The URL can be used to link to this page

Browse Search

Home My WebLink About20170982.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 April 4, 2017 Dear Sir or Madam: RECEIVED APR 062017 WELD COUNTY COMMISSIONERS On April 6, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Kerr- McGee Oil and Gas Onshore LP - 34002694. 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.cotorado.gov/cdphe John W. Hickentooper, Governor Larry Wotk, MD, MSPH, Executive Director and Chief Medical Officer Pubic Re_v;ew cc: HLCPQ),.PLflhIr C / TP.), / � a�� pwc �RicM icK( TM) t-1 / _7 / r _7 1.76 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Kerr-McGee Oil and Gas Onshore LP - 34002694 - Weld County Notice Period Begins: April 6, 2017 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Kerr-McGee Oil and Gas Onshore LP Facility: 34002694 Exploration and production site NENW Sect. 26 T2N R65W Weld County The proposed project or activity is as follows: New Vapor Recovery Tower (VRT) added to existing oil and gas facility to provide another stage of liquid/gas separation. Emissions from VRT are routed to a Vapor Recovery Unit (VRU), or if required, enclosed combustors. This permit covers the gas stream that is routed to the enclosed combustors. 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 maintain emissions below thresholds that would trigger additional regulatory requirements (Regulation No. 3, Part B, Section III.C.1.d) 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 17WE0017 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: Betsy Gillard Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1 (� COLORADO I m "�r Colorado Air Permitting Project Version No. 1.00 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS If yes, for what pollutant? Betsy Gi#ard 333557 6/24/2015 2/28/2017 non -attainment area? Kerr McGee Oil and Gas Onshore LP 123 7810 Battery 34002694 (Hudson 36N-35HZ) NENW Sect. 26 T2N R65W Exploration & Production; Well Pad Oil & Natural Gas Production & Processing Yes ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) Q Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance It Self Cert Required? Action Engineering Remarks 006 Vapor. Rem Towerc VRT) ( � ` Yes 17WE0017 1 `fes Permit Initial ." Y�. ;'�SSUanc€* : %-.' gas flaring during VRU �hYPass Section 03 - Description of Project This application is requesting a permit fora new "Generation 4" tank battery facility in Weld County (non -attainment). KMG is requesting permit coverage for one (1) vapor recovery tower (VRT). Hydrocarbon liquid produced at this faciltiy flows from a HIP separator to a VRT prior to storage in atmospheric tanks: During normal operation, gas vented from the VRT is routed to a vapor recovery unit (VRU) which compresses the gas and directs it to the sales gas gathering pipeline. During periods when the VRU cannot compress 100% of the gas, the gas bypassing the VRU is routed to enclosed combustors (ECDs). Emissions while VRT gas is routed to the ECDs (flare run-time) is a function of condensate throughput. Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?t Yes Requesting Synthetic Minor Per Section 05 - Ambient Air Impact Analysis Requirements 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, explain what programs and which pollutants here: Title V Operating Permits (OP) : VOC, total HAPs, n -Hexane__ Non -Attainment New Source Review (NANSR): VOC Is this stationary source a major source? No 006 One (1) vapor recovery tower (VRT) that processes liquid from thesecond stage of separation to create a third stage of liquid/gas separation. Overhead flash