HomeMy WebLinkAbout20153066.tiff RECEIVED
A COPHE COLORADO
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Co 9 Department of Public SEP 2 1 ?n'r
Health&Environment
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Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
September 15, 2015
Dear Sir or Madam:
On September 16, 2015, the Air Pollution Control Division will begin a 30-day public notice period for
Bill Barrett Corporation - Pappenheim 6-62-27 Pad. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
2015-3066
4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.govicdpl
John W. Hickenlooper,Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer t
�� ��� cc : h/L P/v /a11.76
CDPHE Air pollution Control Division
co �>F Warranting of a Proposed Project or Activity War g Public
TM Comment
Website Title: Bill Barrett Corporation - Pappenheim 6-62-27 Pad - Weld County
Notice Period Begins: September 16, 2015
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Bill Barrett Corporation
Facility: Pappenheim 6-62-27 Pad
Oil Et Gas Exploration and Production Facility
SWNW SEC 27 T6N R62W, South of Briggsdale
Weld County
The proposed project or activity is as follows: Modify existing permit and add new construction permits in
association with the operation of new wells.
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 a draft of Construction Permit 15WE0392 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:
Andy Gruel
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
"mot COLORADO
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STATE OF COLORADO
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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT A.
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
*1876*
CONSTRUCTION PERMIT
PERMIT NO: 13WE2735
Issuance 2
DATE ISSUED:
ISSUED TO: Bill Barrett Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas exploration and production facility, known as the Pappenheim 6-62-27 Pad,
located in the NWNW of Section 27 of T6N R62W in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
Condensate 004 Truck loadout of condensate. Emissions from the loadout
Loadout are not controlled.
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. This construction permit represents final permit approval and authority to operate this
emissions source. Therefore, it is not necessary to self-certify (Regulation 3, Part B,
Section III.G.5).
EMISSION LIMITATIONS AND RECORDS
2. 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 Point VOC Emission Type
ID
Condensate 004 44.1 Point
Loadout
See "Notes to Permit Holder"for information on emission factors and methods used to calculate
limits.
AIRS ID: 123/9BAC Page 1 of 7
Condensate Loadout TM Version 2012-1
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Air Pollution Control Division
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
PROCESS LIMITATIONS AND RECORDS
3. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate 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
AIRS Process Parameter Annual Limit
Point
004 Condensate Loading 520,999 bbl
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.
4. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference:
Regulation 3, Part B, III.E)
STATE AND FEDERAL REGULATORY REQUIREMENTS
5. This source is located in an ozone non-attainment or attainment-maintenance area and
is subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be
conducted by submerged fill. (Reference: Regulation 3, Part B, III.E)
6. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
7. The owner or operator shall follow loading procedures that minimize the leakage of
VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B,
III.E):
AIRS ID: 123/9BAC Page 2 of 7
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a. Hoses, couplings,and valves shall be maintained to prevent dripping, leaking, or
other liquid or vapor loss during loading and unloading.
b. All compartment hatches (including thief hatches) shall be closed and latched at
all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
c. The owner or operator shall inspect loading equipment and operations onsite at
the time of inspections to monitor compliance with Condition 7 (a) and (b) above.
The inspections shall occur at least monthly. Each inspection shall be
documented in a log available to the Division on request.
8. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated
and maintained so as to minimize leakage of volatile organic compounds to the
atmosphere to the maximum extent practicable.
OPERATING & MAINTENANCE REQUIREMENTS
9. This source is not required to follow a Division-approved operating and maintenance
plan.
COMPLIANCE TESTING AND SAMPLING
10. This source is not required to comply with any testing and sampling requirements.
ADDITIONAL REQUIREMENTS
11. All previous versions of this permit are cancelled upon issuance of this permit.
12. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as
follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in
ozone nonattainment areas emitting less than 100 tons of VOC or NO, per
year, a change in annual actual emissions of one (1) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
AIRS ID: 123/9BAC Page 3 of 7
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Air Pollution Control Division
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.
13. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at
any such time that this source becomes major solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the applicable
Federal program threshold will require a full review of the source as though construction
had not yet commenced on the source. The source shall not exceed the Federal
program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
14. 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.
15. 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.
16. 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.
17. 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.
18. 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
AIRS ID: 123/9BAC Page 4 of 7
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Air Pollution Control Division
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.
19. 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.
20. 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:
Andy Gruel
Permit Engineer
Permit History
Issuance Date Description
Issuance 2 This Issuance Modification to increase throughput and permit
limits. Loadout now serves both the "NW Pad"
and the newer"CW2" Pad at the facility.
Final Approval was previously granted for this
permit on 8/28/2014.
Issuance 1 January 27, Issued to Bill Barrett Corporation.
2014
AIRS ID: 123/9BAC Page 5 of 7
Co A do P p e o Public 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: https://www.colorado.gov/pacific/cdphe/aqcc-regs
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
Point Pollutant CAS# (lb/yr) reportable? Rate(Ib/yr)
n-Hexane 110543 1,345 Yes N/A
004
Benzene 71432 266 Yes N/A
5) The emission levels contained in this permit are based on the following emission factors:
Emission Factors-Uncontrolled
CAS Pollutant lb/BBL loaded Source
VOC 0.16921 AP-42 (see below)
110543 n-Hexane 0.0026 Eng. Calc.
71432 Benzene 0.0005 Eng. Calc.
The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
L= 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) =4.0611 psia
M (vapor molecular weight) =68 Ib/Ib-mol
T(temperature of liquid loaded) = 512.45°R
The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP in the condensate tank vapors by the VOC emission
factor. The NCRP mass fraction of VOC in the vapors were modeled to be:
Benzene: 0.00302
n-Hexane: 0.01526
AIRS ID: 123/9BAC Page 6 of 7
Co Ado l p e o Public Health and Environment
6Air Pollution Control Division
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, HAPs (n-Hexane and total)
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 XXXXXX
AIRS ID: 123/9BAC Page 7 of 7
Division Information
Engineer. Andy Gruel
Control Engineer. Stefanie Rucker
Review Date: 05/13/2015
Application Date: Nov 28 2014,revised May 6,2015
Facility Identifiers
Permit No. 13WE2735
Coun # 123 Weld in non-attainment area
AIRs Facility# 9BAC
Point# 004
Section 01: Administrative Information
Company Name: Bill Barrett Corporation
Source Name: Pappenheim 6-62-27 Pad
SWNW of Section 27 of T6N R62W
Source Location:
approximately 12 miles south of Briqqsdale
SIC: 1311
Elevation(feet) 4750
Portable Source?
