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Home My WebLink About20162503.tiffCOLORADO AUG 01 2015 Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 July 27, 2016 Dear Sir or Madam: On August 4, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for Western Operating Company - Hoozee-Bjolin 1. 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, 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.cotorado.gov/cdphe John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer bliL RAN ;cm., C.c,: pLC Mm / "C"P), NL C Pe") C�s/os � �O (Co taw C E.RiC-H i mac— ) ors/oc / 9O %Co 2016-2503 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Western Operating Company - Hoozee-Bjolin 1 - Weld County Notice Period Begins: August 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: Western Operating Company Facility: Hoozee-Bjolin 1 Oil and gas well pad SENE SEC 33 T7N R56W Weld County The proposed project or activity is as follows: Permit for venting of natural gas from heated separator. 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): • 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 16WE0129 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: Timothy Sharp Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd®state.co.us STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 16WE0129 Issuance 1 DATE ISSUED: DRAFT ISSUED TO: Western Operating Company THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Hoozee-Bjolin 1, located in the SENE SEC 33 T7N R56W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description Separator 003 One low-pressure separator; emissions are vented. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, 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 AIRS ID: 123/9D8E Page 1 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days 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 Equipment ID AIRS Point Tons per Year Emission Type NO, VOC CO Separator 003 --- 63.1 --- Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) 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. PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) AIRS ID: 123/9D8E Page 2 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Separator 003 Gas Vented from Separator 3.5 MMSCF 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section I I.A.1. & 4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 12. The operator shall complete an initial site specific extended gas analysis of the gas vented from the separator in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission stream. Results of testing shall be used to calculate site -specific emission factors for the pollutants referenced above (in units of lb/MMSCF gas vented) using Division approved methods. Results of site -specific sampling and emissions factor analysis shall be submitted to the Division as part of the self -certification and demonstrate the emissions factors established through this initial testing are less than or equal to, the emissions factors established in the permit application and "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this sampling and analysis is greater than the emissions factors established in the permit application and "Notes to Permit Holder", the operator shall submit to the Division within 60 days a request for permit modification to update emissions factors and emissions limits specified in this permit. ADDITIONAL REQUIREMENTS 13. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) AIRS ID: 123/9D8E Page 3 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division 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 NOX 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. GENERAL TERMS AND CONDITIONS 14. 