HomeMy WebLinkAbout20194466.tiff COLORADO
ItoDepartment of Public RECEIVED
Health€t Environment
OCT 072019
WELD COUNTY
COMMISSIONERS
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
October 2, 2019
Dear Sir or Madam:
On October 3, 2019, the Air Pollution Control Division will begin a 30-day public notice period for
Extraction Oil Et Gas, Inc. - Thornton 8-P. 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
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe I �•i.
Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director r21
Pvbl :C Rev:ew Cc: PL(TP) FIL(L.K), PW(3-mgR/cH/cb 2019-4466
1O/14/19 oG(3.m)
►O/og/19
Air Pollution ControlDivision
Notice of a Proposed Project or Activity Warranting Public
CDPHE
Comment
Website Title: Extraction Oil Et Gas, Inc. - Thornton 8-P - Weld County
Notice Period Begins: October 3, 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: Thornton 8-P
Well Pad Facility
NWSW SEC 8 T7N R66W
Weld County
The proposed project or activity is as follows: Condensate storage tank
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 16WE0097 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.govtpacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Timothy Sharp
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
a,. Department of Public
1 Icurree Health EtEnvironment
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CONSTRUCTION PERMIT
Permit number: 1 6WE0097 Issuance: 2
Date issued:
Issued to: Extraction Oil and Gas, Inc.
Facility Name: Thornton 8-P
Plant AIRS ID: 123/9E49
Physical Location: NWSW SEC 8 T7N R66W
County: Weld County
General
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Point Equipment Description Description
ID
Crude Oil Two (2) 1600 barrel fixed roof storage Enclosed Flare !t
Storage 004 tanks, comprised of (4)-400bb1 vessels Vapor Recovery Unit
Tanks each, used to store crude oil.
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. This construction permit represents final permit approval and authority to operate this
emissions source. Therefore, it is not necessary to self-certify. (Regulation Number 3,
Part B, Section III.G.5.)
EMISSION LIMITATIONS AND RECORDS
2. Emissions of air pollutants shall not exceed the following limitations. (Regulation
Number 3, Part B, Section II.A.4.)
CIIPH£ ;COLORADO
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Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point PM2.5 NOX VOC CO Type
Crude Oil 004 --- --- 13.0 2.5 Point
Storage Tanks
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 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.
3. 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.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
Crude Oil
Storage 004 Enclosed Flare Et Vapor Recovery Unit VOC and HAP
Tanks
PROCESS LIMITATIONS AND RECORDS
4. 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 AIRS
Equipment Point Process Parameter Annual Limit
ID
Crude Oil Crude Oil 466,944 barrels
Storage 004 Throughput
Tanks VRU Downtime 876 hours
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co s I Air Pollution Control Division
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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 and hours 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
5. 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)
6. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
7. 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)
8. 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;
• 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.
9. 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
core 'COLORADO
CO Air Pollution Control Division
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control requirement must be met within 90 days of the date that the storage tank
commences operation.
10. 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
11. 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 O&M plan are subject to Division approval prior to
implementation. (Regulation Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Periodic Testing Requirements
12. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
13. All previous versions of this permit are cancelled upon issuance of this permit.
14. 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, 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 r
• Whenever a permit limitation must be modified; or
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• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
15. 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.
16. 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.
17. 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.
18. 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.
19. 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.
20. 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.
21. 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,
cDPtE !COLORADO
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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 July 25, 2016 Issued to Extraction Oil and Gas, LLC
Issuance 2 This Issuance Name change to Extraction Oil and Gas, Inc.
Modification to permitted emissions and
process limits.
!COLOR ADO
CO ,'' Air Pollution Control Division
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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.
