HomeMy WebLinkAbout20151419.tiff CDPHE ; COLORADO
co t]' , 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
1150O5t RECEIVED
PO Box 758
Greeley, CO 80632 MAY 1 4 2015
May 11, 2015 WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On May 13, 2015, the Air Pollution Control Division wilt begin a 30-day public notice period for
Synergy Resources Corporation - Kelly Farms Tank Farm Battery, Eberle Tank Farm Battery. 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,
1,
`-4.'& _�A.'L-4.�._ C,1,;
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
;. LL .) 2015-1419
5"a°"SS ee,:?c;?us;+it 5/Pg
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I ,± c
John W. Hickenlooper, Governor ! Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer
CE Air Pollution Control Division
CO Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Synergy Resources Corporation - Kelly Farms Tank Farm Battery, Eberle Tank Farm Battery -
Weld County
Notice Period Begins: May 13, 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: Synergy Resources Corporation
Facility: Kelly Farms Tank Farm Battery, Eberle Tank Farm Battery
Oil and gas exploration and production facility
SENW Section 4, T5N, R66W, NESE Section 32, T1N, R66W
Weld County
The proposed project or activity is as follows: Oil and gas exploration and production facilities with a
portable enclosed separator combustor.
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):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable 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 drafts of Construction Permits 14PO1353, 14PO1354
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:
Stephanie Chaousy
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 ACOLORADO
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STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT „° Ti.1' ail
AIR POLLUTION CONTROL DIVISION an. *,
TELEPHONE:TELEPHONE: (303) 692-3150 �k '
1806
CONSTRUCTION PERMIT
PERMIT NO: 14PO1353
Issuance 1
DATE ISSUED:
ISSUED TO: Synergy Resources Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Portable enclosed combustor, home based at the Kelly Farms Tank Battery, in the SENW of
Section 4, Township 5 North, Range 66 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS Description
Equipment ID Point
One (1) temporary Arctic Oilfield Services 4.5 MMSCF
Enclosed
001 enclosed combustor. Flare will be onsite to control flowback
flare/combustor
during well development.
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 APCD no later than fifteen days after issuance of this permit
by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup
(NOS) form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the APCD of startup of
the permitted source is a violation of 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 on this permit shall be demonstrated to the Division. It is the
permittee'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
on which such construction or activity was scheduled to commence as set forth in the
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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, Ill.F.4.b. (Reference: Regulation No. 3, Part B,
II I.F.4.)
4. 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
5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Tons per Year
Emission Type
Equipment ID Point NO VOC CO
x
Enclosed 001 2.2 80.0 11.7 Point
combustor/flare
See "Notes to Permit Holder #4 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.
6. 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 Control Device Pollutants
Equipment ID Point Controlled
Enclosed 001 Separator controlled by a flare stack VOC
combustor/flare
PROCESS LIMITATIONS AND RECORDS
7. This source shall be limited to the following maximum processing rates as listed below.
Annual records of the actual processing rate 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
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Enclosed 001 Natural gas flaring 48 MMSCF/yr
combustor/flare
STATE AND/OR FEDERAL REGULATORY REQUIREMENTS
8. 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).
9. 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. & 4.)
10. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
11. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B.2 General
Provisions (State only enforceable). All air pollution control equipment shall be operated
and maintained pursuant to the manufacturing specifications or equivalent to the extent
practicable, and consistent with technological limitations and good engineering and
maintenance practices. The owner or operator shall keep manufacturer specifications or
equivalent on file. In addition, all such air pollution control equipment shall be adequately
designed and sized to achieve the control efficiency rates and to handle reasonably
foreseeable fluctuations in emissions of VOCs and other hydrocarbons during normal
operations. Fluctuations in emissions that occur when the separator dumps into the tank
are reasonably foreseeable.
12. Per Regulation no. 7, Section XVII.B.2.d, all combustion devices used to control
emissions of hydrocarbons must be equipped with and operate an auto-igniter.
13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State
Only). On or after August 1, 2014, gas coming off a separator, produced during normal
operation from any newly constructed, hydraulically fractured, or recompleted oil and gas
well, must either be routed to a gas gathering line or controlled from the date of first
production by air pollution control equipment that achieves an average hydrocarbon
control efficiency of 95%. If a combustion device is used, it must have a design
destruction efficiency of at least 98% for hydrocarbons.
