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Home My WebLink About20141073.tiff STATE OF COLORADO John W.Hickenlooper,Governor . C06 Larry Wolk,MD,MSPH E , \ Executive Director and Chief Medical Officer 4" Dedicated to protecting and improving the health and environment of the people of Colorado ,�i*o 4300 Cherry Creek Or.S. Laboratory Services Division \to Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Weld County -Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 RECEIVED March 31, 2014 APR 0 3 2014 WELD COUNTY Dear Sir or Madam: COMMISSIONERS On April 3,2014, the Air Pollution Control Division will publish a public notice for Carrizo Oil &Gas, Inc. — Timbro Ranch 1-41-9-59, in the The Greeley 1 rihuue. 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 date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B I 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, ' ! i f=- - c� Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure R • OD RQ,0 bAA) Le; -PI (Min) ?kJ/04,e.R-, 2014-1073 )4 . q . iq 1} 1. (1).8) STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH �o? co43 Executive Director and Chief Medical Officer y-if - o..'y Dedicated to protecting and improving the health and environment of the people of Colorado *4c{o'`�* 4300 Cherry Creek Dr.S. Laboratory Services Division r raj/ Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Website Title: Carrizo Oil & Gas, Inc.—Timbro Ranch 1-41-9-59—Weld County Released To: The Greeley Tribune On: March 31, 2014 Published: April 3,2014 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT 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: Carrizo Oil & Gas, Inc. Facility: Timbro Ranch 1-41-9-59 Exploration and Production Facility Lot l Section 1, Township 9N, Range 59W/6 Weld County The proposed project or activity is as follows: The applicant proposes to include emissions associated with well flaring for maintenance and emergency procedures. 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.I.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 l3 WE2803 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 www.colorado.gov/cdphe/AirPublicNotices 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: David V. Thompson Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-BI Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us a m STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT NQ``�F;g AIR POLLUTION CONTROL DIVISION ° TELEPHONE: (303)692-3150 ., �- .1a76,/ CONSTRUCTION PERMIT PERMIT NO: 13WE2803 Issuance 1 DATE ISSUED: ISSUED TO: Carrizo Oil & Gas, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as Timbro Ranch 1-41-9-59 Production Facility, located in Lot 1 of Section 1, Township 9N, Range 59W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Separator controlled by an Open Flare. Flare has a minimum Separator 005 combustion efficiency of 95%. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division)no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days(180)after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G2). 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 AIRS ID: 123/9916/005 Page 1 of 8 Wellhead Version 2012-1 Iol.t. De 3-!, ent if Public Health and Environment Air Pollution Control Division 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 following information for all permitted equipment except fugitive emissions from equipment leaks shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 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 - Emission Type NO, VOC CO Separator 005 0.5 6.3 2.8 Point See "Notes to Permit Holder#4"for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 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 Separator 005 Separator controlled by an Open Flare VOC, Haps PROCESS LIMITATIONS AND RECORDS AIRS ID: 123/9916/005 Page 2 of 8 5. Y6 ,fit k Colosac, Deraar4ment f Public Health and Environment • Air Pollution Control Division .tea•'{:. 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 Process Parameter Annual Limit Equipment ID Point Separator 005 Natural gas flaring 11.1 MMSCF/yr 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. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 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. (Reference: Regulation No. 1, Section II.A.1. & 4.) 11. 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.) 12. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 13. Upon startup of these points, the applicant shall follow the operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. The operator shall complete an initial site specific extended gas analysis of the natural gas produced at this site in order to verify the VOC, benzene,toluene, ethylbenzene, xylenes, n- hexane,and 2,2,4-trimethylpentane content(weight fraction)of this emission stream used in the permit application. Results of testing shall be used to determine site-specific emission factors using Division approved methods. Results of site-specific sampling and analysis shall be submitted to the Division as part of the self-certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. AIRS ID: 123/9916/005 Page 3 of 8 of De en f Public Health and Environment Air Pollution Control Division 15. The owner or operator shall demonstrate compliance with Condition 14 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5). Periodic Testing Requirements 16. On an annual basis,the operator shall complete a site specific extended gas analysis of the natural gas produced at this site that is routed to the flare in order to verify the VOC content (weight fraction) of this emission stream used in the permit application. Results of testing shall be used to determine site-specific emission factors using Division approved methods. ADDITIONAL REQUIREMENTS 17. 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 any non-criteria reportable pollutant: If the emissions increase by 50% or five (5)tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted,then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide"final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once AIRS ID: 123/9916/005 Page 4 of 8 u se �m Cola acr) Dey r,1ment%f Public Health and Environment te Air Pollution Control Division self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the 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. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the 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. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: David Thompson Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Carrizo Oil and Gas, Inc. • AIRS ID: 123/9916/005 Page 5 of 8 el.a j. De 3 ent f Public Health and Environment .° Air Pollution Control Division Notes to Permit Holder: 1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpaciename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&paqename=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. If a NCRP is listed as reportable in this table, then a corresponding emission factor needs to be included in Notes to Permit Holder#4. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 A 890 Yes 45 Toluene 108883 C 553 No 28 005 Ethylbenzene 100414 C 59 No 3 Xylenes 1130207 C 124 No 6 n-Hexane 110543 C 5374 Yes 269 5) The emission levels contained in this permit are based on the following emission factors: Emission factor table and associated note for the flare. If operator permitted a flare,please modify the table and note accordingly. If not, please remove table and associated note. The weight fraction of gas(%)should come from the gas analysis calculations(and should be the same values as shown in the emergency tank source). Mass Emission Emission CAS# Pollutant Fraction of Factors Factors Source Gas (%) Uncontrolled Controlled NOx 0.068 0.068 AP-42 lb/MMBtu lb/MMBtu CO 0.37 AP-42 0.37 lb/MMBtu lb/MMBtu AIRS ID: 123/9916/005 Page 6 of 8 a.aaatol./ . Detar4ment f Public Health and Environment rr Air Pollution Control Division Mass Emission Emission CAS# Pollutant Fraction of Factors Factors Source Gas (%) Uncontrolled Controlled VOC 16.02 22703.3089 1135.1654 Engineering lb/mmscf lb/mmscf Calculation 71432 Benzene 0.0389 80.1812 4.0091 Engineering lb/mmscf lb/mmscf Calculation 108883 Toluene 0.0205 49.8437 2.4922 Engineering lb/mmscf lb/mmscf Calculation 5.3225 0.2661 Engineering 100414 Ethylbenzene 0.0019 lb/mmscf lb/mmscf Calculation 1330207 Xylenes 0.0040 11.2053 0.5603 Engineering lb/mmscf lb/mmscf Calculation 484.1088 24.2054 Engineering 110543 n-hexane 0.2129 lb/mmscf lb/mmscf Calculation Note: The uncontrolled VOC and HAP emissions for this point were calculated using the August 9, 2010 analysis of a gas sample collected from the Critter Creek 2-03H well. The controlled VOC and HAP emissions factors for point 003 are based on the flare control efficiency of 95%. Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis OR gas and liquids analyses. 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 of: VOC PSD True Minor of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I AIRS ID: 123/9916/005 Page 7 of 8 ol. A Del ent f Public Health and Environment Air Pollution Control Division Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 SubpartA—SubpartZ 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 XXXXXX 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: www.colorado.qov/cdphe/oilqaspermits AIRS ID: 123/9916/005 Page 8 of 8 Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Division Information Engineer: David Thompson I Attainment Status Control Engineer: Chris Laplante) 1 PM 10 Attainment Review Date: 02/11/2014 PM2.5 Attainment Application Date: 10/03/2013 ______I SOx Attainment NOx Attainment VOC Attainment Facility Information CO Attainment Permit No. 13WE2803 County# f23 Weld Potentially Located within