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Home My WebLink About20162207.tiffCOLORADO 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 6, 2016 Dear Sir or Madam: R,E CFV E.0 JUL 112016 On July 7, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for Great Western Operating Company - Marcus LD 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 a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, 1, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 1c.v t et.0 �7 /IS/1 Co CCG: PL, HL, Pct 7 / l l/ ICo 4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdpne John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer 2016-2207 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Great Western Operating Company - Marcus LD Pad - Weld County Notice Period Begins: July 7, 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: Great Western Operating Company Facility: Marcus LD Pad Exploration and production facility SESE Section 34, T1 N, R67W Weld County The proposed project or activity is as follows: New exploration and production facility including a gas venting flare and truck loadout. 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 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 Permits 16WE0314 and 16WE0316 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 AVIV <oLoaao 1 I A STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: DATE ISSUED: ISSUED TO: 16WE0314 Issuance 1 Great Western Operating Company, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Marcus LD Pad, located in the SESE of Section 34, Township 1 North, Range 67 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description VRU Downtime 004 Heater treater to reduce flash emissions. Vapor recovery unit (VRU) emissions are a function of condensate throughput during VRU downtime. The flare is enclosed. 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 Within one hundred and eighty days (180) after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 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.) AIRS ID: 123/9E5D Page 1 of 9 Wellhead Version 2012-1 f Public Health and Environment Air Pollution Control Division 3. 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.) 4. The following information for all permitted equipment except fugitive emissions from equipment leaks shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 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 Equipment ID AIRS Point Tons per Year Emission Type yp NO, VOC CO VRU Downtime 004 9.7 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 I I.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID AIRS ID: 123/9E5D Page 2 of 9 tmeni f Public Health and Environment Air Pollution Control Division VRU Downtime 004 Heater treater controlled by a flare stack 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, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit VRU Downtime 004 Condensate throughput 33,199 BBL/yr The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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) 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. (Reference: Regulation No. 1, Section II.A.1. & 4.) 11. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.) 12. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: • XVII.B.2.b If a combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. • XVII.B.2.d Auto -igniters: All combustion devices used to control emissions of hydrocarbons must be equipped with and operate an auto -igniter as follows: AIRS ID: 123/9E5D Page 3 of 9 f Public Health and Environment Air Pollution Control Division • XVII.B.2.d.(i) All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device. • XVII.B.2.d.(ii) All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the applicant shall follow the operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5). ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually 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 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. 18. 