HomeMy WebLinkAbout20181632.tiffCOLORADO
Department of Public
Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150.0 St
PO Box 758
Greeley, CO 80632
May 17, 2018
Dear Sir or Madam:
RECEIVED
MAY 2'1 2018
COMMISSION RE S
On May 24, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for
Cureton Front Range LLC - Tiger Compressor Station. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to.
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Fjickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
? 11,c, RtArLew eat "PL(ITp) , j4 LC j T)1
05-30-18 Pw cEokr ck(1-Kfe )
O5-a1-ig
2018-1632
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Cureton Front Range LLC - Tiger Compressor Station - Weld County
Notice Period Begins: May 24, 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: Cureton Front Range LLC
Facility: Tiger Compressor Station
Natural Gas Compressor Station
NWSE Section 19, T1 N, R64W
Weld County
The proposed project or activity is as follows: Source proposes to operate one (1) 40 MMSCFD Triethylene
Glycol dehydrator.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0036 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:
Bradley Eades
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: Bradley. Cedes
Package#: 373231`.
Received Date: 1/4/2018
Review Start Date: 4/18/2018
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name: Tcge{€,0ompres4or4Station;
Physical Address/Locatio NWSE quadrant of Section 19, Township 1N, Range 64WW, in Weld County, Colorado
Type of Facility:
What industry segment? Rit,
Is this facility located in a NAAQ5 non -attainment area?
If yes, for what pollutant? Ca on Mono6de (CO) P�a evlate Matter (PM) Erie (No. a vac)
Weld
Quadrant
Section
Township
Range
64W
NWSE
19
1N
Section 02 - Emissions Units In Permit Application
AIRS Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
001.
'EEGs#Sehytftatssr
TEG1
Yes
IGWE0036
1
Yes;,'
Permitinitisl
Issuance
Section 03 - Description of Project
bmitted app
mbustt
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synicinae
ain a contruction permit fora dehydration unit at a
mpressor station
Emissions fro
dehydrator
rolled use
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 NOx CO VOC PM2.5 PM10 TSP HAPs
Is this stationary source a major source? No„4
If yes, explain what programs and which pollutants here SO2 NOx CO
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
VOC
❑ ❑d
PM2.5 PM10 TSP HAPs
❑ ❑
Glycol Dehydrator Emissions Inventory
Section 01- Administrative Information
LFaCRity AIRS ID:
Section 02- Equipment Description Details
Dehydrator Information
Dehydrator Type:
Make:
Model:
Serial Number:
Design Capacity:
Recirwlation Pump Information
Number of Pumps
Pump Type
Make:
Model:
Design/Max Recirculation Rate:
Dehydrator Equipment
Flash Tank
Reboiler Sumer
Stripping Gas
Dehydrator Equipment Description
9F89
Plant
Poin
MMscf/day
gallons/minute
ash tank,
id reboiler burner
One (1) Trlethylene glycol (TEG) natural gas dehydration unit (Make: TBD, Model: TBD, Serial Number: TBD) welt a design
capacity of 40 MMscf per day. This emissions unit is equipped with one (1) (Make: TBD, Model: TBD) electric driven glycol
pump with a design capacity of 7 gallons per minute. This dehydration unit is equipped with a still vent, flash tank, and
reboller burner.
Emissions from the still vent are routed to the Enclosed Flare. Emissions from the flash tank are routed directly to the
Emission Control Device Description: Enclosed Flare.
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions- Dehydrator Still Vent and Flash Tank (if present)
Requested Permit Limit Throughput= 14600".ff; MMscfper year
Potential to Emit (PTE) Throughput = 14,600.0 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Still Vent Control
Condenser:
Condenser emission reduction claimed:
Primary control device:
Primary control device operation:
Secondary control device:
Secondary control device operation:
Still Vent Gas Heating Value:
Still Vent Waste Gas Vent Rate:
Flash tank Control
Primary control device:
Primary control device operation:
Secondary control device:
Secondary control device operation:
Flesh Tank Gas Heating Value
Rash Tank Waste Gas Vent Rate:
0.14
hr/yr
.434.00 Btu/scf
scfh
9556 Control Efficiency%
Control Efficiency %
Wet Gas Processed:
Still Vent Primary Control: 14,600.0 MMscf/yr
Still Vent Secondary Control: 0.0 MMscf/yr
Waste Gas Combusted:
Still Vent Primary Control: 30.5 MMscR/yr
Still Vent Secondary Control: 0.0 MMscf/yr
Wet Gas Processed:
Flash Tank Primary Control: 14,600.0 MMscf/yr
Flash Tank Secondary Control: 0.0 MMscf/yr
Waste Gas Combusted:
Flash Tank Primary Control: 4.8 MMscf/yr
Flash Tank Secondary Control: 0.0 MMscf/yr
Glycol Dehydrator Emissions Inventory
Section 04- Emissions Factors & Methodologies
Dehydrator
e. Thamn9el'a
1000 :" psig
120 degF
] gpm
STILL VENT
Control Scenario
Primary
Secondary
Pollutant
Uncontrolled (lb/hr)
Controlled (lb/hr)
Controlled (lb/hr)
VOC
20.3116
1.01558
0
Benzene
0.1144
0.00572
0
Toluene
00746.
