HomeMy WebLinkAbout20161552.tiff A CDPHE COLORADO
Co421,
10 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
1150 O St RECEIVED
PO Box 758
Greeley, CO 80632 MAY 0 6 2016
May 3, 2016 WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On May 4, 2016, the Air Pollution Control Division wilt begin a 30-day public notice period for
Bonanza Creek Energy Operating Company, LLC - State North Platte CPF 42-26. 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,
CriLL
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
2016-1552
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/c..,,.._
John W. Hickenlooper, Governor Marry,WilkiMD, SPH, Executive Director and Chief Medical Officer
,,A CDPHE Air Pollution Control Division
CO 1
Notice of a Proposed Project or Activity Warranting Public
rM Comment
Website Title: Bonanza Creek Energy Operating Company, LLC - State North Platte CPF 42-26 - Weld County
Notice Period Begins: May 4, 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: Bonanza Creek Energy Operating Company, LLC
Facility: State North Platte CPF 42-26
Oil and gas central production facility
SENE Sec 26 T5N R63W
Weld County
The proposed project or activity is as follows: Source proposes to construct and operate a new 12 MMSCF
per day TEG dehydrator at an existing oil and gas 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 13WE2994 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:
Kirk Bear
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
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STATE OF COLORADO
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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT N
AIR POLLUTION CONTROL DIVISION *` `
TELEPHONE: (303)692-3150 x,876 *
CONSTRUCTION PERMIT
PERMIT NO: 13WE2994 Issuance 3
DATE ISSUED:
ISSUED TO: Bonanza Creek Energy Operating Company, LLC
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the State North Platte Central Production Facility 42-26
(COGCC#434730), located in SENE Section 26, Township 5N, Range 63W, in Weld
County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS Description
Equipment ID Point
One (1) Caterpillar, Model G3516B LE, Serial Number TBD,
natural gas-fired, naturally aspirated, 4SLB reciprocating
C-2701 002 internal combustion engine, site rated at 1254 horsepower at
1400 RPM. This engine shall be equipped with an oxidation
catalyst and air/fuel ratio control. This emission unit is a
compressor engine used for enhanced oil recovery.
One (1) Caterpillar, Model G3516B LE, Serial Number TBD,
natural gas-fired, naturally aspirated, 4SLB reciprocating
C-2702 003 internal combustion engine, site rated at 1254 horsepower at
1400 RPM. This engine shall be equipped with an oxidation
catalyst and air/fuel ratio control. This emission unit is a
compressor engine used for enhanced oil recovery.
One (1) Caterpillar, Model G3406TA, Serial Number TBD,
natural gas-fired, turbo-charged, 4SRB reciprocating internal
combustion engine, site rated at 243 horsepower at 1800
G-6901 004 RPM. This engine shall be equipped with a non-selective
catalytic reduction (NSCR) system and air/fuel ratio control.
This emission unit is an electrical generator used for prime
power.
AIRS ID: 123/9BEE Page 1 of 36
NGEngine Version 2012-1
Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility AIRS Description
Equipment ID Point
One (1) Cummins, Model G8.3, Serial Number 46834328,
natural gas-fired, naturally aspirated, 4SRB reciprocating
internal combustion engine, site rated at 111 horsepower.
C-2710 007 This engine shall be equipped with a non-selective catalytic
reduction (NSCR) system and air/fuel ratio controller
(AFRO). This emission unit is a compressor engine used for
vapor recovery.
One (1) Cummins, Model G8.3, Serial Number 46869438,
natural gas-fired, naturally aspirated, 4SRB reciprocating
internal combustion engine, site rated at 111 horsepower.
C-2711 008 This engine shall be equipped with a non-selective catalytic
reduction (NSCR) system and air/fuel ratio controller
(AFRC). This emission unit is a compressor engine used for
vapor recovery.
One (1) Cummins, Model G8.3, Serial Number 46957888,
natural gas-fired, naturally aspirated, 4SRB reciprocating
internal combustion engine, site rated at 111 horsepower.
C-2712 009 This engine shall be equipped with a non-selective catalytic
reduction (NSCR) system and air/fuel ratio controller
(AFRO). This emission unit is a compressor engine used for
vapor recovery.
One (1) General Motors, Model Vortec 5.7L, Serial Number
10CHMM211150078, natural gas-fired, naturally aspirated,
4SRB reciprocating internal combustion engine, site rated at
C-9721 010 92 horsepower. This engine shall be equipped with a non-
selective catalytic reduction (NSCR) system and air/fuel ratio
controller(AFRO). This emission unit is a compressor
engine used for vapor recovery.
One (1) General Motors, Model Vortec 5.7L, Serial Number
10CHMM12130046, natural gas-fired, naturally aspirated,
4SRB reciprocating internal combustion engine, site rated at
C-9722 011 92 horsepower. This engine shall be equipped with a non-
selective catalytic reduction (NSCR) system and air/fuel ratio
controller (AFRC). This emission unit is a compressor
engine used for vapor recovery.
One (1) General Motors, Model Vortec 5.7L, Serial Number
10CHMM303180097, natural gas-fired, naturally aspirated,
4SRB reciprocating internal combustion engine, site rated at
C-9723 012 92 horsepower. This engine shall be equipped with a non-
selective catalytic reduction (NSCR) system and air/fuel ratio
controller(AFRO). This emission unit is a compressor
engine used for vapor recovery.
AIRS ID: 123-9BEE Page 2 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility AIRS Description
Equipment ID Point
One (1) General Motors, Model Vortec 5.7L, Serial Number
10CHMM304120033, natural gas-fired, naturally aspirated,
4SRB reciprocating internal combustion engine, site rated at
C-9724 013 92 horsepower. This engine shall be equipped with a non-
selective catalytic reduction (NSCR) system and air/fuel ratio
controller(AFRO). This emission unit is a compressor
engine used for vapor recovery.
Twelve (12) above ground 1,100 barrel atmospheric
CNDTK-01 014 condensate storage tanks controlled by six (6) enclosed
flares. Flares have a combustion efficiency of 95%.
Four (4) above ground 1,100 barrel produced water storage
PWT-01 015 tanks controlled by six (6) enclosed flares. Flares have a
combustion efficiency of 95%.
Fifteen high/low pressure separators, two heater treaters,
LPGFL 017 and three VRTs controlled by six (6) enclosed flares when
the VRUs are down. Flares have a combustion efficiency of
95%.
Truck Condensate Loadout controlled by a vapor recovery
TLO 035 system and six (6) enclosed flares. Flares have a
combustion efficiency of 95%.
MNTK-01 038 One 500 bbl maintenance tank.
One (1) Triethylene glycol (TEG) natural gas dehydration
unit (make, model, serial number: to be determined)with a
design capacity of 12.0 MMscf per day. This emissions unit
is equipped with two (2) Kimray, model 21015 gas-glycol
pumps, each with a design capacity of 3.5 gallons per
DEHY-02 039 minute. Only one Kimray gas-glycol pump will be operated at
any given time. The second Kimray gas-glycol pump serves
as a back-up only. This unit is also equipped with a flash
tank, reboiler and still vent. Emissions from the still vent are
routed to a condenser and then to an enclosed flare.
Emissions from the flash tank are 100% recycled to the
facility inlet or to the fuel gas system.
Points 002 and 003: Each of these engines may be replaced with another engine in
accordance with the temporary engine replacement provision or with another Caterpillar
G3516B LE engine in accordance with the permanent replacement provision of the Alternate
Operating Scenario (AOS), included in this permit as Attachment A.
Point 004: This engine may be replaced with another engine in accordance with the
temporary engine replacement provision or with another Caterpillar G3406TA engine in
accordance with the permanent replacement provision of the Alternate Operating Scenario
(AOS), included in this permit as Attachment A.
AIRS ID: 123-9BEE Page 3 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
Points 007-009: Each of these engines may be replaced with another engine in accordance
with the temporary engine replacement provision or with another Cummins G8.3 engine in
accordance with the permanent replacement provision of the Alternate Operating Scenario
(AOS), included in this permit as Attachment A.
Points 010-013: Each of these engines may be replaced with another engine in accordance
with the temporary engine replacement provisiort or with another General Motors Vortec
5.7L engine in accordance with the permanent replacement provision of the Alternate
Operating Scenario (AOS), included in this permit as Attachment A.
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 after issuance of this permit, by submitting a Notice of Startup form to
the Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. 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.
2. Within one hundred and eighty days (180) after 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.
(Reference: Regulation No. 3, Part B, 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. Point 039: The following information shall be provided to the Division within fifteen (15)
days after commencement of operation.
• 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.)
5. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
AIRS ID: 123-9BEE Page 4 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
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 AIRS Tons per Year
Emission Type
Equipment ID Point NO VOC CO
X
C-2701 002 6.1 2.3 12.2 Point
C-2702 003 6.1 2.3 12.2 Point
G-6901 004 2.4 1.1 4.7 Point
C-2710 007 1.1 0.8 2.2 Point
C-2711 008 1.1 0.8 2.2 Point
C-2712 009 1.1 0.8 2.2 Point
C-9721 010 0.9 0.4 1.8 Point
C-9722 011 0.9 0.4 1.8 Point
C-9723 012 0.9 0.4 1.8 Point
C-9724 013 0.9 0.4 1.8 Point
CNDTK-01 014 0.8 22.1 3.4 Point
PWT-01 015 -- 0.2 -- Point
LPGFL 017 1.1 26.1 4.7 Point
L-01 035 0.3 10.8 1.4 Point
MNTK-01 038 -- 4.1 -- Point
DEHY-02 039 -- 2.1 -- Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Annual emission limits are expressed to the nearest tenth≥APEN requested limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
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)
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.