EAC•determine attainment status of NC AIRs Facility# 9916 Point# 005 Facility Equipment ID Separator Company Name: Carrizo Oil&Gas.Inc Source Name:'Timbro Ranche 1.41-9-59 Source Location:UT 1 SEC1 T(N R59W i SIC:•1311 Elevation(feet) 0 New Permit Modification APEN X (CPI) (Issuance#) Required/Permit Fxemnt Transfer of APEN Ownership Exempt/Permit FxPmnt Notes Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: routed to an open-flame flare Natural gas venting from a well head separator.Emissions from this source are routed to an open- flame flare. Emission Calculation Method EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.4-3) Ex=O"MW*XxIC Ex=emissions of pollutant x O=Volumetric flow rate/volume of gas processed MW=Molecular weight of gas=SG of gas"MW of air Xx=mass fraction of x in gas C=molar volume of ideal gas(379 scf/lb-mot)at S0F and 1 atm Throughput(O) 11 MMscf/yr I 1267.1 scf/hr 0.94 MMscf/mo i MW 24.490 IbAb-md 0.000 MMscf/d [mole 0/0 MW Ibxflbmol 'mass fraction E lb/hr Ib/yr tpy Helium 0 02 4.0026 0.001 0.000 Helium 0.0 23 0.01 CO2 248 44.01 1.091 0.045 CO2 3.6 31966 15.98 N2 1.14 28.013 0.319 0.013 N2 1.1 9353 4.68 methane 68.9799 16.041 11.065 0.452 _methane 37.0 324069 162.03 ethane 113388 30.063 3.409 0.139 ethane 11.4 99835 49.92 propane 8.9931 44.092 3.9652 0.162 _propane 13.3 116132 58.07 isobutane I 0.9365 58.118 0.5443 0.022 isobutane 1.8 15941 7.97 n-butane 3.4021 58.118- 1.9772 0.061 n-butane 6.6 57908 28.95 isopentane 0.6769 72.114 0.4881 0.020 isopentane 1.6 14298 7.15 n-pentane 0.9533 72.114 0.6896 0.028 n-pentane 2.3 2019T 10.10 cyclopentane 0 0859- 70.13 0.0602 0.002 cyclopentane 0.2 1764 0.88 n-Hexane 0.2129 86.18 0.1835 0.007 n-Hexane 0.6 5374 2.69 cydohexane 0.0535 84.16 0.0450 0.002 cyclohexane 0.2 1319 0.66 Other hexanes 0.3632 86.18 0.3130 0.013 Other hexanes , 1.0 9167 4.58 heptanes 0.1635 100.21 0.1638 0.007 heptanes 0.5 4799 2.40 methylcydohexane 0.0347 98.19 0.0341 0.001 methylcyclohexane 0.1 998 0.50 224-TMP 0.0001 114.23 0.0001 0.000 224-TMP 0.0 3 0.00 Benzene 0.0389 78.12 0.0304 0.001 Benzene 0.1 890 0.45 Touene 0.0205 92.15 0.0189 0.001 Toluene 0.1 553 0.28 Ethyl benzene 0.0019 106.17 0.0020 0.000 Ethylbenzene 0.0 59 0.03 Xylenes 0 004 106.17 0.0042 0.000 _Xylenes 0.0 124 0.06 Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division IC8+Heavies I 0 07661 10 300J 0.0847 I 0.003 T 8+Heavies I 0.3 I 2481 1.24 VOC mass fraction: 0.3513 Total VOC Emissions(Uncontrolled) 126.0 24.490 annual limit assuming 95%control 6.3 Notes monthly limit assuming 95%control(Ib/mo.) 1070.2 Mole%,MW,and mass fractions from Critter Creek 2-03H gas analysis Emissions are based on 8760 hours of operation per year I calculated the average MW of C8+based on the average MW on the analysis for the gas Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Flaring Information Equipment Description Flare to combust produced gas until pipeline is available at this wellhead facility. Manufacturer N/A Model Open Flare Serial Number N/A Gas Heating Value '383 Btu/scf Throughput 15351.3 MMBtu/yr Combustion emission factor source. AP-42 Chapter 13.5 0.068 lb NOX/MMBtu 0.37 lb CO/MMBtu 0.52 tpy NOX 2.84 tpy CO Emissions Summary 0.52 tpy NOX Uncontrolled/PTE 2.84 tpy CO 126.003 tpy VOC Controlled 6.300 tpy VOC Uncontrolled Scenario A Controlled Total(Ib/yr) Bin Reportable? Total(Ib/yr) Benzene 890 A Yes 45 Toluene 553 C No 28 Ethylbenzene 59 C No 3 Xylenes 124 C No 6 n-hexane 5374 C Yes 269 224-TMP 3 C No 0 Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section IIA.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 30V opacity' AQCC Regulation 2 Section LA 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 two tons per year in an attainment area. A permit is required for this source because uncontrolled VOC emissions from this facility exceed five tons per year in an attainment area Part B: This source is not subject to Section III.D 2(5/Imor Source PACT)because it is not located in a nonattanment area Is public comment Public Comment Required required? Facility Status This facility is a true synthetic minor source of VOC for Title V applicability This facility is a true minor VOC for PSO applicability _ - = 1 - - c nri- E-:, : :7E' 'Ed a ; 7-'7: ii "22-1- -7 77v c y :=- 3:-L:":": c " c - U _ - ._ : -:4:1E: : rizi: ,_ CIL 11C-i."+- - of ❑ ❑ _ - - l: :„.; reqe:7, !:{ _ ;HIFI. _v - o _ ei u - - 0 .f = _ L - - r - - _r.J ., 27 j I e77 = _ _ = I ti O > F ❑u I m ❑ ❑ ❑ o ci 7-.7, F , a . : - - V v ' - y- = N _ - 7 _ I ✓ M - - N _ 55, _ I '5) V .4I v _ r Elo L G L v oU G V ✓ v `/ ry - p- r- C - / _ I - — - 1 _ _ I - 1 L I ✓. - �i - < iY -_ _ Hr rn lM - _ V I' ° I - = _ ,� - _ _ - ,- 77 N - i ,� I _ - - = _ _ = ^no, — - c = - I C - - _ - I v. - _ - - u y = _ -- I _ = - m - f _ A - E.7.J . - ._ < _ _ O J < _ o = _ -C. I 11 _ = G I o s = _ = o - r o - _ .. •- .. _ _ V y E - . 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