
Other:
HAPs - Oxidation Catalyst
80% HCOH, 50% all other HAPs
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?
2019
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions'
Requested Annual Permit
Emission Limit(s)7
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)
9.99E-3
lb/MMBtu
AP -42
0.73
0.73
PM10
9.99E-3
lb/MMBtu
AP -42
0.73
0.73
PM2,5
9.99E-3
lb/MMBtu
AP -42
0.73
0.73
SOX
5.88E-4
lb/MMBtu
AP -42
0.04
0.04
NOx
0.5
g/hhp-hr
Manufacturer+
12.07
12.07
VOC
0.64
g/hp-hr
Manufacturer
15.47
12.07
CO
2.50
g/hp-hr
Manufacturer
60.35
12.07
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 lbs/year?
If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source:
❑✓ Yes ❑ No
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
(Pounds/year)
Formaldehyde
50000
0.23
g/hp-hr
Mfg.
11104.6
2220.9
Acetaldehyde
75070
8.36E-3
lb/MMBtu
AP -42
1223.9
612.0
Acrolein
107028
5.14E-3
lb/MMBtu
AP -42
752.5
376.3
Benzene
71432
Other:
Methanol
2.50E-2
lb/MMBtu
AP -42 '
366.0
183.0
7 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
9 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-201 - Reciprocating internal Combustion Engine APEN - Revision 1/2017 5 SAY
COLORADO
a rnam
MnuN bEnp.nmu:u
Permit Number:
AIRS ID Number: 123 19F67 /014
[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.
Nicholas Holland
Digitally signed by Nicholas Holland
Dale: 2019.03.01 11:54:49 -07'00'
Signature of Legally Authorized Person (not a vendor or consultant)
Nick Holland Director of EHS&R
VV5// 1
Da e
Name (please print) Title
Check the appropriate box to request a copy of the:
Q Draft permit prior to issuance
r❑ 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 $152.90 and the General Permit For more information or assistance call:
registration fee of $1,500, 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
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
Make check payable to: https://www.colorado.gov/cdphe/apcd
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
6 I COLORADO
NoaaaesnvuoNn.n,
Reciprocating Internal Combustion
Engine APEN - Form APCD-201
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
RECEIVED
MAR 1 B 2019
APcn
tt
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 reciprocating internal combustion engines (RICE). If your engine is a diesel compression
ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for
your source (e.g. diesel 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 will not satisfy your
reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/cdphefapcd.
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:
`1v/ /090
AIRS ID Number: 123 /9F67 /015
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Cureton Front Range LLC
Site Name: Front Range Gas Plant
Site Location: SENE, Sec. 19, T2N, R64W
Mailing Address:
(Include Zip Code) 518 17th Street, Suite 650
Portable Source
Home Base:
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1321
Permit Contact: Nick Holland
Phone Number: 303-324-5967
E -Mail Address2: nick.holland@curetonmidstream.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 APCD via e-mail to the address provided.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
3t54817
I . COLORADO
H!W:h4 FAY<fP�ntn1
Permit Number:
AIRS ID Number: 123 /9F67 /015
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
D NEW permit OR newly -reported emission source (check one below)
❑ STATIONARY source O PORTABLE source
❑ 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 $1,500.00 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 ❑ Change company name O Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership4 ✓❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Blank APENs will not be accepted)
- ADDrnONAL PERMIT ACTIONS -
❑ APEN submittal for permit-exempt/grandfathered source
❑ Notification of Alternate Operating Scenario (AOS) permanent replacements
Additional Info Ft Notes: Convert GP02 to construction permit
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
5 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)? yes
If yes, provide the Company Equipment Identification No.
General description of equipment and purpose: Compression
ENG3
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?
(htto://www.colorado.Rov/cdphe/attainment)
Normal Hours of Source Operation: 24
Seasonal use percentage: Dec -Feb: 25
TBD
✓❑ Yes ❑ No
hours/day 7 days/week 52 weeks/year
Mar -May: 25 June -Aug: 25 Sept -Nov: 25
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
2 IA.COLORADO
faz EEfV,otinxm
Permit Number:
AIRS ID Number: 123 /9F67 / 015
[Leave blank unless APCD has already assigned a permit #1 and AIRS ID]
Section 4 - Engine Information
Engine
Function:
❑ Primary and/or Peaking
❑ - Pump O Water Pump
O Emergency Back-up
O - Other:
0 Compression
What is the maximum number of hours this engine will be used for emergency
back-up power? 0
hours/year
Engine Make: Caterpillar Engine Model: 3608LE - A4 Serial Number6: )(4 7 9 9
What is the maximum designed horsepower rating? 2500 hp What is the engine displacement? 21.2 l/cyl
What is the maximum manufacturer's site -rating? 2500 hp kW
What is the engine Brake Specific Fuel Consumption at 100% Load? 6685 BTU/hp-hr
Engine Features:
Cycle Type: ❑ 2 -Stroke 0 4 -Stroke Combustion: ❑✓ Lean Burn ❑ Rich Burn
Ignition Source: 0 Spark O Compression Aspiration: O Natural El 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? O O2 Sensor (mV) ❑NOX Sensor (ppm) 0 Other:
Is this engine equipped with a Low-NOX design? ❑✓ Yes ❑ No
Engine Dates:
What is the manufactured date of this engine? 4/17/2018
What date was this engine ordered? NA
What is the date this engine was first located to Colorado? 2018
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? NA
Is this APEN reporting an AOS replacement engine? O Yes 0 No
If yes, provide the make, model, and serial number of the old engine below:
Engine Make: Engine Model: Serial Number:
6 The serial number must be submitted if coverage under GP02 is requested.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
3'� ,
COLORADO
Permit Number:
AIRS ID Number: 123 /9F67 / 015
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.127056/-104.586044
Operator
Stack ID No
Discharge Height
Above Ground Level
(Feet)
Temp.
(`F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
ENG3
20
833
16088
151.7
Indicate the direction of the Stack outlet: (check one)
❑✓ Upward 0 Downward
0 Horizontal
0 Upward with obstructing raincap
0 Other (describe):
Indicate the stack opening and size: (check one)
0 Circular
❑ Square/Rectangle
❑ Other (describe):
Interior stack diameter (inches):
18
Interior stack diameter (inches): Interior stack depth (inches):
Section 6 - Fuel Data and Throughput Information
Fuel Use Rate @ 100% Load
(SCF/hour)
Actual Annual Fuel Use
(MMSCF/year)
Requested Annual Permit Limit'
(MMSCF/year)
16,613
145.5
From what year is the actual annual amount? 2019
Indicate the type of fuel used':
❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf)
❑✓ Field Natural Gas Heating value: 1006 BTU/scf
0 Propane (assumed fuel heating value of 2,300 BTU/scf)
❑ Landfill Gas Heating Value: BTU/scf
❑ Other (describe): Heating Value (give units):
7 Requested values will become permit Limitations. Requested limit(s) should consider future process growth.
8 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
I A COLORADO
NwI'A 6SM1YWnmNW
Permit Number:
AIRS ID Number: 123 /9F67 /015
[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 0 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
22%
CO
Oxidation Catalyst
80%
Other:
HAPs - Oxidation Catalyst
80% HCOH, 50% all other HAPs
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?
2019
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions9
Requested Annual Permit
Emission Limit(s)7
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)
9.99E-3
lb/MMBtu
AP -42
0.73
0.73
PM10
9.99E-3
lb/MMBtu
AP -42
0.73
0.73
PM 2.5
9.99E-3
lb/MMBtu
AP -42
0.73
0.73
SOX
5.88E-4
lb/MMBtu
AP -42
0.04
0.04
NOx
0.5
gThp-hr
Manufacturer+
12.07
12.07
VOC
0.64
g/hp-hr
Manufacturer
15.47
12.07
CO
2.50
g/hp-hr
Manufacturer
60.35
12.07
Does the emissions source have any uncontrolled actual emissions of non -criteria o Yes ❑ No
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 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 Emissions'
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Pounds/year)
Controlled Emissions
(Pounds/year)
Formaldehyde
50000
0.23
g/hp-hr
Mfg.