AIRS ID: 123-9BEE Page 5 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
8. Point 039: Compliance with the emission limits in this permit shall be demonstrated by
running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most
recent extended wet gas analysis and recorded operational values (including gas
throughput, lean glycol recirculation rate, and other operational values specified in the
O&M Plan). Recorded operational values, except for gas throughput, shall be averaged
on a monthly basis for input into GRI GlyCalc and be provided to the Division upon
request.
9. Point 039: 100% of emissions that result from the flash tank associated with this
dehydrator shall be recycled to the facility inlet or facility's fuel gas system.
10. 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 AIRS Control Device Pollutants
Equipment ID Point Controlled
C-2701 002 Oxidation catalyst and air/fuel ratio controller VOC, CO, HCHO
C-2702 003 Oxidation catalyst and air/fuel ratio controller VOC, CO, HCHO
G-6901 004 Non-selective catalytic reduction (NSCR) NOx, CO
system and air/fuel ratio controller
C-2710 007 Non-selective catalytic reduction (NSCR) NOx, CO, and
system and air/fuel ratio controller VOC
C-2711 008 Non-selective catalytic reduction (NSCR) NOx, CO, and
system and air/fuel ratio controller VOC
C-2712 009 Non-selective catalytic reduction (NSCR) NOx, CO, and
system and air/fuel ratio controller VOC
C-9721 010 Non-selective catalytic reduction (NSCR) NOx and CO
system and air/fuel ratio controller
C-9722 011 Non-selective catalytic reduction (NSCR) NOx and CO
system and air/fuel ratio controller
C-9723 012 Non-selective catalytic reduction (NSCR) NOx and CO
system and air/fuel ratio controller
C-9724 013 Non-selective catalytic reduction (NSCR) NOx and CO
system and air/fuel ratio controller
CNDTK-01 014 Six Enclosed Flares VOC and HAPs
PWT-01 015 Six Enclosed Flares VOC and HAPs
LPGFL 017 Six Enclosed Flares when the VRUs are not VOC and HAPs
operating.
L-01 035 Six Enclosed Flares VOC and HAPs
DEHY-02 039 Condenser and Enclosed flare for the still VOC & HAPs
vent
PROCESS LIMITATIONS AND RECORDS
11. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
AIRS ID: 123-9BEE Page 6 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
Process/Consumption Limits
Facility AIRS Process Parameter Annual Limit
Equipment ID Point
C-2701 002 Consumption of natural gas as a fuel 62.0 MMscf/yr
C-2702 003 Consumption of natural gas as a fuel 62.0 MMscf/yr
G-6901 004 Consumption of natural gas as a fuel 12.6 MMscf/yr
C-2710 007 Consumption of natural gas as a fuel 6.4 MMscf/yr
C-2711 008 Consumption of natural gas as a fuel 6.4 MMscf/yr
C-2712 009 Consumption of natural gas as a fuel 6.4 MMscf/yr
C-9721 010 Consumption of natural gas as a fuel 5.7 MMscf/yr
C-9722 011 Consumption of natural gas as a fuel 5.7 MMscf/yr
C-9723 012 Consumption of natural gas as a fuel 5.7 MMscf/yr
C-9724 013 Consumption of natural gas as a fuel 5.7 MMscf/yr
CNDTK-01 014 Condensate Throughput 2,084,880 barrels
PWT-01 015 Produced Water Throughput 1,033,680 barrels
LPGFL 017 Gas Vented from Separators, Heater Treaters, 14.0 MMscf
and VRTs when the VRUs are not operational
L-01 035 Condensate Loaded 2,084,880 barrels
MNTK-01 038 Condensate Throughput 2,000 barrels
DEHY-02 039 Natural gas throughput 4,380 MMscf/yr
The owner or operator shall calculate 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.
12. Point 017: The owner or operator shall continuously monitor and record the volumetric
flowrate of gas vented from all low pressure separators and VRTs during VRU downtime
using a flow meter. The flow meter shall continuously measure flowrate and record total
volumetric flow vented to the enclosed flares from the separators and VRTs during VRU
downtime. The owner or operator shall use monthly throughput records to demonstrate
compliance with the limits specified in this permit and to calculate emissions as
described in this permit.
13. Point 039: This unit shall be limited to the maximum lean glycol circulation rate of 3.5
gallons per minute. The lean glycol recirculation rate shall be recorded as per the
frequency required in the approved O&M Plan. This information shall be maintained in a
AIRS ID: 123-9BEE Page 7 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
log on site and made available to the Division for inspection upon request. (Reference:
Regulation No. 3, Part B, II.A.4)
STATE AND FEDERAL REGULATORY REQUIREMENTS
14. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on
the subject equipment for ease of identification. (Reference: Regulation Number 3, Part
B, III.E.) (State only enforceable)
15. Points 002-004, and 007-013: Visible emissions shall not exceed twenty percent (20%)
opacity during normal operation of the source. During periods of startup, process
modification, or adjustment of control equipment visible emissions shall not exceed 30%
opacity for more than six minutes in any sixty consecutive minutes. (Reference:
Regulation No. 1, Section II.A.1. &4.)
16. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
17. Points 002 and 003: This equipment is subject to the control requirements for stationary
and portable engines in the 8-hour ozone control area under Regulation No. 7, Section
XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst
shall be required.
18. Points 002-004: These engines may be subject to the control requirements for natural
gas-fired reciprocating internal combustion engines under Regulation No. 7, Section
XVII.E (State only enforceable). The owner or operator of any natural gas-fired
reciprocating internal combustion engine that is either constructed or relocated to the
state of Colorado from another state after the date listed in the table below shall operate
and maintain each engine according to the manufacturer's written instructions or
procedures to the extent practicable and consistent with technological limitations and
good engineering and maintenance practices over the entire life of the engine so that it
achieves the emission standards required in the table below:
Maximum' Engine Construction or Emission Standard in g/hp-hr
HP Relocation Date NOx CO VOC
<100HP Any N/A N/A N/A
≥100HP and January 1, 2008 2.0 4.0 1.0
<500HP January 1, 2011 1.0 2.0 0.7
≥500HP July 1, 2007 2.0 4.0 1.0
July 1, 2010 1.0 2.0 0.7
Maximum engine horsepower is the nameplate rating of the engine and does not account
for deration.
Note: Per Regulation No. 7, Section XVII.B.5, internal combustion engines that are
subject to an emission standard or an emissions control requirement in a federal
maximum achievable control technology ("MACT") standard under 40 CFR Part 63, a
Best Available Control Technology ("BACT") limit, or a New Source Performance
Standard under 40 CFR Part 60 are not subject to this Section XVII.
19. Points 006-009: These engines are subject to the control requirements for natural gas-
fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E
(State only enforceable). The owner or operator of any natural gas-fired reciprocating
AIRS ID: 123-9BEE Page 8 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
internal combustion engine that is either constructed or relocated to the state of
Colorado from another state after the date listed in the table below shall operate and
maintain each engine according to the manufacturer's written instructions or procedures
to the extent practicable and consistent with technological limitations and good
engineering and maintenance practices over the entire life of the engine so that it
achieves the emission standards required in the table below:
Maximum' Engine Construction or Emission Standard in g/hp-hr
HP Relocation Date NOx CO VOC
<100HP Any N/A N/A N/A
≥100HP and January 1, 2008 2.0 4.0 1.0
<500HP January 1, 2011 1.0 2.0 0.7
≥500HP July 1, 2007 2.0 4.0 1.0
July 1, 2010 1.0 2.0 0.7
Maximum engine horsepower is the nameplate rating of the engine and does not
account for deration.
Note: Per Regulation No. 7, Section XVII.B.5, internal combustion engines that are
subject to an emission standard or an emissions control requirement in a federal
maximum achievable control technology ("MACT") standard under 40 CFR Part 63, a
Best Available Control Technology ("BACT") limit, or a New Source Performance
Standard under 40 CFR Part 60 are not subject to this Section XVII.
20. Point 014, 015, 017, and 035: The flare covered by this permit is subject to Regulation
No. 7, Section XII.C General Provisions (State only enforceable). If a combustion device
is used to control emissions of volatile organic compounds to comply with Section XII.D,
it shall be enclosed, have no visible emissions, and be designed so that an observer
can, by means of visual observation from the outside of the enclosed combustion device,
or by other means approved by the Division, determine whether it is operating properly.
The operator shall comply with all applicable requirements of Section XII.
21. Point 014, 015, 017, and 035: This source is subject to the recordkeeping, monitoring,
reporting and emission control requirements of Regulation 7, Section XII. The operator
shall comply with all applicable requirements of Section XII.
22. Points 014, 015, 017, 035 and 039: The flare(s) covered by this permit is/are subject to
Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These
requirements include, but are not limited to:
XVII.B.2.b If a 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, 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.
