HomeMy WebLinkAbout20161765.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
June 1, 2016
Dear Sir or Madam:
RECEIVED
JUN 0 7 2016
WELD COUNTY
COMMISSIONERS
On June 8, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for Kerr-
McGee Oil and Gas Onshore LP - 36146224 Tank Battery. 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
4/7
2016-1765
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdpl
John W. Hickentooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Kerr-McGee Oil and Gas Onshore LP - 36146224 Tank Battery - Weld County
Notice Period Begins: June 8, 2016
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: 36146224 Tank Battery
Oil and Gas Exploration and Production Facility
NESE of Section 17, Township 1N, Range 67W
Weld County
The proposed project or activity is as follows: Applicant is requesting permit coverage for one (1) vapor
recovery tower (VRT) controlled by three (3) enclosed combustion devices (ECDs) during vapor recovery unit
(VRU) downtime at a synthetic minor exploration and production facility.
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 16WE0044 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:
Harrison Slaughter
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
M
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
1 6WE0044
Issuance 1
DATE ISSUED:
ISSUED TO: Kerr-McGee Oil and Gas Onshore LP
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas exploration and production facility, known as the 36146224 Tank Battery,
located in the NESE of Section 17, Township 1N, Range 67W, in Weld County,
Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
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 three (3) enclosed combustion devices (ECDs).
The ECDs each have a minimum control efficiency of 95%.
Emissions are a function of condensate throughput while
overhead gas is routed to the ECDs. It is assumed that the flash
gas is routed to the ECDs 40% of the time. This permit covers
emissions when flash gas is routed to the ECDs.
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 THOSE 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 operations or issuance of this
permit, by submitting a Notice of Startup form to the Division. The Notice of
Startup form may be downloaded online at https://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 No. 3, Part B, Section
III.G.1 and can result in the revocation of the permit.
AIRS ID: 123/4716
Page 1 of 8
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f Public Health and Environment
Air Pollution Control Division
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.qov/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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
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.
(Reference: Regulation No. 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.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 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 (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO.
VOC
CO
VRT-01
006
---
9.4
---
Point
See "Notes to Permit Holder #4" for nformation on emission factors and methods used to
calculate limits.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
AIRS ID: 123/4716
Page 2 of 8
f Public Health and Environment
Air Pollution Control Division
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
VRT-01
006
Three (3) Enclosed Combustion Devices
VOC and HAPs
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the throughput shall be maintained by the applicant and made
available to the Division for inspection upon request. (Reference: Regulation 3, Part B,
II.A.4)
Process/Consumption Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
VRT-01
006
Condensate throughput through VRT
while emissions are routed to
enclosed combustion devices.
33,260 BBL
The owner or operator shall monitor monthly process rates based on the calendar
month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
10. 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 O&M 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
11. The permit number and AIRS ID number shall be marked on the subject equipment for
ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only
enforceable)
12. 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
AIRS ID: 123/4716 Page 3 of 8
f Public Health and Environment
Air Pollution Control Division
excess of 30% opacity for a period or periods aggregating more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.)
13. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
14. Upon startup of this point, the applicant shall follow the 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 your
O&M plan are subject to Division approval prior to implementation. (Reference:
Regulation No. 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 9, 40 C.F.R. Part 60, Appendix A, to measure opacity from the flare.
This measurement shall consist of a minimum twenty-four consecutive readings taken at
fifteen second intervals over a six minute period. (Regulation Number 1, Section II.A.1
and II.A.5)
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: (Reference: Regulation
No. 3, Part A, II.C)
a. 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 annual actual emissions of one (1) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
AIRS ID: 123/4716 Page 4 of 8
f Public Health and Environment
Air Pollution Control Division
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. 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 No. 3 Part 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 No. 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 No. 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 applicant and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this inforr'nation and with
representations made by the applicant or applicant's agents. It is valid only for the
equipment and operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with
the provisions of Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self -certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the applicant, or the Division
revokes a permit, the applicant or owner or operator of a source may request a hearing
before the AQCC for review of the Division's action.
