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Home My WebLink About20183431.tiff A CDPHE COLORADO co 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 RECEIVED 11500 St PO Box 758 Greeley, CO 80632 OCT 2 3 2018 October 17, 2018 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On October 25, 2018, the Air Pollution Control Division will begin a 30-day public notice period for Extraction Oil Et Gas, Inc. - Keiser 14-28. 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.colorado.gov/cdphe { 7s- John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer I cC. pLC 7P), I-11.C 3T), �c�bl ic. view Pw( ERIC HI Um/GK.) 2018-3431 iC7f& t(1g to/ 6)(4 t ,, CDPHE Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public co Comment Website Title: Extraction Oil St Gas, Inc. - Keiser 14-28 - Weld County Notice Period Begins: October 25, 2018 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: Keiser 14-28 Oil and gas exploration and production facility SWSW Sec 28 T4N R66W Weld County The proposed project or activity is as follows: Source is proposing to flare low pressure separator gas at an existing production 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 18WE0412 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. Any such comment must be submitted in writing to the following addressee: Carissa Money Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1i ,.. Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer: Carissa Money Package#: 375698 Received Date: 4/10/2©18 Review Start Date: 10/2/2028 Section 01-Facility Information Company Name: Extraction Oil&Gas,Inc. Quadrant Section Township Range County AIRS ID: 123 .S)NSW 25 _. 4N 66 ,.. Plant AIRS ID: 9F1E Facility Name: Keiser 14.28 Production Facility Physical Address/Location: SWSW quadrant of Section 28,Township 4N,Range 66W County: - Weld County Type of Facility: Exploration&Production Well Pad What industry segment?Oil&Netural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? Li Carbon Monoxide(CO) E Particulate Matter(PM) r ' Ozone(N0x&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert Engineering AIRS Points Emissions Source Type Equipment Name Permit# Issuance S Action Control? Required? Remarks ,•.ice, - > Permit 002 Separator Venting LP Separator Venting Yes 18WE0412 I Yes issuance' Section 03-Description of Project The source is requesting to permit equipment at an existing E&P site.The source is requesting to flare LP separator gas.- Section 04-Public Comment Requirements Is Public Comment Required? Yen., If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No.- If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. 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 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) Title V Operating Permits(OP) ✓ a 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) Fes--+ ❑ Title V Operating Permits(OP) Colorado Air Permitting Project Non-Attainment New Source Review(NANSR) — 0 - Separator Venting Emissions Inventory 004 Separator Venting 123 911E 002 Facility Allis ID: ' - County Plant Point Section 02-Equipment Description Details Naming of gas front one low-pressure separator Detailed Emissions Unit Description. Enclosed Flare Emission Control Device Description: Pe,s"�,g,//ial Requested Overall VOC&HAP Control Efficiency%: -95 Limited Process Parameter Gas meter •g3;(ueJ � A,,s ,.a.�. Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput=≥P" -"'r°,f MMscf per year Requested Permit Limit Throughput=r ,,83:3'.MMscf per year Requested Monthly Throughput= 5 MMscf per month Potential to Emit(PTE)Throughput= 63 MMscf per year Process Control(Recycling) Equipped with a VRU:905 Is VRU process equipment:/n0 •• z Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 1934 Btu/scf Volume of waste gas emitted per BBL of •�`:' liquids throughput: . 