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Home My WebLink About20152961.tiff A CDPHE COLORADOla , Department of Public _ Health£r Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St RECEIVED PO Box 758 Greeley, CO 80632 SEP 0 8 2015 September 1, 2015 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On September 2, 2015, the Air Pollution Control Division will begin a 30-day public notice period for Kerr-McGee Oil and Gas Onshore LP - 36162745 (Kunzman 3C-5HZ). 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 f il.btAl& Ketic o eC .?L, h6; G191 2015-2961 R-PF/y 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe E~ LL John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer f` .i-6 � � AirPollution Control Division �� Notice of a Proposed Project orActivity Warranting Public ,, Comment Website Title: Kerr-McGee Oil and Gas Onshore LP - 36162745 (Kunzman 3C-5HZ) - Weld County Notice Period Begins: September 2, 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: Kerr-McGee Oil and Gas Onshore LP Facility: 36162745 (Kunzman 3C-5HZ) Oil and Gas Exptoration and Production Facility SESW of Section 5, Township 2N, Range 66W Weld County The proposed project or activity is as follows: Applicant is requesting permit covera�e for one (1) vapor recovery tower (VRT) controlled by three (3) enclosed combustion devices during vapor recovery unit (VRU) bypass at an exploration and production facility. � The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): I • the source is requesting a federatly 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 15WE0307 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Harrison Slaughter Colorado Department of Public Health and Environment , 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcdC state.co.us CUlO�;C)U 1 I ,�� _: �� 5TATE OF COLOR,ADO �� ,��v��C�l�P COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT � -ya AIR POLLUTION CONTROL DIVISION �y �`"� ° TELEPHONE: (303)692-3150 �''`#��'* *�876� CONSTRUCTION PERMIT PERMIT NO: � 5WE0307 Issuance 1 DATE ISSUED: �ssuEo To: Kerr-McGee Oil and Gas Onshore LP THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility, known as the 36162745 Tank Battery (Kunzman 3C-5HZ), located in the SESW of Section 5, 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-01 007 gas is routed to three (3) enclosed combustion devices (ECDs). I 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://www.colorado.qov/ acific/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: 123/2233 Page 1 of 8 Wellhead Version 2012-1 I olo I , De - • ent ,f Public Health and Environment Air Pollution Control Division 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 after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO. VOC CO Emission Type VRT-01 007 1.2 15.0 2.9 Point See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. AIRS ID: 123/2233 Page 2 of 8 it olo.\= De ent f Public Health and Environment ti Air Pollution Control Division 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-01 007 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. Monthly records of the throughput shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point Condensate throughput through VRT VRT-01 007 while emissions are routed to 84,600 BBUyr enclosed combustion devices. The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID 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: 123/2233 Page 3 of 8 Iolo A De -• ent f Public Health and Environment 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 Testing Requirements 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 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or 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 AIRS ID: 123/2233 Page 4 of 8 :t olo . De ent, f Public Health and Environment 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 q q 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: 123/2233 Page 5 of 8 I olo A De.gam, ent f Public Health and Environment 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 History 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: 123/2233 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.gov/pacific/cdphe/agcc-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 Are the Controlled AIRS Pollutant CAS# BIN Emission emissions Emission Point Rate reportable? Rate(Ib/yr) (Ib/yr) Benzene 71432 A 5,288 Yes 265 Toluene 108883 C 5,711 Yes 286 Ethylbenzene 100414 C 339 Yes 17 007 Xylenes 1130207 C 1,608 Yes 81 n-Hexane 110543 C 39,001 Yes 1,950 2,2,4- 540841 C 1,608 Yes 81 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 7.09 3.55E-1 E&P Tanks 71432 Benzene 6.25E-2 3.13E-3 E&P Tanks 108883 Toluene 6.75E-2 3.38E-3 E&P Tanks 100414 Ethylbenzene 4.0E-3 2.0E-4 E&P Tanks 1330207 Xylenes 1.9E-2 9.5E-4 E&P Tanks 110543 n-hexane 4.61E-1 2.3E-2 E&P Tanks 540841 2,2,4-TMP 1.9E-2 9.5E-4 E&P Tanks AIRS ID: 123/2233 Page 7 of 8 Iolo ., De -- ent f Public Health and Environment Air Pollution Control Division Note: The controlled emissions factors for point 007 are based on the enclosed combustor control efficiency of 95%. These emission factors were developed using pressurized liquids analyses from the Kunzman Federal 13N-8HZ and Kunzman Federal 13C-8HZ Wells. 