gas from the VRT is routed to the vapor recovery units (VRUs) in a closed loop process. When the VRUs are unable to capture the entire overhead gas stream, flash gas is routed to an enclosed combustion device (ECU) The ECU has a minimum control efficiency of; 95%. Emissions are a function of condensate throughput while overhead gas is routed to the ECD. It is assumed that the flash gas is routed to the ECU 30% of the time. This permit covers emissions when flash gas is routed to the ECDs. Equipment Description This source vents natural gas from: one (1) vapor recovery tower Emissions from this source are: Natural gas venting from one (1) vapor recovery tower. Emissions from this source are routed to a flare. Calculations The site specific emission factors developed for this source were determined through the use of two pressurized liquid samples, and two E&P Tanks simulations associated with the pressurized liquids samples. The pressurized liquid samples were obtained from two different wells at the facility on April 17, 2015. The wells from which the samples were taken are as follow: Hudson 13C-35HZ & Hudson 14N-35HZ. Two separate E&P Tanks simulations were conducted using the two pressurized liquid samples. The results of the simulation were averaged to determine the site specific emission factors. The simulation uses a sales oil API gravity of 47.4 degrees. The following tables contain the information from the E&P Tanks simulations used to determine the. emission factors: E&P Tanks Simulation 1 (Hudson 13C-35HZ) Throughput: 24 bbl/day 8760 bblNear Pollutant Emission Rate Emission Rate Uncontrolled Factor 13.81 Emission lb/bbl VOC 13.808 lb/hr 120958.08 lb/year Benzene 0.095 lb/hr 832.20 lb/year 0.10 lb/bbl Toluene 0.087 lb/hr 762.12 lb/year 0.09 lb/bbl Ethylbenzene 0.014 lb/hr 122.64 lb/year 0.01 lb/bbl Xylenes 0.066 lb/hr 578.16 lb/year 0.07 lb/bbl n -Hexane 0.344 lb/hr 3013.44 lb/year 0.34 lb/bbl 2,2,4-TMP 0.043 lb/hr 376.68 lb/year 0.04 lb/bbl Note: The E&P Tanks simulation was run on a basis of 24 bbl/day (8760 bbl/year). As a result, the conversion from lb/hr to lb/bbl results in the same value. E&P Tanks Simulation 2 (Hudson 14N-35HZ) Throughput: 24 bbl/day 8760 bbl/ ear Pollutant Emission Rate Emission Rate Uncontrolled Emission VOC 11.21 lb/hr 98199.60 lb/year 11.21 lb/bbl Benzene 0.091 lb/hr 797.16 lb/year 0.09 lb/bbl Toluene 0.086 lb/hr 753.36 lb/year 0.09 lb/bbl Ethylbenzene 0.018 lb/hr 157.68 lb/year 0.02 lb/bbl Xylenes 0.053 lb/hr 464.28 lb/year 0.05 lb/bbl n -Hexane 0.291 lb/hr 2549.16 lb/year 0.29 lb/bbl 2,2,4-TMP 0.042 lb/hr 367.92 lb/year 0.04Ib/bbl Note: The E&P Tanks simulation was run on a basis of 24 bbl/day (8760 bbl/year). As a result, the conversion from lb/hr to lb/bbl results in the same value. Average of Simulation 1 and 2 Throughput: 24 bbl/day 8760 bblNear Pollutant Emission Rate Emission Rate Uncontrolled Emission VOC 12.509 lb/hr 109578.84 lb/year 12.509 lb/bbl Benzene 0.093 lb/hr 814.68 lb/year 0.093 Ib/bbl Toluene 0.0865 lb/hr 757.74 lb/year 0.0865 lb/bbl Ethylbenzene 0.016 lb/hr 140.16 lb/year 0.0160 lb/bbl Xylenes 0.0595 lb/hr 521.22 lb/year 0.0595 lb/bbl n -Hexane 0.3175 lb/hr 2781.30 lb/year 0.3175 lb/bbl 2,2,4-TMP 0.0425 lb/hr 372.30 lb/year 0.0425Ib/bbl Note: The overall emission rates (lb/hr) were determined using a simple average of the emission rates (lb/hr) for each pollutant obtained from the Underhill 27C-17HZ and Underhill 28N-17HZ simulations. 