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Home My WebLink About20152103.tiff AIK CDPHE COLORADO • '1ODepartment of Public `"oHealth Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado RECEIVED Weld County - Clerk to the Board 1150 0 St JUL 13 206 PO Box 758 Greeley, CO 80632 WELD COUN? v COMMISSIONERS July 6, 2015 Dear Sir or Madam: On July 8, 2015, the Air Pollution Control Division will begin a 30-day public notice period for Bill Barrett Corporation - 18434_Helton 5-63-27 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 7- .2d l5 Cc : t Rt th /ILI 2015-2103 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe v; John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer CDPHE= Air Pollution Control DivisionCO -10 Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Bill Barrett Corporation - 18434_Helton 5-63-27 Pad - Weld County Notice Period Begins: July 8, 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: 18434_Helton 5-63-27 Pad Oil and Gas production Facility NWSW Sec. 27, T5N, R63W Weld County The proposed project or activity is as follows: Applicant proposes to operate two (2) Vapor Recovery Towers (VRTs) at a new exploration and production facility. Emissions from the VRT will be routed to enclosed combustors when Vapor Recovery Units (VRUs) are unable to recompress the gas to the sales line. 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 14WE1207 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 1 COLORADO RC r K STATE OF COLORADO /:OF"CO . cOLORAD• DEPARTMENTF PU C HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION it-, o) TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 14WE1207 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 18434_Helton 5-63-27 Pad, located in the NWSW Sec 27 T5N R63W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Two (2) Vapor Recovery Towers (VRTs) to reduce flash VRU emissions. Emissions are a function of liquid throughput during Bypass 004 VRU bypass (40% VRU bypass assumed). Emissions are controlled by enclosed combustors during VRU bypass. 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 issuance of this permit, 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 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: 123/9C82 Page 1 of 8 Ill olor 4 Depa en : P .IiHealth and Environment it Pollution Control Division on which suc ..i. ctika ._ia' . w Y - led toR--mence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, I II.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 Equipment ID Point NO VOC CO Emission Type X VRU Bypass 004 0.4 8.7 2.1 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.) Facility AIRS Equipment Point Control Device Pollutants Controlled ID VRU Two(2) Leed L30-0010 Enclosed 004 VOC, HAPs Bypass Combustors AIRS ID: 123/9C82 Page 2 of 8 'olora: Depa One n elf P lid°Health and Environment Pollution Control Division *'•,. PROCESS LIMITAT S N* : CORDS Of, t,•, 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 004 Condensate throughput to VRTs while 28,800 BBL/yr Bypass VRUs are being bypassed 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 monitor and record 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. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 5.) OPERATING & MAINTENANCE REQUIREMENTS 12. 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.) 13. 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 Enclosed Control Devices using a SCADA (supervisory control and data acquisition) system. The owner or operator shall use monthly VRU downtime records, monthly hydrocarbon liquid 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 AIRS ID: 123/9C82 Page 3 of 8 ssts. ,,:: Ill :' olor. Depa T en P, ill Health and Environment - ALit Pollution Control Division tt required. If th:; . ' obr fi-. _: _. :be - : duri % t,ite 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 14. This source is not required to comply with any testing and sampling requirements. ADDITIONAL REQUIREMENTS 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (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. 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). GENERAL TERMS AND CONDITIONS 17. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. AIRS ID: 12319C82 Page 4 of 8 olor Depar nenz f P lid Health and Environment fir Pollution Control Division 18. If this permit__specif# `all state tb finaLiatitgrjzation4as been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 19. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 20. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 21. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 22. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 23. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Bradley Eades Permit Engineer AIRS ID: 123/9C82 Page 5 of 8 ,. , ., �� olor- * Depa en 6 P •li Health and Environment it Pollution Control Division Permit Histo • _= _, ..._ _._, Issuance Date Description Issuance 1 This Issuance Issued to Bill Barrett Corporation AIRS ID: 12319C82 Page 6 of 8 444 -4 mi444 a,,; olora '4.,Depa en4wf P44 lid Health and Environment ,.