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 AIRS ID: 123/9E5D Page 4 of 9 f Public Health and Environment Air Pollution Control Division 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 19. 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. 20. 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. 21. 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. 22. 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. 23. 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. 24. 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. 25. 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. AIRS ID: 123/9E5D Page 5 of 9 By: Stephanie Spector, PE Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Great Western Operating Company LLC. Newly permitted flare at a synthetic minor facility. f Public Health and Environment Air Pollution Control Division AIRS ID: 12319E5D Page 6 of 9 }{r f:menitf Public Health and Environment rya 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.qov/pacific/cdphe/apcc-reqs 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 # BIN Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 004 Benzene 71432 A 652 Yes 33 Toluene 108883 C 539 Yes 27 Ethylbenzene 100414 C 50 No 3 Xylenes 1130207 C 149 No 7 n -Hexane 110543 C 4345 Yes 218 2,2,4- Trim ethyl .entane 540841 C 422 Yes 21 5) The emission levels contained in this permit are based on the following emission factors: Point 004: CAS # Pollutant Weight Fraction of Gas (%) Emission Factors Uncontrolled Emission Factors Controlled Source NOx 0.068 lb/MMBtu 0.068 lb/MMBtu AP -42 CO 0.31 lb/MMBtu 0.31 lb/MMBtu AP -42 VOC 46.18 11.6296 lb/BBL 0.5815 lb/BBL Engineering Calculation 71432 Benzene 0.10 0.01971b/BBL 0.0010 lb/BBL Engineering Calculation 108883 Toluene 0.08 0.0162 lb/BBL 0.0008 Ib/BBL Engineering Calculation AIRS ID: 123/9E5D Page 7 of 9 f Public Health and Environment Air Pollution Control Division CAS # Pollutant Weight Fraction of Gas (%) Emission Factors Uncontrolled Emission Factors Controlled Source 100414 Ethylbenzene 0.01 0.0015 lb/BBL 0.0001 lb/BBL Engineering Calculation 1330207 Xylenes 0.03 0.0045 lb/BBL 0.0002 lb/BBL Engineering Calculation 110543 n -hexane 0.63 0.1309 lb/BBL 0.0065 lb/BBL Engineering Calculation Note: The uncontrolled VOC and HAP emissions for this point were calculated using the average of two gas samples both sampled on November 4, 2015 collected from the Marcus LD Pad 11- 377HC and Marcus LD Pad 11-374HN wells. The controlled VOC and HAP emissions factors for point 004 are based on the flare control efficiency of 95%. 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 Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -hexane NANSR Synthetic Minor Source of: VOC 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 SubpartA— SubpartKKKK 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 M — 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 AIRS ID: 123/9E5D Page 8 of 9 f Public Health and Environment Air Pollution Control Division 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: 123/9E5D Page 9 of 9 Division Information Engineer Stephanie Spector. PE Control Engineer: Christopher Laptante Review Date: 05/27/2016 Application Date: 02/01/2016 Facility Identifiers Permit No- 16WE0316 AIRs County# Facility # t' 9E5D Point# 006 Section 01: Administrative Information Company Name: Great Western Operating Company. LLC Source Name: Marcus LD Pad Source Location: SESE Section 34, Ti N, R67W SIC: 1311 Elevation (feet) 5043 Portable Source? Mable Source Homebase Mailing Address Address 1. Address 2'. y, State Zip: Great Western Operating Company. LLC 1801 Broadway. Suite 500 Denver, CO 80202 Person To Contact Name: Phone. Fax: Email: Scot Donato 303398-0302 sdonatot swogco corn Section 02 - Emissions Inventory Analysis AP -42: Chapter 5.2 Equation 1 L = 124615*P*M/7 L = loading losses in lb per 1000 gallons loaded S = Saturation Factor P = true vapor pressure of liquid loaded ipso] M = molecular weight of vapors [lb/lb-mole! T = temperature of bulk liquid loaded [deg. R] 1 degree Fahrenheit = 460.67 degree Rankine Criteria Pollutants Emissions that will be controlled by the ECD (not all emissions were captured