Portable Source Homebase
Mailing Address 1: Bill Barrett Corporation
Address Address 2: 1099 18th Street,Suite 2300
City,State Zip: Denver,CO 80202
Name: Wes Hill
Person To Phone: (303)312-8546
Contact Fax:
Email: whillAbillbarrettcorp.com
Section 02-Emissions Inventory Analysis
AP-42:Chapter 5.2
Equation 1
L=12.46`S`P`M/T
L=loading losses in lb per 1000 gallons loaded
S=Saturation Factor
P=true vapor pressure of liquid loaded[psia]
M=molecular weight of vapors[lb/lb-mole]
T=temperature of bulk liquid loaded[deg.R]
1 degree Fahrenheit=460.67 degree Rankine
Criteria Pollutants
Variables
S 0.6 Submerged loading:dedicated normal service
P 4.0611 psia
M 68 lb/lb-mole
T 512.45 deg.R
L 4.03 lb/10^3 gal
1.6921E-01 lb/bbl
Annual requested Throughput 21,881,958 Gallons per Year
Annual requested VOC emissions :,157 Pounds per Year
44.1 Tons VOC •erYear
Non-Criteria Reportable Air Pollutants/Hazardous Air Pollutants
Ratio of NCRP to VOC
VOC in flash gas Emission NCRP Are
from atmospheric Factor,lb/bbl Emission Emissions Emissions
Component tank (from above) Factor,lb/bbl lb r Reportable? •
Benzene 0.00302 1.69E-01 0.0005 266 Yes
n-hexane 0.01526 1.69E-01 0.0026 1,345 Yes
NCRP emission factors were calculated by assuming the ratio of the NCRP to VOC in the loadout vapor
is the same as the ratio of the NCRP to VOC in the flash gas at the atmospheric tanks,as estimated by
the ProMax model submitted with the application.
Section 03-Regulatory Considerations
•
Is this site considered an exploration and production location(e.g.well pad)? Yes
If yes,review the following two exemptions for applicability:
Does the operator unload less than 10,000 gallons(238 BBLs)per day on an annual average basis? No
If yes,this emissions point is categorically exempt from permit requirements per Regulation 3,Part B,Section 11.O.1.1
Does this operator unload less than 6,750 bbls per year of condensate via splash fill or
16,308 bbls per year of condensate via submerged fill procedure? No
If yes,this emissions point is categorically exempt from permit requirements per Regulation 3,Part B,Section 11.O.1.1
Is this site located in an ozone non-attainment area? Yes
If yes,this source is subject to Reasonably Available Control Technology(RACT)requirements under Regulation 3,Part B
Section III.D.2.a. This requirement may be met using"submerged fill"and/or vapor balance with emissions routed to an
emissions control device.
Is this facility classified as a major source of HAPs? No
If yes,evaluate if 40 CFR,Part 63,Subpart EEEE"Organic Liquids Distribution"MACT provisions apply
Does this facility involve the loading of refined crude/condensate in the form of"gasoline"? No
If yes,proceed to evaluate the following:
Is this facility classified as a"Terminal"as defined per Regulation 7,Section VI.C.2.a? No
If yes,the provisions of Regulation 7,Section VI.C.2 may apply
Is this facility classified as a"Bulk Plant"as defined per Regulation 7,Section VI.C.3.a? No
If yes,the provisions of Regulation 7,Section VI.C.3 may apply
Section 04-SCC Coding
Emissions Factor
Pollutant (lb/1,000 gallons)
VOC 4.029 lb/1,000 gallons
Benzene 0.012 lb/1,000 gallons
n-hexane 0.061 lb/1,000 gallons
40600132:Crude Oil:Submerged Loading(Normal Service) Use if S=0.6
I
STATE OF COLORADO
cozo
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION *4
TELEPHONE:(303)692-3150 *%
187
CONSTRUCTION PERMIT
PERMIT NO: 155WE0392
Issuance 1
DATE ISSUED:
ISSUED TO: Bill Barrett Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas exploration and production facility, known as the Pappenheim 6-62-27 Pad,
located in the NWNW of Section 27 of T6N R62W in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
Condensate Three (3) 400-bbl fixed roof storage tanks used to store
condensate, at the "NW Pad" portion of the Pappenheim 6-62-27
Tank Battery 002
NW Pad Pad facility. Emissions from these tanks are controlled by an
enclosed combustor.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days of the issuance of this permit, by submitting a Notice of Startup form
to the Division. The Notice of Startup form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the
Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
AIRS ID: 123/9BAC Page 1 of 11
Condensate Tank SM/M Version 2012-1
•olor- Depa en . ' .Ii Health and Environment
it Pollution Control Division
on which suc cti- ' . w-- - ed to -„ - mence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
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 operator shall retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Monthly Limits:
Facility AIRS Pounds per Month
Equipment ID Point NO VOC CO Emission Type
X
Condensate
Tank Battery 002 ---- 78 --- Point
NW Pad
(Note: Monthly limits are based on a 31-day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Facility-wide emissions of each individual hazardous air pollutant shall be less than
1,359 lb/month.
Facility-wide emissions of total hazardous air pollutants shall be less than 3,398
lb/month.
Annual Limits:
Facility AIRS Tons per Year
Equipment ID Point NO VOC CO Emission Type
Condensate
Tank Battery 002 --- 0.5 --- Point
NW Pad
See "Notes to Permit Holder"for information on emission factors and methods used to calculate
limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
AIRS ID: 123/9BAC Page 2 of 11
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olor- Depa en . ' -•Ii Health and Environment
A it Pollution Control Division
Compliance °_._ -nn , - - I br - - 'x ed b -.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.
7. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
Condensate
Tank Battery 002 Enclosed combustor VOC
NW Pad
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility AIRS Annual Monthly Limit
Equipment Point Process Parameter Limit (31 days)
ID
Condensate 7,334 623
Tank Battery 002 Condensate throughput bbl/yr bbl/month
NW Pad
The owner or operator shall calculate monthly process rates based on the calendar
month.
During the first twelve (12) months of operation, compliance with both the monthly and
annual throughput limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
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
9. The permit number and AIRS ID point number (i.e., 123/9BAC/002) shall be marked on
the subject equipment for ease of identification. (Reference: Regulation Number 3, Part
B, III.E.) (State only enforceable)
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10. Visible emissi- n• e. • ty - 0%) r .;ty 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,
Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation
No. 1, Section I I.A.1. &4.)
11. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
12. The flare covered by this permit is subject to Regulation No. 7, Section XII.C General
Provisions (State only enforceable). If a combustion device is used to control emissions
of volatile organic compounds to comply with Section XII.D, it shall be enclosed, have no
visible emissions, 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. The operator shall
comply with all applicable requirements of Section XII.
13. This source is subject to the recordkeeping, monitoring, reporting and emission control
requirements of Regulation 7, Section XII. The operator shall comply with all applicable
requirements of Section XII.
14. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General
Provisions (State only enforceable). If a flare or other 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 flare
or combustion device, or by other convenient means approved by the Division,
determine whether it is operating properly. The operator shall comply with all applicable
requirements of Section XVII.