14. The flare referenced in this permit may be operated as a portable source within the
interior boundary of Weld County. This flexibility is provided to ensure the operator may
quickly respond to pumping unit capacity requirements at well pad operations within the
designated county. The operator of this flare is subject to the following relocation
notification requirements when this flare is moved within the county.
15. Synergy Resources Corporation shall maintain a record of each location the flare is
operated. The record shall be submitted to the Division on a quarterly basis by the last
day of each calendar quarter (March 31st, June 30th, September 30th and December
31st). The record shall include:
a. The APEN number and AIRS ID;
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b. The date of each relocation;
c. The exact location (Section, Township, Range, County and the name of the well
pad) corresponding to each relocation date identified;
d. A signature of an authorized official within the company.
16. When relocating this equipment the owner or operator shall (Reference: Regulation No.
3, Part A, Section II.C.1.f and Part B, Section III.E.):
a. Submit a Relocation Notice each time this equipment is moved to a new location.
The Relocation Notice shall be received by the Division at least ten (10) days
prior to the change in location.
The Relocation Notice shall include a facility emission inventory that includes all
emission units at the new location. An ambient air quality impact analysis for the
site shall be submitted with the Relocation Notice for this equipment if so
requested by the Division.
b. Maintain records of compliance with all additional requirements that are triggered
by the relocation. Such requirements may include, but are not limited to:
(1) State or Federal New Source Performance Standards (NSPS),
National Emission Standards for Hazardous Air Pollutants
(NESHAP), Maximum Achievable Control Technology (MACT),
and Generally Available Control Technology (GACT)
requirements; and
(2) Major source requirements, including Title V Operating Permit,
Nonattainment Area New Source Review (NANSR) and
Prevention of Significant Deterioration (PS D) program
requirements; and
(3) Permitting requirements for sources no longer permit exempt due
to the relocation of this unit to the site (i.e. previously Air Pollutant
Emission Notice (APEN) required, permit exempt sources).
c. Keep a record of all relocation notices submitted to the Division.
17. If this source relocates to a site causing the facility to become a major source for the
Title V Operating Permit program (see Regulation No. 3, Part A, I.B.23.) or relocates to
an existing Title V Permitted source then this source will be subject to the provisions of
Regulation No. 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act
Amendments). The application for the Operating Permit, or modification for inclusion in
the existing Operating Permit, is due within one year of the date of relocation to the site.
18. This unit shall not remain at any one site for more than two (2) years. Permittee shall
keep records of time spent at each site and provide these records to the Division upon
request (Reference: Regulation No. 3, Part A, I.B.34.). If this unit remains at a site for
two years then the permittee shall submit a revised Air Pollutant Emission Notice
(APEN) requesting a permit as a non-portable stationary source.
Note: If this replaces a unit and is intended to perform the same function as the unit
being replaced then the cumulative time for both units, including the time between
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removal of the original unit and installation of the replacement unit, will be counted
toward the total time spent at the site.
OPERATING & MAINTENANCE REQUIREMENTS
19. Upon startup of these points, 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.)
COMPLIANCE TESTING AND SAMPLING
20. The operator shall complete an initial site specific extended gas analysis of the natural
gas produced at this site in order to verify the VOC, benzene, toluene, ethylbenzene,
xylenes, n-hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission
stream used in the permit application. Results of testing shall be used to determine site-
specific emission factors using Division approved methods. Results of site-specific
sampling and analysis shall be submitted to the Division as part of the self-certification
and used to demonstrate compliance with the emissions factors chosen for this
emissions point.
21. 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
22. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually 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 (NO.) 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
AIRS ID: 777/4030 Page 5 of 9
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d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
f. Within 14 calendar days of commencing operation of a permanent replacement
engine under the alternative operating scenario outlined in this permit as
Attachment A. The APEN shall include the specific manufacturer, model and
serial number and horsepower of the permanent replacement engine, the
appropriate APEN filing fee and a cover letter explaining that the owner or
operator is exercising an alternative-operating scenario and is installing a
permanent replacement engine.
23. 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 Parts C and D).
GENERAL TERMS AND CONDITIONS:
24. 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.
25. 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.
26. 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.
27. 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.
28. 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
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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.
29. 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.
30. 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:
Stephanie Chaousy, P.E.
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Synergy Resources Corporation for a
portable enclosed combustor. Source is
synthetic minor.