by the ECD) Variables 5 0 6 Submerged loadingdedicated normal service P 4 44 psia M 67 lb/lb-mole T 518.16 deg. R 4.29 lb/10^3 gal 1.80E-01 Ib/bbl Annual requested Throughput Annual requested VOC emissions 7.258 272 Gallons per Year 31,153 Pounds per Year 15.58 Tons VOC per Year HAP emissions were calculated based on a ratio from Promax PTE VOC = 0.1808783 lb/hr Promax Pmmax (Ib/bn Raba Uncontrolled PTE :hat will be controlled (lb/yr) Uncontrolled PTE that will NOT be controlled (lb/yr) Benzene 0.0002674 0,001478342 46.05 42.42 Toluene 0.0001911 0.001056511 32.91 30.31 E -Benzene 0.0000152 8.40344E-05 2.62 2.41 Xylenes 0.0000435 0.000240493 7.49 6.90 n -hexane 0.001749 0.009669485 301 23 277.45 224-TMP 0.0001532 0.000846978 26.39 24.30 Emissions that will NOT be controlled by the ECD Variables S 0.8 Submerged loadingdedicated normal service P 444psia M 67 lbilb-mole T 518-16 deg. R • 4.29 lb/10^3 gal 1.80E-01 Ib/bbl Annual requested Throughput Annual requested VOC emissions 6,685,266 Gallons per Year 28,693 Pounds per Year 14.35 Tons VOC per Year Non -Criteria Reportable Air Pollutants/Hazardous Air Pollutants Component Uncontrolled PTE that will be controlled with ECD (TPY) Uncontrolled PTE that will be controlled with ECD (lb/yr) Uncontrolled PTE that will NOT be controlled with ECD (TPT) Uncontrolled PTE that will NOT be controlled with ECD (lb/yr) Total Uncontrell ed PTE (TPVI Total Uncontrolled PTE (10/yr) controlled PTE (TPY) controlled PTE (Ib/yr) Total controlled PTE (TPY) Total Controlled PTE (lb/yr) Emission factor 0blbbb Emhsion factor (lb/1000 590 VOC 1558 - 14.35 -- 29.93 - 0779 -- 15.129 - 0.1803 4.2930 Benzene 0.02 46 00212 42 0.044237 88 0.0012 2.3027 0.0224 45 0.0003 00563 Toluene 0.02 33 0.0152 30 0031614 63 0.0008 18457 00180 32 00002 0.0045 Ethylbenzene 000 3 0.0012 2 0.002515 5 00001 0.1309 0.0013 3 0.0000 0.0004 %ylenes 000 7 0.0035 7 0.007196 14 0.0002 0.3746 0.0036 7 0.0000 0.0010 n -hexane 0.15 301 0.1387 277 0.289341 579 0.0075 15.0616 0.1483 293 0.0017 00415 22,4-TMP 001 28 0.0122 24 0025344 st 0.0007 13193 0.0128 26 0.0002 0.0036 Section 03 - Regulatory Considerations Is this site considered an exploration and production location (e.g. well pad)? Yes Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill? No This emissions point is not categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.I Is this site located in an ozone non -attainment area? Yes If yes, this source is subject to Reasonably Available Control Technology (RACT) requirements under Regulation 3, Part B Section III.D.2.a. This requirement is met by using "submerged fill." Emissions are also routed to an enclosed combustor Is this facility classified as a major source of HAPs? No Does this facility involve the loading of refined crude/condensate in the form of "gasoline"? No Is this facility classified as a "Terminal" as defined per Regulation 7, Section VI.C.2.a? No Is this facility classified as a "Bulk Plant" as defined per Regulation 7, Section VI.C.3.a? No Section 04 - SCC Coding Emissions Factor (lb/1,000 Pollutant gallons) VOC 4.2930 b/1,000 gallons Benzene O0063 b/1,000 gallons Toluene 0.0045 b/1,000 gallons Ethylbenzene 0 0004 b/1,000 gallons Xylenes 0.0010 b/1,000 gallons n -hexane O0415 b/1,000 gallons 2,2,4-TMP 0.0036 b/1,000 gallons 40600132: Crude O/: Submerged Loading (Normal Service) Comments I emailed the operator on 5/27/16 regarding the emission calculations: I am confused on what the emissions are from the loadout. The uncontrolled are 29.92 TPY PTE but the APEN is saying controlled is 15.13 TPY with 95% control. That doesn't seem right. And the calculation sheets provided don't seem to match either. Could you please provide some clarification on the loadout emissions? A revised calculation sheet might also be helpful. The operator's consultant called me explaining that not all of the emissions were controlled prior to the installation of the control device (ECD). He said he would provide different calculation sheets that explains this better. I received these calculations on 6/6/2016. I was able to review the calculation sheets and confirm the calculations from this point source. STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 16WE0316 Issuance 1 DATE ISSUED: ISSUED TO: Great Western Operating Company, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Marcus LD Pad, located in the SESE of Section 34, Township 1 North, Range 67 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description Truck Loading 006 Truck loadout of condensate. Emissions from the loadout are controlled by an enclosed combustor. 