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Home My WebLink About20152648.tiff COP HE ' COLORADO Co Department of Public If Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado RECEIVED Weld County - Clerk to the Board 1150 O St �� 8 2015 PO Box 758 Greeley, CO 80632 WELD COUNTY July 23, 2015 COMMISSIONERS Dear Sir or Madam: On July 29, 2015, the Air Pollution Control Division will begin a 30-day public notice period for Kerr- McGee Oil and Gas Onshore LP - SWD 19-3i. 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 2015-2648 %_Io-I, CC 7i 1,.-PW, 1-k fly r, 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe mss; John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer CDPHE Air Pollution Control Division coNotice of a Proposed Project or Activity Warranting Public tea.. Comment Website Title: Kerr-McGee Oil and Gas Onshore LP - SWD 19-3i - Weld County Notice Period Begins: July 29, 2015 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Kerr-McGee Oil and Gas Onshore LP Facility: SWD 19-3i Salt Water Disposal Facility NWSW SEC 3 T1 N R68W Weld County The proposed project or activity is as follows: Applicant proposes to construct a facility to hold and treat produced water before injecting into subsurface. 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 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 15WE0074 &t 15WE0075 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: Timothy Sharp Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us orMF GOIOR ADO STATE OF COLORADO cot COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 * st' 1876 CONSTRUCTION PERMIT PERMIT NO: 1 5WE0074 Issuance 1 DATE ISSUED: DRAFT ISSUED TO: Kerr-McGee Oil and Gas Onshore LP THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility known as the SWD 19-3i, located in the NWSW SEC3 T1 N R68W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID TL-01 001 Hydrocarbon Loadout to Tanker Trucks THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the AIRS ID: 123/9D7C Page 1 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division 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 NO VOC CO Emission Type x TL-01 001 --- 9.9 --- Point See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID TL-01 001 Oil Loaded 180675 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 AIRS ID: 123/9D7C Page 2 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division 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 8. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 5.) 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. Point 001: 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) 11. Point 001: 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): 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 on site at the time of the inspection to ensure compliance with the conditions (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. 12. Point 001: 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 13. This source is not required to follow a Division-approved operating and maintenance plan. ADDITIONAL REQUIREMENTS 14. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, I I.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: AIRS ID: 123/9D7C Page 3 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division 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 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. GENERAL TERMS AND CONDITIONS 15. 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. 16. 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. 17. 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. AIRS ID: 123/9D7C Page 4 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division 18. 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. 19. 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. 20. 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. 21. 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: -- Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Kerr-McGee Oil and Gas Onshore LP for loadout operations at a minor facility. AIRS ID: 123/9D7C Page 5 of 7 Colorado Department of 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: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s)operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Rate Point Pollutant CAS# (Ib/yr) reportable? (Ib/yr) 001 Benzene 71432 137.01 No 137.01 001 n-Hexane 110543 686.6 Yes 686.6 001 Toluene 108883 432.59 Yes 432.59 001 Xylenes 1330207 373.87 Yes 373.87 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Emission Factors- Uncontrolled Pollutant Ib/BBL loaded Source VOC 0.1096 AP-42 Benzene 0.00076 AP-42 n-Hexane 0.0038 AP-42 Toluene 0.0024 AP-42 Xylenes 0.0021 AP-42 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) = 3.7 psia AIRS ID: 123/9D7C Page 6 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division M (vapor molecular weight) = 50 Ib/Ib-mol T (temperature of liquid loaded) = 530 °R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. 