AIRS ID: 123/4716 Page 5 of 8
f Public Health and Environment
Air Pollution Control Division
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Harrison Slaughter
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Kerr-McGee Oil and Gas Onshore LP
Permit for one (1) vapor recovery tower at an
existing synthetic minor exploration and
production facility.
AIRS ID: 123/4716 Page 6 of 8
Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder:
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 (Reference:
Regulation No. 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 permittee 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
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 permittee 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-reqs
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
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
006
Benzene
71432
3,426
Yes
172
Toluene
108883
5,721
Yes
286
Ethylbenzene
100414
1,081
Yes
54
Xylenes
1330207
2,944
Yes
148
n -Hexane
110543
14,352
Yes
718
2,2,4-
Trimethylpentane
540841
3,110
Yes
156
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Emission Factors
Uncontrolled
lb/bbl
Emission Factors
Controlled
lb/bbl
Source
NOx
4.16x10-2
4.16x10-2
2005-03-22 APCD
Memo
CO
1.05x10-1
1.05x10-'
2005-03-22 APCD
Memo
VOC
11.25
5.63x10-1
E&P Tanks
71432
Benzene
1.03x10-1
5.15x10-'
E&P Tanks
108883
Toluene
1.72x10-1
8.6x10-''
E&P Tanks
100414
Ethylbenzene
3.25x10-2
1.62x10-''
E&P Tanks
1330207
Xylenes
8.85x10-2
4.43x10-3
E&P Tanks
110543
n -Hexane
4.31x10-1
2.15x10-2
E&P Tanks
540841
2,2,4-
Trimethylpentane
9.35x10-2
4.68x10-3
E&P Tanks
AIRS ID: 123/4716
Page 7 of 8
f Public Health and Environment
Air Pollution Control Division
Note: The controlled emissions factors for point 006 are based on the enclosed combustor
control efficiency of 95%. These emission factors were developed using pressurized
liquids analyses from the Underhill 27C-17HZ and Underhill 28N-17HZ wells both
sampled on February 10, 2015. The emission factors obtained from two separate E&P
Tank simulations were averaged in order to determine the overall emission factor for each
pollutant as represented above.
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
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
AIRS ID: 123/4716
Page 8 of 8
Colorado Air Permitting Project
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
Harrison Slaughter
329535
4/28/2015
5/20/2016
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?
Kerr-McGee Oil and Gas Onshore LP 123
4716
36146224 Tank Battery (Underhill 1N-17HZ)
NESE of Section 17, Township 1N, Range 67W
Exploration & Production Well Pad
Oil & Natural Gas Production & Processing
non -attainment area? Yes
❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM)
Section 02 - Emissions Units In Permit Application
Q Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering Remarks
006
Vapor Recovery Tower (VRT)
Yes
16WE0044
1
Yes.
Permit Initial
Issuance
VRT venting to ECD
Section 03 - Description of Project
Kerr-McGee is requesting permit coverage for one (1) vapor recovery tower (VRT) at an existing "Generation:4"oil and gas exploration and
production facility that is located in the ozone non -attainment area. Hydrocarbon liquid produced at this facility flows from a high -low pressure
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 of VRU downtime, the gas vented from the VRT is routed
to three (3) enclosed combustion devices (ECDs). It is assumed that gas vented from the VRT is routed to the enclosed combustion devices 40% of the
time. Emissions while VRT gas is routed to the ECDs is a function of condensate throughput. This permit will cover emissions when the VRT gas is
routed to the ECDs.
4
Section 04 - Public Comment Requirments
Is Public Comment Required?
If yes, why?'
Requesting Synthetic. Min+
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?2
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
Non -Attainment New Source Review (NANSR): VOC
No
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Facility is classified as synthetic minor as described above.
No
Colorado Air Permitting Project
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
006 (VRUs) in a closed loop process. When the VRUs are unable to capture the entire overhead gas stream,
flash gas is routed to three (3) enclosed combustion devices (ECOs). The ECDs each have a minimum
control efficiency of 95%. Emissions are a function of condensate throughput while overhead gas is routed
to the ECDs.. Itis assumed that the flash gas is routed to the ECDs 40% of the time. This permit covers
emissions when flash gas is routed to the ECDs.