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 Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 2. 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, I I I. F.4. ) AIRS ID: 123/9E5D Page 1 of 8 Condensate Loadout TM Version 2012-1 Public Health and Environment Air Pollution Control Division 3. 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 4. 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 VOC Truck Loading 006 15.2 Point See "Notes to Permit Holder" 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. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Truck Loading 006 Enclosed combustor VOC, HAP PROCESS LIMITATIONS AND RECORDS 6. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) AIRS ID: 123/9E5D Page 2 of 8 Process/Consumption Limits of Public Health and Environment Air Pollution Control Division AIRS Point Process Parameter Annual Limit 006 Condensate Loading 331,989 BBL The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 7. 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.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 8. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III. 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect onsite loading equipment during loading operations to monitor compliance with above conditions. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 11. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. AIRS ID: 123/9E5D Page 3 of 8 Co hdo • ; p. '" e o" Public Health and Environment Air Pollution Control Division OPERATING & MAINTENANCE REQUIREMENTS 12. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) 13. The owner or operator of a loadout to control emissions shall: a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back pressure less than the pressure relief valve setting of transport vehicles. e. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. f. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are routed to the control device under normal operating conditions. g Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. COMPLIANCE TESTING AND SAMPLING 14. This source is not required to comply with any testing and sampling requirements. 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 (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NOx per AIRS ID: 123/9E5D Page 4 of 8 a olds of Public Health and Environment Air Pollution Control Division :Sur' GG::Ra efi' 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. 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 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 11.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 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. AIRS ID: 123/9E5D Page 5 of 8 Public Health and Environment Air Pollution Control Division 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 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. 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: Stephanie Spector, PE Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Great Western Operating Company, LLC. Newly permitted truck loadout at a synthetic minor facility. AIRS ID: 123/9E5D Page 6 of 8 1 "%i s1 _ m �n Notes to Permit Holder at the time of this permit issuance: men of Public Health and Environment Air Pollution Control Division 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: https://www.colorado.gov/pacific/cdphe/aqcc-regs 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 # BIN Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 006 Benzene 71432 A 88 NO 45 Toluene 108883 C 63 NO 32 Ethylbenzene 100414 C 5 NO 3 Xylenes 1330207 C 14 NO 7 n -Hexane 110543 C 579 YES 293 