XVII.B.2.d Auto-igniters: All combustion devices used to control emissions of
hydrocarbons must be equipped with and operate an auto-igniter as follows:
XVII.B.2.d.(i) All combustion devices installed on or after May 1, 2014, must be equipped
with an operational auto-igniter upon installation of the combustion device.
AIRS ID: 123-9BEE Page 9 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
XVII.B.2.d.(ii) 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.
23. Points 014 and 015: The storage tanks covered by this permit are subject to Regulation
7, Section XVII.C emission control requirements. These requirements include, but are
not limited to:
Section XVII.C.1. Control and monitoring requirements for storage tanks
XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of
VOCs equal to or greater than six (6) tons per year based on a rolling twelve-
month total must operate 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.
XVII.C.1.b.(i)(b) Control requirements of Section XVII.C.1.b. must be achieved
by May 1, 2015.
XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section
XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks
constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio,
visual, olfactory ("AVO") and additional visual inspections of the storage tank and
any associated equipment (e.g. separator, air pollution control equipment, or
other pressure reducing equipment) at the same frequency as liquids are loaded
out from the storage tank. These inspections are not required more frequently
than every seven (7) days but must be conducted at least every thirty one (31)
days. Monitoring is not required for storage tanks or associated equipment that
are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e.
The additional visual inspections must include, at a minimum:
XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other
access point to ensure that they are closed and properly sealed;
XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control
equipment to ensure that it is operating, including that the pilot light is lit
on combustion devices used as air pollution control equipment;
XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter
and valves for piping of gas to the pilot light to ensure they are functioning
properly;
XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure
that the valves for the piping from the storage tank to the air pollution
control equipment are open; and
XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the
presence or absence of smoke. If smoke is observed, either the
equipment must be immediately shut-in to investigate the potential cause
for smoke and perform repairs, as necessary, or EPA Method 22 must be
conducted to determine whether visible emissions are present for a
period of at least one (1) minute in fifteen (15) minutes.
XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible
to monitor, the owner or operator is not required to monitor such equipment until
it becomes feasible to do so.
AIRS ID: 123-9BEE Page 10 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted
with air pollution control equipment as required by Sections XII.D. or
XVII.C.1.
XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions
to air pollution control equipment, and must operate without venting hydrocarbon
emissions from the thief hatch (or other access point to the tank) or pressure
relief device during normal operation, unless venting is reasonably required for
maintenance, gauging, or safety of personnel and equipment. Compliance must
be achieved in accordance with the schedule in Section XVII.C.2.b.(ii).
XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of
Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement
a documented Storage Tank Emission Management System ("STEM") plan to
identify, evaluate, and employ appropriate control technologies, monitoring
practices, operational practices, and/or other strategies designed to meet the
requirements set forth in Section XVII.C.2.a. Owners or operators must update
the STEM plan as necessary to achieve or maintain compliance. Owners or
operators are not required to develop and implement STEM for storage tanks
containing only stabilized liquids. The minimum elements of STEM are listed
below.
XVII.C.2.b.(i) STEM must include selected control technologies, monitoring
practices, operational practices, and/or other strategies; procedures for
evaluating ongoing storage tank emission capture performance; and
monitoring in accordance with approved instrument monitoring methods
following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection
Frequency in Table 1.
XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections
XVII.C.2.a. and XVII.C.2.b. and begin implementing the required
approved instrument monitoring method in accordance with the following
schedule:
XVII.C.2.b.(ii)(a) A storage tank constructed on or after May 1, 2014, must
comply with the requirements of Section XVII.C.2.a. by the date the
storage tank commences operation. The storage tank must comply with
Section XVII.C.2.b. and implement the approved instrument monitoring
method inspections within ninety (90) days of the date that the storage
tank commences operation.
XVII.C.2.b.(ii)(b) A storage tank constructed before May 1, 2014, must comply
with the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1,
2015. Approved instrument monitoring method inspections must begin
within ninety (90) days of the Phase-In Schedule in Table 1, or within
thirty (30) days for storage tanks with uncontrolled actual VOC emissions
greater than 50 tons per year.
XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method
inspection, owners or operators must continue conducting approved
instrument monitoring method inspections in accordance with the
Inspection Frequency in Table 1.
AIRS ID: 123-9BEE Page 11 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
Table 1 —Storage Tank Inspections
Threshold: Storage Tank Approved Instrument Phase-In Schedule
Uncontrolled Actual VOC Monitoring Method
Emissions (tpy) Inspection Frequency
> 6 and < 12 Annually January 1, 2016
> 12 and < 50 Quarterly July 1, 2015
> 50 Monthly January 1, 2015
XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and
associated equipment that are unsafe, difficult, or inaccessible to monitor,
as defined in Section XVII.C.1.e.
XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that
the selected STEM strategy(ies) are designed to minimize emissions from
storage tanks and associated equipment at the facility(ies), including thief
hatches and pressure relief devices.
XVII.C.3. Recordkeeping
XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or
XVII.C. must maintain records of STEM, if applicable, including the plan, any
updates, and the certification, and make them available to the Division upon
request. In addition, for a period of two (2) years, the owner or operator must
maintain records of any required monitoring and make them available to the
Division upon request, including:
XVII.C.3.a. The AIRS ID for the storage tank.
XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief
device, or other access point are found to be venting hydrocarbon emissions,
except for venting that is reasonably required for maintenance, gauging, or safety
of personnel and equipment.
XVII.C.3.c. The date and duration of any period where the air pollution control equipment
is not operating.
XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA
Method 22 test or investigation pursuant to Section XVII.C.1.d.(v).
XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air
pollution control equipment, and mitigate visible emissions.
XVII.C.3.f. A list of equipment associated with the storage tank that is designated as
unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e.,
an explanation stating why the equipment is so designated, and the plan for
monitoring such equipment.
24. Points 017: The separation equipment, including low pressure separators, heater
treaters, and vapor recovery towers, covered by this permit are subject to Regulation 7,
AIRS ID: 123-9BEE Page 12 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
Section XVII.G emission control requirements. 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.
25. Point 035: This source is located in an ozone non-attainment or attainment-maintenance
area and is subject to the Reasonably Available Control Technology (RACT)
requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck
tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E)
26. Point 035: The owner or operator shall follow loading procedures that minimize the
leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation
3, Part B, III.E):
a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or
other liquid or vapor loss during loading and unloading.
b. All compartment hatches (including thief hatches) shall be closed and latched at
all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
c. The owner or operator shall inspect loading equipment and operations on site at
the time of the inspection to ensure compliance with Condition 26 (a) and (b)
above. The inspections shall occur at least monthly. Each inspection shall be
documented in a log available to the Division on request.
27. Point 035: All hydrocarbon liquid loading operations, regardless of size, shall be
designed, operated and maintained so as to minimize leakage of volatile organic
compounds to the atmosphere to the maximum extent practicable.
28. Minor sources in designated nonattainment or attainment/maintenance areas shall apply
Reasonably Available Control Technology (RACT) for the pollutants for which the area is
nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B,
III.D.2.a). This requirement to apply RACT shall be satisfied by implementing the
following Leak Detection and Repair(LDAR) program:
a. Leak Monitoring
i. Shall be completed on all components as defined per
Regulation 7, Section XVII.A.5;
ii. Auditory/visual/olfactory inspection (AVO) inspections will be
performed on a monthly basis;
iii. Approved Instrument Monitoring Methods (AIMM) as defined
in Regulation 7, Section XVII.A.2 shall be evaluated according
to the provisions of Regulation 7, Section XVII.F.4.c and
inspections performed at the frequencies established in
Section XVII.F.4 Table 4;
iv. Initial AIMM inspections shall be completed within 60 days of
issuance on this permit (The phase in schedule established in
Table 4 of Section XVII.F.4 is not applicable);
AIRS ID: 123-9BEE Page 13 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
v. If a component is unsafe, difficult, or inaccessible to monitor
per Regulation 7, Section XVII.F.5, the owner or operator is
not required to monitor the component until it becomes
feasible to do so.
b. Leaks requiring repair: Leaks must be identified utilizing the methods listed in this
condition. Only leaks detected pursuant to this condition require repair.
i. For EPA Method 21 monitoring, or other Division approved
quantitative instrument based monitoring, at facilities
constructed before May 1, 2014, a leak is any concentration of
hydrocarbon above 2,000 parts per million (ppm) not
associated with normal equipment operation, such as
pneumatic device actuation and crank case ventilation, except
for well production facilities where a leak is defined as any
concentration of hydrocarbon above 500 ppm not associated
with normal equipment operation, such as pneumatic device
actuation and crank case ventilation.
ii. For EPA Method 21 monitoring, or other Division approved
quantitative instrument based monitoring, at facilities
constructed on or after May 1, 2014, a leak is any
concentration of hydrocarbon above 500 ppm not associated
with normal equipment operation, such as pneumatic device
actuation and crank case ventilation.
iii. For infra-red camera and AVO monitoring, or other Division
approved non-quantitative instrument based monitoring, a leak
is any detectable emissions not associated with normal
equipment operation, such as pneumatic device actuation and
crank case ventilation.
iv. For leaks identified using an approved instrument monitoring
method or AVO, owners or operators have the option of either
repairing the leak in accordance with the repair schedule set
forth in this condition. or conducting follow-up monitoring using
EPA Method 21 within five (5) working days of the leak
detection. If the follow-up EPA Method 21 monitoring shows
that the emission is a leak as defined in this condition, the leak
must be repaired and remonitored in accordance with the leak
repair and remonitoring provisions contained herein.
