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Home My WebLink About20152160.tiff A COPHE COLORADO co ke Department of Public .0 Health ft Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board RECEIVED 1150O St PO Box 758 Greeley, CO 80632 JUL 1 7 2015 July 13, 2015 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On July 15, 2015, the Air Pollution Control Division will begin a 30-day public notice period for Bill Barrett Corporation - 18530_70 Ranch 4-63-3 Pad 2. 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 6. 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 RUJaUclwau) 1 -a s-020/1 et;"Pc ); I- L -7I e,d 2015-2160 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cup,,,.. John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer '4 •sj A ,,, CDPHE Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Bill Barrett Corporation - 18530_70 Ranch 4-63-3 Pad 2 - Weld County Notice Period Begins: July 15, 2015 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: Bill Barrett Corporation Facility: 18530_70 Ranch 4-63-3 Pad 2 Oil and Gas Exploration and Production Facility NWSW Section 3, Township 4N, Range 63W Weld County The proposed project or activity is as follows: Applicant is requesting permit coverage for condensate loadout (permit #14WE1158) and six vapor recovery towers (VRTs) controlled by external combustion devices during vapor recovery unit (VRU) bypass (permit #14WE1159) at an exploration and production facility. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • 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 Permit 14WE1158 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Harrison Slaughter Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us Ayt.“ COLORADO 1 I ;°: STATE OF COLORADO .of colp,,. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT �w w' AIR POLLUTION CONTROL DIVISION J �i TELEPHONE: (303) 692-3150 * ` '• * 't1876,' CONSTRUCTION PERMIT PERMIT NO: 14WE1158 Issuance 1 DATE ISSUED: ISSUED TO: Bill Barrett Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the 18530_70 Ranch 4-63-3 Pad 2, located in the NWSW of Section 3, Township 4N, Range 63W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Condensate Truck loadout of condensate. Emissions from the loadout Loadout 004 are not controlled. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air- permittinq-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be 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 AIRS ID: 123/9C98 Page 1 of 8 Condensate Loadout TM Version 2012-1 Igp Co A do •` p e' o Public Health and Environment r Air Pollution Control Division on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall 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 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point VOC Emission Type Condensate 004 28.6 Point Loadout 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. AIRS ID: 123/9C98 Page 2 of 8 Co do "" p e o Public Health and Environment Air Pollution Control Division 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) Process/Consumption Limits AIRS Process Parameter Annual Limit Point 004 Condensate Loading 275,638 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. 7. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) STATE AND FEDERAL REGULATORY REQUIREMENTS 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.E) 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.E): 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 (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 loading equipment and operations onsite at the time of inspections to monitor compliance with Condition 10 (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. AIRS ID: 123/9C98 Page 3 of 8 iCo A do a p e o Public Health and Environment I Air Pollution Control Division 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. OPERATING & MAINTENANCE REQUIREMENTS 12. This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING 13. This source is not required to comply with any testing and sampling requirements. ADDITIONAL REQUIREMENTS 14. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 15. 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 AIRS ID: 123/9C98 Page 4 of 8 Co do 1p r e oT Public Health and Environment Air Pollution Control Division 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 16. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation 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. 17. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation 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. 18. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 19. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 20. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 21. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. AIRS ID: 12319C98 Page 5 of 8 ill Co A do • p e o Public Health and Environment I Air Pollution Control Division 22. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Bill Barrett Corporation AIRS ID: 123/9C98 Page 6 of 8 Co do p men' o 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: https://www.colorado.gov/pacific/cdphe/aqcc-reps 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Rate Point Pollutant CAS# (Ib/yr) reportable? (Ib/yr) n-Hexane 110543 2291 Yes N/A Benzene 71432 351 Yes N/A Toluene 108883 964 Yes N/A 004 Ethylbenzene 100414 310 Yes N/A Xylenes 1130207 1156 Yes N/A 2,2,4 540841 506 Yes N/A Trimethylpentane 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Uncontrolled CAS Pollutant lb/BBL loaded Source VOC 0.207 AP-42 110543 n-Hexane 0.00831 Engineering Calculation 71432 Benzene 0.00127 Engineering Calculation 108883 Toluene 0.003499 Engineering Calculation 100414 Ethylbenzene 0.001126 Engineering Calculation 1130207 Xylenes 0.004195 Engineering Calculation 540841 2,2,4 0.001836 Engineering Calculation Trimethylpentane 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 AIRS ID: 123/9C98 Page 7 of 8 Co A dop• e o°'Public Health and Environment Air Pollution Control Division S= 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 5.2 psia M (vapor molecular weight) =66 Ib/Ib-mol T(temperature of liquid loaded) = 520 °R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the VOC emission factor (lbs/bbl) by the ratio of the HAP mass fraction from the liquids analysis to the VOC mass fraction from the liquids analysis. VOCEF,lbs\ (HAP wt fraction in liquids analysis\ EFHap - ( bbl ) * VOC wt fraction in liquids 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 most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane, Total HAPs NANSR Synthetic Minor Source of: VOC, n-Hexane, Total HAPs 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)0CX 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: 123/9C98 Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Bill Barrett Corporation Permit Number: 14WE1158 Source Name: 18530_70 Ranch 4-63-3 Pad 2 Source Location: NWSW Section 3, Township 4N, Range 63W Equipment Description: Truck loadout of condensate (Point 004) AIRS ID: 123-9C98 Review Date: March 10, 2015 Review Engineer: Harrison Slaughter Control Engineer: Chris Laplante Section 2—Action Completed X CP1 Modification APEN Required/Permit Exempt Final Approval 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? Original Submission: 06/30/2014 On what date was this application complete? Updated APEN was submitted on: 02/25/2015 Section 4—Source Description AIRS Point Equipment Description 004 Truck Condensate Loadout Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source N/A PM10 N/A CO N/A Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region? (Note: If"yes"the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Page 1 Is this source located at an oil and gas exploration X Yes No site? If yes, does this source load less than 10,000 gallons of crude oil per day on an annual average, splash fill less than 6750 bbl of condensate(hydrocarbons that 275,638 bbl/yr have an API gravity of 40 degrees or greater) per year Yes X No of condensate or submerged fill less than 16,308 bbl of condensate per year? Is this source located at a facility that is considered a major source of hazardous air pollutant(HAP) Yes X No emissions? Will this equipment be operated in any NAAQS nonattainment area? X Yes No Does this source load gasoline into transport vehicles? Yes X No Section 5—Emission Estimate Information AIRS Point Emission Factor Source AP-42: Chapter 5.2, Equation 1 L = 12.46*S*P*M/T L= loading losses in lb per 1000 gallons loaded 004 S = Saturation Factor P=true vapor pressure of liquid loaded [psia] M = molecular weight of vapors [lb/lb-mole] T=temperature of bulk liquid loaded [deg. R] 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 004 275,638 BBL per year condensate loaded Basis for Actual Emissions Reported During this APEN'Filinq(Reported to Inventory) AIRS Point Process Consumption/Throughput/Production 004 229,698 BBL per year condensate loaded Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 004 275,638 BBL per year condensate loaded Does this source use a