Equipment Description
This source vents natural gas from:
Emissions from this source are:
one 1 va
recove tower
Natural gas venting from one (1) vapor recovery tower. Emissions from this source are recompressed.
Calculations
The site specific emission factors developed for this source were determined through the use of two pressurized liquid samples, two E&P Tanks simulations
associated with the pressurized liquids samples, and a sales oil sample. The pressurized liquid samples were obtained from two different wells at the facility
on. February 10, 2015. The wells from which the samples were taken areas follow: Underhill 27C-17HZ and Underhill_28N-17HZ. The sales oil sample was obtained on January 29, 2014 from a common production feed at the Underhill well pad. _ Each of the samples was obtained after each of the wells at this.
facility came online_ As a result, the sales oil is still considered representative even though it was taken more than a year before the application submittal. Two
separate ESP Tanks simulations were conducted using the two pressurized liquid samples and the sales oil sample. The results of the simulation were
averaged to determine the site specific emission factors. The following tables contain the information from the E&P Tanks simulations used to determine the
emission factors:
E&P Tanks Simulation 1 (Underhill 27C-17HZ)
Throughput: 24 bbl/day
8760 bbl/ ear
Pollutant
Emission Rate
Emission Rate
Uncontrolled Emission
Factor
10.29 JIb/bbl
VOC
10.292
lb/hr
90157.92
lb/year
Benzene
0.094
lb/hr
823.44
lb/year
0.09
lb/bbl
Toluene
0,147
lb/hr
1287.72
lb/year
0.15
lb/bbl
Ethylbenzene
0.025
lb/hr
219.00
lb/year
0.03
lb/bbl
Xylenes
0.076
lb/hr
665.76
lb/year
0.08
lb/bbl
n -Hexane
0.392
lb/hr
3433.92
lb/year
0.39
lb/bbl
2,2,4-TMP
0.089
lb/hr
779,64
lb/year
0.09
lb/bbl
Note: The E&P Tanks simulation was run on a basis of 24 bbl/day (8760 bbl/year). Asa result, the conversion
from lb/hr to lb/bbl results in the same value.
E&P Tanks Simulation 2 (Underhill 28N-17HZ)
Throughput: 24 bbl/day
8760 bbl/ ear
Pollutant
Emission Rate
Emission Rate
Uncontrolled Emission
VOC
12.216
lb/hr
107012.16
lb/year
12.22
lb/bbl
Benzene
0.112
lb/hr
981.12
lb/year
0.11
lb/bbl
Toluene
0.197
lb/hr
1725.72
lb/year
0.20
lb/bbl
Ethylbenzene
0.04
lb/hr
350.40
lb/year
0.04
lb/bbl
Xylenes
0.101
lb/hr
884.76
lb/year
0.10
lb/bbl
n -Hexane
0.471
lb/hr
4125.96
lb/year
0.47
lb/bbl
2,2,4-TMP
0.09a
lb/hr
858.48
lb/year
0.10
lb/bbl
Note: The E&P Tanks simulation was run on a basis of 24 bbl/day (8760 bbUpear).'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 bbl/ ear
Pollutant
Emission Rate
Emission Rate
Uncontrolled Emission
VOC
11.254
lb/hr
98585.04
lb/year
11.254
lb/bbl
Benzene
0.103
lb/hr
902.28
lb/year
0.103
Ib/bbl
Toluene
0.172
lb/hr
1506.72
lb/year
0.172
lb/bbl
Ethylbenzene
0.0325
lb/hr
284.70
lb/year
0.033
lb/bbl
Xylenes
0.0885
lb/hr
775.26
lb/year
0.089
Ib/bbl
n -Hexane
0.4315
lb/hr
3779.94
lb/year
0.432
Ib/bbl
2,2,4-TMP
0.0935
lb/hr
819.06
lb/year
0.094
Ib/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 Underhill27C-17HZ and Underhill 28N-17HZ simulations.
