HomeMy WebLinkAbout20182304.tiffCOLORADO
Department of Public
Health & Environment
RECEIVED
JUL 2 7 2018
WELD COMM
Dedicated to protecting and improving the health and environment of the peopls.�q, s'10NER,C`,
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
July 24, 2018
Dear Sir or Madam:
On July 26, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Great
Western Operating Company LLC - Burr FD Pad. A copy of this public notice and the public comment
packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection fora 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 Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
P.&b1ic Re.utevJ
p $ —01—tif
cc/- PLC mmjTP) HL(3-?),
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2018-2304
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Great Western Operating Company LLC - Burr FD Pad - Weld County
Notice Period Begins: July 26, 2018
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Great Western Operating Company LLC
Facility: Burr FD Pad
Oil Et Gas Wellsite
SESE SEC 24 T6N R67W
Weld County
The proposed project or activity is as follows: Oil Et Gas separation
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0707 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. Any such comment must be submitted in writing to the following addressee:
Christopher Kester
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Christopher tester
Package #: 383768
Received Date: 6/12/2018
Review Start Date: 7/10/2018
Section 01- Facility Information
Company Name: Great Western Operating Company LLC
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility: Exploration & Production Welt Pad.
What industry segment? Oil & NaturatGas Production& Processing
Is this facility located in a NAAQS non -attainment area? , Yes.
If yes, for what pollutant? ❑ Carbon Monoxide (CO)
9606
Burr FD Pad
SESE quadrant of Section 24, Township 6N, Range 67W
Weld County
Section 02 - Emissions Units In Permit Application
Particulate Matter (PM)
Quadrant
Section
Township
Range
SESE
Ozone (NOx & SOC)
24
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
009
SeparotorVentjng
Process Flare
Yes
18WE0707
l
Yes
Permit Ifebai
issuance
010
Separator Venting
Flarecatcher
Yes
18 070
1
Yes
Permit Initlal
Issuance
011
,- Separator Venting ..
Produced Gas
Yes-
18WE0709...
'1
Yes-
Perm& In tiai
Issuance
Section 03 - Description of Project
odification to synthetic minor facil
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? RequestingSyntfietic Minor P
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2
Is this stationary source a major source?
If yes, explain what programs and which pollutants here SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
No
Yes
NOx CO
1
VOC PM2.5 PM10
IJ
NOx CO VOC PM2.5 PM10
❑❑❑
TSP HAPs
TSP
❑ ❑
HAPs
❑ ❑
Colorado Air Permitting Project
Non -Attainment New Source Review (NANSR)
Separator Venting Emissions Inventory
009 Separator Venting
'Facility AIRs ID:
123
County
5
Plan
009
Section 02 - Equipment Description Details
Open process flare to control the VOC and HAP em issio
Detailed Emissions Unit Description:
Open Process Flare
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator 4110111
Actual Throughput =9i,',I,;1 l'i, ,'13 j,,,,,, ,'9T 1'.. MMscf per year
Requested Permit Limit Throughput= 3 3i,y„`197;1': MMscf per year Requested Monthly Throughput= 17 MMscP per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
197.1 MMscf per year
Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare)
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL o
liquids throughput:
Section 04 - Emissions Factors & Methodologies
Description
Ib/Ib-mal
Displacement Equation
Ex=Q" MW 000/C
MW
Emission Factors
Btu/scf
scf/bbl
e total volume flared betwee
Separator Venting
Pollutant
Uncontrolled Controlled
(lb/MMscf) (lb/MMscf)
(Gas Throughput)
(Gas Throughput)
Emission Factor Source
VOC
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
0.0000
0.0000
0.0000
0.0000
Emission Factor Source
Pollutant
Primary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) lb/MMscf
(Waste Heat
Combusted) (Gas Throughput)
PM10
PM2.5
0.0075
0.0075
0,0006.....
0.0680.
0.3100
9.110
9.110
0.719
83.138
379.012
SOx
NOx
CO
3 of 14
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Separator Venting Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
5Ox
NOx
VOC
CO
0.90
0.90
0.90
0.90
0.90
152
0.90
0.90
0.90
0.90
0.90
152
0.07
0.07
0.07
- 0,07
0.07
12
8.19
8.19
8.19
8.19
8.19
1392
0.00
- 0.00
0.00
0.00
0.00.
0
37.35
37.35
37.35
37.35
37.35
6345
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 IMP
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
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Section XVII.B, G
Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Not enough information
Not enough information
Not enough information
Does the company use site specific emission factors based on a gas sample to estimate emissions? ,4
This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
-A"Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point? No
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not
to exceed 180 days). This condition will use the "Volume of waste gas emitted per 08L of Squids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an an
4 of 14 K:\PA\2018\ 18WE0707.CP1.xlsm
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
Process # SCC Code
009 01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 9.11 0 lb/MMSCF
PM2.5 9.11 0 lb/MMSCF
500 0.72 0 Ib/MMSCF
NOx 83.14 0 lb/MMSCF
VOC 0.00 95 lb/MMSCF
CO 379.01 0 lb/MMSCF
Benzene 0.00 95 lb/MMSCF
Toluene 0.00 95 lb/MMSCF
Ethylbenzene 0.00 95 Ib/MMSCF
Xylene 0.00 95 lb/MMSCF
n -Hexane 0.00 95 lb/MMSCF
224 TMP 0.00 95 lb/MMSCF
5 of 14 K:\PA\2018\18WE0707.CP1.xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Re ulatien 3 Parts A and B. APEN end Pernik Requirement
ISaurce is in the Nan.Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutant from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled V0C emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)?
[Nat enough Information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutant from this Individual source greater than 1 TPY (Regulation 3, Part A, Section ll.D.1.a(?
2. Are total facility uncontrolled V0C emissions from the greater than 2 TPY, N0x greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D2)?
Not enough information
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
INot enough information
Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section'
a. Is this separator controlled by a back-up or alternate combustion device (Le., not the primary control device( that is not enclosed?