AIRS Uncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
Benzene 71432 1424 71
Toluene 108883 803 40
Ethylbenzene 100414 85 4
004 Xylenes 1330207
312 16
n-Hexane 110543 10553 528
2,2,4-
540841
Trimethylpentane 2937 147
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 004:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
CO 0.011 CDPHE
VOC 1.1638 Source
71432 Benzene 0.003 Source
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Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
108883 Toluene 0.002 Source
1330207 Xylene 0.001 Source
110543 n-Hexane 0.023 Source
540841 2'2'4 0.006 Source
Trimethylpentane
Note: The controlled emissions factors for this point are based on the flare 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 Status
Requirement
Operating Permit Synthetic Minor Source of: VOC
PSD/NANSR Synthetic Minor Source of: VOC
MACT HH Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
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, Appendix A - Appendix I
Appendixes
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
a€ :COLORADO
CO ,r Air Pollution Control Division
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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
:COLORADO
Air Pollution Control Division
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Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details
Review Engineer: Timothy Sharp
Package#: 356903".
Received Date: 22/28/2016
Review Start Date: 3/14/2017
Section 01-Facility Information
Company Name: Extraction Oil&Gas,:Inc. Quadrant Section Township Range
County AIRS ID: 123 NWSW a 7n 66
Plant AIRS ID:
Facility Name: Thornton 4-P
Physical
Address/Location: NWSW quadrant of Section 5,Township Sn,Range 66W
County: Weld County
__.._.................
Type of Facility: Exploration&Production Well Pad
What industry segment?Olt&Natural Gas Production&Prcxessing
Is this facility located in a NAAQS non-attainment area? Yes
If yes,for what pollutant? Carbon Monoxide(CO) ❑ Particulate Matter(PM) a one(NOx&VCC)
Section 02-Emissions Units In Permit Application
Emissions Self Cert Engineering
AIRS Point# Emissions Source Type Equipment Name Permit# Issuance# Action
Control? Required? Remarks
Permit
004 Candensatelarrk Crude Oil Storage Tanks Yes 1GLA/E0097 2 No Modification
Section 03-Description of Project �u
; �
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? Requesting syrrtbetiO Minor Permit
Section 05-Ambient Air Impact Analysis Requirement:
Was a quantitative modeling analysis required? No .
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 min TSP HAPs
Prevention of Significant Deterioration(PSD) ❑ CI
V Operating Permits(OP) l
Non-Attainment New Source Review(NANSR)
Is this stationary source a major source? No
If yes,explain what programs and which pollutants here SO2 NOx CO VOC PM2.5 PM10 TSP HAPS
Prevention of Significant Deterioration(PSD) _ _ _ ❑ _ ❑ ❑
Title V Operating Permits(OP) Q
Condensate Storage Tank(s)Emissions inventory
004 Condensate Tank
'Facility AlRs ID:
County Plat Point
Section 02-Equipment Description Details
Detailed Emissions Unit o(2fandv f`qundai73aT4#�iii,, nd8E880e ntQYa5 hol mad80j -0 16::f itoc gdY s58�s�, 'c i3,� -
Oescnptian: x' y;., �
Emission Control Device `" €-' -
Description: i `R�'w S _"Ar' .w- x /,� iiS"T .�,
Requested Overall VOC&HAP Control 0 0
Efficiency%:
Section 03-Processing Rate Information far Emissions Estimates
Primary Emissions-Storage Tank(s)
Actual Condensate Throughput= ".3324531 Barrels(bbl)per year Actual Condensate Throughput While Emissions Controls Operating= 372193)Barrels(bbl)per year
Requested Permit Limit Throughput= ", --468,944''Barrels(bbl)per year Requested Monthly Throughput= 396511 Barrels(bbl)per month
Potential to Emit(PTE)Condensate Throughput
_ _446 944:Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= ,f 1200,1Btu/scf
Volume of waste gas emitted per BBL of liquids
produced= a:..d.,y'148 scf/bbl
Actual heat content of waste gas routed to combustion device= 109,954 MM BTU per year
Requested heat content of waste gas routed to combustion device= 138,721 MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= 130,865 MMBTU per year
Section 04-Emissions Factors&Methodologies
Will this storage tank emit flash emissions?
