colorado air permitting project...colorado air permitting project preliminary analysis - project...

Colorado Air Permitting Project

PRELIMINARY ANALYSIS - PROJECT SUMMARYProject DetailsReview Engineer: Carissa MoneyPackage #: 376100Received Date: 3/9/2018Review Start Date: 8/14/2018

Section 01 - Facility InformationCompany Name: Extraction Oil & Gas, Inc. Quadrant Section Township RangeCounty AIRS ID: 123 NENW 36 12N 62Plant AIRS ID: 9E67Facility Name:Physical Address/Location:County: Weld CountyType of Facility:What industry segment?Is this facility located in a NAAQS non-attainment area? NoIf yes, for what pollutant?

Section 02 - Emissions Units In Permit Application

AIRs Point # Emissions Source Type Equipment NameEmissions Control?

Permit # Issuance #Self Cert

Required?Action

Engineering Remarks

007 Separator Venting Sales Gas Venting Yes 18WE0271 1 YesPermit Initial

Issuance

008 Separator Venting LP Gas Venting Yes 18WE0272 1 YesPermit Initial

Issuance

Section 03 - Description of Project

Section 04 - Public Comment RequirementsIs Public Comment Required? YesIf yes, why?

NoIf yes, for what pollutants?If yes, attach a copy of Technical Services Unit modeling results summary.

Section 06 - Facility-Wide Stationary Source ClassificationIs this stationary source a true minor? NoIs this stationary source a synthetic minor? YesIf yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non-Attainment New Source Review (NANSR)

Is this stationary source a major source? NoIf yes, explain what programs and which pollutants hereSO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD)

Was a quantitative modeling analysis required?

Silverback 36-A Production Facility

NENW quadrant of Section 36, Township 12N, Range 62W

Exploration & Production Well PadOil & Natural Gas Production & Processing

Requesting Synthetic Minor Permit

Section 05 - Ambient Air Impact Analysis Requirements

The source is requesting to permit equipment at an existing E&P site. The site had an existing well and the source drilled a new well. The source is requesting individual permits for the LP separator venting, and sales gas venting, The source is also requesting individual permits for crude oil tanks, produced water tanks, and condensate loading (package 384364, permits 18WE0744, 18WE0745 and 18WE0746). There are also several eninges at the site covered by GP02.I confirmed this site is located outside (north) of the NAA boundary.

Carbon Monoxide (CO) Particulate Matter (PM) Ozone (NOx & VOC)


Title V Operating Permits (OP) Non-Attainment New Source Review (NANSR)

Separator Venting Emissions Inventory

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002 Separator Venting123 9E67 007

County Plant Point

Section 02 - Equipment Description Details

Detailed Emissions Unit Description:

Emission Control Device Description:95

Limited Process Parameter

Gas meter

Section 03 - Processing Rate Information for Emissions Estimates

Primary Emissions - SeparatorActual Throughput = 108.5 MMscf per year

Requested Permit Limit Throughput = 125.0 MMscf per year 11 MMscf per month

Potential to Emit (PTE) Throughput = 125 MMscf per year

Process Control (Recycling)Equipped with a VRU: No

Is VRU process equipment:

Secondary Emissions - Combustion Device(s) for Air Pollution Control

Separator Gas Heating Value: 1352 Btu/scf

Section 04 - Emissions Factors & Methodologies

Description

MW 23.993 lb/lb-mol Displacement Equation Ex = Q * MW * Xx / C

Weight %HeliumCO2 5.17N2 1.56methane 46.90ethane 12.76propane 17.43isobutane 2.29n-butane 7.90isopentane 1.76n-pentane 2.07cyclopentane 0.10n-Hexane 0.40cyclohexane 0.05Other hexanes 0.59heptanes 0.75methylcyclohexane 0.09224-TMP 0.00Benzene 0.04Toluene 0.06Ethylbenzene 0.01Xylenes 0.02C8+ Heavies 0.10

Total 100.00VOC Wt % 33.62

Emission FactorsUncontrolled Controlled(lb/MMscf) (lb/MMscf)

(Gas Throughput) (Gas Throughput)VOC 21281.6 1064.1

Benzene 22.790 1.1395Toluene 34.818 1.7409

Ethylbenzene 6.9637 0.3482Xylene 9.4959 0.4748

n-Hexane 251.96 12.598224 TMP 0.0000 0.0000

Uncontrolled Uncontrolled(lb/MMBtu) lb/MMscf(Waste Heat Combusted) (Gas Throughput)

PM10 0.0075 10.074PM2.5 0.0075 10.074

SOx 0.0006 0.795NOx 0.0680 91.939CO 0.3100 419.13 AP-42 Chapter 13.5 Industrial Flares (CO)

Extended gas analysisExtended gas analysisExtended gas analysisExtended gas analysisExtended gas analysis

Emission Factor Source

Source used expected throughput of sales gas and site-specific extended gas sample of sales gas collected 12/20/2016 at Silverback to estimate emissions.

