HomeMy WebLinkAbout20192221.tiffCOLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
June 3, 2019
Dear Sir or Madam:
RECEIVED
JUN 0 6 2019
WELD COUNTY
COMMISSIONERS
On June 6, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for
Extraction Oil Et Gas, Inc. - Windsor LV2 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: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
C.�/111►
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
C.G'.PLC-TP)1H L(J-c),
cw(dmi£Rlcykion)
Lo 11111°►
2019-2221
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Extraction Oil Et Gas, Inc. - Windsor LV2 Production Facility - Weld County
Notice Period Begins: June 6, 2019
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: Windsor LV2 Production Facility
Wellpad/Production Facility
SESE SEC 14 T6N R67W
Weld County
The proposed project or activity is as follows: Storage Tanks and Separation Equipment at an EEtP Facility
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0112 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.Qov/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:
Timothy Sharp
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
1 I A.;ttr
Waft*P.nvio+vnm.xt
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Timothy Sharp
Package #: 373528
Received Date: 2/2/2018
Review Start Date: 6/13/2018
Section 01 - Facility Information
Company Name: Extraction Oil & Gas, Inc.
County AIRS ID: 123
Quadrant
Section
Township
Range
SESE
14_
.
67
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility:
9F9A
Windsor LV2 Production Facility
SESE quadrant of Section 14, Township 6N, Range 671N
Weld County
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? ❑ Carbon Monoxide (CO) 0 Particulate Matter (PM) 0 Ozone (NOx & VOC)
Section 02 - Emissions Units In Permit Application
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit tt
Issuance tt
Self Cert
Required?
Action
Engineering
Remarks
Condensate Tank
18WE0112
w
Permit Initial
Issuance
Produced Water Tank
18WE0113
Permit Initial
Issuance
Separator Venting
HP Separator
18WE0114
Permit Initia'
Issuance
Separator Venting
LP Separator
18WE0115
Permit Initial
Issuance
Separator Venting
VRT Venting
18WE0116
=
Permit Initia:
Issuance
Section 03 - Description of Project
Well pad facility utilizing Questor/Q5000 ECDs, and requesting 98% control for venting points.
-permit application updated prior to issuance. New APENs received 4-26-2019
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
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: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) DODD ❑ ❑
Title V Operating Permits (OP) ❑ O 0 ❑ LI ❑ El
Non -Attainment New Source Review (NANSR)
is this stationary source a major source?
Colorado Air Permitting Project
If yes, explain what programs and which pollutants heriSO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) ❑ ❑ ODD ❑
Title V Operating Permits (OP) DODO ❑ DOD
Non -Attainment New Source Review (NANSR) ❑ ❑
Condensate Storage Tank(s) Emissions Inventory
007 Condensate Tank
Facility AIRs ID:
County
007
Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit 8x100 bbl condensate storage vessels
Description:
Emission Control Device LCD,
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput =
789,692 Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
739,692 Barrels (bbl) per year
Requested Permit Limit Throughput =
947,630 Barrels (bbl) per year
Requested Monthly Throughput =
80484 Barrels (bbl) per month
Potential to Emit (PTE) Conder sate
Throughput=
Secondary Emissions - Combustion Device(s)
Heat content of waste gas =
Volume of waste gas emitted per BBL of
liquids produced =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
947,630 Barrels (bbl) per year
2518 Btu/scf
3.161188 scf/bbl
Potential to Emit (PTE) heat ccntent of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
6,286 MMBTU per year
7,543 MMBTU per year
7,543 MMBTU per year
Emission Factors
Condensate Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(Ib/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
0,24
0.01
= it
c ES(b9dude:s.flash)
-. cific E.F. (includes flash)
Sr e•rdk 17 F, (inclucksflash)
Benzene
0.001
0.000
Toluene
0.000
0.000
Ethylbenzene
0.000
Xylene
0,000
0.000
n -Hexane
0.004
0.000
224 TMP
0.000
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (Ib/bbl)
(waste heat
combusted)
(Condensate
Throughput)
P M 10
0.0000
• •,:
;
::
PM2.5
0.0000
NOx
0.0680
0.0005
CO
0.3100
0.0025
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)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
PM10
PM2.5
115.6
96.3
4.8
115.6
5.8
982
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
NOx
CO
0.3
0.2
0.2
0.3
0.3
44
1.2
1.0
1.0
1.2
1.2
199
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
505
421
21
505
25
Toluene
425
355
18
425
21
Ethylbenzene
0
0
0
0
0
Xylene
182
152
8
182
9
n -Hexane
3791
3159
158
3791
190
224 TMP
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XII.C, D, E, F
Storage tank is subject to Regulation 7, Section XII.C-F
Regulation 7, Section XII.G, C
Storage Tank is not subject to Regulation 7, Section XII.G
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation 8, Part E, MACT Subpart HH
Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
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Condensate Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
No
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? This sample should be considered representative which generally means site -specific and
collected within one year of the application received date. However, if the facility has not been modified (e.g., no
new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
007
Process #
01
SCC Code
Pollutant
PM10
PM2.5
2.5
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Uncontrolled
Emissions
Factor
0.00
0.00
0.01
5.8
0.06
0.01
0.01
0.00
0.00
0.10
0.00
Control %
0
0
0
95
0
95
95
95
95
95
95
Units
lb/1,000 gallons condensate throughput
lb/1,000 gallons condensate throughput
lb/1,000 gallons condensate throughput
Ib/1,000 gallons condensate throughput
lb/1,000 gallons condensate throughput
Ib/1,000 gallons condensate throughput
lb/1,000 gallons condensate throughput
lb/1,000 gallons condensate throughput
lb/1,000 gallons condensate throughput
lb/1,000 gallons condensate throughput
lb/1,000 gallons condensate throughput
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Condensate Tank Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is 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 II.D.1.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
Not enough information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D-l.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Yes
No
Yes
Source requires a permit
Colorado Regulation 7, Section XII.C-F
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station?
3. Is this storage tank located upstream of a natural gas processing plant?
Yes
Yes
Yes
Storage tank is subject to Regulation 7, Section XII.C
Section XII.C.1 -General Requirements for Air Pollution Control Equipment - Prevention of Leakage
Section XII C.2 - Emission Estimation Procedures
Section XII D - Emissions Control Requirements
Section XII E - Monitoring
Section XII.F - Recordkeeping and Reporting
Colorado Regulation 7, Section XII.G
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at a natural gas processing plant?
3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC?
Yes
No
NA
Storage Tank is not subject to Regulation 7, Section XII.G
Section XII.G.2 - Emissions Control Requirements
Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage
Section XII.C.2 - Emission Estimation Procedures
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility], natural gas compressor stations or natural gas processing plant?
3. Is this condensate storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC?
No
Yes
Yes
Yes
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Section XVII.B - General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1 - Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5. Does the condensate storage tank contain only "stabilized" liquids?
No
Storage tank is subject to Regulation 7, Section XVII.C.2
Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipmen:
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (ms) ['472 BBLs]?
2. Does the storage vessel meet the following exemption in 60.111 b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.874 m' ['10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfers as defined in 60.111b?
3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984?
4. Does the tank meet the definition of "storage vessel"' in 60.11lb?
5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.111 b?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa (`29.7 psi and without emissions to the atmosphere (60.11ob(d)(2))?; or
b. The design capacity is greater than or equal to 151 m' l-950 BBL] and stores a liquid with a maximum true vapor pressure' less than 35 kPa (60.110b(b))?; or
c. The design capacity is greater than or equal to 75 M' ("472 BBL] but less than 151 ms ["'95C BBL] and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.11ob(b))?
No
Source Req
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Source Req
Continue
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Source is su
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Storage Tar
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Source is su
Source is su
Storage Tar
Storage Tank is not subject to NSPS K
b
Subpart A, General Provisions
§60.112b - Emissions Control Standards for VOC
§60.113b - Testing and Procedures
§60.115b - Reporting and Recordkeeping Requirements
§60.116b - Monitoring of Operations
40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions] from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430?
5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 4C CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH?
Storage Tank is not subject to NSPS 00
JO
Subpart A, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§60.5395(g) - Notification, Reporting and Recordkeeping Requirements
§60.5416(c) - Cover and Closed Vent System Monitoring Requirements
§60.5417 - Control Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if
potential VOC emissions drop below 6 tons per yearl
40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids] (63.760(a)(2)); OR
b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gzs enters the natural gas transmission and storage source category or is delivered to a final end user" (63.760(a)(3))?
2. Is the tank located at a facility that is major' for HAPs?
3. Does the tank meet the definition of "storage vessel"" in 63.761?
4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
re;
No
Storage Tank is not subject to MAC HH
Subpart A. General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitoring
§63.774 - Recordkeeping
§63.775 - Reporting
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations This document is not
a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation.
or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations.
and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend.' "may. " 'should. ' and 'can.' is intended to
describe APCD interpretations and recommendations. Mandatory terminology such as 'must' and 'required' are intended to describe controlling requirements under the terms of the Clean Air Act and Air
Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Continue -
Storage Tar
Continue-'
Storage Tar
Produced Water Storage Tank(s) Emissions Inventory
008 Produced Water Tank
Facility AIRs ID:
123
County
9F9A
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
2x400bbl produced water storage vessels
ECD
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Produced Water Throughput =
387,399 Barrels (bbl) per year
Actual Produced Water Throughput While Emissions Controls Operating =
Requested Permit Limit Throughput = 464,879 Barrels (bbl) per year
Requested Monthly Throughput =
39433 Barrels (bbl) per month
Potential to Emit (PTE) Produced Water
Throughput =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas =
Volume of waste gas emitted per BBL of
liquids produced =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
464,879 Barrels (bbl) per year
1496 Btu/scf
36
scf/bbl
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
20,864 MMBTU per year
25,037 MMBTU per year
25,037 MMBTU per year
Emission Factors
Produced Water Tank
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Produced Water
Throughput)
(Produced
Water
Throughput)
VOC
0.262
0.01
Benzene
0.007
0.000
Toluene
0.000
Ethylbenzene
0.000
Xylene
0.000
P .. : ;
n -Hexane
0.022
0.001
224 TMP
0.000
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (lb/bbl)
(waste heat
combusted)
(Produced
Water
Throughput)
PM10
0.0000
AP -47 C s:apter 1.3.5 industrial Mares (Nexi
I5 c, ' flares (CC)
PM2.5
0.0000
NOx
0.0680
0.0037
CO
0.3100
0.0167
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)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
PM10
PM2.5
NOx
CO
60.9
50.7
2.5
60.9
3.0
517
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.9
0.7
0.7
0.9
0.9
145
3.9
3.2
3.2
3.9
3.9
659
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
3254
2712
136
32.54
163
0
0
0
0
0
Ethylbenzene
0
0
0
0
0
Xylene
0
0
0
0
0
n -Hexane
10227
8523
426
10227
511
224 TMP
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
387,399
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
(See regulatory applicability worksheet for detailed analysis)
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Produced Water Storage Tank(s) Emissions Inventory
Section 07- Initial and Periodic Sampling and Testing Requirements
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn
at the facility being permitted and analyzed using flash liberation analysis? This sample shculd be considered
representative which generally means site -specific and collected within one year of the application received date.