INot enough information
Section XVII.B.2.e — Altemative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act, its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as'recommend,"`may,"`should,"and "can," is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must"and 'required" are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
ARIA
Separator Venting Emissions Inventory
010 Separator Venting
'Facility AIRs ID:
123
County
16
Plant
da
Poin
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
87.6'.. MMscf per year
87.6+. MMscf per year Requested Monthly Throughput = 7.4 MMscf per month
Requested Permit Limit Throughput =
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
87.6 MMscf per year
Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare)
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput: ..........:.
Section 04- Emissions Factors & Methodologies
Btu/scf
scf/bbl
Ex= Q. MW . Xx/C
20!:8664 Ib/Ib-mol Displacement Equation
Weight %
Helium
3.00000
C02
4 6565'.
N2
5.7033.
methane
93
ethane
I' 22;7373
mane
8672.6.
isobutane
0.4388
n -butane
08563.
isdpentane
01063..
n -pentane
0.0878
cyclopentane
0.0047
n -Hexane
0 033.
cyclohexane
0 0031.
Other hexanes
0:0230
heptanes
3 3093.
methylcyclohexane
0 0033'
224-TMP
0_0014
Benzene
.0':0036.
Toluene
0.0024
Ethylbenzene
°'. 0 0003'
Xylenes
d. fl 0025.
C8* Heavies
0-0348.
Total
VOC Wt %
93.67
10.27
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
(lb/MMscf) (lb/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
5654.4090
282.7205
Benzene
Toluene
1.9820
1.3214
0.1662
1.3764
7.3225
0.7708
0.0991
0.0661
0.0083
0.0688
0.3661
0.0385
Ethylbenzene
Xylene
n -Hexane
224 TMP
Emission Factor Source
Emission Factor Source
Pollutant
Primary Control Device
Uncontrolled
lb/MMscf
Uncontrolled
(Ib/MMBtu)
(Waste Heat
Combusted)
(Gas Throughput)
PM10
PM2.5
SOK
NOx
7 of 14
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Separator Venting Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/yea)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.00
0.00
0.00
0.00
0.00. ,
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0,00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
247.66
247.66
12.38
247.66
12.38
2103
0.00
0.00
0.00
0.00
0.00
0
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
174
174
9
174
9
_ 116
115
6
116
6
14
14
1
14
1
121
121
6
121
6
641
641
32
641
32
68
68
3
68
3
Section 06 - Re ulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Section XVII.B, G
Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Source requires a permit
Source is subject to Regulation 7, Section XVII.6.2, G
The control device for this separator is subject to Regulation 7, Section XVII.B.2.e
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? -, _ „Techincally No, but they are really close and I plan to require this
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
-A "Periodic Testing Requirement" to collect a sitespecific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application on an annual basis.
Wil the operator have a meter installed and operational upon startup of this point? No
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not
to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95%for a flare or combustion device?W����;'
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer,
S of 14 K:\PA\2018\ 18WE0707.CPlxlsm
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
Combustion Emissionsaccounted for under the process flare, point 009
AIRS Point #
Section 09 - Inventory SCC Coding and Emissions Factors
Process # SCC Code
010 01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant - Factor Control % Units
PM10 0.00 0 Ib/MMSCF
PM2.5 0-00 0 Ib/MMSCF
SOx 0.00 0 Ib/MMSCF
NOx 0,00 0 lb/MMSCF
VOC 5654.41 95 Ib/MMSCF
CO 0,00 0 Ib/MMSCF
Benzene 1.98 95 Ib/MMSCF
Toluene 1.32 95 lb/MMSCF
Ethylbenzene 0.17 95 Ib/MMSCF
Xylene 138 95 lb/MMSCF
n -Hexane 7.32 95 Ib/MMSCF
224 TMP 0.77 95 lb/MMSCF
9 of 14
K:\PA\2018\18W E0707.CP1.xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Re- Motion 3 Parts A and B. APEN and Permit Requirements
Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from arty criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than SIP?, NOx greater than lO TPY or CO emissions greater than to TPY (Regulation 3, Part B, Section 11.0.3)7
Not enough information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1TPY (Regulation 3, Part A, Section llD1.a(?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)7
'Source requires a permit
Colorado Reeulatlon 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,2014?
(source is subject to Regulation 7, Section XVIi.B.2,
Section 0011.0.2 - General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section),
a. Is this separator controlled by a back-up or alternate combustion deuce (i.e., not the primary control device) that is not enclosed?
IThe control device for this separator is subject to Regulation 7, Section llV II.B.2.e
Section XVII.B.2.e - Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,"may,"'should,"and "can," is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
'fe3 5 urce Req
Source Req
Yes 'The control
Separator Venting Emissions Inventory
011 Separator Venting
(Facility AIRs ID:
123
County
9E06 011
Plant
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput = ' 109,5- MMscf per year
Requested Permit Limit Throughput =
.06,5 MMscf per year
Requested Monthly Throughput = 9.3 MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
109,5 MMscf per year
Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare)
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04- Emissions Factors & Methodologies
Operator isusi
MW
22.2835-
Weight %
Helium
0,00
CO2
333:
N2
0.60
methane
53.14
ethane
17 79.
propane
13:32.
isobutane
2.02'
n -butane
- 5.36
isopentane
1.25
n -pentane
5.17
ryyQpentane
0'.09
n -Hexane
035
cyclohexane
0.08
Other hexanes
.0.55
heptanes
0.21
methylcyclohexane
0.08'.
