HomeMy WebLinkAbout20153499.tiff 4 CDPHE COLORADO
Department of Public
CO 1 Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board RECEIVED
1150 O St
PO Box 758 (��� Z � z0�5
Greeley, CO 80632
November 17 2015 WELD COUNTY
COMMISSIONERS
Dear Sir or Madam :
On November 18, 2015 , the Air Pollution Control Division will begin a 30-day public notice period for
Bill Barrett Corporation - 19036_Coffelt 5-61 -35_36 NWNW 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 Et 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
?NS- LIC6
etJaatv-i0-0 C,C,: LI et•3, Wu %lam in,54043' ,
- 4,0 -- 1‘ 4300 Cherry Creek Drive S. , Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe J44 ., t≥s 9 `,
John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer r
NA 1876 '4
CDPHE Air Pollution Control Division
co 1
Notice of a Proposed Project or Activity Warranting Public
' Comment
Website Title: Bill Barrett Corporation - 19036_Coffelt 5-61 -35_36 NWNW Pad - Weld County
Notice Period Begins: November 18, 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: 19036_Coffelt 5-61 -35_36 NWNW Pad
Oil and Gas Production Facility
NWNW Section 35 , T5N , R61W
Weld County
The proposed project or activity is as follows: Applicant proposes to flare a portion of gas generated in the
Vapor Recovery Tower and Low-Pressure Separator when Vapor Recovery Units (VRUs) are unable to
compress gas into the sales pipeline. Permit limits are based on 35% VRU bypass.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3 , Part B, Section III .C due to the following reason(s) :
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application .
A copy of the application , the Division 's analysis, and a draft of Construction Permit 15WE1004 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division 's analysis are
available on the Division 's website at https: / /www. colorado.gov/ pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission . The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Any such comment must be submitted in writing to the following addressee:
Bradley Eades
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South , APCD-SS-B1
Denver, Colorado 80246- 1530
cdphe.commentsapcd@state. co. us
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STATE OF COLORADO
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AIR POLLUTION CONTROL DIVISION H :.
TELEPHONE : (303) 692-3150
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\"` 1876
CONSTRUCTION PERMIT
PERMIT NO : 15WE1004
004
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 19036_Coffelt 5-61 -35_36
NWNW Pad , located in the NWNW Sec 35, T5N , R61 W. Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING :
Facility AIRS
Equipment Point Description
ID
Emissions from one ( 1 ) Heated separator and one ( 1 ) Vapor
Recovery Tower (VRT) used to reduce flash emissions. Emissions
VRU are a function of condensate throughput while emissions bypass
Bypass 004 the Vapor Recovery Units (VRU) . 35% VRU bypass is assumed for
permit limits. Emissions are controlled by enclosed combustor(s) .
O
Each combustor has 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 after commencement of operation or issuance of this permit,
whichever comes later, by submitting a Notice of Startup form to the Division . The
Notice of Startup form may be downloaded online at
www. cdphe. state.co. us/ap/downloadforms . html . Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation No. 3, Part B. Section III . G . 1 and can result in the revocation of the permit.
2. Within one hundred and eighty days ( 180) after commencement of operation or issuance
of this permit, whichever comes later, compliance with the conditions contained in this
permit shall be demonstrated to the Division . It is the owner or operator's responsibility to
self-certify compliance with the conditions . Failure to demonstrate compliance within 180
days may result in revocation of the permit. (Reference: Regulation No. 3. Part B,
III .G . 2) .
AIRS ID : 123/9D9A Page 1 of 9
I Depa en . • 11 Health and Environment
/MA it Pollution Control Division
3. This permit sh.4 e ifRob0ra
er or operator of the s •., for which this permit was
issued : (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No . 3, Part B. III . F.4. b. (Reference: Regulation No. 3, Part B,
III . F .4 . )
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
( Reference: Regulation No . 3, Part B. Section III . E. )
5. The operator shall retain the permit final authorization letter issued by the Division , after
completion of self-certification , with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis) . (Reference: Regulation No. 3. Part B, Section II .A.4)
Annual Limits :
Facility AIRS Tons per Year
Emission Type
Equipment ID Point NO, VOC CO
VRU Bypass 004 --- 23.6 1 .9 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.
7. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No. 3 , Part B. Section III . E. )
AIRS ID: 123/9D9A Page 2 of 9
olor_ Depa en lic Health and Environment
• A it Pollution Control Division
Facility -
Control Device Pollutants
Equipment Point Controlled
ID •
VRU 004 Enclosed Combustor(s) VOC. HAPs
Bypass
PROCESS LIMITATIONS AND RECORDS
8 This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3 , Part B, II .A.4)
Process/Consumption Limits
Facility AIRS
Equipment Point Process Parameter Annual Limit
ID
VRU Condensate throughput to Heated Separator
Bypass 004 and VRT while emissions are routed to 21 , 771 BBL/yr
enclosed combustor(s).
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 point number (e.g . 123/4567/890) shall be marked on
the subject equipment for ease of identification . (Reference: Regulation Number 3, Part
B . III . E . ) (State only enforceable)
10. This source is subject to the odor requirements of Regulation No. 2 . (State only
enforceable)
11 . The control device(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. 1 . b If a flare or other combustion device is used to control emissions of volatile
organic compounds to comply with Section XVII . it shall be enclosed . have no
visible emissions during normal operations. and be designed so that an
observer can . by means of visual observation from the outside of the
enclosed flare or combustion device, or by other convenient means approved
by the Division , determine whether it is operating properly. The operator shall
comply with all applicable requirements of Section XVII .
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
AIRS ID : 123/9D9A Page 3 of 9
olor.. Depa en •f • li 1Health and Environment
it Pollution Control Division
12. The separator an RT • er-:J. - . his permit are 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
13. Upon startup of this point, 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.)
14. The owner or operator shall continuously monitor and record VRU downtime while
emissions are routed to the Enclosed Control Device(s) 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.
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 ?00 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN ; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in
ozone nonattainment areas emitting less than 100 tons of VOC or NOX per
year. a change in annual actual emissions of one ( 1 ) ton per year or more or five
percent, whichever is greater. above the level reported on the last APEN ; or
For sources emitting 100 tons per year or more . a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted : or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division .
b Whenever there is a change in the owner or operator of any facility, process, or
activity: or
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
AIRS ID: 123/9D9A Page 4 of 9
olor- Depa en • ' II Health and Environment
A it Pollution Control Division
e. No later than 1 d le - - e ' 4 a . EN ex ',-- .
16. 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) .
17. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil
and Natural Gas Production Facilities major stationary source requirements shall apply
to this stationary source at any such time that this stationary source becomes major
solely by virtue of a relaxation in any permit limitation and shall be subject to all
appropriate applicable requirements of Subpart HH . ( Reference: Regulation No . 8, Part
E)
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 willprovide written documentation r
of such final authorization . Details fo
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
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
AIRS ID: 123/9D9A Page 5 of 9
olor Depa en - . 11 Health and Environment
• it Pollution Control Division
permit. conditio . y -,i..,. • s - po - rmit co . sted 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:
Bradley Eades
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Bill Barrett Corporation
AIRS ID: 123/9D9A Page 6 of 9
olorl Depa en liealth and Environment
it Pollution Control Division
Notes to Permit Holder of ='' me o , s. pe '''' ttsuan
1 ) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A. Section VI . B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard . A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II . Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible. but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II . E. 1 of the Common Provisions
Regulation . See: http://www, colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid= 1251599389641 &pagename=CBONWrapper
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS # (Ib/yr) reportable? Rate (lb/yr)
Benzene 71432 3936 Yes 197
Toluene 108883 3453 Yes 173
Ethylbenzene 100414 640 Yes 32
004 Xylenes 1130207 1 1148 Yes 57
n-Hexane 110543 22111 Yes 1106
2,2,4-
540841 3971 Yes 199
Trimethylpentane
5) The emission levels contained in this permit are based on the following emission factors:
Emission Emission
CAS # Pollutant Factors Factors Source
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
VOC 43.260 2. 163 Engineering
Calculation
NOx 0.0310 0. 031 Engineering
Calculation/AP-42
CO 0. 169 0. 169 Chapter 13
71432 Benzene 0. 1808 0.0090 Engineering
Calculation
108883 Toluene 0. 1586 0.0079 Engineering
Calculation
AIRS ID : 123/9D9A Page 7 of 9
Depa en lid Health and Environment
•
Dit Pollution Control Division
_.=______ Rmissiool_or
�r mission
CAS # Pollutant Factors Factors Source
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
100414 Ethylbenzene 0. 0294 0. 0015 Engineering
Calculation
1330207 Xylenes 0. 0527 0.0026 Engineering
Calculation
110543 n-hexane 1 .0156 0.0508 Engineering
Calculation
540841 2,2.4-TMP 0. 1824 0. 0091 Engineering
Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using a ProMax
simulation that utilized the April 08, 2015 analysis of a pressurized liquid sample collected from the
Coffelt 5-61 -35-0108BH2 well. The controlled VOC and HAP emissions factors for point 004 are
based on the combustor control efficiency of 95%. Combustion emissions factors ( NOx & CO) are
based on HHV (2325 Btu/scf) and GOR ( 169 scf/bbl) modeled in ProMax.
