HomeMy WebLinkAbout20140518.tiff STATE OF COLORADO
John W.Hickenlooper,Governor
Larry Wolk,MD,MSPH of o`o,�
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado *+ '
4300 Cherry Creek Dr.S. Laboratory Services Division .�/8z.
Denver,Colorado 80246-1530 8100 Lowry Blvd. �a7a
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&Recorder
1402 N 17th Ave
Greeley, CO 80631
February 11, 2014
Dear Sir or Madam:
On February 14, 2014, the Air Pollution Control Division will publish a public notice for Carrizo Oil &Gas
Inc.—Vawter 1-11-41-8-61, 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 I
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
/
I
Clara Gonzales
Public Notice Coordinator RECEIVED
Stationary Sources Program
Air Pollution Control Division
FEB 19 2014
Enclosure WELD COUNTY
COMMISSIONERS
-3vJ,GIAL) 1�9.A;ou.6 `( c:?L 11-1-R 1 Pt )
au)_ � • aoim a -ic1-iLl 2014-0518
STATE OF COLORADO
John W.Hickenlooper,Governor
Larry Wolk,MD, MSPH zbf Co<\
F
Executive Director and Chief Medical Officer e .�RrQ
Dedicated to protecting and improving the health and environment of the people of Colorado * ?.•
• y4300 Cherry Creek Dr.S. Laboratory Services Division •
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.—Vawter 1-11-41-8-61 —Weld County
Released To: The Greeley Tribune
On: February 11, 2014
Published: February 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: Carrizo Oil & Gas Inc.
Facility: Vawter 1-11-41-8-61
Separator at an oil and natural gas exploration and production facility
NENE of Section 11, T8N, 61W
Weld County
The proposed project or activity is as follows: Oil and natural gas exploration and production
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 13 W E 1445 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:
Michael Cleary
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-BI
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
STATE OF COLORADO
/OF Col
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303)692-3150
CONSTRUCTION PERMIT
PERMIT NO: 13WE1445
Issuance 1
DATE ISSUED:
ISSUED TO: Carrizo Oil & Gas, Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Crude oil and natural gas exploration and production facility, known as Vawter 1-11-41-8-61,
located in Section 11, Township 8 North, Range 61 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
SEPARATOR 006 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 APCD no later than fifteen days after issuance of this permit or
activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of
Startup (NOS) form may be downloaded online at
raww.cd2hc store cc usrap/downloadforms.htrnl. Failure to notify the APCD of startup of the
permitted source is a violation of 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 on this permit shall be demonstrated to the Division. It is the permittee'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, II.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: 123/9914 Page 1 of 7
Condensate Tank Version 2009-1
Carizzo Oil & Gas, Inc. Colorado Department of 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 operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self-certification,with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Tons per Year Emission Type
Equipment ID Point NO„ VOC CO
SEPARATOR 006 --- 11.4 5.3 Point
See "Notes 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.
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 8, Section III.E.)
Facility AIRS Pollutants
Control Device
Equipment ID Point Controlled
SEPARATOR 006 Open Flare VOC, HAPs
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum consumption, processing and/or
operational rates as listed below. Monthly records of the actual crude oil 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
AIRS ID: 123/9914 Page 2 of 7
Carizzo Oil & Gas, Inc. Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility AIRS Process Parameter Annual Limit
Equipment ID Point
SEPARATOR 006 Natural gas flaring 21.4 MMscf
Compliance with the yearly 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 monthly crude oil throughput
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. 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.)
11. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
12. 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
13. Point 007: The owner or operator shall demonstrate compliance with Condition 10 using
EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section
II.A.5).
Periodic Testing Requirements
14. Point 007: On an annual basis, the operator shall complete a site specific extended gas
analysis of the natural gas that is routed to the flare to determine the heat content.
ADDITIONAL REQUIREMENTS
15. 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:
AIRS ID: 123/9914 Page 3 of 7
Carizzo Oil & Gas, Inc. Colorado Department of Public Health and Environment
Air Pollution Control Division
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For 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.
19. 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.
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.
AIRS ID: 123/9914 Page 4 of 7
Carizzo Oil & Gas, Inc. Colorado Department of Public Health and Environment
Air Pollution Control Division
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 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.