224-TMP
000
Benzene
0.04
Toluene
- O:04
Ethylbenzene
0.00
Xylenes
0-02
C8+ Heavies
0.15
Total
VOC Wt %
99.96
25.10
etu/scf
scf/bbl
Ib/Ib-mol
Displacement Equation
Ex = Q'MW' Xx/C
Emission Factors
Separator Venting
Uncontrolled
(lb/MMscf) (lb/MMscf)
Pollutant
Controlled
(Gas Throughput)
(Gas Throughput)
VOC
14759.6732
737.9837
Benzene
Toluene
26.0464
20.5784
1.8227
8.9957
1.3023
1.0289
Ethylbenzene
0.0911
Xylene
0.4498
n -Hexane
224 TMP
204.2556
10.2128
0.1176
0.0059
. Pollutant
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
Emission Factor Source
14,739.80
26
20.57
1.8
8.99
204.02
PM10
PM2.5
0.000
0.000
0.000
0.000
0.000
500
NOx
CO
736.99
1.30
1.03
0.09
0.45
10.20
11 of 14
K:\PA\2018\18 W E0707. CP1.xlsm
Separator Venting Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
500
NOx
VOC
CO
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0,00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
808.09
808.09
40.40
808.09
40.40
6863
0.00
0.00
0.00
0.00
0.00
0
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled - Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
2852
2852
143
2852
143
2253
2253
113
2253
113
200
200
10
200
10
985
985
49
985
49
22366
22366
1118
22366
1118
13
13
1
13
1
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Section XVII.B, G
Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Source requires a permit
Source is subject to Regulation 7, Section XVII.B.2, G
The control device For this separator is subject to Regulation 7, Section XVII.B.2.e
fry.
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRS ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? `s Techincally No, but they are really close and I plan to require this
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
-A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point? No
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not
to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require
12 of 14 K:\PA\2018\ 18WE0707.CP1.xlsm
Separator Venting Emissions Inventory
Section 03 -Technical Analysis Notes
Combustion Emissions accounted for rode
the process flare, point 009
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point # Process It SCC Code
011 01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0-00 0 Ib/MMSCF
PM2.5 0-00 0 Ib/MMSCF
5Ox 0.00 0 Ib/MMSCF
NOx 0.00 0 Ib/MMSCF
VOC 14759.67 95 lb/MMSCF
CO 0.00 0 Ib/MMSCF
Benzene 26.05 95 Ib/MMSCF
Toluene 20.58 95 Ib/MMSCF
Ethylbenzene 1.82 95 Ib/MMSCF
Xylene 9.00 95 lb/MMSCF
n -Hexane 204.26 95 lb/MMSCF
224 TMP 5.12 95 lb/MMSCF
13 of 14 K:\PA\2018\ 18WE0707.CP1.xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Re: ulatio; 3 Parts A and B APEN and Permit Requirements
)source is in the Non -Attainment Area.
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 11.0.1.5)7
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)7
INot enough information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1TPY (Regulation 3, Part A, Section 11.0.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)7
'Source requires a permit
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,2014?
'Source is subject to Regulation 7, Section 000.6.2, G
Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
'The control device for this separator is subject to Regulation ?, Section XVII.B.2.e
Section XVII.B.2.e —Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend,"'may," "should,"and "can," is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must' and 'required" are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
S rce Req
Source Req
Permit number:
Date issued:
Issued to:
ADO
n Contro
lc Heal
CONSTRUCTION PERMIT
18WE0707
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Great Western Operating Company, LLC
Burr FD Pad
123/9ED6
SESE SEC 24 T6N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Process
Flare
009
One open process flare to control
flarecatcher system gas (AIRS Point 010) and
produced gas (AIRS point 011)
Open Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, 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.)
[COLORADO
i Air Pollution Control Division
r^Y rt7(1`ztt N„HEV nULtarr�r;r�t r'
Page 1 of 7
3. this permi
ource withi
or the date on
h in the permi
ed with thi = ` "'; (ii) : s -s cons "'r - 'od of eigh = � the or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
III.F.4.)
4. Upon commencement of operation of this point, the operator shall install 2 separate flow meters
to monitor and record volumetric flow rate of natural gas routed to the process flare covered by
this permit. One flow meter will directly measure only the gas routed to the process flare from
the flarecatcher system (AIRS Point 010). The second flow meter will directly measure only the
gas routed to the process flare from the produced gas stream (AIRS Point 011).
5. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section.III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
Annual Limits:
s permit s
does not c
er either,;
stru
er or oper or . e source
tion/modif peration
ce of t .: constron per
uled commen ' _• s set
s issued:
8 months
ich such
lication
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
Process Flare
009
---
8.2
---
37.4
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits for criteria pollutants shall be determined on a rolling twelve
(12) month total. By the end of each month, a new twelve month total is calculated based on
the previous twelve months' data. The permit holder shall calculate actual emissions each month
and keep a compliance record on site or at a local field office with site responsibility for Division
review.
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
COLORADO
Air Pollution Control Division
E;•errvnrner;t
Page 2 of 7
�-
Process
re
09
atural gas tut o process
flare from _ --- er (AIRS 87.6 MM
.int 01 •
ural s routed oces
are rom process gas -s ream
(AIRS Point 011)
109.5 "1'
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total.. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
9. Upon installation of the flow meters, the owner or operator shall continuously monitor and record
the volumetric flow rate of natural gas routed to the process flare from the Flarecatcher system
(AIRS Point 010) and the process gas stream (AIRS Point 011) separately. The owner or operator
shall use monthly throughput records to demonstrate compliance with the process limits
contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
12. The open flare covered by this permit has been approved as an alternative emissions control
device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible
emissions during normal operations, as defined under Regulation Number 7, XVII.A.16, and be
designed so that an observer can, by means of visual observation from the outside of the open
flare, or by other convenient means approved by the Division, determine whether it is operating
properly. This open flare must be equipped with an operational auto -igniter according to the
following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On
or after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING £t MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (OEM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
COLORADO
Air Pollution Control Division
JirtY'%.'rd �t P til;=v 3{e£'t t'v E'..,^Jvcmu'nee C
Page 3 of 7
15. s source is req ) "uct initial nless othected by t=3►ivision or
eral
16. is source is not require:"'"o con:uc peno•ic testing, "un ess o ` erwise directe..y' e`rivision
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
GENERAL TERMS AND CONDITIONS
18. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
19. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
20. 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
COLORADO
Air Poliutiart Control Division
epal tear }duibierA st. s Ear ttm�r3z t+.
