HomeMy WebLinkAbout20152964.tiff � � C4LORA [� �1►
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i Department r_af F>ubiic
. Health fr Environment
Dedicated to protecting and improving the healih and environment of the people of Cotorado
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, co $0632 R E C E I V E D
September 1, 2015 SEP 0 8 2015
WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On September 2, 2015, the Air Pollution Control Division will begin a 30-day pubtic notice period for
Kerr-McGee Oil and Gas Onshore LP - 36166641 Tank Battery (Gobbler 14C-27HZ). 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 Heatth � Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Ctara Gonzales
Regards,
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Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
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John W. Hickenlooper, Governor � Larry Wotk,MD,MSPH, Executive Director and Chief Medical Officer �{ �
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� � AirPollution Control Division
� Notice of a Proposed Project or Acttvity Warranting Public
�µ Comment
Website Title: Kerr-McGee Oil and Gas Onshore LP - 36166b41 Tank Battery (Gobbler 14C-27HZ) - Weld
County
Notice Period Begins: September 2, 2015
Notice is hereby given that an apptication for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Kerr-McGee Oil and Gas Onshore LP
Facility: 36166641 Tank Battery (Gobbler 14C-27HZ)
Oil and Gas Exptoration and Production Facility
SESE of Section 22, Township 2N, Ran�e 66W
Wetd County
The proposed project or activity is as foltows: Applicant is requesting permit covera�e for one (1) vapor
recovery tower (VRT) controlled by three (3) enclosed combustion devices durin� vapor recovery unit (VRU)
bypass at an exploration and production facility.
The Division has determined that this permitting action is subject to pubtic 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 timit 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 15WE0316 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 abitity
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written pubtic 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
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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 4 ��
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TELEPNONE: (303)692-3150 �'�t�,�„*
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CONSTRUCTION PERMIT
PERnniT No: 15WE0316
Issuance 1
DATE ISSUED:
�ss�Eo To: Kerr-McGee Oil and Gas Onshore LP
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oii and gas exploration and production facility, known as the 36166641 Tank Battery
(Gobbler 14C-27HZ), located in the SESE of Section 22, Township 2N, Range 66W, in
Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment point Description
ID
One (1) vapor recovery tower (VRT) that processes liquid from the
second stage of separation to create a third stage of liquid/gas
separation. Overhead flash gas from the VRT is routed to the
vapor recovery units (VRUs) in a closed loop process. When the
VRUs are unable to capture the entire overhead gas stream, flash
VRT-01 005 gas is routed to three (3) enclosed combustion devices (ECDs).
The ECDs have a minimum control efficiency of 95%. Emissions
are a function of condensate throughput while overhead gas is
routed to the ECDs. It is assumed that the flash gas is routed to
the ECDs 30% of the time. This permit covers emissions when
flash as is routed to the ECDs.
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 submittinq a Notice of Startup form to the Division. The Notice of Startup form
may be downloaded online at https:/Iwww.colorado.qov/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.
AIRS ID: 123/1705 Page 1 of 8
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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, I I I.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 for all permitted equipment except fugitive emissions from
equipment leaks shall be provided to the Division within fifteen (15) days of the latter of
commencement of operation or issuance of this 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
Emission Type
Equipment ID Point NOX VOC CO
VRT-01 005 2.0 26.1 4.9 Point
See "Notes to Permif Holder #4" for information on emission factors and methods used to
calculate limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
AIRS ID: 123/1705 Page 2 of 8
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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.
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
VRT-01 005 Three (3) Enclosed Combustion Devices VOC and HAPs
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
r or s of the throu h ut shall be maintained b the a licant and made
Monthly ec d g p y pp
available to the Division for inspection upon request. (Reference: Regulation 3, Part B,
II.A.4)
Process/Consumption Limits
Facility AIRS Process Parameter Annual Limit
Equipment ID Point
Condensate throughput through VRT
VRT-01 005 while emissions are routed to 146,400 BBUyr
enclosed combustion devices.
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
10. The permit number and AIRS ID number shall be marked on the subject equipment for
ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only
enforceable)
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.)
