HomeMy WebLinkAbout20210199.tiffCOLORADO
Department of public
Health S Environment
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
January 11, 2021
Dear Sir or Madam:
RECEIVED
JAN 15 2021
WELD COUNTY
COMMISSIONERS
On January 12, 2021, the Air Pollution Control Division will begin a 30 -day public notice period for
Extraction Oil Et Gas, Inc. - Trott Production Facility. 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 beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive 5., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared PoLis, Governor I Jill Hunsaker Ryan, MPH, Executive Director
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2021-0199
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Extraction Oil a Gas, Inc. - Trott Production Facility - Weld County
Notice Period Begins: January 12, 2021
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: Extraction Oil Et Gas, Inc.
Facility: Trott Production Facility
production facility
NESE, Section 7, T4N, R68W
Weld County
The proposed project or activity is as follows: request a reduction in Potential to Emit (PTE)
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 19WE0041 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Kirk Bear
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
(COLORADO
Department of Public
Health 6 Environment
to,
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0041 Issuance: 2
Extraction Oil Et Gas, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Trott Production Facility
123 A01 C
NESE Section 7 T4N R68W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
AIRS
Point
Equipment Description
Emissions Control
Description
003
Separator gas from 20 high -low pressure separators
during VRU downtime
Enclosed combustor
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
this specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. This construction permit represents final permit approval and authority to operate this
emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B,
Section III.G.5.)
EMISSION LIMITATIONS AND RECORDS
2. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,t
VOC
CO
003
--
--
10.5
2.1
Point
Page 1 of 8
r7 z
• te
COLORADO
Air Pollution Control Division
Department of Public Health b Env onment
Note: See "Notes to Permit Holder" for information on emission factors.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
3. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
4. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
AIRS
Point
Control Device
Pollutants
Controlled
003
Enclosed flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
5. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
II.A.4.)
Process Limits
AIRS
Point
Process Parameter
Annual Limit
003
Process gas during VRU
downtime
6.570 MM scf
Page 2 of 8
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Compliance with the annual throughput limits must 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 must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
6. The owner or operator must continuously monitor and record the volumetric flow rate of
natural gas vented from the separator(s) using the flow meter. The flow meter must be
calibrated and maintained per the manufacturer's specifications and schedule. The owner or
operator must use monthly throughput records to demonstrate compliance with the process
limits contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
7. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III. E. ) (State only enforceable)
8. 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 Number 1, Section II.A.5.)
9. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
10. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II. B.2. General Provisions (State only enforceable). If a flare or other combustion device
is used to control emissions of volatile organic compounds to comply with Section II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual
observation from the outside of the enclosed flare or combustion device, or by other convenient
means approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto -igniter according to the schedule in Regulation Number 7,
Part D, Section II.B.2.d.
11. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or
after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the commencement of operation by air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
12. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
Page 3 of 8
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division -approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING £t MAINTENANCE REQUIREMENTS
13. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (OftM) 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 the 0£tM plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
14. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
15. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
16. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th 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 (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, 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
Page 4 of 8
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
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.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
17. Federal regulatory program requirements (i.e. PSD, NANSR) must 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 must not exceed the Federal program threshold until
a permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
18. 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 Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
19. 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 Number 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.
20. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator 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 owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
Page 5 of 8
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
21. 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.
22. 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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must 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 owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
23. 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.
24. 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:
Kirk Bear
OG Permits
The Division
Permit History
Issuance
Date
Description
Issuance 1
29 August 2019
Issued to Extraction Oil a Gas, Inc.
Issuance 2
This Issuance
Modification to through -put and emissions
Page 6 of 8
rg
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
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 must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 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 owner or operator 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 complete 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 owner or operator must 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: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the sources operates at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
003
Benzene
71432
1215
61
Toluene
108883
749
37
n -Hexane
110543
9356
468
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission Factors
Source
NOx
0.068 lb/MM Btu
AP -42
CO
0.310 lb/MM Btu
AP -42
VOC
63837 lb/MM scf
Extended analysis
71432
Benzene
185 lb/MM scf
Extended analysis
Page 7 of 8
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
CAS #
Pollutant
. Uncontrolled
Emission Factors
Source
108883
Toluene
114 lb/MM scf
Extended analysis
110543
n -Hexane
1424 lb/MM scf
Extended analysis
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the following website: http://www.ecfr.Rov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
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 X 0000(
Page 8 of 8
Colorado Air Permitting Project,
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package /it:
Received Date:
Review Start Date:
For Division Use Only
Kirk Bear
428081
3/26/2020
11/23/2020
Section 01 - Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? Ozone (NOx &.VOC)
Extraction Oil & Gas, Inc..
123
AO1C
Trott Production Facility
NESE quadrant of Section 7, Township 4N, Range 68WW
Weld County
Section 02 - Emissions Units In Permit Application
Quadrant
Section
Township
Range
68W
NESE
7
4N
Leave Blank - For Division Use Only
AIRS Point #
(Leave blank unless APCD
has already assigned)
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
(Leave blank unless
APCD has already
assigned)
Issuance
#
Self Cert
Required?