Page 4 of 7
ade � `-r or opera��. r o ner or op: . ents. It is d only for
d op isr activity s• dentified e� ermit.
21. ess spec ly sta _; othe -, the eral andv-cific c• tions contained i is permit
etermi __ e A nce with t ; ons of
Section 25-7-114.5(7)(a), C.R.S.
22. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
23. 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.
24. 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:
Christopher Kester
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Great Western Operating Company LLC
COLORADO
Air Pollution Control Division
F:aPratrne 5t or P\A*71-leilEthii U114 ,110,1
Page 5 of 7
Notes t. -rmit Hold t the permit iss
1) The requi ees for th . time fo s pe it. An invofor these
fee ll be iss - . fter t .ermi ssued e perms lder sh .ay the invoice w n 30 days
invos e inv.�a�,� . � ,� �� ure � �a���� �.�, z�. ,,;���e�e�i� �� :: evocation ermit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The emission levels contained in this permit are based on the following emission factors:
Point 009:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMBtu)
Source
NOx
0.068
AP -42
CO
0.310
AP -42
5) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
6) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
NOx, VOC, CO, and HAP
NANSR
Synthetic Minor Source of:
NOx and VOC
7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
COLORADO
AirAir Pollution Control Division
Deparepere Pubt16 hie ,Hrt.6 trtainar aertt
Page 6 of 7
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
.. z E - Su
P
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
likrlL He&tth. & Ln,ironment
Page 7 of 7
Permit number:
Date issued:
Issued to:
ADO
n Contro
Healt
CONSTRUCTION PERMIT
1 8WE0708
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: I
Great Western Operating Company, LLC
Burr FD Pad
123/9ED6
SESE SEC 24 T6N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Flarecatcher
010
One Flarecatcher system designed to remove
natural gas liquids from the produced
natural gas stream during instances of
insufficient sales gas pipeline capacity.
Open Process Flare
(AIRS Point 009)
This permit is granted subject to alt rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, 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.)
COLORADO
Air Pollution Control Division
Page 1 of 8
3.
s permit s
does not c
er either,
stru •
expi
enc
e da
r active
a e• with thi
er or oper
tion/modif
f is ce of t
was s .uled
(ii)
e source
peration
constron per
commence, s set
s cons
this permi as issued:
ource withij 8 months
or the date on ich such
th in the perms •• • lication
iod of eigh -- the or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
III.F.4.)
4. Upon commencement of operation of this point, the operator shall install a flow meter to monitor
and record volumetric flow rate of natural gas route to the process flare (AIRS Point 009) from
the flarecatcher system covered by this permit. This must be a separate flow meter from the
flow meter that is used to measure produced gas (AIRS Point 011) routed to this process flare.
5. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
.A.4. )
Annual Limits:
Facility
Equipment ID
AIRS
Point
_ Tons per Year
Emission
Type
PM2.5
NO),
VOC
CO
Flarecatcher
010
---
---
12.4
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month, a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
8. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section TILE.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
Flarecatcher
010
Open Process Flare (AIRS Point 009)
VOC and HAP
1OLORADO
Mr Pollution Control Division
Department d Put*
Page 2 of 8
9.
followi
cessi .tes sh. ` be main
insp.. eque
Process Limits
ate '' -s listed be Monthly
owner or operat : nd made
ber 3, Par . )
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Flarecatcher
010
Natural gas routed to
process flare from
flarecatcher
87.6 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shalt calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
10. Upon installation of the flow meter, the owner or operator shall continuously monitor and record
the volumetric flow rate of natural gas routed to the process flare from the flarecatcher system
using the flow meter. The owner or operator shall use monthly throughput records to
demonstrate compliance with the process limits contained in this permit and to calculate
emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11 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)
12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
13. The open flare covered by this permit has been approved as an alternative emissions control
device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible
emissions during normal operations, as defined under Regulation Number 7, XVII.A.16, and be
designed so that an observer can, by means of visual observation from the outside of the open
flare, or by other convenient means approved by the Division, determine whether it is operating
properly. This open flare must be equipped with an operational auto -igniter according to the
following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On
or after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING £t MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
CDPHE
COLORADO
Air Pollution Control Division
y Hot&h is Environment
Page 3 of 8
ion approv pr' ,ti to implem
ni is esting Requiremen s
(Regulatio= umber 3,
16. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis")
within one hundred and eighty days (180) after commencement of operation or issuance of this
permit, whichever comes later, of the natural gas vented from this emissions unit in order to
verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4-trimethylpentane
content (weight fraction) of this emission stream. Results of the Analysis shall be used to
calculate site -specific emission factors for the pollutants referenced in this permit (in units of
lb/MMSC1= gas vented) using Division approved methods. Results of the Analysis shall be
submitted to the Division as part of the self -certification and must demonstrate the emissions
factors established through the Analysis are less than or equal to, the emissions factors submitted
with the permit application and established herein in the "Notes to Permit Holder" for this
emissions point. If any site specific emissions factor developed through this Analysis is greater
than the emissions factors submitted with the permit application and established in the "Notes
to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as
agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies).
Periodic Testing Requirements
17. On an annual basis, the owner/operator shall complete a site specific extended gas analysis
("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC content
(weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -
specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas
vented) using Division approved methods. Results of the Analysis shall be used to demonstrate
that the emissions factor established through the Analysis are less than or equal to, the emission
factor submitted with the permit application and established herein in the "Notes to Permit
Holder" for this emissions point. If any site specific emissions factor developed through this
Analysis is greater than the emissions factor submitted with the permit application and
established in the "Notes to Permit Holder" the operator shall submit to the Division within 60
days, or in a timeframe as agreed to by, the Division, a request for permit modification to address
this/these inaccuracy(ies).