AIRS ID: 123/1705 Page 3 of 8
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Air Pollution Control Division
12. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
13. Upon startup of this point, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in order to demonstrate
compliance on an ongoing basis with the requirements of this permit. Revisions to your
O&M plan are subject to Division approval prior to implementation. (Reference:
Regulation No. 3, Part B, Section III.G.7.)
14. The owner or operator shall continuously monitor and record the amount of time that
flash gas is routed from the VRTs to the ECDs. The owner or operator shall use monthly
recorded ECD run time, monthly condensate throughput records and calculation
methods detailed in the O&M plan to demonstrate compliance with the limits specified in
this permit and to calculate emissions as described in this permit.
COMPLIANCE TESTING AND SAMPLING
Initial Testinq Repuirements
15. The owner or operator shall demonstrate compliance with opacity standards using EPA
Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section
II.A.5).
ADDITIONAL REQUIREMENTS
16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually by April 30�' whenever a significant increase in emissions occurs as
follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in
ozone nonattainment areas emitting less than 100 tons of VOC or NOX per
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
AIRS ID: 123/1705 Page 4 of 8
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Air Pollution Control Division
e. No later than 30 days before the existing APEN expires.
17. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at
any such time that this source becomes major solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the applicable
Federal program threshold will require a full review of the source as though construction
had not yet commenced on the source. The source shall not exceed the Federal
program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
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 applicant and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the applicant or applicant's agents. It is valid only for the
equipment and operations or activity specifically identified on the permit.
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
permit, conditions imposed upon a permit are contested by the applicant, or the Division
revokes a permit, the applicant or owner or operator of a source may request a hearing
before the AQCC for review of the Division's action.
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.
AIRS ID: 123/1705 Page 5 of 8
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Air Pollution Control Division
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 Histo
Issuance Date Description
Issuance 1 This Issuance Issued to Kerr-McGee Oil and Gas Onshore LP
Permit for one (1) vapor recovery tower at a
synthetic minor exploration and production
facility.
AIRS ID: 123/1705 Page 6 of 8
olo De ent f Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the permittee providing there is no exceedance of any specific emission control
regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and
application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as
soon as possible, but no later than noon of the next working day, followed by written notice to the
Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.qov/pacific/cdphe/aqcc-reqs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr)
Benzene 71432 A 4,319 Yes 216
Toluene 108883 C 7,833 Yes 392
Ethylbenzene 100414 C 1,025 Yes 52
005 Xylenes 1130207 C 6,149 Yes 308
n-Hexane 110543 C 26,865 Yes 1,344
2,2,4-
540841 C 4,100 Yes 205
Trimethylpentane
5) The emission levels contained in this permit are based on the following emission factors:
Emission Factors Emission Factors
CAS# Pollutant Uncontrolled Controlled Source
(lb/bbl) (lb/bbl)
NOx 0.026 0.026 Engineering Estimate
CO 0.067 0.067 Engineering Estimate
VOC 7.13 0.356 E&P Tanks
71432 Benzene 2.95E-2 1.47E-3 E&P Tanks
108883 Toluene 5.35E-2 2.67E-3 E&P Tanks
100414 Ethylbenzene 7.0E-3 3.5E-4 E&P Tanks
1330207 Xylenes 4.2E-2 2.1E-3 E&P Tanks
110543 n-hexane 1.83E-1 9.17E-3 E&P Tanks
540841 2,2,4-TMP 2.8E-2 1.4E-3 E&P Tanks
AIRS ID: 123/1705 Page 7 of 8
' olo A , De -- ent f Public Health and Environment
Air Pollution Control Division
Note: The controlled emissions factors for point 005 are based on the enclosed combustor
control efficiency of 95%. These emission factors were developed using pressurized
liquids analyses from the Gobbler 36N-27HZ and the Gobbler 37C-27HZ wells both
sampled on January 19, 2015. The emission factors obtained from the two separate E&P
Tanks simulations were averaged in order to determine an overall emission factor for
each pollutant
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.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60,Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A—Subpart Z
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX
9) A self certification form and guidance on how to self-certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123/1705 Page 8 of 8
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: Kerr-McGee Oil and Gas Onshore LP
Permit Number: 15WE0316
Source Name: 36166641 Tank Battery (Gobbler 14C-27HZ)
Source Location: SESE of Section 22, Township 2N, Range 66W
One (1)vapor recovery tower(VRT)that processes liquid from the
second stage of separation to create a third stage of liquid/gas
separation. Overhead flash gas from the VRT is routed to the vapor
recovery units (VRUs) in a closed loop process. When the VRUs are
Equipment Description: unable to capture the entire overhead gas stream,flash gas is routed to
three(3) enclosed combustion devices (ECDs). The ECDs have a
minimum control efficiency of 95%. Emissions are a function of
condensate throughput while overhead gas is routed to the ECDs. It is
assumed that the flash gas is routed to the ECDs 30% of the time. This
permit covers emissions when flash as is routed to the ECDs.
