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Home My WebLink About20161323.tiff A CDPHE COLORADO 11. Co Is 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 11500 St PO Box 758 RECEIVED Greeley, CO 80632 April 6, 2016 APR 1 2 2016 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On April 13, 2016, the Air Pollution Control Division will begin a 30-day public notice period for Kerr- McGee Oil and Gas Onshore LP - 36166295 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, ,.g,, 11 '' - Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 44.- 2016-1323 97 / ‘1. 4300 Cherry Creek Drive S., Denver, CO 80246 1530 P 303 692-2000 www.colorado.gov/cdphe ��, x r� /�-,`f,- /6 John W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer (} r 4'. ''..,!.`:‘,,,71;;;'- */ Ja76 CDPHE Air Pollution Control Division CO to Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Kerr-McGee Oil and Gas Onshore LP - 36166295 Tank Battery - Weld County Notice Period Begins: April 13, 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: 36166295 Tank Battery Oil and Gas Exploration and Production Facility NWNW Sect. 34, Ti N, R67W Weld County The proposed project or activity is as follows: Applicant is requesting permit coverage for one (1) vapor recovery tower (VRT) controlled by enclosed combustion devices 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 15WE0980 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: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us Av.!, COLORADO 3xa�b Fav x+nFxti A STATE OF COLORADO of cow COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT A.A. AIR POLLUTION CONTROL DIVISION y , * e TELEPHONE:(303)692-3150 ' *1876* CONSTRUCTION PERMIT PERMIT NO: 1 5WE0980 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 36166295 Tank Battery, located in the NWNW of Section 34, Township 1N, Range 67W, 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 VRT-01 006 VRUs are unable to capture the entire overhead gas stream, flash gas is routed to 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. 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.gov/pacific/cdphe/other-air- permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 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 AIRS ID: 123/9D14 Page 1 of 8 Wellhead Version 2012-1 olo , Deg . entf Public Health and Environment II Air Pollution Control Division 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 operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (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 VRT-01 006 1.8 24.1 4.6 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. 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. 7. 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.) AIRS ID: 123/9D14 Page 2 of 8 Idol.. , Deg • ent f Public Health and Environment £ Air Pollution Control Division Facility AIRS Pollutants Equipment Point Control Device Controlled ID VRT-01 006 Enclosed Combustors (48" HVECD) VOC and HAPs PROCESS LIMITATIONS AND RECORDS 8. 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, I I.A.4) Process/Consumption Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point Condensate throughput to VRT while VRT-01 006 emissions are routed to enclosed 192,000 BBL 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. 9. The owner or operator shall continuously monitor and record the amount of time that flash gas is routed from the VRTs to the ECDs. The owner or operator shall use monthly recorded ECD run time, monthly condensate throughput records and calculation methods detailed in the 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 10. 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) 11. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) OPERATING & MAINTENANCE REQUIREMENTS 13. 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 AIRS ID: 123/9D14 Page 3 of 8 olo De�� ent f Public Health and Environment Air Pollution Control Division O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) TESTING AND SAMPLING Initial Testing Requirements 14. 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 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or 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. 16. 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 AIRS ID: 123/9D14 Page 4 of 8 olo , Der . ent f Public Health and Environment II Air Pollution Control Division 17. 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. 18. 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. 19. 