Emission Factors Condensate Tank
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Condensate (Condensate
Throughput) Throughput)
VOC .1,16 9.06
Benzene 0.003 0.000 .f x `
Toluene 0:0502. 0,000 tt % Q y 0 -
•
Ethylbenzene 0:000 J 0.000 ilWAIS0061041041iiika
Xylene 0,003 0.000
n-Hexane 0.023 0.441 4yas
224 TMP 0:006 0.000 ...:,1�,,#, ,., _ 73:1 a 33"-
Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source
(waste heat (Condensate
combusted) Throughput)
PM10 00975 6.4 0.0037 4 ' AranifiNt6.:33!2-62636
PM2.5 n0 9075; 00022
NOx ti..g4g3it 0.00.14 ..t "P� 0✓/�
CO .44#00 0.0104 y®
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month)
VOC 260.1 216,7 10.8 271.7 13.6 2308
PM10 0.5 0.4 0.4 03 0..6 87
PM25 0.5 0.4 0.4 0.5 11.5 87
NOx 1.0 0.8 0.8 1.9 1.9 174
CO 2.3 1.9 .19 2.4 2.4 412
Potential to Emit Actual Emissions Requested Permit Smelts
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 1360 1136 57 1424 71
Toluene 159 641 32 84133 40
Ethylbenzene 81 67 3 85 4
Xylene 296 249 12 312 16
n-Hexane .1010.1 841'7" 421 10553 578
224 TMP 2811 2343 117 2937 147
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B Santee requires a permit
Regulation 7,Section XII.C,D,E,F Storage tank is subject to Regulation 7,Section X11.14
Regulation 7,Section XII.G,C Storage Took is not subje<t to Regulation 7,Section 111.0
Regulation 7,Section XVII.0,C.1,C.3 Storage tank is_subject to Regulation 0,Section XVII,B,C.1&C.3
Regulation 7,Section XVII.C.2 Storage tank is subject to Regulation 7,Section XV11.0.2
Regulation 6,Part A,NIPS Subpart Kb Storage Tank is not subject to NSPS Kb
Regulation 6,Part A,NIPS Subpart 0000 Storage Tank is not subject to P15P50000
Regulation B,Part E,MACTSubpart HH Storage Tantis not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
3 of 5 K:\PA\2016\16WE0097.CP2
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 p y
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.
Does the company use a site specific emissions factor to estimate emissions? You
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 J
collected within one year of the application received date.However,if the facility has not been modified(e.g.,no x
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
I-CO and Novemissionfaptors are not being modified'. this perndi.tntadit7uatlon_-Ilse of previously (�usly p b -v/Ibcckemission facYorsremain acceptable ;'��, :� � •
Opperatdr has chosed to include Vflll slow Ohs esa-weighteddN4rggpevthe emission factor calculaton.The:Divisiod.finds this accepabl e,with the inclvshan of dtwftimensevtoring I min.
•
Section 09-Inventory 5CC Coding and Emissions Factors
Uncontrolled
Emissions
AIRS Point it Process*I 5CC Code Pollutant Factor Control% Units
004 01 , rcei₹irc± -tfa1hitt-„w,, PM10 0.05 0 l6/1,000 gallons condensate throughput
PM2.5 0.05 0 lb/1,000 gallons condensate throughput
NOx 0.10 0 lb/1,000 gallons condensate throughput
VOC 27.7 95 lb/1,000 gallons condensate throughput
CO 0.25 0 lb/1,000 gallons condensate throughput
Benzene 0.07 95 lb/1,000 gallons condensate throughput
Toluene 0.04 95 lb/1,000 gallons condensate throughput
Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput
Xylene 0.02 95 16/1,000 gallons condensate throughput
- n-Hexane 0.54 95 lb/1,000 gallorscondensxte throughput
224 TMP 0.15 95 lb/1,000 gallons condensate throughput
4 of 5 K:\PA\2016\16W E0097.CP2
Condensate Tank Regulatory Analysis Worksheet
Colorado P-:u ,k lotion 3 Parts A and a-APEN end PemRequlrements
1So4xt.0 in 510 Vot-Atsrinn,ent.Amo I
ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greaterthan 2 MY(Regulation 3,Part?,Section 11.0.1.x)? -may,-"
2. Is theconstmcgan date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 end1.14 and Section 2 for additional guidance on grandfather applicability)? f�rry
3. Aretatal facility uncontrolled VOC emissions greater than 5?PY,NOx greater than lOTPY or CO emissions greater than 10 TM,'(Regulation 3,Part h,Section 11.D.3)?
