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Home My WebLink About20142849.tiff • CDPHE COLORADO 111 CO Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 RECEIVED September 11, 2014 SEP 16 2014 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On September 14, 2014, the Air Pollution Control Division will publish a public notice for Whiting Oil and Gas Corporation - Horsetail 18-0713H, 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 Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, f F i I Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 2014-2849 et.' PL,PWltkL 4300 Cherry Creek Drive S.,Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ,Q( t ₹t'. 'b\ TI.��llL �i John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer �, W I 10,', q-aa- t w;8s, i CDPHE Public Notice Of A Proposed Project irk 9 Or Activity Warranting Public CO Comment Website Title: Whiting Oil and Gas Corporation - Horsetail 18-0713H - Weld County Released To: The Greeley Tribune On: September 11, 2014 Published: September 14, 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: Whiting Oil and Gas Corporation Facility: Horsetail 18-0713H Oil Et Gas Exploration ft Production Facility SWSW SEC 18 T1 ON R57W Weld County The proposed project or activity is as follows: Applicant proposes a new crude oil and associated natural gas 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): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 14WE0830 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: Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us Se COLORADO 1 I A' ;=, DRAFT STATE OF COLORADO 02-coLgers COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT A.4; AIR POLLUTION CONTROL DIVISION 7 TELEPHONE: (303)692-3150 « �* 1876 CONSTRUCTION PERMIT PERMIT NO: 14WE0830 Issuance 1 DATE ISSUED: ISSUED TO: Whiting Oil and Gas Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as Horsetail 18-0713H, located in the SWSW of Section 18, Township 10N, Range 57W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID SEP-1 004 One 3-phase gas/oil/water separator; associated gas is normally flared. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division(the Division)no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.00v/oacific/cdohe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days(180)after issuance of this permit,compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions.Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 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 AIRS ID: 123/9CB9/004 Page 1 of 8 Wellhead Version 2012-1 olo Depa e f Health and Environment r Pollution Control Division application as 'i) ' s co ion 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 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. Within one hundred and eighty(180)days after issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas vented from this separator. The operator shall used the gas flow rate listed in the application for actual flow rate until the flow meter is installed, not to exceed one hundred and eighty(180)days after issuance of this permit. 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 SEP-1 004 4.3 66 23.3 Point See ?Votes to Permit Holder#4"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. The operator shall continuously monitor and record the volumetric flowrate of natural gas vented from the separator using a flow meter. The flow meter shall continuously measure flowrate and record total volumetric flow vented from the separator.The operator shall use monthly throughput records to demonstrate compliance with the process limits and to calculate emissions as described in this permit. 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 AIRS ID: 123/9CB9/004 Page 2 of 8 Depa en f li Health and Environment it Pollution Control Division permit holderDolor a i ac d ke ompliance 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-1 004 Open Flare with Constant Pilot Light VOC and HAP 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 Equipment nn Process Parameter Annual Limit ID Point SEP-1 004 Natural Gas Flaring 83.95 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) AIRS ID: 123/9CB9/004 Page 3 of 8 olo Depa e f li Health and Environment • it Pollution Control Division OPERATING & M N 14. Upon startup of these points, the applicant 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 15. The owner or operator shall demonstrate compliance with opacity requirments using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1,Section I I.