However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to
use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
008
Process # SCC Code
01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons liquid throughput
PM2.5 0.00 0 lb/1,000 gallons liquid throughput
NOx 0.09 0 lb/1,000 gallons liquid throughput
VOC 6.2 95 lb/1,000 gallons liquid throughput
CO 0.40 0 lb/1,000 gallons liquid throughput
Benzene 0.17 95 lb/1,000 gallons liquid throughput
Toluene 0.00 95 lb/1,000 gallons liquid throughput
Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput
Xylene 0.00 95 lb/1,000 gallons liquid throughput
n -Hexane 0.52 95 lb/1,000 gallons liquid throughput
224 TMP 0.00 95 lb/1,000 gallons liquid throughput
7 of 23 K:\PA\2018\18WE0112 18WE0113 18WE0114 18WE0115 18WE0116.CP1.xlsm
Produced Water Storage Tank Regulatory Analysis Worksheet
Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb.
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is 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 II.D.1.a)?
2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source is in the Non -Attainment Area
Yes
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Source requires a permit
No
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this produced water storage tank? located at an oil and gas exploration and production operation , well production facility?, natural gas compressor station3 or natural gas processing plant?
3. Is this produced water storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions° of this storage tank equal to or greater than 6 tons per year VOC?
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Yes
Yes
Yes
Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1 - Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply.
Yes
Ns
Storage tank is subject to Regulation 7, Section XVII.C.2
Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions2 from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430?
Storage Tank is not subject to NSPS OOOO
Yes
Ns
Subpart A, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§60.5395(g) - Notification, Reporting and Recordkeeping Requirements
§60.5416(c) - Cover and Closed Vent System Monitoring Requirements
§60.5417 - Control Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2)
even if potential VOC emissions drop below 6 tons per year]
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations_ This
document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or
substitute for any law. regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the
Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as
'recommend," "may," "should, "and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling
requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Source Req
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Source Req
Continue -
Continue -
Go to the n
Source is sl
Source is st
Continue -
Storage Tar
Separator Venting Emissions Inventory
009 Separator Venting
Facility AIRs ID:
County
9F9A
Plant
009
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
HP Separator Venting
Questar/Q5000 ECD requesting 98% control
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Natural Gas Vented
Yes, meter is currently I ta! r mod oceratio ;I
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
61.5 MMscf per year
98
Requested Permit Limit Throughput =
76.0
MMscf per year
Requested Monthly Throughput =
6 MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
76 MMscf per year
Yes
Yes
Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare)
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04 - Emissions Factors & Methodologies
Description
1394 Btu/scf
scf/bbl
MW
24.0332
Weight %
Helium
0.00
CO2
3.29
N2
0.48
methane
45.10
ethane
19.15
propane
17.31
isobutane
2.50
n -butane
6.81
isopentane
1.42
n -pentane
1.68
cyclopentane
0.11
n -Hexane
0.41
cyclohexane
0.11
Other hexanes
0.68
heptanes
033
methylcyclohexane
0.11
224-TMP
0.00
Benzene
0.05
Toluene
0.05
Ethylbenzene
0.01
Xylenes
0.03
C8+ Heavies
0.37
Total
100.00
VOC Wt %
31.9
Ib/Ib-mol
Displacement Equation
Ex=Q*MW*Xx/C
I mission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
Emission Factor Source
(lb/MMscf) (Ib/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
20279.2015
405.5840
Benzene
31.7061
0.6341
Toluene
31.7061
0.6341
Ethylbenzene
6.3412
0.1268
Xylene
19.0236
0.3805
n -Hexane
259.9898
5.1998
224 TMP
0.0000
0.0000
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM 10
0.000
PM2.5
0.000
SOx
0.000
NOx
94.792
9 of 23 K:\PA\2018\18WE0112 18WE0113 18WE0114 18WE0115 18WE0116.CP1.xlsm
Separator Venting Emissions Inventory
CO
I 0.3100
I
432.140
10 of 23 K:\PA\2018\18WE0112 18WE0113 18WE011418WE011S 18WE0116.CP1.xlsm
Separator Venting Emissions Inventory
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)
Requested Monthly Limits
Controlled
(Ibs/month)
P M 10
P M 2.5
SOx
NOx
VOC
CO
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
3.60
2.92
2.92
3.60
3.60
612
770.51
623.89
12.48
770.51
15.41
2618
16.42
13.29
13.29
16.42
16.42
2789
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
2409
1951
39
2409
48
Toluene
2409
1951
39
2409
48
Ethylbenzene
482
390
8
482
10
Xylene
1446
1171
23
1446
29
n -Hexane
19757
15997
320
19757
395
224 TM P
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
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 90 tons per year?
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.
Nc'
-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 will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on
inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.
andT ! r 4 t `Gf f,„ i;r , .. t 'ri 'n -r:!','+ -it
{ct -; \. �.. l.•:;S�h., mil. !.�l tai, �c'�fi �.
11 of 23 K:\PA\2018\18WE0112 18WE0113 18WE0114 18WE011S 18WE0116.CP1.xlsm
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
009
Process # SCC Code
01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 Ib/MMSCF
PM2.5 0.00 0 Ib/MMSCF
SOx 0.00 0 Ib/MMSCF
NOx 94.79 0 lb/MMSCF
VOC 20279.20 98 Ib/MMSCF
CO 432.14 0 Ib/MMSCF
Benzene 31.71 98 lb/MMSCF
Toluene 31.71 98 Ib/MMSCF
Ethylbenzene 6.34 98 Ib/MMSCF
Xylene 19.02 98 lb/MMSCF
n -Hexane 259.99 98 Ib/MMSCF
224 TMP 0.00 98 Ib/MMSCF
12 of 23 K:\PA\2018\18WE0112 18WE0113 18WE0114 18WE0115 18WE0116.CP1.xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Sluice is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrclled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total fac ity uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TP`' or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
Not enough information
Yes
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greate- than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total faci ity uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Yes
Source requires a permit
Colorado Regu at ion 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
Yes
Source is subject to Regulation 7, Section XVII.B.2, G
Section XVII.B.2 —General Provisions for Air Pollution Control Equipment and Prevention D Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., rot the primary control device) that is not enclosed?
The control device for this separator is not subject to Regulation 7, Section ) VII.B.2.e
Section XVII.B.2.e —Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of cedar? 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 regulaticns, but this document does not establish legally binding requirements in and of itself.
Source Req
Source Req
Source is s�
The control
Separator Venting Emissions Inventory
010 Separator Venting
Facility AIRs ID:
-',
County
SF£' .t
Plant
010
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
LP Separator Venting
ECD; Questor/Q5000; 98% control requested
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Natural Gas Vented
\'c s, meter current!, )staffed and operational
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
12.0 MMscf per year
98
Requested Permit Limit Throughput =
14.4 MMscf per year
Requested Monthly Throughput =
1
MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
14 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:
Section 04 - Emissions Factors & Methodologies
Description
1943 Btu/scf
scf/bbl
MW
34.3986
Weight %
Helium
0.00
CO2
2.41
N2
0.25
methane
16.69
ethane
20.25
propane
27.75
isobutane
4.44
n -butane
13.11
isopentane
3.18
n -pentane
4.24
cyclopentane
C
n -Hexane
1.35
cyclohexane
0.37
Other hexanes
0.00
heptanes
1.16
methylcyclohexane
2.74
224-TMP
0.00
Benzene
0.18
Toluene
0.13
Ethylbenzene
0.02
Xylenes
0.07
C8+ Heavies
1.23
Total
99.93
VOC Wt %
60.33
Ib/Ib-mol
Displacement Equation
Ex = Q * MW * Xx / C
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
Emission Factor Source
(lb/MMscf)
(Ib/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
54756.9822
1095.1396
Benzene
160.6632
3.2133
Toluene
163.8907
3.2778
Ethylbenzene
16.7115
0.3342
Xylene
66.0105
1.3202
n -Hexane
1222.8748
24.4575
224 TMP
0.5994
0.0120
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
0.000
•. A.
- .
- x....:.;
PM2.S
0.000
SOx
0.000
NOx
0.0680
132.464
14 of 23 K:\PA\2018\18WE0112 18WE0113 18WE0114 18WE011S 18WE0116.CP1.xlsm
Separator Venting Emissions Inventory
I
CO
I
0.3100
I 603.8S0
AP -42 Chapter 133 Industrial flares (CO)'
15 of 23 K:\PA\2018\18WE0112 18WE0113 18WE0114 18WE0115 18WE0116.CP1.xlsm
Separator Venting Emissions Inventory
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)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5 2.5
SOx
NOx
VOC
CO
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.96
0.80
0.80
0.96
0.96
162
395.35
329.36
6.59
395.35
7.91
1343
4.36
3.63
3.63
4.36
4.36
741
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TM P
2320
1933
39
2320
46
2367
1972
39
2367
47
241
201
4
241
5
953
794
16
953
19
17658
14711
294
17653
353
9
7
0
9
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
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 factcrs established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contair:
-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? Yes
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on
inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.