11104.6
2220.9
Acetaldehyde
75070
8.36E-3
lb/MMBtu
AP -42
1223.9
612.0
Acrolein
107028
5.14E-3
lb/MMBtu
AP -42
752.5
376.3
Benzene
71432
Other:
Methanol
2.50E-2
lb/MMBtu
AP -42
366.0
183.0
7 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
9 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
COLORADO
5 �
Nwl:p &Eanm.vrww
Permit Number:
AIRS ID Number: 123 /9F67 /015
[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.
Nicholas Holland Digitally signed by Nicholas Holland
Holland Date: 2019.03.0111:55:16-07'00'
Signature of Legally Authorized Person (not a vendor or consultan
Nick Holland Director of EHS&R
3/1J7
Dat
Name (please print) Title
Check the appropriate box to request a copy of the:
0 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 $152.90 and the General Permit For more information or assistance call:
registration fee of $1,500, 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
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
or visit the APCD website at:
Make check payable to: https://www.colorado.gov/cdphe/aped
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
l R COLORADO
6 -=
t)oc L9o9)3
1..);6....
Amine Sweetening Unit - Form APCD-206
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 amine sweetening units only. If your emission unit does not fall into this category,
there may be a more specific APEN available for your source (e.g. glycol dehydration unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
-7WGtog0
AIRS ID Number: 123 / 9F67 / 01 G
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 Administrative Information
Company Name': Cureton Front Range LLC
Site Name: Front Range Gas Plant
Site Location: SENE Sec. 19, T2N, R64W
Mailing Address:
(Include Zip Code) 518 17th Street, Suite 650
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1321
Contact Person: Nick Holland
Phone Number: 303-324-5967
E -Mail Address2: nick.holland@curetonmidstream.com
1 Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-206 - Amine Sweetening Unit APEN - Revision 7/2018 1 I
COLORADO
ve�xoraan�
Permit Number:
AIRS ID Number: 123 / 9F67 /
[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 0 Change company name3 ❑ Add point to existing permit
❑ 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 -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info E: 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: Amine sweetening unit to remove CO2
and trace amounts of H2S. All TO combustion emissions included on this APEN.
Company equipment Identification No. (optional): Aminel
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: TBD
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Will this equipment be operated in any NAAQS
nonattainment area?
hours/day
Does this facility have a design capacity less than 2 long
tons/day of H2S in the acid gas?
days/week
Yes
Yes
weeks/year
COLOHADLY
Form APCD-206 - Amine Sweetening Unit APEN - Revision 7/2018 2 I
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Amine Unit Equipment Information
Manufacturer:
TBD
Model No.: TBD Serial Number: TBD
Absorber Column Stages: 7 stages
Amine Type: O MEA
Pump Make and Model: TBD
O DEA ❑ TEA
❑✓ MDEA O DGA
# of pumps: 2
Sour Gas Throughput:
Design Capacity: 200 MMSCF/day
Requested5: 73,000 MMSCF/year Actual:
MMSCF/year
Sour Gas:
Pressure: 1000 psig
Temperature: 59.9 °F
Lean Amine
Stream:
Pressure: 14
psia
Flowrate: 1000 gal/min
Mole loading H2S: -- 2/1E-5%
Temperature: 252.6 °F
Wt. % amine: 50.1
Mole Loading 0.08%
CO2:
Pressure: -_ psia
Temperature:
NGLlnput:
Flowrate:
Gal/min
Flash Tank:
O No Flash Tank
Pressure: 65 psia
Temperature: 107 °F
Additional Required Information:
▪ Attach a Process Flow Diagram -
❑✓ Attach the simulation model inputs Et emissions report
✓❑ Attach composition reports for the rich amine feed, sour gas feed, NGL feed, a outlet stream (emissions)
✓❑ Attach the extended gas analysis (including BTEX Et n -Hexane, H2S, CO2, temperature, and pressure)
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-206 - Amine Sweetening Unit APEN - Revision 7/2018 3 I
tOLORAD0
Ik7treamattcd
xwsnea romx.1
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
40.127056/-104.586044
eta :n
.�
„aA.
o
(d��jtfsr
TO
TBD
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
O Horizontal
❑ Downward
❑ Other (describe):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches): TBD
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑ Other (describe):
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.
O VRU:
Used for control of:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Make/Model:
%
❑ Combustion
Device:
Used for control of: VOC and HAPs from still vent
Rating: 27.5 MMBtu/hr
Type: Thermal Oxidizer Make/Model: TBD
Requested Control Efficiency: 98 %
Manufacturer Guaranteed Control Efficiency: 99+
Minimum Temperature: `F Waste Gas Heat Content: —12 Btu/scf
Constant Pilot Light: 0 Yes ❑✓ No Pilot Burner Rating: MMBtu/hr
Supplemental Fuel Flow: 184 MMscf /year
Supplemental Fuel Heat Content: 1030 Btu/scf
Closed
El Loop
System:
Used for control of: Flash tank
Description: Closed loop to fuel or inlet
System Downtime: 0 %
O Other:
Used for control of:
Description:
Requested Control Efficiency:
Form APCD-206 - Amine Sweetening Unit APEN - Revision 7/2018 4
Benzene
Permit Number:
AIRS ID Number: 123 / 9F67 / (916
[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
overall (or combined) control efficiency (%reduction):
PM
be used to state the
Overall Requested
Control Efficiency
(% reduction in emissions)
SO.
H2S
TO
98%
NO.
CO
VOC
TO
98%
HAPs
TO
98%
Other:
From what year is the following reported actual annual emissions data? 201 9
0:00328
lb/MMSCF
Mass Balance
Criteria Po
PM-
scions Inventory
ual Annual Emissions
controlled
fissions
(tonslyear)
Contralle
Emissions
tons/year,
Requested Annual Perri)
Emission
Uncontrolled Controlled'
Errxissrons.. ' _ Emissicns„,
ens/year) (tanslyear}";
SOx
H2S
0.087
lb/MMSCF
Promax
3.18
848s t
0.06
NO),
CO
0.098
0.082
Ib/MMBtu
ib/M MBtu
Mfg.
Mfg.
10.1810,g 10.18033
8.52j,.(y11
VOC
4.614
Ib/MMSCF
Promax
M%3 4.97.
Non -Criteria Reportable Pollutant Emissions Inventory
-Chemical Emission Factor
Abstract
Service (CAS)
Number.'
1.975
lb/MMSCF
Promax
Actual Annual Emissions
Uncontrolled
Emissions
(pounds/year)
Controlled,
Em ssrons6
(poundsl year) ;
71432
Toluene
108883
1.028
lb/MMSCF
Promax
2884
-;6,3C6
1501
Ethylbenzene
Xylene
100414
1330207
0.133
0.297
Ib/MMSCF
lb/MMSCF
Promax
Promax
9gs7
195
434
n -Hexane
2,2,4-
Trimethylpentane
110543
540841
0.016
lb/MMSCF
Promax
G8'U
23
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.
....................
1; 56
Form APCD-206 - Amine Sweetening Unit APEN.- Revision 7/2018
51
Permit Number:
AIRS ID Number: 123 / 9F67 /
[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.
Nicholas Holland
Digitally signed by Nicholas Holland
Date: 2019.03.01 11:56:05 -0700'
Signature of Legally Authorized Person (not a vendor or consultant) Date
Nick Holland
Director EHS&R
Name (print)
Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-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-206 - Amine Sweetening Unit APEN - Revision 7/2018
6I
COLORARO
n .�e�a3m rxek
o ` t /OBI /;_o1
c3goc IS -
Boiler APEN - Form APCD-220
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 boilers, hot oil heaters, process heaters, and similar equipment. If your emission unit
does not fall into one of these categories, there may be a more specific APEN for your source (e.g. print shop,
mining operations, engines, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN
options wilt not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD) website at: www.colorado.gov/cdphe/apcd.
Do not complete this form for the following source categories:
- Heaters or boilers with a design capacity less than or equal to 5 MMBtu/hour that are fueled solely by
natural gas or liquid petroleum gas (LPG). •
Heaters or boilers with a design capacity less than or equal to 10 MMBtu/hour used solely for heating
buildings for personal comfort that are fueled solely by natural gas or liquid petroleum gas (LPG).