AIRS ID: 123-1705-005
Date: 08/26/2015
Review Engineer: Harrison Slaughter
Control Engineer: Chris Laplante
Section 2—Action Com leted
Grandfathered Modification APEN Required/Permit Exempt
X CP1 Transfer of Ownership APEN Exempt/Permit Exempt
Section 3—A licant Com leteness 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 Re uest letter to the source?
On what date was this application complete? March 9, 2015
Section 4—Source Descri tion
AIRS Point Equipment Description
One(1)vapor recovery tower(VRT)that processes liquid from the second stage of
separation to create a third stage of liquid/gas separation. Overhead flash gas from
the VRT is routed to the vapor recovery units (VRUs) in a closed loop process.
When the VRUs are unable to capture the entire overhead gas stream,flash gas is
005 routed to three(3) enclosed combustion devices (ECDs). The ECDs have a
minimum control efficiency of 95%. Emissions are a function of condensate
throughput while overhead gas is routed to the ECDs. It is assumed that the flash
gas is routed to the ECDs 30% of the time.This permit covers emissions when flash
as is routed to the ECDs.
Page 1
Is this a portable source? Yes X No
Is this location in a non-attainment area for any criteria X Yes No
ollutant?
If"yes", for what pollutant? PM,o CO X Ozone
Is this location in an attainment maintenance area for Yes X No
an criteria ollutant?
If"yes", for what pollutant?
(Note: These pollutants are subject to minor source N/A PM,o N/A CO N/A Ozone
RACT er Re ulation 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
Re ulation 7, Sections XII and XVII.C ma ap I
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
Source calculated site-specific emission factors using two pressurized liquid
' 005 samples and two E&P Tanks simulations that were averaged to determine an
overall emission factor. Please see Section 14 for additional information.
Did the applicant provide actual process data for the emission inventory? Yes X No
Basis for Potential to Emit(PTE)
AIRS Point Process Consumption/ThroughputlProduction
005 146,400 BBL per year—Representative of condensate throughput while flash gas is
routed from the VRTs to the ECDs 30% of total throu h ut assumed
Basis for Actual Emissions Reported Durinq this APEN Filinq (Reported to'Inventorvl
AIRS Point Process Consumption/Throughput/Production Data Year
146,400 BBL per year—Representative of condensate throughput
005 while flash gas is routed from the VRTs to the ECDs (30% of total N/A
throu h ut assumed)
Basis forPermitted Emissions(Permit Limits)
AIRS Point Process Consumption/ThroughputlProduction
005 146,400 BBL per year—Representative of condensate throughput while flash gas is
routed from the VRTs to the ECDs 30% of total throu h ut assumed
Does this source use a control device? X Yes No
AIRS Point Process Control Device Description % Reduction
Granted
005 0� Three(3) Enclosed Combustors 95
Section 6—Emission Summa tons er ear
Point NOX VOC CO Single HAP Total HAP
PTE: 005 2.0 522.0 4.9 13.5 25 2
n-Hexane
Uncontrolled point 005 2.0 522.0 4.9 13.5 25 2
source emission rate: n-Hexane
Controlled point 005 2.0 26.1 4.9 0'7 1.3 �
source emission rate: n-Hexane
Total APEN Reported 005 2.0 26.1 4.9 ��� 1.3
emissions: n-Hexane
, Page 2
Section 7—Non-Criteria/Hazardous Air Pollutants
Uncontrolled Arethe Controlled Emission
POllutant CAS# BIN Emission Rate emissions Rate Ib/ r
�b/ f reportable7 � y�
Benzene 71432 A 4,319 Yes 216
Toluene 108883 C 7,833 Yes 392
Ethylbenzene 100414 C 1,025 Yes 52
Xylenes 1130207 C 6,149 Yes 308
n-Hexane 110543 C 26,865 Yes 1,344
2,2,4-Trimethylpentane 540841 C 4,100 Yes 205
Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used b the o erator.