AP-42 Table 1.4-2 (PM10/PM.2.5)AP-42 Table 1.4-2 (PM10/PM.2.5)

AP-42 Table 1.4-2 (SOx)AP-42 Chapter 13.5 Industrial Flares (NOx)

Pollutant

Primary Control Device

Separator Venting

Emission Factor SourcePollutant

Extended gas analysisExtended gas analysis

Yes, meter is currently installed and operational

Requested Monthly Throughput =

Volume of waste gas emitted per BBL of liquids throughput: scf/bbl

Facility AIRs ID:

Venting of sales gas from two high-pressure separators

Open elevated flare

Requested Overall VOC & HAP Control Efficiency %:

Natural Gas Vented


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Section 05 - Emissions Inventory

Potential to Emit Requested Monthly LimitsUncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month)

PM10 0.63 0.55 0.55 0.6 0.6 107PM2.5 0.63 0.55 0.55 0.6 0.6 107

SOx 0.05 0.04 0.04 0.0 0.05 8NOx 5.75 4.99 4.99 5.7 5.7 976VOC 1330.10 1154.23 57.71 1330.1 66.5 11297CO 26.20 22.73 22.73 26.2 26.2 4450

Potential to EmitUncontrolled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled

(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) tpy tpyBenzene 2849 2472 124 2849 142 1.42 0.07Toluene 4352 3777 189 4352 218 2.18 0.11

Ethylbenzene 870 755 38 870 44 0.44 0.02Xylene 1187 1030 52 1187 59 0.59 0.03

n-Hexane 31495 27330 1367 31495 1575 15.75 0.79224 TMP 0 0 0 0 0 0.00 0.00

Section 06 - Regulatory Summary Analysis

(See regulatory applicability worksheet for detailed analysis)

Section 07 - Initial and Periodic Sampling and Testing Requirements

Using Gas Throughput to Monitor Compliance

Yes

No

Yes

No

You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.Using Liquid Throughput to Monitor Compliance

NoThis sample should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample.

If no, the permit will contain an "Initial Compliance" testing requirement to collect a site-specific liquid sample and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.

Does the company request a control device efficiency greater than 95% for a flare or combustion device?If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling

If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.

-A "Periodic Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis.

Will the operator have a meter installed and operational upon startup of this point?If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.


Does the company use site specific emission factors based on a pressurized liquid sample (Sampled upstream of the equipment covered under this AIRs ID) and process simulation to estimate emissions?

Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year?

Hazardous Air PollutantsActual Emissions Requested Permit Limits

Regulation 3, Parts A, B Source requires a permitRegulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, GRegulation 7, Section XVII.B.2.e The control device for this separator is subject to Regulation 7, Section XVII.B.2.e

Requested Permit Limits

Does the company use site specific emission factors based on a gas sample to estimate emissions?This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample.

If no, the permit will contain an "Initial Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.

Criteria PollutantsActual Emissions Requested Permit Limits


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Section 08 - Technical Analysis Notes

Section 09 - Inventory SCC Coding and Emissions Factors

AIRS Point # Process # SCC Code Pollutant

Uncontrolled Emissions

Factor Control % Units007 01 3-10-001-60 Flares PM10 10.07 0 lb/MMSCF

PM2.5 10.07 0 lb/MMSCFSOx 0.80 0 lb/MMSCFNOx 91.94 0 lb/MMSCFVOC 21281.60 95 lb/MMSCFCO 419.13 0 lb/MMSCF

Benzene 22.79 95 lb/MMSCFToluene 34.82 95 lb/MMSCF

Ethylbenzene 6.96 95 lb/MMSCFXylene 9.50 95 lb/MMSCF

n-Hexane 251.96 95 lb/MMSCF224 TMP 0.00 95 lb/MMSCF

Separator Venting Regulatory Analysis Worksheet

Colorado Regulation 3 Parts A and B - APEN and Permit RequirementsSource is in the Attainment Area

ATTAINMENT1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Source Req 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Yes Source Req

Source requires a permitNON-ATTAINMENT1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?