15. The flare 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.1.b If a flare or other 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 flare or
combustion device, or by other convenient means approved by the Division,
determine whether it is operating properly. The operator shall comply with all
applicable requirements of Section XVII.
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.
16. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C
emission control requirements. These requirements include, but are not limited to:
Section XVII.C.1. Control and monitoring requirements for storage tanks
XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of
VOCs equal to or greater than six (6) tons per year based on a rolling twelve-
month total must operate air pollution control equipment that achieves an
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avera• ar, -o •ici . %. If - bustion device is used, it
must have a design destruction efficiency of at least 98%for hydrocarbons.
XVII.C.1.b.(i)(b) Control requirements of Section XVII.C.1.b. must be achieved
by May 1, 2015.
XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section
XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks
constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio,
visual, olfactory ("AVO") and additional visual inspections of the storage tank and
any associated equipment (e.g. separator, air pollution control equipment, or
other pressure reducing equipment) at the same frequency as liquids are loaded
out from the storage tank. These inspections are not required more frequently
than every seven (7) days but must be conducted at least every thirty one (31)
days. Monitoring is not required for storage tanks or associated equipment that
are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e.
The additional visual inspections must include, at a minimum:
XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other
access point to ensure that they are closed and properly sealed;
XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control
equipment to ensure that it is operating, including that the pilot light is lit
on combustion devices used as air pollution control equipment;
XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter
and valves for piping of gas to the pilot light to ensure they are functioning
properly;
XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure
that the valves for the piping from the storage tank to the air pollution
control equipment are open; and
XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the
presence or absence of smoke. If smoke is observed, either the
equipment must be immediately shut-in to investigate the potential cause
for smoke and perform repairs, as necessary, or EPA Method 22 must be
conducted to determine whether visible emissions are present for a
period of at least one (1) minute in fifteen (15) minutes.
XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible
to monitor, the owner or operator is not required to monitor such equipment until
it becomes feasible to do so.
XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted
with air pollution control equipment as required by Sections XII.D. or
XVII.C.1.
XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions
to air pollution control equipment, and must operate without venting hydrocarbon
emissions from the thief hatch (or other access point to the tank) or pressure
relief device during normal operation, unless venting is reasonably required for
maintenance, gauging, or safety of personnel and equipment. Compliance must
be achieved in accordance with the schedule in Section XVII.C.2.b.(ii).
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XVII.C.2.b. O o• ,r- - -ra• -, • ubjec a control requirements of
Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement
a documented Storage Tank Emission Management System ("STEM") plan to
identify, evaluate, and employ appropriate control technologies, monitoring
practices, operational practices, and/or other strategies designed to meet the
requirements set forth in Section XVII.C.2.a. Owners or operators must update
the STEM plan as necessary to achieve or maintain compliance. Owners or
operators are not required to develop and implement STEM for storage tanks
containing only stabilized liquids. The minimum elements-of STEM are listed
below.
XVII.C.2.b.(i) STEM must include selected control technologies, monitoring
practices, operational practices, and/or other strategies; procedures for
evaluating ongoing storage tank emission capture performance; and
monitoring in accordance with approved instrument monitoring methods
following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection
Frequency in Table 1.
XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections
XVII.C.2.a. and XVII.C.2.b. and begin implementing the required
approved instrument monitoring method in accordance with the following
schedule:
XVII.C.2.b.(ii)(b) A storage tank constructed before May 1, 2014, must comply
with the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1,
2015. Approved instrument monitoring method inspections must begin
within ninety (90) days of the Phase-In Schedule in Table 1, or within
thirty (30) days for storage tanks with uncontrolled actual VOC emissions
greater than 50 tons per year.
XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method
inspection, owners or operators must continue conducting approved
instrument monitoring method inspections in accordance with the
Inspection Frequency in Table 1.
Table 1 — Storage Tank Inspections
Threshold: Storage Tank Approved Instrument Phase-In Schedule
Uncontrolled Actual VOC Monitoring Method
Emissions (tpy) Inspection Frequency
>6 and < 12 Annually January 1, 2016
> 12 and < 50 Quarterly July 1, 2015
> 50 Monthly January 1, 2015
XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and
associated equipment that are unsafe, difficult, or inaccessible to monitor,
as defined in Section XVII.C.1.e.
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XVII.C - �__ T - • d; „ ation e owner or operator that
the selected STEM strategy(ies) are designed to minimize emissions from
storage tanks and associated equipment at the facility(ies), including thief
hatches and pressure relief devices.
XVII.C.3. Recordkeeping
XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or
XVII.C. must maintain records of STEM, if applicable, including the plan, any
updates, and the certification, and make them available to the Division upon
request. In addition, for a period of two (2) years, the owner or operator must
maintain records of any required monitoring and make them available to the
Division upon request, including:
XVII.C.3.a. The AIRS ID for the storage tank.
XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief
device, or other access point are found to be venting hydrocarbon emissions,
except for venting that is reasonably required for maintenance, gauging, or safety
of personnel and equipment.
XVII.C.3.c. The date and duration of any period where the air pollution control equipment
is not operating.
XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA
Method 22 test or investigation pursuant to Section XVII.C.1.d.(v).
XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air
pollution control equipment, and mitigate visible emissions.
XVII.C.3.f. A list of equipment associated with the storage tank that is designated as
unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an
explanation stating why the equipment is so designated, and the plan for monitoring
such equipment.
OPERATING & MAINTENANCE REQUIREMENTS
17. 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
18. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Method 22 to determine the presence or absence of visible emissions. "Visible
Emissions" means observations of smoke for any period or periods of duration greater
than or equal to one (1) minute in any fifteen (15) minute period during normal operation.
(Reference: Regulation No. 7 Section XVII.All)
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, I I.C)
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a. Annua �� •ril h• - -r� . • • --nt in t - 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.
20. 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).
21. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil
and Natural Gas Production Facilities major stationary source requirements shall apply
to this stationary source at any such time that this stationary source becomes major
solely by virtue of a relaxation in any permit limitation and shall be subject to all
appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part
E)
GENERAL TERMS AND CONDITIONS
22. 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.
23. 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
AIRS ID: 123/9BAC Page 8 of 11
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III.G. Final a . ion. n- • - w an - - ihe o•- .•n 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.
24. 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.
25. 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.
26. 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.
27. 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.
28. 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:
Andy Gruel
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Bill Barrett Corporation.
AIRS ID: 123/9BAC Page 9 of 11
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Notes to Permit Holder ` - me o •e a -.
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: https://www.colorado.gov/pacific/cdphe/aqcc-reqs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s)operate at the permitted limitations.