0.00373
0
Ethylbenzene
-...__. 0.0124
0.00062
0
Xylenes
0.0193
0.000965
0
n -Hexane
0.1856.
0.00928
0
224-TMP
0
0
0
FLASH TANK
Control Scenario
Primary
Secondary
Pollutant
Uncontrolled (lb/hr)
Controlled (lb/hr)
Controlled (lb/hr)
VOC
14.9660
0.99834
0
Benzene
3.7254.:.
0.18627
0
Toluene
3.7019 >
0.185095
0
Ethylbenzene
1.0484
0.05242
- 0
Xylenes
2.4176
0.12088
0
n-Hezane
0.2000
0.010495
0
224-TMP
0 ',.
0
0
Emission Factors
Pollutant
Benzene
Toluene 2.27
Glycol Dehydrator
Uncontrolled
(Ib/MMscf) (lb/MM
(Wet Gas
Throughput)
Controlled
Ethylbenzene 0.64
Xylene 1.46
a -Hexane 0.24
224 IMP 0.00
(Wet Gas Throughput)
.21E+00
1.15E-01
.13E-01
18E-02
7.31E-02
1.19E-02
0.00E+00
Pollutant
Still Vent Primary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu( (Ib/MMscf)
(Waste Hest
Combusted)
(Waste Gas
Combusted(
PM30 _ 0.0075
PM2.5 0.0075
0.8418
0.8418
0.0665
7.6829
35.0248
SO z 0.0006
NO0.0680
CO jj= llilli33?;0-;3100
Pollutant
Pollutant
Still Vent Secondary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu( (Ib/MMscf)
(Waste Haat
Combusted)
Emission Factor Source
(Waste Gas
Combusted)
Flash Tank Primary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu(
(Waste Heat
Combusted(
P M 10 0.0075
PM2.5 0.0075
SO x 0.0006
PIOx 0.0680
CO _.___......0.3100
Pollutant
(Ib/MMsrf)
(Waste Gas
Combusted)
10.6849
10.6849
0.8435
97.5137
444.5478
Flash Tank Secondary Control De
Uncontrolled Uncontrolled
(Ib/MMBtu( (lb/MM
(Waste Heat
Combusted(
(Waste Gas
Combusted)
0.0000
0.0000
0.0000
0.0000
0.0000
Emisslon Factor Source
Emission Factor Source
Emission Factor Source
Emission Factor Source
Glycol Dehydrator Emissions Inventory
Section 05 - Emissions Inventory
Did operator request a buffer?
Requested Buffer (%):
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)
PM10
PM2.5
sox
NOx
CO
VOC
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0,0
0.4
0.9
0.4
0.41
0.41
1.9
1.9
1.9
1.88
1.88
176.4
176.4
8.8
176.42
8.82
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Pe mit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224TMP
33,637
33,637
1,682
33,637
1,682
33,082
33,082
1.654
33,082
1,654
9.293
9,293
465
9,293
465
21,347
21,347
1,067
21,347
1,067
3,465
3,465
173
3,465
173
-
-
-
-
-
S seine 06- Regulatory Summary Analysis
Regulation 3, Parts A,
Regulation 7, Section XVII.6,1
Regulation 7, Section XVII.B.2.e
Regulation 7, Section XII.H
Regulation 6, Part E, MACT Subpart HO (Area)
Regulation 8, Part E, MACT Subpart HO (Major)
Regulation 8, Part E, MACT Subpart HHH
(See regulatory applicability worksheet for detailed analysts)
Source requires a permit
Dehydrator is subject to Regulation 7, Section WI', B, 0.3
The control device for this dehydrator is not subject to Regulation 7, Section XVII.B.2.