You have indicated that source is in the Attainment AreaColorado Regulation 7, Section XVII1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes Source is su

Source is subject to Regulation 7, Section XVII.B.2, GSection XVII.B.2 – General Provisions for Air Pollution Control Equipment and Prevention of EmissionsSection XVII.G - Emissions Control

Alternative Emissions Control (Optional Section)a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? Yes The control

The control device for this separator is subject to Regulation 7, Section XVII.B.2.eSection XVII.B.2.e – Alternative emissions control equipment

Disclaimer

This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act,, its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as “recommend,” “may,” “should,” and “can,” is intended to describe APCD interpretations and recommendations. Mandatory terminology such as “must” and “required” are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.


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001 Separator Venting123 9E67 008

County Plant Point



Emission Control Device Description:95

Limited Process Parameter

Gas meter


Primary Emissions - SeparatorActual Throughput = 2.4 MMscf per year

Requested Permit Limit Throughput = 5.0 MMscf per year 0 MMscf per month

Potential to Emit (PTE) Throughput = 5 MMscf per year

Process Control (Recycling)Equipped with a VRU: No

Is VRU process equipment:

Secondary Emissions - Combustion Device(s) for Air Pollution Control

Separator Gas Heating Value: 2018 Btu/scf


Description

MW 36.4543 lb/lb-mol Displacement Equation Ex = Q * MW * Xx / C

Weight %Helium 0.07CO2 4.57N2 0.47methane 16.77ethane 10.97propane 27.52isobutane 4.42n-butane 15.68isopentane 4.06n-pentane 5.32cyclopentane 0.54n-Hexane 1.75cyclohexane 0.44Other hexanes 3.10heptanes 1.91methylcyclohexane 0.49224-TMP 0.001Benzene 0.23Toluene 0.23Ethylbenzene 0.03Xylenes 0.06C8+ Heavies 1.37

Total 100.00VOC Wt % 67.16

Emission FactorsUncontrolled Controlled(lb/MMscf) (lb/MMscf)

(Gas Throughput) (Gas Throughput)VOC 64597.3 3229.9

Benzene 219.69 10.984Toluene 217.67 10.883


n-Hexane 1684.3 84.215224 TMP 0.6733 0.0337

Uncontrolled Uncontrolled(lb/MMBtu) lb/MMscf(Waste Heat Combusted) (Gas Throughput)

PM10 0.0075 15.038PM2.5 0.0075 15.038

SOx 0.0006 1.187NOx 0.0680 137.24CO 0.3100 625.65

Volume of waste gas emitted per BBL of liquids throughput: scf/bbl

Source used modeled throughput of LP separator gas from Promax and site-specific extended gas sample of LP separator gas collected 2/8/2018 at Silverback 25N-20-3N to estimate emissions.

AP-42 Table 1.4-2 (PM10/PM.2.5)AP-42 Table 1.4-2 (PM10/PM.2.5)

AP-42 Table 1.4-2 (SOx)AP-42 Chapter 13.5 Industrial Flares (NOx)AP-42 Chapter 13.5 Industrial Flares (CO)

Yes, meter is currently installed and operational


Facility AIRs ID:

Venting of gas from two low-pressure separators

Enclosed flare


Natural Gas Vented

Extended gas analysis

Pollutant

Primary Control Device

Separator Venting


Extended gas analysisExtended gas analysis


Extended gas analysisExtended gas analysisExtended gas analysisExtended gas analysis


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PM10 0.04 0.02 0.02 0.0 0.0 6PM2.5 0.04 0.02 0.02 0.0 0.0 6

SOx 0.00 0.00 0.00 0.0 0.00 1NOx 0.34 0.16 0.16 0.3 0.3 58VOC 161.49 77.52 3.88 161.5 8.1 1372CO 1.56 0.75 0.75 1.6 1.6 266

Potential to EmitUncontrolled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled

(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) tpy tpyBenzene 1098 527 26 1098 55 0.55 0.03Toluene 1088 522 26 1088 54 0.54 0.03

Ethylbenzene 167 80 4 167 8 0.08 0.00Xylene 290 139 7 290 15 0.15 0.01

n-Hexane 8422 4042 202 8422 421 4.21 0.21224 TMP 3 2 0 3 0.2 0.00 0.00


(See regulatory applicability worksheet for detailed analysis)


Using Gas Throughput to Monitor Compliance

Yes

No

Yes

No

You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.Using Liquid Throughput to Monitor Compliance

No

Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year?


Regulation 3, Parts A, B

This sample should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample.

If no, the permit will contain an "Initial Compliance" testing requirement to collect a site-specific liquid sample and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.


If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.

-A "Periodic Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis.

Will the operator have a meter installed and operational upon startup of this point?If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.


Does the company use site specific emission factors based on a pressurized liquid sample (Sampled upstream of the equipment covered under this AIRs ID) and process simulation to estimate emissions?