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: 123/2233 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: 15WE0307 Source Name: 36162745 Tank Battery Source Location: SESW of Section 5,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 gas is routed to the ECDs. AIRS ID: 123-2233-007 Date: July 27, 2015 Review Engineer: Harrison Slaughter Control Engineer: Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no"to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? March 4, 2015 Section 4—Source Description AIRS Point Equipment Description Page 1 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 007 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. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM,o CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source N/A PM,o N/A CO N/A Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region?(Note: If"yes"the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Section 5—Emission Estimate Information AIRS Point Emission Factor Source Source calculated site-specific emission factors using two pressurized liquid 007 samples,a sales oil analysis and two E&P Tanks simulations. 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/Throughput/Production 007 84,600 BBL per year—Representative of condensate throughput while flash gas is routed from the VRTs to the ECDs(30% of total throughput assumed) Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 84,600 BBL per year—Representative of condensate throughput while 007 flash gas is routed from the VRTs to the ECDs (30% of total N/A throughput assumed) Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 007 84,600 BBL per year—Representative of condensate throughput while flash gas is routed from the VRTs to the ECDs(30% of total throughput assumed) Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 007 01 Three(3) Enclosed Combustors 95 Section 6—Emission Summary(tons per year) Point NO,, VOC CO Single HAP Total HAP PTE: 007 1.2 300.0 2.9 19.5 26.8 n-Hexane Page 2 Uncontrolled point 007 1.2 300.0 2.9 19.5 26.8 source emission rate: n-Hexane Controlled point 007 1.2 15.0 2.9 1.0 1.4 source emission rate: n-Hexane Total APEN Reported 007 1.2 15.0 2.9 1.0 1.4 emissions: n-Hexane Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions (lb/yr) reportable? Rate(Ib/yr) Benzene 71432 A 5,288 Yes 265 Toluene 108883 C 5,711 Yes 286 Ethylbenzene 100414 C 339 Yes 17 Xylenes 1130207 C 1,608 Yes 81 n-Hexane 110543 C 39,001 Yes 1,950 2,2,4-Trimethylpentane 540841 C 1,608 Yes 81 Note: Regulation 3, Part A, Section Il.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory X Yes No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 007 01 VOC, Initial EPA Method 9 Colorado State Regulation 1 HAPS opacity 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 programs? Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? N/A Minor N/A Synthetic N/A Major Minor Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes",for which pollutants?Why? For Reg. 3, Part B, III.C.1.a (emissions increase> 25/50 tpy)? Yes X No For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? Page 3 If"yes", for which pollutants?Why? No because NOx emissions are less than 40 tpy; CO emissions are less than 100 tpy. AIRS Point Section 12—Regulatory Review Regulation 1 -Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20%opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9(40 CFR, Part 60,Appendix A(July, 007 1992)) in all subsections of Section II.A and B of this regulation. Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. Regulation 2—Odor 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 007 measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7)or more volumes of odor free air. Regulation 3-APENs, Construction Permits,Operating Permits, PSD Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 007 each individual emission point in a non-attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant(pollutants are not summed) for which the area is non-attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) Part B—Construction Permit Exemptions 007 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold(Reg. 3, Part B, Section II.D.2.a) Regulation 6-New Source Performance Standards 007 None Regulation 7—Volatile Organic Compounds 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 007 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 prior to August 1, 2014. As a result, the VRT is not subject to Regulation 7, Section XVII.G or the other control requirements of Regulation 7 Section XVI1.B.2 Regulation 8—Hazardous Air Pollutants MACT EEEE: Organic Liquids Distribution 007 • This source is not subject to MACT EEEE because it is not located at a major source of HAP. MACT HH 007 • This source is not subject to MACT HH because it is not located at a major source of HAP. Section 13—Aerometric Information Retrieval System Coding Information Process Emission Pollutant/ Fugitive Control Point Process Description Factor CAS# (YIN) Emission Factor Source (%) Page 4 7.09 lb/bbl VOC No E&P Tanks 95 throughput 0.026 lb/bbl NOx No Engineering Estimate NA throughput 0.067 lb/bbl CO No Engineering Estimate NA throughput 0.0625 Benzene/ lb/bbl 71432 No E&P Tanks 95 One(1)VRT throughput controlled by three 0.0675 Toluene/ 01 (3) ECDs during lb/bbl 108883 No E&P Tanks 95 007 throughput VRU bypass. 