Dehydrator is subject to Regulation 7, Section XII.H
You have Indicated that this facility is not subject to Major Source requirements of MI,
You have indicated that this facility is not subject to MACT HHH.
Section 07 - Initial and Periodic Sampling and Testing Requirements
Was the extended wet gas sample used in the GlyCalc model/Process model site -specific and collected within a year
of application submittal?
If no, the permit will contain an "Initial Compliance" testing requirement to demonstrate compliance with emission limits
'Inlcodes. Pilot at 1851 mmbtu/yr
'Inlcudes Pilot at 1851 mmbtu/yr
Does the company request a control device efficiency greater than 95% fora 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
Requested Permit Limits
Uncontrolled Controlled
(lb/month) (lb/month)
6.5
6.5
6.5
6.5
0.5
0.5
70.0
70.0
319.3
319.3
29967.1
1498.4
Section oo - Technical Analysis Notes
Applicant indicates that the sell vent waste gas is p.rocessed through a liquid knockout vessel toremaye excess waren prior to combustion in the enclosed. flare. Throb the removal of the water, applicant
Iaas calOulate4 a HHV. of 1720 for the combs ed emission stream directed to the EC D. The caicutationsabove use.: raw data from GlyCalc ancombined results n tlHV 00291 btujscf, however, the
ca(10)a0(60 Rf NOx and Co emissions is a curato since rho sc)/hr Is hig'ner with the inclusion ofwatgr ((.e. the HHV on a btu/`cf A'asis is different when Using the postoknaok Due stOe m, ht¢t the t000l
MMbtu/Mr remains the same Sinn water is 0 btu/scf)S'.
This fanitiy`has not began operaffon and'a site -specific sample cvas
potential emission rates from this dehydrator
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point 9
00
Process SCC Code
001 01 ,3,-'i63HBOW E7:
ended gas analysis will be require
IFsertWoAtben. ta,'con[irm the
Pollutant
PM10
PM2.5
SOx
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
Uncontrolled
Emissions Factor
0.005
0.005
0.000
0.056
24.2
0.258
2.304
2.266
0.636
1.462
0.237
Control%
0.0
0.0
0.0
0.0
95.0
0.0
95.0
95.0
95.0
95.0
95.0
Units
b/MMscf
b/MMsct
b/MMscf
b/MMsd
b/MMscf
b/MMscf
b/MMscf
b/MMscf
b/MMscf
b/MMscf
b/MMscf
Dehydrator Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
'You have indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)?
'Source requires a permit
Colorado Regulation 7, Section XII.H
1. Is this glycol natural gas dehydrator located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Reg 7, Section XII.H.1 and 2)?
2. Is this glycol natural gas dehydrator located at an oil and gas exploration and production operation', natural gas compressor station, natural gas drip station or gas -processing plant (Reg 7 Section
3. Is the sum of actual uncontrolled emissions of VOC from any single dehydrator or group of dehydrators at a single stationary source equal to or greater than 15 tpy (Reg 7, Section XII.H.3.b)?
4. Are actual uncontrolled emissions of VOC from the individual glycol natural gas dehydrator equal to or greater than 1 tpy (Reg 7, Section XII.H.3.a)?
'Dehydrator is subject to Regulation 7, Section XII.H
Section XII.H — Emission Reductions from glycol natural gas dehydrators
MACT Analysis
1. Is the dehydrator located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a))2)); OR
A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end
b. user' (63.760(a)(3))?
2. Is the dehydrator located at a facility that is a major source for HAPs?
IOo to MVMACT HH Area Source Requirement section to determine MALT HH applicability
Yes
Yes
Yes
40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities
Area Source Requirements
1. Is the dehydrator a triethylene glycol (TEG) dehydration unit (63.760(b)(2))?
Exemptions
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.764(e)(1)(i)?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.764(e)(1)(ii)?
3. Is the unit located inside of a UA plus offset and UC boundary area?
0
Yes
Subpart A, General provisions per §63.764 (a) Table 2
§63.765 - Emissions Control Standards Do Not Apply
§63.773 - Monitoring Standards Do Not Apply
§63.774 - Recordkeeping
§63.775 - Reporting Standards Do Not Apply
Major Source Requirements
1. Does the facility have a facility -wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility -wide actual annual average hydrocarbon liquid throughput less than 249.7
Small or Large Dehv Determination
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.761)?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.761)?
