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Home My WebLink About20193967.tiffRECEIVED COLORADO Department of Public Health El Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 November 21, 2019 Dear Sir or Madam: NOV 2 5 2019 WELD COUNTY COMMISSIONERS On November 22, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Kerr McGee Oil and Gas Onshore LP - 36908270 (Mars 5-22HZ, 6-22HZ). A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health £t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor Jilt Hunsaker Ryan, MPH, Executive Director Pvbl;G Rev:ew Cc:Pl.(TP)1HL(LK),P(4(SM/ER/cHfcK), t,Uo9/ t 9 ow.%) ti /2.7/1cl is _oV1 —3967 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Kerr McGee Oil and Gas Onshore LP - 36908270 (Mars 5-22HZ, 6-22HZ) - Weld County Notice Period Begins: November 22, 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: Kerr McGee Oil and Gas Onshore LP Facility: 36908270 (Mars 5-22HZ, 6-22HZ) Exploration &t Production Well Pad SWNW Quadrant of Section 22, Township 1 N, Range 67W Weld County The proposed project or activity is as follows: This project is an effort by Kerr McGee Oil and Gas Onshore, LP (KMOGO) to seek a voluntary permit for the bulk separator(s) used at this well pad in order to seek a formal designation of the bulk separator as a "pollution prevention process" specifically under the provisions of Regulation 7, Section XII.D.2.b. The bulk separator is used to replace the atmospheric condensate storage tank(s) that would otherwise exist at this location to gather the condensate produced from the wells at this site. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the Division has determined that public comment is warranted because: Alternative Control is requested per Reg 7, Sec XI I. D.2. b. (ii) 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 19WE0525.CP1 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: James Ricci Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 1 COLORADO Department of Public Health @ Environment Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health & Environment • CONSTRUCTION PERMIT 19WE0525 Issuance: XX Kerr McGee Oil and Gas Onshore Facility Name: Plant AIRS ID: Physical Location: County: General Description: 36908270 (Mars 5-22HZ, 6-22HZ 123-9FF5 SWNW Quadrant of Section 22, Township 1N, Range 67W Weld Well Production Facility 1 Equipment or activity subject to this permit: Facility Equipment ID AIRS Equipment Description Emissions Control B -Sep -01 B -Sep -02 002 Two (2) Worthington three-phase bulk separators (Serial Number 105625 and Serial Number 105677). These pieces of equipment are pressurized vessels with Mercer pressure relief devices (PRDs) set to a maximum allowable working pressure (MAWP) of 400 psig. This separator is a zero -emission process vessel that receives produced oil (or condensate) from a wellhead production separator and performs an additional 3 -phase separation of liquids and gases. Oil from the bulk separator flows directly to a lease automated custody transfer (LACT) unit which transfers the oil off -site at pipeline pressures without the need for onsite atmospheric condensate storage tanks or loadout by truck. Overhead gas from the bulk separator is directed to the sales gas gathering line. None 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. COLORADO Air Pollution Control Division F ettu>t v Efwir,glr ent Page 1 of 12 This permit is a voluntary permit and is not otherwise required under Regulation 3 to permit construction of the equipment covered by this permit. The operator has sought this permit to obtain approval of the design of this equipment, the three-phase bulk separator, as a pollution prevention process pursuant to Regulation 7, Section XII.D.2.b. Application for and issuance of this construction permit does not suggest that the operator had an obligation to obtain a construction permit for this equipment absent the provisions of Regulation 7, Section XII.D.2.b. 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 Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self - certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. The operator shall complete all initial compliance testing as required in this permit and submit the results to the Division in accordance with the requirements of the APCD Compliance Test Manual (www.colorado.gov/pacific/sites/default/files /AP_Compliance-Test-Manual. pdf). (Regulation Number 3, Part B, Section III.E.) 4. 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 permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type VOC B -Sep -01 B -Sep -02 002 0.0 Point Ahnual records of the actual emission rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. The operator shall COLORADO Mr Pollution Control Division ....uE:r[x: ✓_;t C,f Puh€i tiea�'.=� i E';iiurr:r-;l Page 2 of 12 calculate emissions based on the emission factors approved in the notes to permit holder and records of annual condensate production volumes. 6. Compliance with the emissions limit contained in this permit shall be assessed by reviewing the bulk separator monitoring internal bulk separator pressure records required by the Operating and Maintenance Requirements section of this permit. If records indicate the actual bulk separator internal pressure exceeded the point at which the PRD will initially start to relieve this will be considered an indication that emissions occurred. a. Records of instances of pressure exceeding the point at which the PRD will initially starts to relieve which are the result of instantaneous pressure spikes during preventative maintenance pressure tests on the bulk separator PRD are not considered violations of the permitted emissions limit. STATE AND FEDERAL REGULATORY REQUIREMENTS 7. 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) 8. 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. (Reference: Regulation No. 1, Section II.A.1. Et 4.) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. This source is subject to the provisions of Regulation 7, Section XII.C.1 General Requirements for Air Pollution Control Equipment - Prevention of Leakage, including but not limited to: a. All condensate collection, storage, processing and handling 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 11. This source is subject to the provisions of Regulation 7, Section XII.D Condensate Storage Tank Emissions Controls. 12. This source is subject to the provisions of Regulation 7, Section XII.F Condensate Storage Tank Recordkeeping and Reporting. 13. The bulk separator(s) at this well production facility are approved as alternate emissions control equipment as a pollution prevention process per the provisions of Regulation 7, Section XII.D.2.b. The pollution prevention process includes the complete removal of the atmospheric condensate storage tank(s) from this well production facility. For the purpose of demonstrating compliance with Regulation 7, Section XII.D system wide emissions reductions and related Section XII.F Recordkeeping and Reporting purposes the operator shall apply the following emissions factor and emissions reduction in the associated condensate production and emissions records: a. Uncontrolled actual emissions for Section XII.F.3.a.(ii) purposes shall be based on an emissions factor of 0.78 pounds of VOC per BBL of condensate produced; and COLORADO Air Pollution Control Division Deportment of Pu5E e. E eirarenent Page 3 of 12 b. For Section XII.F.3.a.(iii) a 100% control efficiency for VOC emissions shall be applied during periods of condensate production when the bulk separator is operating. 14. Fugitive component leaks at this well production facility are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to monitoring, repair, re -monitoring, recordkeeping and reporting contained in Regulation 7, Sections XII.L and XVII.F, except as modified below. The operator is required to complete monitoring of all well production facility components (not just bulk separator PRDs) via the following methods at the following frequencies: a. Audio, Visual, Olfactory (AVO) on a weekly basis; and b. Approved Instrument Monitoring Method (AIMM) on a monthly basis For pressure relief devices (PRD) located on the bulk separator only: c. If Method 21 monitoring is used as AIMM (i.e. standard definition of a leak for EPA Method 21 purposes applies to other components) the definition of a leak requiring repair shall mean any concentration of hydrocarbon above 0 ppm.: d. Repairs shall be completed no later than 5 working days after discovery of a leak or the production wells associated with the bulk separator shut in. Compliance with the monitoring frequencies and modified definition of a leak requiring repair when Method 21 is used shall commence within 30 days of the issuance date of this permit. 15. In addition to the requirements for Leak Detection and Repair under Regulation 7, Section XII.L and XVII.F the operator of this source shall comply with the following recordkeeping, cause investigation and reporting requirements when evidence of or emissions are observed from the PRD on the bulk separator during AVO or AIMM inspections. The information recorded and reported through these provisions may be used by the Division to assess compliance with the requirements of this permit and Regulation 7 to minimize leakage to the maximum extent practicable and operate in a manner consistent with good air pollution control practices for minimizing emissions. Recordkeeping and Cause Investigation Requirements a. The following records shall be maintained if evidence of (including a visual indicator on the PRD) or emissions are observed from the PRD on a bulk separator during AVO or AIMM inspections required by this permit. (i) Date and location of the emissions and the method through which the evidence was obtained (e.g., AIMM or AVO) (ii) Identification of the cause of the emissions and the date and description of corrective action. (iii) The maximum bulk separator operating pressure on the day that the evidence of or emissions were observed. (iv) Date and method used (e.g. AIMM or otherwise) to verify corrective action was successful. ;COLORADO Air Pollution Control Division Page 4 of 12 b. If evidence of or emissions are observed from a PRD on a bulk separator three or more times in a rolling six month period, a cause investigation will be completed. The cause investigation will be completed within 90 days of the date of observation of emissions that results in three observations within the prior six month time period. Multiple emissions observations during the same site visit shall count only as one observation. Record of the cause investigation will be maintained. The cause investigation shall include, but may not be limited to: (i) The dates on which evidence of or emissions where observed and the method through which the evidence was obtained (e.g. AIMM, AVO) (ii) The date the cause investigation commenced; and (iii) Description of the investigation and determination of the cause of the emissions; and (iv) Documentation of the date and description of the response actions taken to address the cause of emissions and prevent future recurrence. c. Records required by this condition shall be maintained for a period of 5 years. Reporting Requirements d. The operator shall be subject to the following cause investigation reporting requirements. (i) Records related to all cause investigations completed within the January 1st to June 30th time period of each calendar year will be reported to the Division no later than September 1St of the same calendar year. (ii) Records related to all cause investigations completed within the July 1st to December 31St time period of each calendar year will be reported to the Division no later than March 1st of the following calendar year. e. If the operator does not trigger the requirement to conduct a cause investigation during either of the time periods referenced above, records need only be provided upon Division request. 16. The operator shall comply with the General Provisions contained in Regulation 7, Section XVII.B.1 including" a. All intermediate hydrocarbon liquids collection, storage, processing, and handling operations, regardless of size, shall be designed, operated, and maintained so as to minimize leakage of VOCs and other hydrocarbons to the atmosphere to the extent reasonably practicable. b. At all times, including periods of start-up and shutdown, the facility and air pollution control equipment must be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operation and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operation and maintenance procedures, and inspection of the source. [COLORADO Air Pollution Control Division Page 5 of 12 OPERATING £t MAINTENANCE REQUIREMENTS 17. The operator shall equip each pressure relief device (PRD) located on the bulk separator(s) with a visual indicator such as blow off caps or tattle tale pressure relief indicators. Visual indicators shall be monitored during each AVO inspection to assess if a release of emissions has occurred since the prior inspection. Visual indicators must be replaced or reset after any actuation. 