The URL can be used to link to this page

Browse Search

Home My WebLink About20161567.tiff A CDPHE I C O L O A D O Co ✓ Department of Public • Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board RECEIVED 1150 O St PO Box 758 MAY 0 9 2016 Greeley, CO 80632 WELD May 3, 2016 COMMISSIONERS Dear Sir or Madam: On May 4, 2016, the Air Pollution Control Division will begin a 30-day public notice period for Kerr- McGee Oil and Gas Onshore LP - 36114755 Tank Battery. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govic 2016-1567 John W. Hickenlooper, Governor Larry Wolk,AD,MSPH, Execut11ivv�Director and Chief Medical 01 —.1376 ?1,(1)libtAnict) A CDPHE Air Pollution Control Division s Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Kerr-McGee Oil and Gas Onshore LP - 36114755 Tank Battery - 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: Kerr-McGee Oil and Gas Onshore LP Facility: 36114755 Tank Battery Oil Et Gas Exploration Et Production Facility SWSW of Section 34, Township 3N, Range 66W Weld County The proposed project or activity is as follows: Applicant is requesting permit coverage for one (1) vapor recovery tower (VRT) controlled by three (3) enclosed combustion devices (ECDs) during vapor recovery unit (VRU) downtime at a synthetic minor exploration and production facility. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 15WE1458 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Harrison Slaughter Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us COLORADO 1 I C = II STATE OF COLORADO oF'col) COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT Q W.% AIR POLLUTION CONTROL DIVISION14,' o TELEPHONE: (303)692-3150 * ` � " *i$76* CONSTRUCTION PERMIT PERMIT NO: 15WE1458 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee Oil and Gas Onshore LP THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility, known as the 36114755 Tank Battery, located in the SWSW of Section 34, Township 3N, Range 66W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID One (1) vapor recovery tower (VRT) that processes liquid from the second stage of separation to create a third stage of liquid/gas separation. Overhead flash gas from the VRT is routed to the vapor recovery units (VRUs) in a closed loop process. When the VRUs are unable to capture the entire overhead gas stream, flash VRT-01 011 gas is routed to three (3) enclosed combustion devices (ECDs). The ECDs have a minimum control efficiency of 95%. Emissions are a function of condensate throughput while overhead gas is routed to the ECDs. It is assumed that the flash gas is routed to the ECDs 10% of the time. This permit covers emissions when flash gas is routed to the ECDs. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.pov/pacific/cdphe/other-air- permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. AIRS ID: 123/2223 Page 1 of 8 Wellhead Version 2012-1 Iolo 4 De - ent f Public Health and Environment Air Pollution Control Division 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (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. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information for all permitted equipment except fugitive emissions from equipment leaks shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NOX VOC CO VRT-01 011 1.7 22.4 4.2 Point See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate 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. AIRS ID: 123/2223 Page 2 of 8 . tIlk olo `, De ., ent 3f Public Health and Environment Air Pollution Control Division 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. 8. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID VRT-01 011 Three (3) Enclosed Combustion Devices VOC and HAPs PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the throughput shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point Condensate throughput through VRT VRT-01 011 while emissions are routed to 23,360 BBL enclosed combustion devices The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator shall continuously monitor and record the amount of time that flash gas is routed from the VRTs to the ECDs. The owner or operator shall use monthly recorded ECD run time, monthly condensate throughput records and calculation methods detailed in the O&M plan to demonstrate compliance with the limits specified in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) AIRS ID: 123/2223 Page 3 of 8 olo , Dee ent f Public Health and Environment Air Pollution Control Division , , , ,, 12. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 14. Upon startup of this point, the applicant shall follow the operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 9, 40 C.F.R. Part 60, Appendix A, to measure opacity from the flare. This measurement shall consist of a minimum twenty-four consecutive readings taken at fifteen second intervals over a six minute period. (Regulation Number 1, Section II.A.1 and II.A.5) ADDITIONAL REQUIREMENTS 16. 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 (NOr) 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 AIRS ID: 123/2223 Page 4 of 8 olo : De= ent f Public Health and Environment Air Pollution Control Division d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 17. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 18. 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. 19. 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. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. 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. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. 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 AIRS ID: 123/2223 Page 5 of 8 olo De ent f Public Health and Environment Air Pollution Control Division SST\.d xF Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Kerr-McGee Oil and Gas Onshore LP Permit for one (1) vapor recovery tower at an existing synthetic minor exploration and production facility. AIRS ID: 123/2223 Page 6 of 8 olo De - ent f Public Health and EnvironmentAir Pollution Control Division Notes to Permit Holder: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/agcc-reps 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. - Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# (lb/yr) reportable? Rate(lb/yr) Benzene 71432 7,604 Yes 381 Toluene 108883 10,349 Yes 517 Ethylbenzene 100414 433 Yes 22 011 Xylenes 1330207 5,408 Yes 271 n-Hexane 110543 55,620 Yes 2,781 2,2,4- 540841 3,119 Yes 156 Trimethylpentane 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source (lb/bbl) (lb/bbl) NOx 1.41x10-1 1.41x10-1 2005-03-22 APCD Memo CO 3.59x10-' 3.59x10-' 2005-03-22 APCD Memo VOC 38.28 1.91 E&P Tanks 71432 Benzene 3.25x10-' 1.63x10-` E&P Tanks 108883 Toluene 4.43x10-' 2.21x10-2 E&P Tanks 100414 Ethylbenzene 1.85x10.2 9.25x10-4 E&P Tanks 1330207 Xylenes 2.31x1O' 1.16x10.2 E&P Tanks 110543 n-Hexane 2.38 1.19x10-' E&P Tanks 540841 2,2,4-TMP 1.33x10-' 6.67x10.3 E&P Tanks AIRS ID: 123/2223 Page 7 of 8 olo De ! fubIic Health and Environment Air Pollution Control Division Note: The controlled emissions factors for point 011 are based on the enclosed combustor control efficiency of 95%. These emission factors were developed using pressurized liquids analyses from the Rattler 3N-34HZ and Rattler 29C-34HZ wells both sampled October 28, 2015. The emission factors obtained from two separate E&P Tank simulations were averaged in order to determine the overall emission factor for each pollutant as represented above. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane, and total HAPs NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) 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: 123/2223 Page 8 of 8 Colorado Air Permitting Project Project Details Review Engineer: Harrison Slaughter Package#: 340544 Received Date: 11/10/2015 Review Start Date: 4/14/2016 Section 01-Facility Information Company Name: Kerr-McGee Oil and Gas Onshore LP. , County AIRS ID: 123 Plant AIRS ID: 2223 Facility Name: 36114755 Tank Battery(Rattler 3N-34HZ) Physical Address/Location: SWSW of Section 34,Township 3N,Range 66W Type of Facility: Exp t cjtr l rarfuctiorrWelltFad What industry segment? Oil&Natural Gas.Productton& ing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? ❑Carbon Monoxide(CO) ❑Particulate Matter(PM) ❑Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert AIRs Point# Emissions Source Type Permit# Issuance# Action Engineering Remarks Control? Required? Perms nitial. 