HomeMy WebLinkAbout20142083.tiff STATE OF COLORADO
John W.Hickenlooper,Governor
Larry Wolk, MD,MSPH a of•rotor
Executive Director and Chief Medical Officer FT '✓�
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr.S. Laboratory Services Division `1���6,±V ``
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
July 8, 2014
Dear Sir or Madam:
On July 14, 2014, the Air Pollution Control Division will publish a public notice for Whiting Oil and Gas
Corporation—Twomile Creek 22-13H Pad, 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-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
l' RECEIVED
JUL 10 2011
Clara Gonzales
Public Notice Coordinator WELD COUNTY
Stationary Sources Program COMMISSIONERS
Air Pollution Control Division
Enclosure
eu(9-AA) Cc,: ptlmm) 1 -L(PP5)
l,r(etaeft/3M 2014-2083
� IVILJ
STATE OF COLORADO
John W.Hickenlooper,Governor
Larry Wolk,MD,MSPH cot
Executive Director and Chief Medical Officer Fe ?p
� o
Dedicated to protecting and improving the health and environment of the people of Colorado i, „, e��,;g�'
4300 Cherry Creek Dr.S. Laboratory Services Division �'e"""" »
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: Whiting Oil and Gas Corporation—Twomile Creek 22-13H Pad—Weld County
Released To: The Greeley Tribune
On: July 8, 2014
Published: July 14, 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: Whiting Oil and Gas Corporation
Facility: Twomile Creek 22-13H Pad
Oil and gas exploration and production facility
SWNW Section 22, T1 IN,R57W
Weld County
The proposed project or activity is as follows: Natural gas venting at an oil and gas exploration and production
facility.
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 11 WE3531 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:
Stephanie Chaousy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South,APCD-SS-Bl
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
I ,,,
6Y
STATE OF COLORADO .
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT /
AIR POLLUTION CONTROL DIVISION ' ,
ro .1
TELEPHONE: (303)692-3150 �+
CONSTRUCTION PERMIT
PERMIT NO: 11WE3531
Issuance 1
DATE ISSUED:
ISSUED TO: Whiting Oil & Gas Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Twomile Creek 22-13H Pad, located in the SWNW of
Section 22, Township 11 North, Range 57 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
SEP-1 003 Separator controlled by a flare stack. 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 of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
AIRS ID: 123/9473 Page 1 of 7
Wellhead Version 2012-1
Col D men f Public Health ti and Environment
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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 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 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.)
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 Emission Type
Equipment ID Point NO, VOC CO yp
SEP-1 003 2.9 27.6 5.9 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.
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
SEP-1 003 Separator controlled by a flare stack VOC
AIRS ID: 123/9473 Page 2 of 7
ii lowll
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Air Pollution Control Division
PROCESS LIMITATIONS AND RECORDS
9. 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
SEP-1 003 Natural gas flaring 25.6 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
10. 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)
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. (Reference: Regulation No. 1, Section II.A.1. & 4.)
12. 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.)
13. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
14. 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
15. 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: 123/9473 Page 3 of 7
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Air Pollution Control Division
16. The owner or operator shall demonstrate compliance with Condition 12 using EPA Method 9
to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5).
Periodic Testing Requirements
17. 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
18. 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.
19. 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
20. 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.
21. 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: 123/9473 Page 4 of 7
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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.
22. 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.
23. 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.
24. 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.
25. 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.
26. 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:
Stephanie Chaousy, PE
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Whiting Oil & Gas Corporation. Newly
permitted separator flare at a synthetic minor
facility.
AIRS ID: 123/9473 Page 5 of 7
Col D men f Puee
Airblic PollutionHealth ControlandEnvironm Divisionnt
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.ciov/cs/Satellite?c=Document C&childpaoename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pauename=CBONWraooer
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of
the specific compounds emitted if the source(s)operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr)
Benzene 71432 A 3,476 Yes 174
003 Toluene 108883 C 3,230 Yes 162
n-Hexane 110543 C 31,721 Yes 1,586
