HomeMy WebLinkAbout20153437.tiff C4Ita COLORADO
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
1150 O St RECEIVED
PO Box 758
Greeley, CO 80632 OCT 2 3 2015
October 19, 2015 WELD COUNTY
1?` +. +11SS1ONERS
Dear Sir or Madam:
On October 21, 2015, the Air Pollution Control Division will begin a 30-day public notice period for
Kerr-McGee Oil and Gas Onshore LP - 36164995. 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
• �� 2015-3437
c-PUbtte_) e t, tom; tic.. ��Ia3
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer
A CDPHE Air Pollution Control Division
co s Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Kerr-McGee Oil and Gas Onshore LP - 36164995 - Weld County
Notice Period Begins: October 21, 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: 36164995
Exploration and production site
SWSW $6 Ti N R65W
Weld County
The proposed project or activity is as follows: Addition of vapor recovery tower (VRT) to provide third stage
of separation at a well production site. Gas from VRT is routed to a vapor recovery unit (VRU) and
compressed into a sales line. During VRU bypass/downtime, gases are routed to enclosed flares. This permit
covers the time when VRT gas is routed to the flares.
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 15WE0452 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:
Betsy Gillard
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
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STATE OF COLORADO
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COLOR D T F P IC HEALTH AND ENVIRONMENT es
AIR POLLUTION CONTROL DIVISION ,,W c1.,
TELEPHONE: (303) 692-3150 * "**
*/876*
CONSTRUCTION PERMIT
PERMIT NO: 15WE0452
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 the 36164995, located at
SWSW S6 Ti N R65W, Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
One (1) vapor recovery tower (VRT) that processes liquid from the
second stage of separation to create a third stage of liquid/gas
separation. Overhead flash gas from the VRT is routed to the
vapor recovery units (VRUs) in a closed loop process. When the
VRUs are unable to capture the entire overhead gas stream, flash
VRT-01 005 gas is routed to 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.
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 commencement of operation or issuance of this permit,
whichever comes later, 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.
AIRS ID: 123/7865 Page 1 of 8
olor. Depa - en . P •Ii ealth and Environment
it Pollution Control Division
I
2. Within one hu- d z. • - :0) - - --men - t of operation or issuance
of this permit, whichever comes later, compliance with the conditions contained in this
permit shall be demonstrated to the Division. It is the owner or operator's responsibility to
self-certify compliance with the conditions. Failure to demonstrate compliance within 180
days may result in revocation of the permit. (Reference: Regulation No. 3, Part B,
III.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
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 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
X
VRT-01 005 1.5 19.8 3.7 Point
See "Notes to Permit Holder"for information on emission factors and methods used to calculate
limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
AIRS ID: 123/7865 Page 2 of 8
olora Depa'Hemp P'- Ii Health and Environment
it Pollution Control Division
Compliance it, ,- -nn$.A A}gym . .: I b !-1-t- ed b F.rding the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
VRT-01 005 Enclosed Flare(s) VOC
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
Condensate throughput through VRT while
VRT-01 005 emissions are routed to enclosed 97,500 bbl
combustion devices
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 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. Emission control devices subject to Regulation 7,
AIRS ID: 123/7865 Page 3 of 8
olor. DeP a en •Ii ''Health and Environment
A •it Pollution Control Division
Sections XII. XVII.B.2.b ' .w= •av- e em'- s. (Reference: Regulation
No. 1, Section I I.A.1. &4.)
12. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
13. The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B
General Provisions (State only enforceable). These requirements include, but are not
limited to:
• XVII.B.2.b If a combustion device is used to control emissions of volatile organic
compounds to comply with Section XVII, it shall be enclosed, have no visible
emissions during normal operations, and be designed so that an observer can,
by means of visual observation from the outside of the enclosed combustion
device, or by other means approved by the Division, determine whether it is
operating properly.
• XVII.B.2.d Auto-igniters: All combustion devices used to control emissions of
hydrocarbons must be equipped with and operate an auto-igniter as follows:
• XVII.B.2.d.(i) All combustion devices installed on or after May 1, 2014, must be
equipped with an operational auto-igniter upon installation of the combustion
device.
• XVII.B.2.d.(ii) All combustion devices installed before May 1, 2014, must be
equipped with an operational auto-igniter by or before May 1, 2016, or after the
next combustion device planned shutdown, whichever comes first.
14. The VRT 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.
OPERATING & MAINTENANCE REQUIREMENTS
15. 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.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Method 22 to measure opacity from the flare. (Reference: Regulation No. 7, Section
XVII)
AIRS ID: 123/7865 Page 4 of 8
'Tr
olora :Depa en PA.li Health and Environment
. . it Pollution Control Division
ADDITIONAL REQ i N ss,
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, I I.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 (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
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
virtue of a relaxation in any permit condition. Any relaxation that increases the potential
to emit above the applicable Federal program threshold will require a full review of the
source as though construction had not yet commenced on the source. The source shall
not exceed the Federal program threshold until a permit is granted. (Regulation No. 3
Part D).