011 Vapor Recovery Tower(VRT) . Yes 15WE1458 1 R „ ,,Cs t „,-;i VRT venting to ECD Section 03-Description of Project Kerr-McGee is requesting permit coverage for one(1)vapor recovery tower(VRT)at an existing"Generation 4"oil and gas exploration and production facility that is located in the ozone non-attainment area.Hydrocarbon liquid produced at this facilityflows from a high-low pressure separator to a VRT prior to storage in atmospheric tanks.During normal operation,gas vented from the VRT is routed to a vapor recovery unit(VRU) which compresses the gas and directs it to the sales gas gathering pipeling.During periods of VRU downtime,the gas vented from the VRT is routed to three(3)enclosed combustion devices(ECDs). It is assumed that gas vented from the VRT is routed to the enclosed combustion devices 10%of the time. Emissions while VRT gas is routed to the ECDs is a function of condensate throughput. This permit will cover emissions when the VRT gas is routed to the ECDs. Section 04-Public Comment Requirments Is Public Comment Required? yes; If yes,why?' Requesting Synth cMinorePermit„ Section 05-Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 1,0;44 If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? *41 If yes,explain what programs and which pollutants here: Title V Operating.Permits(OP):VOC,n-Hexane,and total HAPs' Non-Attainment New Source Review(NANSR):VOC Is this stationary source a major source? ltio If yes,explain what programs and which pollutants here: Facility is classified as synthetic minor as described above. Colorado Air Permitting Project One(1)vapor recovery tower(VRT)that processes liquid from the second stage of separation to create a third stage of liquid/gas separation. Overhead flash gas from the VRT is routed to the vapor recovery units 011 (VRUs)in a closed loop process. When the VRUs are unable to capture the entire overhead gas stream, flash gas is routed to three(3)enclosed combustion devices(ECDs).The ECDs each have a minimum control efficiency of 95%. Emissions are a function of condensate throughput while overhead gas is routed to the ECDs.It is assumed that the flash gas is routed to the ECDs 10%of the time.This permit covers emissions when flash gas is routed to the ECDs. Equipment Description This source vents natural gas from: one(1)vapor recovery tower Emissions from this source are: recompressed Natural gas venting from one 1 vapor recovery tower.Emissions from this source are recompressed. Calculations The site specific emission factors developed for this source were determined through the use of two pressurized liquid samples,two E&P Tanks simulations associated with the liquids samples,and the API gravity from the most recent truck loadout sales ticket. The pressurized liquid samples were obtained from two different wells at the facility. The wells from which the samples were taken include Rattler 3N-34HZ and Rattler 29C-34HZ. The API gravity obtained from the most recent truck loadout sales ticket was used to calculate the RVP of the hydrocarbon liquid using the following equation:RVP=(0.179*sales oil API gravity)-1.699(Equation 2-PS Memo 05-01). The API gravity used in the application is consistent with the average API gravity reported to COGCC over the 2015 calendar year for all the wells at this facility. Two separate E&P Tanks simulations were conducted using the two pressurized liquid samples and the calculated sales oil RVP. The results of the simulation were averaged to determine the site specific emission factors. The following tables contain the information from the E&P Tanks simulations used to determine the emission factors: E&P Tanks Simulation 1(Rattler 3N-34HZ) Throughput: 24 bbl/day 8760 bbl/year Uncontrolled Emission Pollutant Emission Rate Emission Rate Factor VOC 38.354 lb/hr 335981.04 lb/year 38.35 lb/bbl Benzene 0.33 lb/hr 2890.80 lb/year 0.33 lb/bbl Toluene 0.455 lb/hr 3985.80 lb/year 0.46 lb/bbl Ethylbenzene 0.02 lb/hr 175.20 lb/year 0.02 lb/bbl Xylenes 0.243 lb/hr 2128.68 lb/year 0.24 lb/bbl n-Hexane 2.441 lb/hr 21383.16 lb/year 2.44 lb/bbl 2,2,4-TMP 0.137 lb/hr 1200.12 lb/year 0.14 lb/bbl Note:The E&P Tanks simulation was run on a basis of 24 bbl/day(8760 bbl/year).As a result,the conversion from lb/hr to lb/bbl results in the same value. E&P Tanks Simulation 2(Rattler 29C-34HZ) Throughput: 24 bbl/day 8760 bbl/year Pollutant Emission Rate Emission Rate Uncontrolled Emission