Itoruhave iodinated that source in 0r ti=e noun-Attainment Irma
NON-ATTAINMENT •
1. Are uncontrolled emissions from any criteria pollutants from this individual source greaterthan OTYY(Regulation 3,Part A,Section 11.0-L5)? fifftflaW44 Source Req
2. A the construction date(service date)priorto 12/30/2002 and not modified after 12/31/2002(The PS Memo o5-01 Definitions 1.12 end114 and section 2 for additional guidance an grandfather applicability)? l'&10 Go to nett
3. Are total facility uncontrolled VOL emissions greaterthan 2 TPY,NO4 greaterthan 5'MY or CO emissions greater than 10 TM/(Regulation 3,Part I,Section 11.0.2)? Iftifrat,Source Req
It[ro-:x,u,loi ties a palmit.
Colorado Regulation 7.Section 011.0-F
1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? You Continue-'
2. Is this storage tank located at an all and gas exploration and production operation',natural gas compressor station or natural gas drip station? Yes Continue-'
3. Is this storage tank located upstream of anatural gas processing plant? i/ Source is
(Storage tank issub ectto Regciat an 7,Sedan Ott.o.? •
Section XII.C.1—Genera(Requirements for Air Pollution Control Equipment—Prevention of Leakage
Section XII.C,2—Emission Estimation Procedure
Section XII.D—Emissions Central Requirements
Section Xa.E—Mon goring
Section XN.P—Recardkeeping and Reporting
Colorado Regulation 7,Section 011.0
1. Is this storage tank located In the'-hr ozone control area or any ozonenon-attainment area or attainment/maintenance area? Yes Continue-'
2. Is this storage tank located at a natural gas processing plant? No Storage Tat
3. Does this storage tank exhibit'Flask'(e.g.storing non-stabilised liquids)emissions and have uncontrolled actual emissions greaterthan or equal to 2 tons per year VIC? Ngx,r4Source Is
!Storage Yank is nuts:MierI to Po?r,iea"en 7,ta:«m1 X11.0
Section tors o-Emissions Control Requirements
Section XII.C1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Section 3n.02—Emission Estimation Procedures
Colorado Regulation 7.Section XVII
1, Is this tank located at atransmsslen/storage facility? me Continue-'
2. Is this condensate storage tan It'laated otor ail and gas exploration end production operation,well production facility',natural gas compressor station'or natural gas processing plant? Yes Go to then
3. Is this condensate storage tank a fixed roof storage tank? MEM G to then
4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC? Reg/(°Source sst
'Storage tart:issallied to Regta:stion V,tou,20n XVII,3,0.1 a C.3
Seel:kn./U.8 General Provisions for Air Pollution Control Equlpmercand Prevention of Emissions
Section XVII.C.1-Emissions Control and Monitoring Provisions
Section XVII.C3 Recordkeeping Requirements
5. Does the condensate storage tank cantaimmnk'stabilized.liquids? rf�l`",'-=?Sous issc
IStrar.,tank Is nukiect to Reot4otico 7,Section 0011.01
Section XVII.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR Part 60.Subpart eb.Standards of Perform..for Volatile Organic Liquid Storage Vessels PP^^
1. Is the ndv duxlst0rage vessel capacity greaterthan or equal to 75 cubic meters INo� /Storegeiar
2. Does the storage vessel meet the fallowmgexempton In 60.111b(d)(4)? ILL
a.Ooesthe vessel has design capacity less than or equal to;589.074 m'("'10,000 BBL]used for petroleurn4 or condensate stored,processed,ortreated prior to custody transfer'as defined In 60.1116?
3, Was this condensate storage tank constructed,reconstructed,or modified(see definitions 40 CFR,60.2)afterluly 23,1984?