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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: http://www.cdphe.state.co.us/regulations/airreqs/100102agcccommonprovisionsreq.pdf.
4) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Weight Emission Emission
CAS # Pollutant Fraction of Factors Factors Source
Gas (%) Uncontrolled Controlled
NOx 0.068 0.068 AP-42
lb/MMBtu lb/MMBtu
CO 0.37 AP-42
0.37 lb/MMBtu lb/MMBtu
VOC 11.791 66629.17 3331.46 Engineering
lb/mmscf lb/mmscf Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the June
22, 2014 analysis of a gas sample collected from the Phelps Gas sample ID. The controlled VOC
and HAP emissions factors for point 001 are based on the flare control efficiency of 95%.
5) 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.
6) This source is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source for
VOC
NANSR Synthetic Minor Source for
VOC
7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
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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 PA—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
8) 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: 777/4030 Page 9 of 9
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Division Information
Engineer. Stephanie Chaousy, PE Attainment Status
Control Engineer: Chris Laplantel PM10 Attainment
Review Date: 03/20/2015 PM2.5 Attainment
Application Date: 07/23/2014 SOx Attainment
Nonattainmen
NOx t
Nonattainmen
VOC t
Facility Information CO Attainment
Permit No. 14PO1353
County# 777 Portable
AIRs Facility# 4030
Point# 001
Facility Equipment ID Enclosed combustor/flare
Company Name: Synergy Resources Corporation
Source Name. Kelly Farms Tank Farm Battery
SENW Section 4.T5N. R66W
Source Location:
SIC: 211112
Elevation(feet)4748
APEN
New Permit Modification
X (CPI) (Issuance#) Required/Permit
Fxemot
Transfer of APEN
Ownership Exempt/Permit
Fxemot
Notes
Equipment Description
This source vents natural gas from'. a well head separator
Emissions from this source are. routed to an enclosed flare
Natural gas venting from a well head separator.Emissions from this source are routed to an
enclosed flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication:Volume II.Chapter 10-Displacement Equation(10.4-3)
Ex=Q*MW'Xx/C
Ex=emissions of pollutant x
O=Volumetric flow rate/volume of gas processed
MW=Molecular weight of gas=SG of gas*MW of air
Xx=mass fraction of x in gas
C=molar volume of ideal gas(379 scf/lb-mol)at 60F and 1 atm
Throughput(O) 48.0 MMscf/yr 66666.7 scf/hr I 4.08 MMscf/mo
MW 23.037 Ib/Ib-cool 0.001 MMscf/d
Only will be conning 1/3 of the year:29:
mole*4 MW lbx/Ibmol mass fraction E lb/hr Iblyr tpy
Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00
CO2 2.087 44.01 0.918 0.040 CO2 1616 471766 235.88
N2 0.566 28.013 0.159 0.007 N2 27.9 81438 40.72
methane 71.682 16.041 11.499 0.499 methane 2022.6 5906007 2953.00
ethane 13.873 30.063 4.171 0.181 ethane 733.6 2142176 1071.09
propane 7.088 44.092 3.1252 0.136 propane 549.7 1605225 802.61
isobutane 0.81 58.118 0.4708 0.020 isobutane 82.8 241795 120.90
n-butane 2.223 58.118 1.2920 0.056 n-butane 22A3 663594 331.80
isopentane 0.442 72.114 0.3187 0.014 isopentane 56.1 163717 81.86
n-pentane 0.52 /2.114 0.3750 0.016 n-pentane 66.0 192608 96.30
cyclopentane 0 70.13 0.0000 0.000 cyclopentane 0.0 0 0.00
n-Hexane 0.0000 86.18 0.0000 0.000 n-Hexane 0.0 0 0.00
cyclohexane 0.0000 84.16 0.0000 0.000 cyclohexane 0.0 0 0.00
Other hexanes 0.686 86.18 0.5912 0.026 Other hexanes 104.0 303657 151.83
heptanes 0 100.21 0.0000 0.000 heptanes 0.0 0 0.00
methylcyclohexane 0 98.19 0.0000 0.000 methylcyclohexane 0.0 0 0.00
224-TMP 0 114.23 0.0000 0.000 224-TMP 0.0 0 0.00
Benzene 0 78.12 0.0000 0.000 Benzene 0.0 0 0.00
Toluene 0 92.15 0.0000 0.000 Toluene 0.0 0 0.00
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Ethylbenzene 0 106.17 0.0000 0.000 Ethylbenzene 0.0 0 0.00
Xylenes 0 106.17 0.0000 0.000 Xylenes 0.0 0 0.00
C8+Heavies 0.00001 1179167 300 0.1179 0.005 C8+Heavies 207 60566 30.28
VOC mass fraction: 0.2731 Total VOC Emissions(Uncontrolled) 1615.6
23.037 annual limit assuming 95%control 80.8
Notes monthly limit assuming 95%control(lb/mo.) 13721.4
Mole%,MW,and mass fractions from Renfroe Wells gas analysis sampled 10/22/2013
Emissions are based on 2920 hours of operation per year.