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. 15. 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. 16. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. AIRS ID: 123/9D8E Page 4 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division 17. 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. 18. 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. 19. 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. 20. 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: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Western Operating Company for separator venting at a true minor facility. AIRS ID: 123/9D8E Page 5 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpaqename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641 &pagename=CBONWrapper 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 003 Benzene 71432 149.3 No 149.3 003 n -Hexane 110543 2751.3 Yes 2751.3 003 Toluene 108883 422.9 Yes 422.9 003 Ethylbenzene 100414 126.5 No 126.5 003 Xylenes 1330207 296.1 Yes 296.1 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Pollutant Weight Fraction of Gas (%) Emission Factors Uncontrolled lb/MMscf Emission Factors Controlled lb/MMscf Source VOC 49.1 36000 36000 Gas Analysis Benzene 0.16 42.7 42.7 Gas Analysis Toluene 0.05 121 121 Gas Analysis Ethylbenzene 0.01 36.1 36.1 Gas Analysis Xylenes 0.03 84.6 84.6 Gas Analysis n -hexane 0.30 786 786 Gas Analysis 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 AIRS ID: 123/9D8E Page 6 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor/Major Source of: Not Applicable PSD or NANSR Synthetic Minor/Major Source of: Not Applicable 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 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: 123/9D8E Page 7 of 7 Division Information Engineer: Timothy Sharp Control Engineer: Stefanie Rucker Review Date: 02/25/2016 Application Date: 01/05/2016 Facility Identifiers Permit No. 16WE0129 AIRs County # 123 (Weld Facility # 9D8E Facility Type: exploration and production facility ❑� Located in the 8 -hour non -attainment area? Administrative Information Potentially located in ozone nonattainment area 0 True Minor 0 Synthetic Minor for: VOC I N0x r' CO Company Name: Western Operating Company Source Name: Hoozee-Bjolin 1 Source Location: SIC: SENE SEC 33 T7N R56W 1311 Mailing Address Address 1: Address 2: ty, State Zip: Western Operating Company 518 17th Street, Suite 200 Denver, CO 80202 Person To Contact Name: Phone: Fax: Email: Steven D. James 3038932438 000-000-0000 steve@westernoperating.com Requested Action Self Certification Required? Issuance Number: Yes 1 Source Description: Oil and gas exploration and production facility known as the Hoozee-Bjolin 1, located in the SENE SEC 33 T7N R56W, Weld County, Colorado. Point Name Type Control Action 003 Separator Separator Venting None Newly reported source One low-pressure separator controlled by one enclosed flare during VRU downtime. Flare has a minimum 003 control efficiency of 95%. Equipment Description This source vents natural gas from: Emissions from this source are: a well head separator vented to the atmosphere Natural gas venting from a well head separator. Emissions from this source are vented to the atmosphere. Calculations Emission Calculation Method EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW *Xx/C Ex = emissions of pollutant x Q = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm Throughput (Q) MW 3.5 27.79 MMscf/yr Ib/Ib-mol 399.543379 0.009589041 scf/hr MMscf/d mole % MW Ibx/Ibmol mass fraction lb/hr lb/yr tpy Helium 0.00 4.0026 0.000 0.000 0.00 0.00 0.00 CO2 1.24 44.01 0.547 0.020 0.58 5052.27 2.53 N2 2.27 28.013 0.637 0.023 0.67 5880.92 2.94 methane 60.38 16.041 9.685 0.349 10.21 