Uncontrolled Controlled
Emission Are the Emission
AIRS Rate emissions Rate
Point Pollutant CAS# (Ib/yr) reportable? (Ib/yr)
Benzene 71432 46 No 3
002
n-Hexane 110543 245 No 13
5) The emission levels contained in this permit are based on the following emission factors:
Point 002:
Emission Factors Emission Factors
Uncontrolled Controlled
CAS# Pollutant Ib/BBL Ib/BBL Source
Condensate Condensate
Throughput Throughput
VOC 2.471 0.124 ProMax and E&P
TANK
71432 Benzene 0.0062 0.00031 ProMax and E&P
TANK
110543 n-Hexane 0.0333 0.0017 ProMax and E&P
TANK
Note: The controlled emissions factors for point 002 are based on the enclosed combustor
control efficiency of 95%.
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
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olor. Depa en . ' .ii Health and Environment
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FINr , - cific =N ion date call the Division at
associated with thi o g-
(303)-692-3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor source of:VOC, HAPs (n-hexane and total HAPs)
NANSR Synthetic Minor source of: VOC
MACT HH 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 XXXX(X
9) A self certification form and guidance on how to self-certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123/9BAC Page 11 of 11
Division Information
Engineer: Andy Gruel
Control Engineer: Stefanie Rucker
Review Date: 05/11/2015
Application Date: 11/28/2014; revised 5/6/2015
Facility Identifiers
Permit No. 15WE0392 Potentially located in ozone nonattainment area
County# 123 Weld
AIRS
Facility# 9BAC
Facility Type: exploration and production facility •
O Located in the 8-hour non-attainment area? O True Minor
0 Synthetic Minor for: l✓' VOC r NOx r CO
Administrative Information
Company Name: Bill Barrett Corporation
Source Name: NW Pad of Pappenheim 6-62-27 Pad
Source Location: NWNW of Section 27 of T6N R62W
SIC: 1311
Address 1: Bill Barrett Corporation
Mailing Address 2: 1099 18th St,Suite 2300
Address
ty,State Zip: Denver,Co 802020
Name: Wes Hill
Person To Phone: (303)312-8547
Contact Fax:
Email: whill@billbarrettcorp.com
Requested Action
Self Certification Required? Yes
Issuance Number: 1
Source Description:
Oil and gas exploration and production facility known as the NW Pad of Pappenheim 6-62-27 Pad,located in the
NWNW of Section 27 of T6N R62W,Weld County,Colorado.
Point Name Type Control Action
Newly
002 Tanks Condensate Tanks Flare reported
source
002 Three(3)400-bbl aboveground storage tanks at the"NW Pad" portion of the facility.
I Requested Throughput 73441bb1
Control Flare
Efficiency 95.00%j
Emissions Summary Table
Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source
VOC 2.471 lb/bbl 9.1 tpy 0.5 tpy E&P TANK
Benzene 0.0062 lb/bbl 45.5328 lb/yr 2.27664 lb/yr E&P TANK
n-Hexane 0.0333 lb/bbl 244.5552 lb/yr 12.22776 lb/yr E&P TANK
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
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
This source is not subject to NSPS Kb because each tank is less than 19,800 gallons(471 bbl).
NSPS OOOO: for storage vessels in the natural gas production,transmission, and processing
segments.
This source is not subject to OOOO control requirements because each tank emits less than 6 tpy VOC.
Regulation 7-Volatile Organic Compounds
XII.VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
Source is subject to emission control requirements for condensate tanks since it is located in the ozone non-
attainment area.
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
Source is subject to Section XVII.C control, monitoring, and recordkeeping requirements because uncontrolled
actual emissions of VOCs exceed 20 tpy.
1 A
STATE OF COLORADO
of cozo
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT es
AIR POLLUTION CONTROL DIVISION
yrG
TELEPHONE: (303)692-3150 i
*1876*
CONSTRUCTION PERMIT
PERMIT NO: 15WE0393
Issuance 1
DATE ISSUED:
ISSUED TO: Bill Barrett Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas exploration and production facility, known as the Pappenheim 6-62-27 Pad,
located in the NWNW of Section 27 of T6N R62W in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
Condensate Ten (10) 400-bbl fixed roof storage tanks used to store
Tank 008 condensate, at the"CW2 Pad" portion of the Pappenheim 6-62-27
Battery Pad facility. Emissions from these tanks are controlled by an
CW2 Pad enclosed combustor.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days of the latter of commencement of operation or issuance of this permit,
by submitting a Notice of Startup form to the Division. The Notice of Startup form
may be downloaded online at https://www.colorado.dov/pacific/cdphe/other-air-
permittinq-notices. Failure to notify the Division of startup of the permitted source is a
violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section
III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. (Reference: Regulation No. 3, Part B, I II.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
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Condensate Tank SM/M Version 2012-1
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olor ` Depa en . • .li Health' and Environment
I a it Pollution Control Division
on which suc cti- - w-- - a ed to -- mence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
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 operator shall retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Monthly Limits:
Facility AIRS Pounds per Month
Equipment ID Point NO VOC CO Emission Type
X
Condensate
Tank Battery 008 ---- 377 --- Point
CW2 Pad
(Note: Monthly limits are based on a 31-day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Facility-wide emissions of each individual hazardous air pollutant shall be less than
1,359 lb/month.
Facility-wide emissions of total hazardous air pollutants shall be less than 3,398
lb/month.
Annual Limits:
Facility AIRS Tons per Year
Equipment ID Point NO VOC CO Emission Type
X
Condensate
Tank Battery 008 --- 2.3 --- Point
CW2 Pad
See "Notes to Permit Holder"for information on emission factors and methods used to calculate
limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
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Compliance nn= - I b - 'z ed b -•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.
7. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
Condensate
Tank Battery 008 Enclosed combustor VOC
CW2 Pad
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility AIRS Annual Monthly Limit
Equipment Point Process Parameter Limit (31 days)
ID
Condensate 513,666 43,627
Tank Battery 008 Condensate throughput bbl/yr bbl/month
CW2 Pad
The owner or operator shall calculate monthly process rates based on the calendar
month.
During the first twelve (12) months of operation, compliance with both the monthly and
annual throughput limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
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
9. The permit number and AIRS ID point number (i.e., 123/9BAC/008) shall be marked on
the subject equipment for ease of identification. (Reference: Regulation Number 3, Part
B, III.E.) (State only enforceable)
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10. Visible emissi- n. e• • ty - 0%) F -Sty 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,
Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation
No. 1, Section I I.A.1. &4.)
11. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
12. The flare covered by this permit is subject to Regulation No. 7, Section XII.C General
Provisions (State only enforceable). If a combustion device is used to control emissions
of volatile organic compounds to comply with Section XII.D, it shall be enclosed, have no
visible emissions, 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. The operator shall
comply with all applicable requirements of Section XII.