ADDITIONAL REQUIREMENTS
18. 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 NO), per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
COLORADO
Air Pollution Control Division
i% b Fie n G'^vttonnwAt
Page 4 of 8
r the in the 0
s installe
of con
erator of «; ity, process activity;
r a different ty.;ab.f control
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
19. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
COLORADO
Air Pollution Control Division
=-axu r .r�;t or PRna1�=� iieni h a & rwc r.*:rh t
Page 5 of 8
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Great Western Operating Company LLC
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
COLORADO
Air Pollution Control Division
Page 6 of 8
con uality sta rd: evised air ' emission n : ce (APEN)
and plete app lion m be submit equest f. pe it revision.
3) This a urce is s t to Com . Provisi s s Regula Part II bpart E, Affirma Defense
P ess Em'a=�==����� v � nn�� �.� The r r shall notif ion of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
Flarecatcher
010
n -Hexane
110543
641
32
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:.
Point 010:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
VOC
5646.7
282.3
Gas Sample Analysis
110543
n -Hexane
7.27
0.364
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
NOx, VOC, CO, and HAP
NANSR
Synthetic Minor Source of:
NOx and VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
COLORADO
Air Pollution Control Division
Page 7 of 8
SubpartA_ub: KKKK
onal E • tanardo
r Source C
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXX)0(X
1C LORADO
Air Pollution Control Division
Page 8 of 8
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
18WE0709
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Great Western Operating Company, LLC
Burr FD Pad
123/9ED6
SESE SEC 24 T6N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Produced
Gas
011
Produced gas from separation equipment to
be flared during instances of insufficient
sales gas pipeline capacity
Open Process Flare
(AIRS Point 009)
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, 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.)
COLORADO
Air Pollution Control. Division
`epar M f Pt.icHetah6 Cxatronmer;t
Page 1 of 7
3.
s permit s
does not c
er either,,
stru •
er or oper or . e source
tion/modif �w<Q •peration
ce of t constr on per
uled . commend .s set
a'ed with thi, ii -s cons
this permi �k= .s issued:
ource withi - 8 months
or the date on ich such
th in the perms lication
od of eigh .' the or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
III.F.4.)
4. Upon commencement of operation of this point, the operator shall install a flow meter to monitor
and record volumetric flow rate of natural gas route to the process flare (AIRS Point 009) from
the flarecatcher system covered by this permit. This must be a separate flow meter from the
flow meter that is used to measure flarecatcher gas (AIRS Point 010) routed to this process flare.
5. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
Produced Gas
011
---
---
40.4
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shalt not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
8. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
Produced Gas
011
Open Process Flare (AIRS Point 009)
VOC and HAP
COLORADO
Mr PdRutiora Control Division
Pubihz Helt^.s Er-gr:vner:k
Page 2 of 7
9.
be li followi ;,processi s listed be ''. Monthly
ctual ' s'icessi .tes shbe main ed by f,' owner or operat nd made
he Di .'.' _ a: ; insp eque 1. ' ber 3, Par ,)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Produced Gas
011
Natural gas routed to
process flare from
produced gas stream
109.5 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
10. Upon installation of the flow meter, the owner or operator shall continuously monitor and record
the volumetric flow rate of natural gas routed to the process flare from the produced gas stream
using the flow meter. The owner or operator shall use monthly throughput records to
demonstrate compliance with the process limits contained in this permit and to calculate
emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. 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)
12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
13. The open flare covered by this permit has been approved as an alternative emissions control
device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible
emissions during normal operations, as defined under Regulation Number 7, XVII.A.16, and be
designed so that an observer can, by means of visual observation from the outside of the open
flare, or by other convenient means approved by the Division, determine whether it is operating
properly. This open flare must be equipped with an operational auto -igniter according to the
following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On
or after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING £t MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (OEM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
COLORADO
Mr Pollution Control Division
L%t:UJvrx-s of P t• Het h & Enviv.oirne,tt
Page 3 of 7
to implem . (Regulatio umber 3,
m iax esting Requiremen" s
16. This source is not required to conduct initial testing, unless otherwise directed by the Division or
other state or federal requirement.
Periodic Testing Requirements
17. On an annual basis, the owner/operator shall complete a site specific extended gas analysis
("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC content
(weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -
specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas
vented) using Division approved methods. Results of the Analysis shall be used to demonstrate
that the emissions factor established through the Analysis are less than or equal to, the emission
factor submitted with the permit application and established herein in the "Notes to Permit
Holder" for this emissions point. If any site specific emissions factor developed through this
Analysis is greater than the emissions factor submitted with the permit application and
established in the "Notes to Permit Holder" the operator shall submit to the Division within 60
days, or in a timeframe as agreed to by the Division, a request for permit modification to address
this/these inaccuracy(ies).
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
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
19. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
'COLORADO
I Air Pollution Control Division
Page 4 of 7
nsfer of . a i;'• and the s ittal of a
20. ecific stat uthoriza has b;ri granted, then themainder
ion is _ :cab. _ ., the •. _ `. :.instruction es not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Christopher Kester
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Great Western Operating Company LLC
COLORADO
Pollution Control Division
Page 5 of 7
Notes t•-rmit Hold
1) The rmit holde 4° requi
fee ll be issu fter t . ro .ermi
e 'nvure
(Regulation Number 3, Part A, Section VI.B.)
time fo s pe it. An invo for these
3s
lder sh .ay the invoice w k n 30 days
evocation -- ermit.
