HomeMy WebLinkAbout20181628.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 16, 2018
Dear Sir or Madam:
RECEIVED
MAY 18 2018
WELD COUNTY
COMMISSIONERS
On May 17, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for
Confluence DJ, LLC - Flaherty 18-I 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 for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health &t Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: 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
?Li RedieW
05-S,3-18
Cc•. N4.LIT) PL( NArt tup),
"Pw (SR I CAA of. )
2018-1628
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Confluence DJ, LLC - Flaherty 18-I Pad - Weld County
Notice Period Begins: May 17, 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: Confluence DJ, LLC
Facility: Flaherty 18-I Pad
Oil and gas well production facility
NWSW SEC 18 T4N R62W
Weld County
The proposed project or activity is as follows: Venting and control of vapor recovery unit during system
downtime.
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 17WE0878 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:
Timothy Sharp
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
A -COLD#ADO
1
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: -Timothy Sharp:.
Package #: 366639
Received Date: 5/31/2017
Review Start Date: 9/13/2017
Section 01 - Facility Information
Company Name: Confluence Di, LLC
County AIRS ID: 123
Plant AIRS ID: 9EE4
Facility Name: Flaherty 18-I Pad
Physical Address/Locatlo NWSW quadrant of Section 18, Township 4N, Range 62W, in Weld County, Colorado
Type of Facility: Exploration & Production Well Pad
What industry segment? Olt & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? �on Monoxide (CO) Pa imlate Matter (PM) Eno (Nov & VOC)
Weld
Quadrant
Section
Township
Range
NWSW
18
4N
62
Section 02 - Emissions Units In Permit Application
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit t4
Issuance#
Self Cert
Required?
Action
Engineering
Remarks
009
Separator Venting
VRU Downtime
Yes
7WE0878
1
No
Permit Initial
Istuanee
Section 03 - Description of Project
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic Minor Permtt
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.
Yes....,....
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)
Yes
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
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)
Non -Attainment New Source Review (NANSR)
NOx
CO
PM2.5
VOC
❑ ❑
PM10 TSP HAPs
❑ ❑
Separator Venting Emissions Inventory
Section 01 Admintstratwe Information
Facility AIRs ID
County
9004
Plant
,.� „ 009' AIDS
Point
Section 02 Equipment Description Details
VRU Dowrttime+
Detailed Emissions Unit Description
endoseddcombustor —
Emission Control Device Description
Requested Overall VOC & HAP Control Efficiency 9'
Limited Process Parameter
Section 03 Processing Rate Information for Emissions Estimates
Pnmary Emissions -Separator
Actual Throughput = —
Requested Permit Unlit Throughput =t' 2*
12146 0T Barrels (bbl) per year
14,56610 Barrels (bbl) per year
Potential to Emit (PTE) Throughput = 14,568 Barrels (bbl) per year
Process Control (Recycling)
Equipped with a VRU IYet
Is VRU process equipment (yes
Uncontrolled and controlled emssions used to establish requested permit limits are based only on when the VRU is bypassed (t a waste gas volume that is muted to the flare)
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value ' ..� 3 3969 Btu/scf
Volume of waste gas emitted per BBL of
liquids throughput 9;',33, 213'081342.2 scf/bbl
Section 04 Emissions Factors & Methodologies
Description
Displacement Equation
Ex = O• MW • Xx / C
MW
n r40 4
Weight $
Helium
" '3"' 000
CO2
_ 233
N2
n33 P." - - 069
methane
`12 04
ethane
'3,3 2577
propane
h 3,', 3216
isobutane
414
n-hutane
412'49
sopentane
lz in'.t'13 p',4 256
n pentane
310
cyclopentane