18. The pressure relief devices (PRD) used on the bulk separator shall have a design relief set point pressure no less than 400 psig. 19. Upon issuance of this permit, the owner or operator shall follow the operating and maintenance (O&M) and recordkeeping requirements per this condition, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to these O&M plan requirements shall not be implemented prior to submitting a permit application and request to modify this permit condition and receiving Division approval through issuance of a revised permit. (Regulation Number 3, Part B, Section III.G.7.) Bulk Separator(s) Pressure Monitoring and Process Control Requirements a. The bulk separator(s) operations covered by this permit shall be monitored and controlled by a process control system that continuously monitors the internal pressure of the bulk separator(s) to ensure that no emissions of hydrocarbons result from the pressure relief device(s) on the bulk separator(s). b. If the process control system monitors a pressure within the bulk separator that exceeds 300 psig the process control system will immediately initiate an automatic shutdown for the production wells serviced by the bulk separator for which the pressure exceedance occurs. Bulk Separator Design and Process Control System Parameter Verification c. The operator shall monitor the make and model of all pressure relief devices (PRD) located on the bulk separator(s) covered by this permit. Based on the specific make and model, the operator shall maintain a record of the manufacturer's design relief set point pressure (psig) and pressure at which emissions will initially relieve for each PRD. d. The operator shall monitor on a monthly basis the automatic well head shut-in pressure(s) programmed in the process control system to prevent emissions from the pressure relief devices on the bulk separator(s). Recordkeeping Requirements e. The following records shall be maintained for the operating and maintenance requirements contained in this condition. (i) Records of the date, time and maximum pressure (psig) achieved within the bulk separator of all exceedances of the bulk separator automatic shutdown set point pressure established in this condition. For these instances, the operator shall also record if the well head automatic shut in procedure occurred (a simply yes or no record is sufficient). (ii) If the maximum pressure achieved in the bulk separator above exceeds the point at which emissions will initially relieve from the PRD, the COLORADO Air Pollution Control Division " ei anent of PliAiiz I'fei .n S EvRenra}e .t Page 6 of 12 operator shall maintain a record of the duration of time pressure remains above that pressure threshold. The reason and cause of the pressure exceedance (including any instances resulting from preventative maintenance pressure tests on the bulk separator PRD) shall also be recorded. (iii) Records of the make and model of all PRD located on the bulk separator(s) and the associated manufacture's design relief set point pressure and pressure at which emissions will initially relieve. (iv) Monthly records of the recorded automatic well head shut-in pressure(s) programmed in the process control system. (v) Records required by this condition shall be maintained for a period of 5 years. 20. This source is subject to the Common Provisions Regulation, Section II.E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee must 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 Section II.E.1. of the Common Provisions Regulation (https: / /www. colorado.gov/pacific/cdphe/aqcc-regs). a. All instances of exceedance of the pressure at which emissions will initially relieve as monitored by the process control system, except those resulting from preventative maintenance pressure tests on the bulk separator PRD, shall be reported as a malfunction per this condition. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 21. Within 180 days after issuance of this permit, the owner or operator shall complete an initial compliance test demonstration of the bulk separator(s) process control system to demonstrate no emissions occur (see condition #5 of this permit) from the bulk separator pressure relief devices (i.e. pressure relief valves) during normal operations. Normal operation means all periods of operation, excluding malfunctions as defined in Section I.G. of the Common Provisions regulation. The operator shall submit a testing protocol to the Division for review and approval, in accordance with the requirements of the APCD Compliance Test Manual, a minimum 30 days prior to the compliance test date. The Division reserves the right to witness the test. No test required herein shall be performed without prior approval of the protocol from the Division. The test protocol shall include, but not be limited to, the following criteria for the compliance test: a. The duration of the compliance test shall be one hour for each pressure relief device on the bulk separator(s); and b. The scheduled date of the compliance test must be provided; and c. The operator shall utilize an infrared camera (as defined in Regulation 7, Section XII.B.15) in High Sensitivity Mode (HSM) to monitor and record video of all COLORADO Air.Pollution ion Control Division :74:,;rG- ;t of Pubffc E;eE'h v Erdv 3rarrier;t Page 7 of 12 pressure relief devices located on the bulk separator(s) process vessel(s) throughout the duration of the test; and d. The infrared camera video footage shall be recorded at all times in high - sensitivity mode (HSM) except for periods during which emissions are observed. If emissions are observed in HSM mode during the test period, the operator shall ensure the video mode is switched to conventional mode (i.e. not infrared) for a period of 30 seconds unless the duration of emissions is less than 30 seconds; and e. The infrared camera(s) shall be located less than or equal to 30 feet away from the pressure relief device monitored during the period of the test; and f. The operator shall monitor the wind speed throughout the duration of the compliance test. Testing shall be suspended if wind speed exceeds 10 mph and may resume when wind speed drops below 10 mph; and g. Bulk separator operating conditions during the test shall include: (I) 60 minutes of operation during conditions representative of normal condensate production and conditions representative of normal bulk separator pressure vessel operation including internal process vessel pressure and condensate production rates that strive to be within ±10% of the previous 30 day daily average. h. Records maintained throughout the test period shall include, but are not limited to: (1) The total volume of condensate oil produced through the bulk separator process vessel reported as the 1 -hour average (e.g. bbl/hour); and (ii) The internal bulk separator actual operating pressure (1 -hour average); and (iii) The ambient wind speed recorded at a minimum of once every 5 minutes; and (iv) A copy of the complete 1 hour IR video observation including time of commencement and completion of the test period; and (v) Records of the date, time, duration and location of any observations of emissions from the pressure relief device(s) located on the bulk separator The Compliance Test Report (Developed in accordance with the requirements of the APCD Compliance Test Manual) shall be reported to the Division within 30 days of completion of the initial compliance test and shall include, but not be limited to: (i) A discussion on whether any observations of emissions occurred with the IR Camera (ii) If emissions are observed during the test a record of the date and timestamp recorded on the IR video. COLORADO Air Pollution Control Division Departr,zent vi PuUic. Page 8 of 12 A record of the actual average condensate production rate (BBL/hour) during the test period reported as a 1 -hour average. A record of the actual average bulk separator operating pressure (psig) throughout the test period reported as a 1 -hour average. An analysis of the 30 day daily average value, based on the previous calendar month of operations, for the following parameters to demonstrate the actual test conditions were representative of normal operations: (a) 30 day average condensate production rate (BBL/hour) through the bulk separator excluding time periods where no production occurred; and (b) 30 day average bulk separator internal operating pressure (psig) (vi) A copy of the IR video recorded during the test period (vii) The results of the test shall be certified by the test team leader, person(s) responsible for the writing and/or reviewing of the report, and a person with direct responsibility for plant or process operations. The certification need only include the portion of the report and data for which the representative is directly responsible. ADDITIONAL REQUIREMENTS 22. The emissions reductions achieved through the implementation of the bulk separator pollution prevention process approved in this permit may not granted as an emissions reduction credit (ERC) or used for any other purpose under Regulation 3, Part V, Certification And Trading Of Emission Reduction Credits Offset And Netting Transactions. 23. This permit may not be transferred to another owner or operator per the provisions of Regulation 3, Part A, Section III and Part B, Section II.B. (Regulation 3, Part B, Section III.E) 24. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (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 ICOLORADO Air Pollution Control Division '%2{hert=sY^.'.t t;ee'j,v 1^ norrnent Page 9 of 12 For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 25. This permit and any attachments must be retained and made available for inspection upon request. 26. 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 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. 27. 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. 28. 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. 29. 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 1COLORADO Air Pollution Control Division [' u2p.ertfytent 3 Sys::?'t rs E?*tiY6Yirter:E Page 10 of 12 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. 30. 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. 31. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT James Ricci Permit Engineer Permit History Issuance Date Description. Issuance 1 This Issuance Issued to Kerr McGee Oil and Gas Onshore LP. Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.9 of the Common Provisions Regulation. See: https: / /www.colorado.gov/pacific/cdphe/aqcc-regs {COLORADO Air Pollution Control Division Pc N.6P,:_ Heath 6 L^inare�rrc Page 11 of 12 4) The emission levels contained in this permit are based on the following emission factors. The operator has volunteered to obtain this permit to comply with the requirement of Regulation 7, Section XII.D.2.b.(i): Point 002: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source -- VOC 0.0 0.0 Operator Analysis 71432 Benzene 0.0 0.0 108883 Toluene 0.0 0.0 100414 Ethylbenzene 0.0 0.0 1330207 Xylene 0.0 0.0 110543 n -Hexane 0.0 0.0 540841 2,2,4-Trimethylpentane 0.0 0.0 5) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 6) This facility is classified as follows: Applicable Requirement Status Operating Permit True Minor Source NANSR True Minor Source PSD True Minor Source COLORADO Air Pollution Control Division Vufatu� i f iiifti?'v F rain r r:t Page 12 of 12 County AIRS ID: Plant AIRS ID: Facility Name, Physical Address/Location: County: Type of Facility: Is this facility located in a NAAQS If yes, for what pollutant? PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package ft: Received Date: Review Start Date: James Ricci,. 