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(Ib/yr)
Controlled
Emissions
(Ib/yr)
Produced Gas
011
Benzene
71432
2,848
142
Toluene
108883
2,252
113
Ethylbenzene
100414
197
10
Xylenes
1330207
984
49
n -Hexane
110543
22,341
1,117
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 011:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
V0C
14,739.8
736.99
Gas Sample Analysis
71432
Benzene
26.00
1.30
108883
Toluene
20.57
1.03
100414
Ethylbenzene
1.8
0.09
1330207
Xylene
8.99
0.45
110543
n -Hexane
204.02
10.20
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
COLORADO
Air Pollution Control. Division
Page 6 of 7
the
ass
at (
7) T
determin
questions r
expirati
specific
ns point
Division
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
NOx, VOC, CO, and HAP
NANSR
Synthetic Minor Source of:
NOx and VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
iiih?=_ e'r<:te:^.'v E vo merit
Page 7 of 7
General APEN - Form APCD-200 SUN 12204
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.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:
1 S v\I F r21 07
AIRS ID Number: 123 / 9ED6 /
[Leave blank unless APCD has already assigned a permit ft and AIRS ID]
Section 1 - Administrative Information
Company Name': Great Western Operating Company, LLC
Site Name: Burr FD Pad
Site Location: SESE Sec. 24 T6N R67W
Mailing Address: 1001 17th St. Suite 2000
(Include Zip Code) 1
Portable Source
Home Base:
Denver, CO 80202
Site Location WeIA
ld
County:
NAICS or SIC Code: 1311
Permit Contact:
Phone Number:
Ben Huggins
(303) 398-0302
E -Mail Address': bhuggins@gwogco.com
Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
383 700
Form APCD-200 - General APEN - Revision 1/2017 1
AY
COLORADO
mPub&
HWNtr flm.mmme
I I TI
'IF�s i
15,1
Ix I
Permit Number: AIRS ID Number: 123 / 9ED6 / XXX
[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)
0 Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
❑ Change permit limit 0 Transfer of ownership' 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 £t Notes:
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Flaring of Produced Gas and Flarecatcher gas.
Manufacturer: QTR
Model No.:
Q5000
Company equipment Identification No. (optional): Process Flare
For existing sources, operation began on:
Serial No.: TBD
For new or reconstructed sources, the projected start-up date -is:
201-8
Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Seasonal use percentage: Dec -Feb: Mar -May:
Form APCD-200 - General APEN - Revision 1/.2017
Jun -Aug:. Sep -Nov:
2 I ACOLORADO
INT f_mtornerkl
Permit Number:
AIRS ID Number: 123 /9ED1f XXX
[Leave blank unless APCD has already assigned a permit /J and AIRS ID]
Section 4 - Processing/Manufacturing Information Et Material Use
9 Check box if this information is not applicable to source or process
From what year is the actual annual amount?
_Material'_:::
Consumption:
Finished
Product(s):
Design Process
Rate
(Specify Units)
Actual Annual.
Amount
(Specify Units),
Requested Annual..
Permit.Limit4
(Specify Units)
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.466215, -104.833861
❑ 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.
qerator .�
c
S ack�ID
Discharge Height
� 4
Above Ground Level
,' . ' (Feet)
� Temp
,: Flow Rate
(ACFMz
ry s Velocity.
t/sec)
Process Flare
-40
-1400
683,100 max.
115 max.
Indicate the direction of the stack outlet: (check one)
9 Upward
9 Horizontal _
9 Downward
0 Other (describe):
9 Upward with obstructing raincap
Indicate the stack opening and size: (check one)
9 Circular Interior stack diameter (inches): 1 35.5
0 Square/rectangle Interior stack width (inches): Interior stack depth (inches):
0 Other (describe):
Form APCD-200 - General APEN - Revision 1/2017 3 I
COLORADO
Department W P b&
Permit Number:
AIRS ID Number: 123 / 9ED& XXX
[Leave blank unless APCD has already assigned a permit i# and AIRS ID]
Section 6 - Combustion Equipment Et Fuel Consumption Information
❑ Check box if this information is not applicable to the source (e.g. there is no fuel -burning equipment associated
with this emission source)
Design Input Rate
(iMA1BTl/Ihr)
Actual Annual Fuel Use
(Specify Units) r --
Requested Annual Permit it Lim
(specify°Units)
80
197.10 MMscf/yr
197.10 MMscf/yr
From what year is the actual annual fuel use data?
Indicate the type of fuel useds:
❑ 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)
O Coal Heating value: BTU/lb Ash Content: Sulfur Content:
❑r Other (describe): Produced Gas and Flarecatcher Heating value (give units): 1221.6
Projected
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
s If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Section 7 Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑ Yes ❑✓ No
If yes describe the control equioment AND state the overall control efficiency (% reduction):
Overall Control Efficiency
(% reduction in emissions)
Pollutant,
Control Equipment—
Description
overall Collection Efficiency—
TSP (PM)
PMio
PM2s
SOX -
NO.
CO
VOC
Other:
IIh,;
II°+i
Form APCD-200 - General APEN - Revision 1/2017
4 IA"
COLORADO
oepa„rnen. Rublk
Wal.6 Fr sear. nr
Permit Number:
AIRS ID Number: 123 /9ED6/XXX
[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?
Projected
Use the following table to report the criteria pollutant emissions from source:
Use the data reported in Sections 4 and 6 to calculate these emissions.
Pollutant
Uncontrolled
Emission _
Factor
(Specify Units)
Emission
Factor
Source
(AP -42, Mfg.
etc).
c all sio
Actual i�nnual Erryss�o�is
, - �
L- t '" . v
Requested Annual Permit
rt� � �
mission Ltmit(s)a
-.7-*!----,..; ,
Uncontrolled
(Tons/year)
Controlled6
(Tons/year) •
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
TSP (PM)
PM10
PM2.5
Sox
NO„
0.068Ib/MMbtu
AP -42
8.2
8.2
8.2
8.2 -
CO
0.31 lb/MMbtu
AP -42
37.3
37.3
37.3
37.3
VOC
Other:
a 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
250 lbs/year?