073
n Hexane
" ,I'Ea5r`°D 86
cyclohexane
IC .->>'/j)j l023
Other hexanes
S ', d; m i3IIl$II3049
heptanes
llIl)ll'a I ',' 075
methylcyclohexane
3 3 3 ns 33,,,«''s0150
224 TMP
, n,a ,vr5'' 001
Benzene
, $ ,, 3,,,,, 33 m�,-r�9111.2
Toluene
, u„-,.010
n
Ethylbenzene
- 0-01
Xylenes
, f - 003
CO. Heavies
,a 046
Total
VOC Wt %
100 00
58 61
lb/lb mol
VRU requested downtime is 7 5% end has 100.4 collection efficiency,
-, 3e13�1'?��B�l�l13�33�3r1�
3 of 5 K \PA\2017\17W E0878 CP1xlsm
Separator Venting Emissions Inventory
Emission Factors
Separator Venting
Pollutant
Uncontrolled
Controlled
(lb/bbl)
(lb/bbl)
(Liquid Throughput)
(liquid Throughput)
Emission Factor Source
VOC
13.3131
0.6657
Benzene
0.0267
0.0013
Toluene
0.0216
0.0011
Ethylbenzene
0.0025
0.0001
Xylene
0.0079
0.0004
n -Hexane
0.1956
0.0098
224 IMP
0.0021
0.0001
Emission Factor Source
Pollutant
Primary Control Device
Uncontrolled
Uncontrolled
(Ib/MMBtu)
lb/bbl
(Waste Heat
Combusted)
(Gas Throughput)
PM10
0.000
PM2.5
0.000
SOx
0.000
NOx
0.000
CO
0.000
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)
PM10
PM2.5
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
SOx
0.00
0.00
0.00
0.00
0.00
NOx
0.00
0.00
0.00
0.00
0.00
VOC
96.97
80.81
4.04
96.97
4.85
CO
0.00
0.00
0.00
0.00
0.00
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
389
325
16
339
19
315
262
13
315
16
36
30
1
36
2
116
96
5
116
6
2850
2375
119
2850
142
31
26
1
31
2
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Not enough information
Regulation 7, Section XVII.B, G
Not enough information
Regulation 7, Section XVII.B.2.e
Not enough information
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
You have indicated above the monitored process parameter is Liquid Througput. The following question does not require an answer.
Using Liquid Throughput to Monitor Compliance
Does the company use site specific emission factors based on a pressurized liquid sample (Sampled upstream of the
equipment covered under this AIRs ID) and process simulation to estimate emissions?
This sample 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 Compliance" testing requirement to collect a site -specific liquid sample 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.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
4 of 5
K:\PA\2017\17WE0878.CP1.xlsm
Separator Venting Emissions Inventory
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling _
Section 08 -Technical Analysis Notes
Apqlita talSed.Nf0Lanalys€s 5epara₹or
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point # Process # SCC Code
009 01 3-10-001-29 Oil & Gas Production: Gas/liquid separation
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 16/1000661
PM2.5 0.00 0 lb/1000bbl
50x 0.00 0 lb/1000bbl
NOx 0.00 0 lb/1000bbl
VOC 13313.05 95 1b/10006bl
CO 0.00 0 lb/1000bbl
Benzene 26.74 95 lb/1000bbl
Toluene 21.62 95 lb/1000bbl
Ethylbenzene 2.47 95 lb/1000bbl
Xylene 7.95 95 lb/1000bbl
n -Hexane 195.63 95 16/1000661
224 TMP 2.11 95 lb/1000bbl
5 of 5 K:\PA\2017\ 17WE0878.CP1.xlsm
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
CONSTRUCTION PERMIT
Permit number:
Date issued: Draft
Issued to:
17WE0878
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Confluence DJ, LLC
Flaherty 18-I Pad
123/9EE4
NWSW SEC 18 T4N R62W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
VRU
Downtime
009
Low Pressure Separator and Vapor Recovery
Unit
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 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 ControlDivision
vevAme :t 4 Pu z b eat e n& norunt
Page 1 of 8
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 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
6. 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
VRU Downtime
009
---
---
4.9
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
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.
