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Home My WebLink About20161158 A ct>PH6 COLORADO Department of Public Health€t Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 PO Box 758 RECEIVED Greeley, CO 80632 MAR 2 6 2016 March 24, 2016 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On March 30, 2016, the Air Pollution Control Division will begin a 30-day public notice period for Extraction Oil and Gas, LLC - Raindance Pad. 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 £t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Czi Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 3/9-1 2016 1158 7LtbLi.e.Riw• L.0..///4„ 4300 Cherry Creek Drive Denver, CO 80246-1 530 P 303-692-2000 www.colorado.gov/cdphe �r : John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer ,. ,, , CDpHE Air Pollution Control Division co 11. Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil and Gas, LLC - Raindance Pad - Weld County Notice Period Begins: March 30, 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: Extraction Oil and Gas, LLC Facility: Raindance Pad Oil and gas exploration and production facility SESE Section 30, T6N, R67W Weld County The proposed project or activity is as follows: Oil and gas exploration and production facility including five (5) condensate storage tanks. 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): a permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) 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 15WE1235 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: Stephanie Spector Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1AyFa`, a CDPHE421. Construction Permit CO - ` Air Pollution Control Division Permit number: 15WE1235 Issuance: 1 Date issued: Issued to: Extraction Oil and Gas, LLC Facility Name: Raindance Pad Plant AIRS ID: 123/9E1A Physical Location: SESE SEC 30 T6N R67W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Equipment Point Equipment Description ID Condensate Five (5) above ground 400 bbl atmospheric condensate storage tanks. Storage 001 Emissions from these tanks are routed to a cluster of six (6) enclosed Tanks combustors with a minimum destruction efficiency of 95%. 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 the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self-certify. (Regulation Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants shall not exceed the following limitations. Annual records of the actual emission rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) ) 3 -c-er Page 1 of IllII A • a :. i s: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO. VOC CO Type Condensate 001 --- --- 65.0 --- Point Storage Tanks Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate 3. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Control Device Equipment ID Point Controlled Condensate 001 Enclosed Combustors VOC and HAPs Storage Tanks PROCESS LIMITATIONS AND RECORDS 4. This source shall be limited to the following maximum processing rates as listed below. Annual records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point TANK-1 001 Condensate throughput 10,000 barrels STATE AND FEDERAL REGULATORY REQUIREMENTS 5. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 6. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 7. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank 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. (Regulation Number 7, Section XII.C.) (State only enforceable) 8. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other 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 C�E COLORADO Co le Air Pollution Control Division Denartme,ti.of Public Healt'n ft-rw*onment Page 2 of 7 op a p pe . T flare st be equipped with an operational auto-igniter according o the o the e. • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 9. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and 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 except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 10. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. 11. This source is subject to the New Source Performance Standards, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution, Subpart OOOO. This facility shall be subject to all provisions of this regulation, as stated in 40 C.F.R Part 60, Subparts A and OOOO. (Regulation Number 6, Part A, Subparts A and OOOO) OPERATING Et MAINTENANCE REQUIREMENTS 12. This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 13. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 14. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: 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;t� or 4, CDPHE ' COLORADO Co Air Pollution Control Division ;mf r,n1i.- ^,g,:,rrn ,r Page 3 of 7 IPA •r V on-' - " repo -. e 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. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 16. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 17. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 18. 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. 19. 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. 20. 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. 21. 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. CDPHE COLORADO CO Air Pollution Control Division Dep2rmett,1„lht,-eai n h.7 4ronment Page 4 of 7 22. V' ti o he erm f ermit • of the provisions of the Colorado Air Pollution Prevention and of r t r ation • 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: Stephanie Spector, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil and Gas, LLC. Newly permitted condensate tanks at a true minor facility. CDPHE COLORADO .61 O Air Pollution Control Division 1,me aht i npv Page 5 of 7 II A No - - '-r . - th- • - this - $ it 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. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/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. AIRS Uncontrolled Controlled Point Pollutant CAS# Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 186 9 001 n-Hexane 110543 1628 81 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. The emission levels contained in this permit are based on the following emission factors: Point 001: Uncontrolled Controlled CAS# Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl VOC 13.7 0.685 PS Memo 05-01 71432 Benzene 0.024 0.0012 PS Memo 05-01 110543 n-Hexane 0.21 0.0105 PS Memo 05-01 Note: The controlled emissions factors for this point are based on the enclosed combustors control efficiency of 95%. 5) 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. 6) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 7) This facility is classified as follows: 4,,. CDPHE COLORADO CO f Air Pollution Control Division ' Ceparmen;n;,,,blt-,:ealtnit7,Irorment Page 6 of 7 Requirement a us Operating Permit True Minor PSD or NANSR True Minor MACT HH 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 XXXXXX CDPHE-' COLORADO 0 to. Air Pollution Control Division Page 7 of 7 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Extraction Oil and Gas, LLC Permit Number: 15WE1235 Source Location: Raindance Pad SESE Section 30,T6N, R67W, Weld County (non-attainment) Equipment Description: Condensate tanks AIRS ID: 123-9E1A-001 Date: March 3, 2016 Review Engineer: Stephanie Spector, PE Control Engineer: Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no" to any of the above, when did you mail an See Section 14 Information Request letter to the source? On what date was this application complete? October 2, 2015 Section 4—Source Description AIRS Point Equipment Description Five(5)above ground 400 bbl atmospheric condensate storage tanks. Emissions 001 from these tanks are routed to a cluster of six(6) enclosed combustors with a minimum destruction efficiency of 95%. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM,() CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM,() CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region? (Note: If"yes" the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Page 1 Section 5—Emission Estimate Information AIRS Point Emission Factor Source 001 CDPHE Condensate Storage Tank Emission Factors Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTE) AIRS Point Process Consumption/Throughput/Production 001 7750 BBL per year(9300 x 1.2) Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 001 7750 BBL per year 2015 Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 001 10,000 BBL per year(Operator requested higher throughput to account for the higher requested emission limit of 65 TPY) Does this source use a control device? X Yes No %Reduction AIRS Point Process Control Device Description Granted 001 01 Six(6) enclosed combustors 95 Section 6—Emission Summary (tons per year) Point NOx VOC CO Single HAP Total HAP PTE: 001 0.2 63.7 0.5 1.0 (Hexane) 1.1 Uncontrolled actual point source emission 001 0.2 53.1 0.6 0.8 (Hexane) 0.9 rate: Controlled actual point 001 0.2 2.7* 0.6 0.04 (Hexane) 0.05 source emission rate: *Operator has requested a roundup limit of 65.0 TPY VOC from the uncontrolled emissions to account for variables in the well unloading process and inherent limitations due to safety concerns. Section 7—Non-Criteria/ Hazardous Air Pollutants—Actuals Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emssions Ib/ r (Ib/yr) reportable? Rate( Y ) Benzene 71432 A 186 No 9 n-Hexane 110543 C 1628 Yes 81 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? Source located at a true minor facility Section 9—Source Classification Is this a new previously un-permitted source? X Yes No Page 2 What is this facility classification? X True Synthetic Major Minor Minor Classification relates to what programs? X Title V PSD X NA NSR MACT Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? Minor Synthetic Major Minor Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes",for which pollutants?Why? For Reg. 3, Part B, III.C.1.a(emissions increase > 25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? Yes X No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards(NAAQS)? AIRS Point Section 12—Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which 001 is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A(July, 1992)) in all subsections of Section II. A and B of this regulation. Regulation 2—Odor Section I.A- 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 001 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. Regulation 3-APENs, Construction Permits, Operating Permits, PSD Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 001 each individual emission point in a non-attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant(pollutants are not summed) for which the area is non-attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) Part B—Construction Permit Exemptions 001 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold(Reg.3, Part B, Section II.D.2.a) Regulation 6 New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. 001 Is this source greater than 19,800 gallons(471 bbl)? No Is this source subject to NSPS Kb? No WHY? Source does not meet the criteria of this subpart; therefore not subject. NSPS OOOO: Tanks with the potential to emission equal to or greater than 6 TPY. Are uncontrolled VOC emissions greater than 6 TPY?Yes 001 Are controlled emissions greater than 6 TPY?Yes • Is the operator requesting a permitted limit less than 6 TPY? No • Source is subject to NSPS OOOO requirements. Page 3 Regulation 7—Volatile Organic Compounds XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks since it is located in a non-attainment area.) 001 XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is currently subject to this since actual uncontrolled emissions are greater than 6 tpy of VOC.) Regulation 8—Hazardous Air Pollutants MACT EEEE: Organic Liquids Distribution 001 This source is not subject to MACT EEEE because it is not located at a major source of HAP. 001 MACT HH This source is not subject to MACT HH because it is not located at a major source of HAP. Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Emission Pollutant/ Fugitive Emission Factor Source Control Description Factor CAS# (Y/N) (%) 326.1905 CDPHE PS Memo 05-01 lb/1000 gal V0C No (converted to lb/1000 gal) 95 1.2068 N0x No Engineering Calculation 0 lb/1000 gal 01 E&P Condensate 3.0659 CO No Engineering Calculation 0 001 Storage Tanks lb/1000 gal 0.5714 Benzene/ CDPHE PS Memo 05-01 lb/1000 gal 71432 No (converted to lb/1000 gal) 95 5.0 n-Hexane CDPHE PS Memo 05-01 lb/1000 gal / 110543 No (converted to lb/1000 gal) 95 SCC 40400311 —Fixed Roof Tank, Condensate,working+breathing+flashing losses Page 4 Section 14—Miscellaneous Application Notes AIRS Point 001 Condensate Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY(permit threshold). Operator used State emission factors PS Memo 05-01. Emission factors have been converted to lb/1000 gal: Condensate Tank Default Emission County Factors(lb/1000 gal) VOC Benzene n-Hexane Adams, Arapahoe, Boulder, Broomfield, Crowley, Denver, 326.1905 0.5714 5.0 Douglas, El Paso, Elbert,Jefferson, Larimer, Logan, Morgan, Philips, Pueblo, Sedgwick, Washington, Weld, Yuma Garfield, Mesa, Rio Blanco and Moffat 238.0952 1.1429 3.3333 Cheyenne, Kiowa, Kit Carson, Lincoln 71.4286 0.0952 1.6667 Remainder of Colorado 280.9524 0.8095 4.4048 The 6 enclosed combustor generated NOx and CO emissions. The operator used the Division's mass fraction ratios of VOC to calculate NOx and CO emissions. PTE uncontrolled: NOx=(0.0037 lb-NOx/Ib-VOC)*63.7*2000/2000=0.2357 TPY NOx*2000/9300=0.0507 lb/bbl* 1000/42 =1.2068 lb/1000 gal CO =(0.0094 lb-CO/Ib-VOC) *63.7*2000/2000=0.5988TPY CO*2000/9300 =0.1288 lb/bbl* 1000/42=3.0659 lb/1000 gal I emailed the operator on 3/4/16 a question regarding the condensate tanks. She wrote back quickly and her responses are in italics: 1. NOx and CO calculations for the condensate tanks. I calculated a much higher number for the emissions [operator calculated 0.8 TPY NOx and 2.1 TPY CO]. Please review and let me know what you think(I emailed her the calculations that are listed above): These calculations for the ECD combustion emissions are ok with me for the permit. Please proceed with your redline edits to this permit. Thanks! I also emailed the operator on 3/4/2016. I received a response on 3/15/16(italics): The O&M plan says: "6 x LEED 48" L30-001-00 ECD's each with maximum 180 MCFD combustion capacity. The ECD will be used to control the residual natural gas if the VRU is down, as a backup system for emissions control. The flare is hard piped to the tanks and has a constant pilot flame. Daily inspections and pilot checks are also used to ensure the system is working properly and providing the necessary control for the system." I didn't think the combustors were used as a backup system but a secondary control device because the uncontrolled emissions from the tanks are significantly high that 95%control would still be over 100 TPY VOC. If it's a backup when the VRU is down, then I would only assume 95%control from the facility, not 95%control and then the remaining 5%would be controlled by the combustors. Should this facility be considered a major source? 1 have attached updated information for you regarding the Raindance Tank Battery(AIRS ID: 123-9E1A). I apologize for the delay; we needed to confirm the changes that have been made to the site since the original application was submitted. The personnel at Extraction has the ability and instruction to shut in both facilities in the event of an upset condition. One control module has the ability to shut in both facilities simultaneously. No fluids(from Raindance or Pavistma South) that are produced under normal operating conditions are routed to the oil storage tanks at the Raindance facility. Since the five oil storage tanks are not used for anything other than "testing"and temporary storage of fluids after well unloading, the throughput for those tanks was estimated based on the Reg 7 downtime records for 2015. The ECDs that are used to control the vapors at these tanks are always on "pilot mode"in order to control for any residual vapors that would remain in the tanks after fluids are sent to the Pavistma North facility. State emission factors were used to calculate the emissions based on this throughput, and we would like to move forward with the individual construction permit. However,we are requesting the permit limit to reflect the uncontrolled potential to emit(rounded up to 65 TPY), rather than the controlled potential to emit to account for variables in the well unloading process and inherent limitations due to safety concerns. There is not a VRT located on this site, and the two compressors onsite are used to push gas to the sales line. Nothing has changed with those two applications. The throughput for produced water was based on the actual production of the wells at Raindance. We would like to move forward with the GP08 on that tank as well. It is also controlled by the ECDs on site. I have included a cancelation request for the Hydrocarbon Liquid Loading permit. No loading operations occurs from this facility. Everything is routed to the Pavistma North facility. I redlined the APEN with the new revisions as well as the PA and permit. Page 5 6. 7 v o ^ c v 3 e ° O c 3 Z Z Z >^ _ `c ° coo (re ^ u v y• = L G G 7 c� . V • a.Y C N -7:'... 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