Does the company use site specific emission factors based on a gas sample to estimate emissions?This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample.

If no, the permit will contain an "Initial Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.

Requested Permit Limits

Source requires a permitRegulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, GRegulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e


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Factor Control % Units008 01 3-10-001-60 Flares PM10 15.04 0 lb/MMSCF

PM2.5 15.04 0 lb/MMSCFSOx 1.19 0 lb/MMSCFNOx 137.24 0 lb/MMSCFVOC 64597.31 95 lb/MMSCFCO 625.65 0 lb/MMSCF

Benzene 219.69 95 lb/MMSCFToluene 217.67 95 lb/MMSCF

Ethylbenzene 33.38 95 lb/MMSCFXylene 58.10 95 lb/MMSCF

n-Hexane 1684.30 95 lb/MMSCF224 TMP 0.67 95 lb/MMSCF

Separator Venting Regulatory Analysis Worksheet


ATTAINMENT1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Source Req 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Yes Source Req

Source requires a permitNON-ATTAINMENT1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?

You have indicated that source is in the Attainment AreaColorado Regulation 7, Section XVII1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes Source is su

Source is subject to Regulation 7, Section XVII.B.2, GSection XVII.B.2 – General Provisions for Air Pollution Control Equipment and Prevention of EmissionsSection XVII.G - Emissions Control

Alternative Emissions Control (Optional Section)a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? No The control

The control device for this separator is not subject to Regulation 7, Section XVII.B.2.eSection XVII.B.2.e – Alternative emissions control equipment

Disclaimer



PRELIMINARY ANALYSIS - PROJECT SUMMARYProject DetailsReview Engineer: Carissa MoneyPackage #: 384364Received Date: 6/25/2018Review Start Date: 8/16/2018

Section 01 - Facility InformationCompany Name: Extraction Oil & Gas, Inc. Quadrant Section Township RangeCounty AIRS ID: 123 NENW 36 12N 62Plant AIRS ID: 9E67Facility Name:Physical Address/Location:County: Weld CountyType of Facility:What industry segment?Is this facility located in a NAAQS non-attainment area? NoIf yes, for what pollutant?

Section 02 - Emissions Units In Permit Application

AIRs Point # Emissions Source Type Equipment NameEmissions Control?

Permit # Issuance #Self Cert

Required?Action

Engineering Remarks

001 Liquid Loading Hydrocarbon loading No 18WE0746 1 YesPermit Initial

IssuanceConverting from GP07

002 Crude Oil Tank Crude Oil Storage Tanks Yes 18WE0744 1 YesPermit Initial


003 Produced Water Tank PW Tanks Yes 18WE0745 1 YesPermit Initial


Section 03 - Description of Project

Section 04 - Public Comment RequirementsIs Public Comment Required? YesIf yes, why?

NoIf yes, for what pollutants?If yes, attach a copy of Technical Services Unit modeling results summary.

Section 06 - Facility-Wide Stationary Source ClassificationIs this stationary source a true minor? NoIs this stationary source a synthetic minor? YesIf yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non-Attainment New Source Review (NANSR)

Is this stationary source a major source? No

Was a quantitative modeling analysis required?

Silverback 36-A Production Facility

NENW quadrant of Section 36, Township 12N, Range 62W

Exploration & Production Well PadOil & Natural Gas Production & Processing

Greater than 50 tons per year in an Attainment Area

Section 05 - Ambient Air Impact Analysis Requirements

The source is requesting to modify three existing points at an existing facility to convert from GP to individual permits. The source needs the individual permit limits instead of GP limits to maintain facility-wide emissions below 90 tpy and thus maintain GP02 coverage.Please note that for Point 002, the source had an individual permit (16WE0337) and then in March 2018, requested GP08 coverage. Prior to an engineer review of the application, the source canceled the GP08 request and requested to maintain an individual permit. Due to these application requests, the tanks received a new permit number instead of simply modifying the old permit.

Carbon Monoxide (CO) Particulate Matter (PM) Ozone (NOx & VOC)


If yes, explain what programs and which pollutants hereSO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non-Attainment New Source Review (NANSR)

Hydrocarbon Loadout Emissions Inventory

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001 Liquid Loading123 9E67 001

County Plant Point



Emission Control Device Description:

No

0.00

Primary Emissions - Hydrocarbon Loadout76,432 Barrels (bbl) per year Barrels (bbl) per year

101,353 Barrels (bbl) per year 8608 Barrels (bbl) per month101,353 Barrels (bbl) per year

Secondary Emissions - Combustion Device(s)

Btu/scf

79899 scf/yearActual heat content of waste gas routed to combustion device = 0 MMBTU per yearRequested heat content of waste gas routed to combustion device = 0 MMBTU per year

0 MMBTU per year

Section 04 - Emissions Factors & MethodologiesYesYes The state default emissions factors may be used to estimate emissions.