400052 5/24/2019 719/201'9 - Section 01- Facility Information Company Name: Kerr McGee Oil and Gas_Onihore.LP. • 123 9FFS 36908270 (Mars 5-22112, 6 ZSHZ).: SWNW Quadrant of Section 22, Township 1N, Range 67W, in Weld County, Colorado Weld Expisrat<'on & Product -ion Wel(Padt::, i - -, 5 t, R & Netdral Gas Production' Fr000miog ;.;% non -attainment area? an Monoxide (CO) Section 02 - Emissions Units In Permit Application Quadrant Section Township Range SWNW 2 1N aver (PM) Lam` (Nox suet) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance Self Cent Required? Action Engineering Remarks 002 Other(Expla{n) Bulk Separa€ot No 19WEG52S 1 y� _ 'etin lnitiai Issuance Voluntary Permit -Request Section 03 - Description of Project This project Is an effort by Kerr McGee Oil and Gas onshore, LP (KMOGO) to seek a voluntary permit for the bulkseparator(s) used atthis well pad in order to seek a formal designation of the bulkseparator as a"pollution prevention process" specifically underthe provisions of Regulation 7, Section XILD.2. h. The bulk separator is used to replace the atmospheric condensate; storagetank(s) that would otherwise exist at this location to gather the condensate producedfrom the wells atthis,site. Through the replacement of the atmospheric condensate storage.tank(s) with the bulk separator, KMOGO has eliminated the potential source of VOC emissions as well as the traditional air pollution control equipment that would be: required under Regulation 7, Section XII. This site design is commonly referred to as the "URNS" tan kless design for KMOGO. Instead of gatheriegthe hydrocarbon liquids inanatmospheric tank, these liquids are processed throughthe bulk separator and routed through a tease and Custody Transfer (LACT) unit into a liquids gathering system (e.g. pipeline). The liquids gathering system is operated by KMOGO. The liquids are delivered by pipeline to a location known as the Central Oil Stabilization Facility. Historically, for Regulation3, Part A (emissions reporting), Part 8(minorsource permitting) and Part 0(Major Stationary Source New Source Review) purposes the operator and APCD have consideredthe bulk separator inherentto the process and therefore not a potential source of VOC or HAP emissions. Therefore, APEN emissions reporting and permits have not been required for condensate storage tanks since the are no longer operated. In addition,the bulk separators have not been regulated as part of the "condensate storage tank" source category under Regulation 7, Section XII. However, through KMOGo's request to obtain a voluntary permit to treat the bulk separator formally as a pollution prevention process, they are asking forthe associated. well production facility oilproduction operations (through the hulk separator) to be treated as part of the "condensate storage tank" source,category for Regulation 7, Section Xd, purposes. in an effort to seek credit for thetechnological advances eliminating the use of atmospheric condensate storage teok(s). KMOGO is seekingapproval-of the bulkseparatoras. "pollution prevention process" under the provisions of Regulation 7, Section XII.D,2.b. These provisions require the following conditions are met: XII.D.2.b.(i) The owner or operator obtains a construction permit authorizing such use of the alternative emissions control equipment orpollution prevention device or process. The proposal for such equipment, device or process shall comply with all regulatory provisions for construction permit applications and shalt include thefoliowing: XII.D.2.b.(i)(A)A description of the equipment, device or process; XII.D.2.b.(I}(IS A description of where, when andhow the equipment, device or process will be used; XII.D,2.b.(i)(C) The claimed control efficiencyand supporting documentation adequate to demonstrate such. control efficiency; - XIIA2.b-(i)(D) An adequate method for measuring actual control efficiency; and - - XII.D.2.b,(i)(E) Description of the records and reportsthet:will be generated to adequately track emission reductions and implementation and operation of the eq device or process, and a description of how such matters will be reflected inthe spreadsheet and annual report required by SectionsXll.F.3, and XII.F_4. j',':XILD.2.b.(il) Public notice ;oftile application is provided pursuant to Regulation Nurnber3, Part6, Section id.C4. • i' XILD.2.b.(iii) EPA approves the proposal. The Division shall transmit a copy of the permit application and anyother:materials provided by the applicant, all public comments, Division responses and theDivision's permit to EPA Region 8, If EPA fails to approve or disapprove the proposal within 45 days of receipt of these materials, EPA shall be deemed to have approved the proposaL ion 03 continues-onthe subs„e'. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? AlternativeControlPee feg7,5ecllll, Is EPA Review and Approval Required? -. If yes, why?--:Perhll,D.2,h,(liii( materialsmustbesabm,ttedtel PAlec for 45 day revlewpostpebloerinent The APCD intends tosubmit€heepplication, technical revmwdue rents and draftpnnmitn totPA et the beglhning eFthecitizenpeblkrommentpen goprovide EPA an addii{onal3J1days minimum revieurtime, lfthe.Dlvisien.reeeieesofinen coeemenis,.those:conrments ded:AP€D'repsoeses wiltbe tra to EPA via a supptementat subeuttalthatwil sta'rtthe•45day review -period for EPA. Otherwise, Poo citizenegmmentu erereceivet llse-EPA re sew per will commence at the erod ofthe 30day public comrtzentpeermd. • Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? 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) Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) 502 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ CO VOC PM2.5 PM10 TSP HAPs ❑ O Section 03 - Description of Project The value to KMOGO in seeking to classify the bulk separator formally as a "pollution r rth these _.. a to __.. prevention process" underthsprovisions of Section XIi, D.2.6 is to be able take credit for the emissions that were eliminated to demonstrate compliance with system wide condensate storage tank emissions control requirements under Section XII.D.a. At the time of this application operators are required to reduce company "system wide" condensate storage tanks emissions by 90% frombaseline uncontrolled actual emissions on a calendar weekly basis in the May 1 through September 30 and 70% from baseline uncontrolled actual emissions on a calendar monthly basis during October 1 through April 30- Compliance with this "system wide" emissions control requirement is typically acheived by operators installing enclosed combustion devices (e.g. enclosed flares) on the atmospheric condensate storage tanks at their well production facilities. The unique system wide model in Regulation 7, Section XILD applies across the operator's entire field of exploration and production operations within the ozone non -attainment area boundary. This system wide program allows for operators to pick andchoose the locations at whim emissions controls are installed (Reg. 7, Section XILD opening paragraph) and allows for downtime of air pollution control equipment as long as operators ensure the 90% system wide emissions reduction standard is met on a weekly basis, Inherent to the program are intensive recordkeeping and reporting requirements to calculate uncontrolled actual emissions from all condensate storage tanks with uncontrolled actual emissions greater than 2 tons VOC per year (Reg. 7, Section XILD.2.a) and emissions reductions achieved using both emissions factors (lb VOC/bbl condensate produced), condensate production volumes and control device operation downtime records. In order to develop a basis for the uncontrolled actual emissions reductions that are acheived through the implementation of the bulk separator as a pollution prevention process, KMOGO developed a VOC emissions factor in this application for what uncontrolled actual emissions would have otherwise been emitted had a storage tank remained in operation at these facilities (similar to more traditional production operations typically used in the field). This part of the analysis is key in order to accurately represent the emissions that are input into the recordkeeping spreadsheets as required by Section XII,D,2.b,(i)(E) and Section XII.F as well as the control requirements under XIl.D.2. After thorough discussion with the Division, KMOGO chose the technical design, basis for this uncontrolled actual VOC emissions, factor analysis to be based on the generation of well production facility design that was commonly in service prior to the implementation of the Generation 5 (GEMS) "Tankless" facility design. Prior to moving to a tankless facility design, KMOGO operated systems known as the Generation 4 (GEN4) design, In the GEN4 design KMOGO produces condensate at well production facilities by routing the gas -oil -water well production stream initially to an High/Low Pressure (HIP) separator which provides two stages of pressure drop to remove potential flash emissions from the liquid hydrocarbon stream. Upon discharge from the low pressure side of the HIP separator the condensate liquid stream is routed to a vapor recovery tower (VRT) to complete one more stage of gas liquid separation prior to routing condensate liquids to an atmospheric storage tank, In the GEN4 design uncontrolled actual VOC emissions are still generated from an atmospheric storage tank. Through developing the GEN5 tankless design, KMOGo removed the condensate storage tanks (i.e a pollution prevention process) as described in the first paragraph, To supportth e emissions factor development KMOGO gathered site specific pressurized condensate liquid samples (QAed through a bubble point check at the lab) and developed aria lyses using PROMax from ten (10) existing sites to determine the representative VOC emissions factor, The average of the ten site specific emissions factors was determined to be 0,78 ib VOC/BBL condensate produced. The basis for this uncontrolled actual emissions factor analysis is provided in Attachment A of this technical review document, The Division feels this is a reasonable approach to representing the uncontrolled emissions that would/could be emitted at this site had an atmospheric storage tank been used. In evaluating this proposal, it's important to understand, Regulation 7, Section XILD allows for operators to emit any level of emissions from a condensate storage tank as long as the storage tank is equipped with air pollution control equipment that reduces those emissions by 95% at the individual storage tank and collectively by 90% overall for all condensate storage tanks (e.g. at all well pads) operated by the company in the ozone non -attainment area (e.g. "system wide"), KMOGO is not required by Regulation 7 to implement a zero emissions "tankless"design. To provide some additional perspective on t he typical range of emissions factors for condensate storage tanks, the Division reviewed the last round of SIP inventory work completed for 2017 base case emissions. This inventory work reflected a range of emissions factors for condensate storage tanks from 0.22 - 13.7 lb VOC/BBL condensate produced (See Page 6, Table 7 "Technical Support Document 2011 and 2017 Oil and Gas Emissions Inventory Development' approved November 17, 2016 by Regional Air Quality Council; https: f/rage. egnyte.com/dI/Kk5j5AcIAm/f5D_2011-2017_Oil%26Gas El.pdfJ. One big initial step in the regulatory review process for this application is to establish the stationary source classification (e.g. true minor, synthetic minor, or major), The Division recognizes that KMOGO is volunteering to seek a permit under Regulation 3, Part B in order to meet the requirement of Regulation 7, XlI.D.2-b.(1) to have the Division's approval of the"pollution prevention process" and associated operating and maintenance practices memorialized in a federally enforceable permit. Again, -KMOGO has not historically been required to obtain a permit under Regulation 3, Part B or report emissions under Regulation 3, Part A for the GEN5 "tankless" well production operations since the replacement of the condensate storage tank withthe bulk separator resulted in the elimination of the potential for VOC and HAP emissions. The basis for a GEN5 "tankless" facilities lack of historical need to obtain a permit from the Division is explained more fully in PS Memo 99-03 "Criteria for determining whether equipment is air pollution control equipment or process equipment" (https://www.colorado.gov/pacific/sitesJdefauit/files/AP_Memo-99-03-Criteria-for- Determining-Whether-Equipment-is-Air-Pollution-Control-Equipment-or-Process-Equipment.pdf). This guidance memo is based on EPA guidance and establishes a framework of criteria to consider when assessing if a piece of equipment that controls emissions shouldbeconsidered air pollution control equipment or process equipment when evaluating uncontrolled actual emissions. (For Regulation 3, Parts A 8, B Emissions reporting and minor source permitting purposes) and potential to emit (for Regulation 3, Parts C & D Title V and Major NSR purposes). The criteria include:. 