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. 17. The owner or operator shall demonstrate compliance with opacity requirements using EPA Method 9 to measure opacity from the flare during periods of startup,process modification, or adjustment of control equipment.This measurement shall consist of a minimum twenty- four consecutive readings taken at fifteen second intervals over a six minute period. (Reference: Regulation No. 1, Section II.A.1 &4) 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) 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 AIRS ID: 123/9CB9/004 Page 4 of 8 Depa en f li Health and Environment it Pollution Control Division commencedDolor s teed ederal 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 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. AIRS ID: 123/9CB9/004 Page 5 of 8 olo Depa e f I' Health and Environment II; Pollution Control Division 0A Christopher Kester Oil and Gas Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123/9CB9/004 Page 6 of 8 olor Depa en f Ii Health and Environment it 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.aov/cs/Satellite?c=Document C&childpaaename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&paaename=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 Point Pollutant CAS# (lb/yr) reportable? Rate(Ib/yr) Benzene 71432 7080 Yes 354 Toluene 108883 7540 Yes 378 004 Ethylbenzene 100414 1180 Yes 58 Xylenes 1130207 1880 Yes 94 n-Hexane 110543 59500 Yes 2974 5) The emission levels contained in this permit are based on the following emission factors: Weight Emission Emission Factors CAS# Pollutant Fraction of Uncontrolled Factors Source Gas(%) Controlled NOx --- 0.068 Ib/MMBtu 0.068 lb/MMBtu AP-42 CO — 0.370 lb/MMBtu 0.370 Ib/MMBtu AP-42 VOC 20.86 31462 lb/MMscf 1573.1 Ib/MMscf Engineering Calculation 71432 Benzene 0.041 84 Ib/MMscf 4.2 lb/MMscf Engineering Calculation 108883 Toluene 0.037 90 lb/MMscf 4.5 lb/MMscf Engineering Calculation 100414 Ethylbenzene 0.005 14 lb/MMscf 0.7 lb/MMscf Engineering Calculation 1330207 Xylenes 0.008 22 Ib/MMscf 1.1 lb/MMscf Engineering Calculation AIRS ID: 123/9CB9/004 Page 7 of 8 olo Depa e f li Health and Environment it Pollution Control Division Emission ors Fraction of m Factors CAS# Pollutant Gas(,�) Uncontrolled Controlled Source 110543 n-hexane 0.312 709Ib/MMscf 35.45 Ib/MMscf Engineering Calculation Note: The uncontrolled VOC and HAP emissions for this point were calculated using the November 4th, 2013 analysis of a gas sample collected from the Horsetail 18-0713H well site. The controlled VOC and HAP emissions factors for point 004 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 Synthetic Minor. VOC and HAP PSD or NANSR Synthetic Minor: VOC and HAP MACT HH Not Applicable 8) Full text of the Title 40,Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart 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)OOO OO( 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: htto://www.colorado.gov/pacific/cdohe/air-permit-self-certfication AIRS ID: 123/9CB9/004 Page 8 of 8 NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC CCMFENT ConocoPhillips proposes a project at an oil and gas exploration and production facility located at NENE Section 19, T4S,R64W,in Arapahoe County. Oil and gas exploration and production facility consisting of crude oil tanks, truck loadoul,emergency flare,vapor recovery tower and associated fugitive emissions.This project is subject to public notice because: permitted emissions exceed public notice threshold values in Regulation No.3. Part B,Section III.C.1 a(25 toy in a non- attainment area and/or 50 tpy in an attainment area),the source is requesting a federally enforceable imit on the potential to emit in order to avoid other requirements.The Division has made a preliminary determination of approval of the application. Comments concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission are solicited from any interested person.The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Additional information regarding this action can be found at the Arapahoe Clerk's office and on the Divisions Website at:hops:// www.colorado.gowyacitc/cdphe/air- pernit-public-notices or by contacting Stephanie Chaousy of the Division at 303-692-2297. RELEASED TO:The Villager on September 11,2014 Published in The Villager Published:September 