4. Doe the tank sat the definition of"storage vessel"'in 60.111b? S^:
5. Dees the storage vessel Aare a"volatile organic liquid(VOL)"'as defined In 60.111b?
6. Does the storage vessel meet any oneef the following additional exemptions:
a.Is the storage vessel a pr.sure vessel designedto operate.eke.of 204.S kPa[-29.7 psil and without emissionsta the atmophere(60.110b(d))2))?;or
0.The design capacity is greaterthan or equal to 151 ma(-9508BL]and star.a liquid with a maximum true vapor pressure°lass than 35 Ira(60.110b(b))?;or
c The design capacity s greaterthan or equal to 75 Ms)^472 BBL)but l.s than 151m'['150 BBL)and stores a liquid with a maximum true vapor pressure'less than 15.0 kPa)fi0.110b(b))? r-644
[Storage Took is not sttblett.to NSP:B nit I
Subpart A,General Provisions _
460.112b-Emissions Control Standards fnrVOC
460.113b-Testing and Procedures
460.11sb-Reporting and Recordkeeping Requirements
460.11611-Monitoring o£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 loatedata facility in the onshore oil and natural gas production segment,natural gas processing segment or natural gas transmission and storagesegment of the industry? Opt Continue-'
2. Was the condensate storage vessel constructed,reconstructed,or miscalled(see definitions 40 CPR,00.2)between August 23,2013 and September 18,2015? too %'Storage Tar
3. Are potential VC(emssions'from the individual storage vessel greaterthan or equal to 6 tors per year? fftnfOlifg
4. Doesthis condensate storage vessel meet thedefnrton of'00rage vessel.'per 605430?
5. A the storage vessel subject to and controlled in accordance with requirements for storage v.sek in 40 CPR Part 60 Subpart Kb or40 CFR Part 63 Subpart HH7
IGtoreie Tank Is not.°Mart to l 11050000
Subpart A,General Provisions Par§60.5425Table3
4605395-Emissans Control Standards far VOC -
46a5413-Tenag and Procedures
4605396(g)-Notification,Reporting and Recerdkeeping Requirements
4605416(cl-Cover and Closed Vent System Monitoring Requirements
§6045417—Control Device Monitoring Requirements
[Note:If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tans per year VOC an the applicability determination date,itshould remain subject to NSPS 0000 per 60.53651e)(2)even
if potential VOc emissions dmp below 6 tons per year]
4a CFR,Part 63,subpart MAR HH,all 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: Itis (Continue-'
a.A facility that processes,upgrades or store hydrocarbon line Ids(63.760(a)(2))i OR
b.Afacility that processes,upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user'(63.760(')(3))?
2. Is the tank located at a facility that is major'for HAPs? Nu ?.storage Tar
3. Do.the tankmeetthe definition of"storage vosei'in 63.761?
4. Does the tank meet the definition of°storage vessel with the potentialfarflash emissions"'per63.761?
5. Is the tank subjeetto control requirements under.CFR Part 60,Subpart Kb or Sehnert 0000?
IStorege Tank A net subject to MAC"HH
Subpart A General provisions per463.764(a)Table 2
§63.736-Emissions Control Standards
§63.743-Monitoring •
§63.734-Recordkeeping
§63.795-Reporting
RACT Review
RAC review is required If Regulation?daes not apply AND if the tank Is In the can-attainment area.lithe 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
riot'.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,
regukfion,or any other legally binding requirement andis 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
reguations,and Air Quality Control Commission regulations,the language afthe statute or regulation will control.The use anon-mandatory language such as`recommend"',nay,. end'can,r is
intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must'and'required'am intended to describe controlling requimments under the terns of the.Clean Air Act
and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself.
AIR POLLUTANT EMISSION NOTICE(APEN)&Application for Construction Permit—Crude Oil Storage Tank(s)'
Permit Number: 16WE0097 [Leave blank unless APCD has already assigned a permit#&AIRS ID] Emission Source AIRS ID: 123 / 9E49 / 004
Facility Equipment ID: Crude Oil Storage Tanks [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.]
Section 01—Administrative Information Section 02—Requested Action(Check applicable request boxes)
Company Name: NAICS,or 0 Request for NEW INDIVIDUAL permit
Extraction Oil&Gas, Inc. SIC Code: 211111 O Request for coverage under GENERAL PERMIT GP08
Source Name: Thornton 8-P 0 Request MODIFICATION to existing INDIVIDUAL peQ)Oh ,
elow) -
Source Location: NWSW, Sec.8,T7N,R66W County: Weld Q Change process or equipment �hange company na
Ault, Colorado Elevation: 5,038 Feet ❑✓ Change permit limit ❑ Transfer of ownersh • ter
Mailing Address: 370 17th Street,Suite 5300 ZIP Code: 80202 O APEN Submittal for Permit Exempt/Grandfathered source
Denver, Colorado ❑ APEN Submittal for update only(Please note blank APEN's will not be accepted)
Person To Contact: Josh Carlisle Phone Number: 720-481-2372 Addl.info.