1. is the primary purpose of the equipment to control air pollution? In the case of the GEN5 "tankless' design, the primary purpose of the bulk separator (which replaced the atmospheric condensate storage tank) is not to control air pollution. Rather, the bulk separator is integral to the well prodcution facility design which enables KMOGO to separate gas a liquids in such a way that condensate liquid can be routed through a lease and custody transfer (LACT) unit and into a liquids gathering pipeline. 2. Where the equipment is recovering product, how to the cost savings from the product recovery compare to the cost of the equipment? The bulk separator helps to more fully recover rich (high BTU) natural gas and maintain that product without it potentially being emitted through an atmospheric storage tank to the atmosphere or a combustion device. The Division does not feel a cost analysis is warranted given how inherent the bulk separator is to support this facility design. Would the equipment be installed if no air quality regulations are in place? While there may be a multitude of reasons for why the GEN5 "tankless" design was developed, the Division feels this model represents both innovation and leadership in reducing potential sources of VOC and HAP emissions. The operation of the bulk separator is inherent to the process and simultaneously eliminates a primary source of emissions within the oil and gas industry, the atmospheric storage tank. it is important to note, the emissions capture performance of traditional atmospheric condensate storage tank and associated vapor control systems has been and remains a national concern for EPA and locally for Colorado. Therefore, this advancement in design warrants recognition as a pollution prevention process that is inherent to design. In addition the criteria above, KMOGO has communicated that the operation of the bulk separator is interlocked with the operation of the wellheads, if for any reason, the pressures inside the bulk separator exceed an established pressure threshold that would result in emissions from the bulk separator (i.e. the pressure relief valve), the facility is designed to shut in the well head production. As a result, we have historically considered the bulk separator inherent to the process and not air pollution control equipment. It is only now, that KMOGO is requesting the bulk seperator to be formally approved as a "pollution prevention process" for the the purpose of Regulation ?, Section XILD.2.b so their innovation may be recognized and credited towards their Section XILD 90%"system wide' emissions reduction requirement across their well production operations in the ozone non -attainment area. Based on:th'.e determination the bulk separator is a "pollution prevent on process , the uncontrolled actual emissions for both Regulation 3; Part Aand Part B and potentialto emit for Parts C and Part D are based on airemissions factor of D.0 pounds of VQCJBBL of condensate produced. This is consistent with historical practices and=the determination the pollution prevent process istustthat, a process and not primarily an air poliution.emissions control device. However, for the purpose of Regulation 7, Section XII, the uncontrolled actual, emissions factor is 018 pounds*VOC/BBL of condensate produced. The application of this second emissions factor is simply: fior the characterization of emissions that are being reduced and"credited to'the Regulation 7, Section Xli,13 system wide control requirement in the.Ozone non -attainment area. This D.7&lbVOC/BBL emissions factor is what 16.40G0 iiisem—VgibiralcomPliance reports required by Regulation1; Section MP, Section 03 - Description of Project One complexity that exists with this process, is determining what information KMOGO should supply on the APENs submitted with the permit applications for these GEN5 well production facilities. 'The Division feels the cleanest way to document the emissions on an APEN is to provide the 0.0 lb VOC/BBL of condensate produced with a 0% control efficiency. This will maintain clarity that this is a pollution prevention process that involuntarily obtaining a permit that would not other wise be required. The voluntary permits issued will outline in the permit conditions the uncontrolled actual VOC emissions factor to be used for Regulation 7, Section XII.D and Xll.f purposes so that it is clear to Division field inspectors what they will see on the semi-annual compliance reports submitted to the Division. The following discussions focus on the key information KMOGO is required to provide in the permit application per Regulation 7, Section XII.D.2_b_ Per the requirements of Regulation 7, Section XIl:D.2.b.(i)(A) KM000 describes the GEN5 "tankless" process as follows: 4 bulk separator, or combination of bulk separators, located and operating at a Gen 5 oil and gas production site, is a pollution prevention device consisting of a pressurized zero -emission process vessel that receives produced oil (or condensate) from a wellhead production separator and performs an additional 3 -phase separation of liquids and gases. Oil from the 3 -phase production separator is routed to the bulk separator. Oil from the bulk separator flows directly to a lease automated custody transfer (I,ACT) unit which transfers the oil off -site at pipeline pressures without the need for onsite atmospheric condensate storage tanks or loadout by truck. Overhead gas from the bulk separator is directed to the sales gas gathering line. Additional water from the bulk separator is drained to the produced water storage tanks which operate at atmospheric pressure. Refer la the process flow drawings included in the Attachment. The bulk separator is a pressurized vessel with a normal operating pressure between 140 and 270 psig, depending on location. The facility shuts in when the bulk separator pressure reaches 300 psig. The vessel is equipped with a pressure relief device that will not relieve pressure until about 392 psig. Thus, during normal operation, with no flash of condensate to atmospheric pressure, the bulk separotorsystem controls 100% of emissions that would otherwise potentially be emitted from 't an uncontrolled condensate production facility design using atmospheric condensate storage tanks and truck loadout of condensate. Refer to the PFD drawings and engineering documentation showing the PRV sizing for the bulk separator in Attachment 0" The produced water stream is reduced to atmospheric pressure and stored onsite in produced water storage tanks, resulting in potential to emit. These emids+ions are typically controlled by enclosed combustion devices and are addressed through the permitting process far the produced water tanks". Per the requirements of Regulation 7, Section XII.D.2,b.(i)(8) KMOGO describes where, when and how the bulk separator process is used as follows: "The bulk separator design is integral to all Gen S production facilities. The Gen5 production facility design is used where a !ACT and condensate gathering system is in place to transport condensate from the production facility to a central oil stabilization facility. The condensate is maintained at pipeline pressures, and therefore the need far atmospheric storage tanks and truck loadout at the production facility is eliminated. All produced fluids must pass through the bulk separator as there are no provisions for the produced fluids from the production separator to bypass the bulk separator. The entire production volumes (100 %)from the wells serviced at the production facility are processed through the bulk separator and benefit from the pollution prevention performance of the Gen5 design. There is no alternative operating scenario which would result in emissions," Upon review of the pollution prevention process proposal as described above the Division determined that the bulk separator proces s used to eliminate the atmospheric condensate storage tanks is inherent to the design and operation of the GEN5 "tankless" well production facility operations. This determination is based on the considerations that the bulk separator enables KMOGO to recover natural gas into the gathering system for resource preservation and sale as well as the fact that process controls are implemented at these sites that monitor the bulk separator to ensure that pressures within the bulk separator pressure vessel will not exceed the pressure at which VOC or HAP emissions will start to vent from the pressure relief devices. These process controls ensure the well head operations will automatically shut in when pressure monitors exceed the shutdown pressure set point which is maintained '. below the pressure at which the pressure relief valves on the bulk separator will begin to relieve emissions. Per the requirements of Regulation 7, Section XIl.D.2.b.(i)(C) KMOGO provided the following information on the claimed control efficiency and supporting documentation adequate to demonstrate such control efficiency. "During normal operations, the claimed control efficiency is 100%. The bulk separator is equipped with a pressure relief valve (PRV) with a pressure relief set point of 400 psig. Since this is a pressurized vesselthe only event that would result in emissions is over pressurizing the vessel which would cause the PRV to open for safety reasons. The API 520 standards that are used for facility design state that the valve will only start to 'simmer' when pressures are within 2% of the set point of the retie valve, or at around 392 psig. (see API Standard 520, Figure 15 — Pressure Level Relationships for PRVs, included in the Attachment). Typical bulk separator operating pressures range between 140 and 270 psig, depending on location. If the pressure in the bulk separator increases to 300 psig the process control system will automatically initiate a shutdown of the facility by closing the wellhead valves. A shutdown scenario will not result in the bypassing of produced fluids ar venting of process streams or equipment. See the attached engineering documents showing the PRV sizing for the bulk separator. In addition, weekly audio, visual and olfactory (AVO) inspections and monthly infrared (IR) camera inspections will be conducted to verify there are no observed emissions from the PRV on the bulk separator or emissions qualifying as leaks from other components. The AVO and IR inspection program will be part of the Operatiol and Maintenance (O&M) program that will be incorporated as a requirement of the permit. However, any emissions detected during the AVO or IR camera inspection would be a result of a leaking component, similar to every other component currently in the WAR program, and should not be accounted for in the overall permitted control efficiency." The Division believes the process control systems implemented on the bulk separator for these well production operations create an adequate system through which routine VOC emissions will be completely prevented (e.g. 100% control) during normal operations. This relies on the process control system operating properly. It is important to note, as KMOGO referenced in their application therein the possibility of some leaking component emissions occurring from these site operations. Typically such fugitive component leaks are regulated separately as part of the Leak Detection and Repair (LDAR) provisions of Regulation 7, Section Xll.L and XVII.F. This LDAR program allows for leaks to occur as long as the operator is complying with the provisions of the regulation (monitoring, repairing, remonitoring'and reporting). Additionally, leaks from components are accounted for as a separate emissions source at this facility. Therefore, emissions that leak from components are not considered in the determination of the control efficiency (which generally considers both capture of emissions and downtime of the control device) applied for use of the bulk separator pollution prevention process. However, there are a couple important considerations discussed below. Section 03 - Description of Project While fugitive component leaks are considered inherent to many industrial processes and for this facility are covered by Regulation 7 Section Xlii. and XVIi:F these requirements were not developed with this pollution preventation process in mind. ' Therefore, we have to consider uniquely how any emissions. identified from pressure relief devices (defined ' in Regulation 7 as a component subject to WAR provisions) located on the bulk separator should be addressed. KM0G0 is requesting that 100% emissions' control be granted based on the design of the process control system. This request inherently means that KM0G0 believes this pollution prevention process will result in1000%capture of the emissions traveling through the bulk separator process and that zero emissions will occur from PROs on the bulk separator during normal operations. Additionally, if the process control system works as designed, there should also be no instances of condensate production that need to be reported for air pollution control device downtime for Regulation 7, Section XII.F.3a.