18,2014 Legal#5146 Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Division Information Engineer: Christopher Kesler Attainment Status Control Engineer: Stefanie Rucker PM10 Attainment Review Date: 07/082014 PM2.5 Attainment Application Date: 12/16/2013 SOx Attainment NOx Attainment VOC Attainment Facility Information CO Attainment Permit No. 14WE0829 County# 123 Weld Potentially Located within EAC-determine attainment status of NO) AIRs Facility# 9CB9 Point* 004 Facility Equipment ID SEP-1 Company Name: Whiting Oil and Gas Corporation Source Name: Horsetail 18-0713H SWSW Section 18,Township 10N,Range 57W Source Location: SIC: 1311 Elevation(feet) 4802 X New Permit Modification APEN (CPI) (Issuance#) Required/Permit Fxemnt Transfer of APEN Ownership Exempt/Permit Fxemnt Notes Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: routed to an enclosed flare Natural gas venting from a well head separator.Emissions from this source are routed to an enclosed flare. Emission Calculation Method EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.4-3) Ex=O'MW'Xx/C Ex=emissions of pollutant x 0=Volumetric flow rateNolume 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) 64 MMscf/yr 9583.3 scf/hr 7.13 MMscf/rno MW 27.328 Ib/Ib-mol 0.002 MMscf/d mole% MW Ibxflbmol mass fraction E Ib/hr lb/yr tpy Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00 CO2 2.596 44.01 1.142 0.042 CO2 28.9 253068 126.53 N2 0.969 28.013 0.271 0.010 N2 6.9 60126 30.06 methane 62.362 16.041 10.003 0.366 methane 252.9 2215812 1107.91 ethane 13.216 30.063 3.973 0.145 ethane 100.5 880063 440.03 propane 11.53 44.092 5.0838 0.186 propane 128.5 1126084 563.04 isobutare 1.231 58.118 0.7154 0.026 isobutane 18.1 158471 79.24 n-butane 4.331 b8.116 2.51/1 0.092 n-butane 63.6 55/546 278.7/ isopentane 0.884 72.114 0.6375 0.023 isopentane 16.1 141206 70.60 n-pentane 1.191 72.114 0.8632 0.032 n-pentane 21.8 191203 95.60 cydopentane 0.133 70.13 0.0933 0.003 cydopentane 2.4 20660 10.33 n-Hexane 0.3120 86.18 0.2689 0.010 n-Hexane 6.8 59558 29.78 cydohexane 0.0420 84.16 0.0353 0.001 cydohexane 0.9 7830 3.91 Otherhexanes 0.516 86.18 0.4447 0.016 Otherhexanes 11.2 98500 49.25 heptanes 0.349 100.21 0.3497 0.013 heptanes 8.8 77467 38.73 methylcyclohexane 0.081 98.19 0.0795 0.003 methylcyclohexane 2.0 17617 8.81 224-TMP 0 114.23 0.0000 0O00 224-TMP 0.0 0 0.00 Benzene 0.041 78.12 0.0320 0.001 Benzene 0.8 7095 3.55 • Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Alr Pollution Control Division Toluene 0.037 92.15 0.0341 0.001 Toluene 0.9 7552 3.78 Ethytbenzene 0.005 108.17 0.0053 0.000 EBMbenzene 0.1 1176 0.59 Xylenes 0.008 106.17 0.0085 0.000 Xylsnee 0.2 1881 0.94 Cat Heavies 0.161 477.880 0.7890 0.028 C8+Heavies 19.4 170344 85.17 VOC mass fraction: 0.4388 Total VOC Emissions(Uncontrolled)_ 1322.1 27.328 annual limit assuring 95%control 08.1 1111 monthly limit assuming 95%control(lb/mo.) 11228.8 Mole%,MW,and mass fractions from Horsetail 18-0713H gas analysis. Emissions are based on 8760 hours of operation per year. I calculated the average MW of C8+based an the average MW on the analysis for the gas. Flaring Information Eauloment Description Flare to combust produced gas until pi ine is available at this wellhead facility. Manufacturer NA Model NA Serial Number NA Gas Heating Value, 1499 Btu/sd Throughput 125841.05 MMBtuM Combustion emission factor source: AP-42:Chapter 13.5 0.088 lb NOXAMdBtu 0.37 b CO/MMBtu 4.28 toy NOX 23.28 tpy CO Emissions Summary 4.28 tpy NOX tp UnconfrolledlPTE 23.28 tPy CO 1322.095 Ipy VOC Controlled 68.105 ipy VOC Uncontrolled Scenario A Controlled Total(Ibyr) Reportable Total(Iblyr)_ Benzene 7095 Yes 355 Toluene 7552 Yes 378 Ethybenzene 1178 Yes 59 Xylenes 1881 Yes 94 n-hexane 59558 Yes 2978 224-TMP 0 No 0 Regulatory Applicability ABC Reauletloe This source is subject to the opacity requirements for flares in Section IIA5:'No owner or operator of a smokeless flare or other flare for the combustion ofwaste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.' AQCC Raauletlon 2 Section LA apples 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. 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 notsubject to Section III.D.2(Minor Source RACT)because it is not located in a nonattainment area. Is pubic comment Public Comment Required required? Facility Status This facility is a synthetic minor source of VOC and HAP for Title V applicability. 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