c. Leak Repairs and Remonitoring
i. First attempt to repair a leak must be made no later than five
(5) working days after discovery, unless parts are unavailable,
the equipment requires shutdown to complete repair, or other
good cause exists. If parts are unavailable, they must be
ordered promptly and the repair must be made within fifteen
(15) working days of receipt of the parts. If shutdown is
required, the leak must be repaired during the next scheduled
shutdown. If delay is attributable to other good cause, repairs
AIRS ID: 123-9BEE Page 14 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
must be completed within fifteen (15) working days after the
cause of delay ceases to exist.
ii. Within fifteen (15) working days of completion of a repair, the
leak must be re-monitored to verify the repair was effective.
d. Record keeping: The owner or operator must maintain the following records for a
period of two (2) years and make them available to the Division upon request.
i. Documentation of the initial approved instrument monitoring
method inspection for new well production facilities;
ii. The date and site information for each inspection;
iii. A list of the leaking components and the monitoring method(s)
used to determine the presence of the leak;
iv. The date of first attempt to repair the leak and, if necessary,
any additional attempt to repair the leak;
v. The date the leak was repaired;
vi. The delayed repair list, including the basis for placing leaks on
the list;
vii. The date the leak was remonitored to verify the effectiveness
of the repair, and the results of the remonitoring; and
viii.A list of components that are designated as unsafe, difficult, or
inaccessible to monitor and explanation stating why the
component is so designated, and the plan for monitoring such
component(s).
29. Point 039: This equipment is subject to the control requirements for glycol natural gas
dehydrators under Regulation No. 7, Section XII.H. Beginning May 1, 2005, uncontrolled
actual emissions of volatile organic compounds from the still vent and vent from any gas-
condensate-glycol (GCG) separator (flash separator or flash tank), if present, shall be
reduced by at least 90 percent through the use of air pollution control equipment.
This source shall comply with all applicable general provisions of Regulation 7, Section
XII.
30. Point 039: This equipment is subject to the control requirements for glycol natural gas
dehydrators under Regulation No. 7, Section XVII.D. (State only enforceable). These
requirements include, but are not limited to:
XVII.D.3. Beginning May 1, 2015, still vents and vents from any flash separator or flash
tank on a glycol natural gas dehydrator located at an oil and gas exploration and
production operation, natural gas compressor station, or gas-processing plant
subject to control requirements pursuant to Section XVII.D.4., shall reduce
uncontrolled actual emissions of hydrocarbons by at least 95 percent on a rolling
twelve-month basis through the use of a condenser or air pollution control
equipment. If a combustion device is used, it shall have a design destruction
efficiency of at least 98% for hydrocarbons.
XVII.D.4. The control requirement in Section XVII.D.3. shall apply where:
AIRS ID: 123-9BEE Page 15 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
XVII.D.4.a. Uncontrolled actual emissions of VOCs from a glycol natural gas dehydrator
constructed on or after May 1, 2015, are equal to or greater than two (2) tons per
year. Such glycol natural gas dehydrators must be in compliance with Section
XVII.D.3. by the date that the glycol natural gas dehydrator commences operation.
31. Point 039: This source is subject to the requirements of 40 CFR, Part 63, Subpart HH -
National Emission Standards for Hazardous Air Pollutants for Source Categories from
Oil and Natural Gas Production Facilities including, but not limited to, the following:
• §63.764 - General Standards
o §63.764 (e)(1) -The owner or operator is exempt from the requirements of
paragraph (d) of this section if the criteria listed in paragraph (e)(1)(i) or (ii) of
this section are met, except that the records of the determination of these
criteria must be maintained as required in §63.774(d)(1).
■ §63.764 (e)(1)(ii) — The actual average emissions of benzene from
the glycol dehydration unit process vent to the atmosphere are less
than 0.90 megagram per year, as determined by the procedures
specified in §63.772(b)(2) of this subpart.
• §63.772 - Test Methods, Compliance Procedures and Compliance
Demonstration
o §63.772(b) - Determination of glycol dehydration unit flowrate or benzene
emissions. The procedures of this paragraph shall be used by an owner or
operator to determine glycol dehydration unit natural gas flowrate or benzene
emissions to meet the criteria for an exemption from control requirements
under§63.764(e)(1).
• §63.772(b)(2) - The determination of actual average benzene
emissions from a glycol dehydration unit shall be made using the
procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this section.
Emissions shall be determined either uncontrolled, or with federally
enforceable controls in place.
• §63.772(b)(2)(i) — The owner or operator shall determine actual
average benzene emissions using the model GRI-GLYCaIc TM
Version 3.0 or higher, and the procedures presented in the associated
GRI-GLYCaIc TM Technical Reference Manual. Inputs to the model
shall be representative of actual operating conditions of the glycol
dehydration unit and may be determined using the procedures
documented in the Gas Research Institute (GRI) report entitled
"Atmospheric Rich/Lean Method for Determining Glycol Dehydrator
Emissions" (GRI-95/0368.1); or
• §63.772(b)(2)(ii) - The owner or operator shall determine an average
mass rate of benzene emissions in kilograms per hour through direct
measurement using the methods in §63.772(a)(1)(i) or (ii), or an
alternative method according to §63.7(f). Annual emissions in
kilograms per year shall be determined by multiplying the mass rate
by the number of hours the unit is operated per year. This result shall
be converted to megagrams per year.
• §63.774 - Recordkeeping Requirements
AIRS ID: 123-9BEE Page 16 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
o §63.774 (d)(1) -An owner or operator of a glycol dehydration unit that meets
the exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1)(ii) shall maintain
the records specified in paragraph (d)(1)(i) or paragraph (d)(1)(ii) of this
section, as appropriate, for that glycol dehydration unit.
■ §63.774 (d)(1)(ii) - The actual average benzene emissions (in terms
of benzene'emissions per year) as determined in accordance with
§63.772(b)(2).
OPERATING & MAINTENANCE REQUIREMENTS
32. Upon issuance of this permit, 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 your O&M plan are subject to Division approval prior to
implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.)
33. Point 035: The owner or operator of a loadout at which vapor balancing is used to
control emissions shall:
a. Install and operate the vapor collection and return equipment to collect vapors
during loading of tank compartments of outbound transport trucks and return
these vapors to the stationary source storage tanks.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in
use.
c. Install dry-break loading couplings to prevent hydrocarbon liquid loss during
uncoupling from vehicles.
d. Use operating procedures to ensure that hydrocarbon liquid cannot be
transferred unless the vapor collection equipment is in use.
e. Operate all recovery and disposal equipment at a back pressure less than the
pressure relief valve setting of transport vehicles.
f. Inspect thief hatch seals annually for integrity and replace as necessary. Thief
hatch covers shall be weighted and properly seated.
g. Inspect pressure relief devices (PRD) annually for proper operation and replace
as necessary. PRDs shall be set to release at a pressure that will ensure
flashing, working and breathing losses are routed to the control device under
normal operating conditions.
h. Document annual inspections of thief hatch seals and PRD with an indication of
status, a description of any problems found, and their resolution.
34. Point 039: The condenser outlet temperature shall be recorded as per the frequency
required in the approved O&M Plan. This information shall be maintained in a log on site
and made available to the Division for inspection upon request. The condenser outlet
temperature shall not exceed 160 °F on a monthly average basis
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
35. Points 014, 015, 017, 035 and 039: The owner or operator shall demonstrate
compliance with opacity standards, using EPA Method 22 to determine the presence or
AIRS ID: 123-9BEE Page 17 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
absence of visible emissions. "Visible Emissions" means observations of smoke for any
period or periods of duration greater than or equal to one (1) minute in any fifteen (15)
minute period during normal operation. (Reference: Regulation No. 7, Section XVII.A.16)
Periodic Testing Requirements
36. Points 002-004, 007-013: These engines are subject to the periodic testing
requirements as specified in the operating and maintenance (O&M) plan as approved by
the Division. Revisions to your O&M plan are subject to Division approval.
Replacements of these units completed as Alternative Operating Scenarios may be
subject to additional testing requirements as specified in Attachment A.
37. Point 039: The owner or operator shall complete an extended wet gas analysis prior to
the inlet of the TEG dehydrator on an annual basis. Results of the extended wet gas
analysis shall be used to calculate emissions of criteria pollutants and hazardous air
pollutants per this permit and be provided to the Division upon request.
ADDITIONAL REQUIREMENTS
38. All previous versions of this permit are cancelled upon issuance of this permit.
39. 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 (NOX) in
ozone nonattainment areas emitting less than 100 tons of VOC or NO. per
year, a change in annual actual emissions of one (1) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
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.
f. Points 002-004, 007-013: Within 14 calendar days of commencing operation of a
permanent replacement engine under the alternative operating scenario outlined
in this permit as Attachment A. The APEN shall include the specific
AIRS ID: 123-9BEE Page 18 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
manufacturer, model and serial number and horsepower of the permanent
replacement engine, the appropriate APEN filing fee and a cover letter explaining
that the owner or operator is exercising an alternative-operating scenario and is
installing a permanent replacement engine.
40. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
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).
41. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil
and Natural Gas Production Facilities major stationary source requirements shall apply
to this stationary source at any such time that this stationary source becomes major
solely by virtue of a relaxation in any permit limitation and shall be subject to all
appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part
E)
42. MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines requirements shall apply to this
source at any such time that this source becomes major solely by virtue of a relaxation in
any permit limitation and shall be subject to all appropriate applicable requirements of
that Subpart on the date as stated in the rule as published in the Federal Register.
(Reference: Regulation No. 8, Part E)
GENERAL TERMS AND CONDITIONS:
43. 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.
44. 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.
45. 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.
AIRS ID: 123-9BEE Page 19 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
46. 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.
47. 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.
48. 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.
49. 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:
Kirk Bear
Permit Engineer
Permit History
Issuance Date Description
Issuance 3 This Issuance Issued to Bonanza Creek Energy Operating
Company LLC. Modification triggered by well
production increase. Flow throughputs
upgraded. Added point 038. Consolidated point
032 and heater treaters into point 017.
Cancelled points 016 and 037. Added a new
dehy unit covered by Point 039.
Issuance 2 This Issuance Issued to Bonanza Creek Energy Operating
(Initial Approval Company LLC
Modification) Addition of points 014, 015, 016, 017, 032, 035,
and 037
Cancellation of points 005 and 006
AIRS ID: 123-9BEE Page 20 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
Issued to Bonanza Creek Energy Operating
Company LLC
This permit issuance includes addition of twelve
(12) RICE: two (2) lean burn gas lift engines,
three (3) rich burn generator engines, and seven
Issuance 1 March 11, 2014 (7) rich burn VRU compressor engines. At the
(Initial Approval) time of permit application DOM and S/N were
not available for any engine; make and model
were not available for VRU compressor engines.
Permit application was submitted concurrently
with application for collocated 8.0 MMscf/day
TEG Dehy (AIRS Point 001).
AIRS ID: 123-9BEE Page 21 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
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 (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 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: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&oagename=CBONWrapper
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.
Uncontrolle Are the Controlled
AIRS Pollutant CAS# d Emission emissions Emission Rate
Point Rate reportable? (lb/yr)
(Ib/yr)
Formaldehyde 5000 8718 Yes 4359
Acetaldehyde 75070 736 Yes 736
Acrolein 107028 453 Yes 453
002 Methanol 67561 220 No 220
n-Hexane 110543 98 No 98
Benzene 71432 39 No 39
Toluene 108883 36 No 36
Formaldehyde 5000 8718 Yes 4359
Acetaldehyde 75070 736 Yes 736
Acrolein 107028 453 Yes 453
003 Methanol 67561 220 No 220
n-Hexane 110543 98 No 98
Benzene 71432 39 No 39
Toluene 108883 36 No 36
Formaldehyde 5000 1220 Yes 1220
004 Methanol 67561 55 No 55
Acetaldehyde 75070 50 No 50
AIRS ID: 123-9BEE Page 22 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
Acrolein 107028 47 No 47
Benzene 71432 28 No 28
1,3-Butadiene 106990 12 No 12
Toluene 108883 10 No 10
Formaldehyde 50000 166 No 166
Methanol 67561 25 No 25
Acetaldehyde 75070 23 No 23
007 Acrolein 107028 21 No 21
Benzene 71432 13 No 13
1,3-Butadiene 106990 5 No 5
Toluene 108883 5 No 5
Formaldehyde 50000 166 No 166
Methanol 67561 25 No 25
Acetaldehyde 75070 23 No 23
008 Acrolein 107028 21 No 21
Benzene 71432 13 No 13
1,3-Butadiene 106990 5 No 5
Toluene 108883 5 No 5
Formaldehyde 50000 166 No 166
Methanol 67561 25 No 25
Acetaldehyde 75070 23 No 23
009 Acrolein 107028 21 No 21
Benzene 71432 13 No 13
1,3-Butadiene 106990 5 No 5
Toluene 108883 5 No 5
Formaldehyde 50000 149 No 149
Methanol 67561 22 No 22
Acetaldehyde 75070 20 No 20
010 Acrolein 107028 19 No 19
Benzene 71432 11 No 11
1,3-Butadiene 106990 5 No 5
Toluene 108883 4 No 4
Formaldehyde 50000 149 No 149
011
Methanol 67561 22 No 22
AIRS ID: 123-9BEE Page 23 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
Acetaldehyde 75070 20 No 20
Acrolein 107028 19 No 19
Benzene 71432 11 No 11
1,3-Butadiene 106990 5 No 5
Formaldehyde 50000 149 No 149
Methanol 67561 22 No 22
Acetaldehyde 75070 20 No 20
012 Acrolein 107028 19 No 19
Benzene 71432 11 No 11
1,3-Butadiene 106990 5 No 5
Toluene 108883 4 No 4
Formaldehyde 50000 149 No 149
Methanol 67561 22 No 22
Acetaldehyde 75070 20 No 20
013 Acrolein 107028 19 No 19
Benzene 71432 11 No 11
1,3-Butadiene 106990 5 No 5
Toluene 108883 4 No 4
Benzene 71432 8500 Yes 425
n-Hexane 110543 59520 Yes 2976
Toluene 108883 7940 Yes 397
014
Ethylbenzene 100414 820 Yes 41
Xylenes 1330207 2860 Yes 143
2,2,4-TMP 540841 817 2660 133
Benzene 71432 130 No 7
n-Hexane 110543 206 No 10
015 Toluene 108883 126 No 6
Ethylbenzene 100414 9 No 0
Xylenes 1330207 38 No 2
Benzene 71432 8390 Yes 420
n-Hexane 110543 58536 Yes 2927
017 Toluene 108883 7700 Yes 385
Ethylbenzene 100414 780 Yes 39
Xylenes 1330207 2732 Yes 137
AIRS ID: 123-9BEE Page 24 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
2,2,4-TMP 540841 2344 Yes 118
Benzene 71432 1364 Yes 85
n-Hexane 110543 15481 Yes 965
Toluene 108883 1075 Yes 67
035
Xylenes 1330207 429 Yes 27
Ethylbenzene 100414 93 No 6
2,2,4-TMP 540841 587 Yes 37
Benzene 71432 96 No 96
038
n-Hexane 110543 684 Yes 684
Benzene 71432 16,248 Yes 712
Toluene 108883 16,100 Yes 665
039 Ethylbenzene 100414 1,826 Yes 67
Xylenes 1330207 9,606 Yes 338
n-Hexane 110543 5,033 Yes 81
5) The emission levels contained in this permit are based on the following emission factors:
Points 002 and 003:
Emission Factors- Emission Factors—
Uncontrolled Controlled
CAS Pollutant Ib/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr
NOx 0.1511 0.5000 0.1511 0.5000
CO 0.9400 3.1100 0.3023 1.0000
VOC 0.4201 1.3900 0.0574 0.1900
5000 Formaldehyde 0.1088 0.3600 0.0544 0.1800
75070 Acetaldehyde 0.0084 0.0277 0.0084 0.0277
107028 Acrolein 0.0051 0.0170 0.0051 0.0170
67561 Methanol 0.0025 0.0083 0.0025 0.0083
110543 n-Hexane 0.0011 0.0037 0.0011 0.0037
71432 Benzene 0.0004 0.0015 0.0004 0.0015
108883 Toluene 0.0004 0.0013 0.0004 0.0013
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7294 Btu/hp-hr, and
a site-rated horsepower value of 1254. Emission factors for NOx, CO, VOC and formaldehyde
are calculated based on a lower heating value of 1292 Btu/scf. Emission factors for all HAPs
excluding formaldehyde are calculated based on a higher heating value of 1420 Btu/scf.
Emission Factor Sources:
CAS Pollutant Uncontrolled EF Source Controlled EF
Source
NOx Manufacturer Manufacturer
CO Manufacturer Vendor
VOC Manufacturer Vendor
5000 Formaldehyde Manufacturer Manufacturer
75070 Acetaldehyde AP-42; Table 3.2-2 (7/2000); Natural Gas No Control
107028 Acrolein AP-42; Table 3.2-2 (7/2000); Natural Gas No Control
67561 Methanol AP-42; Table 3.2-2 (7/2000); Natural Gas No Control
AIRS ID: 123-9BEE Page 25 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
CAS Pollutant Uncontrolled EF Source Controlled EF
Source
110543 n-Hexane AP-42; Table 3.2-2 (7/2000); Natural Gas No Control
71432 Benzene AP-42; Table 3.2-2 (7/2000); Natural Gas No Control
108883 Toluene AP-42; Table 3.2-2 (7/2000); Natural Gas No Control
Point 004:
Emission Factors - Emission Factors—
Uncontrolled Controlled
CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr
NOx 4.9944 17.3100 0.2885 1.0000
CO 4.9944 17.3100 0.5771 2.0000
VOC 0.1241 0.4300 0.1241 0.4300
5000 Formaldehyde 0.0750 0.2600 0.0750 0.2600
67561 Methanol 0.0031 0.0106 0.0031 0.0106
75070 Acetaldehyde 0.0028 0.0097 0.0028 0.0097
107028 Acrolein 0.0026 0.0091 0.0026 0.0091
71432 Benzene 0.0016 0.0055 0.0016 0.0055
106990 1,3-Butadiene 0.0007 0.0023 0.0007 0.0023
108883 Toluene 0.0006 0.0019 0.0006 0.0019
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7641 Btu/hp-hr, and
a site-rated horsepower value of 243. Emission factors for NOx, CO, VOC and formaldehyde are
calculated based on a lower heating value of 1292 Btu/scf. Emission factors for all HAPs
excluding formaldehyde are calculated based on a higher heating value of 1420 Btu/scf.