Loading Loss EquationL = 12.46*S*P*M/T

Factor Meaning Value UnitsS Saturation Factor 0.6P True Vapor Pressure psiaM Molecular Weight of Vapors lb/lb-molT Liquid Temperature RankineL Loading Losses 0 lb/1000 gallons

0 lb/bbl

Component Mass Fraction Emission Factor UnitsBenzene 0 lb/bblToluene 0 lb/bbl

Ethylbenzene 0 lb/bblXylene 0 lb/bbl

n-Hexane 0 lb/bbl224 TMP 0 lb/bbl

Emission FactorsUncontrolled Controlled

(lb/bbl) (lb/bbl)

(Volume Loaded)(Volume Loaded)

VOC 0.1040 0.1040Benzene 0.00018 0.0002Toluene 0.0000

Ethylbenzene 0.0000Xylene 0.0000

n-Hexane 0.0016 0.0016224 TMP 0.0000

Uncontrolled Uncontrolled(lb/MMBtu) (lb/bbl)

(waste heat combusted)(Volume Loaded)

PM10 0.00E+00PM2.5 0.00E+00

SOx 0.00E+00NOx 0.00E+00CO 0.00E+00

Pollutant

Crude Oil Loadout State E.F.Crude Oil Loadout State E.F.Crude Oil Loadout State E.F.

Pollutant

Control Device


Hydrocarbon Loadout


Crude Oil Loadout State E.F.

Crude Oil Loadout State E.F.Crude Oil Loadout State E.F.Crude Oil Loadout State E.F.

Source

Does the hydrocarbon liquid loading operation utilize submerged fill?Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted?

Source

Potential to Emit (PTE) Volume Loaded =

Heat content of waste gas =

Control Efficiency:

Actual Volume Loaded = Actual Volume Loaded While Emissions Controls Operating =Requested Permit Limit Throughput = Requested Monthly Throughput =

Volume of waste gas emitted per year =

Potential to Emit (PTE) heat content of waste gas routed to combustion device =

Does the company use the state default emissions factors to estimate emissions?



Facility AIRs ID:

Hydrocarbon loadout to tank trucks

None

Is this loadout controlled?Collection Efficiency:

Hydrocarbon Loadout Emissions Inventory

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Potential to Emit Requested Monthly LimitsUncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled

(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month)PM10 0.00 0.00 0.00 0.00 0.00 0PM2.5 0.00 0.00 0.00 0.00 0.00 0

SOx 0.00 0.00 0.00 0.00 0.00 0NOx 0.00 0.00 0.00 0.00 0.00 0VOC 5.27 3.97 3.97 5.3 5.3 895CO 0.00 0.00 0.00 0.00 0.00 0

Potential to EmitUncontrolled Uncontrolled Controlled Uncontrolled Controlled

(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year)Benzene 18 14 14 18 18Toluene 0 0 0 0 0

Ethylbenzene 0 0 0 0 0Xylene 0 0 0 0 0

n-Hexane 162 122 122 162 162224 TMP 0 0 0 0 0


RACT - Regulation 3, Part B, Section III.D.2.a(See regulatory applicability worksheet for detailed analysis)

Section 07 - Initial and Periodic Sampling and Testing RequirementsYou have indicated above the source is not controlled. The following question does not require an answer.

If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling





Factor Control % Units001 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) PM10 0.00 0 lb/1,000 gallons transferred

PM2.5 0.00 0 lb/1,000 gallons transferredSOx 0.00 0 lb/1,000 gallons transferredNOx 0.00 0 lb/1,000 gallons transferredVOC 2.5 0 lb/1,000 gallons transferredCO 0.00 0 lb/1,000 gallons transferred

Benzene 0.00 0 lb/1,000 gallons transferredToluene 0.00 0 lb/1,000 gallons transferred

Ethylbenzene 0.00 0 lb/1,000 gallons transferredXylene 0.00 0 lb/1,000 gallons transferred

n-Hexane 0.04 0 lb/1,000 gallons transferred224 TMP 0.00 0 lb/1,000 gallons transferred

Regulation 3, Parts A, B Source requires a permit

Site is in attainment and not subject to RACT

Does the company request a control device efficiency greater than 95% for a flare or combustion device?



Hydrocarbon Loadout Regulatory Analysis Worksheet


ATTAINMENT1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Go to next q2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.l)? Yes Go to the n

3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? No Go to next q4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? No Go to next q5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? No Go to next q

6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Yes The loadou Source requires a permit

NON-ATTAINMENT1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.l)?

