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Home My WebLink About20140443.tiff STATE OF COLORADO John W.Hickenlooper,Governor Larry W -olk,MD,MSPH w cot_ Executive Director and Chief Medical Officer #e/t Ti f Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr.S. Laboratory Services Division +/876 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&Recorder 1402 N 17th Ave Greeley, CO 80631 February 10, 2014 Dear Sir or Madam: On February 13, 2014, the Air Pollution Control Division will publish a public notice for Chesapeake Operating Inc.—Varra 12-9-66-IH, 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, RECEIVED FEB 13 2014 WELD COUNTY Clara Gonzales COMMISSIONERS Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure L� ft_ , ft-i_ PLC 2014-0443 9`-I - .3I`J 9 .0 t I STATE OF COLORADO John W.Hickenlooper,Governor np co Larry Wolk, MD,MSPH �4. o? Executive Director and Chief Medical Officer tie vo Dedicated to protecting and improving the health and environment of the people of Colorado .- 1 � 4300 Cherry Creek Dr. S. Laboratory Services Division .1876 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: Chesapeake Operating Inc. —Varra 12-9-66-1H—Weld County Released To: The Greeley Tribune On: February 10, 2014 Published: February 13, 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: Chesapeake Operating Inc. Facility: Varra 12-9-66-1H Oil and natural gas exploration and production facility Section 12, T9N, R66W 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): • 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 12WE1864 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 conceming 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-B I Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us F COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 4�.d AIR POLLUTION CONTROL DIVISION TELEPHONE: (303)692-3150 "/876" CONSTRUCTION PERMIT PERMIT NO: 12WE1864 E1 064 Issuance 1 DATE ISSUED: May 8, 2013 ISSUED TO: Chesapeake Operating, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as Varra 12-6-66-1 H, located in Section 12, Township 9 North, Range 66 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Plant flare used to control gas stream off of the 3-phase separator. FLARE2 002 Flare has a minimum combustion efficiency of 95%. The flare is enclosed. FUG1 003 Equipment leaks (fugitive VOCs) from an oil and gas facility. 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 www cdphe.state.co.us/ap/downloadforrns html. Failure to notify the APCD of startup of the permitted source is a violation of AQCC Regulation No. 3, Part B, Section I II.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 AIRS ID: 123/9906 Page 1 of 10 Condensate Tank Version 2009-1 D blic Health and Environment Air Pollution Control Division such constructionDolor i a ed co ce as set forth in the permit application associated with this permit; (H)discontinues construction for a period of eighteen months or more; (Hi) 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 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. Point 002: 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 VOC CO Emission Type NO, FLARE2 002 1.1 5.8 5.9 Point FUG1 003 --- 2.7 --- Fugitive 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. Point 003: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas analysis, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. AIRS ID: 123/9906 Page 2 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Annual records of the actual 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 FLARE2 002 Natural gas flaring 4035 MSCF/yr 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) 14. Point 003: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). The requirements of condition number 14 below were determined to be RACT for this source. 15. Point 003: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology(RACT)for the pollutants for which the area is nonattainment or attainment/maintenance(Reference: Regulation No. 3, Part B, III.D.2.a). This requirement to apply RACT shall be satisfied by installing/implementing the following emission controls: a. Directed Inspection & Maintenance as described below shall satisfy the requirement to apply RACT. (i) For leak screening, auditory/visual/olfactory inspection (AVO)will be performed on a quarterly basis. AIRS ID: 123/9906 Page 3 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division (ii) For each leak found in the AVO inspection, a gas detector shall be used to determine the size of the leak. The gas detector shall be regularly calibrated. Component leaks greater than 10,000 ppm shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. For such component leaks that require a shutdown to be repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered. (iii) For repair, valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. (iv) Repaired components shall be re-screened to