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. 20. 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. 21. 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. 22. 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. 23. 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: Bradley Eades Permit Engineer AIRS ID: 123/9D14 Page 5 of 8 olo ' . De ent f Public Health and Environment Air Pollution Control Division 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 a synthetic minor exploration and production facility. AIRS ID: 123/9D14 Page 6 of 8 olo De. , • entf Public Health and Environment ik Am Air Pollution Control Division Notes to Permit Holder: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/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# (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 9216 Yes 461 Toluene 108883 11328 Yes 566 Ethylbenzene 100414 1728 Yes 86 006 Xylenes 1130207 8352 Yes 418 n-Hexane 110543 29472 Yes 1474 2,2,4- 540841 4320 Yes 216 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 0.019 0.019 2005-03-22 APCD Memo CO 0.047 0.047 2005-03-22 APCD Memo VOC 5.009 0.250 E&P Tanks 71432 Benzene 0.048 2.40x10-' E&P Tanks 108883 Toluene 0.059 2.95x1O'' E&P Tanks 100414 Ethylbenzene 0.009 4.50x1O E&P Tanks 1330207 Xylenes 0.044 _ 2.18x1O'' E&P Tanks 110543 n-hexane 0.154 7.68x10-3 E&P Tanks 540841 2,2,4-TMP 0.023 1.13x10-3 E&P Tanks AIRS ID: 123/9D14 Page 7 of 8 IF olo , De: . ent f Public Health and Environment Air Pollution Control Division Note: The controlled emissions factors for point 006 are based on the enclosed combustor control efficiency of 95%. These emission factors were developed using a pressurized liquids analyses from the Grenemyer 36N-3HZ and Wagner 13C-3HZ wells both sampled on February 25, 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, Total HAPs NANSR Synthetic Minor Source of: VOC, n-Hexane, Total HAPs MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 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 X)OO0(X 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: 123/9D14 Page 8 of 8 Colorado Air Permitting Project Project Details Review Engineer: Bradley Eades Package#: 331677 Received Date: 5/19/2015 Review Start Date: 3/31/2016 Section 01-Facility Information Company Name: Kerr-McGee Oil and Gas Onshore LP County AIRS ID: 123 Plant AIRS ID: 9014 Facility Name: Batter 36166295(Grenemyer-Wagner 13N-3HZ) Physical Address/Location: NWNW Sect.34 T1N R67W Type of Facility: 1xplctratit&Production Welt Pad What industry segment? Oil"&'NattxraarGas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? ❑Carbon Monoxide(CO) ❑Particulate Matter(PM) E 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? Permit initial 006 Vapor Recd Tower(VRT), Yes 15WE0980 1 Yes , Is ee VRT venting to ECD Section 03-Description of Project This facility is an existing"Gen 4"KMG production facility that produces a projected 550,000 bbl/yr of condensate.All hydrocarbon liquid flows from an HLP separator into a VRT prior to storage in atmospheric tanks.Gas produced in the VRT is routed to aVRU and recompressed into the sales line during normal operation.This permit is requesting authorization to route a portion of this gas stream to multiple Cimarron enclosed combustors (ECDs)during periods of VRU downtime. Section 04-Public Comment Requirments Is Public Comment Required? Yes.:; aw If yes,why?' RequestrogSynthetic Minor Permit Section 05-Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? :: No Is this stationary source a synthetic minor? Yes If yes,explain what programs and which pollutants here: Prevention of Significant Deterioration(PSD):Minor source Title V Operating Permits(OP):VOC,HAPs Non Attainment New Source Review(NANSR):VOC -_ Is this stationary source a major source? Na If yes,explain what programs and which pollutants here: one(1)vapor recovery tower(VRT)controlled by enclosed combustion devices(ECDs)during downtime of the gas gathering 006 system.ECDs have a minimum control efficiency of 95%. Equipment ID: VRT-01 Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: recompressed Natural gas venting from a well head separator.Emissions from this source are recompressed. Emission Calculation Review Two(2)E&P Tank V2.0 models were run based on two(2)pressurized liquid samples taken from the site at the low-pressure side of the HLP separator(3-phase separator)prior to the VRT.The models were run assuming a liquid throughput of 8760 bbl/yr(24 bbl/day).lb/hr emission rates are from E&P Tank"Total