Small Dehv Requirements
3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.760(b)(1)(i)(B) and (C )?
4. For this small dehy, is a control device required to meet the BTEX emission limit given by the applicable equation?
IYou have indicated that this facility is not subject to Major Source requirements of MACT NH.
Subpart A, General provisions per §63.764 (a) Table 2
§63.765 - Emissions Control Standards
453.773 - Monitoring
§63.774 - Recordkeeping
§63.775 - Reporting
�r
40 CFR, Part 63, Subpart MACT HHH, Natural Gas Transmission and Storage Facilities
1 Is the facility wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the only HAP emission source (63.1270(f))?
Small or Large Dehv Determination
2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per day (63.1270(b)(2))?
2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.1270(b)(2))?
Small Dehv Requirements
3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.1270(b)(2) and (3) )?
4. For this small dehy, is a control device required to meet the BTEX emission limit (standard?) given by the applicable equation?
You have indicated that this facility is not subject to MACT HHH.
Subpart A, General provisions per §63.1274 (a) Table 2
§63.1275 - Emissions Control Standards
§63.1281 -Control Equipment Standards
§63.1283 - Inspection and Monitoring
§63.1284 - Record keeping
§63.1285 - Reporting
Colorado Regulation 7, Section XVII.D
1. Is the dehydrator subject to an emissions control requirement under MACT HH or HHH (Regulation 7, Section XVII.B.5)?
2. Is this dehydrator located at a transmission/storage facility?
3. Is this dehydrator located at an oil and gas exploration and production operation , natural gas compressor station or gas processing plant (Reg 7, Section XVII.D.3)?
4. Was this glycol natural gas dehydrator constructed before May 1, 2015 (Reg 7 Section XVII.D.4.b)?
If constructed prior to May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 6 tons per year VOC or 2 tpy VOC if the
4a. dehydrator is located within 1,320 feet of a building unit or designated outside activity area (Reg 7, Section XVII.D.4.b)?
5. If constructed on or after May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 2 tpy VOC (Regulation 7, Section XVII.D.4.a)?
No
No
'Dehydrator is subject to Regulation 7, Section XVII, B, D.3
Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.D.3 - Emissions Reduction Provisions
Alternative Emissions Control (Optional Section)
6. Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
'The control device for this dehydrator is not subject to Regulation 7, Section XVII.B.2.e
Section XVII.B.2.e — Alternative emissions control equipment
Disclaimer
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.
Yes
Permit number:
Date issued:
Issued to:
h & Environment
CONSTRUCTION PERMIT
18WE0036
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Cureton Front Range, LLC
Tiger Compressor Station
123/9F89
NWSE SEC 19 T1 N R64W
Weld County
Natural Gas Compressor Station
Equipment or activity subject to this permit:
Facility
Equipment ID
AIRS
Point
Equipment Description
Emissions Control
Description
TEG1
001
One (1) Triethylene glycol (TEG) natural gas
dehydration unit (Make: TBD, Model: TBD, Serial
Number: TBD) with a design capacity of 40
MMscf per day. This emissions unit is equipped
with one (1) (Make: TBD, Model: TBD) electric
driven glycol pump with a design capacity of 7
gallons per minute. This dehydration unit is
equipped with a still vent, flash tank, and
reboiler burner.
Emissions from the still
vent and flash tank are
routed to a liquid knock
out vessel and then to
an enclosed flare.
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/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.
COLORADO
Air Pollution Control Division
Ih"xvonewn₹ of Pubic 4ealitr s envoi .nment
Page 1 of 10
2.
rmit. A
this permit
andei
plianc
i he •"
ner
onst
ertl i i•n fo
may be obtained
•',:; the la
•i 1'•ns co
tors resp
• Hance w
online
r of commencement of operation or issuance
fined in this permit shall be demonstrated to
ibility to self -certify compliance with the
in 180 days may result in revocation of the
ance o "` •w to self -certify compliance as required by
at www.colorado.gov/pacific/cdohe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days of the latter
of commencement of operation or issuance of this permit.
• The dehydrator manufacturer name, model number and serial number
• The glycol circulation pump manufacturer name and model number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation Number 3, Part B, III.E.)