5) The emission levels contained in this permit are based on the following emission factors:
Point 003:
Weight Emission Emission
CAS# Pollutant Fraction of Factors Factors Source
Gas(%) Uncontrolled Controlled
NOx 0'138 TCEQ Factor
Ib/MMBtu
CO 0.2755 TCEQ Factor
Ib/MMBtu
VOC 29.23 43290.8204 2164.5410 Engineering
Ib/mmscf Ib/mmscf Calculation
71432 Benzene 0.066 136.0401 6.8020 Engineering
Ib/mmscf Ib/mmscf Calculation
108883 Toluene 0.052 126.4327 6.3216 Engineering
Ib/mmscf Ib/mmscf Calculation
110543 n-hexane 0.546 1241.5377 62.0769 Engineering
Ib/mmscf Ib/mmscf Calculation
AIRS ID: 123/9473 Page 6 of 7
Coley= . D men .f Public PollutionHealthand ControlEnvironment Division
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the October 4,
2011 analysis of a gas sample collected from the Twomile Creek 22-13H well.The controlled
VOC and HAP emissions factors for point 003 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
Synthetic Minor Source of:
Operating Permit
VOC, n-hexane
PSD Synthetic Minor Source of:
VOC
MACT HH Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below-
http://ecfr.gnoaccess.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 7777—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.gov/cd phe/oilgasperm its
AIRS ID: 123/9473 Page 7 of 7
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Division Information
Engineer: Stephanie Chaousy, PE Attainment Status
Control Engineer: Chris Laplantel PM10 Attainment
Review Date: 04/03/2014 PM2.5 Attainment
Application Date: 11/07/2011 SOx Attainment
NOx Attainment
Facility Information VOC Attainment
Permit No. 11WE3531 CO Attainment
County# 123 Weld
AIRs Facility# ,9473
Point# 003
Facility Equipment ID Sep-1
Company Name: Whiting Oil and Gas Corporation
Source Name: Twomile Creek 22-13H Pad
Source Location: SWNW Section 22,Township 11N, Range 57W
SIC: 1311
Elevation(feet)4963
APEN
New Permit Modification
X (CPI) (Issuance#) Required/Permit
Exemot
Transfer of APEN
Ownership Exempt/Permit
Fxpmot
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=Q*MW"Xx/C
Ex=emissions of pollutant x
0=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-mol)at 60F and 1 atm
Throughput(Q) 25.55 MMscf/yr I 2916.7 scf/hr I 2.17 MMscf/mo
MW 30.382 Ib/Ib-mol 0.001 MMscf/d
mole% MW Ibx/Ibmol mass fraction E lb/hr lb/yr tpy
Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00
CO2 2.687 44.01 1.183 0.039 CO2 9.1 79721 39.86
N2 2.01 28.013 0.563 0.019 N2 4.3 37958 18.98
methane 54.452 16.041 8.735 0.287 methane 67.2 588840 294.42
ethane 11.625 30.063 3.495 0.115 ethane 26.9 235601 117.80
propane 14.545 44.092 6.4132 0.211 propane 49.4 432340 216.17
isobutane 1.754 58.118 1.0194 0.034 isobutane 7.8 68721 34.36
n-butane 6.584 58.118 3.8265 0.126 n-butane 29.4 25(960 128.98
isopentane 1.495 72.114 1.0781 0.035 isopentane 8.3 72680 36.34
n-pentane 1.998 /2.114 1.4408 11.04/ n-pentane 11.1 9/1.33 48.5/
cyclopentane 0 70.13 0.0000 0.000 cyclopentane 0.0 0 0.00
n-Hexane 0.5460 86.18 0.4705 0.015 n-Hexane 3.6 31721 15.86
cyclohexane 0.1430 84.16 0.1203 0.004 cyclohexane 0.9 8113 4.06
Otherhexanes 1.143 86.18 0.9850 0.032 Otherhexanes 7.6 66406 33.20
heptanes 0.516 100.21 0.5171 0.017 heptanes 4.0 34859 17.43
methylcyclohexane 0 98.19 0.0000 0.000 methylcyclohexane 0.0 0 0.00
224-TMP 0 114.23 0.0000 0.000 224-IMP 0.0 0 0.00
Benzene 0.066 78.12 0.0516 0.002 Benzene 0.4 3476 1.74
Toluene 0.052 92.15 0.0479 0.002 Toluene 0.4 3230 1.62
Ethylbenzene 0 106.17 0.0000 0.000 Ethylbenzene 0.0 0 0.00
Xylenes 0 106.17 0.0000 0.000 Xylenes 0.0 0 0.00
08+Heavies 0.384 113.731 0.4367 0.014 C8+Heavies 3.4 29442 14.72
VOC mass fraction: 0.5400 Total VOC Emissions(Uncontrolled) 553.0
30.382 annual limit assuming 95%control 27.7
Notes monthly limit assuming 95%control(lb/mo.) 4697.1
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 TBD
Model TBD
Serial Number TBD
Gas Heating Value 1669 Btu/scf
Throughput 42642.95 MMBtu/yr
Combustion emission factor source: AP-42:Chapter 13.5
0.138 lb NOX/MMBtu 0.2755 lb CO/MMBtu
2.94 toy NOX 5.87 tpy CO I
Emissions Summary
2.9 tpy NOX
Uncontrolled/PTE 5.9 tpy CO
553.040 toy VOC
Controlled 27.652 tpy VOC
Uncontrolled Uncontrolle Scenario A Controlled Controlled
Total(Ib/yr) d Total Bin Reportable? Total(Ib/yr) Total(TPY)
Benzene 3476 1.7 A Yes 174 0.09
Toluene 3230 1.6 C Yes 162 0.08
Ethylbenzene 0 0.0 C No 0 0.00
Xylenes 0 0.0 C No 0 0.00
n-hexane 31721 15.9 C Yes 1586 0.79
224-IMP 0 0.0 C No 0 0.00
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 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(Minor Source RACT)because it is
not located in a nonattainment area.
•
Is public comment Public Comment Required
required?
Emission Factors for Permit
Uncontrolled
NOX 230.322 b/MMscf natural gas vented
CO 459.8095 b/MMscf natural gas vented
VOC 43290.8204 b/MMscf natural gas vented
Benzene 136.0401 b/MMscf natural gas vented
Toluene 126.4327 b/MMscf natural gas vented
Ethylbenzene 0.0000 b/MMscf natural gas vented
Xylenes 0.0000 b/MMscf natural gas vented
n-Hexane 1241.5377 b/MMscf natural gas vented •
224-TMP 0.0000 b/MMscf natural gas vented
Controlled
NOX 230.322 Ib/MMscf natural gas vented
CO 459.8095 lb/MMscf natural gas vented
►L'I- 2164.5410- n''sc natural gas vented
=-nzene sc na ural gas vented
o uene na ural gas vented -
•-nzene r r.•Ir' •'• r na ural gas vented
• -nes r.nrr� .• •s na ural gas vented
n- exane na ural gas vented
r 0.I.I. • •s na ural gas vented
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