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Home My WebLink About20152876.tiff A CDPHE COLORADO T `CO Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 RECEIVED Greeley, CO 80632 August 20, 2015 AUG 2 6 2015 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On August 26, 2015, the Air Pollution Control Division will begin a 30-day public notice period for Kerr-McGee Oil and Gas Onshore LP - 36142331 (Turkey Springs 1N-14HZ). 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 - 2015-2876 S-34 - 16- LC .R., l-ii;?to g(a-c,0 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe 'r9; John W. Hickentooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer i,+ r:; \*,pb76_ A CDPHE Air Pollution Control Division CO Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Kerr-McGee Oil and Gas Onshore LP - 36142331 (Turkey Springs 1N-14HZ) - Weld County Notice Period Begins: August 26, 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: 36142331 (Turkey Springs 1N-14HZ) Oil Et Gas Production facility NWNE Section 23, Township 2N, Range 66W Weld County The proposed project or activity is as follows: Applicant is operating a vapor recovery tower (VRT) to provide 3rd stage gas/liquid separation. During normal operation emissions are recompressed into sates line by Vapor Recovery Unit (VRU). This permit addresses emissions during VRU downtime when emissions are routed to a flare. 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 15WE0311 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 I Alr H , rz ',T. x TATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT /,‘,4, iitter: AIR POLLUTION CONTROL DIVISION l'-7 . 8, TELEPHONE: (303) 692-3150 ,,*4k *i `*1876% CONSTRUCTION PERMIT PERMIT NO: 1 5WE031 I Issuance 1 DATE ISSUED: ISSUED 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 Tank Battery 36142331 (Turkey Springs 1 N-14HZ), located in the NWNE Sec. 23, T2N, R66W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID The Vapor Recover Tower (VRT) processes liquid from the 2nd stage of separation to create a 3rd stage of liquid/gas separation. During normal operation flash gas produced from the VRT is VRT-01 005 routed to the vapor recovery units (VRUs) in a closed loop process. When the VRUs are unable to capture the entire flash gas stream, the remaining flash gas is routed to enclosed combustion devices (ECDs). This permit addresses emissions when flash gas 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 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). AIRS ID: 123/9C41 Page 1 of 8 olo o 0. - -n _•f -ublic Health and Environment A Air Pollution Control Division 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-01 005 --- 11.4 2.2 Point See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. AIRS ID: 123/9C41 Page 2 of 8 T1:ioioj&o D a o f ublic Health and Environment Air Pollution Control Division 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 Equipment Point Control Device Pollutants Controlled ID VRT-01 005 Enclosed Combustion Devices (ECDs) VOC, HAPs PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID VRT-01 005 Condensate throughput to VRT while 70,000 bbl/yr emissions are routed to ECDs 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 10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. 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.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 13. Upon startup of these points, 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.) AIRS ID: 123/9C41 Page 3 of 8 olo o D= -n of ublic Health and Environment Air Pollution Control Division 14. The owner or operator shall continuously monitor and record the amount of time that the valves from the VRTs to the ECDs are open. The owner or operator shall use monthly recorded flare 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 I I.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 e. No later than 30 days before the existing APEN expires. 17. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). AIRS ID: 123/9C41 Page 4 of 8 olo o D a o f ublic Health and Environment Air Pollution Control Division GENERAL TERMS AND CONDITIONS 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This 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. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. AIRS ID: 123/9C41 Page 5 of 8 oloA o D- -n if ublic Health and Environment Air Pollution Control Division By: Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This issuance Issued to Kerr-McGee Oil and Gas Onshore LP AIRS ID: 12319C41 Page 6 of 8 olo o D a o f ublic Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpaqename=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# (lb/yr) reportable? (Ib/yr) n-Hexane 110543 14805 Yes 740 Benzene 71432 2520 Yes 126 Toluene 108883 4130 Yes 207 005 Ethylbenzene 100414 910 Yes 46 Xylenes 1130207 3325 Yes 166 2,2,4- 540841 2485 Yes 124 Trimethylpentane 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors Pollutant Uncontrolled Source (lb/bbl) VOC 6.4800 CO 0.0609 n-hexane 0.2115 Benzene 0.0360 E&P Tank V2.0 Toluene 0.0590 Ethylbenzene 0.0130 Xylenes 0.0475 2,2,4-TMP 0.0355 AIRS ID: 123/9C41 Page 7 of 8 olo o D: -n if -'ublic Health and Environment I ip AL Air Pollution Control Division Note: The controlled emissions are based on the combustor control efficiency of 95%. These emission factors were developed using pressurized liquids analyses from the Turkey Springs 1N-14HZ and 10N-7HZ wells sampled on January 19, 2015. 