3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?

6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?You have indicated that source is in the Attainment Area

7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)?Site is in attainment and not subject to RACT

Disclaimer


Crude Oil Storage Tank(s) Emissions Inventory

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002 Crude Oil Tank123 9E67 002

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95


Primary Emissions - Storage Tank(s)Actual Throughput = 84,461 Barrels (bbl) per year Actual Crude Oil Throughput While Emissions Controls Operating = 84,461Requested Permit Limit Throughput = 101,353 Barrels (bbl) per year 8608 Barrels (bbl) per month

121,624 Barrels (bbl) per year


3535 Btu/scf

23 scf/bblActual heat content of waste gas routed to combustion device = 6,867 MMBTU per yearRequested heat content of waste gas routed to combustion device = 8,241 MMBTU per year

9,889 MMBTU per year


Yes


(lb/bbl) (lb/bbl)(Crude Oil

Throughput)(Crude Oil

Throughput)VOC 1.6269 0.0813

Benzene 0.0030 0.0001Toluene 0.0021 0.0001


n-Hexane 0.0196 0.0010224 TMP 0.0001 0.00001

Uncontrolled Uncontrolled(lb/MMBtu) (lb/bbl)(waste heat combusted)

(Crude Oil Throughput)

PM10 0.0075 0.0006PM2.5 0.0075 0.0006NOx 0.0680 0.0055CO 0.3100 0.0252



VOC 98.9 68.7 3.4 82.4 4.1 700PM10 0.0 0.0 0.0 0.0 0.0 5PM2.5 0.0 0.0 0.0 0.0 0.0 5NOx 0.3 0.2 0.2 0.3 0.3 48CO 1.5 1.1 1.1 1.3 1.3 217




n-Hexane 2383 1655 83 1986 99224 TMP 16 11 1 14 1


Regulation 7, Section XVII.B, C.1, C.3 Regulation 7, Section XVII.C.2Regulation 6, Part A, NSPS Subpart KbRegulation 6, Part A, NSPS Subpart OOOORegulation 8, Part E, MACT Subpart HH(See regulatory applicability worksheet for detailed analysis)

Potential to Emit (PTE) Throughput =

Facility AIRs ID:

Four 500 bbl fixed roof crude oil storage vessels connected via liquid manifold

Enclosed flare



Site Specific E.F. (includes flash)Site Specific E.F. (includes flash)

Heat content of waste gas =Volume of waste gas emitted per BBL of liquids produced =


Will this storage tank emit flash emissions?

Crude Oil Tank


Site Specific E.F. (includes flash)Site Specific E.F. (includes flash)Site Specific E.F. (includes flash)Site Specific E.F. (includes flash)Site Specific E.F. (includes flash)

Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3

Pollutant

Control Device


AP-42 Table 1.4-2 (PM10/PM.2.5)

AP-42 Chapter 13.5 Industrial Flares (NOx)AP-42 Chapter 13.5 Industrial Flares (CO)


AP-42 Table 1.4-2 (PM10/PM.2.5)


Regulation 3, Parts A,B Source requires a permit

Storage tank is subject to Regulation 7, Section XVII.C.2Storage Tank is not subject to NSPS Kb

Storage Tank is not subject to MACT HHStorage Tank is not subject to NSPS OOOO

Crude Oil Storage Tank(s) Emissions Inventory

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No

If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03

Yes

YesIf no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.

NoIf yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling





Factor Control % Units002 01 PM10 0.01 0 lb/1,000 gallons crude oil throughput

PM2.5 0.01 0 lb/1,000 gallons crude oil throughputNOx 0.13 0 lb/1,000 gallons crude oil throughputVOC 38.7 95 lb/1,000 gallons crude oil throughputCO 0.60 0 lb/1,000 gallons crude oil throughput

Benzene 0.07 95 lb/1,000 gallons crude oil throughputToluene 0.05 95 lb/1,000 gallons crude oil throughput

Ethylbenzene 0.01 95 lb/1,000 gallons crude oil throughputXylene 0.01 95 lb/1,000 gallons crude oil throughput

n-Hexane 0.47 95 lb/1,000 gallons crude oil throughput224 TMP 0.00 95 lb/1,000 gallons crude oil throughput

Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year?

Does the company use a site specific emissions factor to estimate emissions?

If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the facility being permitted?


The tanks are not subject to NSPS OOOOa because the enforceable control emissions are less than 6 tpy.