Emissoins"summaries for each model/sample combination.The lb/yr emission rate was calculated assuming 8760 hr/yr operation and divided by the total throughput in the model(24 bbl/day).This results in a lb/bbl emission factor.The lb/bbl emission factors for the two models were averaged to derive an overall emisison factor. Emissions are calculated based on the requested liquid througput to the VRT during VRU downtime and the lb/bbl emission factor derived from the models. Calculations MODEL 1(Grenemver 36N-3HZ Pressurized sample 2-25-2015) E&P Tank throughput: 8,760.00 bb/yr 24 bbl/d Pollutant Emissions rate(Hysys) Emissions rate Uncontrolled Emissions Factor VOC 4.363 lb/hr 38219.88 lb/yr 4.36 lb/bbl Benzene 0.042 lb/hr 367.92 lb/yr 0.04 lb/bbl Toluene 0.053 lb/hr 464.28 lb/yr 0.05 lb/bbl Ethylbenzene 0.008 lb/hr 70.08 lb/yr 0.01 lb/bbl Xylenes 0.039 lb/hr 341.64 lb/yr 0.04 lb/bbl n-Hexane 0.132 lb/hr 1156.32 lb/yr 0.13 lb/bbl 2,2,4-TMP 0.019 lb/hr 166.44 lb/yr 0.02 lb/bbl MODEL 2(Wagner 13C-3HZ Pressurized sample 2-25-2015) E&P Tank throughput: 8,760.00 bbl/yr 24 bbl/d Pollutant Emissions rate(Hysys) Emissions rate Uncontrolled Emissions Factor VOC 5.654 lb/hr 49529.04 lb/yr 5.65 lb/bbl Benzene 0.054 lb/hr 473.04 lb/yr 0.05 lb/bbl Toluene 0.065 lb/hr 569.4 lb/yr 0.07 lb/bbl Ethylbenzene 0.01 lb/hr 87.6 lb/yr 0.01 lb/bbl Xylenes 0.048 lb/hr 420.48 lb/yr 0.05 lb/bbl n-Hexane 0.175 lb/hr 1533 lb/yr 0.18 lb/bbl 2,2,4-TMP 0.026 lb/hr 227.76 lb/yr 0.03 lb/bbl OVERALL(AVERAGE) E&P Tank throughput: 8,760.00 bbl/yr 24 bbl/d Pollutant Emissions rate(Hysys) Emissions rate Uncontrolled Emissions Factor VOC 5.0085 lb/hr 43874.46 lb/yr 5.009 lb/bbl Benzene 0.048 lb/hr 420.48 lb/yr 0.048 lb/bbl Toluene 0.059 lb/hr 516.84 lb/yr 0.059 lb/bbl Ethylbenzene 0.009 lb/hr 78.84 lb/yr 0.009 lb/bbl Xylenes 0.0435 lb/hr 381.06 lb/yr 0.044 lb/bbl n-Hexane 0.1535 lb/hr 1344.66 lb/yr 0.154 lb/bbl 2,2,4-TMP 0.0225 lb/hr 197.1 lb/yr 0.023 lb/bbl 15WE0980.CP1.xlsm one(1)vapor recovery tower(VRT)controlled by enclosed combustion devices(ECDs)during downtime of the gas gathering 006 system.ECDs have a minimum control efficiency of 95%. REQUESTED LIMITS Total throughput to VRT: 640,000 bbl/yr collection system downtime: 30% (VRU downtime) Throughput during downtime: 192,000 I bbl/yr • Flaring Information Equipment Description Flare to combust separator gas during collection system downtime. Manufacturer Cimarron Model 48"HVECD Serial Number TBD(Multiple ECDs) Control Efficiency 95.00% Combustion emission factor source: 2005 CDPHE Inter-Office Memo 0.0037 IIb NOX/Ib VOC 0.0094 IIb CO/lb VOC Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 5.0091 Ib/bbl 0.250 lb/bbl 480.82 tpy 24.04 tpy Gas Analysis Nox 0.019 lb/bbl 0.019 lb/bbl 1.779 tpy 1.78 tpy AP-42 CO 0.047 lb/bbl 0.047 lb/bbl 4.51967 tpy 4.52 spy AP-42 Benzene 0.048 lb/bbl 0.00240 lb/bbl 9,216.00 lb/yr 461 lb/yr Gas Analysis Toluene 0.059 lb/bbl 0.00295 lb/bbl 11,328.00 lb/yr 566 lb/yr Gas Analysis Ethylbenzene 0.009 lb/bbl 0.00045016/bbl 1,728.00 lb/yr 86 lb/yr Gas Analysis Xylenes 0.044 lb/bbl 0.00218 lb/bbl 8,352.00 lb/yr 418 lb/yr Gas Analysis n-Hexane 0.154 lb/bbl 0.00768 lb/bbl 29,472.00 lb/yr 1474 lb/yr Gas Analysis 2,2,4-TMP 0.023 lb/bbl 0.00113 lb/bbl 4,320.00 lb/yr 216 lb/yr Gas Analysis 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 This separator is not subject to Reg 7 Section XVII.G NOTES: **Confirmed with applciant that all wells serviced by this VRT(separator)began producing prior to August 1,2014.Therefore this equipmpent is not currently subject to XVII.G.control requirements. First date of production from the most recently completed/recompleted well was 6/15/2014. **Based on prior discussions with KMG,they have requested to monitor compliance using the condensate throughput to the VRT during VRU(collection system)downtime.Operating and maintenance plan outlines monitoring requirements and calculations that shall be used to calculate throughput to VRT during collection downtime,and monitoring requirements. Automated sensors shall monitor the amount of tim ethat the valve is open allowing gas to the backup ECDs. **Initial opacity test using Method 9 is being required since this equipment is subject to 30%opacity requirement set forth in Regulation 1.(not subject to XVII based on this • 15WE0980.CP1.xlsm 6. o u v " b s. o a O 0 E 0 u b °' ° °U' a o a) E z „ n m m d ❑ N ❑ a c pW d4 y N.,N N , in cd • N s Q. L Q Ct °- C '0cle " •� c o g cA , u E o004• °' 0 0 0 O a. 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