I calculated the average MW of C8+based on the average MW on the analysis for the gas.Operator calculated 1599.1 TPY uncontrolled and 80.0
TPY controlled. I believe this is due to rounding between
Flaring Information the 2 sets of calculations. I will use the operator's
Equipment Description calculations for they are insignificantly different.
Flare to combust produced gas until pipeline is available at this wellhead facility.
Manufacturer Artie Oilfield
Model 4.5 MMSCF
Serial Number TBD
Gas Heating Value 1319 Btu/scf
Throughput 63312 MMBtu/yr
Combustion emission factor source: AP-42:Chapter 13.5
0.068 lb NOX/MMBtu 0.37 lb CO/MMBtu
2.15 tpy NOX 11.71 tpy CO
Emissions Summary
2.15 tpy NOX
Uncontrolled/PTE 11.71 tpy CO
1599.100 tpy VOC Emission factor= 66629.167 lb/mmscf
Controlled 79.955 tpy VOC
Uncontrolled Scenario A Controlled
Total(lb/yr) Bin Reportable? Total(lb/yr)
Benzene 0 A No 0
Toluene 0 C No 0
Ethylbenzene 0 C No 0
Xylenes 0 C No 0
n-hexane 0 C _ No 0
224-TMP 0 C No 0
Regulatory Applicability
AQCC Regulation 1
This source is subject to the opacity requirements for flares in Section II A.5:'No owner or operator
of a smokeless flare or other flare for the combustion of waste gases shall allow or cause
emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.'
AQCC Regulation 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 following limits: For areas used predominantly for residential
or commercial purposes it is a violation if odors are detected after the odorous air has been diluted
with seven(7)or more volumes of odor free air."
AQCC Regulation 3
An APEN is required for this source because uncontrolled VOC emissions
Part A: exceed one ton per year in a nonattainment area for ozone.
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed two tons per year in a nonattainment area for ozone.
Part B: This source is subject to Section III.D.2(Minor Source RACT)because it is
located in a nonattainment area.RACT for this source has been determined to
be the use of a flare to control emissions.
Is public comment Public Comment Required
required?
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0
STATE OF COLORADO
of �a�
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT i�-`�-- `o
AIR POLLUTION CONTROL DIVISION �',*�C "19*'
TELEPHONE: (303) 692-3150 *4187e*
CONSTRUCTION PERMIT
PERMIT NO: 14PO1354
Issuance 1
DATE ISSUED:
ISSUED TO: Synergy Resources Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Portable enclosed combustor, home based at the Eberle Tank Battery, in the NESE of
Section 32, Township 1 North, Range 66 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS Description
Equipment ID Point
One (1) temporary Arctic Oilfield Services 4.5 MMSCF
Enclosed
001 enclosed combustor. Flare will be onsite to control flowback
flare/combustor
during well development.
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 APCD no later than fifteen days after issuance of this permit
by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup
(NOS) form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the APCD of startup of
the permitted source is a violation of 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 on this permit shall be demonstrated to the Division. It is the
permittee'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
on which such construction or activity was scheduled to commence as set forth in the
AIRS ID: 777/4031 Page 1 of 9
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permit application associated with this permit; (H) 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 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
5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Tons per Year
- Emission Type
Equipment ID Point NO VOC CO
x
Enclosed 001 2.1 71.2 11.4 Point
combustor/flare
See "Notes to Permit Holder #4 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.
6. 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 Control Device Pollutants
Equipment ID Point Controlled
Enclosed 001 Separator controlled by a flare stack VOC
combustor/flare
PROCESS LIMITATIONS AND RECORDS
7. This source shall be limited to the following maximum processing rates as listed below.
Annual records of the actual processing rate 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
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Enclosed 001 Natural gas flaring 48 MMSCF/yr
combustor/flare
STATE AND/OR FEDERAL REGULATORY REQUIREMENTS
8. 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).