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/Major Source of:
VOC, n-Hexane
NANSR Synthetic Minor/Major 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 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
AIRS ID : 123/9D9A Page 8 of 9
olor. Depa en Ii- •
A it Pollution
Health Controland DivisionEnvironment
MACT 63.65; - : - • 0 S 6 - M M
MACT 63.8980-End Subpart NNNNN — Subpart XXXXXX
9) A self certification form and guidance on how to self-certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123/9D9A Page 9 of 9
Division Information
Engineer: Bradley Eades
Control Engineer: Christopher Laplante
Review Date: 09/30/2015
Application Date: 05/18/2015
Facility Identifiers
Permit No. 15WE1004 Potentially located in ozone nonattainment area
AIRs County # 123 Weld
Facility # 9D9A
Facility Type: exploration and production facility
Located in the 8-hour non-attainment area? 0 True Minor
OO Synthetic Minor for: r VOC F NOx F CO
Administrative Information
Company Name: Bill Barrett Corporation
Source Name: 19036_Coffelt 5-61 -35_36 NWNW Pad
Source Location: NWNW Sec 35, T5N, R61W
SIC: 1311
Address 1: Bill Barrett Corporation
Mailing
Address Address 2: 1099 18th St., Suite 2300
ty, State Zip: Denver, Colorado 80202
Name: Wesley Hill
Person To Phone: 303-312-8546
Contact Fax: 303-291-0420
Email: whill@billbarrettcorp.com
Requested Action
Self Certification Required? Yes
Issuance Number: 1
Source Description:
Oil and gas exploration and production facility known as the 19036_Coffelt 5-61 -35_36 NWNW Pad, located in the
NWNW Sec 35, T5N, R61W, Weld County, Colorado.
Point Name Type Control Action
Newly
004 VRU Bypass Separator Venting Flare reported
source
Controlled smissons from one (1) Heated separator and one (1)Vapor Recovery Tower(VRT) used to reduce flash
004 'missions. Emissions are a function of condensate throughput while emissions bypass the Vapor Recovery Units (VRU).
Equipment Description
This source vents emissions from: One (1) Heated Separators and one (1) Vapor Recovery Tower (VRT)
'Emissions from this source are: routed to a flare
'Emissions are routed to sales line via VRU during normal operation, however emissions are routed to an enclosed flare dunng VRU
downtime. This pemit addresses emissions during VRU downtime
Calculations
Total Throughput to VRT/HFG5 62204 bbl
Estimated annual VRU bypass 35%
Requsted Throughput during VRU bypass 21771 bbl
Control Flare
Efficiency 95.00%
Emissions Summary Table
Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source
VOC 432600 lb/bbl 470.92 tpy 23_55 tpy
Benzene 0.1808 lb/bbl 3936 Ib/yr 197 lb/yr
Toluene 0.1586 lb/bbl 3453 lb/yr 173 lb/yr
Ethylbenzene 0.0294 lb/bbl 640 lb/yr 32 lb/yr Promax 3.2
Xylene 0.0527 lb/bbl 1148 lb/yr 57 lb/yr
224-TMP 0.1824 lb/bbl 3971 lb/yr 199 lb/yr
n-Hexane 1.0156 lb/bbl 22111 lb/yr 1106 lb/yr
Notes:
Emission factors derived from ProMax3.2 model using Coffelt 5.61-35-01088H2 pressurized liquid analysis collected 4/6/2015 as liquid
composition inputs from inlet separator. Mass flow (lb/hr)was taken from ProMax emission stream "VRT Gas to ECD" and "Flash Gas to
VRU" streams (the respective mass flows were summed) and divided by modeled throughput of 1 bbl/d to derive uncontrolled emission
factors.
Emissions are based on 8760 hours of operation per year with estimated 35% VRU downtime (3066 hrs/yr) when emissions are routed to
flare
Emission rates in notes to permit holder are based on operator calculations supplied in application. Differences are due to rounding and
are insignificant.