16 of 23 K:\PA\2018\18WE0112 18WE0113 18WE0114 18WE0115 18WE011S.CP1.xlsm
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
Section 09 - Inventory 5CC Coding and Emissions Factors
AIRS Point #
010
Process # SCC Code
01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 Ib/MNSCF
PM2.5 0.00 0 Ib/MNSCF
SOx 0.00 0 lb/MN/SCE
NOx 132.46 0 Ib/MNSCF
VOC 54756.98 98 Ib/MNSCF
CO 603.88 0 Ib/MMSCF
Benzene 160.66 98 Ib/MNSCF
Toluene 163.89 98 lb/MMSCF
Ethylbenzene 16.71 98 Ib/MMSCF
Xylene 66.01 98 Ib/MMSCF
n -Hexane 1222.87 98 Ib/MMSCF
224 TMP 0.60 98 Ib/MMSCF
17 of 23 K:\PA\2018\18WE0112 18WE0113 18WE0114 18WE0115 18WE0116 CP1.xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
S3urc•- I; in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled ac-ual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TP" or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
Not enough information
Yes
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greate• than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Source requires a permit
Colorado Regulation 7, Section XVII
1. Was the well newly :onstructed, hydraulically fractured, or recompleted on or after August 1, 2014?
Yes
Source is subject to Regulation 7, Section XVII.B.2, G
Section XVII.B.2 —General Provisions for Air Pollution Control Equipment and Prevention 3f Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., rot the primary control device) that is not enclosed?
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
Section XVII.B.2.e — Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rue 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 Req
Source Req
Source is Sl
The control
Separator Venting Emissions Inventory
011 Separator Venting
facility AIRs ID:
County
9F9A
Plant
011
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
VRT
ECD; Questor/Q5000; 98% control requested
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Natural Gas Vented
Yes, meter is bur! ently installed and operational
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
3.3 MMscf per year
98
Requested Permit Limit Throughput =
4.1
MMscf per year
Requested Monthly Throughput =
0 MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
4 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:
Section 04- Emissions Factors & Methodologies
Description
2621 Btu/scf
scf/bbl
MW
Weight %
Helium
0.00
CO2
0.80
N2
0.07
methane
3.40
ethane
11.83
propane
32.40
isobutane
7.10
n -butane
22.19
isopentane
5.84
n -pentane
7.25
cyclopentane
0.50
n -Hexane
1.82
cyclohexane
0.44
Other hexanes
heptanes
1.19
methylcyclohexane
3.86
224-TMP
0.01
Benzene
0.23
Toluene
0.16
Ethylbenzene
0.01
Xylenes
0.04
C8+ Heavies
0.84
Total
99.93
VOC Wt %
83.88
Ib/Ib-mol
Displacement Equation
Ex=Q*MW*Xx/C
Emission Factors
Separator Venting
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/MMscf) (lb/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
102691.8544
2053.8371
Benzene
278.4146
5.5683
Toluene
196.4655
3.9293
Ethylbenzene
12.5300
0.2506
Xylene
48.1653
0.9633
n -Hexane
2224.2170
44.4843
224 TMP
11.9337
0.2397
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(Ib/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
i
P M 10
0.000
Other • Explain
PM2.5
0.000
SOx
0.000
NOx
C. C
172.986
19 of 23 K:\PA\2018\18WE0112 18WE0113 18WE0114 18WE0115 18WE0116 CP1.xlsm
Separator Venting Emissions Inventory
I Co
0.0500
I
131.050
I
•s'
20 of 23 K:\PA\2018\18WE0112 18WE0113 18WE0114 18WE0115 18WE0116 CP1.xlsm
Separator Venting Emissions Inventory
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)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.36
0.29
0.29
0.36
0.36
60
211.34
171.08
3.42
211.34
4.23
718
0.27
0.22
0.22
0.27
0.27
46
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
Ohs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (Ibs/year)
Benzene
1146
928
19
1146
23
Toluene
809
655
13
809
16
Ethylbenzene
52
42
1
52
1
Xylene
1.98
160
3
198
4
n -Hexane
9155
7411
143
9155
183
224 TM P
49
40
1
49
1
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
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 90 tons per year? No
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 a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on
inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.
Yes
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Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
NOx and CO emission factors requested from manufacturer specification.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
011
Process # SCC Code
01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/MMSCF
PM2.5 0.00 0 lb/MMSCF
SOx 0.00 0 Ib/MMSCF
NOx 172.99 0 Ib/MMSCF
VOC 102691.85 98 lb/MMSCF
CO 131.05 0 lb/MMSCF
Benzene 278.41 98 lb/MMSCF
Toluene 196.47 98 lb/MMSCF
Ethylbenzene 12.53 98 Ib/MMSCF
Xylene 48.17 98 lb/MMSCF
n -Hexane 2224.22 98 lb/MMSCF
224 TMP 11.98 98 Ib/MMSCF
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Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is 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 II.D.1.a)?
2. Are total facility unccntrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
Not enough information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Yes
Yes
Source requires a permit
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
Yes
Source k subject to Regulation 7, Section XVlI.B.2, G
Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention o= Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
The control device for this separator is not subject to Regulation 7, Section XEII.B.2.e
Section XVII.B.2.e —Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its
implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend." "may.'
"should." and "can," is intended to describe APCD interpretations and recommendations Mandatory terminology such as 'must" and 'required" are intended to describe controlling requirements under the
terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Source Req
Source Req
Source is st.
The control
COLORADO
Air Pollution Control Division
Department of Public Heath & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
18WE0112 Issuance: 1
Extraction Oil &t Gas, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Windsor LV2 Production Facility
123/9F9A
SESE SEC 14 T6N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
007
Eight (8) 400 barrel fixed roof storage
vessels used to store condensate
Enclosed Flare
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 the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can, result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
Page 1 of 8
COLORADO
Air Pollution Control Division
Department of Public Health E+ Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
I. F.4. )
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOx
VOC
CO
007
-
0.3
5.8
1.0
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The emission points in the table below shall 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.)
Page 2 of 8
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
007
Enclosed Flare
VOC; HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall 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
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
007
Condensate
Throughput
947,630 barrels
The owner or operator shall monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all
applicable requirements of Section XII and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for condensate storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Section XII.C.) (State only enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
Page 3 of 8
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; 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 following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate 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 except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.C.1.d. and maintain records of the inspections for a period of two years, made available
to the Division upon request. This control requirement must be met within 90 days of the date
that the storage tank commences operation.
14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING Et MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (0&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&M 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
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen -minute period during normal
operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
Page 4 of 8
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall 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 (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For, sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
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.
GENERAL TERMS AND CONDITIONS
19. 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.
20. 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
Page 5 of 8
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
21. 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.
22. 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.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the 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.
24. 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.
25. 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:
Timothy Sharp
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil Et Gas, Inc.
Page 6 of 8
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(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 shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in 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 source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
Benzene
71432
421
22
007
Toluene
108883
355
18
n -Hexane
110543
3161
159
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:
Point 007
CAS #
Pollutant
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
N0x
0.068
AP -42
CO
0.310
AP -42
V0C
0.244
Promax
71432
Benzene
5.33E-04
Promax
108883
Toluene
4.49E-04
Promax
110543
n -Hexane
4.00E-03
Promax
Page 7 of 8
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 shall be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, NOx, CO, HAPs
NANSR
Synthetic Minor Source of: VOC, NOx
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart 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 Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
18WE0113 Issuance: 1
Extraction Oil Et Gas, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Windsor LV2 Production Facility
123/9F9A
SESE SEC 14 T6N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
008'
Two (2) 400 barrel fixed roof storage
vessels used to store produced water
Enclosed Flare
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 the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
Page 1 of 8
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
I. F.4. )
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
008
-
0.9
3.1
3.9
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The emission points in the table below shall 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.)
Page 2 of 8
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
008
Enclosed Flare
VOC; HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall 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
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
008
Produced Water
Throughput
464879 barrels
,
The owner or operator shall monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-monthtotal is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all
applicable requirements of Section XII and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for condensate storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Section XII.C.) (State only enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
Page 3 of 8
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; 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 following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate 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 except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.C.1.d. and maintain records of the inspections for a period of two years, made available
to the Division upon request. This control requirement must be met within 90 days of the date
that the storage tank commences operation.
14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING a MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (OEM) 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 O&M 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
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen -minute period during normal
operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
Page 4 of 8
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall 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 (NO,) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
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.
GENERAL TERMS AND CONDITIONS
19. 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.
20. 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
Page 5 of 8
COLORADO
Air Pollution Control Division
Department or Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
21. 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.
22. 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.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the 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.
24. 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.
25. 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:
Timothy Sharp
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil Et Gas, Inc.
Page 6 of 8
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(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 shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated inthis
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 source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
008
Benzene
71432
2712
136
n -Hexane "
110543
8523
426
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:
Point 008
CAS #
Pollutant
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
0.068
AP -42
CO
0.310
AP -42
VOC
0.262
State EF
71432
Benzene
0.007
State EF
110543
n -Hexane
0.022
State EF
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Page 7 of 8
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN shall be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, NOx, CO, HAPs
NANSR
Synthetic Minor Source of: VOC, NOx
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart 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 Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
18WE0114 Issuance: 1
Extraction Oil Et Gas, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Windsor LV2 Production Facility
123/9F9A
SESE SEC 14 T6N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
HP SEP
009
High Pressure Separator
Enclosed Flare
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. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
compliance as required by this permit may be obtained online at www.colorado.Rov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
I. F.4. )
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone, does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO),
VOC
CO
HP SEP
009
-
3.6
15.4
16.5
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to
calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The emission points in the table below shall 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.)
Page 2 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
HP SEP
009
Emissions from the Separator are routed
to an Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall 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
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
HP SEP
009
Natural Gas Venting
76.0 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural
gas vented from the separator(s) using the flow meter. The owner or operator shall 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
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.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 XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; 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 following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Pubic Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only).
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 date of first production 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.
OPERATING Ft MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the OEtM 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
15. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17)
16. A source initial compliance test shall be conducted to measure the emission rate for volatile
organic compounds (VOC) in order to demonstrate compliance with a minimum destruction
efficiency of 98% for VOCs. The test shall determine the mass emission rates of volatile organic
compounds at the inlet and outlet of the control device, which shall be used to determine the
destruction efficiency during the test.
The test protocol must be in accordance with the requirements of the Air Pollution Control
Division Compliance Test Manual and shall be submitted to the Division for review and approval
at least thirty (30) days prior to testing. No compliance test shall be conducted without prior
approval from the Division. (Regulation Number 3, Part B., Section III.G.3)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
Page 4 of 9
COLORADO
Air Pollution Control Division
Department of Pubirc Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
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.
GENERAL TERMS AND CONDITIONS
19. 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.
20. 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.
21. 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 9
COLORADO
Air Pollution Control Division
Department of Pubtc Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
22. 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.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the 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.
24. 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.
25. 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:
Timothy Sharp
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil 8 Gas, Inc.
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(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 shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: 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 source(s) operate at the permitted
limitations.