7. 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
VRU
Downtime
009
Emissions from the Separator are routed to an
Enclosed Flare during Vapor Recovery Unit
(VRU) downtime
VOC and HAP
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.)
COLORADO
} Mr Pollution Control Division
":.�epartment of Pub }letahh 1 E v4imrt'5int
Page 2 of 8
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
VRU Downtime
009
Liquids Throughput
14,568 barrel(s)
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. The owner or operator shall continuously monitor and record Vapor Recovery Unit (VRU)
downtime while emissions are routed to the control device.
10. The owner or operator must use monthly VRU downtime records, monthly condensate/crude oil
throughput records, calculation methods detailed in the O&M Plan, and the emission factors
established in the Notes to Permit Holder to demonstrate compliance with the process and
emissions limits specified in this permit.
11. The owner or operator shall continuously monitor and record Vapor Recovery Unit (VRU)
downtime while emissions are routed to the control device.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. 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)
13. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity
for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
15. 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:
• 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.
16. 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 Et MAINTENANCE REQUIREMENTS
COLORADO
Air Pollution Control Division
Page 3 of 8
17. 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
18. 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 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
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).
19. 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)
Periodic Testing Requirements
20. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
21. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, on monthly basis 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)
ADDITIONAL REQUIREMENTS
22. 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
COLORADO
Air Pollution Control Division
;;ffprane:;l
Page 4 of 8
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
23. 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.
24. 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.
25. 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.
26. 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.
27. 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.
28. 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.
29. 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
COLORADO
Air Pollution control Division
p<fine t or PO:4i,; Sig. 3;w.%t;.'svv 3rvnrty€
Page 5 of 8
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Timothy Sharp
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Confluence DJ, LLC
COLORADO
Air Pollution Control Division
t)epartmenter h+iY7.._ t aec. h C, ,iMlntent
Page 6 of 8
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days
of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit.
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.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)
VRU
Downtime
009
Benzene
71432
389
19
Toluene
108883
315
16
n -Hexane
110543
2850
142
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 009:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/bbl)
Controlled
Emission Factors
( lb/bbl)
Source
N0x
0.0680 lb/MMSCF
AP -42
CO
0.3100 lb/MMSCF
AP -42
V0C
13.3131
0.6657
Source
(Promax/HYSYS)
71432
Benzene
0.0267
0.0013
Source
(Promax/HYSYS)
108883
Toluene
0.0216
0.0011
Source
(Promax/HYSYS)
110543
n -Hexane
0.1956
0.0098
Source
(Promax/HYSYS)
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
COLORADO
Air Pollution Control Division
i'tY'Y"M1C vt ix.Umt`:'c sei:rn+'J ITnvitor eAt
Page 7 of 8
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: VOC
PSD or NANSR
Synthetic Minor Source of: N/A
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
Dep%rr rit Ld. pmt kc %n rvvsr�m.*r
Page 8 of 8
Natural Gas Venting APEN - Form APCD
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/li
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emissio
not fall into this category, there may be a more specific APEN for your source. In addition, the General A
(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: 17WE0878
AIRS ID Number: 123 / 9EE4/ 009
[Leave blank unless APCD has already assigned a permit tt and AIRS ID]
Company equipment Identification: VRU Downtime
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Confluence DJ, LLC
Site Name: Flaherty 18-I Pad
Site Location: NWSW Sec. 18 T4N R62W
Mailing Address:
(Include Zip Code) 1001 17th St., Suite 1250
Denver, CO 80202
E -Mail Address' mdickinson@confluencelp.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Mike Dickinson
Phone Number: (303) 226-9517
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-205 - Natural Gas Venting APEN - Rev 03/2017
'COLORADO
1 I Hepa.h,e.of�
N b n�
Enrronm
Permit Number: 17WE0878
AIRS ID Number: 123 / 9EE4 / 009
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
▪ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name ❑ 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:
Venting from VRU downtime
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
09 / 02 / 2016
/ /
O Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: 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 ❑ No
❑ Yes ❑✓ No
COLORADO
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 I AV'°"""° He�tg b Envin"menu
Permit Number: 17WE0878
AIRS ID Number: 123 / 9EE4 / 009
[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:
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? ❑ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
0 No
Maximum Vent
Rate:
SCF/hr
Vent Gas
Heating Value:
BTU/SCF
Requested:
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
1 4568
Bbl/yr
Actual:
12140
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
40.188
VOC (Weight %)
58.612
Benzene (mole %)
0.053
Benzene (Weight %)
0.118
Toluene (mole %)
0.036
Toluene (Weight %)
0.0952
Ethylbenzene (mole %)
0.004
Ethylbenzene (Weight %)
0.0109
Xylene (mole %)
0.012
Xylene (Weight %)
0.0350
n -Hexane (mole %)
0.352
n -Hexane (Weight %)
0.861
2,2,4-Trimethytpentane
(mole %)
0.00287
2,2,4 Trimethylpentane
(Weight %)
0.00930
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)