6. 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.)
)
Monthly Limits:
Facility
Equipment ID
AIRS Point
Pounds per Month
Emission
Type
PM2.5
NOX
VOC
CO
TEG1
001
---
---
1,499
---
Point
Note: Monthly limits are based on a 31 -day month.
The owner or operator shall calculate monthly emissions based on the calendar month.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 1,359 pounds
per month.
Facility -wide emissions of total hazardous air pollutants shall not exceed 3,398 pounds per
month.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
COLORADO
Air Pollution Control Division
en Punic s e t U ;.itmftment
Page 2 of 10
"mi
TEG1
001
VOC CO
Emission
Type
8.9
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.
During the first twelve (12) months of operation, compliance with both the monthly and annual
emission limitations is required. After the first twelve (12) months of operation, compliance with
only the annuar limitation is required.
Compliance with the annual limits, for criteria and hazardous air pollutants, shall be determined
on a rolling twelve (12) month total. By the end of each month a new twelve month total is
calculated based on the previous twelve months' data. The permit holder shall calculate actual
emissions each month and keep a compliance record on site or at a local field office with site
responsibility for Division review.
8. Compliance with the emission limits in this permit shall be demonstrated by running the GRI
GlyCalc model version 4.0 or higher on a monthly basis using the most recent extended wet gas
analysis and recorded operational values, including: gas throughput, lean glycol recirculation
rate, flash tank temperature and pressure, wet gas inlet temperature, and wet gas inlet pressure.
Recorded operational values, except for gas throughput, shall be averaged on a monthly basis
for input into the model and be provided to the Division upon request.
9. The owner or operator shall operate and maintain the emission points in the table below with
the emissions control equipment as listed in order to reduce emissions to less than or equal to
the limits established in this permit. The owner or operator shall operate this dehydration unit
so as to prevent any emissions directly to the atmosphere. (Regulation Number 3, Part B, Section
III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
TEG1
001
Still Vent: Enclosed Flare
VOC and
HAP
Flash Tank: Enclosed Flare
PROCESS LIMITATIONS AND RECORDS
10. 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.)
COLORADO
Air Pollution Control Division
2 " K. a r } ut c Fieu::h & Dwzronrnelat
Page 3 of 10
Fa ity
Eq me
ID
. S
t
Pro ss P =- meter
Annual Limit
Monthly Limit
(31 days)
TEG1
001
Dry Gas Throughput
14,600 MMscf/yr
1,240 MMscf/month
The owner or operator shall monitor monthly process rates based on the calendar month. The
volume of dry gas processed shall be measured by gas meter.
During the first twelve (12) months of operation, compliance with both the monthly and annual
throughput limitations is required. After the first twelve (12) months of operation, compliance
with only the annual limitation is required.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
11. This unit shall be limited to the maximum lean glycol circulation rate oi.7.0 gallons per minute.
The lean glycol recirculation rate shall be recorded weekly in a log maintained on site and made
available to the Division for inspection upon request. Glycol recirculation rate shall be monitored
by one of the following methods: assuming maximum design pump rate, using glycol flow
meter(s), or recording strokes per minute and converting to circulation rate. This maximum
glycol circulation rate does not preclude compliance with the optimal glycol circulation rate
(Lopt) provisions under MACT HH. (Reference: Regulation Number 3, Part B, II.A.4)
12. On a monthly basis, the owner or operator shall monitor and record operational values including:
flash tank temperature and pressure, wet gas inlet temperature and pressure. These records
shall be maintained for a period of five years.
STATE AND FEDERAL REGULATORY REQUIREMENTS
13. 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)
14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
15. This source is subject to Regulation Number 7, Section XII.H. The operator shall comply with all
applicable requirements of Section XII and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for glycol natural gas dehydrators; and
• Ensure uncontrolled actual emissions of volatile organic compounds from the still vent
and vent from any gas -condensate -glycol (GCG) separator (flash separator or flash tank),
if present, shall be reduced by at least 90 percent on a rolling twelve-month basis
through the use of a condenser or air pollution control equipment. (Regulation Number
7, Section XII.H.1.)
16. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2
General Provisions (State only enforceable). If a flare or other combustion device is used to
control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed;
have no visible emissions during normal operations, as defined under Regulation Number 7,
XVII.A.16; and be designed so that an observer can, by means of visual observation from the
outside of the enclosed flare or combustion device, or by other convenient means approved by
the Division, determine whether it is operating properly. This flare must be equipped with an
operational auto -igniter according to the following schedule:
COLORADO
Air Pollution Control Division
ne x cr ktht = 1eai°^n Er;vvorirnent
Page 4 of 10
n or a''' -r May 1, 2014, must be equipped with an
llation the combustion device;
All mb� _ion•eviced befor `' ay 1, 2014, must be equipped with an
opnanit fore M 016, or after the next combustion device
planned shutdown, whichever comes first.
17. The glycol dehydration unit covered by this permit is subject to the emission control
requirements in Regulation Number 7, Section XVII.D.3. Beginning May 1, 2015, still vents and
vents from any flash separator or flash tank on a glycol natural gas dehydrator located at an oil
and gas exploration and production operation, natural gas compressor station, or gas -processing
plant subject to control requirements pursuant to Section XVII.D.4., shall reduce uncontrolled
actual emissions of hydrocarbons by at least 95% on a rolling twelve-month basis through the use
of a condenser or air pollution control equipment.
18. The glycol dehydration unit at this facility is subject to National Emissions Standards for
Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities,
Subpart HH. This facility shall be subject to applicable area source provisions of this regulation,
as stated in 40 C.F.R Part 63, Subpart A and HH. (Regulation Number 8, Part E, Subpart A and
HH)
MACT HH Applicable
Requirements
Area Source
Benzene emissions exemption
§63.764 - General
Standards
§63.764 (e)(1) - The owner or operator is exempt from the requirements of
paragraph (d) of this section if the criteria listed in paragraph (e)(1)(i) or (ii)
of this section are met, except that the records of the determination of
these criteria must be maintained as required in §63.774(d)(1).
§63.764 (e)(1)(ii) - The actual average emissions of benzene from the glycol
dehydration unit process vent to the atmosphere are less than 0.90
megagram per year, as determined by the procedures specified in
§63.772(b)(2) of this subpart.
§63.772 - Test
Methods, Compliance
Procedures and
Compliance
Demonstration
§63.772(b) - Determination of glycol dehydration unit flowrate or benzene
emissions. The procedures of this paragraph shall be used by an owner or
operator to determine glycol dehydration unit natural gas flowrate or
benzene emissions to meet the criteria for an exemption from control
requirements under §63.764(e)(1).
§63.772(b)(2) - The determination of actual average benzene emissions
from a glycol dehydration unit shall be made using the procedures of either
paragraph (b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be determined
either uncontrolled, or with federally enforceable controls in place.
§63.772(b)(2)(i) - The owner or operator shall determine actual average
benzene emissions using the model GRI-GLYCaIc TM, Version 3.0 or higher,
and the procedures presented in the associated GRI-GLYCaIc TMTechnical
Reference Manual. Inputs to the model shall be representative of actual
operating conditions of the glycol dehydration unit and may be determined
using the procedures documented in the Gas Research Institute (GRI) report
entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator
Emissions" (GRI-95/0368.1); or
§63.772(b)(2)(ii) - The owner or operator shall determine an average mass
rate of benzene emissions in kilograms per hour through direct measurement
using the methods in §63.772(a)(1)(i) or (ii), or an alternative method
according to §63.7(f). Annual emissions in kilograms per year shall be
determined by multiplying the mass rate by the number of hours the unit is
operated per year. This result shall be converted to megagrams per year.
COLORADO
Air Pollution Control Division
0,strnelt of Past e E e & invzonment
Page 5 of 10
563.774 -
Recordkeeping
Requirements
rea Source
missions exemption
. ` 4 ( • - ner o - for of a glycol dehydration unit that
meets the exemption criteria in 563.764(e)(1)(i) or $63.764(e)(1)(ii) shall
maintain the records specified in paragraph (d)(1)(i) or paragraph (d)(1)(ii)
of this section, as appropriate, for that glycol dehydration unit.
$63.774 (d)(1)(ii) - The actual average benzene emissions (in terms of
benzene emissions per year) as determined in accordance with
563.772(b)(2).
OPERATING Et MAINTENANCE REQUIREMENTS
19. 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
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
20. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
21. The owner or operator shall complete the initial extended wet gas analysis within one hundred
and eighty days (180) of the latter of commencement of operation or issuance of this permit.