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 Minor Source PSD or NANSR Minor Source MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.clov/ 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: 123/9D7C Page 7 of 7 Division Information Engineer: Timothy Sharp Control Engineer: Stefanie Rucker Review Date: 05/20/2015 Application Date: 12/16/2014 Facility Identifiers Permit No. 15WE0074 Potentially located in ozone nonattainment area AIRS County# 123 Weld Facility# 9D7C Facility Type: exploration and production facility ❑� Located in the 8-hour non-attainment area? ®True Minor O Synthetic Minor for: fl VOC r NOx r CO Administrative Information Company Name: Kerr-McGee Oil and Gas Onshore LP Source Name: SWD 19-3i Source Location: NWSW SEC3 T1 N R68W SIC: 1311 Address 1: Kerr-McGee Oil and Gas Onshore LP Mailing Address 2: PO Box. 173779 Address ty,State Zip: Denver, CO 80217-3779 Name: Carissa Krey Person To Phone: 720-929-6916 Contact Fax: 000-000-0000 Email: carissa.kreyPanadarko.com Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the SWD 19-3i, located in the NWSW SEC3 Ti N R68W, Weld County, Colorado. Point Name Type Control Action Newly 001 TL-01 Loadout None reported source 001 Hydrocarbon Loadout to Tanker Trucks The table of inputs below enables you to calculate the loading loss emissions factor"L". If you choose to use a state default emissions Calculations factor,you may enter is directly into cell B14 L= 12.46*S*P*M/T(AP-42: Chapter 5.2, Equation 1) in units lb/1,000 gallons which will overwrite L= loading losses in lb per 1000 gallons loaded Factor Meaning Value Units Source S Saturation Factor 0.6 AP-42 P True Vapor Pressure 3.7 psia AP-42 M Molecular Weight of Vap 50 lb/lb-mole AP-42 T Liquid Temperature 530 deg. R Field Data L 2.61 lb/10A3 gal 1.10E-01 lb/bbl Annual requested Throughput 180675 BBL/yr 7588350 gal/yr Annual requested VOC emissions 19802 lb/yr 9.90 tpy Control: None Efficiency: 0.00% NCRPs Component Mass Fraction If the operator provides HAP speciation from a stable "sales oil" Benzene 0.0018 analysis,enter the mass fraction from this data. Alternatively,if n-hexane 0.0153 the operator modeled a pressurized oil to develop a site specific emissions factor, enter the modeled mass fraction for the Toluene 0.0153 Xylenes 0.0153 Source: Pressurized oil or Stable Sales Oil Analysis Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.1096 lb/bbl 9.9 tpy 9.9 tpy AP-42 Benzene 0.0002 lb/bbl 34.7 lb/yr 34.7 lb/yr AP-42 n-Hexane 0.0038 lb/bbl 687 lb/yr 687 lb/yr AP-42 Toluene 0.0017 lb/bbl 304 lb/yr 304 lb/yr AP-42 Xylenes 0.0017 lb/bbl 304 lb/yr 304 lb/yr AP-42 Regulatory Review 'Regulation 3-APEN and Permitting Requirements 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 of crude oil on an annual average basis? NO If yes,this emissions point is categorically exempt from permit requirements per Regulation 3, Part B,Section II.D.1.I 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 II.D.1.I STATE OF COLORADO of�cot COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT e� o P� AIR POLLUTION CONTROL DIVISION a TELEPHONE: (303)692-3150 \'* * *1876* CONSTRUCTION PERMIT PERMIT NO: 1 5W E0075 Issuance 1 DATE ISSUED: DRAFT ISSUED TO: Kerr-McGee Oil and Gas Onshore LP THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the SWD 19/3i Saltwater Disposal Facility, located in the NWSW of Section 03, Township 1N, Range 68W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Blanket A blanket gas is displaced from various fixed roof storage tanks Gas 002 used to store produced water. Emissions from these tanks are Control controlled by an enclosed flare. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation OR issuance of thispermit, b Y p �C submitting a Notice of Startup form to the Division. The Notice of Startup form may Y be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after 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 on which such construction or activity was scheduled to commence as set forth in the AIRS ID: 123/9D7C Page 1 of 10 Produced Water Tank TM Version 2012-1 Colorado Department of Public Health and Environment Air Pollution Control Division 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 retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type x Blanket Gas 002 --- 2.2 --- Point Control See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Annual records of the actual emission rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. 6. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Control Device Pollutants Equipment ID Point Controlled Blanket Gas 002 (2) Enclosed Combustor(s) VOC and HAPs Control PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following processing rate as listed below. Annual 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 Facility Equipment ID AIRS Process Parameter Annual Limit Point Blanket Gas Control 002 Displaced Blanket Gas 6.4 mmscf/yr AIRS ID: 123/9D7C Page 2 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division 8. The source shall track the actual displaced blanket gas rate for comparison against the process limit in Condition 7 by the direct metering of displaced blanket gas. The source shall be allowed up to 10% annual downtime of the meter. The source shall track downtime and throughput metering in records kept as electronic files or hard copies, for a period of three years and provided to the Division upon request. The source shall calculate blanket gas throughput during meter downtime by multiplying the time the meter was not in correct operation by the average metered emissions for the last two continuously metered days prior to downtime. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c 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 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. 13. 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.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) AIRS ID: 123/9D7C Page 3 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division 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). 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 AIRS ID: 123/9D7C Page 4 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 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. AIRS ID: 123/9D7C Page 5 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 14. Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance. This source shall meet the requirements to apply RACT and reduce emissions by installing and operating an enclosed flare. (Reference: Regulation No. 3, Part B, III.D.2.a). OPERATING & MAINTENANCE REQUIREMENTS 15. This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING 16. This source is not required to comply with any testing and sampling requirements. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, I I.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than one hundred tons of VOC or NOx 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 AIRS ID: 123/9D7C Page 6 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division 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. GENERAL TERMS AND CONDITIONS 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. AIRS ID: 123/9D7C Page 7 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Kerr-McGee Oil and Gas Onshore LP AIRS ID: 123/9D7C Page 8 of 10 Colorado Department of 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: http://www.colorado.gov/cs/Satellite?c=Document C&childpaqename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Rate Point Pollutant CAS # (Ib/yr) reportable? (Ib/yr) Benzene 71432 223 No 11 Toluene 108883 191 No 10 002 n-Hexane 110543 1295 Yes 65 Ethylbenzene 100414 11 No 1 Xylenes 1330207 70 No 3 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source lb/mmscf blanket gas lb/mmscf blanket displaced gas displaced NOx 53.2 53.2 CDPHE CO 131.4 131.4 CDPHE VOC 13994 700 Engineering Calculation 110543 n-Hexane 10.13 Engineering 202.6 Calculation 71432 Benzene 1 74 Engineering 34.835 Calculation AIRS ID: 123/9D7C Page 9 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source lb/mmscf blanket gas lb/mmscf blanket displaced gas displaced 108883 Toluene 1.50 Engineering 29.9 Calculation Note: The controlled emissions factors for point 002 are based on the flare 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 , Minor Source PSD or NANSR Minor Source 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: 123/9D7C Page 10 of 10 Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Division Information Engineer: Timothy Sharp Attainment Status Control Engineer: Stefanie Rucker PM10 Attainment Review Date: 05/20/2015 PM2.5 Attainment - Application Date: 12/16/2014 SOx Attainment NOx Attainment VOC