Action
Engineering
Remarks
003
Separator Venting
Yes
19WE0041
2;
No
Permit
Modification
004
Separator Venting
Yes
19WE0042
2
No
Permit' '
Modification
I
Section 03 - Description of Project
reduction in the potential to emit
Sections 04, 05 & 06 - For Division Use Only
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic Minor Permit
Section 05 -Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Yes
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
No
Yes
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
DODO ❑ ❑
❑ ❑ ❑ 0 ❑ ❑ ❑ ❑
❑ O
No
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ ❑ ❑ ❑
Colorado Air Permitting Project
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
❑ ❑ ❑ ❑ DODO
Separator Venting Emissions Inventory
Section 01- Administrative Information
Facility AIRS ID:
123:, a
County
AO1C
Plant
003
Point
Section 02 - Equipment Description Details
Detailed Emissions Umt Description: separator gas "from 20 high -low pressure separators during VRU downtime
"Emission Control Device Description: .enclosed combustor
Requested Overall VOC & HAP Control Efficiency %.
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Irdormation for Emissions Estimates
Primary Emissions - Separator
Actual Throughput=
5:480 MMscf per year
95_'lA
Requested Permit Limit Throughput = 6.570: MMscf per year
Potential to Emit (PTE) Throughput =
6.570 MMscf per year
Secondary Emissions Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids through put:
1x060.0;: Btu/scf
cf/bbl
Control Device
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
';fr
Section 04 - Emissions Factors & Methodologies
I",?I scfh
Btu/scf
0.0 MMscf/yr
Description
MW
36.4,
Weight
Helium
0.0
CO2
18
N2
09
methane
'14.5
ethane
16.0
propane
- '."29.9
isobutane
4.7
n -butane
15.7
isopentane
3.9
n -pentane
5.2
cyclopentane
0.5
n -Hexane
1:5
cydohexane
0.4
Other hexanes
2.6
heptanes
- 0.9
methylcyclohexane
-0.3
224-TMP
0.0
Benzene
0,2
Toluene
0.1
Ethylbenzene
p:D
Xylenes
0:0
C8* Heavies
0.8.
Total
VOC Wt
99.8
66.6
13/113-mal
brought forward from previous issuance
Displacement Equation
Ex=Q*MW*Xx/C
3 of 10 K:\PA\2019\ 19WE0041.CP2.xlsm
Separator Venting Emissions Inventory
Pollutant
Pollutant
Separator Venting
Uncontrolled
63956.04
Primary Control Device
Uncontrolled
(Ib/MMBtu)
(Waste Heat
Comhusted)
Uncontrolled
Ib/MMscf
0.0680
(Gas Throughput)
0.0000
0.0000
0.0000
140.0800
638.6000
Pilot Light Emissions
Uncontrolled
(Ib/MMBtu)
• Uncontrolled
Ib/MMscf
(Pilot Gas Throughput)
0.0000
Emission Factor Source
Emission Factor Source
Emission Factor Source
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
PM10
PM2.5
sox
NOx
VOC
CO
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.5
0.4
0.4$,
210.1
175.2
8.8
2.1
1.7
1.7
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
Ohs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TM
1217
1015
51
„--.=-211;
69
753
628
31
:753
38
79
66
3
Aa
4
240
200
100,
e 32 r
U
9371
7816
391
9
3
3
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Part D, Section ILB, F
Regulation 7; Part D, Section II.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Source requires a permit
Source is subject to Regulation 7, Part D, Section 11.6.2, F
The control device for this separator is not subject to Regulation 7, Part D, Section 11.B.2.e
4 of 10 IC\PA\2019\ 19WE0041.CP2.xlsm
Separator Venting Emissions Inventor;
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
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.
;?J
Are facility -wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment
area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area?
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? Yes
If np, 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 "Volumeof waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require. an. answer
Section 08 - Technical Analysis Notes
Section 09 -SCC Coding and Emissions Factors (For Inventory Use Only).
AIRS Point #
Process # SCC Code
003 01 3-10-001-60 Flares
Pollutant Uncontrolled Emissions Factor Control % Units
PM10 0.0 0 Ib/MMSCF
PM2.5 0.0 0 Ib/MMSCF
5Ox 0.0 0 Ib/MMSCF
NOx 140.1 0 Ib/MMSCF
VOC 63956.0 95 Ib/MMSCF
CO 638.6 0 Ib/MMSCF
Benzene 185.2 95 Ib/MMSCF
Toluene 114.6 95 Ib/MMSCF
Ethylbenzene 12.0 95 Ib/MMSCF
Xylene 36,5 95 Ib/MMSCF
n -Hexane 1426.3 95 Ib/MMSCF
224 TMP 0.5 95 Ib/MMSCF
5 of 10 K:\PA\2019\ 19WE0041.CP2.xlsm
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Re: ulation 3 Parts A and 8 - APEN and Permit Requirements
Srur._,_ fn the tier-Attaintuent Area
ATTAINMENT
1. _Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.l.a)?
2. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.3)?
IRouhat, irtdit,t,d that tour. is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3, Part A, Section ll.D.l.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOa greater than 5 TPY or CO emissions greater than 30 TPY (Regulation 3, Part B, Section ll.D2)7
'S^._crc_ met j =_se Damn -
Colorado Regulation 7, Part D, Section II
1. Was the well newly constructed, hydraulically ft d recompleted on or after August 1, 20147
IScurce,uSettle,=#2,F
Section II.B2— General Provisions for Air Pollution Control Equipment Used to Comply with Section II
Section II.F - Control of emissions from well production facilities
Akernative Emissions Control (Optional Sectiont
a. Is this separator controlled by. back-up It to combustion device ( not the primary control device) that is not enclosed?