^ it Pollution Control Division Notes to Permit Holder _ -' me o errneruan 44)4' f' 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 Rate Point Pollutant CAS# (Ib/yr) reportable? (Ib/yr) Benzene 71432 708 Yes 35 n-Hexane 110543 4660 Yes 233 Toluene 108883 544 Yes 27 004 Ethylbenzene 100414 43 No 2 Xylenes 1330207 145 No 7 224- 540841 314 Yes 16 Trimethylpentane 5) The emission levels contained in this permit are based on the following emission factors: Point 004: Emission Factors Pollutant (lb/MMbtu) Source NOx 0.068 AP-42, Table 13.5-1 CO 0.37 AP-42, Table 13.5-1 AIRS ID: 123/9C82 Page 7 of 8 olor- Depa r en P_ill Health and Environment it Pollution Control Division Emission Emission Pollutant Factors Factors Source Uncontrolled Controlled (lb/bbl) (lb/bbl) VOC 11.9578 0.5979 Benzene 0.0246 0.0012 Toluene 0.0189 0.0009 Ethylbenzene 0.0015 0.0001 ProMax 3.2 Xylenes 0.0050 0.0003 n-hexane 0.1618 0.0081 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 NANSR Synthetic Minor/Major Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXX(X 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: 123/9C82 Page 8 of 8 Division Information Engineer: Bradley Eades Control Engineer: Christopher Laplante Review Date: 05/15/2015 Application Date: 02/10/2015 Facility Identifiers Permit No. 14WE1207 Potentially located in ozone nonattainment area AIRS County# 123 Weld Facility# 9CF9 Facility Type: exploration and production facility Located in the 8-hour non-attainment area? O True Minor Synthetic Minor for: VOC r NOx r CO Administrative Information Company Name: Bill Barrett Corporation Source Name: 18434_Helton 5-63-27 Pad Source Location: NWSW Sec. 27, T5N, R63W SIC: 1311 Address 1: Bill Barrett Corporation Mailing Address 2: 1099 18th Street, Suite 2300 Address 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 18434_Helton 5-63-27 Pad, located in the NWSW Sec. 27,T5N, R63W,Weld County, Colorado. Point Name Type Control Action Newly 004 VRU Bypass Separator Venting Flare reported source • • • • Controlled emissons from two(2)Vapor Recovery Towers(VRTs)used to reduce flash emissions.Emissions area function of 005 condensate throughput during VRU bypass.40%VRU bypass assumed Equipment Description This source vents emissions from: Two(2)Vapor Recovery Towers(VRTs) 'Emissions from this source are: routed to a flare 'Emissions are routed to sales line during normal operation.however emissions are routed to an enclosed flare during VRU downtime.This permit addresses emissions during VRU downtime Calculations Total Throughput to VRT /2UV0 bbl Estimated annual VRU bypass 40% Requsted Throughput during VRU bypass 28800 bbl Control flare Efficiency 95.00%I Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source Controlled Emision Factors VOC 11 9578 ib/bb 172.19 tpy 8.61 tpy 0.5979 lb/bb Benzene 0.0246 lb/bb 708 lb/yr 35 lb/yr 0.0012 lb/bb Toluene 0.0189 lb/bb 544 lb/yr 27 lb/yr (lows lb/bb Ethylbenzene 0.001516/bb 43 lb/yr 2 lb/yr Promax 3.2 0.0001 lb/bb Xylene 0.0050 lb/bb 145 lb/yr 7 lb/yr 0.0003 lb/bb 224-TMP 0.01091b/bb 314 lb/yr 16 lb/yr 0.0005 lb/bb n-Hexane 0.1618 lb/bb 4660 lb/yr 233 lb/yr 0.0081 lb/bb • Notes: • Emission factors derived from ProMax3.2 model using Helton 563-27 Pad pressurized liquid analysis collected 03/25/2014 as composition inputs of liquid from inlet separator.Mass flow(lb/hr)was taken from Pro Max emission stream"VRT Gas to ECU'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 40%VRU downtime(3504 hrs/yr)when emissions are routed to flare Flaring Information Equipment Description ECDs to combust flash emissions from pressurized liquids during VRU downtime. Manufacturer (2)Leed Model L30-0010 Heat Content Calculation Serial Number 22754822845 HHV)Btu/scf) 'MMscf/bbl Vol.)MMscf/yr) Total(MMBtu/yr) Gas Heating Value 222375 Btu/scf VRT Flash 2223.75 1.61E-04 4.641000 10307.43349 Pilot 1288.4 7.91E-01 1.026903 Throughput .11327.00626 MMBtu/yr TOTAL - - 0.6352 11327.00626 'MMscf/bO is derived from Std Vapor Volumetric Flow calculated using Promax based on 1EV/d 'Volume of pilot gas derived from 100 scf/hr rating for four(2)Leed Combustors apportioned across equipment controlled(point 003,004,8 007)based on relative throughput to combustors. Combustion emission factor source: AP-42:Chapter 115 0.07 IIb NOX/MMBtu 0.37 Ilb CO/MMBtu Emissions Summary Table NOx 0.39 tpy CO 2.10 tpy 14WE1207.CP1.xlsm Controlled emissons from two 12)Vapor Recovery Towers(VRTs)used to reduce flash emissions.Emissions area function of 005 condensate throughput during VRU bypass.40%VRU bypass assumed Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares or Section II A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.' AQCC Regulation 2 Section I A applies to all emission sources."No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the 10ll0wi0g limits:For areas used predominantly for residential or commerdal purposes it is a violation if odors are detected after e odorous air has been diluted th with seven(7)or more volumes of odor free air" AQCC Regulation 7 Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1.2014? No Per cover letter,this site began producing on March 22,2014.Also.W.Hill confirmed via email that the FDOP for the most recently completed well was 03/23/2014(Helton 5-63-27-3340CDH) Miscellaneous Notes Based on conversation oath Wes Hill at Bill Barrett Corp.,SCADA controls(automated monitoring for VRU downtime)are scheduled for installation but are not currently installed.Asa result,a permit condition was included to allow for manual montitoring during the first 180 days after issuance,or until SCADA cotnrols are operational. 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 06/22/2015 and received no comments. Emissions from VRTs are routed to common control devices also used to control condensate tanks(point 007)and Water Tanks(003).Point 007 is subject to Regulation 7,Section XVII.C and therefore control requiremetns per XVII.B.Both points 003 and 007 are included on GP08 registration. Applicant sent in changes via revised APEN on 06/17/2015.Changes included increasing assumed downtime to 40%(28,800 bV/yr)from 10%on original application. 14WE1307.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 lb/1000 ga ProMax 95% Yes 004 31000205 NOx Ib/MMBTU AP-42 0% Yes 004 31000205 CO Ib/MMBTU AP-42 0% Yes 004 31000205 Benzene lb/1000 ga ProMax 95% Yes 004 31000205 n-Hexane lb/1000 ga ProMax 95% Yes 004 31000205 Toluene lb/1000 ga ProMax 95% Yes 004 31000205 Ethylbenzene lb/1000 ga ProMax 95% Yes 004 31000205 Xylenes lb/1000 ga ProMax 95% Yes cte 0 o w r p c c c C a0. s >, s _ �j' o0 77) = E Z .O U M M . O "' �D R ❑ 7 O W N (V (V N Y rOn .= � > '� .4 ¢ as ___ it •P' O o J (� p O G. 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