control device? Yes X No Section 6—Emission Summary (tons per year) Point NO„ VOC CO Single HAP HAP PTE: 004 --- 28.56 --- 1.145 2.79 (n-hexane) Total --- 28.56 --- 1.145 2.79 (n-hexane) Uncontrolled point 004 --- 28.56 - 1.145 2.79 source emission rate: (n-hexane) Permitted point source 004 --- 28.56 1.145 2 79 emission rate: (n-hexane) Total --- 28.56 1.145 2.79 (n-hexane) Page 2 Uncontrolled Are the Controlled Emission Rate Pollutant CAS# Emission Rate emissions(Ib/yr) reportable? (lb/ r Y ) Benzene 71432 351 Yes N/A n-Hexane 110543 2291 Yes N/A Toluene 108883 964 Yes N/A Ethylbenzene 100414 310 Yes N/A Xylenes 1130207 1156 Yes N/A 2,2,4-Trimethylpentane 540841 506 Yes N/A Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? Section 9—Source Classification Is this a new previously un-permitted X Yes No source? What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what X Title V PSD X NA NSR MACT programs? Is this a modification to an existing permit? Yes X No • If"yes"what kind of modification? N/A Minor N/A Synthetic N/A Major Minor Section 10— Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes", for which pollutants?Why? For Reg. 3, Part B, III.C.1.a (emissions increase> 25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.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 Yes X No Air Quality Standards (NAAQS)? AIRS Point Section 12—Regulatory Review Regulation 1 - Particulate, Smoke, Carbon;,Monoxide and Sulfur Dioxide Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of 004 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.) Regulation 2—Odor Section I.A- No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are 004 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. Page 3 Regulation 3-APENs, Construction Permits, Operating Permits, PSD 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 tons per year or more of any individual criteria pollutant(pollutants are not summed) for which the area is non-attainment. 004 (Applicant is required to file an APEN since emissions exceed 1 tons per year VOC) 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) Part B, III.D.2 - RACT requirements for new or modified minor sources This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or attainment/maintenance areas. This source is located in the 8-hour ozone nonattainment area, but not in the 1-hour ozone area. The date of interest for determining whether the source is new or modified is 004 therefore November 20, 2007 (the date of the 8-hour ozone NA area designation). The date operation began, for the condensate tanks at the facility, is designated as April 01, 2014. Since the tank battery from which loadout is occurring came into service since after the date above, this source is considered "new or modified." Operator is using submerged fill (0.6 saturation factor), therefore, RACT requirements are satisfied. Regulation 6-New Source Performance Standards 004 No applicable subpart. This facility is not a bulk gasoline terminal. Regulation 7-Volatile,Organic Compounds No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum liquid storage and distribution facility that has a daily average throughput of more than 004 76,000 liters of gasoline(20,000 gallons), which is loaded directly into transport vehicles. This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C. Regulation 8—Hazardous Air Pollutants 004 None Section 13—Aerometric Information Retrieval System Coding Information Process/ Emission Process Emission Pollutant/ Fugitive Control Point Process Description throughput Factor CAS# (Y/N) Factor (%) Limit Source 4.93 lb/1,000 VOC No AP-42 N/A gallon throughput 0.0303 lb/1,000 Benzene/ Engineering gallon 71432 No Calculation N/A throughput 0.198 004 01 Truck Condensate 275,638 lb/1,000 n-Hexane/ No Engineering N/A Loadout BBUyr gallon 110543 Calculation throughput 0.0833 lb/1,000 Toluene/ Engineering gallon 108883 No Calculation N/A throughput 0.0268 lb/1,000 Benzene/ No Engineering N/A gallon 100414 Calculation throughput Page 4 0.0999 lb/1,000 Xylenes/ Engineering gallon 1130207 No Calculation N/A throughput 0.0437 lb/1,000 2,2,4-TMP Engineering gallon /540841 No Calculation N/A throughput SCC 40600132: Crude Oil: Submerged Loading (Normal Service) Section 14—Miscellaneous Application Notes AIRS Point 004 Truck Condensate Loadout Units Basis S 0.6 Submerged loading: dedicated normal service based on source's description P 5.2 Psia Based on AP 42 Chapter 7 Table 7.1-2; True vapor pressure for gasoline RVP 10 at 60°F. Sales oil analysis provided in