Inne ca , :A Beni square., 7,_ SUbNCY to Regulation `, Part G. Senna, thEthe...
Section II.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 AirQuality 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.
I
Source Re
Source Re
raMMElSource.is.
The contn
Separator Venting Emissions Inventory
Section 01- Administrative Information
'Facility AlRs ID:
123
County
AO1C
Plant
004
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
two vapor recovery towers
Emission Control Device Description: enclosed combustor .,..:.W -,.t.
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
0.8�, MMscf per year
Requested Permit Limit Throughput =
Potential to Emit (PTE) Throughput =
1.0 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:.
r
269�,:U'; Btu/scF
scf/bbl
Control Device
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
scfh
Btu/scf
0.0 MMscf/yr
Section 04 - Emissions Factors & Methodologies
Description
46.4210
113/1b-mol
MW
Weight %
Helium
CO2
N2
methane
ethane
0;0000
0:5980
0.3037
2:1276
9.9590
propane
isobutane
n -butane
isopentane
n -pentane
cyclopentane
n -Hexane
cyclohexane
Other hexanes
heptanes
methylcyclohexane
224-TMP
Benzene
Toluene
Ethylbenzene
Xylenes
C8+ Heavies
37.9375
7.6636
25.2777
5.5378
6.3166
0.4205
0.9824
0.1735
1:9226
0.3313
0.0940
0.0003
0.0937
0:0256
0.0009
00021
0:1382
99.9066
86.9183
Total
VOC Wt %
broght forward from previous issuance
t
Displacement Equation
Ex=C1•MW•Xx/C
7 of 10 K:\PA\2019\ 19WE0041.CP2.xlsm
Separator Venting Emissions Inventory
Emission Factors
Separator Venting
Uncontrolled
(Ib/MMscf)
Pollutant
Controlled
(Ib/MMscf)
(Gas Throughput)
VOC
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
1216.2319
0.3714
Pollutant
(Gas Throughput)
Emission Factor Source
5380.3345
5.8001
1.5847
0.0557
0.1300
60.8116
0.0186
Primary Control Device
Uncontrolled
(Ib/MMBtu)
(Waste Heat
Combusted)
Uncontrolled
Ib/MMscf
(Gas Throughput)
gdedgas analysis
piled gas analysis
'led. gas analysis
�'• ed gas analy
sis
peed gas analysis
§'• ed. gas analysis
'Med gas analysis
Emission Factor Source
PM10
PM2.5
0.0000-
0.0000
0.0000
SOx
NOx
CO
0.0680
0.3100 834.2100
182.9880
Pollutant
Pilot Light Emissions
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBM) Ib/MMscf
(Waste Heat
Combusted)
(Pilot Gas Throughput)
PM10
PM2.5
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
SOx
NOx
VOC
Co
Section OS - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
PM10
PM2.5
. SOx
NOx
VOC,
CO
0.0
0.0
0.0
0.1
53.8
0.4
0.0
0.0
0.0
0.1
44.7
0.3
0.0
0.0
0.0
0.1
2.2
0.3
0.0
0.0
0.0
0.1
53.8
04
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TIVIP
116
32
96 5
26
1
2
116
32
1
0
0
50
0
3
1216
1009
1216
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Part D, Section II.B, F
Regulation 7, Part D, Section II.8.2.e-
(See regulatory applicability worksheet for detailed analysis)
Source requires a permit
Source is subject to Regulation 7, Part D, Section II.B.2, F
The control device for this separator is not subject to Regulation 7, Part D, Section II.B.2.e
8 of 10 KAPA\2019\ 19WE0041.CP2.xism
Separator Venti: emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site spedfic 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 6e 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.
Are facility -wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment
area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area?
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? Yes
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 request control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.
Section 08 -Technical Analysis Notes
AIRS Point #
Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only)
Process # SCC Code
004 01 3.10-001-60 Flares
Pollutant Uncontrolled Emissions Factor Control % Units
P M10 0.0 0 Ih/MMSCF
PM2.5 0.0 0 Ib/MMSCF
50x 0.0 0 Ib/MMSCF
NOx 183.0 0 Ib/MMSCF
VOC 107606.7 95 Ib/MMSCF
CO 834.2 0 Ib/MMSCF
Benzene 116.0 95 Ib/MMSCF
Toluene 31.7 95 Ib/MMSCF
Ethylbenzene 1.1 95 Ib/MMSCF
Xylene 2.6 95 Ib/MMSCF
n -Hexane 1216.2 95 Ib/MMSCF
-- 224 TMP 0.4 95 Ih/MMSCF
9 of 10 K:\PA\2019\19WE0041.CP2.xlsm
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B -APEN and Permit Requirements
'Source Is In the Non-AttaSnment fir as
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 30 TPY (Regulation 3, Part B, Section ll.D.3)T
'You have indicated that snsrue is in the NoniAttainm@nt Arrow
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3, Part A, Section ll.D.l.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 ll.D.2)?