Facility
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
HP SEP
009
Benzene
71432
2629
53
Toluene
108883
2546
51
Ethylbenzene
100414
298
6
Xylenes
1330207
1403
28
n -Hexane
110543
19936
399
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:
Point 009:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
NOx
0.068
AP -42
CO
0.310
AP -42
Page 7 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
VOC
20259.18
405.18
Source (Promax)
71432
Benzene
34.59
0.6918
Source (Promax)
108883
Toluene
33.51
0.6702
Source (Promax)
100414
Ethylbenzene
6.3412
0.126824
Source (Promax)
1330207
Xylene
18.47
0.3694
Source (Promax)
110543
n -Hexane
262.35
5.247
Source (Promax)
Note: The controlled emissions factors for this point are based on the flare control efficiency of
98%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN shall be submitted no later than 30 days before the five-year term expires. Please
refer to the most, recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, NOx, CO, HAPs
Synthetic Minor Source of: VOC, NOx
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart 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
Page 8 of 9
MACT
COLORADO
Air Pollution Control Division
Department of Pubfrc Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 9 of 9
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
18WE0115 Issuance: 1
Extraction Oil Ft Gas, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Windsor LV2 Production Facility
123/9F9A
SESE SEC 14 T6N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
LP SEP
010
Low Pressure Separator
Enclosed Flare
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. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of r
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Pubiic Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4. )
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation ! Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,t
VOC
CO
LP SEP
010
---
1.0
8.0
4.4
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to
calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The emission points in the table below shall 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.)
Page 2 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
e
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
LP SEP
010
Emissions from the Separator are routed
to an Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall 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
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
LP SEP
010
Natural Gas Venting
14.5 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural
gas vented from the separator(s) using the flow meter. The owner or operator shall 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
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.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 XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; 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 following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only).
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 date of first production 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.
OPERATING £t MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O8:M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&M 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
15. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B2. and XVII.A.17)
16. A source initial compliance test shall be conducted to measure the emission rate for volatile
organic compounds (VOC) in order to demonstrate compliance with a minimum destruction
efficiency of 98% for VOCs. The test shall determine the mass emission rates of volatile organic
compounds at the inlet and outlet of the control device, which shall be used to determine the
destruction efficiency during the test.
The test protocol must be in accordance with the requirements of the Air Pollution Control
Division Compliance Test Manual and shall be submitted to the Division for review and approval
at least thirty (30) days prior to testing. No compliance test shall be conducted without prior
approval from the Division. (Regulation Number 3, Part B., Section III.G.3)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
Page 4 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 (NOr) 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
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.
GENERAL TERMS AND CONDITIONS
19. 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.
20. 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.
21. 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 9
COLORADO
Mr Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
22. 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.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the 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.
24. 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.
25. 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:
Timothy Sharp
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil &t Gas, Inc.
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of Pubic Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(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 shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
pen -nit 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 source(s) operate at the permitted
limitations.
Facility
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
LP SEP
010
Benzene
71432
2320
46
Toluene
108883
2367
47
Ethylbenzene
100414
241
5
Xylenes
1330207
953
19
n -Hexane
110543
17658
353
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:
Point 010:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
NOx
0.068
AP -42
CO
0.310
AP -42
Page 7 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
VOC
54756.9822
1095.1396
Source (Promax)
71432
Benzene
160.6632
3.2133
Source (Promax)
108883
Toluene
163.8907
3.2778
Source (Promax)
1330207
Xylene
66.0105
1.3202
Source (Promax)
110543
n -Hexane
1222.8748
24.4575
Source (Promax)
Note: The controlled emissions factors for this point are based on the flare control efficiency of
98%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN shall be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, NOx, CO HAPs
NANSR
Synthetic Minor Source of: VOC, NOx
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart 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 9
COLORADO
Air Pollution Control Division
Department of Public Health $ Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Page 9 of 9
COLORADO
Air Pollution Control Division
Department of Public Heath & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 18WE0116
Date issued:
Issued to:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Extraction Oil Et Gas, Inc.
Windsor LV2 Production Facility
123/9F9A
SESE SEC 14 T6N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
VRT SEP
011
Vapor Recovery Tower
Enclosed Flare
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. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Pubic Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4. )
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by. the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO),
VOC
CO
VRT SEP
011
---
0.4
4.3
0.3
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to
calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shalt not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The emission points in the table below shall be operated and maintained with the emissions ,I
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.)
Page 2 of 9
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
VRT SEP
011
Emissions from the Separator are routed
to an Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall 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
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
VRT SEP
011
Natural Gas Venting
4.2 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural
gas vented from the separator(s) using the flow meter. The owner or operator shall 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
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) I. E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.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 XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; 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 following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Public Heath & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only).
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 date of first production 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.
OPERATING Et MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall 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 O&M 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
15. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B2. and XVII.A."17)
16. A source initial compliance test shall be conducted to measure the emission rate for volatile
organic compounds (VOC) in order to demonstrate compliance with a minimum destruction
efficiency of 98% for VOCs. The test shall determine the mass emission rates of volatile organic
compounds at the inlet and outlet of the control device, which shall be used to determine the
destruction efficiency during the test.
The test protocol must be in accordance with the requirements of the Air Pollution Control
Division Compliance Test Manual and shall be submitted to the Division for review and approval
at least thirty (30) days prior to testing. No compliance test shall be conducted without prior
approval from the Division. (Regulation Number 3, Part B., Section III.G.3)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
Page 4 of 9
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division
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.
GENERAL TERMS AND CONDITIONS
19. 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.
20. 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.
21. 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 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
22. 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.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the 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.
24. 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.
25. 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:
Timothy Sharp
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil Et Gas, Inc.
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(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 shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part'II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
Facility
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
VRT SEP
011
Benzene
71432
1146
23
Toluene
108883
809
16
n -Hexane
110543
9155
183
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:
Point 011:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
NOx
0.066
Manufacturer
CO
0.050
Manufacturer
VOC
102691.8544
2053.8371
Source (Promax)
71432
Benzene
278.4146
5.5683
Source (Promax)
108883
Toluene
196.4655
3.9293
Source (Promax)
Page 7 of 9
COLORADO
Air Pollution Control Division
Department of Pubiic Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
110543
n -Hexane
2224.2170
44.4843
Source (Promax)
Note: The controlled emissions factors for this point are based on the flare control efficiency of
98%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN shall be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Operating Permit
Synthetic Minor Source of: VOC, NOx, CO, HAPs
NANSR
Synthetic Minor Source of: VOC, NOx
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart 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 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Page 9 of 9
cuperv,dea- 4PE/J A * c \ Re e,v W26 // g
Sao c0 >✓3
FEB 12r*%
i
Condensate Storage Tank(s) APEN
Form APCD-205
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. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, 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 and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.Rov/pacific/cdphe/air-permits.
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:
I8WEa//z
AIRS ID Number: /23 /qP:1A / QQ`r
�j<<itixi,.�ll
Cc e
[Leave blank unless APCD has already assigned a permit , and AIRS ID)
Section 1 - Administrative Information
Company Name': Extraction Oil & Gas, Inc.
Site Name: Windsor LV2 Production Facility
Site Location: SESE SEC14 T6N R67W
Mailing Address:
(Include Zip Code) 370 17th Street, Suite 5300
Denver, Colorado
Site Location
County: Weld
NAICS or SIC Code: 211111
Permit Contact: Kathy Steerman
Phone Number: (720) 974-7765
E -Mail Address2: KSteerman@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.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
�j
CRL4R4 DO
1 I A.
4
Permit Number: AIRS ID Number:
[Leave blank unless A?CD has already assigned a permit r and AIRS ID]
Section 2 - Requested Action
✓❑ NEW permit OR newly -reported emission source
✓❑ Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $250 must be
submitted along with the APEN filing fee.
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
El Change in equipment ❑ Change company name
❑ Change permit limit El Transfer of ownership3 O Other (describe below)
- OR
• APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 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:
For existing sources, operation began on:
Eight (8) - 400 bbl Condensate Storage Vessels
For new or reconstructed sources, the projected start-up date is: 11/04/2017
Normal Hours of Source Operation: 24
hours/day 7 days/week 52
Storage tank(s) located at: ❑✓ Exploration a Production (E&P) site
weeks/year
O Midstream or Downstream (non E&P) site
Will this equipment be operated in any NAAQS nonattainment area?
0
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
El
Yes
IN
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
GI
Yes
■
No
If "yes", identify the stock tank gas -to -oil ratio:
0.0010
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
0
■
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
0
•
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07.2017
cataR ADD
2 l men
ltca'vl:h Cn:ro�menv:
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit ti and AIRS ID]
Section 4 - Storage Tank(s) Information
Condensate Throughput:
Actual Annual Amount
(bbl/yeor)
1,312,638
From what year is the actual annual amount? Projected
Average API gravity of sales oil: 47.1 degrees
O Internal floating roof
Tank design: ❑✓ Fixed roof
Requested Annual Permit Limit4
(bbl/year)
1,575,166
RVP of sales oil: 11.45
❑ External floating roof
Storage
Tank ID
it of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
TK-0O7 - TK-008
8
3200
11/2017
11/2017
Wells Serviced by this Storage Tank or Tank Battery5 (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
- -
See Form APCD-212
■
- -
•
_
■
_
■
- -
•
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.481878°, -104.852464°
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
ECD
-15
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
❑r Upward
O Horizontal
Indicate the stack opening and size: (check one)
ID Circular
O Square/rectangle
❑ Other (describe):
O Upward with obstructing raincap
Interior stack diameter (inches): 48
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 07/2017 3
COLORADO
ixiry,!rn:+l HAic
11.41, 6 try ;rem mea,
Permit Number: AIRS ID Number:
[Leave blank unless A?CI7 has already assigned a permit it and AIRS ID)
Section 6 - Control Device Information
0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor
❑ Recovery
Unit (VRU):
Size: Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed (emissions vented): %
❑ Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating: TBD MMBtu/hr
Type: Two (2) ECDs Make/Model:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature: N/A
95 %
>98
IES-48
Waste Gas Heat Content: 2518 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr
O Closed Loop System
Description of the closed loop system:
O Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 -Gas/Liquids Separation Technology Information (EEP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —5 psig
Describe the separation process between the well and the storage tanks: HLP Separator, VRT,
Condensate Storage Tanks
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 07/2017
AIM,COLOR ADO
4 l r.tra e
�.euio- vv..rem.vice
ig
Permit Number:
AIRS ID Number:
[Leave blank unless A?CD has already assigned a permit /1 and MRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form6.