89438.08 44.72 ethane 10.91 30.063 3.279 0.118 3.46 30284.35 15.14 propane 13.41 44.092 5.911 0.213 6.23 54586.01 27.29 isobutane 1.64 58.118 0.956 0.034 1.01 8827.80 4.41 n -butane 5.97 58.118 3.469 0.125 3.66 32039.96 16.02 isopentane 1.11 72.114 0.797 0.029 0.84 7360.86 3.68 n -pentane 1.53 72.114 1.105 0.040 1.16 10200.52 5.10 cyclopentane 0.00 70.13 0.000 0.000 0.00 0.00 0.00 n -Hexane 0.35 86.18 0.298 0.011 0.31 2751.28 1.38 cyclohexane 0.00 84.16 0.000 0.000 0.00 0.00 0.00 Other hexanes 0.57 86.18 0.489 0.018 0.52 4517.29 2.26 heptanes 0.31 100.21 0.309 0.011 0.33 2854.93 1.43 methylcyclohexane 0.00 98.19 0.000 0.000 0.00 0.00 0.00 224-TMP 0.00 114.23 0.000 0.000 0.00 0.00 0.00 Benzene 0.02 78.12 0.016 0.001 0.02 149.33 0.07 Toluene 0.05 92.15 0.046 0.002 0.05 422.94 0.21 Ethylbenzene 0.01 106.17 0.014 0.000 0.01 126.48 0.06 Xylenes 0.03 106.17 0.032 0.001 0.03 296.10 0.15 C8+ Heavies 0.11 186.8960925 0.200 0.007 0.21 1846.77 0.92 VOC mass Tract 0.491 Total VOC (Uncontrolled)( 62.99 Notes Mole %, MW, and mass fractions from Hoozee/Bjolin 1 gas analysis collected 10/21/2014. Emissions are based on 8760 hours of operation per year. NOTES: Well confirmed to be completed in 1981 (08/1981) Uncontrolled minor separator source approved. 16WE0129.CP1.xlsm One low-pressure separator controlled by one enclosed flare during VRU downtime. Flare has a minimum 003 control efficiency of 95%. Flaring Information Equipment Description Manufacturer Model Serial Number Gas Heating Value Btu/scf Throughput 0 MMBtu/yr VRU Information Equipment Description Make Model Requested Control Efficiency Annual Bypass Time Backup Overall Control 0.00% Combustion emission factor source: 0.07 Ilb NOX/MMBtu Emissions Summary Table AP -42: Chapter 13.5 0.37 IIb CO/MMBtu Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 35994 lb/MMscf 35994.36 lb/MMscf 63.0 tpy 63.0 tpy Gas Analysis Nox 0.07 lb/MMBTU 0.07 lb/MMBTU 0.0 tpy 0.0 tpy AP -42 CO 0.37 lb/MMBTU 0.37 Ib/MMBTU 0.0 tpy 0.0 tpy AP -42 Benzene 42.67 lb/MMscf 42.67 lb/MMscf 149 lb/yr 149 lb/yr Gas Analysis n -Hexane 786.08 lb/MMscf 786.0798 lb/MMscf 2751 lb/yr 2751 lb/yr Gas Analysis Toluene 120.841 lb/MMscf 120.8405 lb/MMscf 423 lb/yr 423 lb/yr Gas Analysis Xylenes 84.600 lb/MMscf 84.5998 lb/MMscf 296 lb/yr 296 lb/yr Gas Analysis Ethylbenzene 36.137 lb/MMscf 36.1370 lb/MMscf 126 lb/yr 126 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 16WE0129.CP1.xlsm AIRS (County/Plant) 123/9D8E Permit No. 16WE0129 Date 2/25/2016 Point # SCC Pollutant or CAS Uncontrolled Emission Factor 003 31000205 VOC 35994.364 lb/MMscf 003 31000205 NOx 0.068 lb/MMBTU 003 31000205 CO 0.37 lb/MMBTU 003 31000205 Benzene 42.667 lb/MMscf 003 31000205 n -Hexane 786.08 lb/MMscf 003 31000205 Toluene 120.841. lb/MMscf 003 31000205 Ethylbenzene 36.137 lb/MMscf 003 31000205 Xylenes 84.6 lb/MMscf Emisison Factor Source Controlled Actual Emissions (tpy)* Controlled Requested Emissions (tpy)* PTE (tpy)* Ctrl. Eff% NCRP = reportable ? Gas Analysis 63 63 0% Yes AP -42 0 0 No AP -42 0 0 No Gas Analysis 149.3 149.3 0% No Gas Analysis 2751.3 2751.3 0% Yes Gas Analysis 422.9 422.9 0% Yes Gas Analysis 126.5 126.5 0% No Gas Analysis 296.1 296.1 0% Yes �M N V./ CC E O o O GC 023 W W HI a k11 gio Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit # & AIRS ID] Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Facility Equipment ID: uested Action (check applicable request boxes) Section 02 — Re Section 01 — Administrative Information Request for NEW permit or newly reported emission source Request MODIFICATION to existing permit (check each box below that applies) Change company name 0 C Transfer of ownership ❑ ❑ Change fuel or equipment Change permit limit ❑ ❑ Request to limit HAPs