GENERAL TERMS AND CONDITIONS
19. 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.
20. 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
AIRS ID: 123/7865 Page 5 of 8
I Ill
olorl Depa en . P •li Health and Environment
it Pollution Control Division
and has been - sy •_- c•, in all -,-cts 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.
21. 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.
22. 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.
23. 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.
24. 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.
25. 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:
Betsy Gillard
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Kerr-McGee Oil and Gas Onshore LP
AIRS ID: 123/7865 Page 6 of 8
V . .color. Depa em) P. li "Health and Environment
it Pollution Control Division
Notes to Permit Holder e" ime
.e: `" an
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 Are the Controlled
AIRS Emission Rate emissions Emission Rate
Point Pollutant CAS # (Ib/yr) reportable? (Ib/yr)
Benzene 71432 5168 Yes 258
n-Hexane 110543 29153 Yes 1458
Toluene 108883 7605 Yes 380
005
Ethylbenzene 100414 1853 Yes 93
Xylenes 1330207 6874 Yes 344
2,2,4-TMP 540841 4534 Yes 227
Note: Controlled emissions based on a 95% reduction efficiency of enclosed flare(s)
5) The emission levels contained in this permit are based on the following emission factors:
Point 005:
Emission Emission Factor
Pollutant Factors Unit Source
Uncontrolled
NOx 0.0037 lb/lb VOC CDPHE
(lb/MMBTU)
CO 0.0094 lb/lb VOC ' CDPHE
(Ib/MMBTU)
VOC 8.106 lb/bbl E&P Tanks
Benzene 0.053 lb/bbl E&P Tanks
Toluene 0.078 lb/bbl E&P Tanks
Ethylbenzene 0.019 lb/bbl E&P Tanks
Xylenes 0.0705 lb/bbl E&P Tanks
AIRS ID: 123/7865 Page 7 of 8
olor-i Depa en • P` •li Health and Environment
it Pollution Control Division
I
io
l
Pollutant Factors U Source
Uncontrolled
n-hexane 0.299 lb/bbl E&P Tanks
2,2,4-TMP 0.0465 lb/bbl E&P Tanks
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:
VOCs, HAPs, n-Hexane
NANSR Synthetic Minor Source of:
VOCs, HAPs, n-Hexane
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: 123/7865 Page 8 of 8
Division Information
Engineer: Betsy Gillard
Control Engineer: Stefanie Rucker
Review Date: 10/08/2015
Application Date: 03/11/2015
Facility Identifiers
Permit No. 15WE0452 Potentially located in ozone nonattainment area
AIRs County# 123 Weld
Facility# 7865
Facility Type: exploration and production facility
Q Located in the 8-hour non-attainment area? O True Minor
®Synthetic Minor for: PVOC EN0x f CO
Administrative Information
Company Name: Kerr-McGee Oil and Gas Onshore LP
Source Name: 36164995
Source Location: SWSW S6 T1 N R65W
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:
Email: carissa.krev@anadarko.com
'Requested Action
Self Certification Required? Yes
Issuance Number: 1
Source Description:
Oil and gas exploration and production facility known as the 36164995, located in the SWSW S6 T1 N R65W,Weld
County,Colorado.
Point Name Type Control Action
Newly
005 VRT-01 Separator Venting Flare reported
source
005 One(1)vapor recovery tower(VRT)that processes liquid from the second stage of
separation to create a third stage of liquid/gas separation.Overand 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 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 when flash gas is routed to the ECDs.
I-Requsted Throughput 97500 bbl
Control Flare
Efficiency 95.00%l
Emissions Summary Table
Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source
VOC 8.106 lb/bbl 395.2 tpy 19.8 tpy E&P TANK
NOx 0.0037 lb/lb VOC 1.5 tpy 1.5 tpy CDPHE
CO 0.0094 lb/lb VOC 3.7 tpy 3.7 tpy CDPHE
Benzene 0.053 lb/bbl 5168 lb/yr 258 lb/yr E&P TANK
n-Hexane 0.299 lb/bbl 29153 lb/yr 1458 lb/yr E&P TANK
Toluene 0.078 lb/bbl 7605 lb/yr 380 lb/yr E&P TANK
Ethylbenzene 0.019 lb/bbl 1853 lb/yr 93 lb/yr E&P TANK
Xylene 0.0705 lb/bbl 6874 lb/yr 344 lb/yr E&P TANK
2,2,4-TMP 0.0465 lb/bbl 4534 lb/yr 227 lb/yr E&P TANK
E&P Tank analysis from the average of two condensate samples taken from the low-pressure separator
Model uses separator temperature for ambient temperature input as well;this increases the emissions so I found it
acceptable.
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.
Re ulation 6-New Source Performance Standards
Regulation 7-Volatile Organic Compounds
XII.VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, Section XVII.B.2
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