17WE0017.CP1.xlsm One (1) vapor recoverytower (VRT) that processes liquid from the second stage of separation to create a third stage of liquid/gas separation. Overhead flash gas from. the VRT is routed to the vapor recovery units (VRUs) in a closed loop process. When the VRUs are unable to capture the entire overhead gas stream, flash gas is routed to an enclosed combustion device, (ECD). The ECD has a minimum control efficiency; of 95%. Emissions are a function of condensate throughput while overhead gas is routed to the ECD. It is assumed that the flash gas is routed to the ECD 30% of the time. This permit covers emissions when flash gas is routed to the ECDs. Requested Throughput: Total throughput to VRT: VRU downtime: 200,000 bbl/year 30% IVRT Throughput during VRU downtime: 60,000 bbl/year Flaring Information Equipment Description Three (3enclosed combustors to combust vapor recovery tower gas during VRU downtime. Manufacturer Cimarron Model 48" HVECD Serial Number multiple Control Efficiency 95.00% Combustion emission factor source: 0.0037 lib NOx/Ib VOC Emissions Summary Table CDPHE Inter -Office Communication (2005-03-22) 0.0094 Ilb CO/lb VOCI Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 12.509 lb/bbl 0.625 lb/bbl 375.27 tpy 18.76 tpy E&P Tanks NOx 0.0463 lb/bbl 0.0463 lb/bbl 1.39 tpy 1.39 tpy CDPHE CO 0.1176 lb/bbl 0.1176 lb/bbl 3.53 tpy 3.53 tpy CDPHE Benzene 0.0930 lb/bbl 4.65000E-03 lb/bbl 5580 lb/yr 279 lb/yr E&P Tanks Toluene 0.0865 lb/bbl 4.32500E-03 lb/bbl 5190 lb/yr 260 lb/yr E&P Tanks Ethylbenzene 0.0160 lb/bbl 8.00000E-04 lb/bbl 960 lb/yr 48 lb/yr E&P Tanks Xylenes 0.0595 lb/bbl 2.97500E-03 lb/bbl 3570 lb/yr 179 lb/yr E&P Tanks n -Hexane 0.3175 lb/bbl 1.58750E-02 lb/bbl 19050 lb/yr 953 lb/yr E&P Tanks 2,2,4-TMP 0.0425 lb/bbl 2.12500E-03 lb/bbl 2550 lb/yr 128 lb/yr E&P Tanks Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'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.' AQCC Regulation 2 Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air." AQCC Regulation 7 Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, Section XVII.B.2 Additional Notes: 1. Initial sampling will not be required with this issuance since samples were taken from two producing wells at this facility within 1. year of application submittal. 2. This is a Anadarko Gen 4 Tank Battery and as such, emissions are estimated per discussions with Division staff on 12/16/14. Per this discussion, KMG uses a sample pulled downstream of the inlet HLP separator (upstream of the VRT) as input composition to E&P Tank. The E&P Tank model is run assuming the bottom of the HLP separator as the E&P Tank separator, and the VRT as the E&P Tank oil tank. 3. The amount of time that a valve is open allowing gas to the ECED is monitored on a daily basis. The total monthly liquid throughput to the VRT is multiplied by the percentage of time the VRU is down (i.e. while valve is open allowing gas to the ECD) to obtain throughput to VRT during VRU downtime. For the purposes of establishing permit limits, a maximum VRU downtime of 30% is assumed. 4. Secondary emissions from combustion of the waste gas are calculated using emission factros from a 2005 APCD memo for use on storage tanks (Ib/IbVOC). I calculated emissions using the "GOR" (scf/bbl) and heating value of the waste gas calculated in the E&P tanks run (average of the two model runs). This resulted in a less conservative estimate of emissions of CO and NOx and therefore the calculations proposed with the original application are being used here. It was communicated that the Division prefers the use of AP -42 factors and calculated waste stream data to the lb/lb VOC factor referenced in the 2005 APCD Memo. 5. O&M plan outlines continous monitoring of VRU downtime and calcualtion methods used to demonstrate compliance with the liquid throughput limits in this permit. 