application indicates RVP = 9.1. M 66 Lb/lb-mole Based on AP 42 Chapter 7 Table 7.1-2;Vapor Molecular Weight for gasoline RVP 10 at 60°F. Sales oil analysis provided in application indicates RVP = 9.1. T 520 Deg R Based on source's knowledge of bulk liquid temperature L 4.93 Lb/10^3 gal This value is used to calculate annual emissions 0.207 Lb/bbl AP-42: Chapter 5.2 Equation 1 L = 12.46*S*P*M/T L = loading losses in lb per 1000 gallons loaded S = Saturation Factor P =true vapor pressure of liquid loaded [psia] M = molecular weight of vapors [lb/lb-mole] T=temperature of bulk liquid loaded [deg. R] L 4.931b/10^3 gal 2.07E-01 lb/bbl Annual requested Throughput 11,576,796ga1/yr Annual requested VOC emissions 57,122lb/yr 28.6tpy Page 5 Section 14—Miscellaneous Application Notes AIRS Point 004 Truck Condensate Loadout The emission factors for Benzene and n-Hexane were calculated using the following method: (VOCEF,lbs) * (HAP wt fraction in liquids analysis EFHap = l bbl \VOC wt fraction in liquids analysis) Given Information: Pollutant Wt. Fraction in Liquids Analysis VOC (NMNE) 97.7912 Benzene 0.6008 n-Hexane 3.9212 Toluene 1.6511 Ethylbenzene 0.5313 Xylenes 1.9796 2,2,4-Trimethylpentane 0.8663 Sample Calculation: 0.207 lbs VOC) r 0.6008 l _ 0.001273 lbs Benzene EFbenzene = ( bbl * \97.79121 bbl APEN Updates/Redlines: 1. Actual calendar year data was added to the APEN. This was to ensure yearly emissions were calculated based on the actual emissions rather than potential emissions. The resulting emissions were updated on the APEN. 2. The emission factors for benzene and n-Hexane were incorrectly calculated. The operator was notified of the error and the emission factors were updated. The actual and requested emissions on the APEN were updated to reflect the new emission factors. 3. Emission Factors and resulting emissions for Toluene, Xylene, Ethylbenzene, and 2,2,4- Trimethylpentane were added to the non-criteria reportable APEN addendum form because they are all reportable HAPs. This information is also included in the notes to permit holder section of the permit. Permit Notes: 1. The operator was provided with a draft permit prior to beginning public notice. They expressed that they did not have any comments on the draft permit. Page 6 umnr 74,7-7.21 41 a STATE OF COLORADO pF-cot LOR D T N FP C HEALTH AND ENVIRONMENT aw �� AIR POLLUTION CONTROL DIVISION 4 '� TELEPHONE: (303) 692-3150 `� *1876 CONSTRUCTION PERMIT PERMIT NO: 14W E1159 1 59 Issuance 1 DATE ISSUED: ISSUED TO: Bill Barrett Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the 18530_70 Ranch 4-63-3 Pad 2, located in the NWSW Section 3, Township 4N, Range 63W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Six (6) vapor recovery towers (VRTs) used to reduce flash emissions. Emissions are a function of condensate throughput VRTs 005 during vapor recovery unit (VRU) downtime. 35% VRU downtime is assumed. The VRTs are controlled by three (3) enclosed combustors during VRU downtime. Enclosed combustors have a minimum control efficiency of 95%. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air- permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify AIRS ID: 123/9C98 Page 1 of 9 olor_ pzDepa en . •Ii Health and Environment it Pollution Control Division compliance w. •n• to : ate c• ..nce within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, I II.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type X VRTs 005 1.7 41.5 9.0 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. AIRS ID: 123/9C98 3 9C98 Page 2 of 9 e vm Vt- 'olor iDepa en &P , li 'Health and Environment I it Pollution Control Division The permit h I c t sioa onth . eep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID VRTs 005 Three (3) Enclosed Combustors VOC, HAPs PROCESS LIMITATIONS AND RECORDS 9. 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) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID VRTs 005 Condensate throughput through VRTs while 96,473 BBL VRUs are being bypassed The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. 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) 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. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS AIRS ID: 123/9C98 Page 3 of 9 olorl Depa en ' ill Health and Environment 'it Pollution Control Division 13. Upon startup _. e -, -wn- --rator :. :-F I 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.) 