Flaring Information
Equipment Description
Flare to combust flash emissions from pressunzed liquids during VRU downtime.
Manufacturer Cimarron
Model 48"
Serial Number TBD
Gas Heating Value 2325 Btu/scf
Throughput 9940.931928 MMBtu/yr
Heat Content Calculation
HEN(Btu/scf) 'MMscf/bbl Vol. (MMscf/yr) Total (MMBtu/yr)
Sep.Vapor 2325.29 1.40E-04 3.04E+00 7063.073456
VRT Vapor 2325.29 2.99E-05 6.518E-01 1.516E+03
Apportioned Pilot' 1.362E+03
TOTAL - 1.69E-04 3.6893 9940.931928
'MMscf/bbl is derived from 'Vapor Volumetric Flow' calculated using Promax for each
stream based on 1 bbl/d
'Estimated pilot gas combusted based on 150 sd/hr total pilot gas distributed across points
004, 005, 006. Distnbution is weighted based on relative volume of gas combusted from
each point.
Combustion emission factor source ARC: Chapter 13.5
0.07 IIb NOX/MMBtu 0.37 IIb CO/MMBtu
Emissions Summa Table
NOx 0.34 tpy
CO 1.84 tpy
'Since combustion emissions are below APEN thresholds for the respective pollutant, they are not included as limits in the permit.
Pollutant Emission Factor(for permit)
NOx 0.0310 lb/bbl
CO 0.1689 lb/bbl
Regulatory Applicability
AQCC Regulation 1
This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or
other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is
in excess of 30% opacity.'
AQCC Regulation Z
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are measured in excess of the following
limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the
odorous air has been diluted with seven (7) or more volumes of odor free air."
AQCC Regulation 7
Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
Wells at this facility began producing February 2015. Therefore this separation equipment is subject to Reg 7, Section XVII G.
and control requirements of Reg 7. Section XV11.B.2
1SWE1004.CPl.xlsm
Controlled emissons from one (1) Heated separator and one (1) Vapor Recovery Tower (VRT) used to reduce flash
004 emissions. Emissions are a function of condensate throughput while emissions bypass the Vapor Recovery Units (VRU).
Miscellaneous Notes
Based on conversation with Wes Hill at Bill Barrett Corp., SCADA controls (automated monitoring for VRU downtime) are
currently installed and operating at this site in compliance with condition 14 in the Operating and Maintenance section.
This permit and associated permit limits and conditions are based on hydrocarbon liquid throughput since Bill Barrett Corp.
does not have gas flow meters installed at this facility at this time.
Sent draft of permit to operator on 11/02/2015. Received request from W. Hill (81 BBC to change references to "enclosed flare"
to "enclosed combustor".
15 WE1004.CP1.xlsm
AIRS (County/Plant) 123/9CF9
Permit No. 15WE0371
Date 5/15/2015
Controlled Controlled
Actual Requested NCRP =
Uncontrolled Emission Emisison Factor Emissions Emissions PTE Ctrl. reportable
Point # SCC Pollutant or CAS .Factor Source (tpy)` (tpy)* (tpy)* Eff% ?
004 31000205 VOC 43.260 lb/bbl ProMax 19.62 23.6 471 .0 95% ,Yes
004 31000205 NOx 0.068lb/MMBT4AP-42 0.34 . 0.34 0% Yes
004 31000205 CO 0.31 Ib/MMBTU AP-42 1 .84 1 .84 0% Yes
004 31000205 Benzene 0.181 lb/bbl ProMax 0.08 0.1 1 .97 95% _Yes
004 31000205 n-Hexane 1 .016Ib/bbl ProMax 0.46 0.55 11 .06 95% Yes
004 31000205 Toluene 0.159 lb/bbl ProMax 0.07 0.09 1 .73 . 95% Yes
004 31000205 Ethylbenzene 0.029 lb/bbl ProMax 0.01 0.02 0.32 95% Yes
004 31000205 Xylenes 1 0.053 lb/bbl ProMax 0.02 0.03 0.57 95% -Yes
AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Natural Gas Venting'Permit Number: I SW C l UU LI [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 123 / 9 D5 A / O )mot
Facility Equipment ID: VRU Bypass [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.]