Nonattainmen Facility Information CO Attainment Permit No. 15WE0075 County# 123 Weld __ Potentially Located within EAC-determine attainment status of NC AIRs Facility# 9D7C Point# 002 Facility Equipment ID Blanket Gas Company Name: Kerr-McGee Oil and Gas Onshore LP Source Name: SWD 19-3i Source Location: NWSW SEC3 T1N R68W SIC: 1311 Elevation(feet) 0 New Permit Modification APEN X (CP1) (Issuance#) Required/Permit Exemot Transfer of APEN Ownership Exempt/Permit Exemnt Notes Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: routed to an enclosed flare Vent and control for water filter and injection/disposal. Emission Calculation Method 1 EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.4-3) Ex=Q*MW*Xx/C Ex=emissions of pollutant x Q=Volumetric flow rate/volume of gas processed MW=Molecular weight of gas=SG of gas*MW of air Xx=mass fraction of x in gas C=molar volume of ideal gas(379 scf/Ib-mol)at 60F and 1 atm Throughput(Q) 6 MMscf/yr I 729.9 sd/hr 0.54 MMscf/mo I MW 22.170 Ib/Ib-mol 0.000 MMscf/d mole% MW Ibx/Ibmol mass fraction E lb/hr lb/yr tpy Helium 0.01 4.0026 0.000 0.000 Helium 0.0 7 0.00 CO2 2.04 44.01 0.898 0.040 CO2 1.7 15146 7.57 N2 0.44 28.013 0.123 0.006 N2 0.2 2079 1.04 methane 74.2142 16.041 11.905 0.537 methane 22.9 , 200832 100.42 ethane 12.1604 30.063 3.656 0.165 ethane 7.0 61673 30.84 propane 6.0482 44.092 2.6668 0.120 propane 5.1 44988 22.49 isobutane 0.8078 58.118 0.4695 0.021 isobutane 0.9 7920 3.96 n-butane 1.941 58.118 1.1281 0.051 n-butane 2.2 19030 9.52 isopentane 0.4221 72.114 0.3044 0.014 isopentane 0.6 5135 2.57 n-pentane 0.4475 72.114 0.3227 0.015 n-pentane 0.6 5444 2.72 cyclopentane 0.0241 70.13 0,0169 0.001 cyclopentane 0.0 285 0.14 n-Hexane 0.0891 86.18 0.0768 0.003 n-Hexane 0.1 1295 0.65 cyclohexane 0.0251 84.16 0.0211 0.001 cyclohexane 0.0 356 0.18 Other hexanes 0.164 86.18 0.1413 0.006 Other hexanes 0.3 2384 1.19 heptanes 0.0661 100.21 0.0662 0.003 heptanes 0.1 1117 0.56 methylcyclohexane 0.0221 98.19 0.0217 0.001 methylcyclohexane 0.0 366 0.18 224-TMP 0.0001 114.23 0.0001 0.000 224-TMP 0.0 2 0.00 Benzene 0.0169 78.12 0.0132 0.001 Benzene 0.0 223 0.11 Toluene 0.0123 92.15 0.0113 0.001 Toluene 0.0 191 0.10 Ethylbenzene 0.0006 106.17 0.0006 0.000 Ethylbenzene 0.0 11 0.01 Xylenes 0.0039 106.17 0.0041 0.000 Xylenes 0.0 70 0.03 I Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division IC8+Heavies I 0.03341 116.0001 0.0387 1 0.002 jC8+Heavies I 0.1 1 654 0.33 VOC mass fraction: 0.2392 Total VOC Emissions(Uncontrolled) 44.7 21.886 annual limit assuming 95%control 2.2 Notes monthly limit assuming 95%control(lb/mo.) 380.0 Mole%,MW,and mass fractions from Vollmar Compressor Station gas analysis collected 08/05/2014 Emissions are based on 8760 hours of operation per year. Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Flaring Information Equipment Description "Blanket Gas"collected from all equipment at facility&flared. Manufacturer Tornado Model 40'Flare Stack Serial Number tbd Gas Heating Value 1549 Btu/scf Throughput MMBtu/yr Combustion emission factor source: APCD 0.0037 lb NOX/lb VOC 0.0094 lb CO/lb VOC 0.17 tpy NOX 0.42 tpy CO Emissions Summary 0.2 tpy NOX Uncontrolled/PTE 0.4 tpy CO 44.7 tpy VOC Controlled 2.2 tpy VOC Uncontrolled Scenario A Controlled Total(lb/yr) Reportable? Total(lb/yr) Benzene 223 No 11 Toluene 191 No 10 Ethylbenzene 11 No 1 Xylenes 70 No 3 n-hexane 1295 Yes 65 224-TMP 2 No 0 Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.' AQCC Regulation 2 Section I.A applies to all emission sources."No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air." AQCC Regulation 3 An APEN is required for this source because uncontrolled VOC emissions Part A: exceed one ton per year in a nonattainment area for ozone. A permit is required for this source because uncontrolled VOC emissions from this facility exceed two tons per year in a nonattainment area for ozone. Part B: This source is subject to Section III.D.2(Minor Source RACT)because it is located in a nonattainment area.RACT for this source has been determined ,to be the use of a flare to control emissions. Is public comment Public Comment Required required? AQCC Regulation 7 Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? yes This separator is subject to Reg 7,Section XVII.G.and control requirements of Reg 7,XVI1.B.2 Facility Status This facility is a true minor source of NOXNOC/CO/HAP for Title V applicability. This facility is a true minor source of NOXNOC/CO/HAP for PSD/NSR applicability. N I—. •v °� L N o P. .a'5 z o 3 3 o cc a. 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