14. Within 180 days after issuance of this permit, the owner or operator shall continuously monitor and record VRU downtime while emissions are routed to the backup Enclosed Control Devices using a SCADA (supervisory control and data acquisition) system. The owner or operator shall use monthly VRU downtime records, monthly condensate throughput records and calculation methods detailed in the O&M Plan to demonstrate compliance with the process and emissions limits specified in this permit. After issuance of this permit and prior to startup of the SCADA monitoring system, the operator shall monitor and record VRU downtime manually through site visits a minimum of once per week until the SCADA monitoring system is continuously monitoring and recording VRU downtime, at which point the manual checks for VRU downtime are no longer required. If the VRU is observed to not be operating during a site visit, the operator must record downtime hours as the number of hours elapsed since the last time the VRU was observed to be operating. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The operator shall complete a site specific extended liquids analysis of a pressurized liquid sample from the low pressure outlet of the three-phase inlet separator. Results of sampling shall be used to verify the emissions factor(lb VOC/bbl) for the VRT emissions stream used in the permit application. The VOC site specific emission factor shall be verified using ProMax modeling and the site specific extended liquids analysis. ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or AIRS ID: 12319C98 Page 4 of 9 '.�✓ to a y .,� _..,. �� qq 4tolora?�-Depar en hf Pl li Health and Environment •it Pollution Control Division rl For anx b rite l e p al 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. 17. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the 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. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This AIRS ID: 123/9C98 Page 5 of 9 olorl Depa en : P •li Health and Environment it Pollution Control Division E3 permit may b= . a ti - -r t• - ficati•.: -• 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. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Bill Barrett Corporation AIRS ID: 123/9C98 Page 6 of 9 Ft- olor Depa ens f P li Health and Environment Vas it Pollution Control Division Notes to Permit Holder ime o e an . 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.qov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&paqename=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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Rate Point Pollutant CAS# (lb/yr) reportable? (Ib/yr) 005 Benzene 71432 4,513 Yes 226 005 n-Hexane 110543 29,656 Yes 1,483 005 Toluene 108883 3,366 Yes 168 005 Ethylbenzene 100414 307 No 15 005 Xylenes 1130207 913 Yes 46 005 2'2'4 540841 2,250 Yes 113 Trimethylpentane 5) The emission levels contained in this permit are based on the following emission factors: Point 005: Weight Emission Emission Fraction Factors Factors Pollutant of Gas Uncontrolled Controlled Source (%) lb/bbl lb/bbl NOx(lb/MMBTU) --- 0.068 0.068 AP-42 CO (lb/MMBTU) --- 0.37 0.37 AP-42 VOC 75.7 17.21 0.86 Engineering Calculation Benzene 0.20 0.0468 0.00234 Engineering Calculation AIRS ID: 123/9C98 Page 7 of 9 olor A Depa en . • .11 Health and Environment it Pollution Control Division -ig g.- .'on ..a.. ,. .- sion Fraction Factors Factors Pollutant of Gas Uncontrolled Controlled Source (%) lb/bbl lb/bbl Toluene 0.20 0.0349 0.00175 Engineering Calculation Ethylbenzene 0.01 0.0032 0.00016 Engineering Calculation Xylenes 0.04 0.0095 0.00048 Engineering Calculation n-hexane 1.4 0.3074 0.015 Engineering Calculation 2,2,4- 0.10 0.0233 0.0012 Engineering Trimethylpentane Calculation 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane, Total HAPs NANSR Synthetic Minor Source of:VOC, n-Hexane, Total HAPs MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.q poaccess.qov/ 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 AIRS ID: 123/9C98 Page 8 of 9 M olor Depa en & P li Health and Environment it 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: 12319C98 Page 9 of 9 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Bill Barrett Corporation Permit Number: 14WE1159 Source Location: 18530 70 Ranch 4-63-3 Pad 2 NWSW Section 3, Township 4N, Range 63W(Weld County) Six(6)VRTs where liquid from separator is flashed. Flashed gas is Equipment Description: routed a VRU and recycled in a pipeline 65% of the time. During the 350/0 downtime,the flash gas is controlled with three(3)enclosed combustion devices with an efficiency of 95%. AIRS ID: 123-9C98-005 