If multiple emission control methods were identified in Section 6, the following table can be used to state the overall
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
ECD
95%
NOx
CO
HAPs
ECD
95%
Other:
From what year is the following reported actual annual emissions data? Projected
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor&
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)4
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc) )
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions7
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
VOC
0.244
lb/bbl
Promax
159.94
8.00
191.93
9.60
NOx
0.068
Ib/MMBtu
AP -42
0.30
0.35
CO
0.31
Ib/MMBtu
AP -42
1.35
1.62
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor6
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
g
Uncontrolled
Emissions
Pounds/ ear
(Pounds/year) )
Controlled
Emissions7
(Pounds/year)
Benzene
71432
5.33E-04
lb/bbl
Promax
698.98
34.95
Toluene
108883
4.49E-04
lb/bbl
Promax
589.64
29.48
Ethylbenzene
100414
Xylene
1330207
1.92E-04
lb/bbl
Promax
252.03
12.60
n -Hexane
110543
4.00E-03
lb/bbl
Promax
5,253.18
262.66
2,2,4-
Trimethylpentane
540841
a Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 07/2017
Low COLORADO
5 I4;bra
Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit # and AIRS ID)
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is
and wilt be operated in full compliance with each condition of the applicable General Permit.
Signature of Legally Authorized Person (not a vendor or consultant) Date (J
Kathy Steerman
Air Quality Coordinator
Name (print)
Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
Q 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 $152.90 and the General Permit For more information or assistance call:
registration fee of $250, if applicable, to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-61
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
COLORADO
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 07/2017
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
Extraction Oil & Gas, Inc.
Source Name:
Windsor LV2 Production Facility
Emissions Source AIRS 1112:
N/A / 173 /9f1/4 /667
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 -123 - 44311
Windsor LV2 #1
1
05 -123 - 44307
Windsor LV2 #2
CI
05 -123 - 44312
Windsor LV2 #3
./
05 -123 - 44308
Windsor LV2 #4 .
05 -123 - 44309
Windsor LV2 #5
./
05 -123 - 44313
Windsor LV2 #6
/1
05 -123 - 44310
Windsor LV2 #7
./
05 -123 - 44314
Windsor LV2 #8
L
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
Footnotes:
1 Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
Form APCD-212
5. AP FormAPCD-212-EP-StorageTank-APEN-Addendum_20180130
Condensate Storage Tank(s) APEN -��z`
Form APCD-205 APCD
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. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, 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 and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/pacific/cdphe/air-permits.
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:
&We0l(2-
AIRS ID Number: I /gFiA/o07
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name1:
Site Name:
Extraction Oil & Gas, Inc.
Windsor LV2 Production Facility
Site Location: SESE SEC14 T6N R67W
Mailing Address:
(Include Zip Code) 370 17th Street, Suite 5300
Denver, Colorado
Site Location
County: Weld
NAICS or sic Code: 211111
Permit Contact: Catie Nelson
Phone Number:
E -Mail Address?:
(720) 354-4579
cneison@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.
? Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 1 I
COLORADO
nrp.,me.otor rauo
Heatmb Owvon.a1
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
✓❑ NEW permit OR newly -reported emission source
✓❑ Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $250 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment O Change company name
O Change permit limit 0 Transfer of ownership3 ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info & Notes:
3 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:
For existing sources, operation began on:
Eight (8) - 400 bbl Condensate Storage Vessels
For new or reconstructed sources, the projected start-up date is: 11/04/2017
Normal Hours of Source Operation: 24
hours/day 7 days/week 52
weeks/year
Storage tank(s) located at: ❑✓ Exploration Et Production (EEtP) site ❑ Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
O
•
Are Flash Emissions anticipated from these storage tanks?
Yes
No
•
•
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
Yes
No
El
•
If "yes", identify the stock tank gas -to -oil ratio:
0.0010
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
ig
■
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
D
■
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
c COLORADO
2 I tieff =7,==
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Condensate Throughput:
Actual Annual Amount
(bbl/year)
789,692
From what year is the actual annual amount?
Projected
Average API gravity of sales oil: 47.1 degrees
❑ Internal floating roof
Tank design: ❑✓ Fixed roof
Requested Annual Permit Limit4
(bbl/year)
947,630
RVP of sales oil: 11.45
O External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
TX-°°i - TK-008
8
3200
11/2017
11/2017
Wells Serviced by this Storage Tank or Tank Battery5 (EftP Sites On
y)
API Number
Name of Well
Newly Reported Well
-
See Form APCD-212
■
- -
■
_
■
■
- -
■
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
5 The EEP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.481878°, -104.852464°
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
ECD
-15
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
0 Horizontal
El Downward
0 Other (describe):
Indicate the stack opening and size: (check one)
Circular
0 Square/rectangle
0 Other (describe):
0 Upward with obstructing raincap
Interior stack diameter (inches): 48
Interior stack width (inches): Interior stack depth (inches):
COLORADO
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 3 I MV '"n""�"'°`"'m" �N tk6GNionwN
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
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.
Pollutants Controlled:
Vapor
O Recovery
Unit (VRU):
Size: Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed (emissions vented): %
❑ Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating: TBD MMBtu/hr
Type: Two (2) ECDs Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: >95
Minimum Temperature: N/A
ES -48
Waste Gas Heat Content: 2518 Btu/scf
Constant Pilot Light: ✓❑ Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr
❑ Closed Loop System
Description of the closed loop system:
O Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 -Gas/Liquids Separation Technology Information (E&tP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —5 psig
Describe the separation process between the well and the storage tanks: HLP Separator, VRT,
Condensate Storage Tanks
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
COLORADO
4jA,�o��
NCL@ b D�vacewnS
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form6.
If multiple emission control methods were identified in Section 6, the following table can be used to state the overall
(
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
V0C
ECD
95%
NOx
CO
HAPs
ECD
95%
Other:
From what year is the following reported actual annual emissions data? Projected
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor6
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)4
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions7
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
VOC
0.244
lb/bbl
Promax
96.22
4.81
115.47
5.77
NOx
0.068
Ib/MMBtu
AP -42
0.18
0.18
0.21
0.21
CO
0.31
lb/MMBtu
AP -42
0.8
0.8
0.96
0.96
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor6
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
etc)
)
Uncontrolled
Emissions
(Pounds/ ear
(Pounds/year)
)
Controlled
Emissions7
(Pounds/year)
Benzene
71432
5.33E-04
lb/bbl
Promax
420.51
21.03
Toluene
108883
4.49E-04
lb/bbl
Promax
354.73
17.74
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
4.00E-03
lb/bbl
Promax
3160.35
158.02
2,2,4-
Trimethylpentane
540841
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 5
AV
COLORADO
befanmaIcf Pub.
Hea:@b bevIalmsten!
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already as igned a permit It and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is
and will be operated in full compliance with each condition of the applicable General Permit.
Sig
of Legally 1,
Catie Nelson
uthorized
not a vendor or consultant)
Air Quality Engineer
Name (print)
Title
Check the appropriate box to request a copy of the:
Draft permit prior to issuance
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 $152.90 and the General Permit For more information or assistance call:
registration fee of $250, if applicable, 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
Telephone: (303) 692-3150
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-205 Condensate Storage Tank(s) AFEN - Revision 07/2017
6,, YI
COLORADO
OWM6EnNronrtau
Su 11P /961,0„440, 4� LJ - 2e tio,6/aeg�
Produced Water Storage Tank(s)
APEN - Form APCD-207
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. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, 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 and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.Rov/pacific/cdphe/air-permits.
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:
� gWE4P / 13 AIRS ID Number: /Z5 /cjru / bog
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name: Extraction Oil & Gas, Inc.
Site Name: Windsor LV2 Production Facility
Site Location: SESE SEC14 T6N R67W
Mailing (Include Address:
p Code)
370 17th Street, Suite 5300
Zip Codej
Denver, Colorado
Site Location
County: Weld
NAICS or SIC Code: 211111
Permit Contact: Kathy Steerman
Phone Number: (720),974-7765
E -Mail Address2: KSteerman@ExtractionOG.com
i 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 APCD via e-mail to the address provided.
SZ4-
Form APCD-207 - Produced Water Storage Tank(s) APEN Revision 07/2017
1 I ASV COLORADO
1==Z
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit i1 and AIRS IO]
Section 2 - Requested Action
El NEW permit OR newly -reported emission source
✓❑ Request coverage under traditional construction permit
O Request coverage under a General Permit
0 GP05 0 GP08
If General Permit coverage is requested, the General Permit registration fee of $250 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
O Change in equipment ❑ Change company name
❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Ft Notes:
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
IIg
Section 3 - General Information
General description of equipment and purpose:
For existing sources, operation began on:
Two (2) - 400 bbl Produced Water Storage Vessels
For new or reconstructed sources, the projected start-up date is: 11/04/2017
Normal Hours of Source Operation: 24
hours/day 7 days/week 52
Storage tank(s) located at: ❑✓ Exploration & Production (E&P) site
weeks/year
0 Midstream or Downstream (non E&P) site
Will this equipment be operated in any NAAQS nonattainment area?
GI
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
p
Yes
■
No
Are these storage tanks located at a commercial facility that accepts oil production
wastewater for processing?
Yes
No
•
0
Do these storage tanks contain less than 1% by volume crude oil on an annual average basis?
SI
Yes
I
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
0
■
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
SI
■
Form APCD-207 Produced Water Storage Tank(s) APEN Revision 07/2017
VriCOLORADO
2 i `>Ha2iai,e:nvrt<ews.,x
lo
`;y
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit it and AIRS ID]
Section 4 - Storage Tank(s) Information
Produced Water Throughput:
Actual Annual Amount
(bbl/year)
1,051,536
Requested Annual Permit Limits
(bbl/year)
1,261,844
From what year is the actual annual amount?
Tank design:
✓❑ Fixed roof
Projected
O Internal floating roof
❑ External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
PW-0ol & PW-002
2
800
11/2017
11/2017
Wells Serviced by this Storage Tank or Tank Battery5 (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
- -
See Form APCD-212
•
- -
•
■
.
■
- -
•
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
5 The EttP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.481878°, -104.852464°
Operator Stack
ID No.