5) The emission levels contained in this permit are based on the following emission factors: CAS Pollutant Emission Factors Uncontrolled lb/100 gal loaded - Source Emission Factors Lb/1000 gal loaded — Controlled Source VOC 4.2930 AP -42 0.2147 AP -42 110543 n -hexane 0.0415 Engineering Calculation 0.0021 Engineering Calculation The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 4.44 psia M (vapor molecular weight) = 67 Ib/Ib-mol T (temperature of liquid loaded) = 518.16 °R AIRS ID: 123/9E5D Page 7 of 8 0 Public Health and Environment Air Pollution Control Division The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors from the ProMax simulation model by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95%. 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 Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -hexane NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXX)OCX 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: 123/9E5D Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 — Applicant Information Company Name: Great Western Operating Company, LLC Permit Number: 16WE0314 Source Location: Marcus LD Pad SESE Section 34, T1 N, R67W, Weld County (non -attainment) Description Heater treater to reduce flash emissions. AIRS ID: 123-9E5D-004 Date: May 31, 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 Information Request letter to the source? See Section 14 On what date was this application complete? February 1, 2016 Section 4 — Source Description AIRS Point Equipment Description 004 Heater treater to reduce flash emissions. Vapor recovery unit (VRU) emissions are a function of condensate throughput during VRU downtime The flare is enclosed. Is this a portable source? Yes X No Is this location in a non -attainment area for any criteria pollutant? X Yes No If "yes", for what pollutant? PMio CO X Ozone Is this location in an attainment maintenance area for any criteria pollutant? Yes X No If "yes", for what pollutant? (Note: These pollutants are subject to minor source RACT per Regulation 3, Part B, Section III.D.2) PM10 CO Ozone Is this source located in the 8 -hour ozone non - attainment region? (Note: If "yes" the provisions of Regulation 7, Sections XII and XVII.C may apply) X Yes No Page 1 Section 5 — Emission Estimate Information AIRS Point Emission Factor Source 004 VOC and HAPs: Site -specific using ProMax Simulation model. NOx and CO: AP -42, Table 13.5-1 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 004 33,199 BBL/YR Basis for Actual Emissions Reported Durinq this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 004 27,666 BBL/YR Projected Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 004 33,199 BBL/YR Does this facility use control devices? X Yes No AIRS Point Process Control Device Description % Reduction Granted 004 01 Enclosed flare 95 Section 6 — Emission Summary (tons per year) Point NO, VOC CO SOx PM10 Single HAP Total HAP PTE: 004 0.2 193.0 0.8 ---(n-hexane) 2.2 3.1 Uncontrolled point source emission rate: 004 0.2 9.7 0.8 --- 0.1 (n -hexane) 0.2 TOTAL PERMITTED (TPY) 004 0.2 9.7 0.8 0.1 (n- hexane) 0.2 Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (Iblyr) Are the emissions reportable? Controlled Emission Ibl r Rate ( Y ) Benzene 71432 A 652 Yes 33 Toluene 108883 C 539 Yes 27 Ethylbenzene 100414 C 50 No 3 Xylenes 1130207 C 149 No 7 n -Hexane 110543 C 4345 Yes 218 2,2,4-Trimethylpentane 540841 C 422 Yes 21 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 X Yes No standard? AIRS Point Process Pollutant Regulatory Basis Test Method Page 2 004 01 Opacity Regulation No. 1, Section II.A.5 EPA Method 9 Section 9 - Source Classification What is this facility classification? True Minor X Synthetic Minor Major Classification relates to what programs? X Title V PSD X NA NSR X MACT Is this a modification to an existing permit? Yes X No If "yes" what kind of modification? Minor Synthetic Minor Major Section 10 — Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If "yes", for which pollutants? Why? VOC For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? Yes X No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 — Modeling Is modeling required to demonstrate compliance with National Ambient Air Quality Standards (NAAQS)? Yes X No If "yes", for which pollutants? Why? NOx emissions are less than 40 TPY. AIRS Point Section 12 — Regulatory Review Regulation 1 - Particulate. Smoke, Carbon Monoxide and Sulfur Dioxide 004 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 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. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases 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 2 — Odor 004 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 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 004 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 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) ' 004 Part B — Construction Permit Exemptions 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 004 None Page 3 Regulation 7 — Volatile Organic Compounds 004 None Regulation 8 — Hazardous Air Pollutants 004 None Section 13 —Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Factor Pollutant/ CAS # Fugitive (Y/N) Emission Factor Source Control (%) 004 01 Flare 11.6296 lb/BBL VOC No Engineering Calculation 95 0.068 Ib/MMBtu NOx No AP -42, Table 13.5-1 NA 0.31 lb/MMBtu CO No AP -42, Table 13.5-1 NA 0.0197 lb/BBL Benzene No Engineering Calculation 95 0.0162 Ib/BBL Toluene No Engineering Calculation 95 0.0015 lb/BBL Ethlybenzene No Engineering Calculation 95 0.0045 lb/BBL Xylenes No Engineering Calculation 95 0.1309 lb/BBL n -hexane No Engineering Calculation 95 SCC 31000205 -Flares Page 4 Section 14 — Miscellaneous Application Notes AIRS Point 004 Flare Source requires a permit because uncontrolled emissions are greater than 1 TPY (APEN threshold) and total facility uncontrolled VOC are greater than 2 TPY (Permit threshold). There are no categorical exemptions for this point source. Source used AP -42, Table 13.5-1 to calculate emissions of NOx and CO. The flash rate was provided on operator's calculation sheet. The PTE emissions are: Flash rate = Average gas flow* Net Ideal Gas Heating value (from ProMax Model) = (2.298 mmscf/yr) * 2118.87 btu/scf = 4869.16 MMbtu/yr. NOx = 0.068 lb 4869.16 mmbtu 1 T =0.1656 TPY NOx (0.2 TPY) mmbtu yr 2000 lb CO = 0.31 lb 4869.16 mmbtu 1 T =0.7547 TPY CO (0.8 TPY) mmbtu yr 2000 lb Operator provided VOC and HAP emissions using a ProMax Simulation model. The ProMax model is based on 1 bbl/day. Operator is requesting a throughput of 33,199 BBUyr. Emissions generated from the flare are: Emissions (TPY) = (Throughput/365) * (lb/hr)*8760/2000 PTE = 33199/365 = 90.95616438 bbl/day Uncontrolled Emission Total (lb/hr) Uncontrolled Controlled Controlled factor ProMax Total (TPY) Total (lb/yr) Total (TPY) (lb/bbl) VOC 0.484566994 --- 193.0457 -- 9.65 11.6296 Benzene 0.000818826 652 0.3262 33 0.02 0.0197 Toluene 0.000676531 539 0.2695 27 0.01 0.0162 Ethylbenzene 0.0000632189 50 0.0252 3 I 0.001 0.0015 Xylenes 0.000186424 149 0.0743 7 0.004 0.0045 n -hexane 0.00545351 4345 2.1762 218 0.11 0.1309 224-TMP 0.000528992 422 0.2107 21 0.01 0.0127 There were two gas analyses p ovided and perfomed less than a year of submittal and then an average was taken for the ProMax model. Both extended gas analyses provided in the application dated 11/4/2015. An updated extended gas analysis will not be required because an extended gas analysis was performed within a year of this submittal and included with this package. I emailed the operator on 5/31/16 regarding the gas analyses and ProMax. I was not seeing how the provided analyses are matching the "composite HC liquids Analysis" calculation sheet. I received more guidance from the consultant on 6/6/2016: Background Information The oil and gas industry utilizes computer simulation to estimate emissions from an oil production facility, used in applying for the required permits to operate. The simulation is based on data obtained from the site, particularly a liquid sample which is analyzed by a third -party laboratory. This data is input into the simulation with as little manipulation as possible in an effort to model emissions based