The owner or operator shall use this analysis to calculate actual emissions, as prescribed in the
Emission Limitation and Records section of this permit, to verify initial compliance with the
emission limits. The owner or operator shall submit the analysis and the emission calculation
results to the Division as part of the self -certification process. (Reference: Regulation Number
3, Part B, Section III.E.)
I. E. )
Periodic Testing Requirements
22. The owner or operator shall complete an extended wet gas analysis prior to the inlet of the
dehydration unit on an annual basis. Results of the wet gas analysis shall be used to calculate
emissions of criteria pollutants and hazardous air pollutants per this permit and be provided to
the Division upon request.
ADDITIONAL REQUIREMENTS
23. 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 (NO),) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO„ per year, a change in
COLORADO
Aix Pollution Control Division
'?egta_rrelt- P b€ Lriiron'tent
Page 6 of 10
year or more or five percent, whichever is
t APEN; or
For `urc em' ing 1 er year E; more, a change in actual emissions of five
pe - or • ` • ` pe - . ore, wh ' -ver 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.
24. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any
stationary source or modification becomes a major stationary source or major modification solely
by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980,
on the capacity of the source or modification to otherwise emit a pollutant such as a restriction
on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B).
GENERAL TERMS AND CONDITIONS -
25. 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.
26. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this 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.
27. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
28. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
29. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
COLORADO
Air Pollution Control Division
"Depart en puhtc Hea₹au.E, twsvircxrrteit
Page 7 of 10
e to meet any express term or condition of
ns imposed upon a permit are contested by
mit, the owner or operator of a source may
Division's action.
30. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
31. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Bradley Eades
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Cureton Front Range, LLC
COLORADO
Air Pollution Control Division
PubticIle utter&e-^nn:rrunt
Page 8 of 10
1) Th .•ermit •ld is .uire• fees: t !- proc ing time for this permit. An invoice for these
fe: will • ssu ` of the ermi iss v'• The per t holder shall pay the invoice within 30 days
of nv :ilun - he in will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions Dosing 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
(lb/yr)
TEG1
001
Benzene
71432
33,637
1,682
Toluene
108883
33,082
1,654
Ethylbenzene
100414
9,293
465
Xylenes
1330207
21,347
1,067
n -Hexane
110543
3,465
173
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 information provided in the application
and the GRI GlyCalc 4.0 model. Controlled emissions are based on 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 permit fulfills the requirement to hold a valid permit reflecting the glycol dehydration unit and
associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(B)
when applicable.
COLORADO
Air Pollution Control. Division
pepovntnt Pubit elvptinniet;C
Page 9 of 10
Synthetic Minor Source of:
VOC, Total HAP
Status
Operating Permit
NANSR
Synthetic Minor Source of:
VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix
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
it Pollution Control Division
Eert iJ
Page 10 of 10
Glycol Dehydration Unit APEN - Form APCD-202
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, 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 Glycol Dehydration (Dehy) Units only. If your emission unit does not fall into this
category, there may be a more specific APEN for your source. 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: Co(due--00(C) AIRS ID Number: 1?. /(iMi bo I
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: TEG1
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Namel:
Site Name:
Site Location:
Cureton Front Range LLC
Tiger Compressor Station
Site Location
NWSE Sec. 19, R1 N, T64W County: Weld
Mailing Address:
(Include Zip Code) 518 17th Street, Suite 650
Denver, CO 80202
E -Mail Address2: nick.holland@curetonmidstrem.com
NAICS or SIC Code: 211111
Permit Contact: Nick Holland
Phone Number: 303-324-5967
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-202 - Glycol Dehydration Unit APEN - Revision 02/2017
373229
COLORADO
1 IAV
1427414�,,, =,�,<
Permit Number: AIRS ID Number:
,;s
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
El NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment O Change company name O Add point to existing permit
O 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:
40 MMSCFD TEG Dehydration unit equipped