17WE0017.CP1.xlsm AIRS (County/Plant) 123/7801 Permit No. 17WE0017 Date 2/28/2017 Point # SCC Pollutant or CAS Uncontrolled Emission Factor Emission Factor Source Lontrolled Actual Emissions (tpy) Controlled Requested Emissions (tpy) PTE (tpy) Ctrl. Eff % NCRP = reportable ? 006 31000205 VOC 12.509 lb/bbl E&P Tank 375.27 18.76 375.27 95% -- 006 31000205 NOx 0.0463 lb/bbl CDPHE 1.39 0.07 1.39 0% -- 006 31000205 CO 0.118 lb/bbl CDPHE 3.54 0.18 3.54 0% -- 006 31000205 Benzene 0.093 lb/bbl E&P Tank 2.79 0.14 2.79 95% Yes 006 31000205 n -Hexane 0.3175 lb/bbl E&P Tank 9.53 0.48 9.53 95% Yes 006 31000205 Toluene 0.0865 lb/bbl E&P Tank 2.80 0.13 2.60 95% Yes 008 31000205 Ethylbenzene 0.016 lb/bbl E&P Tank 0.48 0.02 0.48 95% Yes 006 31000205 Xylenes 0.0595 lb/bbl E&P Tank 1.79 0.09 1.79 95% Yes 006 31000205 2,2,4-TMP 0.0425 lb/bbl E&P Tank 1.28 0.06 1.28 95% Yes COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Kerr-McGee Oil & Gas Onshore LP 123 7810 34002694 History File EdIt Date 2/28/2017 02one Status Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 3.2 26.9 41.4 2.8 5.4 0.0 0.0 0.0 0.0 3.2 39.3 41.4 2.8 4.5 Previous Permitted Fecild / total 0.0 0 0 0.0 0.0 0.1 39.0 41.4 0.2 4.5 001 GP01 Condensate Tanks (12), 3600bb1 total 0.1 23.0 0.2 0.1 0.1 39.0 0.2 0.4 002 14WE0166.OP Produced water storage, 440 -bbl 2.6 0.3 2.6 0.3 Updated emissions based on APEN reed 05/0312016 003 14W E0167 FugNye leak emissions 41A 4A 41A 4 4 004 14WE1241. CN CompresscoG1230, sn: 50324 0:0 80 Cann -eked >06242015- Previously aategoncallyexerr t due too 501 hp 005 GP07 Hydrocarbon loadout 0.7 195.0 1.8 3.3 0.7 9.7 1.8 02 006 17WE0017 VRT venting during VRU bypass 1.4 375.3 3.5 18.5 1.4 18.8 3.5 0.9 New point FACILITY TOTAL 0.0 0.0 0.0 0.0 2.2 595.9 41.4 5.5 26.6 0.0 0.0 0.0 0.0 2.2 70.1 41.4 5.5 6.2 VOC: Synthetic Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Minor FIB: Minor ZZZZ: Minor Permitted Facility Total 0 0 0.0 0 0 0.0 0.8 218.0 41.4 2.0 7.9 0.0 0.0 0.0 0.0 0.8 48.7 41.4 2 0 5.0 Excludes units exempt from pemrds/APENs (A) Chafe in Permitted Emissions 0.0 0.0 0.0 0.0 0.7 9.7 00 1.8 Pubcom & modeling not required Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 111.5 Facility is eligible for GP02 because < 90 tpy Project emissions less than 25/50 tpy 9.7 Note 2 Page 1 of6 Printed 3/31/2017 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Kerr-McGee Oil & Gas Onshore LP County AIRS ID 123 Plant AIRS ID 7810 Facility Name 34002694 Emissions - uncontrolled ( bs pervear POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H25 TOTAL (toy) Previous FACILITY TOTAL 0 0 0 1213 1471 196 1595 6293 0 0 0 0 10768.0 001 GP01 Condensate Tanks (12), 3600bb1 total 257 41 0.1 002 14WE0166.XP Produced water storage, 440 -bbl 138 - 434 0.3 003 14WE0167 Fugitive leak emissions 754 1471 196 1595 4846 4.4 004 14WE1241.CN Compressco GJ230, sn: 50324 0.0 005 GP07 Hydrocarbon loadout 677 5940 3.3 006 17WE0017 VRT venting during VRU bypass 5580 5190 960 3570 19050 2550 18.5 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 3.7 3.3 0.6 2.6 15.2 0.0 1.3 0.0 0.0 26.6 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs pervear POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (toy) Previous FACILITY TOTAL 0 0 0 780 1471 196 1595 4919 0 0 0 0 8961.0 001 GP01 Condensate Tanks (12), 3600bb1 total 13 813 0.4 002 14WE0166.XP Produced water storage, 440 -bbl 138 434 0.3 003 14WE0167 Fugitive leak emissions 754 1471 196 1595 4846 4.4 004 14WE1241.CN Compressco GJ230, sn: 50324 0.0 005 GP07 Hydrocarbon loadout 