O Yes ❑✓ No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
CAS
Number"
Chemical
Name
Overall
Control
Efficiency
Uncontrolled
Emission
Factor
(specify units)
Emission Factor
Source
(AP -42, Mfg. etc)
-Uncontrolled--
Actual
Emissions
(Ws/year)
Controlled= --
Actual
Emissions'
(lbs/year)
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
,,
I°t'I
Form APCD-200 - General APEN - Revision 1/2017
COLORADO
5IMo :;
Permit Number:
AIRS ID Number: 123 /9ED6/ XXX
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification N
,ICI
I hereby certify that all information contained herein and information submitted with this application is complete,
true and correct.
Iwl
]X!I
6/12/2018
Signature of Legally Authorized Person (not a vendor or consultant) Date
Ben Huggins EHS Manager
Name (print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
El Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $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 Or visit the APCD website at:
Denver, —CO 80246-1530
Make check payable to: https://www.colorado.gov/cdphe/apcd
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Form APCD-200 - General APEN - Revision 1/2017 6 I
AY
COLORADO
r uc
HWO Rof F i.t.vmmmll
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.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: I S W E 9s70g AIRS ID Number: 123 / 9ED6/ O/D
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: Flarecatcher
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Great Western Operating Company, LLC
Site Name: Burr FD Pad
Site Location: SESE Sec. 24 T6N R67W
Mailing Address:
(Include Zip Code) 1001 17th St., Suite 2000
Denver, CO 80202
E=Mau Address2 bhuggins@gwogco.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Ben Huggins
Phone Number: (303) 398-0302
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-211 - Natural Gas Venting APEN • Rev 03/2017
323705 or COLORADO
Nurt1A b Lnneewrm
Permit Number:
AIRS ID Number: 123 / 9ED6 / XXX
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
2 NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment 0 Change company name ❑ Add point to existing permit
❑ Change permit limit 0 Transfer of ownership' ❑ Other (describe below)
OR -
• APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info It Notes:
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
gas.
Removal of natural gas liquids from produced
For existing sources, operation began on: / /
For new or reconstructed sources, the projected
start-up date is:
2018
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
days/week weeks/year
Will this equipment be operated in any NAAQS nonattainment 0 Yes
area
Is this equipment located at a stationary source that is ❑ Yes
considered a Major -Source -of (HAP) -Emissions
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
❑ No
2 No
COLORADO
2I AV'°R-
Ile.[�T 6 Enwexam�
Permit Number:
AIRS ID Number: 123 /9ED6/ XXX
[Leave blank unless APCD has already assigned a permit 5 and AIRS ID]
Section 4 - Process Equipment Information
❑ Gas/Liquid Separator
O Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑✓ Other
Description: Natural gas processing using a Flarecatcher
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? El Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
10, 000
SCF/hr
Vent Gas
Heating Value:
1130.5
BTU/SCF
Requested:
87.60
MMSCF/year
Actual:
87.60
MMSCF/year
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
4.6487
VOC (Weight %)
10.2700
Benzene (mole %)
0 001
Benzene (Weight %)
0.0037
Toluene (mole %)
0.0005
Toluene (Weight %)
0.0022
Ethylbenzene (mole %)
0.0001
Ethylbenzene (Weight %)
0.0005
Xylene (mole %)
0.0005
Xylene (Weight %)
0.0025
n -Hexane (mole %)
0.0032
n -Hexane (Weight %)
0.0132
2,2,4-Trimethylpentane
(mole %)
2 2;4 Trimethylpentane-
—
0.0016
0.0003
(Weight %)
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX a n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX ft n -Hexane, temperature, and
pressure)
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
3 i AY COLORADO
Tut
Permit Number:
AIRS ID Number: 123 / 9ED6/ XXX
[Leave blank unless APCD has already assigned a permit N and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.466215, -104.833861
operator
Stack ID No
Discharge Height ,
Above Ground Level
r
(Feet)
Tem
)
( )
Flow Rate
(ACFM) ..
Velocity
(ft/sec)
Flarecatcher
-40
-1400
683,100 max.
115 max.
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
❑✓ Upward
0 Horizontal
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
0 Other (describe):
❑ Upward with obstructing raincap
135.5
Section 6 - Control Device Information
❑✓ VRU:
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled:
Rating:
VOC, HAP
80
MMBtu/hr
Type: ECD Make/Model: QTI Q5000
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency 98 %
Minimum Temperature:
Constant Pilot Light: ❑✓ Yes 0 No Pilot burner Rating .0.25 MMBtu/hr
Waste Gas HeatContent1130.5 Btu/scf
•
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
��cOLO =
PM
Permit Number:
AIRS ID Number: 123 / 9ED6/ XXX
[Leave blank unless APCD has already assigned a permit Ya and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑ No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Overall Requested.Controt
Efficiency
(% reduction in emissions)
Control Equipment Description
sox
NOx
VOC
ECD
95
CO
HAPs
ECD
95
Other:
Projected
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source:
late these emissions.
te d in Sections 4 and 6 to calcu)
(use
the data repot
Pollutant
Uncontrolled :
Emission
Factor
Emission
Factor
Units
Emission
Factor
Actual"Annual Emissions
Requested Annual Permit
Fa Emission Limit s skx '"
Source
(AP -42,
Mfg. etc)
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year) ,'.(Tons/year).