More information can be found in the APEN exempt/permit exempt
checklist: https://www.colorado.gov/pacific/cdphe/apen-or-air-permit-exemptions.
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:
—AIRS ID
Number:
123 -/ 9F671 —g
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Namet:
Site Name:
Site Location:
Cureton Front Range LLC
Front Range Gas Plant
Site Location
SENE Sec. 19, T2N, R64W County: Weld
Mailing Address:
(Include Zip code) 518 17th Street, Suite 650
Denver, CO 80202
NAICS or SIC Code: 1321
Contact Person: Nick Holland
Phone Number: 303-324-5967
E -Mail Address2: nick.holland@curetonnvdsream.com
I Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
cac�xxoo
Form APCD-220 - Boiler APEN - Revision 7/2018
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
✓❑ NEW permit OR newly -reported emission source
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment 0 Change company name3 0 Add point to existing permit
❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
❑ APEN submittal for permit exempt/grandfathered source
Additional Info £t 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:
Mol sieve regen gas heater
Manufacturer: TBD Model No.: TBD Serial No.: TBD
Company equipment Identification No.
(optional):
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
HTR4
TBD
• Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Seasonal use Dec -
percentage: Feb:
hours/day
Mar -
May:
days/week weeks/year
June -
Aug:
Sept -
Nov:
Are you reporting multiple identical boilers on this APEN? ❑ Yes ❑✓ No
If yes, please describe how the fuel usage will be measured for each boiler (i.e., one meter for all boilers
or separate meters for each unit):
ctriaaexoo
Form APCD-220 - Boiler APEN - Revision 7/2018 2 I
Permit Number:
AIRS ID Number:
123 /9F67/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Stack Information
GeographicalCoordinates
'
atitudefLongitude or UTM)
40.127056/-104.586044
a„
HTR4
TBD
800
2903
9.86
Indicate the direction of the stack outlet: (check one)
0✓ Upward
O Horizontal
▪ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
Circular
Interior stack diameter (inches):
O Upward with obstructing raincap
30
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
0 Other (describe):
Section 5 - Fuel Consumption Information
Design Input Rafe
BTiII}�r
Actual Annual Fuel Uses
(Specify Untts)
Reg uested'Annual Permit
��x
Lin -iii?''; --10,-4.,N,,
(SpecifyUntfs)k,
20.0
170.1 MMSCF/yr
From what year is the actual annual fuel use data?
Fuel consumption values entered above are for: O Each Boiler O All Boilers ❑✓ N/A
Indicate the type(s) of fuel used7:
O Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF)
0 Field Natural Gas Heating value: 1030 BTU/SCF
❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon)
❑ Propane
❑ Coal
O Other (describe):
(assumed fuel heating value of 2,300 BTU/SCF)
Heating value:
BTU/lb — Ash content: Sulfur Content:
Heating value (give units):
5 If you are reporting multiple identical boilers on one APEN, be sure to clarify if the values in this section are on an individual
boiler basis, or if the values represent total fuel usage for multiple boilers.
6 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
7 If fuel heating value is different than the listed assumed value, please provide this information in the "Other" field.
6 •
R_A....D.._._
CLTL#3D
Form APCD-220 - Boiler APEN - Revision 7/2018 3 I
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Criteria Pollutant Emissions information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? _❑ Yes .. _ [] No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction)
TSP (PM)
PM:0
PM2.5
Sox
NOx
CO
VOC
From what year is the following reported actual annual emissions data?
2019
Use the following tables to report the criteria pollutant emissions from source:,
(Use the data reported in Section 5 to calculate these emissions.)
ission,;
Natural
Gas -_.-
7.6
TSP (PM)
AF' -42
0.65
€ontr
tans
PM: o _-
7.6 AP -42
0.65
PM2.5
7.6
AP -42
0.65
SOx
0.6 AP -42
0.05
NOx
50 AP -42
4.25
CO
41 Mfg.
3.50
VOC
5.5 AP -42
0.47
✓D Check this box if multiple fuels were NOT fired during this reporting period and skip to Section 7.
If multiple fuels were fired during this reporting period, complete this secondary fuel emissions table and the
total criteria pollutant emissions table below:
Secondary
Fuel Type,:,
(#2 diesel,
asteoif, etc
TSP (PM)
Uncontrolled
Emissiann
Factor
ipecijy Ur its)
Emission
Factor
Source"
(A,D 42,
.h1f5 , etc.)
Uncantrolled';
(tnnc/year) ,
rcontrolled.
ontrolled -:
ear
PM10
PM10
PM2.5
SOx
NOx
CO
VOC
6 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
a Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
coc�>`aaz�
Form APCD-220 Boiler APEN - Revision 7/2018 4 I
n -Hexane
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
If multiple fuels were fired during this reporting period, use the following table to report the TOTAL criteria
pollutant emissions from the source. Values listed below should be the sum of the reported emissions from the
primary and secondary fuels' emissions tables in this Section 6:
TSP (PM)
trite
td`dsl year,
!ns/
tro
isly
PMto
PM2.s
SOx
NOx
CO
VOC
6 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Section 7 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria Yes ❑ No
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 Lbs/year?
_. f yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:..__.
rsmary.Fuel.Type (natural gas, #2 diesel. etc_) Natural Gas
£?vsrall dncontrolted"
Control Emission
a . Factory
Efficiency u "i
specify »zr. ��
0.075 b/MMSCF
AP -42
ncontro(ieci Controlled
Actual Actual
Emissions Emissions
(lbsi year)';' (lbsl year)
0✓ Check this box if multiple fuels were NOT fired during this reporting period and skip to Section 8.
If multiple fuels were fired during this reporting period, complete this secondary fuel emissions table and the
total non -criteria pollutant (HAP) emissions table below:
Secondary Fue'
yPe ( `2 diesel, "heste oil et
Overall
Control
Efficiency
Uncontrolled
Factor
.peciTy unit
! 1ncontrotlei
Actual
Emissions'
(tbs l year)
Controlled
Actual
Emissions
(lbsl year3
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, Leave
blank.
Form APCD-220 - Boiler APEN - Revision 7/2018
51
Permit Number:
AIRS ID Number: 123 I 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
If multiple fuels were fired during this reporting period, use the following table to report the TOTAL non -criteria
pollutant (HAP) emissions from the source. Values listed below should be the sum of the reported emissions from
the primary and secondary fuels' emissions tables in this Section 7:
ncontroll;
ea
nsi
ontrollel
tonslyea
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
Nicholas Holland
Digitally signed by Nicholas Holland
-Date: 2019.04.04 10:08:15 -06'00'
4/4/19
Signature of Legally Authorized Person (not a vendor or consultant) Date
Nick Holland
Director EHS&R
Name (please print)
Title
Check the appropriate box if you want:
Draft permit prior to public notice
❑✓ Draft of the permit prior to issuance
(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 reportablechange 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
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
For more information or assistance call:
Health and Environment Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Make check payable to:
Colorado Department of Public Heath and Environment
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
Form APCD-220 - Boiler APEN - Revision 7/2018
6I
Rew +) aocAJ39 y S l
z.e.ce,;\ 04 /oci /,2O\6
Boiler APEN - Form APCD-220
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 boilers, hot oil heaters, process heaters, and similar equipment. If your emission unit
does not fall into one of these categories, there may be a more specific APEN for your source (e.g. print shop,
mining operations, engines, 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.Rov/cdphe/apcd.
Do not complete this form for the following source categories:
Heaters or boilers with a design capacity less than or equal to 5 MMBtu/hour that are fueled solely by
natural gas or liquid petroleum gas (LPG).
Heaters or boilers with a design capacity less than or equal to 10 MMBtu/hour used solely for heating
buildings for personal comfort that are fueled solely by natural gas or liquid petroleum gas (LPG).
More information can be found in the APEN exempt/permit exempt
checklist: https://www.colorado.Rov/pacific/cdphe/apen-or-air-permit-exemptions.