Disciiiiite Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
ECD
—15
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
0 Upward 0 Downward
0 Horizontal
❑ Other (describe):
0 Upward with obstructing raincap
Indicate the stack opening and size: (check one)
❑r Circular Interior stack diameter (inches): 48
❑ Square/rectangle Interior stack width (inches):
❑ Other (describe):
Interior stack depth (inches):
Form APCD-207 Produced Water Storage Tank(s) APEN Revision 07/2017
COLORADO
3 4cr rlrvxre Klan
,:.,..;wus..cr,:n r
Io-
;lF
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit if and AIRS ID]
Section 6 - Control Device Information
O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor
❑ Recovery
Unit (VRU):
Size: Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
❑ Combustion
Device:
Pollutants Controlled: V0C/HAPs
Rating: TBD MMBtu/hr
Type: Two (2) ECDs Make/Model: I ES -48
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: >98
Minimum Temperature: N/A Waste Gas Heat Content: 1496 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr
❑ Closed Loop System
Description of the closed loop system:
O Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 -Gas/Liquids Separation Technology Information (E£tP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —52 psig
Describe the separation process between the well and the storage tanks: HLP Separator, Produced
Water Storage Tanks
Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 07/2017
AW.00L0RAD0
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit if and AIRS ID]
Section 8 - 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
(
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
ECD
95%
NOx
CO
HAPs
ECD
95%
Other:
Projected
From what year is the following reported actual annual emissions data?
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor6
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)4
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Tons/ ear )
Controlled
Emissions
(tons/year)
Uncontrolled
Emissions
(Tons/year)
(r ns/year)
Controlled
Emissions
(Tons/year)
VOC
0.262
lb/bbl
State EF
137.75
6.89
165.30
8.27
NOx
0.068
Ib/MMBtu
AP -42
1.93
2.31
CO
0.31
Ib/MMBtu
AP -42
8.78
10.53
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor6
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Pounds/year)
Controlled
Emissions
(Pounds/year)
Benzene
71432
0.007
lb/bbl
State EF
7,360.76
368.04
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.022
lb/bbl
State EF
23,133.80
1,156.69
2,2,4-
Trimethylpentane
540841
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific
emissions factors according to the guidance in PS Memo 14-03.
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD• 207 - Produced Water Storage Tank(s) APEN Revision 07/2017
COLORADO
5
rp
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is
and will be operated in full compliance with each condition of the applicable General Permit.
Signature of Legally Authorized Person (not a vendor or consultant) Date
Kathy Steerman
Air Quality Coordinator
Name (print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
0 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 $152.90 and the General Permit
registration fee of $250, if applicable, to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
Make check payable to: https://www.colorado.gov/cdphe/apcd
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017
COLORADO
6 sAV
"Yr'°..".�
Produced Water Storage Tank(s)
APEN - Form APCD-207
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. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, 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 and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/pacific/cdphe/air-permits.
Arty 26 2p19
i'CO
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: I go E 0113 AIRS ID Number: /23 / grgA/ oo?
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 Administrative Information
Company Name1: Extraction Oil & Gas, Inc.
Site Name: Windsor LV2 Production Facility
Site Location: SESE SEC14 T6N R67W
Mailing Address:
(include Zip Code) 370 17th Street, Suite 5300
Denver, Colorado
Site Location
County: Weld
NAICS or SIC Code: 211111
Permit Contact: Catie Nelson
Phone Number: (720) 354-4579
E -Mail Address2: cnelson@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.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 1 i
COLORADO
MAW> ciin'� en..1
Permit Number: AIRS ID Number:. / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
O NEW permit OR newly -reported emission source
• Request coverage under traditional construction permit
O Request coverage under a General Permit
❑ GP05 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $250 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
O Change in equipment O Change compahy name
❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
- OR
• APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes:
3 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:
For existing sources, operation began on:
Two (2) - 400 bbl Produced Water Storage Vessels
For new or reconstructed sources, the projected start-up date is: 11/04/2017
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week 52
weeks/year
0 Exploration It Production (EftP) site O Midstream or Downstream (non EftP) site
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
SI
I
Are Flash Emissions anticipated from these storage tanks?
Yes
No
si
•
Are these storage tanks located at a commercial facility that accepts oil production
wastewater for processing?
Yes
No
•
p
Do these storage tanks contain less than 1% by volume crude oil on an annual average basis?
Yes
No
•
•
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.•
Yes
No
■
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
D
■
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017
2 I AyCOLORADO
orrnu<
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit ,t and AIRS ID]
Section 4 - Storage Tank(s) Information
Produced Water Throughput:
Actual Annual Amount
(bbl/year)
387,399
Requested Annual Permit Limit4
(bbl/year)
464,879
From what year is the actual annual amount?
Tank design:
p Fixed roof
Projected
❑ Internal floating roof
O External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
PW-001 & PW-002
2
800
11/2017
11/2017
Wells Serviced by this Storage Tank or Tank Battery5 (E&P Sites On y)
API Number
Name of Well
Newly Reported Well
- -
See Form APCD-212
■
-
■
_
■
■
- -
•
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
5 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.481878°, -104.852464°
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
ECD
—15
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
❑� Upward
❑ Horizontal
❑ Downward
El Other (describe):
Indicate the stack opening and size: (check one)
El Circular
❑ Square/rectangle
❑ Other (describe):
El Upward with obstructing raincap
Interior stack diameter (inches): 48
Interior stack width (inches): Interior stack depth (inches):
COLORADO
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 3 I
DeputmaniN Putt.
NeV W b Fraionme.9
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
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.
Pollutants Controlled:
Vapor
❑ Recovery
Unit (VRU):
Size: Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed (emissions vented): %
❑ Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating: TBD MMBtu/hr Q
Type: Two (2) ECDs Make/Model: I ES -48
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: X98
Minimum Temperature: N/A Waste Gas Heat Content: 1496 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 -Gas/Liquids Separation Technology Information (EftP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —52 psig
Describe the separation process between the well and the storage tanks: HLP Separator, Produced
Water Storage Tanks
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 4
COLORADO
er,
HHovaE 6 Ertviinnrrenf
Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form6.
If multiple emission control methods were identified in Section 6, the following table can be used to state the overall
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
EGO
95%
NOx
CO
HAPs
ECD
95%
Other:
From what year is the following reported actual annual emissions data? Projected
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor6
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)4
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
VOC
0.262
lb/bbl
State EF
50.75
2.54
60.90
3.04
NOx
0.068
Ib/MMBtu
AP -42
0.71
0.71
0.85
0.85
CO
0.31
Ib/MMBtu
AP -42
3.23
3.23
3.88
3.88
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor6
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
etc)
)
Uncontrolled
Emissions
(Pounds/ ear
(Pounds/year)
)
Controlled
Emissions?
(Pounds/year)
Benzene
71432
0.007
lb/bbl
State EF
2,711.79
135.59
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.022
lb/bbl
State EF
8,522.78
426.14
2,2,4-
Trimethylpentane
540841
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific
emissions factors according to the guidance in PS Memo 14-03.
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 5 1
COLORADO
HCVtbbEhvLmr..ea1
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is
and will be operated in full compliance with each condition of the applicable General Permit.
1`'jY1 / ZS
Si atur e g Y role all Authorized Person (not a vendor or consultant) I Date
Catie Nelson Air Quality Engineer
t
Name (print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
❑✓ 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 $152.90 and the General Permit
registration fee of $250, if applicable, to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
Make check payable to: https://www.colorado.gov/cdphe/apcd
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Form APCD-207 Produced Water Storage Tank(s) APEN Revision 07/2017
4� j, COLORADO
6 I • 7ium.66 iitur 1 P &I
sue, s - APO) ei,eiwl" Ai -fad -fro'- 12e4.e 4a6 -2-49i9
Natural Gas Venting APEN - Form APCD-211 s
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. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural 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. 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/cdphe/apcd.
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: / $W E,eillf AIRS ID Number: 1 Z3 /'7F9A/A f
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: HP Separator Venting
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization)
Section 1 - Administrative Information
Company Name': Extraction Oil & Gas, Inc.
Site Name: Windsor LV2 Production Facility
Site Location: SESE SEC14 T6N R67W
Mailing Addrede) 370 17th Street, Suite 5300
(Include Zip Code)
Denver, Colorado
E -Mail Address2: KSteerman@ExtractionOG.com
Site Location
County: Weld
NAICS or SIC Code: 211111
Permit Contact: Kathy Steerman
Phone Number: (720) 974-7765
'Please 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 APCD via a-mair to tha a.at+ra« nrnvided.
Form APCD-211 - Natural Gas Venting APEN - Rev 03/2017
37352-S
COLORADO
1 wwranarn or s-.1wc
(taJ,: b1,..rtesalnra
X
Permit Number: AIRS ID Number: / /
[Leave blank unless APCI) has already assigned a permit It and AIRS ID]
Section 2- Requested Action
O NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment O Change company name O Add point to existing permit
❑ Change permit limit O Transfer of ownership3 O Other (describe below)
OR
❑ APEN submittal for update only (Please 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 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:
HP Separator Venting Emissions
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
11 /04/ 2017
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
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
days/week weeks/year
O Yes ❑ No
O Yes. O No
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
(qy COLORADO
2 I �t ,7,11 nn
iii Ns;u:N cr•racanrn,
Permit Number: AIRS ID Number:
iX
[Leave blank unless APCD has already assigned a permit II and AIRS ID]
Section 4 - Process Equipment Information
Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
3 344.8
SCF/hr
Vent Gas
Heating Value:
1,394
BTU/SCF
Requested:
29.30
MMSCF/year
Actual:
23.73
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
24.0332
VOC (mole %)
14.905
VOC (Weight %)
31.982
Benzene (mole %)
0.0168
Benzene (Weight %)
0.0547
. Toluene (mole %)
0.0138
Toluene (Weight %)
0.0529
Ethylbenzene (mole %)
0.0014
Ethylbenzene (Weight %)
0.0062
Xylene (mole %)
0.0066
Xylene (Weight %)
0.0291
n -Hexane (mole %)
0.1155
n -Hexane (Weight %)
0.4142
2,2,4-Trimethylpentane
(mole %)
000 1
0.0001
2,2,4-Trimethylpentane
(Weight %)
0.0003
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX & n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX & n -Hexane, temperature, and
pressure)
Form APCD-211 -Natural Gas Venting APEN • Rev 03/2017
COLORADO
3 I WWYY inT r!R neo(3 eMe
)travRb 4.v.mnnes.
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has atready assigned a permit # and AIRS ID]
,11
fw
fit
O.7
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.481878°, -104.852464°
Operator
Stack 1D No
Discharge Height
Above Ground Level
(Feet)
Temp.