VOC 38.211 lb/hr 334728.36 lb/year 38.21 lb/bbl Benzene 0.321 lb/hr 2811.96_lb/year 0.32 lb/bbl Toluene 0.431 lb/hr 3775.56 lb/year 0.43 lb/bbl Ethylbenzene 0.017 lb/hr 148.92 lb/year 0.02 lb/bbl Xylenes 0.22 lb/hr 1927.20 lb/year 0.22 lb/bbl n-Hexane 2.321 lb/hr 20331.96 lb/year 2.32 lb/bbl 2,2,4-TMP 0.13 lb/hr 1138.80 lb/year 0.13 lb/bbl Note:The E&P Tanks simulation was run on a basis of 24 bbl/day(8760 bbl/year).As a result,the conversion from lb/hr to lb/bbl results in the same value. Average of Simulation 1 and 2 Throughput: 24 bbl/day 8760 bbl/year Pollutant Emission Rate Emission Rate Uncontrolled Emission VOC 38.2825 lb/hr 335354.70 lb/year 38.283 lb/bbl Benzene 0.3255 lb/hr 2851.38 lb/year 0.326 lb/bbl Toluene 0.443 lb/hr 3880.68 lb/year 0.443 lb/bbl Ethylbenzene 0.0185 lb/hr 162.06 lb/year 0.019 lb/bbl Xylenes 0.2315 lb/hr 2027.94lb/year 0.232 lb/bbl n-Hexane 2.381 lb/hr 20857.56 lb/year 2.381 lb/bbl 2,2,4-TMP 0.1335 lb/hr 1169.46 lb/year 0.134 lb/bbl Note:The overall emission rates(lb/hr)were determined using a simple average of the emission rates(lb/hr)for each pollutant obtained from the Rattler 3N-34HZ and Rattler 29C-34HZ simulations. Requested Throughput: 'Total throughput to VRT: 233,600 bbl/year 15WE1458.CP1.xlsm E1458.CP1.xlsm One(1)vapor recovery tower(VRT)that processes liquid from the second stage of separation to create a third stage of liquid/gas separation. Overhead flash gas from the VRT is routed to the vapor recovery units 011 (VRUs)in a closed loop process. When the VRUs are unable to capture the entire overhead gas stream, flash gas is routed to three(3)enclosed combustion devices(ECDs).The ECDs each have a minimum control efficiency of 95%. Emissions are a function of condensate throughput while overhead gas is routed to the ECDs.It is assumed that the flash gas is routed to the ECDs 10%of the time.This permit covers emissions when flash gas is routed to the ECDs. VRU downtime: 10% IVRT Throughput during VRU downtime: 23,360 bbl/year 15WE1458.CP1.xlsm One(1)vapor recovery tower(VRT)that processes liquid from the second stage of separation to create a third stage of liquid/gas separation. Overhead flash gas from the VRT is routed to the vapor recovery units 011 (VRUs)in a closed loop process. When the VRUs are unable to capture the entire overhead gas stream, flash gas is routed to three(3)enclosed combustion devices(ECDs).The ECDs each have a minimum control efficiency of 95%. Emissions are a function of condensate throughput while overhead gas is routed to the ECDs.It is assumed that the flash gas is routed to the ECDs 10%of the time.This permit covers emissions when flash gas is routed to the ECDs. Flaring Information Equipment Description Three(3)enclosed combustors to combust vapor recovery tower gas during VRU downtime. Manufacturer TBD Model TBD Serial Number TBD Control Efficiency 95.00% Combustion emission factor source: CDPHE Inter-Office Communication(2005-03-22) 0.0037 Ilb NOX/Ib VOC 0.0094 IIb CO/lb VOCI Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 38.283 lb/bbl 1.914 lb/MMscf 447.14 tpy 22.36 tpy E&P Tanks NOx 0.1416 lb/bbl 0.1416 Ib/MMBTU 1.65 tpy 1.65 tpy CDPHE CO 0.3599 lb/bbl 0.3599 lb/MMBTU 4.20 tpy 4.20 tpy CDPHE Benzene 0.3255 lb/bbl 0.0163 lb/MMscf 7603.7 lb/yr 380.2 lb/yr E&P Tanks Toluene 0.4430 lb/bbl 0.0222 lb/MMscf 10348.5 lb/yr 517.4 lb/yr E&P Tanks Ethylbenzene 0.0185 lb/bbl 0.0009 lb/MMscf 432.2 lb/yr 21.6 lb/yr E&P Tanks Xylenes 0.2315 lb/bbl 0.0116 lb/MMscf 5407.8 lb/yr 270.4 lb/yr E&P Tanks n-Hexane 2.3810 lb/bbl 0.1191 lb/MMscf 55620.2 lb/yr 2781.0 lb/yr E&P Tanks 2,2,4-TMP 0.1335 lb/bbl 0.0067 lb/MMscf 3118.6 lb/yr 155.9 lb/yr E&P Tanks Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.' AQCC Regulation 2 Section I.A applies to all emission sources."No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air." AQCC Regulation 7 Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? No See Additional Note#1 below for additional discussion. This separator is not subject to Reg 7 Section XVII.G Additional Notes: 1. Based on the interpretation that the date of first production is equivalent to the date of a well being"newly constructed,"the date of first production for the most recent well at this facility occurred prior to the August 1,2014 applicability date. The operator was asked about this point and they confirmed that the date of first production for the most recent well was before August 1,2014. As a result,the VRT is not subject to Regulation 7,Section XVII.G and the other control requirements of Regulation 7 Section XVII.B.2. 