9. 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. & 4.)
10. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
11. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B.2 General
Provisions (State only enforceable). All air pollution control equipment shall be operated
and maintained pursuant to the manufacturing specifications or equivalent to the extent
practicable, and consistent with technological limitations and good engineering and
maintenance practices. The owner or operator shall keep manufacturer specifications or
equivalent on file. In addition, all such air pollution control equipment shall be adequately
designed and sized to achieve the control efficiency rates and to handle reasonably
foreseeable fluctuations in emissions of VOCs and other hydrocarbons during normal
operations. Fluctuations in emissions that occur when the separator dumps into the tank
are reasonably foreseeable.
12. Per Regulation no. 7, Section XVII.B.2.d, all combustion devices used to control
emissions of hydrocarbons must be equipped with and operate an auto-igniter.
13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State
Only). On or after August 1, 2014, gas coming off a separator, produced during normal
operation from any newly constructed, hydraulically fractured, or recompleted oil and gas
well, must either be routed to a gas gathering line or controlled from the date of first
production by air pollution control equipment that achieves an average hydrocarbon
control efficiency of 95%. If a combustion device is used, it must have a design
destruction efficiency of at least 98% for hydrocarbons.
14. The flare referenced in this permit may be operated as a portable source within the
interior boundary of Weld County. This flexibility is provided to ensure the operator may
quickly respond to pumping unit capacity requirements at well pad operations within the
designated county. The operator of this flare is subject to the following relocation
notification requirements when this flare is moved within the county.
15. Synergy Resources Corporation shall maintain a record of each location the flare is
operated. The record shall be submitted to the Division on a quarterly basis by the last
day of each calendar quarter (March 31st, June 30th, September 30th and December
31st). The record shall include:
a. The APEN number and AIRS ID;
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b. The date of each relocation;
c. The exact location (Section, Township, Range, County and the name of the well
pad) corresponding to each relocation date identified;
d. A signature of an authorized official within the company.
16. When relocating this equipment the owner or operator shall (Reference: Regulation No.
3, Part A, Section II.C.1.f and Part B, Section III.E.):
a. Submit a Relocation Notice each time this equipment is moved to a new location.
The Relocation Notice shall be received by the Division at least ten (10) days
prior to the change in location.
The Relocation Notice shall include a facility emission inventory that includes all
emission units at the new location. An ambient air quality impact analysis for the
site shall be submitted with the Relocation Notice for this equipment if so
requested by the Division.
b. Maintain records of compliance with all additional requirements that are triggered
by the relocation. Such requirements may include, but are not limited to:
(1) State or Federal New Source Performance Standards (NSPS),
National Emission Standards for Hazardous Air Pollutants
(NESHAP), Maximum Achievable Control Technology (MACT),
and Generally Available Control Technology (GACT)
requirements; and
(2) Major source requirements, including Title V Operating Permit,
Nonattainment Area New Source Review (NANSR) and
Prevention of Significant Deterioration (PSD) program
requirements; and
(3) Permitting requirements for sources no longer permit exempt due
to the relocation of this unit to the site (i.e. previously Air Pollutant
Emission Notice (APEN) required, permit exempt sources).
c. Keep a record of all relocation notices submitted to the Division.
17. If this source relocates to a site causing the facility to become a major source for the
Title V Operating Permit program (see Regulation No. 3, Part A, I.B.23.) or relocates to
an existing Title V Permitted source then this source will be subject to the provisions of
Regulation No. 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act
Amendments). The application for the Operating Permit, or modification for inclusion in
the existing Operating Permit, is due within one year of the date of relocation to the site.
18. This unit shall not remain at any one site for more than two (2) years. Permittee shall
keep records of time spent at each site and provide these records to the Division upon
request (Reference: Regulation No. 3, Part A, I.B.34.). If this unit remains at a site for
two years then the permittee shall submit a revised Air Pollutant Emission Notice
(APEN) requesting a permit as a non-portable stationary source.
Note: If this replaces a unit and is intended to perform the same function as the unit
being replaced then the cumulative time for both units, including the time between
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removal of the original unit and installation of the replacement unit, will be counted
toward the total time spent at the site.