Date: 03/13/2015 Review Engineer: Harrison Slaughter 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? Yes X 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 The source did not provide an O&M Information Request letter to the source? Plan for the VRT to be permitted. An email was sent to the operator on 03/24/15 requesting the O&M plan. An O&M plan was received from the operator on 04/14/2015 Original Submission: 06/30/2014 On what date was this application complete? Updated APEN was submitted on: 02/25/2015 Section 4—Source Description AIRS Point Equipment Description Six(6)VRTs where liquid from separator is flashed. Flashed gas is routed a VRU 005 and recycled in a pipeline 65% of the time. During the 35% downtime,the flash gas is controlled with three(3) enclosed combustion devices with an efficiency of 95%. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria Yes No pollutant? Page 1 If"yes", for what pollutant? PMto CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source N/A PM,o N/A CO N/A Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region?(Note: If"yes"the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Section 5—Emission Estimate Information AIRS Point Emission Factor Source Operator provided site-specific emission factors determined through the use of a Pro-Max 005 simulation with a basis production rate of 1 bbl/day. Please refer to section 14 for calculations. 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 005 96,473 bbl/year(Representative of 35% of condensate throughput during VRU downtime) Basis for Actual Emissions Reported During this APEN Filing(Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 005 80,394 bbl/year(Representative of 35% of condensate throughput 2014 during VRU downtime) Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 005 96,473 bbl/year(Representative of 35% of condensate throughput during VRU downtime) Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 005 01 VRU used to capture flash gas and route to sales pipeline 100 005 02 Three(3)48" Leed Enclosed Combustors 95 Section 6 Emission Summary (tons per year) Point NO„ VOC CO Single HAP Total HAP PTE: 005 1.7 830.1 9.0 14.9 20.5 (n-Hexane) Uncontrolled point 005 1.7 830.1 9.0 14.9 20.5 source emission rate: (n-Hexane) Controlled point 005 1.7 41.5 9.0 0.8 1.1 source emission rate: (n-Hexane) Total APEN Reported 005 1.7 41.5 9.0 0.8 1.1 emissions: (n-Hexane) Uncontrolled Are the Controlled Emission Rate Pollutant CAS# Emission Rate emissions (Ib/yr) reportable? (Ib/yr) Benzene 71432 4,513 Yes 226 n-Hexane 110543 29,656 Yes 1,483 Page 2 Toluene 108883 3,366 Yes 168 Ethylbenzene 100414 307 Yes 15 Xylenes 1130207 913 Yes 46 2,2,4-Trimethylpentane 540841 2,250 Yes 113 Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory X Yes No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method VOC, Site specific 005 01 HAPs State only requirement extended natural gas liquid analysis Section 9—Source Classification Is this a new previously un-permitted X Yes No source? What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what X Title V PSD X NA NSR MACT programs? Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? N/A Minor N/A Synthetic N/A Major Minor Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes",for which pollutants?Why? For Reg. 3, Part B, III.C.1.a (emissions increase>25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? AIRS Point Section 12—Regulatory Review Regulation 1 Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which 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, 005 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 Page 3 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 005 measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7)or more volumes of odor free air. Regulation 3-APENs. Construction,Permits, Operating Permits, PSD Part A-APEN Requirements Criteria Pollutants: For criteria pollutants,Air Pollutant Emission Notices are required for: 005 each individual emission point in a non-attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant(pollutants are not summed) for which the area is non-attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) Part B—Construction Permit Exemptions 005 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 005 None Regulation 7—Volatile Organic Compounds Section XVII.G: Was the well newly constructed, hydraulically fractured, or recompleted on or after August 005 1, 2014? No(cover letter states that wells began producing on April 01, 2014) • -The separator is