. 'Source requires a permit
Colorado Regulation 7, Part D, Section II
1. Was the well newly constructed, hydraulically fractured, or recompieted on or after August 1, 2014?
ISc..ce is subject to nose scion 7. Fart 0, Section 11.8.2. K
Section II.B.2— General Provisions for Air Pollution Control Equipment Used to Comply with Section II
Section IhP - Control of emissions from well production facilities
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?
ITho control device for this se_nerator is not subject to P.egutattan 7, Part D, Section II.B.2s
Section II.B.2.e—Alternative emissions control equipment
Disclaimer
This document assists operators with detemdning 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
es 'Source Re
Yes Source Re
iffiAlSourCe iss
), The contr.
I
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0042 Issuance: 2
Extraction Oil Et Gas, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Trott Production Facility
123 A01 C
NESE Section 7 T4N R68W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
AIRS
Point
Equipment Description
Emissions Control
Description
004
Separator gas from 2 vapor recovery towers
Enclosed combustor
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
this specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. This construction permit represents final permit approval and authority to operate this
emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B,
Section III.G.5.)
EMISSION LIMITATIONS AND RECORDS
2. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section I I.A.4. )
Annual Limits:
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
004
--
--
2.7
--
Point
Note: See "Notes to Permit Holder" for information on emission factors.
Page 1 of 8
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
3. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
4. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
AIRS
Point
Control Device
Pollutants
Controlled
004
Enclosed flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
5. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
I I.A.4. )
Process Limits
AIRS
Point
Process Parameter
Annual Limit
004
Process gas during VRU
downtime
1.0 MM scf
Page 2 of 8
• *M
COLORADO
Air Pollution Control Division
Department of Pubhe Health b Environment
Compliance with the annual throughput limits must 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 must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
6. The owner or operator must continuously monitor and record the volumetric flow rate of
natural gas vented from the separator(s) using the flow meter. The flow meter must be
calibrated and maintained per the manufacturer's specifications and schedule. The owner or
operator must use monthly throughput records to demonstrate compliance with the process
limits contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
7. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section I I I. E. ) (State only enforceable)
8. 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 Number 1, Section II.A.5.)
9. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
10. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device
is used to control emissions of volatile organic compounds to comply with Section II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual
observation from the outside of the enclosed flare or combustion device, or by other convenient
means approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto -igniter according to the schedule in Regulation Number 7,
Part D, Section II.B.2.d.
11. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or
after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the commencement of operation by air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
12. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
Page 3 of 8
r•",M,
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
information in the Division -approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING Et MAINTENANCE REQUIREMENTS
13. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (OEtM) 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 the OIIM plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
14. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
15. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
16. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th 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 (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, 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
Page 4 of 8
COLORADO
.Air Pollution Control Division
Department of Public Health F:1 Environment
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.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
17. Federal regulatory program requirements (i.e. PSD, NANSR) must 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 must not exceed the Federal program threshold until
a permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
18. 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 Number 3, Part B, Section II. B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
19. 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 Number 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.
20. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator 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 owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
Page 5 of 8
COLORADO
Air Pollution Control Division
Department of Public Health 5 Environment
21. 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.
22. 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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must 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 owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
23. 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.
24. 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:
I�
�f
Kirk Bear
OG Permits
The Division
Permit History
Issuance
Date
Description
Issuance 1
29 August 2019
Issued to Extraction Oil Et Gas, Inc.
Issuance 2
This Issuance
Modification to through -put and emissions
Page 6 of 8
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
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 must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 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 owner or operator 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 complete 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 owner or operator must 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: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the sources operates at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
004
n -Hexane
110543
1215
61
ote: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission Factors
Source
NOx
0.068 lb/MM Btu
AP -42
CO
0.310 lb/MM Btu
AP -42
VOC
107470 lb/MM scf
Extended analysis
110543
n -Hexane
1215 lb/MM scf
Extended analysis
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
Page 7 of 8
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the following website: http://www.ecfr.Qov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
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
Page 8 of 8
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
For Division Use Only
Kirk Bear
428081
3/26/2020
11/23/2020
Section 01- Facility Information
Company Name: Extraction Oil & Gas, Inc,
County AIRS ID: -:123
Plant AIRS ID: ,A01C
Facility Name: Trott Production Facility
Physical
Address/Location:
County:
Type of Facility:
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant?
NESE quadrant of Section 7, Township 4N, Range 68WW
1Neld County
Exploration & Production Well Pad
Section 02 - Emissions Units In Permit Application
Yes
Ozone (NOx & VOC)
Quadrant
Section
Township
Range
68W
NESE
7
4N
leave Blank - For Division Use Only
AIRS Point #
(Leave blank unless APCD
has already assigned)
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
(Leave blank unless
APCD has already
assigned)
Issuance
#
Self Cert
Required?