Emission Factor Sources:
CAS Pollutant Uncontrolled EF Source Controlled EF
Source
NOx Manufacturer 40 CFR 60 Subpart
JJJJ
CO Manufacturer 40 CFR 60 Subpart
JJJJ
VOC Manufacturer Manufacturer
5000 Formaldehyde Manufacturer Manufacturer
67561 Methanol AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
75070 Acetaldehyde AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
107028 Acrolein AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
71432 Benzene AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
106990 1,3-Butadiene AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
108883 Toluene AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
Points 007-009:
Emission Factors- Emission Factors—
Uncontrolled Controlled
CAS Pollutant Ib/MMBtu g/bhp-hr Ib/MMBtu g/bhp-hr
NOx 3.6850 13.90 0.2651 1.00
CO 2.4125 9.10 0.5302 2.00
VOC 0.5461 2.06 0.1856 0.70
50000 Formaldehyde 0.0205 0.08 0.0205 0.08
67561 Methanol 0.0031 0.01 0.0031 0.01
75070 Acetaldehyde 0.0028 0.01 0.0028 0.01
107028 Acrolein 0.0026 0.01 0.0026 0.01
71432 Benzene 0.0016 0.01 0.0016 0.01
AIRS ID: 123-9BEE Page 26 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
Emission Factors - Emission Factors-
Uncontrolled Controlled
CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr
106990 1,3-Butadiene 0.0007 0.00 0.0007 0.00
108883 Toluene 0.0006 0.00 0.0006 0.00
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8316 Btu/hp-hr, a
site-rated horsepower value of 111, and a fuel heat value of 1264 Btu/scf.
Emission Factor Sources:
CAS Pollutant Uncontrolled EF Source Controlled EF Source
NOx Manufacturer Manufacturer
CO Manufacturer Manufacturer
VOC Manufacturer Manufacturer
50000 Formaldehyde AP-42; Table 3.2-3 (7/2000); AP-42; Table 3.2-3 (7/2000);
Natural Gas Natural Gas
67561 Methanol AP-42; Table 3.2-3 (7/2000); No Control
Natural Gas
75070 Acetaldehyde AP-42; Table 3.2-3 (7/2000); No Control
Natural Gas
107028 Acrolein AP-42; Table 3.2-3 (7/2000); No Control
Natural Gas
71432 Benzene AP-42; Table 3.2-3 (7/2000); No Control
Natural Gas
106990 1,3-Butadiene AP-42; Table 3.2-3 (7/2000); No Control
Natural Gas
108883 Toluene AP-42; Table 3.2-3 (7/2000); No Control
Natural Gas
Points 010-013:
Emission Factors- Emission Factors—
Uncontrolled Controlled
CAS Pollutant Ib/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr
NOx 3.4294 14.00 0.2450 1.00
CO 2.6945 11.00 0.4899 2.00
VOC 0.0980 0.40 0.0980 0.40
50000 Formaldehyde 0.0205 0.08 0.0205 0.08
67561 Methanol 0.0031 0.01 0.0031 0.01
75070 Acetaldehyde 0.0028 0.01 0.0028 0.01
107028 Acrolein 0.0026 0.01 0.0026 0.01
71432 Benzene 0.0016 0.01 0.0016 0.01
106990 1,3-Butadiene 0.0007 0.00 0.0007 0.00
108883 Toluene 0.0006 0.00 0.0006 0.00
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 9000 Btu/hp-hr, a
site-rated horsepower value of 92, and a fuel heat value of 1264 Btu/scf.
Emission Factor Sources:
CAS Pollutant Uncontrolled EF Source Controlled EF Source
NOx Manufacturer Manufacturer
CO Manufacturer Manufacturer
VOC Manufacturer Manufacturer
50000 Formaldehyde AP-42; Table 3.2-3 (7/2000); AP-42; Table 3.2-3 (7/2000);
Natural Gas Natural Gas
AIRS ID: 123-9BEE Page 27 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
CAS Pollutant Uncontrolled EF Source Controlled EF Source
67561 Methanol AP-42; Table 3.2-3 (7/2000); No Control
Natural Gas
75070 Acetaldehyde AP-42; Table 3.2-3 (7/2000); No Control
Natural Gas
107028 Acrolein AP-42; Table 3.2-3 (7/2000); No Control
Natural Gas
71432 Benzene AP-42; Table 3.2-3 (7/2000); No Control
Natural Gas
106990 1,3-Butadiene AP-42; Table 3.2-3 (7/2000); No Control
Natural Gas
108883 Toluene AP-42; Table 3.2-3 (7/2000); No Control
Natural Gas
Point 014:
Emission Factors
Pollutant Uncontrolled Source
lb/bbl Condensate
Throughput
VOC 0.42 ProMax
n-Hexane 0.029 ProMax
Benzene 0.004 ProMax
Toluene 0.004 ProMax
Ethylbenzene 0.000 ProMax
Xylenes 0.001 ProMax
2,2,4-TMP 0.001 ProMax
Note: The controlled emissions for this point are based on the flare control efficiency of 95%.
Point 015:
Emission Factors
Pollutant Uncontrolled Source
lb/bbl Produced
Water Throughput
VOC 0.006740 ProMax
n-Hexane 0.000199 ProMax
Benzene 0.000126 ProMax
Toluene 0.000122 ProMax
Ethylbenzene 0.000009 ProMax
Xylenes 0.000037 ProMax
2,2,4-TMP 0.000002 ProMax
Note: The controlled emissions for this point are based on the flare control efficiency of 95%.
Point 017:
Weight Emission Emission
Pollutant Fraction Factors Factors Source
of Gas Uncontrolled Controlled
(%) lb/MMscf lb/MMscf
NOx (lb/MMBTU) --- 0.068 0.068 AP-42
CO (Ib/MMBTU) --- 0.310 0.310 AP-42
VOC 68.7002 74635 3732 Promax
AIRS ID: 123-9BEE Page 28 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
Weight Emission Emission
Pollutant Fraction Factors Factors Source
of Gas Uncontrolled Controlled
(0/0) lb/MMscf lb/MMscf
Benzene 0.6000 599.9 30.0 Promax
Toluene 0.5068 550.6 27.5 Promax
Ethylbenzene 0.0513 55.8 2.79 Promax
Xylenes 0.1799 195.4 9.8 Promax
n-hexane 3.8531 4185.9 209.3 Promax
2,2,4-TMP 0.2000 167.6 8.4 Promax
Note: The controlled emissions for this point are based on the flare control efficiency of 95%
Point 035:
Emission Factors - Emission Factors -
Uncontrolled Controlled
Pollutant lb/bbl loaded Source lb/bbl loaded Source
VOC 0.1657 AP-42 0.008285 Eng. Calc.
Benzene 0.0007 AP-42 0.000035 Eng. Calc.
n-Hexane 0.0074 AP-42 0.000370 Eng. Calc.
Toluene 0.0005 AP-42 0.000025 Eng. Calc.
Xylenes 0.0002 AP-42 0.000010 Eng. Calc.
2,2,4-TMP 0.0003 AP-42 0.000015 Eng. Calc.
The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
L = 12.46*S*P*M/T
S = 1.0 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 4.27 psia
M (vapor molecular weight) = 46.31 Ib/Ib-mol
T (temperature of liquid loaded) = 524°R
The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor.
Point 038:
Emission Factors
Pollutant Uncontrolled Source
lb/bbl Condensate
Throughput
VOC 4.13 ProMax
n-Hexane 0.342 ProMax
Benzene 0.048 ProMax
Toluene 0.039 ProMax
Ethylbenzene 0.004 ProMax
Xylenes 0.013 ProMax
2,2,4-TMP 0.013 ProMax
Note: The controlled emissions for this point are based on the flare control efficiency of 95%
AIRS ID: 123-9BEE Page 29 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
Point 039:
The emission levels contained in this permit are based on information provided in the application and
the GRI GlyCalc 4.0 model.
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) Points 002-004, 009-013: These engines may be subject to 40 CFR, Part 60, Subpart JJJJ—
Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See
January 18, 2008 Federal Register posting — effective March 18, 2008). This rule has not yet been
incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the
complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ja08.pdf
8) Points 002-004, 007-013: These engines are subject to 40 CFR, Part 63, Subpart ZZZZ - National
Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion
Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January
18, 2008 amendments to include requirements for area sources and engines < 500 hp located at
major sources have not yet been incorporated into Colorado Air Quality Control Commission's
Regulation No. 8. A copy of the complete subpart is available on the EPA website at:
http://www.epa.gov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards
can be found on the EPA website at: http://www.epa.gov/ttn/atw/area/arearules.html
9) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: NOx, CO, VOC, Individual HAP (HCHO,
Benzene, Toluene, Xylenes, and n-Hexane), Total HAPs
PSD True Minor Source
NANSR Synthetic Minor Source of: NOx and VOC
MACT HH Area Source Requirements:Applicable
MACT ZZZZ Area Source Requirements:Applicable
10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecf r.gpoaccess.qov/
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
AIRS ID: 123-9BEE Page 30 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
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 XXXXX(
11) A self certification form and guidance on how to self-certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123-9BEE Page 31 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
October 12, 2012
2.Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of
natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the
requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating
Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary
Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all
applicable substantive and procedural requirements. This permit incorporates and shall be considered a
Construction Permit for any engine replacement performed in accordance with this AOS, and the owner
or operator shall be allowed to perform such engine replacement without applying for a revision to this
permit or obtaining a new Construction Permit.