(viii) purposes. This conclusion is based on the process control system being designed to shut in well production at a pressure (300 psig) well below the pressure at which the PROs will initially begin to release (392 psig). The Division discussed our concern about how observations of emissions from the PROs will be treated in practice with KMOGO. There are three primary methods of monitoring that will indicate that emissions are occurring or have occurred from the PRD on the bulk separator. This include: 1. Bulk separator pressure monitoring data/records that indicate an exceedance of the pressure at which emissions will initially start to relieve from the PRO 2. Weekly AVO monitoring events that observe emissions actively occuring or evidence of emissions having occurred such as from a visual indicator on the PRO 3. Monthly AIMM monitoring events that observe emissions actively occuring. We agreed observations of emissions or evidence of emissions will not be required to be reported as "downtime" for Regulation 7, Section XII recordkeeping and reporting purposes. However, KMOGO intends to report observations that result from category 41 above to the Division as "malfunctions" as any monitored overpressurization would be an indication that the process control systems are not functioning normally and shutting down the well prior to the internal pressure of the bulk separator exceeding the relief pressure of the PRO. The Division intends to capture this expectation in the proposed permit and would consider these emissions a violation of the zero VOC emissions limit in the permit. For any emissions or evidence of emissions observed through routine AVO and AIMM monitoring (category 42 and #3 above) the requirements of the permit take a different approach. The Division intends that emissions observed through AVO Of AIMM monitoring will be repaired and remonitored as required under the LDAR provisions of Section Xll.L and XVII.F. However, a condition was added to the permit to treat these emissions with additional recordkeeping, cause investigation, corrective action and reporting to the Division. Further detailed discussion on how any emissions observed from the PRD on the bulk separator will be treated from a compliance evaluation context is contained on the next page under the heading "Key Compliance Consideration related to the Emissions Limit in the permit and Overlap of LDAR" Per therequirements of Regulation 7, Section Xll.0.2.b.(i)(D) KMOGO provided the following information on an adequate method for measuring actual control efficiency. "The claimed control efficiency of 100% is based on an automatic shutdown of the facility at 300 psig, which is well below the PRV pressure relief point of 392 psig. Therefore, by design, the facility will automatically shut down during normal operations before the pressure in the bulk separator exceeds the pressure relief point. To verify the actual control efficiency at the facility, KMOGO will review the automatic shutdown set points annually to verify the settings are still valid. If the automatic shutdown set points ore correct, ,and there hove been no PRV releases due to over- pressure, the actual control efficiency is 100%. Fugitive equipment leaks from piping connectors, fittings, flanges, and valves are not process emissions. These leaks are appropriately addressed through the required LDAR program, but are not considered in the overall control efficiency used to quantify the amount of pollution prevention provided by the bulk separator process in reporting system -wide control efficiency for Reg 7 reporting. On a monthly frequency, KMOGO will use an IR camera to verify that no emissions are observed from the PRV, or any other component of the bulk separator. When possible, the Monthly IR camera inspection will occur while the wells at the facility are producing. Due to the high production volumes, there is a relatively constant flaw of fluids to the bulk separator. in addition, the bulk separator is a pressurized vessel Therefore, it is not necessary to ensure that the IR camera inspection is performed at the exact moment that the production separator is dumping to the bulk separator." The Division reviewed KMOGO's approach to measuring actual control efficiency of the bulk seperator pollution prevention process more broadlyend contemplated the intent of this requirement For a more traditional alternate emissions control, such as another type of combustion device or a carbon adsorption system an operator may be able to complete a traditional field test of the performance of the system to determine control efficiency using EPA reference test methods. However, in this case, that is not possible since this pollution prevention process does not normally result in any emissions like a traditional control device would from the outlet of a stack:' So, in this case, the most effective manner through which to demonstratethe actual control efficiency is to ensure that all the emissions are fully captured. The proposal by KMOGO does not adequately address the need to demonstrate the proposed control efficiency. The need to demonstrate performance through a field testis even more critical in this case since there are few other practically enforceable mechanisms (like production volume tracking and emissions calculations) within the permit for ongoing compliance monitoring. Therefore, the Division had the following questions on the proposal. KM0Go implies that 100% control is acheived if k(vm0G0 monitors and demonstrates that the automatic shutdown set points are still valid and there have been no PRV releases due to over -pressure. What is the process to demonstratethe automatic shutdown set points are valid? Is it simply a review of the PRVs on the bulk seperator to determine their design relief pressure and then a check to see the control logic has a shutdown pressure below the design relief pressure? Why is an annual evaluation the appropriate frequency? For this portion of the monitoring, the Division believes that monthly monitoring; and recordkeeping is appropriate. A condition reflecting this requirement will be added to the permit. In addition the Division hard coded specific PRO and process logic control requirements into the permit. The PRD on the bulk separator needs to have a design relief pressure no less than 400 psig and the process logic control system cannot set the well head shut in pressure point lower than 300 psig. This should ensure the system triggers the wellhead shut in process well below the point at which the bulk separtor PRO initially starts to relieve (392 psig), In addition, the Di' outcomes: on initiallyspoke with K 0G0 about our desire to incorporate an initial compliance test into the permit to have KMOGO demonstrate two 1. There are no emissions fro he bulk separator PROs during normal representative operations; and 2. The process control system initiates the well head shut down procedure, as designed, when the bulk separator pressure increases to the process control system shut-in pressure. Section 03 - Description of Project Upon further discussion, KM0GO indicated concern complete _._ .. well we ,. ... a well l_ p about having to coa full ehead shut down during theinitial compliance testing. Forcing a wellhead shut in when a w can potentially be mid -cycle could result in liquids build-up in the wellbore and has the potential to result in liquids unloading or swabbing to re -start the well, This would result in additional emissionsto the atmosphere they avoid during normal operations. So, we agreed to not include a demonstration of the well head shut in process that as part of the initial compliance test. Therefore, the initial compliance field test will focus on KMOGO demonstrating a zero emissions rate from the bulk separator PRDs during a period representative of normal operation only. To supplement the Division's need to ensure theprocess control shut-in works as designed, a separate ongoing pressure monitoring requirement will be added to the O&M requirements which requires KM0GO to record any instances of pressure that occur above the PRV well head shut in pressure (300 psig), In addition, KMOGO will be required to record the maximum Internal pressure acheived when the well head shut in pressure is exceeded. This will ensure records are maintained of pressure conditions that could result in emissions from the PRO. If operating as described, the internal bulk separator pressure should not ever exceed the pressure at which emissions will initially relieve (392 ps€g) since the shut down set point is set below the PRV initial relief point pressure. Given the unique nature of the initial compliance test the Division felt it best to develop an outline test ere clearly established. he test protoca in the permit language. This will help ensure the criteria forthe In order to provide:a clear understanding of how the process control system is intended to work, the Division developed the following graphical representation. Bulk-separator-Pressure•Relief•Device-(PRD)•and-Process•Control-systems Graphirat-Representation-of•Operations R Process Control Pressure Trigger Thresholds Legends Black-Une:a 400-psig:-The•PRD•Manufacturers•Design•Relefset-Pressureit Red•LineOt 392•psigl-Ttle•pressure-at•which•emissions-will•initially'startto- rel ieve-per-engineering-standardsn Purpie•Lineu 300•psig•The•Process•Control•System•svelt•head•shut-inset-point. pressures Gold-Line:u A•graph•of•how•the•process•control-system•monitored•pressure•and• hovrthe-pressure•shouid• be•prevented•from•exceeding•the•red-line. ••t The graphic above also helps to demonstrate why certain O&M requirements are included in the permit- First, the selection of the process control system shut-in pressure is critically related to the manufacture design relief set pressure (black line) and the pressure at which emissions will initially relieve (red line)- The goal of the process control system is to ensure neither of these pressures will be exceeded. Since these pressures are which emissions will occur are inherently tied to the PRO design, we've defined in the O&M requirements that KMOGO cannot use,a PRO with a manufacturer design relief set pressure less than 400 psig and that the pressure at which the process control system commences the well head shut €n process as 300 psig. KMG is required to continuously monitor the internal pressure within the bulk separator. During discussions with EPA Region 8 regarding this permit proposal, EPA had questions about how emissions from the facility are handled during a well -head shut in event and whether a blowdownof process units is required. KMOGO verfied that the shut down process does not result in the need to blowdown the facility and provided the following description of the high pressure shut-in process, "When a high pressure condition occurs at a bulk separator, the latch vu lye closes on the wellhead, the inlet valve at the separator. closed and the hi -10 valve at the separator inlet closes. The control valve on the bulk separator opens to bleed down the bulk separator pressure to the pipeline, The location is not programmed to be blown downwhen a shut -down occurs." Section 03 - Description of Project Per the requirements of Regulation 7, Section XII.D.2.b.