2. The operator expressed in the application that the normal operating pressure of the separator was increased by 10 psi prior to obtaining a sample for analysis. This artificial load on the VRT leads to a more conservative estimate of flash emissions at the vapor recovery tower due to the increased pressure drop. 3. As indicated above,the operator obtained the API gravity used to calculate RVP for E&P Tanks from the most recent truck loadout sales ticket.The value from the sales ticket was compared to the average API gravity reported to COGCC for each of the wells at this facility for the 2015 calendar year.Since the value from the sales ticket(49.4)was almost identical to the average(49.5),the sales oil ticket was deemed representative and acceptable for use in the analysis. 4.The pressurized condensate samples used for this analysis were obtained on October 28,2015.Since this is within one year of the submittal of this application,initial testing will not be required in the permit. 5. During review,the operator requested that the VRU downtime be decreased from 15%to 10%. This request was made in order to decrease permitted VOC emissions below 80 tpy. This also resulted in a decrease in frequency of O&M monitoring requirements(from daily to weekly). This request was agreed to and the necessary adjustments were made to the permitted throughput and emissions. 6.The operator was provided with a draft permit to review prior to public comment.The operator reviewed the draft permit and responded with three questions/comments.Following,you will find the questions/comments along with the responses provided: (i)Comment:Can we get the language"whichever comes later"added into the second requirement? Previous permits like this one we've completed read,"...after commencement of operation or issuance of this permit,whichever comes later compliance with the conditions...". Response:We have updated our standard language for this condition to now state"Within one hundred and eighty days/1 Rnl of the latter of commencement of nneratinn nr issuance of this nermit."I believe this 15WE1458.CP1.xlsm One(1)vapor recovery tower(VRT)that processes liquid from the second stage of separation to create a third stage of liquid/gas separation. Overhead flash gas from the VRT is routed to the vapor recovery units 011 (VRUs)in a closed loop process. When the VRUs are unable to capture the entire overhead gas stream, flash gas is routed to three(3)enclosed combustion devices(ECDs).The ECDs each have a minimum control efficiency of 95%. Emissions are a function of condensate throughput while overhead gas is routed to the ECDs.It is assumed that the flash gas is routed to the ECDs 10%of the time.This permit covers • emissions when flash gas is routed to the ECDs. language satisfies the request to add"whichever comes later." However,if you would like the language simplified,I could update it to read"Within one hundred and eighty days(180)of issuance of this permit,"since the VRT has already commenced operation.Just let me know how you would like to proceed.Operator Decision/Agreeement:The current language is fine. I missed the word"latter"in the new standard wording,which was why I asked. Thanks. (ii)Comment:On requirement 15,can we use Method 22 instead of Method 9? Response:Since the VRT is not subject to Regulation 7 Section XVII,the opacity standard(30%)stems from Regulation 1,II.A.5.The corresponding test method for this standard is thus Method 9 not Method 22. However,this does raise an additional question for me.Based on the application,I was under the impression that the three back-up flares were only used to control emissions from the VRT.Is this the case,or are these back-up flares also used to control emissions from other sources at the facility? If the back-up flares are a common control device for sources other than the VRT that are subject to a no visible emissions requirement,Method 22 may be the more appropriate test method.Operator Decision/Agreement:The three back up ECDs only control VRT emissions. Method 9 is fine if that's the right course. (iii)Comment:Also on requirement 15,Reg.1,II.A.5 specifies"...30%opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes." The draft permit says,"This measurement shall consist of a minimum twenty-four consecutive readings taken at fifteen second intervals over a six minute period.