2.1 Engine Replacement
The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown
or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a
temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90
operating days or less in any 12 month period. "Permanent" is defined as in the same service for more
than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is
in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90
day total. The compliance demonstrations and any periodic monitoring required by this AOS are in
addition to any compliance demonstrations or periodic monitoring required by this permit.
All replacement engines are subject to all federally applicable and state-only requirements set forth in this
permit(including monitoring and record keeping).
The results of all tests and the associated calculations required by this AOS shall be submitted to the
Division within 30 calendar days of the test or within 60 days of the test if such testing is required to
demonstrate compliance with NSPS or MACT requirements.
Results of all tests shall be kept on site for five (5)years and made available to the Division upon request.
The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date
of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and
serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer,
model number, horsepower, and serial number of the replacement engine. In addition to the log, the
owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make
them available to the Division upon request.
2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to
the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and
horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying
this permit, so long as the temporary replacement engine complies with all permit limitations and other
requirements applicable to the existing engine. Measurement of emissions from the temporary
replacement engine shall be made as set forth in section 2.2.
AIRS ID: 123-9BEE Page 32 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
2.1.2 The owner or operator may permanently replace the existing compressor engine with another
engine with the same manufacturer, model, and horsepower engines without modifying this permit so
long as the permanent replacement engine complies with all permit limitations and other requirements
applicable to the existing engine as well as any new applicable requirements for the replacement engine.
Measurement of emissions from the permanent replacement engine and compliance with the applicable
emission limitations shall be made as set forth in section 2.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial
number and horsepower of the permanent replacement engine shall be filed with the Division for the
permanent replacement engine within 14 calendar days of commencing operation of the replacement
engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that
the owner or operator is exercising an alternative operating scenario and is installing a permanent
replacement engine, and a copy of the relevant Applicability Reports for the replacement engine.
Example Applicability
Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be
accompanied by a certification from the Responsible Official indicating that"based on the information and
belief formed after reasonable inquiry, the statements and information included in the submittal are true,
accurate and complete".
This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine
or an engine that is not subject to emission limits.
The owner or operator shall agree to pay fees based on the normal permit processing rate for review of
information submitted to the Division in regard to any permanent engine replacement.
2.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping
Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss
streamlining the testing requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements
specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer
testing, this test conducted under the AOS will serve as the quarterly test and an additional portable
analyzer test is not required for another three months).
The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required
by this Condition, if approved in advance by the Division.
The owner or operator shall measure nitrogen oxide (NOx) and carbon monoxide (CO) emissions in the
exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of
commencing operation of the replacement engine.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable
Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at:
http://www.colorado.gov/cs/Satellite/CDPH E-AP/CBON/1251596520270.
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the
tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or
year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation
the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever
applies.
AIRS ID: 123-9BEE Page 33 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
For comparison with a short-term limit that is either input based (lb/MMBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement
engine will be subject to, the results of the test shall be converted to the appropriate units as described in
the above-mentioned Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOx and CO emission limitations, in the
absence of credible evidence to the contrary, the source may certify that the engine is in compliance with
both the NOx and CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOx or CO emission
limitations, the engine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOx and CO emission limitations or
until the engine is taken offline.
2.3 Applicable Regulations for Permanent Engine Replacements
2.3.1 Reasonably Available Control Technology(RACT): Reg. 3, Part B§ II.D.2
All permanent replacement engines that are located in an area that is classified as
attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT)
for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and
NOx are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which
the area is in attainment/maintenance or nonattainment, except as follows:
In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of
emissions and to NOx and SO2, as precursors to PM10, if the potential to emit of NOx or SO2 exceeds 40
tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating
internal combustion engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NON: The emission limitations in NSPS JJJJ
SO2: Use of natural gas as fuel
PM10: Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains
20.0 grains or less of total sulfur per 100 standard cubic feet.
2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State-
Only conditions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is
subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified
below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-
selective catalyst and air fuel controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation
catalyst to reduce emissions.
AIRS ID: 123-9BEE Page 34 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
The above emission control equipment shall be appropriately sized for the engine and shall be operated
and maintained according to manufacturer specifications.
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
Emission Standards: Section XVII.E-State-only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state,
after the date listed in the table below shall operate and maintain each engine according to the
manufacturer's written instructions or procedures to the extent practicable and consistent with
technological limitations and good engineering and maintenance practices over the entire life of the
engine so that it achieves the emission standards required in the table below:
Construction or Emission Standards in G/hp-hr
Max Engine HP Relocation Date
NOx CO VOC
January 1, 2008 2.0 4.0 1.0
100<Hp<500 January 1, 2011 1.0 2.0 0.7
July 1, 2007 2.0 4.0 1.0
500≤Hp July 1, 2010 1.0 2.0 0.7
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ
A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater
than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp
except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for
lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements
of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting
requirements for the permanent engine replacement shall be included in the Applicability Reports
required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this
AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this
AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted
within the time frame specified in Condition 2.2.
Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from
outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to
the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes
equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ
requirements).
However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does,
any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ,
there will be an additional step added to the determination of the NSPS. Under the provisions of
Regulation No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the
State of Colorado into the State of Colorado is considered to be a new source, subject to the
requirements of NSPS JJJJ.
2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ
A permanent replacement engine located at either an area or major source is subject to the requirements
in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting
AIRS ID: 123-9BEE Page 35 of 36
Colorado Department of Public Health and Environment
Air Pollution Control Division
requirements for the permanent engine replacement shall be included in the Applicability Reports
required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this
AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under
Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time
frame specified in Condition 2.2.
2.4 Additional Sources
The replacement of an existing engine with a new engine is viewed by the Division as the installation of a
new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an
advanced construction permit review. The AOS cannot be used for additional new emission points for any
site; an engine that is being installed as an entirely new emission point and not as part of an AOS-
approved replacement of an existing onsite engine has to go through the appropriate
Construction/Operating permitting process prior to installation.
AIRS ID: 123-9BEE Page 36 of 36
Section 01-Adminstrative Information
'Facility AIRs 10: 123 98EE 039 _.
County Plant Point
Section 02-Equipment Description Details
One(3)Tdedsylens Sheol(FEG).mdursi gas dekydration Unit(Make,model.Serial Number:TBD)
with a design capacity of 12.01411411a per day-This emitsimsierit tsequitfpedwithtwo f2)Klmray
Model 2101,5gas•gycol pump with a deafen capasity of 0.5 gadions perMinute Onlyonapumpwll
operate eta time;theotherpumpwglsorve as is backup.This ur110 lsequipped witisa retksiler,still
Detailed Emissions unit yentaadfleshtank.Emissionsfnsmghe still wmtareroutedto a condenser andthenta enclosed
flare.Emissions*.the flash tank amrecyeled tethefeal gas systesafar the site.
Description:
Emission Control Device 5 11 Vent Condenser and EncloaodF1are flashier*:Recycled foRne'gas system
Description( I
Requested Overall VOC&HAP Control
Efficiency%: 0...