34 297 0.2 006 17WE0017 VRT venting during VRU bypass 279 260 48 179 953 128 0.9 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.6 0.9 0.1 0.9 3.7 0.0 0.1 0.0 0.0 6.2 2 1237810.xlsx 3/31/2017 Permit number: Date issued: Issued to: ADO n Contro is Heal CONSTRUCTION PERMIT 17WE0017 Issuance: 1 Kerr-McGee Oil and Gas Onshore LP Facility Name: 34002694 Plant AIRS ID: 123/7810 Physical Location: NENW Sec 26 T2N R65W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT-01 006 One (1) vapor recovery tower (VRT) that processes liquid from the second stage of separation to create a third stage of liquid/gas separation. Overhead flash gas from the VRT is routed to the vapor recovery units (VRUs) in a closed loop process. When the VRUs are unable to capture the entire overhead gas stream, flash gas is routed to an enclosed combustor. Emissions are a function of condensate throughput while overhead gas is routed to the ECDs. Enclosed Combustor 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. COLORADO Air Pollution Control Division Page 1 of 8 2. hin one hu his permit Division. diti this s (180) of of comme the conditi e .. ed in this operato" respon: ity to s com. ; nce withi :0 da self certieon h • ^ el of operatio mi hall be dem -certify complia a result in revo complianc r issuance trated to with the on of the red by permit may be obtained online at www.co orado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. 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 VRT-01 006 --- 1.4 18.8 3.5 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. COLORADO Air Pollution Control Division Page 2 of 8 7. emission trot equip ablished i below sha order to r tion Nu er 3, rated an sions to , Secti ned with t ;_" emissions or equal •. . he limits .:, acility Equipment ID Point . �.. .. �� Control Device • : nts r' ' Controlled VRT-01 006 Enclosed Combustors controlling emissions from the VRT 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.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit VRT-01 006 Condensate throughput while emissions are routed to enclosed combustors 60,000 bbl/yr 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 the amount of time that flash gas is routed from the VRTs to the ECDs. The owner or operator shall use monthly recorded ECD run time, monthly condensate throughput records, and calculation methods detailed in the OEtM plan to demonstrate compliance with the limits specified in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) COLORADO Air Pollution Control Division Page 3 of 8 12. - devi • by this p Pro o _°,.,,..,,ate only e missi of v g ile orga x compo no vi le ems �, s du • normal r , XVII.A.1`., e des ":t an 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. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 14. 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 15. 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 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: combusts I.B.2. Gen d to contra lose • - subject t If a flar to co eration c on Numbe, Section r combusts '. device is with Section XV " t shall be as defined unde e•ulation _: eans of vss r . • ation 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 (V0C) and nitrogen oxides sources (NO),) 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 COLORADO Air Pollution Control Division Page 4 of 8 or any no a rep • . • utant. tons per ear or mor ore, a c r is less, actual emi e level rep ns of five ed on the 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. 18. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by COLORADO Air Pollution Control Division Page 5 of 8 rato ti; '`sion revok it, the o Aerator of : urce may bef • CC for revi ivision's 24. lion 25 7 .' 4.7(2)( C.R •uires . t all sour requir • file an Air Pollu • Emission mus . nn er thf• ns and ad •==Fan. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Betsy Gillard Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Kerr-McGee Oil and Gas Onshore LP COLORADO Air Pollution Control Division Page 6 of 8 Notes t• ;, rmit Holdt the y`;,� '"�' permit iss 1) Theees for th • - � time fore's pe it. An invo for these feed ll be issu .fter t •ermi ssued. * e permi ' lder sh ay the invoice w n 30 days e invure invoi e - arm evocationermit. (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-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 006 Benzene 71432 5580 279 Toluene 108883 5190 260 Ethylbenzene 100414 960 48 Xylenes 1130207 3570 179 n -Hexane 110543 19050 953 2,2,4- Trimethylpentane 540841 2550 128 Note: All non -criteria reportable pol utants in the table above with uncontrolled emiss'on 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 006: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source N0x 0.0463 0.0463 2005-03-22 APCD Memo CO 0.1176 0.1176 V0C 12.509, 0.625 EEtP Tanks 71432 Benzene 0.0930 4.65E-03 108883 Toluene 0.0865 4.33E-03 100414 Ethylbenzene 0.0160 8.00E-04 1130207 Xylenes 0.0595 2.97E-03 110543 n -Hexane 0.3175 1.59E-02 COLORADO Air Potiutkon Control Division Deorvr,nt 1 bt,: Page 7 of 8 # ollut Uncon MIle • Emissio (I.bl) Co a Emissi (l • Fac 3 rs bl) rce g ; 2,-.... Trimethylpentane . 5 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. The emission factors listed above are based on modeled separator (VRT) temperature of 50 °F and separator pressure of 0 psig. 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, total HAPs, n -Hexane NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division iQi✓"(yS i Puff,P `? Er;o .. nm2rtc Page 8 of 8 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General1 Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit # & AIRS ID] Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] 5 Facility Equipment ID: uested Action (check applicable request boxes) Section 02 — Re Section 01— Administrative Information Request for NEW permit or newly reported emission source Request PORTABLE source permit 0 a> b U U U Z C C Source Name: Change company name Transfer of ownership ❑ ❑ Change fuel or equipment Change permit limit ❑ ❑ Request to limit HAPs with a Federally enforceable limit on PTE Request APEN Update N 0 00 a> 0 0 P. N Emissions data must be completed Blank APENs will not be accepted Denver, CO 80217-3779 Requesting individual permit for vapor recovery tower (VRT) C C O C y O O O 0 c.. z Section 03 — General Information For existing sources, operation began on: 0 s N N Normal Hours of Source Operation: Provide 3rd stage of gas/liquid separation General description of equipment and purpose: o 413 00 tr) O 0. c o � � E z y U on on on C WbAN N N N d .0 A F U . E L�j- � N M M M 42 CO C .,„ O O O z O a)on rn on Q u �+ .i"o. iV�" R C cd 4" C C O E a) N cl W 0 R.. E ti C in 01 1.0y > 7 cd cd 6R s 'o x ",..7 V] C U L O �3 �x s g es a 0 " 0 •a 0 0 .� tD a° ,0, C°p. E •°,, o .� E 7 Y 0 r+ 0 L M o > C UC L.. L 0 C A v) , A cd c a b N ,O O E d O sz -2� 0 >w oo isCI .N C oQ o b E a. 00 o U y ^O W O L d >a N 0 U i0 O }, 0 en L O U O, E I. U C a�> y O euU g .; o N ors •� UC rd ,`d, .. EAU d 0 -5= Ca .