'Total throughput to VRT:
Requested Throughput:
83,150 bbl/year
1'
16WE0044.CP1.xlsm E0044.CP1.xlsm
VRU downtime:
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 three (3) enclosed combustion devices (ECDs). The ECDs each have a minimum
control efficlency,of 95%. "Emissions are a function of condensate throughput while overhead gas is routed
to the ECDs. It is assumed that the flash gas is routed to the ECDs 40% of the time. This permit covers
emissions when flash gas is routed to the ECDs.
40%
VRT Throughput during VRU downtime:
33,260 bbl/year
}
16WE0044.CP1.xlsm
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
U06 (VRUs) in a closed loop process. When the VRUs are unable to capture the entire overhead gas stream,
flash gas is routed to three (3) enclosed combustion devices (ECDs). The ECDs each have a minimum
control efficiency of 95%. Emissions are a function of condensate throughput while overhead gas is routed
to the ECDs. It is assumed that the flash gas is routed to the ECDs 40% of the time. This permit covers
emissions when, flash gas is routed to the ECDs.
Flaring Information
Equipment Description
Three (3) enclosed combustors to combust vapor recovery tower as during VRU downtime.
Manufacturer
TBD
Model
TBD
Serial Number
TBD
Control Efficiency
95.00%
Combustion emission factor source:
010037 llb NOx/Ib VOC
Emissions Summary Table
CDPHE Inter -Office Communication (2005-03-22)
0.0094 jib CO/lb VOCI
Pollutant
Uncontrolled Emission Factor
Controlled Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
VOC
11.254
lb/bbl
0.563 lb/MMscf
187.15 tpy
9.36 tpy
E&P Tanks
NOx
0.0416
lb/bbl
0.0416 Ib/MMBTU
0.69 tpy
0.69 tpy
CDPHE
CO
0.1058
lb/bbl
0.1058 Ib/MMBTU
1.76 tpy
1.76 tpy
CDPHE
Benzene
0.1030
lb/bbl
0.00515 lb/MMscf
3425.8 lb/yr
171.3 lb/yr
E&P Tanks
Toluene
0.1720
lb/bbl
0.00860 Ib/MMscf
5720.7 lb/yr
286.0 lb/yr
E&P Tanks
Ethylbenzene
0.0325
Ib/bbl
0.00163 lb/MMscf
1081.0 lb/yr
54.0 lb/yr
E&P Tanks
Xylenes
0.0885
lb/bbl
0.00443 lb/MMscf
2943.5 lb/yr
147.2 lb/yr
E&P Tanks
n -Hexane
0.4315
lb/bbl
0.02158 Ib/MMscf
14351.7 lb/yr
717.6 lb/yr
E&P Tanks
2,2,4-TMP
0.0935
lb/bbl
0.00468 lb/MMscf
3109.8 lb/yr
155.5 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?
No See Additional Note #1 below for additional discussion.
This separator is not subject to Reg 7 Section XVII.G
k
Additional Notes:
1. Based on the interpretation that the date of first production is equivalent to the date of a well being "newly constructed," the date of first production for the most
recent well at this facility occurred prior to the August 1, 2014 applicability date. The operator was asked about this point and they confirmed that the date of first
production for the most recent well at this facility was before August 1, 2014. As a result, the VRT is not subject to Regulation 7, Section XVII.G and the other control
requirements of Regulation 7 Section XVII.B.2.
2. The operator expressed in the application that the normal operating pressure of the separator was increased by 10 psi prior to obtaining a sample for analysis. This
artificial load on the VRT leads to a more conservative estimate of flash emissions at the vapor recovery tower due to the increased pressure drop.
3. As indicated above, the operator obtained the API gravity and RVP used in the E&P Tanks simulation from a sales oil sample obtained January 29, 2014. This sample
was taken more than a year before the application was submitted. However, the sample was also taken after all of the active wells at this facility came online and
began producing. Since new wells have not come online since this sample was obtained, it is considered representative and is acceptable to use in the E&P tank
simulation to determine emissions.