s❑
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
COLORADO
3 ANY D P.
3lutgbEna.e�.nent
Permit Number: 17WE0878
AIRS ID Number: 123 / 9EE4/ 009
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
eographical Coordinates
Latitude/Lohgitude or UTM)
40.311237/-104.376041
a
�
O erator�v
ac D o.,
Dtschar Heightx
AboVe�GrotindfLeve1�
(Feet-
`x
�J"em
;�
z
Flow ate
A
e ocY�
sec z.
ECD
25
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
E Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
48
Section 6 - Control Device Information
❑✓ VRU:
Pollutants Controlled: VACS & HAPs
Size: 92 hp Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
100
7.5
%
GM Vortec 5.7L
❑ Combustion
Device:
Pollutants Controlled: VOCS & HAPs
Rating: 12.8 MMBtu/hr
Type: ECD Make/Model: Leed 48 HEC
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
NA
95
98
%
%
Waste Gas Heat Content 1969 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating
0.01 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-2O5 -Natural Gas Venting APEN - Rev 03/2017
COLORADO
4 Dep.nm.nt f P b
HeaN. & Eamrnnment
Permit Number: 17WE0878
AIRS ID Number: 123 / 9EE4/ 009
PM
PM
[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? ❑✓ Yes ❑ No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Overall Requested Controls,.
tmciency
reduction in emissions)
SOX
NO,
VOC
ECD
95
CO
HAPs
ECD
95
Other:
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.)
Uncontrolled "
Emission
Factor_
Emission;
Factor -
Units
Emission
Factor
Source
(AP -42,
Mfg. etc).
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year),,
SOX
NOx
0.068
lb/MMBtu
AP -42
0.07
0.09
VOC
13.307
lb/bbl
Eng. Est.
80.78
4.04
96.93
4.85
CO
0.31
Ib/M M Btu
AP -42
0.34
0.41
Benzene
0.0264
lb/bbl
Eng. Est.
0.16
0.01
0.19
0.01
Toluene
0.0214
lb/bbl
Eng. Est.
0.13
0.01
0.16
0.01
Ethylbenzene
Xylenes
n -Hexane
0.193
lb/bbl
Eng. Est.
1.17
0.06
1.41
0.07
2,2,4-
Trimethylpentane
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-205 -Natural Gas Venting APEN - Rev 03/2017
5
.COLORADO
Department of Pram
health b Environment
Permit Number: 17W E0878
AIRS ID Number: 123 / 9EE4/ 009
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
t ( i 3/15/2018
Signature of Legally Authorized Person (not a vendor or consultant) Date
Mike Dickinson
Senior Vice President Operations
Name (please print) Title
Check the appropriate box to request a copy of the:
Z 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
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-205 -Natural Gas Venting APEN - Rev 03/2017 6
'COLORADO
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