Action
Engineering
Remarks
003
Separator Venting
Yes
19WE0041
2
No
Permit
Modification
004
Separator Venting"
Yes
19WE0042
2
No
Permit
Modification
i
Section 03 - Description of Project
reduction in the potential to emit
Sections 04, 05 & 06 - For Division Use Only
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Yes
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
No
Yes
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ ❑ ❑ ❑
O 0000 000
❑ O
No
502 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ ❑ ❑ ❑
Colorado Air Permitting Project
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
0000 O 000-
Separator Venting Emissions Inventory
Section 01 -Administrative Information
Facility AIRS ID:
123
County
A01C
Plant
003
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Emission Control Device Descr4tion:
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions -Separator
Actual Throughput =
5.480 MMscf per year
Requested Permit Limit Throughput = 6.570 MMscf per year
Potential to Emit (PTE) Throughput =
6.570 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL
liquids throughput:
Control Device
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
160.0; Btu/scf
scf/bbl
scfn
Btu/scf
0.0 MMscf/yr
Section 04 - Emissions Factors & Methodologies
MW
6.4
Weight
Helium
00
CO2
'f` 1.8
N2
' 0:9
methane
14.5
ethane
16.0
propane
29.9
isobutane
4.7
n -butane
.15.7
isopentane
: 3.9
n -pentane
5.2
cyclopentane
-=0.5
n -Hexane
1',5
cyclohexane
` ,0:4
Other hexanes
`2.6
heptanes
- ;. 0.9
methylcyclohexane
0.3
224TMP
0.0
Benzene
0,2
Toluene
' 0.1
Ethylbenzene
'!-0.0
Xylenes
0.0
C8+ Heavies
._08
Total
VOC Wt %
99.8
66.6
Ib/Ib-mal
Displacement Equation
Ex=Q.MW.Xx/C
3 of 10 K:\PA\2019\19WE0041.CP2.xlsm
Separator Venting Emissions Inventor
Pollutant
Pollutant
Pilot
Pollutant
Separator Venting
Uncontrolled
Primary Control Device
Uncontrolled
(Ib/MMBtu)
(Waste Heat
Combusted)
Uncontrolled
Ib/MMscf
0.0680
0.3100
(Gas Throughput)
0.0000
0.0000
0.0000
140.0800
638.6000
ight Emissions
Uncontrolled
(Ib/MMBtu)
(Waste Heat
Combusted)
Uncontrolled
Ib/MMscf
Section OS - Emissions Inventory
(Pilot Gas Throughput)
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
Emission Factor Source
`:Extended gas analysis
-:.Extended gas analysis
xtended gas analysis
nded. gas analysis
r ded gas analysis
nded gas analysis
"sanalsis
Emission Factor Source
AP 42 Chi
AP-42Glia
ndustrial Flares (NOx)
5`Itidustrial Flares (CO)
Emission Factor Source
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
PM10
0.0
0.0
0.0
0.0
0.0
PM2.5
0.0
0.0
0.0
0.0
0.0
SOx
0.0
0.0
0.0
0.0
0.0
NOx
0.5
0.4
0.4
- 0.5.
OS
VOC
210.1
175.2
8.8
210.1
10.5
CO
2.1
1.7
1.7
-.. 2.1
Potential to Emit
Actual Emissions
Requested Permit Limits
Hazardous Air Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
(Ibs/year)
(Ibs/year) (Ibs/year)
(Ibs/year) (Has/year)
Benzene
1217
1015
51;:1217
61
Toluene
753
628
31
x'-;:753
38
Ethylbenzene
79
66
3
-V—".,.79
4
Xylene
240
200
30=-340
12
n -Hexane
9371
7816
391
WS9371
469
224 TMP
3
3
0
-'::'3
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Part D, Section II.B, F
Regulation 7, Part D, Section II.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Source requires a permit
Source is subject to Regulation 7, Parr D, Section 11.8.2, F
The control device for this separator is not subject to Regulation 7, Part D, Section 11.B.2.e
4 of 10 KAPA\2019\19WE0041.CP2.xlsm
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
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.
Are facility -wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment
area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area?
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 paint? Yes
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 request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require swer.
Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only)
AIRS Point #
003
Process # SCC Code
01 3-10-001-60 Flares
Section 08 - Technical Analysis Notes
Pollutant Uncontrolled Emissions Factor Control % Units
PM10 0.0 0 Ib/MMSCF
PM2.5 0.0 0 Ib/MMSCF
5Ox 0.0 0 Ib/MMSCF
NOx 140.1 0 Ib/MMSCF
VOC 63956.0 95 Ib/MMSCF
CO 638.6 0 Ib/MMSCF
Benzene 185.2 95 Ib/MMSCF
Toluene 114.6 95 Ib/MMSCF
Ethylbenzene 12.0 95 Ib/MMSCF
Xylene 36,5 95 Ib/MMSCF
n -Hexane 1426.3 95 Ib/MMSCF
224 TMP 0.5 95 Ib/MMSCF
5 010 K:\PA\2019\ 19WE0041.CP2.xlsm
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B - APEN and Permit Reguirem ants
'Source is in the hton.nttai,m=_nt Araa '
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section li.D.l.a)7
2. Are total facility uncontrolled VOC emissions greater than 5TPY, NOz greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)7
IYou twit, ;maicrted»t source ni mho won -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled. emissions from any criteria pollutants from thls individual source greater than STPY(Regulation 3, PartA, Section ll.D.l.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOz greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.02)7
'Source rettttirera F,Ftttit
Colorado Regulation 7, Part %Section II
1. Wasthe well newly constructed, hydraulically fractured, or recompleted on or after August 1, 20147
'Source is suhtscr RegutprIPp 7, Part:, Section:I,B.2,F
Section II.B.2— General Provisions for Air Pollution Control Equipment Used to Comply with Section II
Section II.F - Control of emissions from well production facilities
Alternative Emlulons Control (Optional Section).
a. Is this p tor controlledbya back-up or alternatecombustion device(I.e., notthe primary control device) that is not enclosed?