('F)
Flow Rate
(ACFM)
Velocity
(fel/sec)
Q5000
-30
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
0 Downward
❑ Other (describe):
p Upward
0 Horizontal
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
TBD
Section 6 - Control Device Information
0 VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating: TBD MMBtu/hr
Type: Thermal Oxidizer Make/Model: Questor/Q5000
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
TBD
98 %
>99 %
Waste Gas Heat Content
Constant Pilot Light: 0 Yes 0 No Pilot burner Rating
1,394
TBD
Btu/scf
MMBtu/hr
Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
41
A
COLORADO
Rm t1,6 cm.ronm.m
Permit Number:
AIRS ID Number:
/ /
Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 Yes O No
rol equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOX
NO.
VOC
Thermal Oxidizer
98%
CO
HAPs
Thermal Oxidizer
98%
Other:
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
Requested Annual Permit
Emission tiiinil s s
�"
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SOX
NO,
0.066
Ib/MMStu
Mfg.
1.09
1.35
VOC
20,259.18
lb/MMscf
Promax
240.32
4.81
296.80
5.94
CO
0.05
lb/MMBtu
Mfg.
0.83
1.02
Benzene
34.59
lb/MMscf
Promax
0.41
0.01
0.51
0.01
Toluene
33.51
lb/MMscf
Promax
0.40
0.01
0.49
0.01
Ethylbenzene
Xylenes
18.47
lb/MMscf
Promax
0.22
0.00
0.27
0.01
n -Hexane
262.35
lb/MMscf
Promax
3.11
0.06
3.84
0.08
2,2,4-
Trimethylpentane
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
COLORADO
ram*
z-t
Form APCD-211 ...Natural Gas Venting APEN Rev 03/2017 5 1 m
Permit Number:
AIRS ID Number:
/
/
[Leave blank unless APCD has already assigned a permit # and AIRS ID)
Ui
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct
Signatlre of Legally Authorized Person (not a vendor or consultant)
Kathy Steerman
�I�ord'
e
Air Quality Coordinator
Name (please print)
Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
Q Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-61
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Form APCD-211 -Natural Gas Venting APEN Rev 03/2017
For more information or assistance call:
Small Business.Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.cotorado.gov/cdphe/apcd
6 I AY' COLORADO
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Natural 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. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural 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 maybe a more specific APEN for your source. 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/cdphe/apcd.
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:
63(dotiq AIRS ID Number: 12 3 / RF5,q/Qo9
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: HP Separator Venting
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Extraction Oil & Gas, Inc.
Site Name: Windsor LV2 Production Facility
Site Location: SESE SEC14 T6N R67W
Mailing Address:
(Include Zip Code) 370 17th Street, Suite 5300
Denver, Colorado
E -Mail Address'-:. cnelson@extractionog.com
Site Location
County: Weld
NAICS or SIC Code: 211111
Permit Contact: Catie Nelson
Phone Number: (720) 354-4579
'Please 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 APCD via e-mail to the address provided.
Form APCD-211 - Natural Gas Venting APEN - Rev 03/2017
.... ...............
COLORADO
Depvimam N VaLuc
xwnpe Otvunnmem
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID)
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 name ❑ Add point to existing permit
❑ Change permit limit 0 Transfer of ownership3 ❑ Other (describe below)
- OR
❑ APEN submittal for update only (Please 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 a Notes:
3 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:
HP Separator Venting Emissions
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
11 / 04 / 2017
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: hours/day
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
days/week weeks/year
❑✓ Yes 0 No
0 Yes 0 No
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
COLORADO
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HcattEb Dtinha xN
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
O Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
.
3 3448
SCF/hr
Vent Gas
Heating Value:
1 394
BTU/SCF
Requested:
75.99
MMSCF/year
Actual:
61.53
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:.
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
24.03
VOC (mole %)
14.905
VOC (Weight %)
31.982
Benzene (mole %)
0.0168
Benzene (Weight %)
0.0547
Toluene (mole %)
0.0138
Toluene (Weight %)
0.0529
Ethylbenzene (mole %)
0.0014
Ethylbenzene (Weight %)
0.0062
Xylene (mole %)
0.0066
Xylene (Weight %)
0.0291
n -Hexane (mole %)
0.1155
n -Hexane (Weight %)
0.4142
2,2,4-Trimethylpentane
(mole %)
0.0001
2,2,4-Trimethylpentane
(Weight %)
0.0003
Additional Required Information:
O 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)
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
AYCOLORADO
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit ti and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.481878°, -104.852464°
Operator
P
Stack ID No.
Discharge Height
,
Above Ground Level
Temp.
('F)
Flow Rate
(ACFM) '`,
Velocity
e
(ft/sec)
)
Q5000
—30
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
p Upward
0 Horizontal
0 Downward
0 Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
❑ Other (describe):
0 Upward with obstructing raincap
TBD
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating: TBD MMBtu/hr
Type: Thermal Oxidizer Make/Model: Questor/Q5000
Requested Control Efficiency: 98
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
TBD
>99 %
Waste Gas Heat Content
Constant Pilot Light: ❑✓ Yes 0 No Pilot burner Rating
1,394
Btu/scf
TBD MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
COLORADO
4
I Nr,eaw=
Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes O No
If es lease describe the control equipment AND state the overall control efficiency (% reduction):
Y P
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOX
NOx
VOC
Thermal Oxidizer
98%
CO
HAPs
Thermal Oxidizer
98%
Other:
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
''�7'
Requested Annual Permit
Emission Limt:(s)s -
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SOX
NOx
0.068
lb/MMBtu
Mfg.
2.92
2.92
3.6
3.6
VOC
20,259.18
lb/MMscf
Promax
623.28
12.47
769.76
15.40
CO
0.31
lb/MMBtu
Mfg.
13.29
13.29
16.42
16.42
Benzene -
34.59
lb/MMscf
Promax
1.06
0.02
1.31
0.03
Toluene
33.51
lb/MMscf
Promax
1.03
0.02
1.27
0.03
Ethylbenzene
Xylenes
18.47
lb/MMscf
Promax
0.57
0.01
0.70
0.01
n -Hexane
262.35
lb/MMscf
Promax
8.07
0.16
9.97
0.20
2,2,4-
Trimethylpentane
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 5 I
COLORADO
N 'W FGrlroemeN
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
C.. /25/ 26 CISignature of Legally 'Authorize rson (not a vendor or consultant) Dat
Catie Nelson Air Quality Engineer
Name (please print) Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
✓�] Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 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 -
Telephone: (303) 692-3150
Form APCD-211 -Natural Gas Venting APEN Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
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Natural 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. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural 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. 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/cdphe/apcd.
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:
ITIVEOng
AIRS ID Number: / Z3 /9F913161 l)
[Leave blank unless APCD has already assigned a permit: and AIRS ID]
Company equipment Identification: LP Separator Venting
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name':
Site Name:
Site Location:
Extraction Oil & Gas, Inc.
Windsor LV2 Production Facility
Site Location
SESE SEC14 T6N R67W County: Weld
Mailing Address:
p Code370 17th Street, Suite 5300
(Include Zip Code)
Denver, Colorado
E -Mail Address2: KSteerman@ExtractionOG.com
NAICS or SIC Code: 211111
Permit Contact: Kathy Steerman
Phone Number: (720) 974-7765
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that wilt
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 APCD via e-mail to the address provided.
Form APCD-211 Natural Gas Venting APEN - Rev 03/2017
312D52-4,
� COLORADO
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Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit t and AIRS ID]
Section 2- Requested Action
r❑ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
O Change fuel or equipment O Change company name O Add point to existing permit
O Change permit limit ❑ Transfer of ownership3 O Other (describe below)
OR -
APEN submittal for update only (Please 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 £t Notes:
3 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:
LP Separator Venting Emissions
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
11 / 04 / 2017
O Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
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
Form APCD-211 Natural Gas Venting APEN . Rev 03/2017
days/week weeks/year
O Yes
O Yes
O No
❑✓ No
Il coLORApo
2 I A
F���
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit .# and MRS ID]
•r.•
Section 4 - Process Equipment Information
• Gas/Liquid Separator
O Well Head Casing
❑ Pneumatic Pump
Make: Model:
O Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:Heating
10,486.7
SCF/hr
Vent Gas
Value:
1 948
BTU/SCF
Requested:
91.86
MMSCF/year
Actual:
74.38
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
34.3986
VOC (mole %)
38.43
VOC (Weight %)
60.104
Benzene (mole %)
0.0784
Benzene (Weight %)
0.1780
Toluene (mole %)
0.0678
Toluene (Weight %)
0.1817
Ethylbenzene (mole %)
0.0060
Ethylbenzene (Weight %)
0.0186
Xylene (mole %)
0.0238
Xylene (Weight %)
0.0736
n -Hexane (mole %)
0.5409
n -Hexane (Weight %)
1.3551
2,2,4-Trimethylpentane
0.0002
2,2,4-Trimethylpentane
Weight %)
0 0007
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX Ft n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX ft n -Hexane, temperature, and
pressure)
Form APCD-211 -Natural Gas Venting APEN Rev 03/2017
3 COLORADO
N e.Th cnv[romwm
ra
f T'
;f€
❑✓ Upward
❑ Horizontal
Permit Number:
AIRS ID Number:
ntess APCD has already assigned a permit f and AIRS I0)
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.481878°, -104.852464°
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp.
(^F)
Flow Rate
(ACFM)
Velocity
(ftlsec)
Q5000
—30
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
TBD
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled:
Rating:
Type:
VOC/HAPs
TBD
MMBtu / hr
Thermal Oxidizer Make/Model: Questor/Q5000
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
TBD
98
>99
Waste Gas Heat Content
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating
1,948
Btu/scf
TBD MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0
Form APCD-211 ...Natural Gas Venting APEN - Rev 03/2017
4
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ry
a
.k
Permit Number:
AIRS ID Number:
/
{Leave bank unless APCD has already assigned a , er;rit f ar€d AIRS Ill]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? El Yes Q No
If yes. olease describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOX
NOx
VOC
Thermal Oxidizer
98%
CO
HAPs
Thermal Oxidizer
98%
Other:
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)6
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SOX
NOx
0.066
lb/MMBtu
Mfg.
4.78
5.90
VOC
55.00
lb/Mscf
Promax
2,045.54
40.91
2,526.25
50.52
CO
0.05
lb/MMBtu
Mfg.