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: \-9 U TO
— --AIRS ID —
Number: 123 /9F67/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Cureton Front Range LLC
Site Name: Front Range Gas Plant
Site Location: SENE Sec. 19, T2N, R64W
Mailing Address:
(Include zip code) 518 17th Street, Suite 650
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1321
Contact Person: Nick Holland
Phone Number: 303-324-5967
E -Mail Address2: nick.holland@curetonmidsream.com
i Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-220 - Boiler APEN - Revision 7/2018
1
COLORA DO
tk....artdr tc
Permit Number:
AIRS ID Number: 123 I 9F67 /
[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 0 Change company name3 0 Add point to existing permit
❑ Change permit limit 0 Transfer of ownership4 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)
❑ APEN submittal for permit exempt/grandfathered source
Additional Info Ft 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: Hot oil heater
Manufacturer: TBD Model No.: TBD Serial No.: TBD
Company equipment Identification No.
(optional):
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
HTR6
TBD
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Seasonal use Dec -
percentage: Feb:
hours/day
Mar -
May:
days/week weeks/year
June -
Aug:
Sept -
Nov:
Are you reporting multiple identical boilers on this APEN? ❑ Yes 0 No
If yes, please describe how the fuel usage will be measured for each boiler (i.e., one meter for all boilers
or separate meters for each unit):
Form APCD-220 - Boiler APEN - Revision 7/2018 2 I
coy.) RA DB
otmstic
55.0
Permit Number:
AIRS ID Number:
123 /9F671
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Stack Information
Geographical` Coordinates?
a* LatitudefLongtude or UTM)
40.127056/-104.586044
r e Oi
� s � _
@
.. '�S"�:S�zszr'�,
o L-ya '"
e
HTR6
TBD
800
7984
18.8
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
O Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
❑ Square/rectangle Interior stack width (inches):
❑ Other (describe):
O Upward with obstructing raincap
36
Interior stack depth (inches):
Section 5 - Fuel Consumption Information
dual Annual Fuel U`'
(Specify Units)
Requested Annual Permit
Limits
(Specify Units),
467.8 MMSCF/yr
From what year is the actual annual fuel use data?
Fuel consumption values entered above are for: O Each Boiler ❑ All Boilers 0 N/A
Indicate the type(s) of fuel used7:
O Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF)
✓❑ Field Natural Gas Heating value: 1030 BTU/SCF
O Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon)
❑ Propane
❑ Coal_
❑ Other (describe): -
(assumed fuel heating value of 2,300 BTU/SCF)
Heating value:
BTU/lb Ash content: Sulfur Content:
Heating value (give units):
5 If you are reporting multiple identical boilers on one APEN, be sure to clarify if the values in this section are on an individual
boiler basis, or if the values represent total fuel usage for multiple boilers.
6 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
7 If fuel heating value is different than the listed assumed value, please provide this information in the "Other" field.
Form APCD-220 - Boiler APEN - Revision 7/2018 3
TSP (PM)
Permit Number:
AIRS ID Number: 123 I 9F67 i
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? . _ 0 Yes __ 0 No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Overall Control
Efficiency
reduction in emissions;
PMio
PM2.s
Sox
NO.
CO
VOC
From what year is the following reported actual annual emissions data?
2019
Use the following tables to report the criteria pollutant emissions from source:
(Use the data reported in Section 5 to calculate these emissions.)
Emission
Fector
source
(AP -42, Uncontrolled
Jg., etc.) (ton,iyear}
TSP (PM)
Natural
Gas
Uncontrolled
Emission
Factor
7.6
AP -42
Controlled°
(tons/year)
Uncontrolled C,ontrolle�
(ronsfyear) ("tons year}
1.78
PMio -
7.6 -
AP -42
1.78
PM2.5 _
/.6
AP -42
—1.78
SOX
0.6
AP -42
0.14
NO),
50
AP -42
11.69
CO
41
Mfg.
9.64
VOC
5.5
AP -42
1.29
0 Check this box if multiple fuels were NOT fired during this reporting period and skip to Section 7.
If multiple fuels were fired during this reporting period, complete this secondary fuel emissions table and the
total criteria pollutant emissions table below:
TSP (PM,)
PMio
>Emission
Factor
Source
(AP-47,
Mfg., etc.)
Uncon)ro
(tons/year
6)14O
antrolled
onslyear
PM2.s
SOX,
NO),
CO
VOC
6 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
i_
Form APCD-220 - Boiler APEN - Revision 7/2018
4!
n -Hexane
Permit Number:
AIRS ID Number: 123 I 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
If multiple fuels were fired during this reporting period, use the following table to report the TOTAL criteria
pollutant emissions from the source. Values listed below should be the sum of the reported emissions from the
primary and secondary fuels' emissions tables in this Section 6:
TSP (PM)
controlled
o tsf year)
o`ntrotledsgr'
cnslyear)
Uncontrolled
(tons/ year)
Centrotfe
(fons/year,
PM10
PMi.5
SOX
N0x
CO
V0C
6 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Section 7 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria ❑✓ Yes
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Natural Gas
verall
Control._.
Efficiency
Uncontrolled Emission Facti
Emission Source
Factor.. F (?P-.42 Mf3 , etc,
specify units)
0.075 Ib/MMSCF
AP -42
❑ No
ncontrolled Controlled
Actual. Actual
E;nissions Emissions
(tbs/year) (lbs/year)
842
❑✓ Check this box if multiple fuels were NOT fired during this reporting period and skip to Section 8.
If multiple fuels were fired during this reporting period, complete this secondary fuel emissions table and the
total non -criteria pollutant (HAP) emissions table below:
Secondary Fuel Type (#2 diesel
Overalls
Control
Efficiency
Uncontrolled
Ernission Facto
Emission
Source
Factor
specify units) AP -42, Mfg., etc. 3,
ncontrolled Controlled
Actual Actual"
EmissionsEmissions5
(lbs/year)'' ((bs/year)
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-220 - Boiler APEN - Revision 7/2018
5!
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
If multiple fuels were fired during this reporting period, use the following table to report the TOTAL non -criteria
pollutant (HAP) emissions from the source. Values listed below should be the sum of the reported emissions from
the primary and secondary fuels' emissions tables in this Section 7:
CAWS tl0 et.
�tg�4
ntra le "7
year
j�
Dllt 1Jlle�
r lags
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
Nicholas Holland
- Digitally signed by Nicholas Holland
Date: 2019.04.04 10:08:36 -06'00`
4/4/19
Signature of Legally Authorized Person (not a vendor or consultant) Date
Nick Holland
Director EHS&R
Name (please print)
Title
Check the appropriate box if you want:
Ei Draft permit prior td public notice
E✓ Draft of the permit prior to issuance
(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-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.gov/cdphelapcd
Form APCD-220 - Boiler APEN - Revision 7/2018
61
CoLP:RA 15 +a
time ea:d Pahim
Ack? `) aO O
tr-ce/'\'L') 1-1/1//?O‘cl
Boiler APEN - Form APCD-220
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 boilers, hot oil heaters, process heaters, and similar equipment. If your emission unit
does not fall into one of these categories, there may be a more specific APEN for your source (e.g. print shop,
mining operations, engines, 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.Rov/cdphe/apcd.
Do not complete this form for the following source categories:
- Heaters or boilers with a design capacity less than or equal to 5 MMBtu/hour that are fueled solely by
natural gas or liquid petroleum gas (LPG).
Heaters or boilers with a design capacity less than or equal to 10 MMBtu/hour used solely for heating
buildings for personal comfort that are fueled solely by natural gas or liquid petroleum gas (LPG).
More information can be found in the APEN exempt/permit exempt
checklist: https://www.colorado.Rov/pacific/cdphe/apen-or-air-permit-exemptions.
