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Home My WebLink About20142832.tiff ,A CD�E COLORADO n. co .0Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 RECEIVED September 10, 2014 SEP 15 2014 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On September 13, 2014, the Air Pollution Control Division will publish a public notice for Synergy Resources - Phelps Tank Farm Battery, in the The Greeley Tribune. 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-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, f A Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 2014-2832 CC•pC(mn,)AW; fit(P6) ratbLw lleilietb Tic AVIA"`°l't q �1n 4300 Cherry Creek Drive S., Denver, CO 8M6-1530 P 303-692-2000 www.colorado.gov/cdphe pzi ,!, b,, 9-,P J0/'{ John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer CDPHE Public Notice Of A Proposed Project CO Or Activity Warranting Public Comment Website Title: Synergy Resources - Phelps Tank Farm Battery - Weld County Released To: The Greeley Tribune On: September 10, 2014 Published: September 13, 2014 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Synergy Resources Facility: Phelps Tank Farm Battery Exploration and Production Facility SENE, Sec. 32, T1 N, R66W Weld County The proposed project or activity is as follows: The source is using a Temporary 4" 10MMSCF Flare with XFC6413 flow computer/meter. The flare will be onsite to control flowback during well development. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 14WE0837 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: David Thompson Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us COLORADO I A STATE OF COLORADO oe coiog•LO- • i• D ' • -T' •F P : C HEALTH AND ENVIRONMENT �° AIR POLLUTION CONTROL DIVISION H TELEPHONE: (303) 692-3150 +. * '1846+, CONSTRUCTION PERMIT PERMIT NO: 14WE0837 Issuance 1 DATE ISSUED: ISSUED TO: Synergy Resources Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Phelps Tank Farm Battery, located in the SENE, Sec. 32 Ti N, R66W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Model NO. 15 Flare controlling all flowback and natural gas venting Flare 001 during drilling operations at the Phelps Wells Battery. Flare has a minimum combustion efficiency of 95%. The flare is not enclosed. 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.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period AIRS ID: 123/9CBA Page 1 of 7 olor epa en Ii Health and Environment it Pollution Control Division of eighteen (i n to c ction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type Flare 001 4.1 8.5 22.3 Point See 'Notes to Permit Holder"for information on emission factors and methods used to calculate limits. 8. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit(Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Flare 001 Flare VOC, NOx, CO PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) AIRS ID: 123/9CBA Page 2 of 7 III olor- ik Depa en : P di Health and Environment it Pollution Control Division III Process/Con< .n ' • Facility AIRS Equipment Point Process Parameter Annual Limit ID Flare 001 Gas Vented from Separator 1825 MMSCF Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 13. 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 14. Point 001: The owner or operator shall demonstrate compliance with opacity requirements, using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.1 &4) ADDITIONAL REQUIREMENTS 15. 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: AIRS ID: 123/9CBA Page 3 of 7 olor pa en Ii Health and Environment it Pollution Control Division For a For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,J 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. 16. 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 17. 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. 18. 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. AIRS ID: 123/9CBA Page 4 of 7 olor Depa en Ii Health and Environment it Pollution Control Division 19. This permit i - in t y an pleteness 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. 20. 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. 21. 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. 22. 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. 23. 