Section 01 — Administrative Information Section 02 — Requested Action (check applicable request boxes)
Company Name: Bill Barrett Corporation NAICS, or ® Request for NEW permit or newly reported emission source
SIC Code: 1311
Source Name: 19036_Coffelt 5-61-35_36 NWW N Pad ❑ Request MODIFICATION to existing permit (check each box below that applies)
Source Location: NWNW Sec 35 T5N R61W County: Weld El Change fuel or equipment ❑ Change company name
Elevation: 4,525 Feet ❑ Change permit limit ❑ Transfer of ownership ❑ Other
Mailing Address: 1099 18th St., Suite 2300 ❑ Request to limit HAPs with a Federally enforceable limit on PTE
Denver, CO ZIP Code: 80202 ❑ Request APEN update only (check the box below that applies)
Revision to actual calendar year emissions for emission inventory
Update 5-Year APEN term without change to permit limits or previously
Person To Contact: Wesley Hill Phone Number: (303) 312-8546 ❑ reported emissions
E-mail Address: whin@billbarrettcorp.com Fax Number: (303) 291-0420 Additional lien ted separator and vapor recovery tower (VRT) are controlled by VRUs - 100% control for
65 t of the time.
Info. &
Section 03 — General Information Notes: Requested permitted emissions based on condensate throughput of 21,771 bbl/yr based on 35%
VRU bypass (35% of total condensate throughput during VRU bypass).
For existing sources, operation began on: 03 / 10 / 2015 For new or reconstructed sources, the projected startup date is: / /
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
General description of equipment and purpose: Heated separator and vapor recovery towers to reduce flash emissions. VRU bypass emissions are a function of condensate throughput during VRU bypass.
Will this equipment be operated in any NAAQS nonattainment area? ® Yes El No
❑ Don't
(http://www.colorado.gov/cdphe/attainment) know
Colorado Department of Public Health and Environment
Section 04 Processing 'muil)lllcnt Information Air Pollution Control Division (APCD)
Description of Source': This notice is valid for five (5) years. Submit a revised APEN prior to
❑ Well Head Casing expiration of five-year term, or when a significant change is made
N Gas/liquid Separator (increase production, new equipment, change in fuel type, etc).
❑ Pneumatic Pump: Make: Model: Serial #: Capacity: gal./min. Mail this form along with a check for $152.90 to:
❑ Compressor Rod Packing Make: Model: # of pistons: Leak rate: Sef/hr/pist. Colorado Department of Public I lealth & Environment
APCD-SS-B1
❑ Blowdowns: # of events: Volume: MMscf/event 4300 Cherry Creek Drive South ✓em,
Description: Denver, CO 80246-1530 gy `��
CI For guidance on how to complete this APEN form: �S
Maximum Vent Rate Actual Volume Requested Volume Vent Gas Heating Value
Air Pollution Control Division: (303) 692-3150
(scf/hr) (MMscf/yr) (MMscf/yr) (Btu/scf) Small Business Assistance Program (SBAP): (303) 692-3148 or
(303) 692-3175
Process Parameters: NA NA 21 ,771 bbl/yr 2325.29 APEN forms:http://www.colorado.gov/cdphe/oilgaspermits
VOC Benzene/ Coulene Ethylbenzenc Xylenc n-Hexane Application status:http://www.colorado.gov/cdphe/permitstatus
Molecular Wt. ( °/°) ° ) °/°) °/o) °/°) °/°)
mole (mole /° (mole (mole (mole (mole
Vented Gas Properties: 41.455 58.915 0.169 0.126 0.020 0.036 0.863
❑ Submit a representative gas analysis (including BTEX & n-Hexane) to support calculations ® Check box to request copy of draft permit prior to issuance.
z You will be charged an additional APEN fee if APEN is filled out incorrectly or missing information and requires re-submittal. ® Check box to request copy of draft permit prior to public notice.
Only one source type may be reported per APEN.
332790
FORM APCD-211 Page 1 of 2 Coffelt Venting_APEN
AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Natural Gas Venting'
Requested values will become permit limitations. Requested level shall be a "not to exceed value".