Section 8—Testin 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
005 01 VOC, Colorado State Regulation 1 Initial EPA Method 9
HAPS opacit test.
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
ro rams?
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 —Modelin
Is modeling required to demonstrate compliance with National Ambient Yes X No
Air Qualit Standards NAAQS ?
If"yes", for which pollutants?Why? No because NOx emissions are less than 40 tpy; CO
emissions are less than 100 tp .
AIRS Point Section 12—Re ulatory Review
Re ulation 1 - Particulate Smoke Carbon Monoxide and Sulfur Dioxide
Page 3
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.
Re ulation2—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
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.
Re ulation 3-APENs Construction Permits'D eratin 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.
A licant is re uired to file an APEN since emissions exceed 1 ton er ear VOC
Part B-Construction Permit Exemptions
005 Applicant is required to obtain a permif since uncontrolled VOC emissions from this
facili are reater than the 2.0 TPY threshold R . 3,Part B, Section II.D.2.a
Re Ulation 6'-New Source'Performance'Standards
005 None
Re ulation 7—Volatile Or anic Com ounds
Was the well newly constructed, hydraulically fractured, or recompleted on or after August
1, 2014?
No.—Based on the interpretation that the date of first production is equivalent to the date
of a well being "newly constructed,"the date of first production for each of the wells at the
005 facility is prior to the August 1, 2014 applicability date. The operator was asked about
this point and they confirmed that the date of first production for the most recent
well was in July of 2014.
As a result, the VRT is not subject to Regulation 7, Section XVII.G or the other control
re uirements of Re ulation 7 Section XVI1.6.2
Re ulation 8---Hazardaus Air Pollutants
MACT EEEE: Organic Liquids Distribution
005 . This source is not subject to MACT EEEE because it is not located at a major
source of HAP
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 S stem Codin Information
Process Emission Pollutant/ Fugitive Control
Point Process Descri tion Factor CAS# Y/N Emission Factor Source a�o
7.13
One(1)VRT Ib/bbl VOC No E&P Tanks 95
005 01 controlled by three throu h ut
(3)ECDs during 0.026
VRU bypass. Ib/bbl NOx No Engineering Estimate NA
throu h ut
Page 4
0.067
ib/bbl CO No Engineering Estimate NA
throu h ut
2.95E-2 genzene/
Ib/bbl 71432 No E&P Tanks 95
throu h ut
5.35E-2 Toluene/
Ib/bbl 108883 No E&P Tanks 95
throu h ut
7.0E-3 Ethylbenzene
ib/bbl /100414 No E&P Tanks 95
throu h ut
4.2E-2 Xylenes/
Ib/bbl 1130207 No E&P Tanks 95
throu h ut
1.835E-1 n-Hexane/
Ib/bbl 110543 No E&P Tanks 95
throu h ut
0.028 2 2 4-TMP/
Ib/bbi 540841 No E&P Tanks 95
throu h ut
SCC 31000205-Flares
Page 5
Section 14—Miscellaneous A lication Notes
One(1)vapor recovery tower(VRT)that processes liquid from the second
stage of separation to create a third stage of liquid/gas separation.
Overhead flash gas from the VRT is routed to the vapor recovery units
(VRUs) in a closed loop process. When the VRUs are unable to capture the
AIRS Point 005 entire overhead gas stream,flash gas is routed to three(3)enclosed
combustion devices(ECDs).The ECDs have a minimum control efficiency
of 95%. Emissions are a function of condensate throughput while overhead
gas is routed to the ECDs. It is assumed that the flash gas is routed to the
ECDs 30% of the time.This permit covers emissions when flash gas is
routed to the ECDs.