E-mail Address: &Notes:
jarlisle@extractionog.com Fax Number:
Section 03—General Information
For existing sources,operation began on: 08 / 27 / 2015 For new or reconstructed sources,the projected startup date is: - / - / -
This Storage Tank is Exploration 8e Production Midstream or Downstream hours/ days/ weeks/
Located at: 0 (E&P)Site (Non-E&P)Site Normal Hours of Source Operation: 24 day 7 week 52 year
Will this equipment be operated in any NAAQS nonattainment area? ❑ Yes O No Are Flash Emissions anticipated at these tanks Yes No
DI' Are you requesting≥6 ton/yr VOC emissions,or are uncontrolled actual emissions≥6 ton/yr? Yes ✓ No
II, Are these crude oil tanks subject to Colorado Oil and Gas Conservation Commission(COGCC)805 series rules?If so,submit Form APCD-105. �✓ Yes O No
General description of equipment purpose: Onsite storage of crude oN prior to truck loadout.
Section 04—Storage Tank(s)Information
Crude Oil Requested Permit Limit: 466,944 bbl/year Colorado Department of Public Health and Environment
Air Pollution Control Division(APCD)This notice is valid for five
throughput: Actual: 372,453 bbl/year Actual While Controls Operational: 372,453 bbl/year
(5)years. Submit a revised APEN prior to expiration of five-year
Average API Gravity of Sales Oil: 39.9 degrees RVP of Sales Oil 9.22 term,or when a significant change is made(increase production,new
Tank Design: Fixed Roof: ❑! Internal Floating Roof: O External Floating Roof! O equipment,change in fuel type,etc).
Mail this form along with a check for S152.90 per APEN for non-
Storage #of Liquid Manifold Total Volume of Installation Date of most recent E&P,midstream and downstream sources or_S152.90 for up to
Date Of First Production
Tank Storage Vessels in Storage Tank storage vessel in storage tank five(5)APENs for E&P sources and S250 for each,general permit
(Moath/Year)
ID Storage Tank (bbl) (Month/Year) registration to: �,
001 4 1600 08/2015 08/2015 Colorado Department of Public Healthcpvironinent
APCD-SS-BI
002 4 1600 08/2015 08/2015 4300 Cherry Creek Drive South "'s�`
Denver,CO 80246-1530
Wells Serviced by this Storage Tank or Tank Battery(E&P Sites Only) For guidance on how to complete this APEN form:
Air Pollution Control Division: 303 API Number Name of Well Newly Re orted Well ( )692-3150
05- 123 - 40257 Thornton 3 a Small Business Assistance Program(SBAP): (303)692-3148 or
(303)692-3175
05- 123- 40269 Thornton 6 O APEN forms:hitp://Hww.colorado.uov/cdphe/oilcasAPENS
05- 123- 40271 Thornton 9 O Application status:http://www.colorado.eovicdphcmermitstatus
05- 123 - 40261 Thornton 12 O
05- 123- 40256 Thornton 11 O
FORM APCD-210 Page I of 2 AP Form-APCD-210-CrudeTankAPEN.doc
356901
AIR POLLUTANT EMISSION NOTICE(APEN)&Application for Construction Permit—Crude Oil Storage Tank(s)t
Permit Number: 16WE0097 Emission Source AIRS ID: 123 / 9E49 / 004
Section 05—Stack Information(For Midstream sites only) Section 06—Stack(Source,if no combustion)Location(Datum either Lat/Long or UTM)
operator Stack Base Stack Discharge
P Horizontal Datum UTM UTM Easting or UTM Northing or Method of Collection for
Stack Elevation Height Above Temp. Flow Rate Velocity Moisture
ID No. (feet)
Ground Level ("F) (ACFM) (ft/see) (%) (NAD27,NAD83, Zone Longitude Latitude Location Data(e.g.map,
(feet) WGS84) (12 or 13) (meters or degrees) (meters or degrees) GPS,GoogleEarth)