IThe contr., 7, sap..., Fr 'tot subject tt, SmtulatIon 7, Part 0,5ectlon Ii,B,2.t
Section II.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
net 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.
Source Re
Source Re
''Source is:
Separator Venting Emissions Inventory
Section 01- Administrative Information
Facility Al Rs ID:
123;
County
Section 02 - Equipment Description Details
Emission Control Device Description: enclosed combustor
Requested Overall VOC & HAP Control Efficiency %.
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Actual Throughput
x.,06 MMsd per year
Potential to Emit (PTE) Throughput =
1.0 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
scfn
Btu/scf
Control Device
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
0.0 MMscf/yr
Section 04 - Emissions Factors & Methodologies
IMW
46:9210
Weight
Helium
X0:0000
CO2
: F≥:0:5980
N2
0.3037
methane
::2.1276
ethane
..`;9.9590
propane
37.9375
isohutane
7.6636
n -butane
25:2777
isopentane
5.5378
n -pentane
: 6.3166
cyclopentane
':'.0.4205
n -Hexane
:0:9824
cyclohexane
:0.1735
Other hexanes
:1.9226
heptanes
0:3313
methylcyclohexane
0.0940
224TMP
0.0003
Benzene
.0.0937
Toluene
.:.,0:0256
Ethylhenzene
.:0.0009
Xylenes
D 0021
C8+ Heavies
"01382
Total
VOC Wt
99.9066
86.9183
Ih/Ih-mol
broght forward from previous issuance
Displacement Equation
Ex=Q'MW'XX/C
7 of 10 K:\PA\2019\19WEo041.CP2.xlsm
Separator Venting Emissions inventory
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
(Ib/MMscf) - (Ib/MMscf)
(Gas Throughput)
(Gas Throughput)
Emission Factor Source
VOC
107606.6901
5380.3345
Benzene
Toluene
116.0026
31.6933
1.1142
2.5998
5.8001
1.5847
0.0557
0.1300
60.8116
0.0186
Ethylbenzene
Xylene
n -Hexane
224 TMP
1216.2319
0.3714
Emission Factor Source
Pollutant
Primary Control Device
Uncontrolled Uncontrolled
(Ib/MM6tu) Ib/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
PM2.5
0.0000
0.0000
0.0000
SOx
NOx
CO
=0.0680 182.9880
4.3100
834.2100
AP -42
AP -42.
tndustrial Flay
ndustrial Flat;
Pollutant
Pilot Light Emissions
Uncontrolled Uncontrolled
(Ib/MMBtu) Ib/MMscf
(Waste Heat
Combusted)
(Pilot Gas Throughput)
Emission Factor Source
PM10
PM2.5
0.0000
0.0000
0.0000
SOx
NOx
VOC
CO
0.0000
0.0000
0.0000
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
PM10
PM2.5
SOx
NOx
VOC
CO
0.0
0.0
0.0
-- 0.0
0.0
0.0
0.0
0.0
0.0
0.0
'; 0.0...=_,D
0.1
0.1
0.1
53.8
44.7
2.2
0.4
0.3
0.3".
0.4
_ 0.4
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TM P
116
96
5
.'116
6
32
26
1
1
1
0
3
2
0
1216
1009
50
;`-1216'=-,763.-,F,
0
0
0
: 0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Part D, Section II.B, F
Regulation 7, Part D, Section II.8.2.e
(See regulatory applicability worksheet for detailed analysis)
Source requires a permit
Source is subject to Regulation 7, Part D, Section II.B.2, F
The control device for this separator is not subject to Regulation 7, Part D, Section II.B.2.e
8 of 10 K:\PA\2019\19WE0041.CP2.xlsm
Separator Venting Emissions inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
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.
Are facility -wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment
area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area?
If yes, the permit will contain:4
-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? - Yes
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 request a control. device efficiency greater than 95% for a flare or combustion device?
If yes, the permit wi8 contain initial and. periodic compliance testing in accordance with PS Memo 20-02
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.
Section 08 -Technical Analysis Notes
Section 09 - SCC Coding and Emissions Factors IFor Inventory Use Only)
AIRS Point ft
004
Process ft SCC Code
01 3-10-001.60 Flares
Pollutant Uncontrolled Emissions Factor Control % Units
PM10 0.0
PM2.5 0.0
SOx 0.0
NOx 183.0
VOC 107606.7
CO 834.2
Benzene 116.0
Toluene 31.7
Ethylbenzene 1.1
Xylene 2.6
n -Hexane 1216.2
224 TMP 0.4
O Ib/MMSCF
O Ib/MMSCF
O Ib/MMSCF
O Ib/MMSCF
95 Ib/MMSCF
O Ib/MMSCF
95 Ib/MMSCF
95 Ib/MMSCF
95 Ib/MMSCF
95 Ib/MMSCF-
95 Ib/MMSCF
95 Ib/MMSCF
' 9 of 10 K:\PA\2019\19WE0041.CP2.xlsm
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Re illation 3 Parts A and B-APEN and Permit Reouirements
Source be in the Non Attainment Area -
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NON greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B,Section ll.D.37?
IYou have indicated that source is In the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section 11.0.1.a)?