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 NANSR Synthetic Minor 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 XXX)0(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.cov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9C41 Page 8 of 8 Division Information Engineer: Bradley Eades Control Engineer: Christopher Laplante Review Date: 07/10/2015 Application Date: 07/10/2015 Facility Identifiers Permit No. 15WE0311 Potentially located in ozone nonattainment area AIRS County# 123 Weld Facility# 9C41 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: Kerr-McGee Oil and Gas Onshore LP Source Name: Tank Battery 36142331 Source Location: NWNE, Section 23, T2N, R66W SIC: 1311 Address 1: Kerr-McGee Oil and Gas Onshore LP Mailing Address 2: PO Box 173779 Address ty,State Zip: Denver, CO 80217 Name: Carissa Krey Person To Phone: 720-929-6916 Contact Fax: 720-929-7916 Email: Carissa.krey@anadarko.com 'Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the Tank Battery 36142331, located in the NWNE, Section 23,T2N, R66W,Weld County, Colorado. Point Name Type Control Action Newly 005 VRT-01 Separator Venting Flare reported P source Flash gas produced from 3rd stage gas/liquid separation between HLP separators and condensate storage tanks. 005 Emissions are a function of condensate throughput while emissions are routed to Enclosed Combustors(ECDs). Emissions are routed to ECDs when the existing vapor recovery units are not able to capture all of the flash gas from the VRT *Requsted Throughput 70000 bbl/yr *This throughput is based on estimated time(40%)that flash gas from VRT is routed to ECDs(Total Liq.Throughput:175,000 BBL/yr) Control Flare I 48"ECDs Efficiency 95.00%I Emissions Summary Table Pollutant *Emission Factor Uncontrolled Emissions Controlled Emissions I Source VOC 6.4800 lb/bbl 226.80 tpy 11.34 tpy Benzene 0.0360 lb/bbl 2520.0 lb/yr 126.0 lb/yr Toluene 0.0590 lb/bbl 4130.0 lb/yr 206.5 lb/yr Ethylbenzene 0.0130 lb/bbl 910.0 lb/yr 45.5 lb/yr E&P Tank Xylene 0.0475 lb/bbl 3325.0 lb/yr 166.3 lb/yr 224-TMP 0.0355 lb/bbl 2485.0 lb/yr 124.3 lb/yr n-Hexane 0.2115 lb/bbl 14805.0 lb/yr 740.3 lb/yr *The emission factors were calculated using E&P Tank V2.0 by modeling the bottom vessel of the HLP as the separator,and the VRT as the tank.Two pressurized liquid samples were taken from the site(Turkey Springs 1N-14HZ&Turkey Spgs 3C-14HZ;sampled 01/19/2015) and the corresponding E&P Tank outputs were averaged for each constituent. Pollutant Emission Factor Source CO 0.0094 Ib/IbVOC 0.061 lb/bbl CDPHE Inter-Office Communication to Inventory NOx 0.0037 lb/lbVOC 0.024 lb/bbl &Support Group 03/22/2005 Pollutant Emission Factor Controlled Emissions CO 0.0609 lb/bbl 2.13 tpy Nox 0.0240 lb/bbl 0.84 tpy Regulatory Review 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, 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 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 6-New Source Performance Standards Regulation 7—Volatile Organic Compounds AQCC Regulation 7 Was the well newly constructed, hydraulically fractured,or recompleted on or after August 1,2014? No Per email from KMG,the date of first production for the most recently completed well is 11/19/2013 This separator is not subject to Reg 7 Section XVII.G (Miscellaneous Notes Applicant is calculating emisisons based on the liquid throughput and measured flare run-time.Automated sensors will monitor the amount of time that produced gas is routed to the flare.The total monthly condensate will be multiplied by the fraction of time each month that emissions are routed to the flare to calculate a liquid throughput to VRT during VRU downtime. Rather than monitoring and recording VRU downtime,the operator has requested to monitor time that the valve is open and allowing emissions to be routed to the flare(there are multiple VRUs on-line that may still be able to handle all of the flash gas in the event that one of the VRUs are down). Sent operator suggested changes to O&M Plan on 7/13/2015 to include"KMOGO shall monitor and record total condensate throughput on a monthly basis using sales/haul tickets or other methods"and"pilot flames shall be monitored through visual inspection,auto-igniter signals,or thermocouples.Also,Section 6 was changed to require records be maintained for a period of 5 years. Per email from Mr.Steger on 07/13/2015,the most recently completed well at this facility is Turkey Springs 1N-14HZ.The date of first production from this well was 11/19/2013. Per conversation with applicant,the entire gas stream may not be routed to the flare(i.e.VRUs may still be capturing some of the gas and recompressing it into sales)however emissions during flare run-time are calculated and reported as if the entire gas stream is routed to the ECDs during flare run-time. AIRS(County/Plant) 123/9C41 Permit No. 15WE0311 Date 7/13/2015 Controlled Controlled Actual Requested NCRP= Uncontrolled Emisison Factor Emissions Emissions Ctrl. reportable Point# SCC Pollutant or CAS Emission Factor Source (tpy)* (tpy)* PTE(tpy)* Eff% ? 005 31000205 VOC 6.48 lb/bbl E&P Tank V2.0 11.34 226.8 95% Yes 005 31000205 NOx 0.024 lb/bbl CDPHE 0.84 0.84 95% No 005 31000205 CO 0.061 lb/bbl CDPHE 2.13 2.13 95% No 005 31000205 Benzene 0.036 lb/bbl E&P Tank V2.0 126 2520 95% Yes 005 31000205 n-Hexane 0.2115 lb/bbl E&P Tank V2.0 740 14805 95% Yes 005 31000205 Toluene 0.059 lb/bbl E&P Tank V2.0 207 4130 95% Yes 005 31000205 2,2,4-TMP 0.0355 lb/bbl E&P Tank V2.0 124 2485 95% Yes 005 31000205 Xylenes 0.0475 lb/bbl E&P Tank V2.0 166 3325 95% Yes 005 31000205 Ethylbenzene 0.013 Ib/bbl E&P Tank V2.0 46 910 95% Yes y O U `N ai O O p 0 U "CI .: C GO 'n '- V �"'r4 S CD �jp" ,� __, aJ C a ❑ y E z U J M M _ V —0 N . V N N N y :J •> .0 C a, ,-. ._ a. N T C y CL a U 0. _y C 0 G= 0 Z O o c 0. 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