Permit Number: 1 SW( gowN Emission Source AIRS ID: 123 / 9D9A / apt-A
Section 05 - Stack Information (Combustion stacks must be listed here) Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM)
Stack Discharge
Operator Stack Base Horizontal Datum UTM UTM Easting or UTM Northing or Method of Collection for
Height Above Temp. Flow Rate Velocity Moisture
Stack Elevation Ground Level (°F) (ACFM) (fl/sec) (%) (NAD27, NAD83, Zone Longitude Latitude Location Data (e.g. map,
ID No. (feet) (feet) WGS84) (12 or 13) (meters or degrees) (meters or degrees) 1 GPS, GoogleEarth)
WGS84 -104.184419 40.362681 GoogleEarth
I
Direction of stack outlet (check one): ❑ Vertical 0 Vertical with obstructing raincap 0 Horizontal 0 Down ❑ Other (Describe):
Exhaust Opening Shape & Size (check one): ❑ Circular: Inner Diameter (inches) = 0 Other: Length (inches) = Width (inches) =
Section 07 — Control Device Information
® VRU used for control of: Heated Separator and VRT ® Combustion Device used for control of: VRU bypass Rating: 9 MMBtu/hr
Size: (3) 30 HP Make/Model: Platinum/Quincy Type: (3) Enclosed Combustors Make/Model/Serial #: (3) Cimarron 48"
Requested VOC & HAP Control Efficiency: 100 % VOC & HAP Control Efficiency: Requested: 95 % Manufacturer Guaranteed: 98
Annual time that VRU is bypassed (emissions vented): 35 % Minimum temp. to achieve requested control: N/A °F Waste gas heat content: —2325 Btu/scf
The VRU recycles venting emissions to: Sales pipeline Constant pilot light? ® Yes 0 No Pilot burner rating: MMBtu/hr
❑ Describe Any Other: .
Section 08 — Emissions Inventory Information & Emission Control Information
Attach any emission calculations and emission factor documentation to this APEN form.
® Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput above (e.g. 2007)_ NA
Actual Calendar Year Estimation
Control Device Description Overall Control Emission Factor Emissions4 Requested Permitted Emissions Method or
Pollutant Collection Efficiency Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Emission
Primary Secondary Efficiency (% Reduction) Basis Units (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year Factor Source
VOC VRU ECDs 65 95 43.26 lb/bbl 392.47 19.62 470.97 23.55 ProMax
NOx 0.068 lb/MMBtu 0.29 0.34 AP-42
CO 0.37 Ib/MMBtu 1.57 1.84 AP-42
Sox
Benzene VRU ECDs 65 95 0.1808 lb/bbl 1.64 0.08 1.97 0.10 ProMax
Toulene VRU ECDs 65 95 0.1586 lb/bbl 1.44 0.07 1.73 0.09 ProMax
Ethylbenzene VRU ECDs 65 95 0.0294 lb/bbl 0.27 0.01 0.32 0.02 ProMax
Xylene VRU ECDs 65 95 0.0527 lb/bbl 0.48 0.02 0.57 0.03 ProMax
n-Hexane VRU ECDs 65 95 1.0156 lb/bbl 9.21 0.46 11.06 0.55 ProMax
Please use the APCD Non-Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above.
-1 You will be charged an additional MEN fee if APEN is filled out incorrectly or missing inlbnnation and requires re-submittal.
' Annual emission fees will be based on actual emissions reported here.
Section 09 -An licant Certification - hereby certify that all information contained herein and information submitted with this a plication is complete, true and correct.
V.._57/S Wesley Hill J1/^1 _ ' � N.
$b# '\ Sr. Environmental Specialist
Signature of Person Leg ly Authorized to Supply Data Date Name of Legally`Authori�ek'?rson (Please print) Title
FORM APCD-211 Page 2 of 2 Coffelt Vent►ntAPEN
NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM
(See reverse side for guidance on completing this form)
Permit Number: l wr_ Ic)01 AIRS ID Number: 123/9D9A/OO9
Company Name : Bill Barrett Corporation
Plant Location : NWNW Sec. 35, T5N , R61 W County: Weld Zip Code :
Person to Contact: Wesley Hill Phone Number: (303) 312-8546
E-mail Address : whill@billbarrettcorp.com Fax Number: (303) 291 -0420
'` Chemical Abstract Uncontrolled Controlled Actual
Service (CAS) Chemical Name Control Equipment Emission Factor Emission Factor Actual Emissions Emissions
Number / Reduction ( o) (Include Units) Source (lbs/year) (lbs/year)
540-84-1 2,2,4-Trimethylpentau 75%(VRU)/95%(ECD) 0. 1824 lb/bbl Promax 2363.86 118. 19
Calendar Year for which Actual Data Applies: 2015
&r/.
Signature of Person Legally Authorized to Supply Data "�' Date
9 g Y pp Y A
Wesley Hill Air Quality Specialist
Name of Person Legally Authorized to Supply Data ( Please print) Title of Person Legally Authorized to Supply Data
Form Revision Date: April 14, 2014
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