on the production facility's operating conditions i.g. temperature, pressure, location elevation etc. The process simulation software contains a vast database of physical and chemical properties of components of which oil and gas streams are comprised. The software utilizes fundamentals of equilibrium and steady-state thermodynamics to quantify the vapor and liquid streams in addition to their respective compositions. ProMax is an industry -approved process engineering software and is developed and licensed by Bryan Research and Engineering, Inc. Page 5 AIRS Point 004 Flare continued Generally, the liquid sample is obtained at the facility's production separator where actual temperature and pressure are also recorded. When the sample is obtained from the production separator the protocol is to input the laboratory report compositional data into the model, in addition to the reported temperature and pressure. The simulation's results are subsequently used to develop emission factors. These factors are applied to known site production quantities to conservatively estimate the facility emissions. The liquid sample analysis provided was obtained from the heater treater as opposed to the production separator. Because this sample is in theory a bubble point liquid, i.e. contains no vapor phase, it is necessary to "back - calculate" the vapor and liquid streams from which it is derived using the unit operation called 'saturator block" in ProMax, depicted below as Sat -1. In order to use the saturator block a vapor composition needs to be estimated. This is accomplished by using the liquid composition provided by the laboratory analysis and assigning it a slight vapor fraction by allowing the temperature to vary. The resulting vapor composition is then applied to stream 2 — Inlet Gas , the saturant, shown in Figure 2. The saturator block essentially combines the liquid and vapor streams at the known production separator temperature and pressure conditions. Using the Peng-Robinson equation of state, ProMax calculates the resulting stream which is now saturated with the theoretical amount of vapor entrained in the liquid stream. As the oil routes to downstream facility equipment and the stream pressures and temperatures are altered, compositions and flowrates are calculated. The resulting composition of stream 7 — HT Lq (Calc'd), in Figure Z should compare to the liquid analysis provided by the laboratory, thus validating this procedure. Consequently, Streams 6 and 8 can then be used to estimate the facility emissions. It is important to note that Great Western's Simpson Pad is not equipped with a Vapor Recovery Tower (VTR). 1 - Inlet Liq SAT -1 2 - Inlet Gas 3 - Sat'd Liq 4 - Prod Sep Gas to Comp Production Separator Prod Sep Liq Figure 2 Great Western Oil & Gas Simpson Pad 6 - HT Gas to VRUs Heater Treater 7- HT Liq (Calc'd) e - Atm Gas to ECD Atmospheric Storage 0 - Oil Produc Page 6 Emission Source AIRS ID: 9-7 o VRU Downtime a N n Section 02— Requested Action (check applicable request boxes) Section 01 —Administrative Information ck each box below that applies) Request for NEW permit or at ❑ a Federally enforceable limit on PTE c V a Request ADEN update only (check the box below that applies) ❑ ❑ ❑ Q -t N GC O _ VG E a zv — N Great Western Operating Comp Marcus IA Pad SESE Sec 34 TIN R67W 1801 Broadway, Suite 500 ❑ ❑ Phone Number: (303) 398-0302 ai To Contact C mail Address: Section 03 — General Information V. N > G L C v cc N [�1 �. E O E � 0 L .0 N 7 S F v Z W CC 0 TE E N F E E cat O o E Molecular Wt. eq eo M L cc O e ®® FORM APCD-21 I a LA . er- g ai m 0. N O'1 = rr o • C CJ L u O L z C V1 a a W z U C z z rte. a C Permit Number: Section 06 -Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) O N a) N -o Y C Section 05 — Stack Information (Combusti 0 o `o N� CEE tib O N O A m O A o ❑ U 471 at O ca oe N e 0 00 e m en e On O u J � 0.' oQ ✓ . n ✓ : Other (Describe): Width (inches) = A C _ Q Of) 0 II L O 3 o d o C N ❑ >C A O - > u d e s co Ot Section 07 — Control Device Information to c CZ u x :F ® Combustion Device used for control of: Make/Model/Serial # (4) Enclosed Combustors 038 P Manufacturer Guaranteed: H N Waste gas heat content: 0 O O z Heater Treaters VRU used for control of: Make/Model: b y e e U V OO Lo 0 0 U ¢ U O U, C 5 O a 0 N ei a 0 a G L C C c E E ° W W C — Q o C U c c C 3 o a m C E 0 C ao C O � O L y C y C E u o m C c W O m y V � O C., O E I d 00 T o n C o CS Estimation Method or Emission Factor Source Eng. Est. N S Q N Q Q Eng. Est. Eng. Est. W el C 0 Eng. Est. Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) in V O: N Hi 0 e\ N 0 N O 0 Hi O 0 Hi O 0 — .. 0 Uncontrolled (Tons/Year) e O q n In O 10.27 I N O N Actual Calendar Year Emissions° Controlled (Tons/Year) C 0 e C 0 O; e C e 0 0 ON O e Uncontrolled (Tons/Year) N O e 0.27 N N o co H o •.. W .. Emission Factor w a a C a C i; a a a = s a a a .c z a Uncontrolled Basis en .. W O 0 M e N O\ O � N O e N N C e O O en o Control Efficiency (% Reduction) It O. VI P an T on T T Overall Collection Efficiency C = e e O o O ^ Control Device Description Primary Secondary O U U U ECD ❑ U a U VRU VRU o > o > o CL > E a ® o. U O x Oz o x O Benzene w o F Ethylbenzene 224 TMP u i° s C U L U ea C C Y a E 0 is u 0. O. t 2 a y C O Ca E 0 C e a C- .e 1 Ca C O C O a L e O b N N L ❑ >. O. C 00 0 N O Y C Q CZ O0 a O a O IS C m AP Form APEN VRU Downtime pk O 00 0. FORM APCD-211 1j Permit Number: Truck Loading Facility Equipment ID: Section 02 — Requested Action (Check applicable request boxes) Section 01 — Administrative Information General Permit GP07 E G O C O Great Western Operating Company, LLC u V L = 0 C y ` E i aS = u ° E _ O V `• w G E c 7! E u C U ✓ VO ✓ R q g o L = G j v V VF o '; T • 2 O 2 R C R O P ` < s - G Z 2: I= .o ✓ V V a J g.442:400 ` x ❑oD ❑o Co z H M U co w W 0 0cz Change company rim 7 G Y e ❑ a u • E A^' u C O E ▪ Le R R u C_ c u • W u a z R ra 0 0 U a < 9 _ G 0 O G E z_ U A o < w oo R = v u ai n 3 0 E F - ❑o F 0 asa E o ` tau to a c c La C cu 1801 Broadway, Suite 500 co cr Denver, CO N O m sdonato@gwogco.com Fax Number: Phone Number: (303) 398-0302 CO O N a N C LL to O -o W L_ N O c O N c 0 E m N 0 H Section 03 — General Information V a) LO a) at a N- 7) O N ro c o `o o p N C C m CU. 2 O s O O ` ry O E 0 z C ern N N m m O E 0 at to C N 0 O m a N O O 0 Don't know ❑ ❑ OOO z z z z z > > r r r o❑❑o❑ <V < < ; u u O O o a, o O 3 R U C E C "5" 2 v c 004 R 7.5 R C E c - a C E ` .- - C c ✓] ti C O 72 a a 7< G n m < x C Z Z _ E C .15 c00 `n v, N m m N N N T T T 0 0 '0 M CO 0 0 0 to �� _ an c O U U ^ `c y � 3 0 L N c 0 < L � Fe o e-) v Pe;Z'o V E.O 7 g s ` o G V u 07O- =— 0 0 tr)Ci 0c. CG N O C n = - a L se Ls ' 't CO < 0 0 ✓ R E m = C 7-0 0 R 0. = _ >- o ♦ ♦ ♦ < • Vi A T r COLO CD N E .5 T at F a G V n U V L � O a G p c L V V T C L L U ✓ V L 2 E• o C a m 0i o R E M 9 .. u c u R G y = F Y u a e � co a) FORM APCD-208 inLiyuidLoadingAPEN-Ver 4-14-2 G R O O b A W if no combustion Section 06 —Stack G Az en • N W co O ✓ CO N 0 a O C a 0 r v bhp V O Li) m 0▪ 0 tII E O • 5 > q U c r o w. V W � Ci z 0 .2 N 0 y 0 U Section 07 — Control Device Information Section 08 — Emissions Inventory Information a p CO O C K I+) G J a a O C C) C1 N O O W 2 O U a co 8 O C X G J 0.0 8 O v C) W a O U Data year for actual calendar year emissions below & throughput in Sec. 04 (e.g. 2007): Estimation Method or Emission Factor Source AP42 AP42 AP42 L. Eng. Est. Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) co O 6 r r V r O U, ,- O Uncontrolled (Tons/Year) N C) N O N 6 Actual Calendar Year Emissions5 Controlled (Tons/Year) Oc`i O O 1-O .- O r O Uncontrolled (Tons/Year) 24.94 N N O Emission Factor J A 2 m .a m .0 o o a o Uncontrolled Basis to N CO O N V CI, O O O Control Efficiency (% Reduction) Lo t oi4aeg of Control Device Description o v L Pollutant °z VOC O v 0 s CZ ao 00 m 2 a u 9 e r m C d L 0.1 E o m u a e ▪ u C CL r • e 7. a e o E 0 EV aELi 10, m w e • EO E fl u c m m L • 0 o • u a 0 � 2 T V a C a C m co .8 o u N O V 10 o 0 • O in L m _ 6. C a m � i a , ' o u e o'.J}' LT _ C s v ,z = m L 2 I © M - a LO e L T tit m d y • U t o y v m c E L o ° L I } G u T a U F n ❑ rm C) a 4.1 m m Scot A. Donato at D-208-HydrocarbonLiquidLoadingAPEN-Ver.4-14-2014 (1).docx N 0 N 00 at Hello