determine if the leak is repaired. (v) The following records shall be maintained for a period of two years: • The name of the site screened via AVO inspection and the name of the inspector. • Components evaluated with the gas detector. • Repair methods applied. • Dates of the AVO screenings, gas detector calibrations, attempted repairs,successful repairs, repair delays,and post-repair screenings. (vi) Leaks shall be repaired as soon as practicable, but no later than 15 calendar days after detection, unless it is technically or operationally infeasible to make the repair within 15 calendar days. Records documenting the rationale shall be maintained if it is technically or operationally infeasible to make the repair within 15 calendar days. OPERATING & MAINTENANCE REQUIREMENTS 16. 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 17. Point 002: The operator shall complete an initial site specific extended gas analysis of the natural gas produced at this site that is routed to the enclosed flare 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. 18. Point 002: 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). 19. Point 003: Within one hundred and eighty days(180)after issuance of permit,the permittee shall complete the initial extended gas analysis of gas samples and extended natural gas AIRS ID: 123/9906 Page 4 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division liquids analysis of liquids that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP)that may be released as fugitive emissions. This extended gas and liquids analyses shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the gas and liquids analyses and emission calculations to the Division as part of the self- certification process to ensure compliance with emissions limits. 20. Point 003: Within one hundred and eighty days(180)after issuance of permit,the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service". The operator shall submit the results to the Division as part of the self-certification process to ensure compliance with emissions limits. Periodic Testing Requirements 21. Point 002: The owner or operator shall sample the gas routed to the flare to determine the heat content on an annual basis. 22. Point 003: On an annual basis, the owner or operator shall complete an extended gas analysis of produced gas that is representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP)that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 23. 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 volatile organic compounds (VOC) and nitrogen oxides sources(NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NOx 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 AIRS ID: 123/9906 Page 5 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division e. No later than 30 days before the existing APEN expires. 24. 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 25. 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. 26. 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. 27. 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. 28. 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. 29. 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. 30. 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. AIRS ID: 123/9906 Page 6 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division 31. 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: / + � /V //./ v Michael Cleary Permit Engineer Air Pollution Control Division Permit History Issuance Date Description Issuance 1 This Issuance Permit for: (1) enclosed flare and associated fugitives. New synthetic minor source facility. AIRS ID: 123/9906 Page 7 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 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.cdphe.state.co.us/requ lations/a irregs/100102agcccommonprovisionsreq.pdf. 4) The emission levels contained in this permit are based on the following emission factors: Point 002: Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source NOx 0.068 lb/MMBtu --- AP-42, Table 13.5-1 CO 0.37 lb/MMBtu --- AP-42, Table 13.5-1 VOC Engineering 35.160 lb/MCF 1.758 lb/MCF Calculation Note: The controlled emissions factors for point 002 are based on the flare control efficiency of 95%. Point 003: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors Flanges 55 --- 6 Open-Ended Lines Pump Seals 10 --- 3 Valves 50 --- 5 Other 13 --- 3 VOC Content(wt%) 47.69% 100% 100% 100% Benzene Content(wt%) Toluene Content(wt%) Ethylbenzene(wt%) --- Xylenes Content(wt%) n-hexane Content(wt%) `Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): AIRS ID: 123/9906 Page 8 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division Water/Oil Component Gas Service Heavy Oil Light Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA-453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas and liquids analyses. 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 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: hilp:`ectr.L'po8CCess.