NAD83 -104.810368 40.585794 COGCC
Direction of stack outlet(check one): ❑ Vertical ❑ Vertical with obstructing raincap ❑ Horizontal ❑ Down ❑ Other(Describe):
Exhaust Opening Shape&Size(check one): n Circular:Inner Diameter(inches)_ El Other:Length(inches)= Width(inches)---
Section 07—Control Device Information
❑ Vapor Recovery Unit(VRU)used for control of the Storage Tank(s) ❑✓ Combustion Device used for control of the Storage Tank(s) Rating: 11.66 MMBtu/hr
Size: Make/Model: Type: Eclosed Combustor Make/Model
Requested VOC&HAP Control Efficiency: % VOC&HAP Control Efficiency: Requested: 95 % Manufacturer Guaranteed: 99 %
Annual time that VRU is bypassed(emissions vented): % Minimum temp.to achieve requested control: °F Waste gas heat content: —1200 Btu/scf
❑ Closed loop system used for control of the storage tank(s) Constant pilot light? 1? Yes ❑ No Pilot burner rating: O.Q3 MMBtu/hr
Description: ❑ Describe Any Other:
Section 08—Gas/Liouids Separation Technology Information(E&P Sites Only)
What is the pressure of the fmal separator vessel prior to discharge to the storage tank(s)? —30 psig
Please describe the separation process between the well and the storage tanks: Wellhead>3-Phase Separator>Heater Treater>Crude Oil Storage Tanks
Section� 09—Emissions Inventory Information&Emission Control Information
`17 1 Emission Factor Documentation attached Data year for actual calendar yr.emissions below&throughput in Sec.04(e;.2007): ) '15-16
Pollutant Emission Factor Actual Calendar Year Emission Requested Permitted Emissions Emission Factor
Uncontrolled Basis Units Uncontrolled(Tons/Year) Controlled(Tons/Year) Uncontrolled(Tons/Year) Controlled(Tons/Year) Data Source
NOx 0.0037 lb/lb-VOC 0.80 - 0.96 - CDPHE
VOC 1.1638 lb/bbl 216.74 10.84 260.1 13.0 ProMax
CO 0.0094 lb/lb-VOC 2.04 - 2.44 - CDPHE
Benzene 3.05E-03 lb/bbl 0.57 0.03 0.68 0.03 ProMax
Toluene 1.72E-03 lb/bbl 0.32 0.02 0.38 0.02 ProMax
Ethylbenzene 1.81 E-04 lb/bbl de minimis de minimis de minimis de minimis ProMax
Xylenes 6.68E-04 lb/bbl 0.12 0.01 0.15 0.01 ProMax
n-Hexane 2.26E-02 lb/bbl 4.20 0.21 5.04 0.25 ProMax
2,2,4-Trimethylpentane 6.29E-03 lb/bbl 1.17 0.06 1.17 0.06 ProMax
Please use the APCD Non-Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above.
Sectio icant s ,;,,, - ereby certify that all information contained herein and information submitted with this application is complete,true and correct.
/o7/6/() Josh Carlisle EHSR Manager
natu Pe • egal y orized to Supply Data Date Name of Legally Authorized Person(Please print) Title
You will be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and needs to be resubmitted.
z Annual emissions fees will be based on actual emissions reported here. If leR blank,annual emissions fees will be based on requested emissions.
Additional E Attach a pressurized pre-flash crude oil extended liquids analysis,RVP&API analysis of the post-flash oil
Information E Attach E&P Tanks input&emission estimate documentation(or eqtyvalent simulation report/test results) Int Check box to request copy of draft permit prior to issuance.
Required: O Attach EPA TANKS emission analysis if emission estimates do not contain working/breathing losses x Check box to request copy of draft permit prior to public notice.
FORM APCD-210 Page 2 of 2 AP_Form-APCD-210-CrudeTankAPEN.doo
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