Section 93-Processing Rate Information for Emissions Estimates
Primary Emissions-Deily
Actual Gas Throughput= `MMscf per year Actual Gas Throughput While Emissions Controls Operating=
Requested Permit Limit Throughput= 4,380.0 MMscf per year
Potential to Emit(PTE)Throughput= 4,380.:MMscf per year
Secondary Emissions-Combustion Device(s)for Air Pollution Control
Heat content of waste gas= 1602.Btu/scf
Volume of waste gas emitted= scf/bbl
Actual heat content of waste gas routed to combustion device= 0 MMBTU per year
Request heat content of waste gas routed to combustion device= 0 MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device- 0 MMBTU per year
Section 04-Emissions Factors&Methedoloeies
Reboller Bumer
Heater Design Rate 0.5 MMBtu/hr per heater EXEMPT PER REG 3,PART A,II.D.1.K
Fuel Heating Value 1000 Btu/scf
No.of Heaters 1
Hours of Operator 8760 hr/yr
Fuel Consumption 4.4 MMscf/yr per heater
0.4 MMscf/month per heater
4 4 MMscf/yr for all heaters
0.4 MMscf/month for all heaters
Estimated emissions based on rating of heaters
Emission Factor Emissions __
Pollutant Ib/MMscf Source lb/yr tpy
NOx 100 AP-42 438.0 0.219
CO 84 AP-42 367.9 0.184
VOC 5.5 AP-42 24.1 0.012
PM Total 7.6 AP-42 33.3 0.017
SO2 0.6 AP-42 2.6 0.001
Formaldehyde 0.075 AP-42 0.33 0.000
Benzene 0.0021 AP-42 0.01 0.000
Toluene 0.0034 AP-42 0.01 0.000
n-Hexane 1.8 AP-42 7.88 0.004
Total HAP 0.004
Dehydrator
The source used GRI Glycalc 4.0 to estimate emissions.Wet gas composition,pressure and temperature are based on a weighted
average of 6 site-specific extended wet gas analyses collected 5/16/2014.The model was based on the following parameters:
Inlet Gas Pressure 800 prig
Inlet Gas Temperature 80 deg F
Glycol Recirculate Rate 3.5 gpm
Glvcalc Results On tons per year)
12 MMsttl 372 MMscf/mon .4380 MMsct/yr 1095.0 MMst/quarter
STILL VENT
Uncontrolled Controlled Controlled Controlled
Pollutant Uncontrolled(lb/hr) (IbM) Uncontrolled(tpy) Rbmr) (Ib/yr) MN)
%Control EF(lb/MMscf)
VOC 11.7851 103,237 51.6 0.4775 4,183 2.1 96% 23.57
HAPs 4.9300 43,187 21.6 0.2126 1,862 0.9 96% 9.86
Benzene 1.7212 15,078 7.5 0.0813 712 0.4 95% 3.44
Toluene 1.7441 15,278 76 0.0759 665 0.3 96% 3.49
Ethylbenzene 0.2016 1,766 0.9 0.0076 67 0.0 96% 0.40
Xylenes 1.0714 9,385 4.7 0.0386 338 0.2 96% 2.14
n-Hexane 0.1915 1,678 0.8 0.0093 81 0.0 95% 0.38
224-TMP 0.0002 2 0.0 0.0001 1 0.0 50% 0.00
z660 TANK
Uncontrolled Controlled Controlled Controlled %Control EF(lb/MMscf)
Pollutant Uncontrolled(lb/hr) (IbM) Uncontrolled(tpy) IIbA1r) (Ibryr) (IOW
VOC 24.9698 218,735 109.4 0 0 0.0 100% 49.94
HAPs 0.6428 5,631 2.8 0.0000 0 0.0 100% 1.29
Behzene 0.1336 1,170 0.6 0.0000 0 0.0 100% 0.27
Toluene 0.0938 822 0.4 0 0 0.0 100% 0.19
Ethylbenzene 0.0068 60 0.0 0 0 0.0 100% 0.01
Xylenes 0.0252 221 0.1 0 0 0.0 100% 0.05
n-Hexane 0.383 3,355 1.7 0 0 0.0 100% 0.77
224-TMP 0.0005 4 0.0 0 0 0.0 100% 0.00
1 013 K:\PA\2013\13WE2994.CP3 Point 039.xlsm
•
123 98EE
(Facility AIRS ID: 039.
County Plant Point
TOTAL DEHY EMISSIONS-STILL VENT PLUS FLASH TANK
Uncontrolled Controlled Controlled plus Buffer
Pollutant (lb/hr) (Ib/yr) (tpy) (lb/hr) (lb/yr) (tpy) (lb/hr) (Ib/yr) (tpy) %Control)lb/MMsci) lb/31 day
VOC 36.7549 321972.9 161.0 0.4775 4182.9 2.1 0.5 4182.9 2.1 99% 73.51 355
HAPs 5.5728 48817.7 24.4 0.2126 1862.4 0.9 0.2 1862.4 0.9 96% 158
Benzene 1.8548 16,248 8.1 0.0813 712.2 0.4 0.1 712 0.4 96% 3.710 60
Toluene 1.8379 16,100 8.1 0.0759 664.9 0.3 0.1 665 0.3 96% 3.676 56
Ethylbenzene 0.2084 1,826 0.9 0.0076 66.6 0.0 0.0 67 0.0 96% 0.417 6
Xylenes 1.0966 9,606 4.8 0.0386 338.1 0.2 0.0 338 0.2 96% 2.193 29
n-Hexane 0.5745 5,033 2.5 0.0093 81.5 0.0 0.0 81 0.0 98% 1.149 7
. 2,2,4-trimethylpentane 0.0007 6 0.0 0.0001 0.9 0.0 0.0 1 0.0 86% 0.001 0
Controlled emissions are based on 100%recycle of flash tank and still vent emissions controlled with a condenser and combustor.
Dehy Control Device
Uncontrolled E.F.
Pollutant Jibs/MMBtu Uncontrolled Emissions Factor Source Citation
Uncontrolled E.F. Controlled E.F. waste heat E.F.
(Ibs/MMscf) (Ibs/MMscf) combusted) (Ibs/MMscf)
IrsZEINIM \\\\\, \\\\\\\\�\\ I 0.0000
: �� ���' 0.0000
\\\\\\\O\\\\\\\\\\\\\\\\\\\\\\\\
®���, ,
\\\\\\\\\\\\\\\\\\\\\\\\\\\\Vl .
01 0.00 -- ;IMEITEMMEMMMELEIMEIMIIIM ..
,01
MINIEZEI 0.0
Section 05-Emissions Inventory
Potential to Emit Requested Permit Limits Actual Emissions
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year)
PM10 0.0 0.0 0.0 0.0 0.0
PM2.5 0.0 0.0 0.0 0.0 0.0,
NOx 0.0 0.1 0.1 0.0
VOC 161.0 161.0 2.1 0.0 0.0
CO 0.0 0.3 0.3 0.0 0.0
Potential to Emit Requested Permit Limits Actual Emissions
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) lb/yr
Benzene 8.1E+00 8.1E+00 3.6E-00 0.0E+00 0.0E+00 16248 712
Toluene 8.1E+00 8.1E+00 3.3E-01 0.0E+00 0.0E+00 16100 665
Ethylbenzene 9.1E-01 9.1E-01 3.3E-02 0.0E+00 0.0E+00 1826 67
Xylene 4.8E+00 4.8E+00 1.7E-01 0.0E+00 0.0E+00 9606 338
n-Hexane 2.5E+00 2.5E+00 4.1E-02 0.0E+00 0.0E+00 5033 81
224 TMP 3.1E-03 3.1E-03 4.4E-04 0.0E+00 0.0E+00 6 1 '
Section 06-Regulatory Summary Analysis
Reeulaton 3
Part A APEN Requirements
APEN is required since actual uncontrolled VOC emissions are greater than 1 tpy.
Part B-Construction Permit Requirements
Permit is required since facility-wide actual uncontrolled VOC emissions from all APEN-required points are greater than 2 tpy.
Reoulation 7—Volatile Organic Compounds
XII.H VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
This source is ubject to this section since it is located in the ozone nonattainment area.
XVII.D STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS
Per Reg 7,Section X911.0.5,dehydrators subject to an emission control requirement under 40 CFR Part 63 are exempt from Section XVII.However,as discussed below in MAC?HH,this dehy is not
subject to a control standard under MACE because it is meeting an emission exemption.Thus,the dehy must still be evaluated under Regulation 7 XVII.D
This Achy is subject to XVII.D.1 because per XVII.D.2.1 and b,actual uncontrolled VOC emissions are greater than 15 tpy.
This dehy is subject to 0011.0.3 because per XVII.0.4.a the dehydrator will be constructed after 5/1/2015 and uncontrolled actual emissions of VOC will be greater than 2 tpy.
Regulation 8-Control of HAPs
Part E-MACT HH
Since this facility is an oil and gas E&P facility,it qualifies as a production field facility as defined in MACT HH.As a production field facility,only dehys and storage vessels with flash are included when
determining major source status.HAP emissions from the existing 12 MMSCF per day TEG dehy are 0.9 tpy,HAP emissions from the condensate tank are 0.5 tpy.Total HAP emissions from the dehy
and storage vessels are 2.3 tpy.Thus,the site is a synthetic minor source of HAPs and is then an area source of HAPs per MACT HH.As specified in 63.760(b)(2),the only affected sources for area
sources are TEG dehydrators.The controlled emissions from this TEG dehy are less than 1,984 lb/yr so it will meet the benzene exemption in 63.764(e)(1)(ii).
Section 07-Initial and Periodic Sampling and Testing Requirements
Does the company use a site specific extended gas analysis to estimate emissions?
If no,the permit will contain an"Initial Compliance"testing requirement to demonstrate compliance with emission limits
M r
i4,
Does the company request a control device efficiency greater than 95%for a flare or combustion device? *fie Wilk
-
If yes,the permit will contain and intial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08-Technical Analysis Notes
2 of 3 K:\PA\2013\13W E2994.CP3 Point 039.xlsm
'Facility AIRS ID: 123 99EE: 039
County Plant Point
Section 09-Inventory SCC Coding and Emissions Factors
Uncontrolled
Emissions
AIRS Point a Process a SCC Code Pollutant Factor Control% Units
039 01 �" ���, 2,311 PM30 0.0 0 lb/MMscf
PM2.5 0.0 0 Ib/MMscf
NOx 0.031 0 Ib/MMscf
VOC 73.5 0 Ib/MMsd
CO 0.141 0 Ib/MMsd
Benzene 3.710 0 Ib/MMscf
Toluene 3.676 0 lb/MMscf
Ethylbenzene 0.417 0 Ib/MMscf
Xylene 2.193 0 Ib/MMscf
n-Hexane 1.149 0 Ib/MMscf
224 TMP 0.001 0 Ib/MMscf
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