not subject to Regulation 7, Section XVII.G and control requirements of Regulation 7, Section XVII.B.2 Regulation 8 Hazardous Air Pollutants MACT HH 005 • This source is not subject to MACT HH because it is not located at a major source of HAP. Section 13—Aerometric Information Retrieval System Coding Information Pollutant Process Emission Fugitive Control Point Process Description Factor / (Y/N) Emission Factor Source (%) CAS# 17.21 VOC No Engineering Calculation 95 lb/bbl 0.068 NOx No AP-42 Table 13.5-1 N/A Ib/MMBtu 0.37 CO No AP-42 Table 13.5-1 N/A lb/MMBtu 0.0468 Benzene No Engineering Calculation 95 lb/bbl /71432 Six(6)VRTs 0.3074 n- Hexane 02 controlled by three lb/bbl 110543/ No Engineering Calculation 95 005 (3)ECDs during 0.0349 Toluene/ VRU downtime lb/bbl 108883 No Engineering Calculation 95 0.0095 Xylenes/ No Engineering Calculation 95 lb/bbl 1130207 0.0032 E lb/bbl Benzene No Engineering Calculation 95 /100414 0.0233 2,2,4 lb/bbl TMP/ No Engineering Calculation 95 540841 SCC 31000205-Flares Page 4 Section 14—Miscellaneous Application Notes Six(6)VRTs where liquid from separator is flashed. Flashed gas is routed a AIRS Point 005 VRU and recycled in a pipeline 65% of the time. During the 35% downtime, the flash gas is controlled with three(3)enclosed combustion devices with an efficiency of 95%. A permit will be issued because the uncontrolled VOC emissions are greater than 1 TPY(APEN threshold)and greater than 2 TPY(permit threshold). The operator utilized site specific emission factors. The site specific liquid analysis provided in the application was utilized as an input for a Pro-Max simulation (i.e. mole% of each component of liquid stream). The Pro-Max flash simulation was run using a basis rate of 1 barrel/day. The output of the Pro- Max simulation resulted in rates of VRT gas reported in (Ib/hr)/(1 bbl/day). These outputs were the basis for the emission factors reported on the APEN and are as follow: Pollutant Pro-Max VRT Gas Stream Rate(lb/hr/bbl/day) VOC 0.71701 Benzene 0.00195 n-Hexane 0.01281 Toluene 0.00145 Xylenes 0.000394 Ethyl benzene 0.000132468 2,2,4-Trimethylpentane 0.000971811 The calculations used to determine the emission factors in lb/bbl as reported on the APEN are as follow: Given Information: • Requested Throughput (based on 35% of condensate throughput) = 96,473 bbl/year(264.3 bbl/day). This throughput is based on the estimated 35% downtime of the VRU, which typically routes the flash gas to a sales pipeline. Calculation: EF(Ib/bbl) = EFproMax *24hrs/day Example Calculation for VOC: 0.71701 24hrs 17.211b EFvoc = (1bbl) * day = bbl day **Actual and calendar year emissions reported on the APEN were calculated by multiplying the emission factors (lb/bbl) by the actual and requested throughputs. APEN Redlines: 1. The emission factors reported on the APEN were updated to reflect units of lb/bbl. 2. It was determined that Toluene, Xylene and 2,2,4-TMP were reportable HAPs. As a result, the APEN was redlined to reflect emissions resulting from these pollutants. Notes: 1. It should be noted that the enclosed flare that controls the VRTs during VRU downtime is the same control device used for the condensate tanks at the facility. Since the condensate tanks are subject to Regulation 7 section XVII, the flares are as well. Due to this, method 22 is the test used to demonstrate compliance and is expressed in the O&M plan. Additionally, the VRTs are not subject to Reg 7; however, the most stringent testing requirement is applied since the condensate tanks are subject to Reg 7. Page 5 Permit Updates: 1. After initial draft permit review the operator expressed that they would like to change the VRU bypass from 10%to 35%. This does not have an effect on the calculation of the emission factors. However, it does affect the permitted process limits and emission limits. As a result, calculations were conducted to confirm the new process limits and emissions proposed by the operator. An updated APEN was also supplied as a result of this change. 2. Additional conditions were added to the permit to address alternate compliance until the SCADA controls are implemented. The operator was provided with an updated draft for review prior to public comment. The operator reviewed the permit and expressed that the changes made to the permit were acceptable and that they did not have any further comments. Page 6 o I., 0 `o 0 Z o 0o n J C Z a. o, o 0 0 0 0 0 a (c W o- r-- ,---; W .O. O N f.' �G _o �o _c 0 W C 4J N N N O • ?' 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