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.=---
� J 99' -- ---- AIRS ID
Permit Number:--1-?-1,78-019/
umber: Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID]
123 % 9F67 /,D
Section 1 - Administrative Information
Company Name:
Site Name:
Cureton Front Range LLC
Front Range Gas Plant
Site Location: SENE Sec. 19, T2N, R64W
Mailing Address:
(Include Zip Code) 518 17th Street, Suite 650
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1321
Contact Person: Nick Holland
Phone Number: 303-324-5967
E -Mail Address2:
nick.holland@curetonmidsream.com
i Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-220 - Boiler APEN - Revision 7/2018 1
COLORADO
bwasaasnf. AvAwro
Permit Number:
AIRS ID Number: 123 / 9F67 /
[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)
0 Change fuel or equipment ❑ Change company name3 0 Add point to existing permit
El Change permit limit ❑ Transfer of ownership4 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)
❑ APEN submittal for permit exempt/grandfathered source
Additional Info Et 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: Hot oil heater
Manufacturer: TBD Model No.: TBD Serial No.: TBD
Company equipment Identification No.
(optional):
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
HTR7
TBD
Normal Hours of Source
Operation:
Seasonal use Dec -
percentage: Feb:
hours/day
Mar -
May:
days/week weeks/year
June -
Aug:
Sept -
Nov:
Are you reporting multiple identical boilers on this APEN? ❑ Yes Q No
If yes, please describe how the fuel usage will be measured for each boiler (i.e., one meter for all boilers
or separate meters for each unit):
Form APCD-220 - Boiler APEN - Revision 7/2018 2 I
COLORADO
naxnatrxamwsmem
✓❑ Upward
O Horizontal
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Stack Information
Geographical Coordinates`.
atitudefLongitude'or UTM)'
40.127056/-104.586044
�I ,z2P�a-Y.i.�h; ....
,.. � ...,,-✓^wX--.,�-,- ;Lreca.�
- ,. ._. .i..:ss_
�'S�_!iY2. ,a_—. ,.e`
n' ..o,..... ..._.:-
HTR7
TBD
800
7984
18.8
Indicate the direction of the stack outlet: (check one)
ID Downward
0 Other (describe):
Indicate the stack opening and size: (check one)
0 Circular
0 Square/rectangle
O Other (describe):
Interior stack diameter (inches):
Interior stack width (inches):
0 Upward with obstructing raincap
36
Interior stack depth (inches):
Section 5 - Fuel Consumption Information
�
esignnput alActual
�pkiBT
Annual Fuel Uses
(Specify Units)
Requested Annual Permmt
Limit 6
₹Specify Units)
55.0
467.8 Iv1MSCF/yr
From what year is the actual annual fuel use data? - -
Fuel consumption values entered above are for: D Each Boiler D All Boilers 0 N/A
Indicate the type(s) of fuel used7:
❑ Pipeline Natural Gas
❑✓ Field Natural Gas
❑ Ultra Low Sulfur Diesel
❑ Propane
o Coal
❑ Other (describe):
(assumed fuel heating value of 1,020 BTU/SCF)
Heating value: 1030 BTU/SCF
(assumed fuel heating value of 138,000 BTU/gallon)
(assumed fuel heating value of 2,300 BTU/SCF)
Heating value:
BTU/lb Ash content: Sulfur Content:
Heating value (give units):
5 If you are reporting multiple identical boilers on one APEN, be sure to clarify if the values in this section are on an individual
boiler basis, or if the values represent total fuel usage for multiple boilers.
6 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
7 If fuel heating value is different than the listed assumed value, please provide this information in the "Other" field.
Form APCD-220 - Boiler APEN - Revision 7/2018
31
Gcs!<O R.A B 3•
TSP (PM)
TSP (PM)
Permit Number:
AIRS ID Number: 123 I 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? .._- ❑ Yes No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Overall:Control
Efficiency
reduction in emissions,
PMto
PMz.5
SOX
NO.
CO
VOC
From what year is the following reported actual annual emissions data?
2019
Use the following tables to report the criteria pollutant emissions from source:
(Use the data reported in Section 5 to calculate these emissions.)
TSP (PM)
1.78
Natural
Gas _
7.6
AP -42
F t.
ons/yeq
controlleds
,(tonslyear)
controller
PM c)
7.6
- AP -42
1.78
PM2.5
7.6
AP -42
1.78
SOX
0.6
AP -42
0.14
NO.
50
AP -42
11.69
CO
41
Mfg.
9.64
VOC
5.5
AP -42
1.29
[]✓ Check this box if multiple fuels were NOT fired during this reporting period and skip to Section 7.
If multiple fuels were fired during this reporting period, complete this secondary fuel emissions table and the
total criteria pollutant emissions table below:
Uricontral ed
Emission
actor
ecify Units)
ncontrolled
tons/year)
controlled°
(₹dnsfyear)
Uncontralle
j tons/yea
ontrolled
ofs/year'
PMio
PM2.5
SOX
NO.
CO
VOC
6 Requested values will become permit limitations. Requested timit(s) should consider future process growth.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
L.............A... _. O
li3RA6£5-
Form APCD-220 - Boiler APEN - Revision 7/2018
41
n -Hexane
Permit Number:
AIRS ID Number:
123 /9F67/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
If multiple fuels were fired during this reporting period, use the following table to report the TOTAL criteria
pollutant emissions from the source. Values listed below should be the sum of the reported emissions from the
primary and secondary fuels' emissions tables in this Section 6:
nrcori&rollei
i o trot
inn„yet
TSP (PM)
PM1a
PM2.5
SOx
NOx
CO
VOC
6 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Section 7 - Non -Criteria Pollutant Emissions Information
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 lbs/year?
ID Yes ❑ No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Itura
s,.2 diesef,`ea
Natural Gas
Overall Uncontrolled
control Emission'
Efficiency Facto„:
(speczfy unit's)
0.075 Ib/MMSCF
AP -42
Uncontrolled*
Actual .
Emissions
(tbslyear);y
842
Controlledr`
Actual
Emissions
,{lbsJyear) ire
❑✓ Check this box if multiple fuels were NOT fired during this reporting period and skip to Section 8.
If multiple fuels were fired during this reporting period, complete this secondary fuel emissions table and the
total non -criteria pollutant (HAP) emissions table below:
econ
.e oil etc.,,
Over-all
Control
Efficiency
Uncontrolled
Emission
Factor
(suecify un7%S)
mission; Factor
Source
(AP 42, Mfg., etc.)'
'Uncontrolled Controlled
Actual Actual
Emissions Emissions
fibs; year) abslyear).,
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
C uA5es
Form APCD-220 - Boiler APEN - Revision 7/2018
51
Permit Number:
AIRS ID Number: 123 I 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
If multiple fuels were fired during this reporting period, use the following table to report the TOTAL non -criteria
pollutant (HAP) emissions from the source. Values listed below should be the sum of the reported emissions from
the primary and secondary fuels' emissions tables in this Section 7:
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true; and correct.
Nicholas Holland
≥, Digitally signed by Nicholas Holland
'Date: 2019.04.04 10:09:17 -06'00'
4/4/19
Signature of Legally Authorized Person (not a vendor or consultant) - Date
Nick Holland
Director EHS&R
Name (please print)
Title
Check the appropriate box if you want;
E✓ Draft permit prior to public notice
D Draft of the permit prior to issuance
(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-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-220 - Boiler APEN - Revision 7/2018
6I 4
01/00(
r4�a c�v()Oct; -FWDS
Condensate Storage Tank(s) APEN
Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/pacific/cdphe/air-permits.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
piono.q.0
AIRS ID Number: _ 123 / 9F67 l oa o�
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information __
Company Name': Cureton Front Range LLC
Site Name: Front Range Gas Plant
Site Location: SENE Sec. 19, T2N, R64W
Mailing Address:
(Include Zip Code) 518 17th Street, Suite 650
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1321
Contact Person: Nick Holland
Phone Number: 303-324-5967
E -Mail Address2: nick.holland@curetonmidstream.com
I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 1
Permit Number:
AIRS ID Number: 123 /9F67/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
ID NEW permit OR newly -reported emission source
❑✓ Request coverage under traditional construction permit
O Request coverage under a General Permit
0 GP01 0 GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
'
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
O Change in equipment 0 Change company name3
❑ Change permit limit 0 Transfer of ownership' ❑ 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 a 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:
4, 1000 bbl stabilized condensate tanks
Company equipment Identification No. (optional): TK1-4
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week
0 Exploration Et Production (EEtP) site
52
weeks/year
❑✓ Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
D
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
•
Yes
151
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
SI
Yes
•
No
If "yes", identify the stock tank gas -to -oil ratio:
0.00165
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
•
D
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
0
•
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
21
COLORADO
TK-1-TK4
4
❑✓ Upward
❑ Horizontal
Permit Number:
AIRS ID Number:
123 /9F67/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amoun
,,;(hbli year)
Condensate Throughput
From what year is the actual annual amount?