OPERATING & MAINTENANCE REQUIREMENTS
19. Upon startup of these points, 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.)
COMPLIANCE TESTING AND SAMPLING
20. The operator shall complete an initial site specific extended gas analysis of the natural
gas produced at this site in order to verify the VOC, benzene, toluene, ethylbenzene,
xylenes, n-hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission
stream used in the permit application. Results of testing shall be used to determine site-
specific emission factors using Division approved methods. Results of site-specific
sampling and analysis shall be submitted to the Division as part of the self-certification
and used to demonstrate compliance with the emissions factors chosen for this
emissions point.
21. 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
22. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually 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 (NO,) 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
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Vu
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
f. Within 14 calendar days of commencing operation of a permanent replacement
engine under the alternative operating scenario outlined in this permit as
Attachment A. The APEN shall include the specific manufacturer, model and
serial number and horsepower of the permanent replacement engine, the
appropriate APEN filing fee and a cover letter explaining that the owner or
operator is exercising an alternative-operating scenario and is installing a
permanent replacement engine.
23. 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 Parts C and D).
GENERAL TERMS AND CONDITIONS:
24. 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.
25. 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.
26. 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.
27. 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.
28. 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
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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.
29. 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.
30. 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:
Stephanie Chaousy, P.E.
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Synergy Resources Corporation for a
portable enclosed combustor. Source is
synthetic minor.
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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: http://www.cdphe.state.co.us/requlations/airregs/100102agcccommonprovisionsreq.pdf.
4) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Weight Emission Emission
CAS# Pollutant Fraction of Factors Factors Source
Gas (To) Uncontrolled Controlled
NOx 0.068 0.068 AP-42
lb/MMBtu lb/MMBtu
CO 0.37 AP-42
0.37 lb/MMBtu lb/MMBtu
VOC 10.366 59304.167 2965.208 Engineering
lb/mmscf Ib/mmscf Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the June
22, 2014 analysis of a gas sample collected from the Phelps Gas sample ID. The controlled VOC
and HAP emissions factors for point 001 are based on the flare control efficiency of 95%.
5) 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.
6) This source is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source for:
VOC
NANSR Synthetic Minor Source for:
VOC
7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
AIRS ID: 777/4031 Page 8 of 9
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4
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Air Pollution Control Division
a tea, aiibx
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
8) 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: 777/4031 Page 9 of 9
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Division Information
Engineer: Stephanie Chaousy, PE Attainment Status
Control Engineer: Chris Laplante' PM10 Attainment
Review Date: 01/12/2015 PM2.5 Attainment
Application Date: 07/23/2014 SOx Attainment
Nonattainmen
NOx t
Nonattainmen
VOC t
Facility Information CO Attainment
Permit No. 14PO1354
County# 777 Portable
AIRs Facility# 4031
Point# 001
Facility Equipment ID Enclosed combustor/flare
Company Name: Synergy Resources Corporation
Source Name: Eberle Tank Farm Battery
NESE Section 32,TIN, R66W
Source Location:
SIC: 211112
Elevation(feet) 5036
New Permit Modification APEN
X (CPI) (Issuance#) Required/Permit
Exempt
Transfer of APEN
Ownership Exempt/Permit
Fxemot
Notes
Equipment Description
This source vents natural gas from: a well head separator
Emissions from this source are. routed to an enclosed flare
Natural gas venting from a well head separator. Emissions from this source are routed to an
enclosed flare.