(i)(E) KMOGO provided the following description of the records and reports that will be generated to adequately track emission d. reductions and implementation and operation of the equipment, device or process, and a description of how such matters will be reflected in the spreadsheet and annual report required by Sections XIIF.3. and X11.F.4. "KMOGO will fallow the O&M program as required by the permit to document the 100% control efficiency. Reductions in emissions far the facility will be oakulated based on actual ail throughput, the Division approved emission factor, and 100% control. The emissions spreadsheet and annual report will reflect this by showing Gen5 facilities with hulk separators in '> the same manner as other non-Gen5 facilities, listing the Division approved emission factor the facility actual production, and€ontrol efficiency of 200%. Emission factor development ' dacumenation was provided in the application." KMOGO did not initially adequately document the specific continuous and periodic O&M practices which are necessary to ensure 100% econtinuous, The recordl of production and emissions information using the Division's standard spreadsheet is an appropriate proposal. One key item not addressed is haw"downtime" of the pollution prevention process will be tracked? Based on the design information KMOGO shared the wells are shut in prior to acheicing a pressure in the bulk separator that would lead to any,.. emissions to the atmosphere from the bulk separator PRD. Therefore, there should be no opportunity for uncontrolled emissions to occur while condensate oil is being produced. Rased on this design, KMOGO should not have periods of condensate production that need to be recorded as downtime for the GEN 5 sites. Operation and maintenance requirements were developed by Division staff through discussions with KMOGO. The O&M requirements which have been incorporated into the permit focus on a couple keyareas including: 1. Ensuring the operator monitors and validates the process logiccontrol system to establish appropriate set point pressures for well head shutdown below the point at which emissions would result from pressure relief devices on the bulk separator 2. Monitor and record any instances of pressure that occur above the shut down set point to ensure the well head shut down process actually occurs and pressures remain below the: PRD initial relief pressure. Key Compliance Considerations related to the Emissions Limit in the permit and Overlap of LDAR One key compliance scenario question that needs to be fully clear is how would any emissions observed from the PRO on the hulk separator be treated during an inspection completed by Division staff? Scenarios for which this question may come up include: review of KMOGO's own AVO (including observation of a displaced visual indicator of emissions such as a blow -off cap or tattle relief vent) or-AIMM monitoring records, APCD inspection staff own IR camera inspections, an actual measured and recorded pressure on a bulk separator FED that is above the pressure point at which emissions will initially start to relieve. If any of these dreumstances occur how would they be treated from a compliance standpoint? Specifically, would they be considered a. violation of the zero emissions limit established in the permit or a requirement to minimize emissions? The Division's worked with KMG to clarify the compliance requirements. These are explained in further detail below. First, if KMOGO's pressure monitoring shows that pressures inside the bulk separator exceed the pressure point at which emissions will initially start to relieve from the PRO on the bulk separator, records of those instances need to be maintained as required by -the permit. The duration of time over which the pressures remain above the relief point must also be • recorded. These instances are required to be reported to the Division as a "malfuction" (as it is indicative of the process logic control system not operating as designed) and the Division will consider such emissions a violation of the permit emissions limit (0 tons VOC per year). KMG may be offered an affirmative defense from civil penalty if the Division concursthe reported emissions are the result of a valid malfunction. Any emissions that are observed through the routine weekly AVO and monthly AIMM required by the permit will be treated differently. They are not, by default, considered a violation of the permitted emissions limit nor are they required to be reported as malfunctions, This recognizes that components such as PROs could, in theory, wear and result In emissionsevenwith routine maintenance. Therefore, the Division built a robust record keeping, cause investigation, corrective action and reporting requirement into the permit for any emissions from the PRO on the bulk separator observed during AVO and AIMM monitoring events. These requirements go above and beyond what is otherwise required under the standard Regulation 7, Section XILL and XVI1.F LDAR requirements. The intention here is to enhance the oversight of any emissions that are observed from the bulk separtor PRO.• through AIMM and AVO and ensure that KMOGO is reporting any repeat occursnces. If there are substantial repeat occurances (more than 3 instances in a rolling 6. month time penod) KMOGO is required to do a deeper cause analysis and report those outcomes to the Division. If there appears to be a ongoing performance issues resulting in these emissions, the Division may consider those emissions a violation of the requirements to minimize leakage to the maximum extent practicable and operate in a manner consistent with good air pollution control practicesfor minimizing emissions. Another important lens to review these scenarios through is KMOGO's obligation to implement LDAR provisions for all components at the: facility, per Peg.?, Section•XII.L and XVILF,..: These provisions include requirements to monitor for teaks, repair, remonitor, maintain records and reporting. While these provisions apply to all components at the well production :. facility a couple key modifications and caveats apply. These include: 1. All components at the facility will be required to be monitored at an enhanced frequency including:weekly AVO and monthly AIMM (KMOGO will not use the traditional method of'. determining monitoring frequency contained in the regulation language) 2. The Method 21. thresholdfor determining a leak that requires repair is established as 0 ppm for the FED on the bulk separator. For other components the standard definition of a leak requiring repair while using Method 21 will apply. = - 3. The provisions under XVII.F,7.c and XII.L.S.c establishing that"leaks discovered are not subject to enforcement unless the operator fails to repair or keep records in accordance with the regulation does not necessaily apply to emissions observed from the PRD. on the bulk separator. Emissions -from this source are potentially subject to enforcement. This is a critical component of the enforceability of the zero emissions limit of the permit for monitored pressure exceedsnces above the pressure at which emissions will initially start to relieve. in addition, if KMG routinely monitors evidence of or emissions from the PRD during AVO and AIMM, those records may be used as the basis to pursue enforcement: for no compliance with the permit requirements to minimize leakage to the maximum extent practicable and operate in a manner consistent with good air pollution control practices for minimizing emissions (consistent with the statement of basis and purpose in Regulation 7, SectionXX.P. November16, 2017 which states, "However, as it also explained in 2014, the ' Commission does not intend to relieve owners or operators of the obligation to comply with the general requirements of Section Xil.C. For example, closing art open thief hatch within five days of an LDAR inspection does not shield an owner or operator from a possible violation of the requirement to minimize emissions to the. maximum extent pratticable.e). The Division reserves theright to pursue enforcement for non-compliance with these provisions even if KMG is fully complying with the provisions of Section 101.1. and XVII.F if there is evidence of repeat occurances of emissions from the PRO on the bulk separator. 4. Delay of repairprovisions offered under Section XVil.F.7 and Xe.L.5 do not apply to emissions observed from the PRO on the bulk separator. A placement of the PRO on the bulk separator on the delay of repair list for unavailable parts, need to shutdown or delay attributable togood cause will notshield KMOGO from potential enforcement. The Division's sets this expectation in permit condition tl15 by establishing that repairs of leaks identified on the PRO on the bulk separator will be repaired within 5 days ar the wells will be shut in. This is consistent with the Division's expectation that KMOOG will minimize the duration of any leaks. Other Key Considerations As part of the review of this request, the Division identified several key policy considerations First, we considered whether the emissions not occurring at the well pads are otherwise being emitted in the production field. In this case, the hydrocarbon liquids are gathered via pipeline and routed to the Central Oil Processing Facility (COSF) which is permitted under " facility AIRS ID (123-9070). This facility manages the condensate liquids by processing it initially through stabilization towers prior to storage in three (3) internal floating roof storage tanks (two 250,000 bbland one 100,000 bbl). There arestorage tank emissions from this process, but their combined permitted emissions are 1.4:5 tons VOC per year (Permit #13WE2236Issuance :3). The key consideration here is whether there is any double counting of emissions in the system wide control reporting and recordkeeping. I've verified that KMG does not report the emissions from the COSF in their semi-annual system wide reporting. Therefore, they will not be double counting emissions reductions acheiyed by the Division issuing this permit and allowing this well pads emissions reductions to be credited in the Section XII recrodkeeping and reporting. Another key consideration is ensuring the permit contains practical enforceable terms and conditions to enable the operator and the Division assess ongoing compliance with the permit terms, In this case, the key permit terms include:, the permit emissions limit of zero tons per year, the requirements of the ]DAR program and the operation and maintenence requirements to demonstrate the performance of the pollution prevention process and process control systems. Therefore, the main focus of the permit is to ensure ongoing.. performance of the process logic control system which is intended to ensure that zero emissions occur during normal operations. This is why both the initial compliance test and the O&M requirements are critical components of the practical enforceability of the emissions limit, in the permit, , . The Division discussed with KMOGO the best way to address KMOGO's commitment to increase the frequency of Approved instrument Monitoring Method tAIMM) monitoring at tn� well production facility. Given the structure of Regulation, Section XII.c.2 and XVII.F.4 and this site being a tankless". facility for applicab lity and determination of frequency of monitoring, KMO00. might otherwise only be subject to monthly AVO and annual AIMM monitoring for all components. Since the PRVs on the bulk separator are only one of the many- facility components required to ftc monitored under the LOAF programs, the Division proposed for KMOGO to complete their enhanced weekly AVO and monthly;AFMM for all components at these sites to mare the permit and compliance demonstration more straight forward. This commitment will be memorialized in the permtttre tns(Si ut'g aCLkivon inspectors understand the monitoring frequencies required. in order so determine the stationary source classiication(minor, synthetic mino-ormalortEte>enfirernvemtd of emissions so s=a£tirt5acili s?ravrewdel'`TEtis�in#tsrmaftan summarized on Form IAPCD-102 submitted with the application. Based' on this information the y engineer deter n dthis faGl�if aua potential to em it less than 100 tons per year of c VOC and less than 'O.tons per of each hazardous air pollutant and less than 25 tors per year rombmedafa i. " air oos-air pollutants. Therefore, this stationary source is considered a true minor source `or the purposes- of the Title V Operating Permit program, No, n Attain sleet New Source Review and Prevention or Significant Deterioration prograr05 •r 3 'table of reported taciiity wide emissions is contained on the "Emissions Inventory" woresheeu This technical review and the proposed permit covers the bulk separator' r . emissions point only, y0i, r r emissions sources requiring a permit are add,eased _separately by KMOGO. s ' e Section 03 - Description of Project Additional Air Quality Benefits When reviewing this proposal KMGOG was able to share an analysis of additional air quality benefits, beyond the primary benefit of eliminating storage tank emissions, that result from the implementation -of this tankless well production facility design. At a high level these benefits:include, but are not limited to: - - 1. Elimination of oil and produced water haul truck traffic and associated bOx, CO and NMHC tailpipe emissions as well as fugitive dust from vehicle traffic 2. Elimitaciion, of WIC emissions thetresults from oil. loading from storage tanks to haul trucks , -- 3. Elimination of VOC and methane emissions that could otherwise result from pneumatic controllers since these sites are connected to grid power and use instrument air.