with a Combustor for 95% control (design destruction efficiency of 98%)
Facility equipment Identification:
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
TEG1
/ /
TBD / /
El 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
Will this equipment be operated in any NAAQS nonattainment
area
Is this unit located at a stationary source that is considered a
Major Source of (HAP) Emissions
Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017
0
days/week
Yes
Yes
O
0
weeks/year
No
No
COLORADO
2 I �V xp mo a cur
Nwtl'yb EitI � n4nne1
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Dehydration Unit Equipment Information
Manufacturer: TBD Model Number: TBD
Dehydrator Serial TBD Reboiler Rating: 0.5
Number:
Glycol Used ❑ Ethylene Glycol ❑ DiEthylene Glycol
(EG) (DEG)
Glycol Pump Drive: El Electric ❑ Gas If Gas, injection pump ratio:
Pump Make and Model: TBD
MMBTU/hr
❑ TriEthylene Glycol
(TEG)
# of pumps:
Glycol Recirculation rate (gal/min):
Lean Glycol Water Content:
Max: 7.0
Wt.%
Requested: 7.0
Acfm/gpm
1
Dehydrator Gas Throughput:
Design Capacity: 40 MMSCF/day
Requested: 14600 MMSCF/year Actual: MMSCF/year
Inlet Gas: Pressure: 1000
Water Content: Wet Gas:
Flash Tank: Pressure: 35
Cold Separator: Pressure:
Stripping Gas: (check one)
j None ❑ Flash Gas ❑ Dry Gas 0 Nitrogen
Flow Rate:
scfm
psig Temperature: 120 °F
lb/MMSCF o Saturated Dry gas: 7.0 lb/MMSCF
psig Temperature: 130 °F 0 NA
psig Temperature: °F El NA
Additional Required linformation:
❑ Attach a Process Flow Diagram
Q Attach GRI-GLYCalc 4.0 Input Report Et Aggregate Report (or equivalent simulation report/test results)
El Attach the extended gas analysis (including BTEX ft n -Hexane, temperature, and pressure)
Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017
COLORADO
3INrHlegb E�'Viyp[H�w��.l
Permit Number:
AIRS ID Number:
0 Upward
0 Horizontal
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.036142/-104.594469
Operator
Stack ID NO
Discharge Height
eGround Level_
b‘'re
(Feet)
Temp
( F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Combustor
12
1000
5605
7.43
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
0 Upward with obstructing raincap
Indicate the stack opening and size: (check one)
El Circular Interior stack diarneter (inches): 48
0 Square/rectangle Interior stack width (inches): Interior stack depth (inches):
0 Other (describe):
Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017
COLORADOO
4 n<. Rt&P.auc
N�!4Ie14F++V!u≥m o,n
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
Used for control of:
❑ Condenser:
Type: Make/Model:
Maximum Temp Average Temp
Requested Control Efficiency
❑ VRU:
Used for control of:
Size: Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
❑ Combustion
Device:
Used for control of: VOC, HAPs
Rating: MMBtu / hr
Type: Combustor Make/Model: TBD
Requested Control Efficiency:
Manufacturer Guarankeed Control Efficiency
95
98
%
Minimum Temperature: NA Waste Gas Heat Content Btu/scf
Constant Pilot Light: 0 Yes 0 No Pilot burner Rating —0.21 MMBtu/hr
Closed
❑ Loop
System:
Used for control of:
Description:
System Downtime
❑ Other:
Used for control of:
Description:
Control Efficiency
Requested
Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017
COLORADO
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Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # 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? ID Yes O No
escribe the control eouipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOX
NOx
CO
VOC
Combustor
95%
HAPs
Combustor
95%
Other:
From what year is the following reported actual annual emissions data? - 2018
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
PM
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions..`
Requested Annual Permit
mission �tmttls
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
SOX
NOx
CO
VOC
24.17
Ib/MMSCF
Glycalc
176.42
8.82
Benzene
2.30
Ib/MMSCF
Glycalc
4-1.3`,
-0.19.0
Toluene
Ethylbenzene
2.27
0.64
Ib/MMSCF
Ib/MMSCF
Glycalc
Glycalc
3.7816St
- 0.83 DA
Xylenes
1.46
Ib/MMSCF
Glycalc
0.52.08
e:esa.o4.1
n -Hexane
2,2,4-
Trimethylpentane
Other:
0.24
lb/MMSCF
Glycalc
0.40443,
2
3
7
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
5Annual emission fees wilt be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
17,
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Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017
COLORADO
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Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contaiped herein and information submitted with this application is complete, true
and correct.
/9/062/ 7
Signature�f Legally Authorized Person (not a vendor or consultant) Date
Nick Holland
Director of EHS&R
Name (please print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
i] 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-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
S
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-202 -Glycol Dehydration Unit APEN - Revision 02/2017
I COLORADO
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