Emission Calculation Methcd
EPA Emission Inventory Improvement Program Publication:Volume II, Chapter 10-Displacement Equation(10.4-3)
Ex=Q'MW'Xx/C
Ex=emissions of pollutant x
Q=Volumetric flow rate/volume of gas processed
MW=Molecular weight of gas=SG of gas"MW of air
Xx=mass fraction of x in gas
C=molar volume of ideal gas(379 scf/lb-mol)at 60F and 1 atm
Throughput(CO 48.0 MMscf/yr 66666.7 sct/hr 4.08 MMscf/mo l
MW 22.440 Ib/Ib-mot 0.001 MMscf/d
Only will be mnninq 1/3 of the year:29:
mole% MW Ibx/Ibmol mass fraction E Iblhr lb/yr tpy
Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00
CO2 1.78 44.01 0.783 0.035 CO2 137.8 402368 201.18
N2 0.979 28.013 0.274 0.012 N2 48.2 140862 70.43
methane 73.688 16.041 11.820 0.527 methane 2079.2 6071285 3035.64
ethane 13.186 30.063 3.964 0.177 ethane 697.3 2036094 1018.05
propane 5.8 44.092 2.5573 0.114 propane 449.8 1313531 656.77
isobutane 0.825 58.118 0.4795 0.021 isobutane 84.3 246273 123.14
n-butane 2.206 58.118 1.2821 0.057 n-butane 226.5 658519 329.26
isopentane 0.484 72.114 0.3490 0.016 isopentane 61.4 179274 89.64
n-pentane 0.542 /2.114 0.3916 0.01/ n-pentane 68.9 201128 100.55,
cyclopentane 0 70.13 0.0000 0.000 cyclopentane 0.0 0 0.00
n-Hexane 0.0000 86.18 0.0000 0.000 n-Hexane 0.0 0 0.00
cyclohexane 0.0000 84.16 0.0000 0.000 cyclohexane 0.0 0 0.00
Other hexanes 0.508 86.18 0.4378 0.020 Other hexanes 77.0 224865 112.43
heptanes 0 100.21 0.0000 0.000 heptanes 0.0 0 0.00
methylcyclohexane 0 98.19 0.0000 0.000 methylcyctohexane 0.0 0 0.00
224-TMP 0 114.23 0.0000 0.000 224-TMP 0.0 0 0.00
Benzene 0 78.12 0.0000 0.000 Benzene 0.0 0 0.00
Toluene 0 92.15 0.0000 0.000 Toluene 0.0 0 0.00
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Ethylbenzene 0 106.17 0.0000 0.000 Ethylbenzene 0.0 0 0.00
Xylenes 0 106.17 0.0000 0.000 Xylenes 0.0 0 0.00
C8+Heavies 0.00001 1006777 100 0.1007 0.004 C8+Heavies 17.7 51711 25.86
VOC mass fraction: 0.2495 Total VOC Emissions(Uncontrolled) 1437.7
22.440 annual limit assuming 95%control 71.9
Notes monthly limit assuming 95%control(lb/mo.) 12210.2
Mole%,MW.and mass fractions from Phelps Gas gas analysis sampled 6/2/2014.
Emissions are based on 2920 hours of operation per year. Operator calculated 1423.3 TPy uncontrolled and 71.2
I calculated the average MW of C8+based on the average MW on the analysis for the gas.Tpy controlled. I believe this is due to rounding between
the 2 sets of calculations. I will use the operators
Flaring Information calculations for they are insignificantly different.
Equipment Description
Flare to combust produced gas until pipeline is available at this wellhead facility.
Manufacturer Antic Oilfield
Model 4.5 MMSCF
Serial Number TBD
Gas Heating Value 1288 Btu/scf
Throughput 61824 MMBtu/yr
Combustion emission factor source: AP-42:Chapter 13.5
0.068 lb NOX/MMBtu 0.37 lb CO/MMBtu
2.10 tpy NOX 11.44 tpy CO
Emissions Summary
2.10 tpy NOX
Uncontrolled/PTE 11.44 tpy CO
1423.300 tpy VOC Emission factor= 59304.167 lb/mmscf
Controlled 71.165 tpy VOC
Uncontrolled Scenario A Controlled
Total(Ib/yr) Bin Reportable? Total(Ib/yr)
Benzene 0 A No 0
Toluene 0 C No 0
Ethylbenzene 0 C No 0
Xylenes 0 C No 0
n-hexane 0 C No 0
224-TMP 0 C No 0
Regulatory Applicability
AQCC Regulation 1
This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator
of a smokeless flare or other flare for the combustion of waste gases shall allow or cause
emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.'
AQCC Regulation 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 following limits: For areas used predominantly for residential
or commercial purposes it is a violation if odors are detected after the odorous air has been diluted
with seven(7)or more volumes of odor free air."
AQCC Regulation 3
An APEN is required for this source because uncontrolled VOC emissions
Part A: exceed one ton per year in a nonattainment area for ozone.
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed two tons per year in a nonattainment area for ozone.
Part B: This source is subject to Section III.D.2(Minor Source RACT)because it is
located in a nonattainment area.RACT for this source has been determined to
be the use of a flare to control emissions.
Is public comment Public Comment Required
required?
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