- KMGOG intends to permit 81 tankless well produ,ctianfaclltieswhich encom passes approximately 40.3 rt7illion barrels of production. Based enran analysis provid,ed by KM060, the- ..! folldwing specific air quality benefits will be acheived-ecross the 61 permitted facilities 'combined. Condensate produced by the bulk separator facilities is collected by gathering lines so thereis no need for condensate tanker truck loading. This results in the following emissions reduction benefits; as 238 TPY VOC prevented of controlled actual emissions from condensate loadout at the 61 facilities. a 541 TPY NOW 2,097 TPY CO and 176 TPY of NMHC from the loadout truck tailpipe emissions prevented from the 61 facilities. Production (bbfe} Loedaut Emission Factor () VOC/1313!) Control %* Loadout Controlled Emissions (TPY VOCS) 40.3MM 0.236 95 238 *Assume that all loadout is controlled with an ECD and achieves 95% control. onswill be acheived:..:'. Oil Gathering Volume (1000 k Truck Trips Reduced Mites Driven Reduced** NOx EF (g/tz. bd... NOX Emissions (Tpyl CO EF (P./hp-hr)*** CO Emissions (TPn NMHC EF (g/s.w NMHC Emissions (TPY) 40300 223725 10738806 4 541 16 2097 1.3 176 * 180 bbls of oil per truck load ** Assuming an average round trip from loadout point to delivery point of 48 miles, and 180 bbls per truck load *** Using an average j of heavy duty diesel engines (430hp) Using US EPA and California emissions standards for heavy duty CI Engines (fittps-//www.cfiesetnet.cornistandards/usffid.php) COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Kerr McGee Oil and Gas Onshore LP 123 9FF5 36908270 (Mars 5-22HZ, 6-22HZ) History File Edit Date Ozone Status 9/4/2019 Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons oer year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S - SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 S.D 0.2 43.9 0.0 0.4 4.9 0.0 0.0 0.0 D.0 0.2 10.0 0.0 0.4 D.2 Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.2 43.9 0.0 0.4 4.9 0.0 0.0 0.0 0.0 0.2 10.0 0.0 0.4 0.2 ' 001 GP05 Produced Water Vessels (3) (PWTK-01 - 031 0.0 0.0 0.0 0.0 0.2 43.9 0.0 0.4 4.9 0.0 0.0 0.0 D.0 0.2 10.0 0.0 0.4 0.2 NOx and CO from Enclosed Combustor 002 19WE0525.CP1 Bulk Seperators (B-SEP-01 and 021 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 NEW .XA (12) 0.75 MMBTU/hr Heaters (H-01 - H-12] 0.4 4.8 0.3 4.0 0.0 0.4 4.8 , 0.3 4.0 0.0 12 Separate Seperator Heaters FACILITY TOTAL 0.4 0.0 0.0 0.0 5.0 44.2 0.0 4.5 4.9 0.4 0.0 0.0 0.0 5.0 10.3 0.0 4.5 0.2 VOC: True Minor (NANSR, PSD and OP) NOx True Minor (NANSR, PSD and OP) CO: True Minor (PSD and OP) HAP True Minor (OP) Permitted Facility Total 0.0 0.0 0.0 0.0 0.2 43.9 0.0 0.4 4.9 0.0 0.0 0.0 0.0 0.2 10.0 0.0 0.4 0.2 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Public Comment required for Point 002 since alternative emissions control equipment is requested, per Reg 7 XII.D.2.b.(ii) Note1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Pe mitted VOC emissions (point and fugitive) 10.3 Facility is eligible for GP02 because < 90 tpy Project emissions less than 25/50 tpy 0.D Note 2 Page 10 of 12 Printed 11/20/2019 Attachment A Site Specific Emissions Factor Analysi In order to assess the emissions redaction that kM0G0 has acheived by implmenting the GEMS 'tankless' system design, HMOGO decidedto gather field data from existing operations to develop an emissions factor forthe baseline uncontrolled actual emissions. KMOGO collected pressurized liquid hydrocarbon samples fromthe high pressure discharge ('"240 psig) of a single wellhead high presuare 3 -phase separators (one stage of gas -liquid separation) operating upstream of the bulk separators at ten (10) GENE b "tankless" welt production facilities. In addition, KMOGO gathered other operational data critical tomodeling the emission rate (separator: and vapor recorvery tower operating pressures, etc.) from existing GEN4 design sites to use in the process simulator PROMax to estimate envisions. In essense,. KMOGO collected pressurized, liquid samples from GENS locations and '.. then developed a PROMax model to estimate emissions that would occur using a GEN4 sire design. The GEN4'. site design consists of a processing train that routes well head fluids t High/Low pressure 3 -phase separator (two stages of separation} and then condensate liquids from the law pressurevessel to a vapor recovery tower (VRT} for a third stage of gas- liquid separation. Finally, the condensate flows from the VRT to the atmopheric condensate tank: Emissions from. the condensate tank are controlled by an enclosed combustion device. KMOGO setup the PROMax model to see: the pressurized liquid samples obtained from the GEMS citesand: mimic the design of the GEN4 facility. The high pressure samples were. modeled through the final two stages (HLP low pressure vessel and VRT) of separation and then modeled emissions Chet would result from an atmosphericcondensate storage tank. The Division reviewed more closely thebasis for the parameters modeled by KMO6O since the outcomes of the PROMax model are highly sensitive to the. inputs. Specifically, the Division reviewed the modeled operatingpressures for each stage of separation. - KMOGO used 35 psig for the low pressure vessel (2nd stage) and psig for the VST (3€d stage). .':These values appear to conservatively represent the operating pressures of existing GEN4 sites. Through the technical review the Division identified a couple corrections thatwere necessary to: generate accurate Division's request which included; 1 Including estimates of ,y orkreg and breathing less emissions n the.em ssionsfactors. 2. Correcting the molecularwerght and specific gravity; of the Decanes plus (C10 E)-dompon Using the. ten (10) individual model runs the Division devel ped an eye rage VOC emission ptused below. Burge34N-I1HZ Emission Factors Flash (lb/bbl) W&B (lb/bbl) - Total (lb/6bl) VOC 0.6666 0.1670 0.8336 Benzene 0.0041 0.0005 0.0046 Toluene 0.0034 0.0004 0.0038 Ethylbenzene 0.0002 0.0000 0.0002 Xylene 0.0028 0.0004 0.0031 n -Hexane 0.0364 0.0072 0.0436 224 -IMP 0.0026 0.0005 0.0031 Camenisch 3C-35HZ Emission Factors Flash (lb/bbl) Who:(Ib/bbl) Total (lb/bbl) VOC 0.6168 0.1550 0.7719 Benzene 0.0041 0.0005 0.0046 Toluene 0.0041 0.0004 0.0046 Ethylbenzene 0.0002 0.0000 0.0002 Xylene 0.0034 0.0004 0.0038 n -Hexane 0.0365 0.0071 0.0436 224-TMP 0.0027 0.0005 0.0033 ents sthe model ressto be consistent with the lab sampling results actors that is proposed for this. permit. That emissions factor is 0.78 lb VOC/88L of Tern(10) Site Sample Set Average Average Emission Factors Flash (Ib%6bl) W&B (lb/bbl) Total (16(661) SOS .0.6219 0.1637 0.7855 Benzene 0.0039 0.0005 6.0044 Toluene : 0.0040 0.0005 0_0045 Ethylbenzene 0.5002 0.0000 0.0002 Xylene 0.0039 0.0006 0.0045 5 -Hexane :0.0339 0.0070 0.0409 224-TMP : 0.0023 0.0005 0.0028 Hopper St.16C-22HZ Emission Factors Flash (lb/bbl) Who (1b/bbl) Total (16/bbp VOC 0.6520 0.1737 0.8257 Benzene 0.0039 0.0005 0.0044 Toluene 0.0054 0.0006 0.0060 Ethylbenzene 0.0002 0.0000 0.0002 Xylene 0.0034 0.0005 0.0038 n -Hexane 0.0349 0.0073 0.0422 224 -IMP 0.0024 0.0005 0.0028 Camenisch 15N-22HZ JZM 27N-W3H2 Emission Factors Flash (lb/bbl) W&B (lb/bbl) Total (lb/bbl) VOC 0.6424 0.1676 0.8099 Benzene 0.0040 0.0005 0.0045 Toluene 0.0037 0.0004 0.0042 Ethylbenzene 0.0001 0.0000 0.0002 Xylene 0.0031 0.0004 0.0035 n -Hexane 0.0364 0.0075 0.0439 224 -IMP 0.0024 0.0005 0.0028 Emission Factors Flash (10/061) W&B (lb/bbl) Total (lb/bbl) VOC 0.6856 0.1640 0.8495 Benzene 0.0046 0.0005 0.0051 Toluene 0.0038 0.0004 0.0042 Ethylbenzene 0.0002 0.0000 0.0002 Xylene 0.0027 0.0004 0.0031 n -Hexane 0.0392 0.0074 0.0466 224 -IMP 0.0028 0.0005 0.0033 Guest 29C-12HZ Keown St. 19N-34HZ Emission Factors Flash llb/bbl) w&B (lb/bbl) Total (lb/bbl) VOC 0.6507 0.1720 - 0.8307 Benzene 0.0033 0,0004 0.0037 Toluene 0.0044 0.0005 0.0049 Ethylbenzene 0.0002 0.0000 0.0002 Xylene 0.0030 0.0005 0.0041 n -Hexane 0.0374 i 0.0077 0.0451 224 -IMP 0.0021 0.0004 0.0025 Emission Factors Flash (lb/bbl) Who (lb/bbl) Total (Ib/bbll VOC 0.6296 0.1667 0.7963 Benzene 0.0042 0.0005 0.0047 Toluene 0.0041 0.0005 0.0046 Ethylbenzene 0.0002 0.0000 0.0002 Xylene 0.0033 0.0005 0.0038 n -Hexane 0.0363 0.0076 0.0439 224 -IMP 0.0024 0.0005 0.0028 Highlands 36C-16HZ Wilson Ranch 12C-27HZ Emission Factors Flash (Ib/bbi) W&B (16/661) Total (16/661) VOC 0.6176 0,1630 0.7805 Benzene 0.0040 0.0005 0.0045 Toluene 0.0040 0.0005 0.0045 Ethylbenzene 0.0002 0.0000 0.0002 Xylene 0.0030 0.0004 0.0034 n -Hexane 0.0293 0.0061 0.0354 224-TMP 0.0025 0.0005 0.0030 Hilgers 41N-26HZ Emission Factors Flash )lb/bbl) Who (lb/bbl) Total (lb/bbl) VOC 0.5846 0.1688 0.7534 Benzene 0.0039 0.0005 0.0044 Toluene 0.0034 0.0004 0.0038 Ethylbenzene 0.0002 0.0000 0.0002 Xylene 0.0024 0.0004 0.0027 n -Hexane 0.0301 0.0068 0.0369 224TMP 0.0020 0.0004 0.0025 Emission Factors Flash (Ib/bbi) W&B (lb/bbl) Total (lb/bbl) VOC 0.4649 0.1389 0.6037 Benzene 0.0029. 0,0004 0.0034 Toluene 0.0035 0.0004 0.0039 Ethylbenzene 0.0003 0.0000 0.0003 Xylene 0.0118 0.0018 0.0136 n -Hexane 0.0226 0.0052 0.0279 224 -IMP 0.0014 0.0003 0.0018 Separator Venting Emissions Inventory Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 002 Process # SCC Code 01 Uncontrolled Emissions Pollutant Factor Control % Units 40400340 VOC 0.00 0 lb/BBL Benzene 0.00 0 lb/BBL Tol=uene 0.00 0 Ib/BBL Ethylbenzene 0.00 0 lb/BBL Xylene 0.00 0 lb/BBL n -Hexane 0.00 0 ib/BBL 224 TMP 0.00 0 Ib/BBL 12 of 12 H:\World\Working\'Bulk Seperators\19WE0525.CP1 S\Egs E1Ef) - tt (tce;vett YIz1Ili General APEN - Form APCD-200 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. There may be a more specific APEN for your source (e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available on the Air Pollution Control Division (APCD) website at: www.codorado.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: pI wE O 5 zs AIRS ID Number: 123 / 9FF5 [Leave blank unless APCD has already assigned a permit # and AIRS ID] oz Section 1 - Administrative Information Company Name1: Kerr McGee Oil and Gas Onshore LP Site Name: 36908270 Site Location: Site Location SWNW Sect. 22 T1N R67W County: Weld Mailing Address: (Include Zip Code) PO Box 173779 NAICS or SIC Code: 1311 Denver, CO 80217 Permit Contact: Carissa Krey Phone Number: (720) 929-6916 Portable Source Home Base: E -Mail Address2: Carissa.krey@anadarko.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-200 -General APEN - Revision 1/2017 4000WL ©y;� COLORADO A �' 1 I fIRi1�116 LnV1tonmenl Permit Number: AIRS ID Number: 123 / 9F47 / TBD [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 - O MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' 0 Other (describe below) - OR - O APEN submittal for update only (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: Request individual permit for Bulk Separators at Gen5 production facility to recognize 100% emission control efficiency for a pollution prevention process under Reg 7, Sec XII.D.2.b 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Two (2) Zero emission 3 -phase bulk separators at Gen5 production facility used to eliminate need for atmospheric condensate storage tanks Manufacturer: WORTHINGTON Model No.: Bulk Separator Serial No.: 105625, 105677 Company equipment Identification No. (optional): B -Sep -01, B -Sep -02 For existing sources, operation began on: 7/3/2018 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: Form APCD-200 - General APEN - Revision 1/2017 Mar -May: days/week weeks/year June -Aug: Sept -Nov: COLORADO 2 I Av Department et,c xwJm 6Env��onnwn� Permit Number: AIRS ID Number: 123 / 9F47 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section, 4 - Processing/Manufacturing Information a Material Use ❑ Check box if this information is not applicable to source or process From what year is the actual annual amount? 