� 1 no o c; o> to p., g akin U<4,= w <ci APEN forms: httn://www.colorado. ermitstatus //www.colorado. Application status: htt O O z 4) 4) C . es et coo CY O 0 z° g al • a> U O 0 .0 0 'O 0 E p O U cr 5 3 ment Information & Material Use Section 04 — Processine/Manufacturin Description of equipment2: 0 z z 0 Manufacturer: 0 0 0 0 bA Ca O Check box to request copy of draft permit prior to issuance. Check box to request copy of draft permit prior to public notice. El To z 6 L vi wa ta a, C > a- W- R0 C C E o „; s C 0.0 en R 'O• N P. 0 t 0 .6. .o L a t y N 0 L cy u O C v o a v 0 b r« o }' z - 0 c. 6I C4 0. C Ns w C .174 Z U w et.- C.) V O 2, a) d O R .e y C c. -O al V . d 3 000 CI0 u a.. a) 0 b ti :o 0 3 °> Form APCD-200 — GeneralAPEN — Ver.02.10.2014.docx N C O Co an a FORM APCD-200 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Genera11 Emission Source AIRS ID: Permit Number: Section 05 — Emission Release Information (Attach a separate sheet with relevant information in the event of multiple releases; provide datum & either Lat/Long or UTM) N N 40.1141294 -104.6356428 .8 1' ti a o Hv mr ❑ Other (Describe): Width (inches) = ❑ Horizontal ❑ Down ❑ Other: Length (inches) = Vertical with obstructing raincap Direction of outlet (check one): 00 Exhaust Opening Shape & Size (check one): tion Information ment & Fuel Consum Section 06 — Combustion E Multiple ECDs O z 0) 48" HVECD 0) 'O 0 CO 0 CO 8 Manufacturer: h 0 0 0 CO 0 0 CO G7 0 z 0) G7 47) ti N cd N w N 00 3 2 0 00 CO 00 c _ t) a b aa aa 0 b 4. Y R. v aa 6) F-) w Natural Gas 'Requested values will become permit limitations. Requested level should consider process growth over the next five years. Section 07 — Emissions Inventory Information & Emission Control Information 0 W Y 0 V C: E 0 O b 0 0 O N E b 0 U U a 0 E 7) eat U N N 00 u 0 t R CO a r eo CO L 0 d i, L R C d is R L CC Estimation Method or Emission Factor Source 2005 APCD E&P Tank 1 2005 APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) Men .-i 18.76 to Uncontrolled (Tons/Year) i el N M i Actual Calendar Year Emissions4 Controlled (Tons/Year) Uncontrolled (Tons/Year) Emission Factor Units Ib/IbVOC 7O 0 O Uncontrolled Basis 0.0037 o vfi eel a o o Control Efficiency (% Reduction) v7 a, Overall Collection Efficiency Please use the APCD Control Device Description Secondary CO E .O a Flare Pollutant TSP G a ''°C) a x c4 X0 2 E 0 Vi L y d CO 0' I- R 00 E CO O E L w e 0 d L L O 0 .0C) d z` N O d u zE pW mu d o p fl N 3 resentative 0) u 0 U 'O C R 0) VI xPI E U CO CO y CO . tE. a) R a) hi a O C � R CiE s 4 C 0 0) CO R ea CO A z 0) 0) `J R \ 0 C !" •o a CO R C) u u4 a a) ~ 'CO O C N tro o U 0) 0 Form APCD-200 — GeneralAPEN — Ver.02.10.2014.docx N 0 O N 0O0 a 2 o O Q o w M N CD Q L /w ✓ H z O Z N Z o _ Q V/ O V) w • rn c Ha. ZE `Q U r O D J J -2 Jc rn 0. N I.L. N Q N N J 03 a °' oc 53 0 0 is 3 C w` V Permit Number: 1:1- - J L O t Cl) 0 U) a U) 0 a) a) U Company Name: a) a O 0 a N NE&NW/NW S26 T2N R65W Plant Location: 720 929 6916 E-mail Address: Controlled Actual Emissions (lbs/year) r. N co N co co N— co Ln O co N e- Uncontrolled Actual Emissions (lbs/year) 0 CO lf) to 5190 0 CO a) 3570 19050 2550 Emission Factor Source E&P Tank c co I — a_ ces E&P Tank E&P Tank E&P Tank E&P Tank Emission Factor (Include Units) 171-764717O - ,,Cr) 0 0 42 F• CO O O .� CO 00U) O O CO O CO I- O 0.043 lb/bbl Control Equipment / Reduction (%) 95 95 t) 0) 95 95 95 Chemical Name Benzene Toluene E -Benzene Xylene N -Hexane 224-TMP Chemical Abstract Service (CAS) Number Requested Emissions C cs a) 0 HSE Representative U) U) 0 0 a_ U) • O N O -C 7 (C O) a) J C 0 U) LL O L a) 0) L C a C O) o Title of Person Legally Authorized to Supply Data Name of Person Legally Authorized to Supply Data (Please print) Form Revision Date: April 14. 2014 Hello