13. This source is subject to the recordkeeping, monitoring, reporting and emission control
requirements of Regulation 7, Section XII. The operator shall comply with all applicable
requirements of Section XII.
14. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General
Provisions (State only enforceable). If a flare or other 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 flare
or combustion device, or by other convenient means approved by the Division,
determine whether it is operating properly. The operator shall comply with all applicable
requirements of Section XVII.
15. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C
emission control requirements. These requirements include, but are not limited to:
Section XVII.C.1. Control and monitoring requirements for storage tanks
XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of
VOCs equal to or greater than six (6) tons per year based on a rolling twelve-
month total must operate 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.
XVII.C.1.b.(i)(b) Control requirements of Section XVII.C.1.b. must be achieved
by May 1, 2015.
XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section
XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks
constructed before May 1, 2014 subject to Section XVI I.C.1. must conduct audio,
visual, olfactory ("AVO") and additional visual inspections of the storage tank and
any associated equipment (e.g. separator, air pollution control equipment, or
other pressure reducing equipment) at the same frequency as liquids are loaded
out from the storage tank. These inspections are not required more frequently
than every seven (7) days but must be conducted at least every thirty.one (31)
days. Monitoring is not required for storage tanks or associated equipment that
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are un- - _ icu ; i - - or, a ned in Section XVII.C.1.e.
The additional visual inspections must include, at a minimum:
XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other
access point to ensure that they are closed and properly sealed;
XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control
equipment to ensure that it is operating, including that the pilot light is lit
on combustion devices used as air pollution control equipment;
XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter
and valves for piping of gas to the pilot light to ensure they are functioning
properly;
XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure
that the valves for the piping from the storage tank to the air pollution
control equipment are open; and
XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the
presence or absence of smoke. If smoke is observed, either the
equipment must be immediately shut-in to investigate the potential cause
for smoke and perform repairs, as necessary, or EPA Method 22 must be
conducted to determine whether visible emissions are present for a
period of at least one (1) minute in fifteen (15) minutes.
XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible
to monitor, the owner or operator is not required to monitor such equipment until
it becomes feasible to do so.
XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted
with air pollution control equipment as required by Sections XII.D. or
XVII.C.1.
XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions
to air pollution control equipment, and must operate without venting hydrocarbon
emissions from the thief hatch (or other access point to the tank) or pressure
relief device during normal operation, unless venting is reasonably required for
maintenance, gauging, or safety of personnel and equipment. Compliance must
be achieved in accordance with the schedule in Section XVII.C.2.b.(ii).
XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of
Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement
a documented Storage Tank Emission Management System ("STEM") plan to
identify, evaluate, and employ appropriate control technologies, monitoring
practices, operational practices, and/or other strategies designed to meet the
requirements set forth in Section XVII.C.2.a. Owners or operators must update
the STEM plan as necessary to achieve or maintain compliance. Owners or
operators are not required to develop and implement STEM for storage tanks
containing only stabilized liquids. The minimum elements of STEM are listed
below.
XVII.C.2.b.(i) STEM must include selected control technologies, monitoring
practices, operational practices, and/or other strategies; procedures for
evaluating ongoing storage tank emission capture performance; and
monitoring in accordance with approved instrument monitoring methods
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olor. Depa en . 'II
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A it Pollution Control Division
rt <� • t_ - 'p . c - - ecti•- II.C.2.b.(ii) and Inspection
Frequency in Table 1.
XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections
XVII.C.2.a. and XVII.C.2.b. and begin implementing the required
approved instrument monitoring method in accordance with the following
schedule:
XVII.C.2.b.(ii)(b) A storage tank constructed before May 1, 2014, must comply
with the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1,
2015. Approved instrument monitoring method inspections must begin
within ninety (90) days of the Phase-In Schedule in Table 1, or within
thirty (30) days for storage tanks with uncontrolled actual VOC emissions
greater than 50 tons per year.
XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method
inspection, owners or operators must continue conducting approved
instrument monitoring method inspections in accordance with the
Inspection Frequency in Table 1.
Table 1 —Storage Tank Inspections
Threshold: Storage Tank Approved Instrument Phase-In Schedule
Uncontrolled Actual VOC Monitoring Method
Emissions (tpy) Inspection Frequency
>6 and < 12 Annually January 1, 2016
> 12 and < 50 Quarterly July 1, 2015
> 50 Monthly January 1, 2015
XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and
associated equipment that are unsafe, difficult, or inaccessible to monitor,
as defined in Section XVII.C.1.e.
XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that
the selected STEM strategy(ies) are designed to minimize emissions from
storage tanks and associated equipment at the facility(ies), including thief
hatches and pressure relief devices.
XVII.C.3. Recordkeeping
XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or
XVII.C. must maintain records of STEM, if applicable, including the plan, any
updates, and the certification, and make them available to the Division upon
request. In addition, for a period of two (2) years, the owner or operator must
maintain records of any required monitoring and make them available to the
Division upon request, including:
XVII.C.3.a. The AIRS ID for the storage tank.
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XVII.C.3.b. T n• --t r - -ny i- here - ief hatch, pressure relief
device, or other access point are found to be venting hydrocarbon emissions,
except for venting that is reasonably required for maintenance, gauging, or safety
of personnel and equipment.
XVII.C.3.c. The date and duration of any period where the air pollution control equipment
is not operating.
XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA
Method 22 test or investigation pursuant to Section XVII.C.1.d.(v).
XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air
pollution control equipment, and mitigate visible emissions.
XVII.C.3.f. A list of equipment associated with the storage tank that is designated as
unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an
explanation stating why the equipment is so designated, and the plan for monitoring
such equipment.
OPERATING & MAINTENANCE REQUIREMENTS
16. 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
17. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Method 22 to determine the presence or absence of visible emissions. "Visible
Emissions" means observations of smoke for any period or periods of duration greater
than or equal to one (1) minute in any fifteen (15) minute period during normal operation.
(Reference: Regulation No. 7 Section XVII.AII)
ADDITIONAL REQUIREMENTS
18. 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
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For a its - . . -
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.
19. 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).
20. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil
and Natural Gas Production Facilities major stationary source requirements shall apply
to this stationary source at any such time that this stationary source becomes major
solely by virtue of a relaxation in any permit limitation and shall be subject to all
appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part
E)
GENERAL TERMS AND CONDITIONS
21. 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.
22. 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.
23. 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.
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24. Unless specifi - ed - - ., - g ,,.s. -• spec" onditions 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.
25. 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.
26. 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.
27. 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:
Andy Gruel
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Bill Barrett Corporation.
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Notes to Permit Holder - ,.W_ me o •e a -.