These tanks were permitted under 16WE0337. In March 2018, the source requested to cancel the individual permit and be covered under GP08. The division logged in the March 2018 application but prior to the application being reviewed, the source submitted a revised application June 2018 to maintain an individual permit for the tanks. The facility-wide VOC emissions are at 89 tpy; thus, for the source to maintain GP02 coverage, the tanks must be covered by an individual permit limit.Due to the multiple applications, the tanks will get a new permit number instead of simply a modification to the existing permit number.

Crude Oil Storage Tank Regulatory Analysis Worksheet


ATTAINMENT1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Source Req 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? No Go to next q2a. If answer to #2 is yes, is the crude oil throughput less than 40,000 gallons per year? NA3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Yes Source Req

Source requires a permitNON-ATTAINMENT1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a. If answer to #2 is yes, is the crude oil throughput less than 40,000 gallons per year?3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?

You have indicated that source is in the Attainment Area

Colorado Regulation 7, Section XVII1. Is this tank located at a transmission/storage facility? No Continue - Y 2. Is this crude oil storage tank1 located at an oil and gas exploration and production operation , well production facility2, natural gas compressor station3 or natural gas processing plant? Yes Continue - Y 3. Is this crude oil storage tank a fixed roof storage tank? Yes Go to the n 4. Are uncontrolled actual emissions4 of this storage tank equal to or greater than 6 tons per year VOC? Yes Source is su

Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3Section XVII.B – General Provisions for Air Pollution Control Equipment and Prevention of EmissionsSection XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements

5. Does the crude oil storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. No Source is su Storage tank is subject to Regulation 7, Section XVII.C.2

Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment

40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) [~472 BBLs]? Yes Go to the n 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? Yes Storage Tan

a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 [~10,000 BBL] used for petroleum1 or condensate stored, processed, or treated prior to custody transfer2 as defined in 60.111b?3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984?4. Does the tank meet the definition of “storage vessel”3 in 60.111b? 5. Does the storage vessel store a “volatile organic liquid (VOL)”5 as defined in 60.111b?6. Does the storage vessel meet any one of the following additional exemptions:

a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa [~29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; orb. The design capacity is greater than or equal to 151 m3 [~950 BBL] and stores a liquid with a maximum true vapor pressure6 less than 3.5 kPa (60.110b(b))?; orc. The design capacity is greater than or equal to 75 M3 [~472 BBL] but less than 151 m3 [~950 BBL] and stores a liquid with a maximum true vapor pressure6 less than 15.0 kPa(60.110b(b))?

Storage Tank is not subject to NSPS KbSubpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures§60.115b - Reporting and Recordkeeping Requirements§60.116b - Monitoring of Operations

40 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution

1. Yes Continue - Y 2. No Storage Tan 3. Are potential VOC emissions2 from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this crude oil storage vessel meet the definition of “storage vessel”1 per 60.5430?

Storage Tank is not subject to NSPS OOOOSubpart A, General Provisions per §60.5425 Table 3§60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures§60.5395(g) - Notification, Reporting and Recordkeeping Requirements§60.5416(c) - Cover and Closed Vent System Monitoring Requirements§60.5417 - Control Device Monitoring Requirements

40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: Yes Continue - Y

a. A facility that processes, upgrades or stores hydrocarbon liquids2 (63.760(a)(2)); OR

b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user3 (63.760(a)(3))?1. Is the tank located at a facility that is major1 for HAPs? No Storage Tan 3. Does the tank meet the definition of “storage vessel”4 in 63.761?4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"5 per 63.761?5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO?

Storage Tank is not subject to MACT HHSubpart A, General provisions per §63.764 (a) Table 2§63.766 - Emissions Control Standards§63.773 - Monitoring§63.774 - Recordkeeping§63.775 - Reporting

RACT ReviewRACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area. If the tank meets both criteria, then review RACT requirements.

Disclaimer


Is this crude oil storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? Was this crude oil storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?

[Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year]

Produced Water Storage Tank(s) Emissions Inventory

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Primary Emissions - Storage Tank(s)Actual Produced Water Throughput = 228,331 Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = 228,331Requested Permit Limit Throughput = 273,997 Barrels (bbl) per year 23271 Barrels (bbl) per month

328,796 Barrels (bbl) per year


1496 Btu/scf

36 scf/bblActual heat content of waste gas routed to combustion device = 12,297 MMBTU per yearRequested heat content of waste gas routed to combustion device = 14,756 MMBTU per year

17,708 MMBTU per year


Yes


(lb/bbl) (lb/bbl)

(Produced Water Throughput)

(Produced Water

Throughput)VOC 0.262 0.013

Benzene 0.0070 0.0004Toluene 0.0000

Ethylbenzene 0.0000Xylene 0.0000

n-Hexane 0.0220 0.0011224 TMP 0.0000

Uncontrolled Uncontrolled(lb/MMBtu) (lb/bbl)