0.004 Ethylbenzene lb/bbl No E&P Tanks 95 / 100414 throughput 0.019 Xylenes/ lb/bbl 1130207 No E&P Tanks 95 throughput 0.461 n-Hexane/ lb/bbl 110543 No E&P Tanks 95 throughput 0.019 2,2,4-TMP/ lb/bbl 540841 No E&P Tanks 95 throughput SCC 31000205-Flares Page 5 Section 14—Miscellaneous Application Notes AIRS Point 007 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 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, two E&P Tanks simulations associated with the liquids samples, and a sales oil analysis. The pressurized liquid samples were obtained from two different wells at the facility. The wells from which the samples were taken include Kunzman Federal 13N-8HZ and Kunzman Federal 13C- 8HZ. The sales oil sample was obtained from a common production feed at the Kunzman well pad. 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 Kunzman Federal 13N-8HZ Kunzman Federal 13C-8HZ Emission Factors (lb/bbl) Emission Factors(lb/bbl) VOC 6.200 7.982 Benzene 0.063 0.062 Toluene 0.070 0.065 E-Benzene 0.004 0.004 Xylenes 0.021 0.017 n-Hexane 0.484 0.438 2,2,4-TMP 0.019 0.019 **The values from the E&P Tanks simulation have units of lb/hr; however, the simulation was run on a basis of 24 bbl/day, so the conversion from lb/hr to lb/bbl results in the same value. For example the flow rate of VOC from E&P Tanks for the 13N-8HZ well is 6.2 lb/hr. The conversion of this value to lb/bbl is as follows: VOC EF (lb/bbl) = (6.2 lb/hr)*(24 hr/day)*(1 day/24 bbl) =6.2 lb VOC/bbl. The overall emission factor for the VRT was determined through a simple average of the emission factors for each pollutant from the Kunzman Federal 13N-8HZ and the Kunzman Federal 13C-8HZ wells. Following is an example calculation of the determination of the overall emission factor: Overall EF = EF13N-8HZ+EF13C-8HZ 2 6.200 lb+ 7.982 lb 7.091 lb VOC Overall EF bbl bbl = voc = 2 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,lb (EF,lb VOC Emission Factortpy = \lb VOC/ * \ bbl / The calculation of the NOx and CO emission factors represented in the permit are as follow: 0.0037 lbs NOx) (7.091 lb VOC) _ 0.02624 lb NOx NOxIb/bbi = ( lb VOC I * \ bbl bbl 0.0094 lbs CO) (7.091 lb VOC) 0.06666 lb CO COib/bbt = ( lb VOC ) * \ bbl bbl The calculation of the NOx emission limit found in the permit is as follows: 0.02624 lbs NOx) (84,600 bbl) 1 ton l 1.11 tons NOx NOxtpy = ( bbl 1 * \ year ) * (20001bs1 year The calculation of the CO emission limit found in the permit is as follows: 0.06666 lb (84,600 bbl) ( 1 ton l _ 2.82 tons CO COtpy = , CO)1 bbl * \ year I * 120001bs1 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. Multiple discussions were held with the operator in order to update the language in the O&M plan. The sections updated in the O&M plan include the calculations section and the pilot flame monitoring and emission control section. The following language was updated/added to the calculations section of the O&M plan: Process Limits Daily ECD runtime and daily facility condensate throughput will be monitored and recorded. The daily facility condensate throughput will be converted to an average hourly rate and multiplied by the daily ECD runtime to determine the daily condensate throughput while gas is routed from the VRT to the ECDs. VRT condensate throughput while gas is routed to the ECD will be calculated on a monthly basis. Equation Condensate throughput while gas is routed from the VRT to the ECDs is calculated with the following equation: /Daily Condensate Throughput,bbl\* /1 day\*(Daily ECD Runtime,hrs) l day ) l24 hrs J Sample Calculation For example, if the automated sensors indicate that gas is routed from the VRT to the ECDs for two (2) hours in one day when 240 bbls are produced, then condensate throughput while gas is routed from the VRT to the ECDs would be calculated as follows: r240 bbl\ * r��is day *(2 hrs) = 20 bbls for one day in the month day ) This language was added in order to clarify the information in the O&M plan as well as tie it directly to the process and emission limits in the permit. Further,the pilot flame monitoring and emission control section was updated to express that the monitoring would be conducted on a weekly basis. The operator agreed to the updates that were made to the O&M plan. Page 7 3. 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