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 AIRS ID: 123/9906 Page 9 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division MACT 63.6580-63.8830 Subpart ZZZZ-Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXX( 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.cdphastate.co.ustapioilqaspermittinq.html • • AIRS ID: 123/9906 Page 10 of 10 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Chesapeake Operating, Inc. Permit Number: 12WE1864 Source Location: 512, T9N, R66W,Weld County (Non-Attainment) Point 002: Plant flare with a minimum combustion efficiency of 95%. Equipment Description Point 003: Fugitive emissions AIRS ID: 123-9906 Date: 05/14/2013 Review Engineer: Michael Cleary Control Engineer: Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt "If tank is a true minor source at a true minor facility, it shall be granted "Final Approval" Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? Yes X No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no" to any of the above, Initial estimates for flare did not appear to include the when did you mail an Information Request separator emissions. letter to the source? 12/24/2012: Received new calculations on 12/24/12 for VOC emissions (including separator emissions) via S.Chousy On what date was this application complete? August 15, 2012 Section 4—Source Description AIRS Point Equipment Description Plant flare used to control gas stream off of the 3-phase separator. Flare has a 002 minimum combustion efficiency of 95%. The flare is enclosed. 003 Fugitive emission leaks. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria Yes No pollutant? If"yes", for what pollutant? PMio CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? Page 1 If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM10 CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region? (Note: If"yes"the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Section 5—Emission Estimate Information AIRS Point Emission Factor Source 002 AP-42,Table 13.5-1 for combustion emissions; mass balance for 3-phase separator 003 EPA-453/R-95-017,Table 2-4 Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTEI AIRS Point Process Consumption/Throughput/Production 002 Process gas: 4035 MCF/yr Pilot Light: 3.0 MMbtu/yr Equipment Type Gas Heavy Oil (or Light Oil (or Water/Oil Heavy Liquid) Light Liquid) Connectors --- --- --- --- 003 Flanges 55 --- 6 --- Open-Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- Basis for Actual Emissions Reported During this APEN Filing(Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 002 Process gas: 4035 MCF/yr . Pilot Light: 3.0 MMbtu/yr Equipment Type Gas Heavy Oil Light Oil Water/Oil (or Heavy (or Light Liquid) Liquid) Connectors --- --- --- --- 003 Flanges 55 --- 6 --- Open-Ended --- --- --- --- Lines Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 002 Process gas: 4035 MCF/yr Pilot Light: 3.0 MMbtu/yr Equipment Type Gas Heavy Oil(or Light Oil (or Water/Oil Heavy Liquid) Light Liquid) Connectors --- --- --- --- 003 Flanges 55 --- 6 --- Open-Ended Lines --- --- --- --- Pump Seals 10 --- 3 --- Valves 50 --- 5 --- Other 13 --- 3 --- Does this facility use control devices? X Yes No Page 2 AIRS Point Process Control Device Description % Reduction Granted 002 01 Flare 95 Point NO, VOC CO Single HAP Total HAP 001 2.0 0.2 1.1 0'08 0.1 (formaldehyde) 002 1.1 70.9 5.9 --- --- PTE: 003 --- 2.7 --- --- --- 004 --- 93.0 --- 1.4 (hexane) 1.6 005 --- 9.2 --- 0.78 (hexane) 1.0 TOTAL: 3.1 176.0 7.0 001 2.0 0.2 1.1 0.08 0.1 (formaldehyde) Uncontrolled point source emission rate: 002 1.1 5.8 5.9 003 --- 2.7 --- --- --- 004 --- 77.5 --- 1.2 (hexane) 1.3 005 --- 9.2 --- 0.78 (hexane) 1.0 001 2.0 0.2 1.1 0'08 0.1 (formaldehyde) 002 1.1 5.8 5.9 --- --- Permitted point source emission rate: 003 --- 2.7 --- --- --- 004 --- 39.0 --- 0.06 (hexane) 0.1 005 --- 10.0 --- 0.04 (hexane) 0.1 TOTAL PERMITTED 3.1 57.7 7.0 (TPY) Section 7—Non-Criteria./ Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions Ibl r (Ib/yr) reportable? Rate( Y) Note: Regulation 3, Part A, Section ll.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory X Yes No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 002 01 VOC, State only requirement Site-specific gas HAPS analysis 003 01 VOC, State only requirement Site-specific gas HAPS analysis VOC, Hard 003 01 HAPS State only requirement count component Section 9—Source Classification Is this a new previously un-permitted source? Yes No Page 3 Point 002: Flare X Point 003: Fugitives X What is this point classification? True Minor Synthetic Minor Major Point 002: Flare X Point 003: Fugitives X What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V PSD X NA NSR X MACT Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? Minor Synthetic Major Minor Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes",for which pollutants?Why? For Reg. 3, Part B, III.C.1.a (controlled emissions increase>25/50 X Yes No tpy)? For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? NOx emissions are less than 40 TPY. AIRS Point Section 12—Regulatory Review Regulation 1 -Particulate. Smoke. Carbon Monoxide and Sulfur Dioxide Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20%opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A(July, 002, 003 1992)) in all subsections of Section II.A and B of this regulation. Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases 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. _Regulation 2'-Odor Section I.A-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 002, 003 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. Page 4 Regulation 3-APENs, Construction Permits, Operating Permits, PSD Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission point in a non-attainment area with uncontrolled actual emissions 002, 003 of one ton per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is non-attainment. (Applicant is required to file an APEN since emissions from production exceed 1 ton per year VOC) Part B—Construction Permit Exemptions 002, 003 Applicant is required to file a permit since uncontrolled VOC emissions are greater than the 2.0 TPY threshold(Reg. 3, Part B, Section Il.D.2.a) Regulation 6 - New Source Performance Standards 002 None NSPS KKK: Equipment Leaks of VOC from onshore natural gas processing plants. Affected facilities at onshore natural gas facilities (any processing site engaged in the extraction of natural gas liquids from field gas, fractionation of mixed natural gas 003 liquids (NGLs) or both). Is this source at a"natural gas processing plant?" No Is this source subject to NSPS KKK? No WHY? Facility not defined as a natural gas processing plant, therefore, does not meet the criteria of NSPS KKK. Regulation 7—Volatile Organic Compounds 002 None Section XII.G: If facility is a natural gas processing plant located in non-attainment 003 area,then subject to Section XII.G. Facility is not a natural gas processing plant, therefore, not subject to Section XII.G. Regulation 8—Hazardous Air Pollutants 002 None MACT HH: If facility is MAJOR source for HAP (summation of HAPS of dehydrators and fugitives), then fugitive emissions are subject to MACT HH. 003 Is this facility considered MAJOR for HAPS? No Is this source subject to MACT HH? No WHY? Facility is area source for MACT HH, therefore, only TEG dehydrators are subject to MACT HH. This facility has no TEG dehydrators, so facility not subject to MACT HH, Section 13—Aerometric Information Retrieval System Coding Information Emission Pollutant/ Fugitive Emission Factor Control Point Process Process Description Factor CAS# (Y/N) Source (%) 35.160 Engineering Ib/MCF V0C No Calculation0.068 AP-42, 95 01 Flare NA Ib/MMBtu N0x No Table 13.5-1 002 0.37 AP-42, lb/MMBtu CO No Table 13.5-1 NA SCC 31000205-Flares 01 Fugitive V0C Leak VOC Yes EPA-453/R-95-017, NA 003 Emissions Table 2-4 SCC 31000220: All Equip. Leak Fugitives (Valves, flanges, connections,seals, drains) Page 5 Section 14—Miscellaneous Application Notes AIRS Point 002 Flare Permit issued because emissions are greater 2 TPY CO (Reg. 3, Part B, Section II.D.2.e) VOC, NOx and CO (from AP-42, Chapter 13, Table 13.5-1 (NOx= 0.068 Ib/mmbtu; CO = 0.37 Ib/mmbtu; VOC = 0.14 Ib/mmbtu) Original VOC calculations did not include emissions from the separator. Received new calculations on 12/24/12 and generated a new VOC emission factor: VOC = (70.935 TPY*2000)/4035 Ib/MCF = 35.16 Ib/MCF AIRS Point 003 Fugitive emissions A permit will be issued because the uncontrolled VOC emissions are greater than 1 TPY (APEN threshold)and TOTAL FACILITY is greater than 2 TPY (permit threshold). Operator did not include associated gas analysis with the application. A condition requiring initial sampling will be included. I calculated fugitives based on their APEN. Their calculation sheet showed that they used the same emission factor for GAS-compressor seals and GAS-relief valves(even though compressor seals are on the APEN as GAS-pump seals and the relief valves are listed as GAS-Other). Operator used the emission factor for GAS-Other for all sources. I calculated it both ways, and did not get a big difference in emissions, (2.48 typ vs. 2.79 tpy) The Operator's calculation of 2.73 is on the conservative end of this range, so I have accepted this as a reasonable estimate. RACT was not included in the application. Mr. Ingerson with Chesapeake had agreed to the Division's standard fugitive for other, similar facilities. Page 6 N pL M _ N o f ow EF �!w` �0 0 O c O �f o' _ - -rv'�dn� '1=- �_ cn a :. "�,� E Z o o n a G 2 w v, s E vc°. ". c c\�c n L a) C ._ < s v � c o rn• .9 3 e 15.,. % v U > _ .. — .. es ' c �' c1 G-. �' o v r G e = ...2, x " - m e R c _ c `e o ----' V c G. c c� :d y E �, E ` E ,; i P R - sP z a. 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