(waste heat combusted)

(Produced Water

Throughput)PM10 0.0075 0.0004PM2.5 0.0075 0.0004

NOx 0.0680 0.0037CO 0.3100 0.0167



VOC 43.1 29.9 1.5 35.9 1.8 305PM10 0.1 0.0 0.0 0.1 0.1 9PM2.5 0.1 0.0 0.0 0.1 0.1 9

NOx 0.6 0.4 0.4 0.5 0.5 85CO 2.7 1.9 1.9 2.3 2.3 389




n-Hexane 7234 5023 251 6028 301224 TMP 0 0 0 0 0


Regulation 7, Section XVII.B, C.1, C.3 Regulation 7, Section XVII.C.2Regulation 6, Part A, NSPS Subpart OOOO(See regulatory applicability worksheet for detailed analysis)

Produced Water State E.F. (includes flash) - Front Produced Water State E.F. (includes flash) - Front

Potential to Emit (PTE) Produced Water Throughput =

Facility AIRs ID:

One 500 bbl fixed roof produced water storage vessel

Enclosed flare



Heat content of waste gas =Volume of waste gas emitted per BBL of liquids produced =


Will this storage tank emit flash emissions?

Produced Water Tank


Produced Water State E.F. (includes flash) - Front Produced Water State E.F. (includes flash) - Front Produced Water State E.F. (includes flash) - Front


Produced Water State E.F. (includes flash) - Front

Pollutant

Control Device


Produced Water State E.F. (includes flash) - Front

AP-42 Table 1.4-2 (PM10/PM.2.5)AP-42 Table 1.4-2 (PM10/PM.2.5)AP-42 Chapter 13.5 Industrial Flares (NOx)AP-42 Chapter 13.5 Industrial Flares (CO)


Regulation 3, Parts A, B Source requires a permitStorage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3Storage tank is subject to Regulation 7, Section XVII.C.2Storage Tank is not subject to NSPS OOOO

Produced Water Storage Tank(s) Emissions Inventory

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No

If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing.

NoIf yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling





Factor Control % Units003 01 PM10 0.01 0 lb/1,000 gallons liquid throughput

PM2.5 0.01 0 lb/1,000 gallons liquid throughputNOx 0.09 0 lb/1,000 gallons liquid throughputVOC 6.2 95 lb/1,000 gallons liquid throughputCO 0.40 0 lb/1,000 gallons liquid throughput

Benzene 0.17 95 lb/1,000 gallons liquid throughputToluene 0.00 95 lb/1,000 gallons liquid throughput

Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughputXylene 0.00 95 lb/1,000 gallons liquid throughput

n-Hexane 0.52 95 lb/1,000 gallons liquid throughput224 TMP 0.00 95 lb/1,000 gallons liquid throughput

If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site-specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample.


4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses

Does the company use a site specific emissions factor to estimate emissions?

The tanks are not subject to NSPS OOOOa because the enforceable control emissions are less than 6 tpy.

Produced Water Storage Tank Regulatory Analysis Worksheet


ATTAINMENT1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Source Req 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) No Go to next q3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Yes Source Req

Source requires a permitNON-ATTAINMENT1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M)3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?

You have indicated that source is in the Attainment Area

Colorado Regulation 7, Section XVII1. Is this tank located at a transmission/storage facility? No Continue - Y 2. Is this produced water storage tank1 located at an oil and gas exploration and production operation , well production facility2, natural gas compressor station3 or natural gas processing plant? Yes Continue - Y 3. Is this produced water storage tank a fixed roof storage tank? Yes Go to the n 4. Are uncontrolled actual emissions4 of this storage tank equal to or greater than 6 tons per year VOC? Yes Source is su

Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3Section XVII.B – General Provisions for Air Pollution Control Equipment and Prevention of EmissionsSection XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements

5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. No Source is su Storage tank is subject to Regulation 7, Section XVII.C.2

Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment

40 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution

1. Yes Continue - Y 2. No Storage Tan 3. Are potential VOC emissions2 from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this produced water storage vessel meet the definition of “storage vessel”1 per 60.5430?

Storage Tank is not subject to NSPS OOOOSubpart A, General Provisions per §60.5425 Table 3§60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures§60.5395(g) - Notification, Reporting and Recordkeeping Requirements§60.5416(c) - Cover and Closed Vent System Monitoring Requirements§60.5417 - Control Device Monitoring Requirements

RACT ReviewRACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area. If the tank meets both criteria, then review RACT requirements.

Disclaimer


Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb.

Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?

[Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year]

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