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: https://www.colorado.gov/pacific/cdphe/agcc-reps
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 Controlled
Emission Are the Emission
AIRS Rate emissions Rate
Point Pollutant CAS# (lb/yr) reportable? (Ib/yr)
Benzene 71432 267 Yes 14
Toluene 108883 216 No 11
Ethylbenzene 100414 30 No 2
008 Xylenes 1330207 57 No 3
n-Hexane 110543 1357 Yes 68
2,2,4-
540841 170 No 9
Trimethylpentane
5) The emission levels contained in this permit are based on the following emission factors:
Point 008:
Emission Emission
Factors Factors
CAS# Pollutant Uncontrolled Controlled Source
lb/BBL Ib/BBL
Condensate Condensate
Throughput Throughput
VOC 0.172743 0.0864 ProMax and E&P TANK
71432 Benzene 0.00052 0.000026 ProMax and E&P TANK
108883 Toluene 0.00042 0.000021 ProMax and E&P TANK
100414 Ethylbenzene 0.000058 0.0000029 ProMax and E&P TANK
1330207 Xylenes 0.00011 0.0000055 ProMax and E&P TANK
110543 n-Hexane 0.00264 0.000132 ProMax and E&P TANK
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olor. Depa := en ' .li `Health and Environment
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Factors Factors
CAS# Pollutant Uncontrolled Controlled Source
lb/BBL lb/BBL
Condensate Condensate
Throughput Throughput
540841 0.00033 0.0000165 ProMax and E&P TANK
Trimethyipthylpentane
Note: The controlled emissions factors for point 008 are based on the enclosed combustor
control efficiency of 95%.
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, HAPs (n-hexane and total HAPs)
NANSR Synthetic Minor source of: VOC
MACT HH 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: 123/9BAC Page 11 of 11
Division Information
Engineer: Andy Gruel
Control Engineer: Stefanie Rucker
Review Date: 05/11/2015
Application Date: 11/28/2014, revised 5/6/2015
Facility Identifiers
Permit No. 15WE0393 Potentially located in ozone nonattainment area
AIRS County# 123 Weld
Facility# 9BAC
Facility Type: exploration and production facility
❑� Located in the 8-hour non-attainment area? O True Minor
Synthetic Minor for: I✓.VOC r NOx CO
Administrative Information
Company Name: Bill Barrett Corporation
Source Name: Pappenheim 6-62-27 Pad
Source Location: SWNW of Section 27 of T6N R62W
SIC: 1311
Address 1: Bill Barrett Corporation
Mailing Address 2: 1099 18th Street,Suite 2300
Address
ty,State Zip: Denver,CO 80202
Name: Wes Hill
Person To Phone: 303-312-8547
Contact Fax:
Email: whill@billbarrettcorp.com
'Requested Action
Self Certification Required? Yes
Issuance Number: 1
Source Description:
Oil and gas exploration and production facility known as the Pappenheim 6-62-27 Pad, located in the SWNW of
Section 27 of T6N R62W,Weld County,Colorado.
Point Name Type Control Action
Newly
008 Tanks Condensate Tanks None reported
source
008 Ten (10)400-bbl aboveground storage tanks at the"CW2 Pad"portion of the facility.
IRequsted Throughput I 513,666 Ibbl
Control Flare I
Efficiency 95.00%
Emissions Summary Table
Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source
V0C 0.172743 lb/bbl 44.4 tpy 2.2 tpy ProMax and E&P TANK
Benzene 0.00052 lb/bbl 267.1 lb/yr 13.4 lb/yr ProMax and E&P TANK
Toluene 0.00042 lb/bbl 215.7 lb/yr 10.8 lb/yr ProMax and E&P TANK
Ethylbenze 0.000058 lb/bbl 29.8 lb/yr 1.5 lb/yr ProMax and E&P TANK
Xylenes 0.00011 lb/bbl 56.5 lb/yr 2.8 lb/yr ProMax and E&P TANK
n-Hexane 0.00264 lb/bbl 1356.1 lb/yr 67.8 lb/yr ProMax and E&P TANK
2,2,4-TMP 0.00033 lb/bbl 169.5 lb/yr 8.5 lb/yr ProMax and E&P TANK
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
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
This source is not subject to NSPS Kb because each tank is less than 19,800 gallons(471 bbl)
NSPS OOOO:for storage vessels in the natural gas production,transmission,and processing segments.
This source is not subject to OOOO control requirements because each tank emits less than 6 tpy VOC.
Regulation 7-Volatile Organic Compounds
XII.VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
Source is subject to emission control requirements for condensate tanks since it is located in the ozone non-attainment
area.
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
Source is subject to Section XVII.C control, monitoring,and recordkeeping requirements because uncontrolled actual
emisisons of VOCs exceed 20 tpy.
I A
STATE OF COLORADO
of_c?./.0
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT A.
her,
AIR POLLUTION CONTROL DIVISION
TELEPHONE:(303)692-3150
*/816*
CONSTRUCTION PERMIT
PERMIT NO: 15WE0394
Issuance 1
DATE ISSUED:
ISSUED TO: Bill Barrett Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas exploration and production facility, known as the Pappenheim 6-62-27 Pad,
located in the NWNW of Section 27 of T6N R62W in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
Emissions from bypass of vapor recovery unit (VRU). VRU collects
and recompresses flash emissions from heated separator and vapor
VRU recovery tower; when VRU bypass occurs, those emissions are
Bypass 009 controlled by an enclosed combustor. A VRU bypass rate of 22% is
assumed. Emissions are based on condensate throughput during
VRU bypass.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division(the Division)no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the
Division of startup of the permitted source is a violation of Air Quality Control Commission
(AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the
permit.
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).
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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 operator shall retain the permit final authorization letter issued by the Division, after
completion of self-certification,with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Tons per Year
Equipment ID Point Coli0 VOC Emission Type
VRU Bypass 009 1.3 31.4 6.6 Point
See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
7. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility AIRS
Equipment Control Device Pollutants
ID Point Controlled
VRU 009 Enclosed combustors (Leed 48" L30-0011) VOC
Bypass
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PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the throughput shall be maintained by the applicant and made available
to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility AIRS
Equipment Process Parameter Annual Limit
Point
ID
Liquids throughput through separator while
VRU is being bypassed.
VRU 009 113,006 bbl/yr
Bypass VRU bypass shall be measured using a
SCADA system as described in the O&M
Plan.
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 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
9. Visible emissions shall not exceed twenty percent(2O%)opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 3O%opacity for more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. &4.)
10. No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30% opacity for a period or periods aggregating more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.)
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 emissions covered by this permit are 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
AIRS ID: 123/9BAC Page 3 of 8
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Air Pollution Control Division
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. This source is subject to the odor requirements of Regulation No.2.(State only enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
15. Upon startup of this point, the applicant shall follow the operating and maintenance (O&M)
plan and record keeping format approved by the Division, in order to demonstrate
compliance on an ongoing basis with the requirements of this permit. Revisions to your
O&M plan are subject to Division approval prior to implementation. (Reference: Regulation
No. 3, Part B, Section III.G.7.)