2. Are total facility uncontrolled VOC emissions from thegreater than 2 TPY, NOc greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.2)7
ISc= _. requires a Permit
Colorado Regulation ] Part D. Section II
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
ISotece sublect to Regulation 7, Part 0, Sectlon li.R.2, F
Section II.B.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II
Section Il.F - Control of emissions from well production facilities
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?
ITte nTral device for this separator is net subject to Regulation Y, Part 0, Section ll.R.2.e
Section II.B.2.e—Altemative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Ad, 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 Centro/ 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 APCO interpretations and recommendations. Mandatory terminology such as °musr'and *required" are intended to describe controlling requirements under the temrs of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Source Re
Source Re
'Source is:
The contra
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
Alt sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require
payment for a new filing fee.
This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-2OO) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.cotorado.aovlcdphe aocd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 19WE0041
.PCD `�as
AIRS ID Number: 123 / A01 C /003
Section 1 - Administrative Information
Company Name': Extraction Oil & Gas, Inc.
Site Name: Trott Production Facility
Site Location: NESE SECT T4N R68W
Mailing Address: 370 17th Street, Suite 5300
(Include Zip Codei
Denver, Colorado 80202
Site Location
County: Weld
NAILS or SIC Code: 211111
Contact Person:
Phone Number:
E -Mail Address2:
Jonathan Torizzo
(303) 396-6051
air@extractionog.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
z Permits. exemption letters. and any processing invoices wilt be issued by the APCD via e-mail to the address provided.
1I
428070
00
Permit Number: 19WE0041
AIRS ID Number:
123 / A0 i C / 003
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source
-OR -
• MODIFICATION to existing permit (check each box below that gybes)
❑ Change fuel or equipment ❑ Change company name' ❑ Add point to existing permit
Q Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
OR
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info £t Notes:
3 For company name charge, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Emissions
Low Pressure ("LP") Separator Venting
Company equipment Identification No. (optional):
For existing sources, operation began on:
10/05/2018
For new, modified, or reconstructed sources, the projected start-up date is:
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
TBD hours/day TBD days/week TBD weeks/year
Will this equipment be operated in any NAAQS
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
h 3 2019
Q Yes ❑ No
❑ Yes ❑� No
Yes ❑ No
2 ®®
co.oR.00
Permit Number: 19WE0041
AIRS ID Number: 123 / A01 C /003
Section 4 - Process Equipment Information
0 Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial v:
ft of Pistons:
Volume per event:
Capacity: gal /min
Leak Rate: Scf/hr/pist
MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 toy?
Gas Venting
Process Parameters':
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
Yes ❑ No
Vent Gas 12 060
Heating Value: I ,
Requested:
6.57
MMSCF/year
Actual: 15.48
BTU/SCF
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbltyear
Molecular Weight:
36.36
VOC (Weight %)
66.59
Benzene (Weight %)
0.19
Toluene (Weight %)
0.12
Ethylbenzene (Weight %)
0.01
Xylene (Weight %)
0.04
n -Hexane (Weight %)
1.49
2,2,4-Trimethytpentane (Weight %)
0.00
Additional Required Information:
Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
' Requested values will become permit limitations. Requested limit(s) should consider future process growth.
r'm APC -211 GaS ✓y{j APEr.-1 •sicin 2019
t Ot OtAaO
3i_.
Permit Number: 19VVE0041
AIRS ID Number:
123 /A0iC /003
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.324431, -105.040427
Operator
p
Stack 1D No.
Discharge Height
Above Ground Level
(Feet)
Temp.
f'F)
Flow Rate
(ACFM)
Velocity
tf mac) `
ECD
-30 N/A
N/A N/A
Indicate the direction of the stack outlet: (check one)
�]✓ Upward
❑ Horizontal
Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
Q Circular Interior stack diameter (inches):
•
[� Other (describe):
[] Upward with obstructing raincap
144
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑ VRU:
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed: q�
a Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating: N/A
Type: EC
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature: N/A
MMBtu / h r
Make/Model: 6)5000
95
>99
1
Waste Gas Heat Content:
Constant Pilot Light: Q Yes ❑ No Pilot burner Rating:
2;060
N/A
Btu /scf
MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
01.O*A00
~oral APCD-211 Sas Venting APEN - revision 312019 4 I
Permit Number: 19WE0041
AIRS ID Number:
123 /Aoic /003
Section 7 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency C� reduction):
Pollutant
Description of Control Method(s)
Overall Requested
Control Efficiency
(% reduction in emiss€ons)
PM
SOx
NOx
CO
VOC
Enclosed Combustion Device
95%
HAPs
Enclosed Combustion Device
95%
Other:
From what year is the following reported actual annual emissions data?
2019
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
MIS., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tonslyear)
Controlled
Emissions
(tons/year)
PM
SOx
NOx i 0.068
Ib/MMBtu
AP -42
0.38
0.38
0.46
0.46
CO 0.31
Ib/MMBtu
AP -42
1.75
1,75
2.1
2.1
VOC 63.837
Ib/Mscf
19WE0041
174.75
8.74
209.71
10.49
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Number Mjg., etc.