The site specific emission factors developed for this source were determined through the use of two
pressurized liquid samples and two E&P Tanks simulations associated with the liquids samples. A sales
oil analysis was not provided with the application. As a result, the operator assumed an API gravity of
46° and a RVP of 9. The average API gravity for each of the wells reported to COGCC over the past year
for this facility was determined to be 46.7°. As a result, the assumed API gravity and RVP were accepted
as reasonable estimates. The pressurized liquid samples were obtained from two different wells at the
facility. The wells from which the samples were taken include Gobbler 36N-27HZ and Gobbler 37C-
27HZ. Two separate E&P Tanks simulations were conducted using the two pressurized liquid samples.
The results of the simulation were averaged to determine the site specific emission factors. The following
table contains the information from the E&P Tanks simulations used to determine the emission factors:
Pollutant Gobbler 36N-27HZ Gobbler 37C-27HZ
Emission Factors Ib/bbl Emission Factors Ib/bbl
, VOC 7.995 6.266
Benzene 0.035 0.024
Toluene 0.058 0.049
E-Benzene 0.008 0.006
X lenes 0.047 0.037
n-Hexane 0.222 0.145
2,2,4-TMP 0.036 0.02
"'`The values from the E&P Tanks simulation have units of Ib/hr; however,the simulation was run on a
basis of 24 bbl/day, so the conversion from Ib/hr to Ib/bbl results in the same value. For example the flow
rate of VOC from E&P Tanks for the Gobbler 36N-27HZ well is 7.995 Ib/hr. The conversion of this value
to Ib/bbl is as follows: VOC EF (Ib/bbl) _ (7.995 Ib/hr)*(24 hr/day)"`(1 day/24 bbl) = 7.995 Ib VOC/bbl.
The overall emission factor for the VRT was determined through a simple average of the emission factors
for each pollutant from the Gobbler 36N-27HZ and the Gobbler 37C-27HZ wells. Following is an example
calculation of the determination of the overall emission factor:
Overall EF — EF36N-z�yz+EFs�c-2�xz
_ z
7.9951b +6.266 lb �13 l6 VOC
Overall EF bbl bbl _
voc = Z bbl
The above calculation was conducted for each of the pollutants listed in the table in order to obtain an
overall emission factor.
Page 6
Additional Notes:
1. The uncontrolled NOx and CO emission factors represent approved values from the CDPHE inter-
Office Communication on 2005-03-22 multiplied by the site specific VOC emission factor calculated in the
application and represented above. The emission factor for and emissions of NOx and CO were
determined through the following calculation:
EF,lbl rEF,Ib VOCl
Emission Factortpy = (lb VOC/ * l bbl l
The calculation of the NOx and CO emission factors represented in the permit are as follow:
0.0037 16s NOxl (7.13 lb VOCl 0.0264 lb NOx
N0X�b/6bi — ( lb VOC / * \ bbl / 6bl
0.0094 lbs COl (7.13 lb VOCl 0.067 lb CO
C0cb�bbi = ( Ib VOC / * \ bbl 1 bbl
The calculation of the NOx emission limit found in the permit is as follows:
0.0264 lbs NOxl (146,400 bbll ( 1 ton l 1.93 tons NOx
NOXtpY = ( bbl / * \ year / * \20001bs1 year
The calculation of the CO emission limit found in the permit is as follows:
0.067 lb COl (146,400 bbll ( 1 ton l 4.9 tons CO
COtpY = ( bbl 1 * \ year 1 * \20001bs1 year
'These combustion emission factors were developed for use with storage tanks; however, they are
approved for use here because the VRT operates at low pressure (�1 psig)
2.The operator expressed in the application that prior to obtaining a sample from the separator for
analysis, the normal operating pressure of the separator was increased by 10 psi. This artificial load on
the separator leads to a more conservative estimate of flash emissions at the vapor recovery tower due to
the increased pressure drop.
3. The operator was provided with a draft permit to review prior to public comment. The operator
reviewed the permit draft and expressed they did not have any comments.
Page 7
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