16. Within 180 days after issuance of this permit, the owner or operator shall continuously
monitor and record VRU downtime while emissions are routed to the enclosed
combustors using a SCADA (supervisory control and data acquisition)system. The owner or
operator shall use monthly VRU downtime records, monthly condensate throughput records
and calculation methods detailed in the O&M Plan to demonstrate compliance with the
process and emissions limits specified in this permit. After issuance of this permit and prior
to startup of the SCADA monitoring system, the operator shall monitor and record VRU
downtime manually through site visits a minimum of once per week until the SCADA
monitoring system is continuously monitoring and recording VRU downtime, at which point
the manual checks for VRU downtime are no longer required. If the VRU is observed to not
be operating during a site visit, the operator must record downtime hours as the number of
hours elapsed since the last time the VRU was observed to be operating.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. 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).
Periodic Testing Requirements
18. On an annual basis,the operator shall complete a site-specific extended liquids analysis of a
high-pressure liquid sample from the high-pressure separator. Results of testing shall be
used to verify the VOC content(weight fraction)of the emission stream that is routed to the
flare during VRU bypass. VOC content of this emission stream and site-specific emission
factors shall be verified using ProMax and the most recent extended liquids analysis.
ADDITIONAL REQUIREMENTS
19. 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(NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. per year, a
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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 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.
20. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at
any such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source shall not exceed the Federal program threshold
until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
21. 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.
22. 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.
23. 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.
24. 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.
25. 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
AIRS ID: 123/9BAC Page 5 of 8
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revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the applicant, or the Division revokes a permit,the applicant
or owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
26. 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.
27. 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:
Andy Gruel
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Bill Barrett Corporation.
AIRS ID: 123/9BAC Page 6 of 8
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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:
https://www.colorado.gov/pacific/cdphe/aqcc-reqs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s)operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# (lb/yr) reportable? Rate(Ib/yr)
Benzene 71432 6,392 Yes 320
Toluene 108883 6,656 Yes 333
Ethylbenzene 100414 1,192 Yes 60
009 Xylenes 1130207 2,431 Yes 122
n-Hexane 110543 33,295 Yes 1,665
2,2,4- 540841 5,028 Yes 251
Trimethylpentane
5) The emission levels contained in this permit are based on the following emission factors:
Mass Emission Factors Emission
CAS# Pollutant Fraction Uncontrolled Factors Source
of Gas(%) Controlled
NOx --- 0.068 lb/MMBtu 0.068 lb/MMBtu AP-42
CO --- 0.37 lb/MMBtu 0.37 lb/MMBtu AP-42
VOC 80.1545 11.10011b/bbl 0.5551b/bbl ProMax
liquids throughput liquids throughput
71432 Benzene 0.4084 0.05661b/bbl 0.00283 lb/bbl ProMax
liquids throughput liquids throughput
108883 Toluene 0.4253 0.05891b/bbl 0.002945 lb/bbl ProMax
liquids throughput liquids throughput
100414 Ethylbenzene 0.0761 0.01051b/bbl 0.0005271b/bbl ProMax
liquids throughput liquids throughput
1330207 Xylenes 0.1553 0.02151b/bbl 0.0010761b/bbl ProMax
liquids throughput liquids throughput
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Mass Emission Factors Emission
CAS# Pollutant Fraction Uncontrolled Factors
of Gas(%) Controlled Source
110543 n-hexane 2.1275 0.2946 lb/bbl 0.01473 lb/bbl ProMax
liquids throughput liquids throughput
540841 2,2,4- 0.3212 0.0445 lb/bbl 0.00222 lb/bbl
ProMax
Trimethylpentane liquids throughput liquids throughput
Note: The uncontrolled VOC and HAP emission factors for this point were modeled using ProMax
software, based on a site-specific sample taken 10/20/2014 at the Pappenheim 6-62-27-
1724BH2 well. The controlled VOC and HAP emissions factors are based on the enclosed
combustor control efficiency of 95%.
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, HAPs(n-hexane and total)
NANSR Synthetic Minor source of: VOC
MACT HH 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
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 M—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 XXXXX(
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: 123/9BAC Page 8 of 8
Division Information
Engineer: Andy Gruel
Control Engineer: Stefanie Rucker
Review Date: 05/13/2015
Application Date: 05/06/2015
Facility Identifiers
Permit No. 15WE0394 Potentially located in ozone nonattainment area
County# 123 Weld
AIRs
Facility# 9BAC
Facility Type: exploration and production facility
❑� Located in the 8-hour non-attainment area? 0 True Minor
0 Synthetic Minor for: VOC r NOx r Co
Administrative Information
Company Name: Bill Barrett Corporation
Source Name: Pappenheim 6-62-27 Pad
Source Location: SWNW of Section 27 of T6N R62W
SIC: 1311
Address 1: Bill Barrett Corporation
Mailing Address 2: 1099 18th Street, Suite 2300
Address
ty,State Zip: Denver,CO 80202
Name: Wes Hill
Person To Phone: (303)312-8546
Contact Fax:
Email: whill@billbarrettcorp.com
'Requested Action
Self Certification Required? Yes
Issuance Number: 1
Source Description:
Oil and gas exploration and production facility known as the Pappenheim 6-62-27 Pad, located in the SWNW of
Section 27 of T6N R62W,Weld County,Colorado.
Point Name Type Control Action
Newly
009 VRU Bypass Separator Venting Flare reported
source
Emissions associated with bypass of VRU. Emissions are a function of condensate throughput during VRU
009 bypass; assumed 22%VRU bypass.
•
Equipment Description
This source vents natural gas from: a well head separator and a vapor recovery tower
Emissions from this source are: recompressed except during VRU bypass time (22% of the time)
[Natural gas venting from a well head separator and a vapor recovery tower. Emissions from this source are recompressed, with 22%VRU bypass.
Calculations
Emission Calculation Method
Applicant submitted a Promax model, which modeled flash emissions from the separator("Flash to VRU 1 &2")and the VRT("VRT Flash").
The Promax model calculated mass flows from these two sources, which are collected by the VRU and recycled. The emissions from
these two sources occur when the VRU is down. The applicant requested a VRU downtime of 22% of the time.
Promax output provided a lb/hr flash emission rate from the two streams. As these streams are combined prior to combustion in the
enclosed combustor, the mass flow rate from each stream is added together to obtain the total mass flow rate to the VRU.
Applicant presented Promax model in on a 1 barrel per day basis; to convert this from lb/hr to lb/bbl, multiply by(24 hrs/day)and divide by 1 bpd.