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:
Michael Cleary
Permit Engineer
Air Pollution Control Division
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Carrizo Oil & Gas Inc. Permit for: (1)
crude oil SEPARATOR at a synthetic minor
facility.
AIRS ID: 123/9914 Page 5 of 7
Carizzo Oil & Gas, Inc. Colorado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder:
1) 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.
2) 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.cd ohe.state.co.us/reo ulations/airrecis/100602aocccommonorovisionsreo.pdf.
3) 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(lb/yr)
Benzene 71432 A 1595 Yes 80
Toluene 108883 C 1008 Yes 50
006 Ethylbenzene 100414 C 114 No 6
Xylenes 1130207 C 210 No 10
n-Hexane 110543 C 9499 Yes 475
4) The emission levels contained in this permit are based on the following emission factors:
Point 006:
Weight
CAS# Pollutant Fraction Emission Factors Emission Factors Source
of Gas Uncontrolled Controlled
(%)
NOx --- 0.068 lb/MMBtu 0.068 lb/MMBtu AP-42
CO --- 0.37 lb/MMBtu 0.37 lb/MMBtu AP-42
Engineering
VOC 32.57 21376.00 lb/MMscf 1068.80 lb/MMscf
Calculation
Engineering
71432 Benzene 74.616 Ib/MMscf 3.7308 lb/MMscf
0.114 Calculation
Engineering
108883 Toluene 47.169 lb/MMscf 2.3585 lb/MMscf 0.072 Calculation
Engineering
100414 Ethylbenzene 5.323 lb/MMscf 0.2661 lb/MMscf
0.008 Calculation
Engineering
1330207 Xylenes 9.805 lb/MMscf 0.4902 lb/MMscf 0.015 Calculation
110543 n-hexane 444.316 lb/MMscf 22.2158 lb/MMscf Engineering
0.677 Calculation
AIRS ID: 123/9914 Page 6 of 7
Carizzo Oil & Gas, Inc. Colorado Department of Public Health and Environment
Air Pollution Control Division
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the March 27,
2012 analysis of a gas sample collected from the Vawter 11-41 well. The controlled VOC and
HAP emissions factors for point 005 are based on the flare control efficiency of 95%.
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: VOC, HAPs (nHexane)
NANSR Synthetic Minor Source: VOC
MACT HH 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: ee1r__moaccess.grg vv'
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60, Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A—Subpart Z
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX
8) 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:
http://www.cdphe.state.co.us/ap/oilciaspermittIng.html
AIRS ID: 123/9914 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: Michael Cleary Attainment Status
Control Engineer Chris Laplantej PM10 Attainment
Review Date: 05/15/2013 PM2.5 Attainment
Application Date: 02/12/2013 SOx Attainment
NOx Nonattainment
VOC Nonattainment
Facility Information CO Attainment
Permit No. 13WE1445
County# 123 Weld Potentially Located within EAC-determine attainment status of NOx
AIRS Facility# 9914
Point# 006
Facility Equipment ID Separator
Company Name: Carrizzo Oil and Gas Inc.