3.62
4.47
Benzene
0.161
lb/Mscf
Promax
6.00
0.12
7.41
0.15
Toluene
0.165
lb/Mscf
Promax
6.12
0.12
7.56
0.15
Ethylbenzene
0.017
lb/Mscf
Promax
0.62
0.01
0.77
0.02
Xylenes
0.066
lb/Mscf
Promax
2.47
0.05
3.05
0.06
n -Hexane
1.288
lb/Mscf
Promax
45.68
0.91
56.42
1.13
2,2,4-
Trimethylpentane
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-211 ...Natural Gas Venting APEN - Rev 03/2017 5 1 A.
:l3trg
Permit Number: AIRS ID Number:
/
[Leave blank unless APCD has already assigned a permit # and AIRS ID)
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
Signature of Legally Authorized Person (not a vendor or consultant)
Kathy Steerman
Name (please print)
41,196tr
Date
Air Quality Coordinator
Title
Check the appropriate box to request a copy of the:
Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 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
Telephone: (303) 692-3150
Form APCD-211 -Natural Gas Venting APEN Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
COLORADO
APR 2 b 2019
Natural 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. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural 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. 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/cdphe/apcd.
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: ou5
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: LP Separator Venting
AIRS ID Number: J' J / (1/34/O/O
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Extraction Oil & Gas, Inc.
Site Name: Windsor LV2 Production Facility
Site Location: SESE SEC14 T6N R67W
Mailing Address:
(Include Zip Code) 370 17th Street, Suite 5300
Denver, Colorado
E -Mail Address' cnelson@extractionog.com
Site Location
County: Weld
NAICS or SIC Code: 211111
Permit Contact: Catie Nelson
Phone Number: (720) 354-4579
'Please 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 APCD via e-mail to the address provided.
Form APCD-211 - Natural Gas Venting APEN - Rev 03/2017
COLORADO
- NeasN Q E,.ruanrt»
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
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 name ❑ Add point to existing permit
O Change permit limit 0 Transfer of ownership3 ❑ Other (describe below)
- OR
❑ APEN submittal for update only (Please 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 £t Notes:
3 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:
LP Separator Venting Emissions
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
11 / 04 / 2017
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
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
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
days/week weeks/year
0 Yes
0 Yes
❑ No
0 No
COLORADO
2 I = 6 GN enrmd ecl FubUc
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
❑ Well Head Casing
El Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
10 4867
.
SCF/hr
Vent Gas
Heating Value:
1 948
5
BTU/SCF
Requested:
14.44
MMSCF/year
Actual:
12.03
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
34.3986
VOC (mote %)
38.43
VOC (Weight %)
60.104
Benzene (mole %)
0.0784
Benzene (Weight %)
0.1780
Toluene (mole %)
0.0678
Toluene (Weight %)
0.1817
Ethylbenzene (mole %)
0.0060
Ethylbenzene (Weight %)
0.0186
Xylene (mole %)
0.0238
Xylene (Weight %)
0.0736
n -Hexane (mole %)
0.5409
n -Hexane (Weight %)
1.3551
2,2,4-Trimethylpentane
0.0002Weight
2,2,4-Trimethylpentane
%)
0.0007
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX it n -Hexane, temperature, and
pressure)
LI
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
�, COLORADO
3 I el ,.<
.fl bEnrtlanmam
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit tt and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.481878°, -104.852464°
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp.
,
CF)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Q5000
—30
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
✓❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
✓❑ Circular Interior stack diameter (inches):
❑ Other (describe):
O Upward with obstructing raincap
TBD
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating: TBD MMBtu/hr
Type: Thermal Oxidizer Make/Model: Questor/Q5000
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
TBD
98
>99
%
Waste Gas Heat Content
Constant Pilot Light: ❑✓ Yes El No Pilot burner Rating
1,948
TBD
Btu /scf
MMBtu/hr
El Other:
Pollutants Controlled:
Description:
Control Efficiency.
Requested
0
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
4 ®� ,COLORADO
1=1. 1
I � a�m.msr ��{
Hea!fh60sY +S
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
If yes please describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SO,
NO,
VOC
Thermal Oxidizer
98%
CO
HAPs
Thermal Oxidizer
98%
Other:
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
Requested Annual Permit
-Emission Limits 5 ,.
�`
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SO,
NO,
0.068
lb/MMBtu
Mfg.
0.8
0.8
0.96
0.96
VOC
55.00
lb/Mscf
Promax
330.80
6.62
396.96
7.94
CO
0.31
Ib/MMBtu
Mfg.
3.63
3.63
4.36
4.36
Benzene
0.161
lb/Mscf
Promax
0.971
0.0194
1.165
0.0233
Toluene
0.165
lb/Mscf
Promax
0.990
0.0198
1.188
0.0238
Ethylbenzene
0.017
lb/Mscf
Promax
0.101
0.0020
0.121
0.0024
Xylenes
0.066
lb/Mscf
Promax
0.399
0.0080
0.479
0.0096
n -Hexane
1.288
lb/Mscf
Promax
7.388
0.1478
8.865
0.1773
2,2,4-
Trimethylpentane
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 5 I
COLORADO
wrueuc
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
,.. t u a, )
Signature of Legally Authorized Pe on(not a vendor or consultant)
� Y
Catie Nelson
J7S(O('1
te
Air Quality Engineer
Name (please print) Title
Check the appropriate box to request a copy of the:
J Draft permit prior to issuance
❑✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 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
Telephone: (303) 692-3150
Form APCD-211 -Natural Gas Venting APEN Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692.3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
COtoRADQ
6 I ANIIr
°°„,
Natural 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. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural 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. 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/cdphe /apcd.
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:
c&W ��/1(� AIRS ID Number: (*Z3 / cm/ D/(
[Leave blank unless APCD has already assigned a permit #. and AIRS ID]
Company equipment Identification: • VRT Separator Venting
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name':
Site Name:
Site Location:
Extraction Oil & Gas, Inc.
Windsor LV2 Production Facility
Site Location
SESE SEC14 T6N R67W County: Weld
Mailing Address:
(Include Zip Code) 370 17th Street, Suite 5300
Denver, Colorado
E -Mail Address': KSteerman@ExtractionOG.com
NAICS or SIC Code: 211111
Permit Contact: Kathy Steerman
Phone Number: (720) 974-7765
'Please 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 APCD via e-mail to the address provided.
Form APCD-211 Natural Gas Venting APEN - Rev 03/2017
AV
31;52:1
COLORADO
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J4,i 4frvW,n*.'enr
to
ii
Permit Number:
N
a
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit it and AIRS ID]
.v.
Section 2- Requested Action
f❑ NEW permit OR newly -reported emission source
- OR -
MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment O Change company name O Add point to existing permit
❑ Change permit limit O Transfer of ownership' O Other (describe below)
OR
• APEN submittal for update only (Please 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 Et Notes:
3 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:
VRT Separator Venting Emissions
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
11 / 04 / 2017
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: hours/day
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
Form APCD-211...Natural Gas Venting APEN Rev 03/2017
days/week weeks/year
❑✓ Yes
❑ Yes
❑ No
❑✓ No
-wiCOLORADO
2 1
3lraank bsarocssamc
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit r and AIRS ID]
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
El Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
469 8
5CF/hr
Vent Gas
Heating Value:
2621
,
BTU/SCF
Requested:
4.116
MMSCF/year
Actual:
3.332
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
46.4006
VOC (mole %)
70.74
VOC (Weight %)
83.77
Benzene (mole %)
0.1359
Benzene (Weight %)
0.2288
Toluene (mole %)
0.0813
Toluene (Weight %)
0.1614
Ethylbenzene (mole %)
0.0045
Ethylbenzene (Weight %)
0.0103
Xylene (mote %)
0.0173
Xylene (Weight %)
0.0397
n -Hexane (mole %)
0.9841
n -Hexane (Weight %)
1.8276
2,2,4-Trimethylpentane
0.0004Weight
2,2,4-Trimethylpentane
%)
0.0009
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)
COLORADO
Form APCD-211 -Natural Gas Venting APEN Rev 03/2017
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
.r.
N
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UM)
40.481878°, -104.852464°
Operator ..
=5tac ID No.
Discharge Height.
Above Ground Level '
(Feet)
Temp.
rF)
Flow Rate
(ACFM)
Velocity,
(ft/secj
Q5000
'-30
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
0 Upward
0 Horizontal
❑ Downward
0 Other (describe):
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter (inches):
0 Other (describe):
0 Upward with obstructing raincap
TBD
Section 6 - Control Device Information
❑✓ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled:
Rating:
Type:
VOC/HAPs
TBD
Thermal Oxidizer
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
TBD
MMBtu/hr
Make/Model: QueStOr/Q5OOO
98
>99
%
Waste Gas Heat Content
Constant Pilot Light: 0 Yes 0 No Pilot burner Rating
2,621
TBD
Btu/scf
MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
Form APCD-211 -.Natural Gas Venting APEN Rev 03/2017
COLORADO
4 I :nIH �e
��L'iiiiiiiii 6Lrvaonm.ne
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑� Yes ❑ No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SO,
NO,
VOC
Thermal Oxidizer
98%
CO
HAPs
Thermal Oxidizer
98%
Other:
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
Requested Annual Permit
Emission iimit(s)s
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SO,
NO,
0.066
lb/MMBtu
Mfg.
0.29
0.36
VOC
103.20
lb/Mscf
Promax
171.95
3.44
212.36
4.25
CO
0.05
Ib/MMBtu
Mfg.
0.22
0.27
Benzene
0.280
lb/Mscf
Promax
0.47
0.01
0.58
0.01
Toluene
0.197
lb/Mscf
Promax
0.33
0.01
0.41
0.01
Ethytbenzene
Xylenes
n -Hexane
2.235
lb/Mscf
Promax
3.72
0.07
4.60
0.09
2,2,4-
Trimethylpentane
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-211 -Natural Gas Venting APEN Rev 03/2017
A COLORADO•
J
G l M I
Lim :,n.aa,,«onru�nn.n.
Permit Number: AIRS ID Number:
I
[Leave blank unless APCD has already assigned a permit # and MRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
Signature of Legally Authorized Person (not a vendor or consultant)
?td- 20 IT
Da e
Kathy Steerman Air Quality Coordinator
Name (please print)
Title
Check the appropriate box to request a copy of the:
Draft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-55431
4300 Cherry Creek Drive.South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Form APCD-211 -Natural Gas Venting APEN Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
COLORADO
6 i N°'w:�-
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