Promax output:
"Flash to VRU 1 &2" "VRT Flash" Sum of the two streams
mass fraction mass flow rate mass fraction mass flow rate mass flow rate
% lb/hr % lb/hr lb/hr
Helium 0.000 0.00E+00 0.00 0.00E+00 0.00E+00
CO2 1.566 8.80E-03 2.10 3.14E-04 9.12E-03
N2 0.022 1.22E-04 0.02 2.27E-06 1.25E-04
methane 4.969 2.79E-02 5.93 8.85E-04 2.88E-02
ethane 13.129 7.38E-02 17.83 2.66E-03 7.65E-02
propane 32.655 1.84E-01 37.28 5.56E-03 1.89E-01
isobutane 6.066 3.41E-02 5.90 8.80E-041. 3.50E-02
n-butane 20.228 1.14E-01 18.31 2.73E-03 1.16E-01
isopentane 4.242 2.38E-02 3.20 4.77E-04 2.43E-02
n-pentane 5.754 3.23E-02 4.05 6.05E-04 3.29E-02
2,2-dimethylbutane 0.016 8.81E-05 0.01 1.55E-06 8.96E-05
2,3-dimethylbutane 0.654 3.68E-03 0.40 6.04E-05 3.74E-03
2-methylpentane 1.374 7.73E-03 0.82 1.22E-04 7.85E-03
3-methylpentane 0.722 4.06E-03 0.42 6.28E-05 4.12E-03
n-heptane 2.987 1.68E-02 1.31 1.95E-04 1.70E-02
n-octane 0.947 5.32E-03 0.33 4.87E-05 5.37E-03
n-nonane 0.366 2.06E-03 0.10 1.49E-05 2.07E-03
benzene 0.413 2.32E-03 0.23 3.48E-05 2.36E-03 HAP
toluene 0.431 2.43E-03 0.19 2.87E-05 2.45E-03 HAP
ethylbenzene 0.077 4.35E-04 0.03 4.03E-06 4.39E-04 HAP
m-xylene 0.112 6.28E-04 0.04 5.53E-06 6.33E-04 HAP
o-xylene 0.046 2.61E-04 0.02 2.27E-06 2.63E-04
n-hexane 2.153 1.21E-02 1.18 1.77E-04 1.23E-02 HAP
2,2,4-trimethylpentani 0.326 1.83E-03 0.15 2.27E-05 1.85E-03 HAP
n-decane 0.745 4.19E-03 0.16 2.40E-05 4.21E-03
Notes Total VOC (C3+) 0.4625 lb/hr
ProMax model based on site-specific analysis, sample taken 10/20/2014.
Emissions are based on 8760 hours of operation per year.
Because model was based on 1 barrel per day basis, multiply lb/hr by(24 hr/d) and divide by (1 barrel/day)to obtain EF in lb/bbl:
mass flow rate, lb/hr Emission factor, lb/bbl
VOC 0.4625 11.1001
Benzene 2.36E-03 0.0566
Toluene 2.45E-03 0.0589 -
Ethylbenzene 4.39E-04 0.0105
Xylenes (total) 8.96E-04 0.0215
n-hexane 1.23E-02 0.2946
2,2,4-TMP 1.85E-03 0.0445
Applicant has requested VRU bypass of 22% based on liquids throughput. The PTE limit for liquids throughput is 513,666 bbl/yr, so the
permit limit for emissions from VRU bypass is based on 513,666 * 0.22 = 113,007 bbl/yr. 113007 bbl/yr
15WE0394.CP1.xlsm E0394.CP1.xlsm
Emissions associated with bypass of VRU. Emissions are a function of condensate throughput during VRU
009 bypass;assumed 22%VRU bypass.
Flaring Information
Equipment Description
Flare to combust gas during VRU downtime.
Manufacturer Leed
Model 48"
Serial Number L30-0011
Gas Heating Value 1500 Btu/scf as stated on APEN
Throughput 33235 MMBtu/yr
Pilot 2383.4 MMBtu/yr
Total 35618.4 MMBtu/yr
VRU Information
Equipment Description
N/A—Although a VRU is in use,the calculations are based on liquids throughput during VRU bypass(22%of the time).
Make
Model
Requested Control Efficiency
Annual Bypass Time
Backup i
$Overall Control I 95.00%I
Combustion emission factor source: AP-42:Chapter 13.5
0.07 jlb NOX/MMBtu 0.37 IIb CO/MMBtu
Emissions Summary Table
Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source
VOC 11.1001 lb/bbl 0.56 lb/bbl 627.2 tpy 31.4 tpy ProMax
Nox 0.07 Ib/MMBTU 0.07 Ib/MMBTU 1.21 tpy 1.21 tpy AP-42
CO 0.37 Ib/MMBTU 0.37 lb/MMBTU 6.59 tpy 6.59 tpy AP-42
Benzene 0.0566 lb/bbl 0.00283 lb/bbl 6391.12 lb/yr 320 lb/yr ProMax
Toluene 0.0589 lb/bbl 0.00294 lb/bbl 6655.05 lb/yr 333 lb/yr ProMax
Ethylbenzene 0.0105 lb/bbl 0.00053 lb/bbl 1191.37 lb/yr 60 lb/yr ProMax
0.0215 lb/bbl 0.00108 lb/bbl 2430.74 lb/yr 122 lb/yr ProMax
Xylenes n-Hexane 0.2946 lb/bbl 0.01473 lb/bbl 33294.81 lb/yr 1665 lb/yr ProMax
2,2,4-Trimethylpenta 0.0445 lb/bbl 0.00222 lb/bbl 5027.14 lb/yr 251 lb/yr ProMax
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 7
Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014?
yes APEN for 123-9BAC-008(condensate tanks)states that startup of new wells was September 2,2014.
This separator is subject to Reg 7,Section XVII.G.and control requirements of Reg 7,Section XVII.B.2
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E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name: Bill Barrett Corporation
Source Name: Pappenheim 06-62-27 Pad
Emissions Source AIRS ID2: 123 / 9BAC /
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number Name of Well Newly Reported Well
0
05 - 123 - 38491 Pappenheim 06-62-27-1609BH2
05 - 123 - 38490 Pappenheim 06-62-27-1724BH2
05 - 123 - 38492 Pappenheim 06-62-27-3325B112
05 - 123- 38427 Pappenheim 06-62-27-3340B112
05 - 123 - 38430 Pappenheim 06-62-27-4841BH2
05 - 123 - 38428 Pappenheim 06-62-27-4956BH2
05 - 123 - 38429 Pappenheim 06-62-27-645713112
0
- ❑
- - ❑
- - ❑
- - ❑
- _ ❑
- _ ❑
- - ❑-
- - ❑
- - ❑
Footnotes:
1 Attach this addendum to associated APEN form when needed to report additional.wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
Form APCD-212 18217 Pappenheim 6-62-27 CW2 APCD-212-Tank-APENadd
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