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 Synergy Resources Corporation AIRS ID: 123/9CBA Page 5 of 7 olo pa en li ealth and Environment it Pollution Control Division Notes to Permit Holder me o 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: htto://www.colorado.aov/cs/Satellite?c=Document C&childpaaename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&oaaename=CBONWraDDer 4) The emission levels contained in this permit are based on the following emission factors: Point 001: Weight Emission Emission Pollutant Fraction of Factors Factors Source Gas(%) Uncontrolled Controlled Ib/MMEITU Ib1MMBTU NOx - 0.068 0.0034 AP-42 CO - 0.37 0.0185 AP-42 VOC 11.791 0.14 0.007 AP-42 5) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice(APEN)associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 6) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO NANSR Synthetic Minor Source of: VOC, CO MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.g poaccess.oov/ AIRS ID: 123/9CBA Page 6 of 7 Depa en P li Health and Environment it Pollution Control Division Part 60: StandarDolor e S ourc 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 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 7777-Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 1) 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.00v/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9CBA Page 7 of 7 Division Information Engineer: David Thompson Control Engineer: Chris Laplante Review Date: 08/06/2014 Application Date: 04/14/2014 07/13/2014 Facility Identifiers Permit No. 14WE0837 AIRS County# 123 Weld Facility# 9CBA Facility Type: exploration and production facility O Located in the 8-hour non-attainment area? O True Minor Synthetic Minor for: 1-; VOC r NOx r Co Administrative Information Company Name: Synergy Resources Corporation Source Name: Phelps Tank Farm Battery Source Location: SENE, Sec. 32 TIN, R66W SIC: 1311 Address 1: Synergy Resources Corporation Mailing Address Address 2: 20203 Highway 60 /,State Zip: Platteville, CO Name: Rhonda Sandquist Person To Phone: 970-737-1073 Contact Fax: 970-737-1045 Email: rsandquist@syrginfo.com Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the Phelps Tank Farm Battery, located in the SENE,Sec. 32 Ti N, R66W,Weld County,Colorado. Point Name Type Control Action Newly 001 Flare Separator Venting Flare reported source Model NO.15 Flare controlling all flowback and natural gas venting during drilling operations at the Phelps 001 Wells Battery.Flare has a minimum combustion efficiency of 95%. The flare is not enclosed. Equipment Description This source vents natural gas from: well casing Emissions from this source are: routed to a flare Natural gas venting from well casing.Emissions from this source are routed to a flare. Calculations Emission Calculation Method EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.43) Ex=Q•MW•Xx/C Ex=emissions of pollutant x Q=Volumetric flow ratehrolume of gas processed MW=Molecular weight of gas=SG of gas•MW of air Xs=mass fraction of x in gas C=molar volume of ideal gas(379 scf/Ib-mol)at B0F and 1 atm Throughput(O) 1825 MMscfyr 208333.3333 scthr MW 22.17 IbAb-mol 5 MMac7/d mole% MW Ibrlbmd mass notion Ib/hr Ibyr 4•y Helium CO2 N2 methane ethane propane Isobdane n-dnane • letpenthue n-pentane cydopentane n-Hews cydohexana Other hennas hep_tenea methylcydduexv e 224TMP Benzene Toluene EBrylbenzene Xylenes C8+Heavies Notes Emissions are based on 8780 hours of operation per year. Flaring Information Equipment Description Flare to combust produced gas until pipeline is available at this wellhead facility. Manufacturer NA Model Model 15 Serial Number NA Gas Heating Value 1319 Btu/scf Throughput 2407175 MMBtu/yr VRU information Equipment Description 1825 Engine to recompress gas to sales line. Make Model Requested Control 100.00% Annual Bypass Tim 50.00% Backup Flare Overall Control 95.00% Combustion emission factor source: AP-42:Chapter 13.5 0.07 alb NOX/MMBtu 0.37 IIb CO/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.14 Ib/MMBTU 0.01 lb/MMscf 168.50 tpy 8.43 tpy Gas Analysis Noy 0.07 lb/MMBTU 0.00 Ib/MMBTU 81.84 tpy 4.09 tpy AP-42 CO 0.37 lb/MMBTU 0.02 Ib/MMBTU 445.33 tpy 22.27 tpy AP-42 • Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section ll.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." el k §us • |§ z a 111 \ ' lij la z § S | | re ILI® § !§ ° . § k ■ 0 ) 00 W• > ` . co \ | - © k \ o !.§ ! ! § o uj �3§ k : § nIn .,wr !§ o® $ 5 § _ __ ; :� E z rea ®{ k1t, |/ a h"! ! \a.� o I I to \ ■ - § . 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J o K AIRS(County/Plant) 123/9CBA Permit No. 14WE0837 Date 8/6/2014 Uncontrolled Emission Point# SCC Pollutant or CAS Factor 001 31000205 VOC 0.14 lb/MMBTU 001 31000205 NOx 0.068 Ib/MMBTU 001 31000205 CO 0.37 Ib/MMBTU Controlled Controlled Actual Requested NCRP = Emissions Emissions Ctrl. reportable Emisison Factor Source (tpy)` (tpy)* PTE (tpy)* Eff% ? Gas Analysis 8.4 168.5 95% Yes AP-42 4.1 81.8 95% Yes AP-42 22.3 445.3 95% Yes 1 vI o v o t! O N I I ° o - 0 0I B T = ? c cr g, = r- � = --- _ `_ J N N N Cr" y ^� - —I tell : Z II"' U ^W E J O = e � -3 -, S. E Mr, t--, a . _ = c "5a o - _o v N Z .. G u E m- ❑ ❑ _ .4. v. _ - 3 — - o R ..... O v C 3 c. 4 er I u _ d v 2 IA s •2 ' r = < > _ = a U x rr .3 .- .no E c = a 3 Z = _ = 5 c 9 0 — v _ U _ d C c :C .C 5 .- n .ov. 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