2018 1,663,180 bbl/y 613593.33 bb(/y 1,663,180 bbl/y Produced Condensate Condensate to Pipeline 1,663,180 bbl/y 613593.33 bbl/y 1,663,180 bbl/y 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Section 5 - Stack Information 40.03809/ -104.88016 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. ® e St c a yes e e sc " r e� c ourf - .ue , pe e j Indicate the direction of the Stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward O Other (describe): Indicate the stack opening and size: (check One) ❑ Circular Interior stack diameter (inches): ❑ Square/Rectangle Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack depth (inches): Form APCD-200 - General APEN - Revision 1/2017 3 I ?COLORADO flegarunn Health i 6 PnH rel vlronmanl Permit Number: AIRS ID Number: 123 / 9F47 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Fuel Data and Throughput 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) e'gPu,Rai B/itf1,7 cu n 1F e u ese. ri<u e �` i From what year is the actual annual fuel use data? Indicate the type of fuel used5: ❑ 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: D Other (describe): Heating Value (give units): 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Section 7 - Emissions Inventory 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 ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): TSP (PM) Palo PM2.5 SOx NOx VOC Closed System Pressurized Vessel 100 100 CO Other: HAPs Closed System Pressurized Vessel 100 100 Form APCD-200 - General APEN - Revision 1/2017 4I COLORADO Dcpartmcm Pueut Hagtrit Envitnnmtn1 Permit Number: AIRS ID Number: 123 / 9F47 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 (continued) From what year is the following reported actual annual emissions data? 2018 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.) �x o' Q tro a F t r Seel�ts)� Em n Actua Annual Emissions{ Regaes - 1 S Facto�Essa ( " g- � �e �llnco CO ed� TQ s,t e � Control • . (To is/yea mot.,.. , con ltd To s f ® ' a e TSP (PM) PM1 o PM2.5 SOx NOx CO VOC 0.780 lb/bbl ProMax 0 0 0 0 Other: " Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emission 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) emissions equal to or greater than ❑ Yes ® No 250 lbs/year? If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: s= Nu ber-moo erracal� -Arne� Overall Gontrd s x Efficiency atroll c E iss on " n ,-mss en c So ce , o tro at al e p t • e' s 71432 Benzene 100 % 0.0044 1b/bbl ProMax 0 0 108883 Toluene 100 % 0.0038 lb/bbl ProMax 0 0 100414 Ethylbenzene 100 % 0.0002 lb/bbl ProMax 0 0 1330207 Xylene 100 % 0.0027 lb/bbl ProMax 0 0 110543 n -Hexane 100 % 0.0369 lb/bbl ProMax 0 0 540841 2,2,4-Trimethylpentane 100 % 0.0025 lb/bbl ProMax 0 0 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-200 - General APEN - Revision 1/2017 COLORADO V Hce,b&melmnmPutn Hearn a Fnwromm�m Permit Number: AIRS ID Number: 123 / 9F47 / TBD [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. 5/zt /zvl9 Signature of Legally Authorized Person (not a vendor or consultant) Date Carissa Krey Staff HSE Representative 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 notices 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 to: For more information or assistance call: 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-200 - General APEN - Revision 1/2017 6 COLORADO Depa frofhWle xtah tn Enwmnm.m R.1.t.e.vta C1- ' \ General APEN - Form APCD-200 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. There may be a more specific APEN for your source (e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available 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: 1c we OSis AIRS ID Number: 123 / 9FF5 / OO1. [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name1: Kerr McGee Oil and Gas Onshore LP Site Name: 36908270 Site Location: SWNW Sect. 22 T1N R67W Mailing Address: (Include Zip Code) PO Box 173779 Portable Source Home Base: Site Location County: Weld NAICS or SIC Code: 1311 Denver, CO 80217 Permit Contact: Carissa Krey Phone Number: (720) 929-6916 E -Mail Address2: Carissa.krey@anadarko.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-200 -General APEN - Revision 1/2017 AvCOLORADO Permit Number: AIRS ID Number: 123 / 9F47 / TBD [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) El Change fuel or equipment ❑ Change company name 0 Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 0 Other (describe below) - OR - ❑ APEN submittal for update only (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: Request individual permit for Bulk Separators at Gen5 production facility to recognize 100% emission control efficiency for a pollution prevention process under Reg 7, Sec XII.D.2.b 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Two (2) Zero emission 3 -phase bulk separators at Gen5 production facility used to eliminate need for atmospheric condensate storage tanks Manufacturer: WORTHINGTON Model No.: Bulk Separator Serial No.: 105625, 105677 Company equipment Identification No. (optional): For existing sources, operation began on: B -Sep -01, B -Sep -02, PRVS: mercer valve with set pressure pf 400 psi 7/3/2018 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 days/week weeks/year Form APCD-200 - General APEN - Revision 1/2017 2 I AV COLORADO eynma[nt Permit Number: AIRS ID Number: 123 / 9F47 / TBD Produced Condensate [Leave blank unless APCD has already assigned a permit # and AIRS ID] Seasonal use percentage: Dec -Feb: Mar -May: June -Aug: Sept -Nov: Section 4 - Processing/Manufacturing Information Ft Material Use ❑ Check box if this information is not applicable to source or process From what year is the actual annual amount? 2018 Design Process Rate (Specify Units) Actual Annual Amount (Specify Units), equested Annual ermit Limit4 f (Specify Units) Material Consumption: 1,663,180 bbl/y 613593.33 bbl/y 1,663,180 bbl/y Condensate to Pipeline 1,663,180 bbl/y 613593.33 bbl/y 1,663,180 bbl/y Requested values will become permit limitations. Requested limit(s) should consider future process growth. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.03809/-104.88016 ® 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. ; k Aperator �5tack ID No � � Discharge Height Above Ground Level �." (Feet) ' Temp ("F) " Flow Rate (ACFM) °.Velocity (ft/sec) Indicate the direction of the Stack outlet: (check one) -❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (Check One) ❑ Circular Interior stack diameter (inches): Form APCD-200 - General APEN - Revision 1/2017 ❑ Upward with obstructing raincap ®fir COLORADO Permit Number: AIRS ID Number: 123 / 9F47 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] ❑ Square/Rectangle Interior stack diameter (inches): Interior stack depth (inches): ❑ Other (describe): Section 6 - Fuel Data and Throughput 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 (MMBTU/hr) Actual AnnualFuel Use (Specify Units) Requested Annual Permit Limit4 (Speci)y Units) From what year is the actual annual fuel use data? Indicate the type of fuel used5: ❑ Pipeline Natural Gas ❑ Field Natural Gas ❑ Ultra Low Sulfur Diesel ❑ Propane (assumed fuel heating value of 1,020 BTU/scf) Heating Value: BTU/scf (assumed fuel heating value of 138,000 BTU/gallon) (assumed fuel heating value of 2,300 BTU/scf) ❑ Coal Heating Value: BTU/lb Ash Content: Sulfur Content: • Other (describe): Heating Value (give units): 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? Z Yes ❑ . No If yes, describe the control equipment AND state the overall control efficiency (% reduction): r ontro ,EquipmeOverall & ption^ �: -^sr. .... ® r l C•lecho E men v g ter . �,. -..x - T�. ��..a�. ,. w. Control Efficiency duchon �n emrssians) � 'rw ( s; "1 .agavo;,.' TSP (PM) PMi o PM2.5 SOX NOx VOC Closed System Pressurized Vessel 0 0 % Form APCD-200 - General APEN - Revision 1/2017 4I AV COLORADO Department c: K c fp Er vNonmen< Permit Number: AIRS ID Number: 123 / 9F47 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] CO Other: HAPs Closed System Pressurized Vessel 0% 0% Section 7 (continued) From what year is the following reported actual annual emissions data? 2018 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 Factor (Specify Urits) Emission Factor Source (AP-42, Mfg. ' ect) Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled (Tons/year) Controlled6 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons year) TSP (PM) PM1 o PM2.5 SOx NOx CO VOC 01b/bbl ProMax 0 0 0 0 Other: " Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emission 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) emissions equal to or greater than ❑ Yes ® No 250 lbsJyear? If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: CAS Numbers Chemical Name Overall Control Efficiency Uncontrolled Emission Factor •~� : (specify,, grits) Emission Factor Source (AP -42, Mfg. etc) Uncontrolled Actual Emissions (lbsJyear) Controlled Actual Emissions' (lbs/year) 71432 Benzene 0 % 0.0 lb/bbl ProMax 0 0 108883 Toluene 0 % 0.0 lb/bbl ProMax 0 0 100414 Ethylbenzene 0 % 0, O lb/bbl ProMax 0 0 1330207 Xylene 0 % 0.0 lb/bbl ProMax 0 0 110543 n -Hexane 0 % O. O lb/bbl ProMax 0 0 540841 2,2,4-Trimethylpentane 0 % 0, O lb/bbl ProMax 0 0 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-200 - General APEN - Revision 1/2017 1 MAw D COLORADO 5 =1;71=., Permit Number: AIRS ID Number: 123 / 9F47 / TBD [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. Plid ',1 acooV`s an be h&IC sag CAP ssa. V,rcy g -Z1 -2.c'11 Signature of Legally Authorized Person (not a vendor or consultant) Date Carissa Krey Air Manager 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 notices 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 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-55-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-200 - General APEN - Revision 1/2017 �� COLORADO 6 I 11.�+I�T h [nv�n•nrtxni 11/20/2019 State.co.us Executive Branch Mail - APEN Review: Bulk Separators, 36908270 (Marrs 5-22HZ, 6-22HZ), AIRS ID 123-9FF5-002 STATE OF COLORADO Ricci - CDPHE, James <james.ricci@state.co.us> APEN Review: Bulk Separators, 36908270 (Marrs 5-22HZ, 6-22HZ), AIRS ID 123-9FF5-002 Stephen_Tartaglia@oxy.com <Stephen_Tartaglia@oxy.com> To: "Ricci - CDPHE, James" <james.ricci@state.co.us> Cc: Carissa_Krey@oxy.com Hi James, Please see our response to your comments below. • It has been confirmed that there are only two bulk separators at this location. • Please revise the HAP emission factors to 0 lb/bbl. Tue, Nov 19, 2019 at 3:54 PM Please also find attached a copy of the preliminary analysis that highlights requested change to the regulatory review. These changes were included in the August 29th application submittal but don't seem to have been updated in this version of the preliminary analysis. We also noticed that condition 21 in the draft permit is referencing the incorrect condition regarding compliance testing, please see below. I believe the reference should be made to condition #2 and not condition #5. 21. Within 180 days after issuance of this permit, the owner or operator shall complete an initial compliance test demonstration of the bulk separator(s) process control system to demonstrate no emissions occur (see condition #5 of this permit) from the bulk separator pressure relief devices (i.e. pressure relief valves) during normal operations. Normal operation means all periods of operation, excluding malfunctions as defined in Section I.G. of the Common Provisions regulation. Can you please send us a revised copy with a day or two of review time prior to sending out to public comment? Please let us know if you have any questions. Thank you, Stephen Tartaglia Air Permitting Support Occidental Petroleum Corporation Direct: 720-929-6019 OXY From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Wednesday, November 13, 2019 3:25 PM To: Carissa_Krey@oxy.com; Stephen_Tartaglia@oxy.com Subject: [EXTERNAL] Re: APEN Review: Bulk Separators, 36908270 (Marrs 5-22HZ, 6-22HZ), AIRS ID 123-9FF5-002 https://mail.google.com/mail/u/0?ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1650672776445912310&simpl=msg-f%3A16506727764... 1/2 11/20/2019 State.co.us Executive Branch Mail - APEN Review: Bulk Separators, 36908270 (Marrs 5-22HZ, 6-22HZ), AIRS ID 123-9FF5-002 Hi Carissa, I attached a draft permit and preliminary analysis to this email. We plan to send these drafts to public/EPA comment next week, please let me know if you need additional time past November 20th to review. I also have two additional comments: • I wanted to confirm that there are only 2 bulk separators on location. It looks like there may be a third on the PFD? • I would like to change the HAP emission factors in Section 8 of the APEN all to 0 lb/bbl. Please let me know if you approve and I can redline the APEN. Thanks, James Ricci Permit Engineer [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] Thanks, James Ricci Permit Engineer [Quoted text hidden] 19WE0525.CP1 - Analysis DRAFT v2_20191119.pdf 984K https://mai I.goog le.com/mail/u/0?ik=5517734b80&view=pt&sea rch=all&pemimsg id=msg-f%3A1650672776445912310&si mpl=msg-f%3A16506727764... 2/2 Hello