with a Federally enforceable limit on PTE Request APEN update only (check the box below that applies) ® ❑ ❑ ❑ 0.4 V 7 7 00 O N 0 'O 'O _ U U 0 d o Q C_) U a>i e. Z 7 W N Western Operating Company I) E z 0 C a. E O 518 17'h Street, Suite 200 C 77, C O O LL O C •- E U CD O a V e0 V b Y U W Q o ro r E c - 0 O O -57 "C1 c U 0 C, ❑ ❑ O z Fax Number: steve@westernoperating.com E-mail Addr Section 03 — General Information For new or reconstructed sources, the projected startup date is: For existing sources, operation began on: V 3 V V 3 b CC 0 N N Normal Hours of Source Operation: Natural gas venting from the heater -treater General description of equipment and purpose: o0 ro — o o E n • E• t W U U ' V t' r P-, y L N Cl N c1 _C 01 01 �' .�. Q O I y i -� E n T.) U E m m m a� O ,> C r.. C O O O Q Cy ,,ED '� 0_▪ � .OC cd C ,O O -a C W N \ .1C CO bU0 ~ z L' '� C .0 W - C.. e C fiR i V] C U L Q O w� . v �x E o 0 ✓ E d .V s V v 'a o >> O n C o o o 'ED Ed O O C O L, a E •° V o 3 > �' o • o o •> V z w C6. d V •j C •L o Q 9 c C °' A 3 0 E g o cd > O R L L _C CO > �- D E 0. U m o U .; o 2 o` a' t'0 • o c a V V • 7 a U O U .� V] t -.cOj v� C -..ad u i L A V> • a C_ • V C U O C d ca o,O d Ems- o'er V 7 A 2• n APEN forms:http:// Application status:http: C 03 0 0 z C C C E C C C O a� Z >, c c 'E C 71771 0.3 CC C CO o c R °' qo _ U• Q' ment Information C C Section 04 — Processin Description of Source': Well Head Casing Gas/liquid Separator c E E. 0,5 o V a Cd • O U a C c;-,) CO C V a C. TJ E C V E C C Compressor R C C0 Blowdowns: ❑®❑❑❑ C O 5. Ca V 0 O O En 0.1 C7 v C > E a E z, O e' Process Parameters: g v x0 a .. 0 a= > o X E O co d a He 0 Q U [ 9 c a C1. O O O O n a 8 V U 4J n a b• b 0 0 0 0 n a o o o C a o V O 0 o x .x ✓ U s c U U ® ❑ aCi glav 0 > o 5 Molecular Wt. O\ Uri r N Vented Gas Properties: APEN - Natural Gas Venting.doc N 0 O FORM APCD-211 Gas Ventin CC z 'U a •E a N O A a O Q• � CJ L u 1L1 O O L O .4- • O ¢ "CJ z LHL C z O W � N E Section 05 — Stack Information (Combustion stacks must be listed here) C V C7 O N 7 z 7.3 0 o ea O w " " 0 U O z O Ga Other (Describe): Width (inches) = ❑ Horizontal ❑ Down ❑ Other: Length (inches) = Vertical with obstructing raincap ❑ Direction of stack outlet (check one): Circular: Inner Diameter (inches) _ Section 07 — Control Device Information Section 08 — Emissions Inventory Information & Emission Control Information E W z 0 C O CC c E C U O O 0 U C O E. • • C C c CC C c O .5 C) CC CC bn Y a, r ba 0 0 C 0 E eer •O R C R R ea .O u r C O a, C O A C 0 w 0 E W IZI Estimation Method or Emission Factor Source See Calcs II V/N V/N V/NI See Calcs I [ See Calcs See Calcs I See Calcs See Calcs Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. fi Requested Permitted Emissions Controlled (Tons/Year) 63.07 V/N V/N N/A V7 N O 10.212 Moe C.O O 7© O 1.377 Uncontrolled (Tons/Year) 63.07 V/N N/A N/A V N O O 0.212 M O O O 00 ^ O N N M - Actual Calendar Year Emissions4 Controlled (Tons/Year) 52.56 z z zz o O .. O O O 10.124 ,- Uncontrolled (Tons/Year) 52.56 1 N/A N/A Q z N O o ,O 1-,--:, 0 M V7 0 7 N 0 00 7 Emission Factor Units U w, L N/A N/A N/A V s C L V s C L lbs/MMscf V . C L Ibs/MMscf Uncontrolled Basis O O M N/A N/A Q z O W n N v O W I. N ,—; O W . •w `O M O W ,,,C) R oo O ‘.O,.D 00 N Control Efficiency (% Reduction) z N/A z z z z z z z Overall Collection Efficiency V/N N/A V/N VIM N/A Q z N/A N/A V/N Control Device Description Secondary Q z Q z N/A N/A N/A Q z N/A z N/A E G� V/N Q z N/A N/A V/N N/A N/A N/A V/N Pollutant DOA I xON O 0 Benzene Toulene Ethylbenzene Xylene n -Hexane CC 8 .0 O q E Cc to G 8 0 U Steven D. James 12-18-2015 O -Legally Authorized to Supply Data O a C~ O a) C CC c on APEN - Natural Gas Venting.doc N O N co O 4 O 0. FORM APCD-211 Hello