2019
Average API gravity of sales oil: 73.3 degrees
❑ Internal floating roof
Tank design: 0 Fixed roof
2,555,000
RVP of sales oil: 9.4
❑ External floating roof
Total Volume of
Storage.Tan k
(bbl)
4000
Installation Date of Most Date of First
Recent Storage Vessel in Production'
Storage Tank (month/year) (;nonthlyear)
Number~~..
is Storage Tank or Tank 6a(_,AP Sites On y)
Name, of Well Newly Reported Well
0
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The EEP 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
leograp hica t Coordinates;
Latitude/Longitude or UTM)''
40.127056/104.586044
C3perator Scack
Discharge Height Above
Ground Level (feet) ,
Temp
°F
Flow Rate
ACFM
Velocity �aa;
K tic
Combustor
12
1000
Variable
Variable
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
Circular
❑ Square/rectangle
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches): 48
Interior stack width (inches):
Interior stack depth (inches):
APO
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 3 I
Permit Number:
AIRS ID Number: 1 23 / 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Vapor
❑ Recovery
Unit (VRU):
Pollutants Controlled:
•
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Make/Model:
❑ Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: l 'j' B D
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98+
Minimum Temperature: NA Waste Gas Heat Content: 4058 Btu/scf
Constant Pilot Light: Yes ❑ No Pilot Burner Rating: 0.2 MMBtu/hr
Description of the closed loop system:
_ ❑ __Closed Loop System __ _
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (EaP 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 I
LOVAPO
nYc₹Pui01r
Benzene
71432
4.99E-3
Permit Number:
AIRS ID Number:
123 /9F67 /
[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 form7.
- If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction):
VOC
Description of Con
Combustor
at Method(ss),-
o e[atl"Requested Control
Efficiency
(%reduction in emissions)
95%
NOx
CO
HAPs
Combustor
95%
Other:
From what year is the following reported actual annual emissions data? 201 9
VOC
0.3213
lb/bbl
ena.Pollutant"Emissions inventory "
Actual Annual Emissions
Source .
(AP -42°
Mfg.
E&P Tanks
Uncontrolled
Emissions
(Tons/year)
Requested Annual Permit
Emission Limit(s)s'
Uncontrolled Controlled'
Emissions Emissions
(Tons/year) (TonsIyeart
254.24 12.71
-NOx
0.068
Ib/MMBtu
= AP -42
0.84
0.84 -
CO
0.31
Ib/MMBtu
AP -42
3.82
-- 3.82
on -Criteria RepOrta
Pollutant omissions Inven
emical f `
Abstract
eryCAS Uncontrolled
(CAS) UnitsBasis
Emission Factor''
Uncontrolled Controlled
Emissions,„:, Emissions5
{Po ndslyk0 (Pounds! yea(
Actual Annual Emissions`
Source
(AP -42,
Mfg. etc)
lb/bbl
E&P Tanks
7896
395
Toluene
108883
2.14E-3 lb/bbl
E&P Tanks
3384
169
Ethylbenzene
100414
2.82E-4
lb/bbl
E&P Tanks
456
23
Xylene
1330207
4.23E-4 lb/bbl
E&P Tanks
640
32
n -Hexane
110543
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 I
—,uig..noak
Permit Number:
AIRS ID Number: 123 /9F67/
[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. -
Nicholas Holland
Digitally signed by Nicholas Holland
Date: 2019.04.04 10:09:58 -06'00'
04/04/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Nick Holland
Director EHS&R
Name (print)
Title
Check the appropriate box to request a copy of the:
❑ 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 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.gov/cdphe/apcd
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
6I
Apo
Psltk
Abc.,f)osiv\ _ c)c390q�o
—►1,1s Aral kw -° ' ‘+551)0"••,c -h2- o2 1 i\f-v;),.5
Hydrocarbon Liquid Loading APEN
Form APCD-208
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 hydrocarbon liquid loading 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, glycol dehydration unit,
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.Rov/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:
t 71/0C/ (MO AIRS ID Number: 123 / 9F67 /0a3
[Leave blank unless APCD has already assigned a permit It and AIRS ID]
Section 1 - Administrative Information
— — -Company Name':-Cureton Front Range LLC
Site Name: Front Range Gas Plant
Site Location: SENE Sec. 19, T2N, R64W
Mailing Address:
(Include zip code) 518 17th Street, Suite 650
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1321
Contact Person: Nick Holland
Phone Number: 303-324-5967
E -Mail Address2: nick.holland@curetonmidstream.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be, issued by the APCD via e-mail to the address provided.
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 I
D•puramatol
xwnaa..icw..a
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
Ei NEW permit OR newly -reported emission source
❑✓ Request coverage under construction permit ❑ Request coverage under General Permit GP07
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)
0 Change fuel or equipment 0 Change company name3
o Change permit limit ❑ Transfer of ownership4 ❑ 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 £t 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: Loadout of stabilized condensate
Company equipment Identification No. (optional): LOAD2
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: TBD
Will this equipment be operated in any NAAQS nonattainment area?
El
Yes
■
No
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Yes
No
•
4
Does this source load gasoline into transport vehicles?
■
Yes
J
No
Is this source located at an oil and gas exploration and production site?
Yes
No
■
12
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Yes
No
•
■
Does this source splash fill less than 6750 bbl of condensate per year?
Yes
No
■
•
Does this source submerge fill less than 16308 bbl of condensate per year?
Yes
No
■
■
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
AVItOLORADO
2 itn.ve.�amv
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: O Condensate 0 Crude Oil D Other: stabilized condensate
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5:
2,555,000
bbl/year
Actual Volume Loaded:
This product is loaded from tanks at this facility into: tank trucks
(e.g. "rail tank cars" or "tank trucks")
bbl/year
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
Average temperature of
bulk liquid loading:
,F
True Vapor Pressure:
Psia @60 °F
Molecular weight of
displaced vapors:
lb/lb-mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5:
bbl/year
Actual Volume Loaded:
bbl/year
Product Density:
lb/ft3
Load Line Volume:
ft3/truckload
Vapor Recovery Line Volume:
ft3/truckload
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 I
eNttic
b
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates.
(Latif dj gitude or UTM)
40.127056/-104.586044
-c
j perm or
y $ 5't ar' !•lei ht 9 i3' e„.
u d
to
ACFM)
j'tI :
Combustor
12
1000
variable
variable
Indicate the direction of the stack outlet:: (check one)
0 Upward
O Horizontal
O Downward
❑ Other (describe):
Indicate the stack opening and size: (checkone)
0 Circular
O Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches): 48
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.
O Loading occurs using a vapor balance system: Requested Control Efficiency: 70
O Combustion
Device:
Used for control of: VOC and HAPs
Rating: _, MMBtu/hr
Type: Enclosed Combustor Make/Model: TB D
Requested
Manufacturer Guaranteed
Minimum Temperature:
Constant Pilot Light:
Control Efficiency: 95
Control Efficiency: 98+
NA 'F Waste Gas Heat Content:
❑✓ Yes ❑ No Pilot Burner Rating:
4058 Btu/scf
0.2 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
•
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 I
Benzene
Permit Number:
AIRS ID Number:
123 / 9F67 /
[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 (74 reduction):
PM
Overall Requested'
Control Efficiency
reduction r. _emission)
SOX
NO.
CO
VOC
Vapor Balance/Combustor
95%
HAPs
Vapor Balance/Combustor
95%
Other:
ID Using State Emission Factors (Required for GP07)
0 Condensate
0 Crude
VOC
0.236 Lbs/BBL
0.104 Lbs/BBL
Benzene
0.00041 Lbs/BBL
0.00018 Lbs/BBL
n -Hexane
0.0036 Lbs/BBL
0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data?