Units
Source
(AP -42,
)
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions6
(pounds/year)
Benzene
71432
0.185
lb/Mscf
19WE0041
1215
61
Toluene
108883
0.114
Ib/Mscf
19WE0041
749
37
! Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
1.424
Ib/Mscf
19WE0041
9356
468
2,2,4-
Trimethylpentane
540841
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
ri 2� 1
Revision 3'2' 19
5!
cocolt Do
Permit Number: 19WE0041
AIRS ID Number:
123 / Ao1 C /003
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
3/23/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Jonathan Torizzo
Air Quality Coordinator
Name (please print) Title
Check the appropriate box to request a copy of the:
Q✓ Draft permit prior to issuance
Ej Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payabte to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303)692-3150
Or visit the APCD website at:
https://www.coloracio.govicdpheiapcd
arm APCD-2
co 3 wty
to,O*.00
--
i
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require
payment for a new filing fee.
This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphetapcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 19WE0042
AIRS ID Number:
D
123 / A01 C /004
Section 1 - Administrative Information
Company Name': Extraction Oil & Gas, Inc.
Site Name: Trott Production Facility
Site Location: NESE SECT T4N R68W
Marling Address: .3/0 17th Street, Suite 5300
Include Zip Code!
Denver, Colorado 80202
Site Location
County: Weld
NAILS or SIC Code: 211111
Contact Person: Jonathan Torizzo
Phone Number: (303) 396-6051
E -Mail Address2: air@extractionog.com
' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters. and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-211 APEN e is.Lon 3 2019
428080
COLO#AD0
1�.
1
Permit Number: 19WE0042
AIRS ID Number:
123 / A01 C /004
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source
-OR -
❑✓ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
0 Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
- OR
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes:
3 For company name change, a completed Company Name Change Certification Form ;Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Vapor Recovery Tower ("VRT") Venting
Emissions
Company equipment Identification No. (optional):
For existing sources, operation began on:
10/05/2018
For new, modified, or reconstructed sources, the projected start-up date is:
❑ Check this box if operating hours are 8,760 hours per year: if fewer, fill out the fields below:
Normal Hours of Source
Operation:
TBD hours/day TBD days/week TBD weeks/year
Will this equipment be operated in any NAAQS
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
0
Yes
Yes
Yes
❑ No
p No
No
2iAV
COLOk Apo
Permit Number: 19WE0042
AIRS ID Number:
123 / Ao1 C /004
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
❑ Welt Head Casing
❑ Pneumatic Pump
Make: Model:
Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #:
of Pistons:
Volume per event:
Capacity: gal/min
Leak Rate: Scf/hr/pist
MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy?
Gas Venting
Process Parameters':
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
Q Yes ❑ No
Gas 2 691
HeatingVent Value:
BTU/SCF
Requested: 0 MMSCF/year
•
Actual: 0.83
MMSCF/year
-OR-
Requested:
I bbl/year
Actual:
bbl/year
1
Molecular Weight:
46.92
VOC (Weight %)
86.90
Benzene (Weight %)
0.09
Toluene (Weight %)
0.03
Ethylbenzene (Weight %)
0.00
Xylene (Weight %)
0.00
n -Hexane (Weight %)
0.98
2,2,4-Trimethylpentane (Weight %)
0,00
Additional Required Information:
❑ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
5 Requested values will become permit limitations. Requested timitis) should consider future process growth.
orm APrD-2? i a_ vents;Revlson 3 '2019
ca��:.ao
3 I �. .
Permit Number: 19WE0042
AIRS ID Number:
•
123 / A0 1 C /004
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.324431, -105.040427
Operator
Stack lip No.
Discharge Height
Above Ground Level
(Feet)
Temp.
('F)
Flow Rate
(ACFM)
Ve
k
ECD
—30
N/A
N/A N/A
Indicate the direction of the stack outlet: (check onej
❑✓ Upward
❑ Horizontal
[] Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular
❑ Other (describe):
Interior stack diameter (inches):
❑ Upward with obstructing raincap
144
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑ VRU:
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Make/Model:
EI Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating: N/A
Type: ECD
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
MMBtu/hr
Make/Model:
95
>99
Q5000
Minimum Temperature: N/A Waste Gas Heat Content: 2 691 Stu/scf
t
Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating: N/A MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
DO
.=arm APCD-211 - Gas Venting APEN - Revision 3 2019 4 I
Permit Number: 19VVE0042
AIRS ID Number:
123 / A01 C /004
Section 7 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (.fin reduction):
Pollutant
Description of Control Method(s)
Overall Requested
Control Efficiency
(% reduction in emissions)
PM
50.
N0.
CO
VOC
Enclosed Combustion Device
95%
HAPs
Enclosed Combustion Device
95%
Other:
From what year is the following reported actual annual emissions data? 2019
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions('
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SO.
N0.
0.068
Ib/MMBtu
AP -42
0.1
0.1
0.1
0.1
CO
0.31
Ib/MMBtu
AP -42
0.35 0.35
0.42
0.42
VOC
107.47
lb/Mscf
19VdE0042
44.8 2.24
53.76
2.69
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions
(pounds/year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
1.215
Ib/Mscf
19WE0042
1215
61
2,2,4-
Trimethylpentane
540$41
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
3,2(319
5I
O iallaDO
Permit Number: 19WE0042
AIRS ID Number:
123 /Ao1C/004
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
3/23/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Jonathan Torizzo
Air Quality Coordinator
Name (please print) Title
Check the appropriate box to request a copy of the:
Q✓ Draft permit prior to issuance
❑r Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.), See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: iwww.cotorado.goy icdohe/apcd
6 AV
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