Source Name: Vawter 11-41-8-61
Source Location'. NENE Section 11. TBN R61 VV
SIC 1311
Elevation(feet) 4991
New Permit Modification APEN
X (CPI) (Issuance#) Required/Permit
Fxemnt
Transfer of APEN
Ownership Exempt/Permit
Exempt
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=Q*MW"Xx/C
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/Ib-mol)at 60F and 1 atm
Throughput(O) 21.4 MMscf/yr I 21208.3 scf/hr 1.82 MMscf/mo l
MW 24.873 Ib/Ib-mol 0.509 MMscf/d
mole% MW Ibx/lbmol mass fraction E lb/hr lb/yr tpy
Helium 0.01 4.0026 0.000 0.00002 Helium 0.0 23 0.01
CO2 266 44.01 1.171 0.04707 CO2 65.5 66033 33.02
N2 3 47 28.013 0.972 0.03908 N2 54.4 54830 27.41
methane 66 2407 16.041 10.626 0.42720 methane 594.6 599355 299.68
ethane 117832 30.063 3.542 0.14242 ethane 198.2 199813 99.91
propane 8 6073 44.092 3.7951 0.15258 propane 212.4 214069 107.03
isobutane 0 9114 58.118 0.5297 0.02130 isobutane 29.6 29878 14.94
n-butane 3 11/9 58.118 1.8121 0.07285 n-butane 101.4 102212 51.11
isopentane 0.6391 72.114 0.4609 0.01853 isopentane 25.8 25997 13.00
n-pentane 0 8674 72.114 0.6255 0.02515 n-pentane 35.0 35283 17.64
cyclopentane 0.0800 70.13 0.0561 0.00226 cyclopentane 3.1 3165 1.58
n-Hexane 01954 86.18 0.1684 0.00677 n-Hexane 9.4 9499 4.75
cyclohexane 0.0504 84.16 0.0424 0.00171 cyclohexane 2.4 2393 1.20
Other hexanes 0 3415 86.18 0.2943 0.01183 Other hexanes 16.5 16601 8.30
heptanes 01523 100.21 0.1526 0.00614 heptanes 8.5 8609 4.30
methylcyclohexane 00338 98.19 0.0332 0.00133 methylcyclohexane 1.9 1872 0.94
224-TMP 0.0002 114.23 0.0002 0.00001 224-TMP 0.0 13 0.01
Benzene 0.0362 78.12 0.0283 0.00114 Benzene 1.6 1595 0.80
Toluene 0.0194 92.15 0.0179 0.00072 Toluene 1.0 1008 0.50
Ethylbenzene 0 0019 106.17 0.0020 0.00008 Ethylbenzene 0.1 114 0.06
Xylenes 0.0035 106.17 0.0037 0.00015 Xylenes 0.2 210 0.10
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
IC8+Heavies I 0.06591 123 C001 0.0791 1 0.00318 IC8+Heavies 1 4.4 1 4461 2.23
99.2875 VOC mass fraction: 0.3257 Total VOC Emissions(Uncontrolled) 228.5
24.413 annual limit assuming 95%control 11.4
Notes monthly limit assuming 95%control(lb/mo.) 1940.6
Mole`0! MW.and mass fractions from Vawter 11-41 gas analysis with a sample date of 3;27/2012.
Emissions are based on 1008 hours of operation per year.(3.5 days/moo
I calculated the average MW et C84-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 25'Flare Stack
Serial Number TBD
Gas Heating Value 1334 Btu/scf
Throughput 28518.252 MMBtu/yr
Combustion emission factor source. AP-42. Chapter 13.5
0.068 lb NOX/MMBtu 0.37 lb CO/MMBtu
0.97 tpy NOX 5.28 tpy CO
Emissions Summary
0.97 tpy NOX 1939
Uncontrolled/PTE 5.28 tpy CO 10552
228.488 tpy VOC
Controlled 11.424 tpy VOC
Uncontrolled Scenario A Controlled
Total(lb/yr) Bin Reportable? Total(Ib/yr)
Benzene 1595 A Yes 80
Toluene 1008 C Yes 50
Ethylbenzene 114 C No 6
Xylenes 210 C No 10
n-hexane 9499 C Yes 475
224-TMP 13 C No 1
12438
Regulatory Applicability
AQCC Regulation 1
This source is subject to the opacity requirements for flares in Section II.A.5'No owner or operator
of a smokeless flare or other flare for the combustion of waste gases shall allow or cause
emissions into the atmosphere of any air pollutant which is in excess of 30%opacity
AQCC Regulation 2
Section I A applies to all emission sources."No person,wherever located,shall cause or allow the
emission of odorous air contaminants from any single source such as to result in detectable odors
which are measured in excess of the following limits. For areas used predominantly for residential
or commercial purposes it is a violation if odors are detected after the odorous air has been diluted
with seven(7)or more volumes of odor free air."
AQCC Regulation 3
An APEN is required for this source because uncontrolled VOC emissions
Part A. exceed one ton per year in a nonattainment area for ozone
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed two tons per year in a nonattainment area for ozone.
Part B. This source is subject to Section III D 2 iMnor Source RACT because it is
locates in a nonattainment area RACT for this source has been determined
to be the use of a flare to control emissions.
Is public comment Public Comment Required
required?
Facility Status
This facility is a synthetic minor source of VOC/HAP for Title V applicability.
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