(Regulation Number 1,Section II.A.1 and H.A.5)". This is probably me being new,but does that mean we'd be required to do a 6 minute opacity test,or a 60 minute opacity test? Thanks for the clarification.Response:The entirety of a method 9 opacity test is 60 minutes.This is further broken down into 6 minute intervals during which twenty-four(24)consecutive opacity readings are taken at 15 second intervals. The following link goes into more detail regarding the Method 9 test procedure:https://www3.epa.gov/ttnemc0l/promgate/m-09.pdf Operator Decisison/Agreement:Thanks for the link,that helps! 15WE1458.CP1.xlsm AIRS(County/Plant)123/2223 Permit No. 15WE1458 Date 4/21/2016 Controlled Controlled Actual Requested NCRP= Uncontrolled Emission Emissions Emissions Ctrl. reportable Point# SCC Pollutant or CAS Factor Emisison Factor Source (tpy)* (tpy)* PTE(tpy)• Eff% ? 011 31000129 VOC 38283 lb/1000 ba E&P Tanks 22.4 447.1 95% Yes 011 31000129 NOx 141.6 lb/1000 be CDPHE 1.7 1.7 0% Yes 011 31000129 CO 359.9 lb/1000 ba CDPHE 4.2 4.2 0% Yes 011 31000129 Benzene 325.5 lb/1000 ba E&P Tanks 381 7604 95% Yes 011 31000129 Toluene 443 lb/1000 ba E&P Tanks 517 10349 95% Yes 011 31000129 Ethylbenzene 18.5 lb/1000 ba E&P Tanks 22 433 95% Yes 011 31000129 Xylenes 231.5 lb/1000 ba E&P Tanks 271 5408 95% Yes 011 31000129 n-Hexane 2381 lb/1000 ba E&P Tanks 2781 55620 95% Yes 011 31000129 2,2,4-TMP 133.5 lb/1000 ba E&P Tanks 156 3119 95% Yes **HAP emissions have units of Ibs/year. CDPHE General APEN - Form APCD-200 CO sr-fv Air Pollutant Emission Notice(APEN)and y Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. There may be a more specific APEN for your source (e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available on the Air Pollution Control Division (APCD) website at www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: 123 / 2223 / T © [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 - Administrative Information Company Name': Kerr-McGee Oil and Gas Onshore LP Site Name: 36114755 Site Location Site Location: SWSW Sect. 34 T3N R66W County: Weld NAICS or SIC Code: 1311 Mailing Address: PO Box 173779 (Include Zip Code) Permit Contact: Steger, David Denver, CO 80217.3779 Phone Number: (720) 929-6075 Portable Source E-Mail Address: david.steger@anadarko.com Home Base: 'Please use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 340542 p COLORADO Form APCD-200 - General APEN - Revision 7/2015 1 I �tilVo a nwm a�,nWrnmmi Ott Permit Number: IS LOE 145 AIRS ID Number: 123/ 2223 / TBD [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2- Requested Action ® NEW permit OR newly-reported emission source (check one below) STATIONARY source El PORTABLE source -OR • MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name El Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership2 O Other(describe below) -OR- ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS- • Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info a Notes: Initial individual permit application for vapor recovery tower (VRT) 2 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Provide 3rd stage of gas/liquid separation Manufacturer: Model No.: Serial No.: Company equipment Identification No. (optional): V R T - 0 1 For existing sources, operation began: / / For new or reconstructed sources, the projected start-up date is: / / ® Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 . COLORADO Form APCD-200 - General APEN - Revision 7/2015 2 I iel n, In,„ ilk Permit Number: I SSE 14S� AIRS ID Number: 123/ 2223 / -5 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Processing/Manufacturing Information Et Material Use ❑ Check box if this information is not applicable to source or process From what year is the actual annual amount? r, lstrkokG ?Cr 'hv 1kotnor`cb,_ Design Process Actual Annual Requested Annual itzS Description Rate Amount Permit Limit3 (Specify Units) (Specify Units) (Specify Units) Condensate Throughput in Material Consumption: Flash Gas Finished Product(s): 3 Requested values will become permit limitations. Requested limit(s)should consider future process growth. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.17982/-104.76568 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Discharge Height Operator- - Temp Flow,Rate elocity i .Above Ground Level ; Stac 1D'No (.F) (AGFMN (f#/sec a (Feet) . >t VRT ECD-01 Indicate the direction of the stack outlet: (check one) ® Upward ❑ Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑ Other(describe): Indicate the stack opening and size: (check one) Circular Interior stack diameter (inches): 48 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other(describe): COLORADO Form APCD-200 - General APEN - Revision 7/2015 3 I �� HNllfIbFIW�1DIInfYn� oil Permit Number: t KS% AIRS ID Number: 123 /2223 / TBD [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 6 - Combustion Equipment £t Fuel Consumption Information ❑Check box if this information is not applicable to the source (e.g. there is no fuel-burning equipment associated with this emission source) Design Input Rate Actual Annual Fuel Use Requested Annual Permit Limits (MMBTU/hr) (Specify Units) (Specify,Units) From what year is the actual annual fuel use data? Indicate the type of fuel used4: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) ® Field Natural Gas Heating value: BTU/SCF ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑Coal Heating value: BTU/lb Ash Content: Sulfur Content: ❑Other(describe): Heating value (give units): 3 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 4 If fuel heating value is different than the listed assumed value, please provide this information in the"Other"field. Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ®Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Overall Control Efficiency Pollutant Control Equipment Description (%reduction in emissions) TSP (PM) PM10 PM2.5 SOX NO. CO VOC Enclosed Flare 95 Other: _.. __. ..._ _.. COLORADO Form APCD 200 General APEN Revision 7/2015 4 I �� ° E "`°w"`°"` Hepnh Er Olt Permit Number: ,5 r AIRS ID Number: 123/ 2223 / TBD [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7(continued) From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Emission re Uncontrolled �� , �--�� Re uesed nnua"�'Perm�t=�` Factor = �Actua1;.Annual Errnssions� Emission ' g `ai,- rssrn Pollutant" Source � �Factor (AP-42 Mfg Uncontrolled Controlled5 Uncontrolled Controlled (Specify Units) etc) y ) (Tons/year) (Tons/year) ' ( y ) (Tons/ ear . Tons/ ear TSP (PM) PM-0 PM2.5 SOx NOx 0.0037 Ib/IbVOC 2005 APCD -- •E74$ (,(pq CO 0.0094 Ib/IbVOC 2005 APCD -- C.30 Li•L VOC 38.283 Ib/bbl E&P Tank v2.0 33.54 22.3,0 Other: 3 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants (e.g. HAP- hazardous air pollutant) emissions equal to or greater than 250 ®Yes ❑ No lbs/year? If yes, use the following table to report the non-criteria pollutant (HAP) emissions from source: Uncontrolled Uncontrolled Controlled Overall Emission Factor CAS Emission Actual Actual Chemical Name Control Source Number Factor Emissions Emissions Efficiency (AP-42,Mfg.etc) (specify units) (lbs/year) (lbs/year) Benzene 95 0.326 Ib/bbl E&P Tank -WO Toluene 95 0.443 lb/bbl E&P Tank _.c 4.76. Sri_ E-Benzene 95 0.019 lb/bbl E&P Tank 3;Z 11 Xylene 95 0.232 lb/bbl E&P Tank — 406 2.qi n-Hexane 95 2.381 lb/bbl E&P Tank „ 41-73 2.1}V 224-TMP 95 0.134 Ib/bbl E&P Tank 1, -234 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. t co�oiiAao Form APCD-200 - General APEN - Revision 7/2015 5 I °`"'"° °` "` Permit Number: I LADE,`-15% AIRS ID Number: 123 / 2223 / Ta [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Signature of egally Authorized Person (not a vendor or consultant) Date David Steger HSE Representative Name (please print) Title Check the appropriate box to request a copy of the: ® Engineer's Preliminary Analysis conducted ® Draft permit prior to issuance ® Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303) 692-3175 or(303) 692-3148 APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 www.colorado.gov/pacific/cdphe/air-permits Telephone: (303) 692-3150 COLORADO Form APCD-200 - General APEN - Revision 7/2015 6 I A' H�IN b F.nintON�YnI Hello