4. The pressurized condensate samples used for this analysis were obtained on February 10, 2015. Since this is within one year of the submittal of this application,
initial testing will not be required in the permit.
5. During review, I noticed the operator specified an ambient pressure of 12.63 psi in the E&P Tank simulations. I expressed to the operator that this value will
underestimate emissions since the ambient pressure for the Denver area is 12.12 psi. The operator agreed with this assertion and provided updated E&P Tank
simulations with the ambient pressure updated to reflect 12.12 psi.
6. The operator requested that the requested throughput be updated from 54,000 bbl/year to 33,260 bbl/year. This request is based on the current production
estimates from this facility. This request was accepted and the necessary changes were made to the APEN.
7. The operator was provided with a draft permit to review prior to public comment. The operator reviewed the draft permit and provided one comment. They
requested that the language for condition 15 be updated from stating "The owner or operator shall demonstrate compliance with opacity standards using EPA Method
9 to measure onacity from the flare (Reference: Reeulation No. 1. Section II.AS1" to "The owner nr onerator shall demonstrate romnlianre with onacity standards.
16WE0044.CP1.xlsm
4
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 three (3) enclosed combustion devices (ECDs). The ECDs each have a minimum
control efficiency of 95%. Emissions are a function of condensate throughput while overhead gas is routed
to the ECDs. It is assumed that the flash gas is routed to the ECDs 40% of the time. This permit covers
emissions when flash c as'is routed to,the ECDs._ �, . I-„�.,
using EPA Reference Method 9, 40 C.F.R. Part 60, Appendix A, to measure opacity from the flare. This measurement shall consist of a minimum twenty-four consecutive
readings taken at fifteen second intervals over a six minute period. (Regulation Number 1, Section II.A.1 and II.A.5)." This request accepted since the requested
language is consistent with the language contained in our updated permit templates. The changes were made to the permit accordingly.
16 W E0044.CP1.xlsm
AIRS (County/Plant) 123/4716
Permit No. 16WE0044
Date 5/24/2016
Point #
SCC
Pollutant or CAS
Uncontrolled Emission
Factor
Emisison Factor Source
Controlled
Actual
Emissions
(tpy)"
Controlled
Requested
Emissions
(tpy)*
PTE (tpy)*
Ctrl.
Eff%
NCRP =
reportable
?
006
31000129
VOC
11254 lb/1000 ba
E&P Tanks
9.36
187.15
95%
Yes
006
31000129
NOx
41.6 lb/1000 ba
CDPHE
0.69
0.69
0%
No
006
31000129
CO
105.8 lb/1000 ba
CDPHE
1.76
1.76
0%
No
006
31000129
Benzene
103 lb/1000 ba
E&P Tanks
172
3426
95%
Yes
006
31000129
Toluene
172 lb/1000 ba
E&P Tanks
286
5721
95%
Yes
006
31000129
Ethylbenzene
32.5 lb/1000 ba
E&P Tanks
54
1081
95%
Yes
006
31000129
Xylenes
88.5 lb/1000 ba
E&P Tanks
148
2944
95%
Yes
006
31000129
n -Hexane
431.5 lb/1000 ba
E&P Tanks
718
14352
95%
Yes
006
31000129
2,2,4-TMP
93.5 lb/1000 ba
E&P Tanks
156
3110
95%
Yes
**HAP emissions have units of Ibs/year.
0
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40
M
N
Emission Source AIRS ID:
[Leave blank unless APCD has already assigned a permit # & AIRS ID]
Permit Number:
Facility Equipment ID:
nested Action (check applicable request boxes)
Section 02 — Re
Section 01— Administrative Information
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Design Process Rate
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Annual Requested Permitted Level3
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IIPlease use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above.
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Person to Contact:
Carissa.krey@anadarko.com
E-mail Address:
Emission Factor Uncontrolled Controlled Actual
Source Actual Emissions Emissions
(Ibs/vearl (Ihs/vaarl
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Chemical Name
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E -Benzene
Xylene
N -Hexane
224-TMP
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