Controlled
PM
SOx
NOx
VOC
5646.7
Ib/MMscf
SSEF
247.3 -
12.4 -
247.3
12.4
CO
Benzene
2.06
Ib/MMscf
SSEF
0.1
0.0
0.1
0.0
Toluene
1.21
Ib/MMscf
SSEF
0.1
0.0
0.1
0.0
Ethylbenzene
0.28
Ib/MMscf
SSEF
0.0
0.0
0.0
0.0
Xylenes
1.40
lb/MMscf
SSEF
0.1
0.0
0.1
0.0
n -Hexane
7.27
Ib/MMscf
SSEF
0.3 -
0.0
0.3
0.0
2,2,4-
Trimethylpentane
0.90
Ib/MMscf
SSEF
0.0
0.0
0.0
0.0
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
®COLORADO
5 j
Permit Number:
AIRS ID Number: 123 / 9ED6/ XXX
[Leave blank unless APCD has already assigned a pennit and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
6/12/2018
Signature of Legally Authorized Person (not a vendor or consultant) Date
Ben Huggins
EHS Manager
Name (please print) Title
Check the appropriate box to request a copy of the:
�✓ Draft permit prior to issuance
• Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
43O0 Cherry Creek Dnve South -
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
-Or visit -the APCD website at: — ----
https: //www.colorado.gov/cdphe/apcd
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 6 I
AY
COLORADO
xis a rnw,e
117
II
I' i
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
IlSi
17
o/tv / 2 2018 'q-:!
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal. -
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
f SWE01
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: Produced Gas
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
AIRS ID Number: 123 / 9ED6/ d / /
Section 1 - Administrative Information
Company Name': Great Western Operating Company, LLC
Site Name: Burr FD Pad
Site Location: SESE Sec. 24 T6N R67W
Malting Address: 1001 17th St., Suite 2000 _
(Include Zip Code)
Denver, CO 80202
E -Mail Address': bhu-ggirfs@gwogcocom
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Ben Huggins
Phone Number: (303) 398-0302
1Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-211 - Natural Gas Venting APEN - Rev 03/2017
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Permit Number:
AIRS ID Number: 123 / 9ED6 / XXX
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 2- Requested Action
O NEW permit OR newly -reported emission source
- OR -
• MODIFICATION to existing permit (check each box below that applies).
Change fuel or equipment 0 Change company name 0 Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Produced Gas flaring
For existing sources, operation began on:
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:
/ / 2018
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered -a Major Source of (HAP) Emissions
days/week weeks/year
Yes 0 No
❑ Yes 0 No
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
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Permit Number:
AIRS ID Number: 123 / 9ED6 / XXX
[Leave blank unless APCD has already assigned a permit ;' and AIRS ID]
Section 4 - Process Equipment Information
❑ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make:
Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑✓ Other
Description: Produced Gas flaring
Serial #:
# of Pistons:
Volume per event:
Capacity:
Leak Rate:
Gal/min
Scf/hr/pist
MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
12 500
9
SCF/hr
Vent Gas
Heating Value:
1295.4
BTU/SCF
Requested:
109.50
MMSCF/year
Actual:
109.50
MMSCF/year
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will became permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
10.8143
VOC (Weight %)
25.1038
Benzene (mole %)
0.0126
Benzene (Weight %)
0.0443
Toluene (mole %)
0.0085
Toluene (Weight %)
0.0350
Ethylbenzene (mole %)
0.0006
Ethylbenzene (Weight %)
0.0031
Xylene (mole %)
0.0032
Xylene (Weight %)
0.0153
n -Hexane (mole %)
0.0898
n -Hexane (Weight %)
0.3475
2,2,4-Trimethylpentane
(mole %)
0.00004
x,2,4-Trimethylpentane
(Weight %)
0.0002
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
II
.II'I
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
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Process Flare
Permit Number:
AIRS ID Number: 123 / 9ED6/ XXX
[Leave blank unless APCD has already assigned a permit t; and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.466215, -104.833861
Discharge Height
Above Ground Level
(Feet)
Flow Rate,
(ACI=M),
Velocity
(ft/set)
-40
—1400
683,100 max.
115 max.
Indicate the direction of the stack outlet: (check one)
0 Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
El Other (describe):
❑ Upward with obstructing raincap
135.5
Section 6 - Control Device Information
❑r VRU:
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled: VOC, HAP
Rating:
80
Type: ECD
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
MMBtu/hr
Make/Model: QTI Q5000
95 %
98 %
Waste Gas Heat Content 1294.5 Btu/scf
Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating
0.25 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
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4 I ®- e,
Permit Number:
AIRS ID Number: 123 / 9ED6/ XXX
[Leave blank unless APCD has already assigned a permit H and AIRS ID)
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? I Yes ❑ No
.....\.
If describe the control equipment. Hwu DLoLC a eC u.ci au .......... • •.... •-, ,... ----
yes, please
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
sox
NO.
VOC
ECD
95
CO
HAPs
ECD
95
Other:
Projected
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source:
ise me aam repotLeu lit JCL-L,LAL) -, a,m.., ........ ...--_
Pollutant
Uncontrolled .
Emission
Factor
Emission
Factor
Units
Emission
Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)s'
Source
(AP -42.
Mfg. etc)
Uncontrolled
(Tons/year) .
Controlled6
(Tons/year)
Uncontrolled
- (Tons/year)
Controlled
(Tons/year)
PM
SOx
NOx
VOC
14739.8
Ib/MMscf
SSEF
807.0
40.4
807.0 -
40.4 -
CO
Benzene
26.00
Ib/MMscf
SSEF
1.4
0.1
1.4 -
0.1
Toluene
20.57
lb/MMscf
SSEF
1.1
0.1
1.1 -
0.1
Ethylbenzene
1.80
Ib/MMscf
SSEF
0.1
0.0
0.1
0.0
Xylenes
8.99
lb/MMscf
SSEF
0.5
0.0
0.5 ,-
0.0 -
n -Hexane
204.02
Ib/MMscf
SSEF
11.2
0.6
11.2 -
0.6
2,2,4-
Trimethylpentane
0.12
Ib/MMscf
SSEF
0.0
0.0
0.0
0.0
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
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Permit Number:
AIRS ID Number: 123 / 9ED6/ XXX
[Leave blank unless APED has already assigned a permit # and .-.IRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
6/12/2018
Signature of Legally Authorized Person (not a vendor or consultant)
Ben Huggins
Date
EHS Manager
Name (please 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)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek_ Drive_ South _-
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visittheAPCD website_at:
https: //www.colorado.gov/cdphe/apcd
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