2019
.so
SOX
NO.
CO
VOC
0.236
lb/bbl
g., et
State Default
Requtd Annual mit;
Emission Limit(s)a/i
Uncontrolled Controlled
Emissions Emissions;:
(tans/yeseare)'' (tons/year)
301.49
15.07
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical
Abstract
Service (CAS)
Number
Emission Fact.
Source`
(4P-42,
Mfg etc.,
Uncontrolled
Emissions
(pounds/year)
ns
Controlle
Emissionsb'
(pounds/year);
71432
0.00041
lb/bbl
State Default
1048
52
Toluene
108883
0.0036
lb/bbl
State Default
9198
460
Ethylbenzene
Xylene
n -Hexane
100414
1330207
110543
2,2,4-
Trimethylpentane
Other:
540841
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-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 5 I
Permit Number:
AIRS ID Number: 123 / 9F67 /
[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 GP07, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
Nicholas Holland
Digitally signed by Nicholas Holland
Date: 2019.04.04 10:09:40 -06'00'
4/4/19
Signature of Legally Authorized Person (not a vendor or consultant) Date
Nick Holland Director EHS&R
Name (print)
Title
Check the appropriate box to request a copy of the:
EI 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.gov/cdphe/apcd
tattiRAuc
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
6I
General APEN - Form APCD-200 Stturces
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. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require
payment for a new filing fee.
There may be a more specific APEN for your source (e.g. boiler, mining operations, engines, etc.). 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:
AIRS ID Number:
123 19F67/ 02g
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Cureton Front Range LLC
Site Name: Front Range Gas Plant
Site Location: SENE Sec. 19, T2N, R64W
Mailing Address: 518 17th Street, Suite 650
(Include Zip Code)
Portable Source
Home Base:
Denver, CO 80202
Site Location Weld
County:
NAICS or SIC Code: 1321
Contact Person:
Phone Number:
E -Mail Address2: nick.holland@curetonrnidstream.com
Nick Holland
303-324-5967
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.
3.4814
COLOR Aoo
Form APCD-200 - General APEN - Revision 3/2019
Permit Number:
AIRS ID Number: 123 19F671
[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 0 PORTABLE source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
0 Change fuel or equipment 0 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 -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
❑ APEN submittal for permit exempt/grandfathered source
Additional Info Et Notes: HAP reportable only
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:
Methanol Tank
Manufacturer: TBD
Model No.: TBD
Company equipment Identification No.
(optional):
For existing sources, operation began on:
TK-11
Serial No.: TBD
For new or reconstructed sources, the projected start-up date is:
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Seasonal use percentage: Dec -Feb: Mar -May:
Form APCD-200 - General APEN - Revision 3/2019
days/week weeks/year
Jun -Aug: Sep -Nov:
COtO R A DO
2 I �. e ; Department ofPublic
!teeth 6 1:.14.1NIn.
Permit Number:
AIRS ID Number: 123 I 9F67 /
[Leave blank unless APCD has already assigned a permit ft and AIRS ID]
Section 4 - Processing/Manufacturing Information Et Material Use
O Check box if this information is not applicable to source or process
From what year is the actual annual amount? 2019
Description
Design Process.
Rate
(Specify Units)
Actual Annual
Amount
(Specify Units)
. Requested Annual
Permit Limits
(Specify Units)
Material
Consumption:
Finished
Product(s):
Methanol
NA
8872.4 bbl/yr
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.127056/-104.586044
o Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator '
Stack ID No.
_._
Discharge Height
Above Ground Level
('F)
(Feet)
Temp.
Flow Rate
(ACFM)
_
Velocity
(ft/sec)
TK-11
25
Amb.
<0.01
<0.01
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
O Horizontal
O Downward
o Other (describe):
Indicate the stack opening and size: (check one)
O Upward with obstructing raincap
❑✓ Circular Interior stack diameter (inches): -2
o Square/rectangle Interior stack width (inches): Interior stack depth (inches):
o Other (describe):
Form APCD-200 - General APEN - Revision 3/2019
COLOR4Do
3 I ilMIV kWh e>n.ao+4msm
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Combustion Equipment & Fuel Consumption Information
0 Check box if this information is not applicable to the source (e.g. there is no fuel -burning equipment associated
with this emission source)
Design Input Rate
(MMBTU/hr)
Actual Annual Fuel Use
(Specify Units)
Requested Annual Permit Limits
(Specify Units)
From what year is the actual annual fuel use data?
Indicate the type of fuel used6:
❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF)
❑ Field Natural Gas Heating value: BTU/SCF
❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon)
❑ Propane (assumed fuel heating value of 2,300 BTU/SCF)
❑ Coal Heating value: BTU/lb Ash content: Sulfur content:
❑ Other (describe): Heating value (give units):
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑ Yes 0 No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment
Description
Overall Collection Efficiency
Overall Control Efficiency
(% reduction in emissions)
TSP (PM)
PM15
PM2.5
SOX
NOx
CO
VOC
Other:
Form APCD-200 - General APEN - Revision 3/2019
41 Ater Iteetim,Rr=p4upppit
!COLORADO
Permit Number:
AIRS ID Number: 123 I 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
From what year is the following reported actual annual emissions data?
2019
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.
Pollutant .
Uncontrolled
Emission
Factor
(Specify Units)
Emission
Factor
Source
(AP-42,ttc.Mfg.,
Actual Annual Emissions
Requested Annual Permit
Emission Limits 5
Uncontrolled oe
(tons/year) ld7
Uncontrolled (tons/year)
(tons/year)
TSP (PM)
PM10
PM2.5
SOX
NO.
CO
VOC
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Section 8 - Non -Criteria Pollutant Emissions Information
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 lbs/year?
ID Yes ❑ No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
CAS
Number
Chemical
Name
Overall
Control
Efficiency
Uncontrolled
Emission
Factor
(Specify Units)
Emission Factor
Source
(AP -42, Mfg., etc.)
Uncontrolled
Actual
Emissions
(lbs/year)
Controlled
Actual
Emissions?
(lbs/year)
67561
Methanol
0%
0.1124 lb/bbl
EPA Tanks
997
997
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-200 - General APEN - Revision 3/2019
COLORADO
5I kpec •W j [.rent of Pudtic
��ttttt K,.tU,b0,4,u,
Permit Number:
AIRS ID Number: 123 / 9F67/
[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.
Signature of Legally Authorized Person (not a vendor or consultant) Date
Nick Holland
Director EHS&R
Name (print) Title
Check the appropriate box to request a copy of the:
O 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-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
COLORADO
Form APCD-200 - General APEN - Revision 3/2019
Hydrocarbon Liquid Loading APEN
Form APCD-208
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 hydrocarbon liquid loading 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, glycol dehydration unit,
condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN
options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD) website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
/7v1/4/Eio59�
AIRS ID Number: 123 / 9F67 / 025
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Cureton Front Range LLC
Site Name: Front Range Gas Plant
Site Location: SENE Sec. 19, T2N, R64W
Mailing Address:
(Include Zip code) 518 17th Street, Suite 650
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1321
Contact Person:
Phone Number:
E -Mail Address2:
Nick Holland
303-324-5967
nick.holland@,curetonmidstream.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
39481S
COLORS DO
. wm,.e+mnv.e,.eac
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit tt and AIRS ID]
Section 2 - Requested Action
O NEW permit OR newly -reported emission source
0 Request coverage under construction permit
0 Request coverage under General Permit GP07
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 fuel or equipment ❑ Change company name3
❑ Change permit limit ❑ 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 £t 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: Loadout of pressurized NGL
Company equipment Identification No. (optional): LOAD1
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: TBD
Will this equipment be operated in any NAAQS nonattainment area?
GI
Yes
■
No
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Yes
No
•
F4
Does this source load gasoline into transport vehicles?
Yes
No
•
A
Is this source located at an oil and gas exploration and production site?
Yes
No
■
NI
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Yes
No
•
■
Does this source splash fill less than 6750 bbl of condensate per year?
Yes
No
•
■
Does this source submerge fill less than 16308 bbl of condensate per year?
Yes
No
I
III
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
21 EIPT
!COLORADO
moo &EPvflZmuM
Permit Number:
AIRS ID Number: 123 / 9F67
[Leave blank unless APCD has already assigned a permit tt and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: 0 Condensate O Crude Oil p Other: stabilized condensate
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded77'50-0
bbl/year
Actual Volume Loaded:
This product is loaded from tanks at this facility into: tank trucks
(e.g. "rail tank cars" or tank trucks")
bbl/year
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
Average temperature of
bulk liquid loading:
°F
True Vapor Pressure:
Psia @ 60 °F
Molecular weight of
displaced vapors:
lb/lb-mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded': isspo0
bbl/year
Actual Volume Loaded:
bbl/year
Product Density:
g , ss-
lblft3
Load Line Volume:
0.03.36
ft3/truckload
Vapor Recovery Line Volume:
0,01./x
ft3/truckload
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
GcI11//g
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
COLOR ADO
! kaPtlAb;�°lt4rvro!M
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.127056/-104.586044
Operator
Stack ID No.
Discharge Height Above
Ground Level
(feet)
Temp.
CF)
Flow Rate
(ACFM)
Velocity
(ft/sec)
LOAD1
2
Amb.
variable
variable
Indicate the direction of the stack outlet: (check one)
O Upward
0 Horizontal
O Downward
0 Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
✓❑ Other (describe):
Interior stack diameter (inches):
Disconnection of hoses
0 Upward with obstructing raincap
Section 6 - Control Device Information
0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
O Loading occurs using a vapor balance system:
Requested Control Efficiency: %
❑ Combustion
Device:
Used for control of:
Rating:
Type:
MMBtu/hr
Make/Model:
Requested Control Efficiency: %
Manufacturer Guaranteed Control Efficiency: %
Minimum Temperature: °F Waste Gas Heat Content:
Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating:
Btu/scf
scf
MMBtu/hr
hr
O Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
';COLORADO
rF=7;4s 1-b°c
Permit Number:
AIRS ID Number: 123 / 9F67 /
[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
iency (% reduction):
Pollutant
Description of Control Method(s)
Overall Requested
Control Efficiency
(% reduction in emissions)
PM
SO.
NO.
CO
VOC
HAPs
Other:
❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane
❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data? 201 9
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SOX
NO.
CO
VOC
0.00907
lb/bbl
Mass Balance
11.62
11.62
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
Emissions6
(pounds/year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
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-208 - Hydrocarbon Liquid Loading APEN = Revision 7/2018
COLORADO
51 raal,u
• MIA%b.d 101,iat*t
Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit if and AIRS ID]
Section 8 - Applicant Certification
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 GP07, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
Digitally signed by Nicholas Holland I\ l
Date: 2019.03.01 11:55:42 -0700' Q✓
Nicholas Holland
Signature of Legally Authorized Person (not a vendor or consultant)
Nick Holland
Date
PtIfc/(1
Director EHS&R
Name (print)
Title
Check the appropriate box to request a copy of the:
❑r 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 $312.50, 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/aped
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
COLORADO
6 I AY
' HeN�hb SN�11m.�rtlM
10‘ -
General APEN - Form APCD-200 E,�c
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. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require
payment for a new filing fee.
There may be a more specific APEN for your source (e.g. boiler, mining operations, engines, etc.). 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: ( U V E a n1 O
AIRS ID Number:
123 /9F67/ 0 ap
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name:
Site Name:
Cureton Front Range LLC
Front Range Gas Plant
Site Location: SENE Sec. 19, T2N, R64W
Mailing Address: 518 17th Street, Suite 650
(Include Zip Code)
Portable Source
Home Base:
Denver, CO 80202
Site Location Weld
County:
NAICS or SIC Code: 1321
Contact Person:
Phone Number:
Nick Holland
303-324-5967
E -Mail Address2: nick.holland@curetonmidstream.com
I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
395634
COLORADO
Form APCD-200 - General APEN • Revision 3/2019
Permit Number:
AIRS ID Number: 123 I 9F67 /
[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 ❑ PORTABLE 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
o Change permit limit 0 Transfer of ownership4 0 Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
o Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
❑ APEN submittal for permit exempt/grandfathered source
Additional Info It 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:
Emergency Plant Flare
Manufacturer: TBD Model No.: TBD Serial No.: TBD
Company equipment Identification No.
(optional):
For existing sources, operation began on:
Flare
For new or reconstructed sources, the projected start-up date is:
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Seasonal use percentage: Dec -Feb: Mar -May:
Form APCD-200 - General APEN - Revision 3/2019
Jun -Aug: Sep -Nov:
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Permit Number:
AIRS ID Number: 123 I 9F67 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Processing/Manufacturing Information Et Material Use
0 Check box if this information is not applicable to source or process
From what year is the actual annual amount?
Description
Design Process
Rate
(Specify Units)
Actual Annual
Amount
(Specify Units)
Requested Annual
Permit Limits
(Specify Units)
Material
Consumption:
Finished
Product(s):
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.127056/-104.586044
❑ Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Stack ID No.
Discharge _ Height
Above Ground Level
(Feet)
Temp.
(�F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Flare
75
1000
308
1.64
Indicate the direction of the stack outlet: (check one)
0 Upward
O Horizontal
O Downward
O Other (describe):
Indicate the stack opening and size: (check one)
0 Upward with obstructing raincap
0✓ Circular Interior stack diameter (inches): 24
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑ Other (describe):
Form APCD-2OO - General APEN - Revision 3/2019
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Permit Number:
AIRS ID Number: 123 / 9F67 /
[Leave blank unless APCD has already assigned a permit if and MRS ID]
Section 6 - Combustion Equipment a Fuel Consumption Information
✓❑ Check box if this information is not applicable to the source (e.g. there is no fuel -burning equipment associated
with this emission source)
Design Input Rate
(MMBTUIhr)
Actual Annual Fuel Use
(Specify Units)
Requested Annual Permit Limits
(Specify Units)
2.1
18.09 MMscf/yr
From what year is the actual annua fuel use data? 2019
Indicate the type of fuel used6:
o Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF)
O Field Natural Gas Heating value: 1030 BTU/SCF
o Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon)
❑ Propane (assumed fuel heating value of 2,300 BTU/SCF)
❑ Coal Heating value: BTU/lb Ash content:
o Other (describe):
Heating value (give units):
Sulfur content:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? O Yes 0 No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment
Description
Overall Collection Efficiency
Overall Control Efficiency
(% reduction in emissions)
TSP (PM)
PM10
PM2.s
SOX
NO.
CO
VOC
Other:
Form APCD-2OO - General APEN - Revision 3/2019
COLORADO
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Permit Number:
AIRS ID Number: 123 I 9F67 i
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.
Pollutant
Emission
Factor
(specify Units)
Emission
Factor
Source
(AP -42, Mfg.,
etc.)
Requested Annual Permit
Emission Limit�s 5
�:,
Uncontrolled
(tons/year)
Controlled?
(tons/year)
Uncontrolled
(tons/year)
Controlled
(tons/year)
TSP (PM)
PM10
Pik
SOx
NO,,
0.068Ib/MMBtu
AP -42
0.63
CO
0.31 lb/MMBtu
AP -42
2.89
VOC
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Section 8 - Non -Criteria Pollutant Emissions Information
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 lbs/year?
El Yes 0✓ No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
CAS
Number
Chemical
Name
Overall
Control
Efficiency
Uncontrolled
Emission
Factor
(Specify Units)
Emission Factor
Source
(AP -42, Mfg., etc.)
Uncontrolled
Actual
Emissions
(lbs/year)
Controlled
Actual
Emissions?
Ohs/year)
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-20O - General APEN - Revision 3/2019
COLOR A DO
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Permit Number:
AIRS ID Number: 123 I 9F67i
[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.
Signature of Legally Authorized Person (not a vendor or consultant)
Date
Nick Holland Director EHS&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 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.gov/cdphe/apcd
Form APCD-2OO - General APEN - Revision 3/2019
COLORADO
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