4,4 scf/bbl Section 04-Emissions Factors&Methodologies Description Source used estimate of LP separator Qas volume and an extended gas sample of LP separator gas coitected 1/29/2018 at a nearby site,.002 Stromberger,to estimate emissions. i gigl MW 340767'.lb/Ib-mol Displacement Equation Ex=Q'MW'Xx/C Weight Helium 0.12 CO2 2 55 N2 _ .0.50 methane .16 40 ethane - 21.67 propane !. 2914. isobutane 4.50 n-butane 22'x65 isopentane 2.96 n-pentane 3.73 cyclopentane 0.27 n-Hexane ___I.12 yclohexane 0_29 Other hexanes 1.76 heptanes 0.98 methylcyclohexane 0.03I 224-TMP 5 201 Benzene 015 Toluene s!. 0ti.5' E ylbenzene 0.01 Xylenes 0 04 COO Heavies --,0.67. Total 100.00 VOC Wt% 58.8 Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) 2641.6 9.6206 0.4810 .;(44 litUtit44.4 tVi 1004.14 50.2069 • 0.6294 IMMIEEM Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu( lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) 0.0075 14.410 t AP-4Z BISI&-13••3(PR4 ..-::: s� e•..�... A.0075 14.410 2:s a, ..,1Y068D .?A 599.540 :s�i44. 3 of 6 K:\PA\2018\18WE0412.CP1.xlsm Separator Venting Emissions Inventory 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) (lbs/month) PM10 0.46 0.00 0.00 0.5 0.5 79 Includes combustion emissions from pilot gas also PM2.5 0.46 0.00 0.00 0.5 0.5 79 Includes combustion emissions from pilot gas also SOx 0.04 0.00 0.00 0.0 0.0 6 Indudes combustion emissions from pilot gas also NOx 4.16 0.00 0.00 4.2 4.2 721 Includes combustion emissions from pilot gas also VOC 1671.84 0.00 0.00 1671.8 83.6 14199 CO 18,97 0.00 0.00 19.4 19.4 3289 Includes combustion emissions from pilot gas also Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (Ibs/year) (Ibs/year) (Ibs/year) (Ibs/year) Benzene 8496 0 0 8496 425 Toluene 8251 0 0 8251 413 Ethylbenzene 609 0 0 609 30 Xylene 2128 0 0 2128 106 n-Hexane 63552 0 0 63552 3178 224 TMP 40 0 0 • 40 2 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B 'Source requires a permit Regulation 7,Section XVII.B,G Source is not subject to Regulation 7,Section XVII.B.2,G Regulation 7,Section XVII.8.2.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 she 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 maybe 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. -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? 4'„ 44.1114 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 von eq answer. ii _ -. 1 ail r.� r,, ,rryr r r i ii ry a , v%,% / O.a dok.44A4c4,50414,e6,44 f'&..41,11N4 a - ii' t .s ' / OgY Fig. r 4 4 of 6 K:\PA\2018\18WE0412.CP1.xlsm Separator Venting Emissions Inventory Section 08-Technical Analysis Notes • Tfiesogtee did rmtprovujeasrsr#,tglc3afe u0 ttta?RENernn the appllcatlan,6asgd,on•#heweEl assacmtedw p h`e euttdansatetarrk ApEId rthg'Fatn'evtetl llas been tr gpera ton since 1387 This app ca#ion sG3tantydiseusst„or:samewetll-'.::. i00p5 rsNSe�yell yras�notalledi L9&7 and has not been recom'plcted's7hus tfie separator�sttet su6iect teR 7 I f :-. ,,q ,�, e i ...131�i},.� i 3 3 p' r 1 y11 ` 3 1 1 r#,y t 1 ,>�� 11 -C �- 1 Ali �1� r 333 1 titZ;� 11�� 1 h a' ��1 lI� � � ,I � 3 • �Il ill�� 7331113��3'y' � � ` ��" ,,� � EJ �' Y9 - ••,6f;,',':'. 3 3I 1 Y ''. . d3. Ir i :y,� .: I '1� / s _ �..� �t - '131440:7 'y Iraq! 1 is1 r 1 a . 1i t r- :111 3111111 , 11 • 3 33 3 1 _ 1'P \91 i N gC 3 11313 .3�3�1 31 F 7 1j t. F+ r/ .. t 3 �� „, � 3 1 S 31 if 331 1 j31 11 .31 1i, z u .. 1�� 1 --ri ..,,•„4",•:;:7.,,,61F.59—.7:,..,2'„,---",— -= �a 1 1 .r 1 1 1� �z�.3 t1 1�� .. 1 .. -- - ,1V� 11 v ,� 1�1j�� S r 1v ..wu:,.t11.2��' . �..., ,,.....,.....:�._.._ ,�� -. ...............:...: 1._: � d�3 ..._.y 3. .. � - ,,, :.. ..,,,Maa�.c.:v;..:< ..............�...,.,..... Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point S Process If SCC Code Pollutant Factor Control% Units 002 01 3-10-001-60 Flares PM10 14.41 o Ib/MMSCF PM25 14.41 0 lb/MMSCF sox 1.14 0 Ib/MMSCF NOx 131.51 0 Ib/MM5CF VOC 52831.20 95 Ib/MM5CF Co 599.54 0 Ib/MM5CF Benzene 134.24 95 Ib/MM5CF Toluene 130.37 95 Ib/MM5CF Ethylneezene 9.02 95 Ib/MM5CF 0ylene 33.631 95 Ib/MM5CF n-Hexane 1004.4 95 Ib/MM5CF 224 IMP 0.63 95 Ib/MM5CF 5 of 6 K:\PA\2018\18WE0412.CP1.xlsm Separator Venting Regulatory Analysis Worksheet - Colorado Regulation 3 Pars 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(Regulation3,Part A,Section ll.D.l.a)7 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOX greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,PartS,Section l[.D.3)? [Not enough Information _• NON-ATTAINMENT -- - 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than l TPY(Regulation 3,Part A,Section II.0.1.a)? %MI5Source Req 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY,000 greater than 5TPY or CO emissions greater than 10TPY(Regulation 3,Part B,Section 11.0.2)? Source Reg • [Source requires a permit - Colorado Regulation 7,Section XVII 1. Was the well newly constructed,hydraulically fractured,orrecompleted on or after August 1,2014? r[Sourre ism [Source is not subject to Regulation 7,Section XVII.B.2,G Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of 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 [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 rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts endcircumstances.This document does not change or substfutefor 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. r CDPHE egit :tAir id,a4 n Contro yj.„, Me <. DcDa ent ofomW he Heal; EnvFrcrr sent ., XT ktrA2 MZEd2trA CONSTRUCTION PERMIT Permit number: 18WE0412 Issuance: 1 Date issued: Issued to: Extraction Oil Et Gas, Inc. Facility Name: Keiser 14-28 Production Facility Plant AIRS ID: 123/9F1 E Physical Location: SWSW SEC 28 T4N 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 LP Separator 002 Venting of gas from one Low Pressure (LP) Enclosed Flare Venting separator 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/pacific/cdphe/other-air-permitting- notices. 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 compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) eDet E COLORADO A...,.. :Air Pollution Control Division Page 1of7 ''' ;•--t, --,--,„ ...iwammim,, , _ ,, _ ,,,,,,,,....„.,,,,,,,r,„e„ ,,,,-,, -IA ,,,.,, ., •,,, t.,,,, . 3. ! spertI ,s expir f er or oper or = e source hit this perms .as issued: does not c enc o tion/modifi;, • peration is ource withi , 8 months after either jr e datf is ce of t, g constr on perm or the date on ich such strucS 9 r actis p #was s used commen as set th in the perms cation 4with th rtiri; (ii)`di ' Dili u s cons i?' 1 a• eriod of eigh e the 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.) 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.) .A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO, VOC CO Type LP Separator 002 --- 4.2 83.6 19.4 Point Venting 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.) Facility AIRS Pollutants Control Device Equipment ID Point Controlled LP Separator 002 Enclosed Flare VOC and HAP Venting zE COLORADO +O Air Pollution Control Envision ,�.. .. . _ Page 2 of 7 nip PROCES ; IMITATION. ND R Cy 8. source s be ti ' ed tQL; e followi rtixTm6 processirOrateAs listed be . Monthly ords oft ; ctual cessirt tes sh be main ed by t� owner or operatorand made ablest he Divi en insP'eaionzuOarkcequesLa lalooialumber 3, Pare .) Process Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point LP Separator 002 Gas Venting 63.3 MMSCF Venting Compliance with the annual throughput limits shall be determined on a rotting 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 gas vented from the separator(s) to the flare 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. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) OPERATING Ft MAINTENANCE REQUIREMENTS 13. 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 0&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 14. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after issuance of this permit of the gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n- hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self-certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 pm COLORADO Air Pollution Control Division Page 3 of 7 or in a t frams to by the D' sio request f modificati o address 's/these inn racy 15. _- owner opera $.E shat monstr e compl e wit ~ pacity standards sing EPA ear et hod 24 F.R. pendix to the presen celotabsence 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.16) ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shalt 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. 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. 17. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold wilt require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization crlIE COLORADO 41, Co Air Pollution Control Btvislon Page 4 of 7 5 not be grad un the lion or activity mences a s en verified the APCD conformin all , spe ; ith the con ktbos o *, the perm ii n self-certifi . ion of all nts has be evie and roved byhe Divisi ,�it will ide written docu tation of h fin onzati. ,Detailsor obta ng final a t orizati' to operate are to ed in the aurAgvatua- ` fluihements to Seff'Certfy for 1=i u orizatiorllgc`fion i permit. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the'costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Carissa Money Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Issued to Extraction Oil 8 Gas, Inc for venting of gas from one low pressure separator (AIRS ID 002) caP a COLORADO CO Air Pollution Control Division Page 5 of 7 Notes t rmitHold"t the I5tJPpermit iss4inc 1) The hermit holde , requil' to ees for thp4es" -time fo is p it. An invo for these fee ll be issu " `" fter t ermi 'ssued. e perms t Lder sh ay the invoice w n 30 days o e inv 'lure invoice. ._ ��re revocation 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 AIRS Uncontrolled Controlled Equipment ID Point Pollutant CAS # Emissions Emissions (Ib/yr) (Ib/yr) Benzene 71432 8,496 425 Toluene 108883 8,251 413 Ethylbenzene 100414 609 30 LP Separator Venting 002 Xylenes 1330207 2,128 106 n-Hexane 110543 63,552 3,178 2,2,4- 540841 40 2 Trimethylpentane 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 002: Uncontrolled Controlled CAS # Pollutant Weight Emission Emission Source Percent of Factors Factors Gas (%) (lb/MMSCF) (lb/MMSCF) NOx --- 131.51 131.51 AP-42, Table 13.5-1 CO --- 599.54 599.54 AP-42, Table 13.5-2 VOC 58.8 52,831 2,641.6 Extended gas analysis 71432 Benzene 0.15 134.24 6.7119 Extended gas analysis 108883 Toluene 0.15 130.37 6.5186 Extended gas analysis * axam COLORADO CO et Air Pollution Control Division Page 6 of 7 ifia 11 711 I '-• ' ,,,,,, 11 Weight ., n issio # ° luta cent of I Fact& ctors, a i rce � ' c%� i� (Ib/MMSat. (I SCF) '' Ex ended'gas 100414 Ethylbenzene 0.01 9.6206 0.4810 analysis 1330207 Xylene 0.04 33.627 1.6814 Extended gas analysis Extended gas 110543 n-Hexane 1.12 1,004.1 50.207 analysis 540841 2,2,4- 0.001 0.6294 0.0315 Extended gas Trimethylpentane analysis 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 facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, HAPs NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the 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 eOgE COLORADO O 7 Aix Pollution Control Division Page 7 of 7 s'. CDRHE Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and CO Vrr 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: ' glib L)')z AIRS ID Number: 123 /9F1 E/&03 [Leave boink unless PCID has cy assigned a permit.`and - Company equipment Identification: • LP Separator Venting inro i.t•: a::-ity Equipment ID to identify how ttsis equipment i,referenced within your crgerCzatihn] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Keiser 14-28 Production Facility Site Location Site Location: SWSW Sec. 28 T4N, R66W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 E-Mail Address2: ksteerman@extractionog.com '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. volir Form APCD-211 Natural Gas\ent ,APEN - Rev 03/2017 17 1 A COLORADO 3 *5 g Permit Number: AIRS ID Number: 123 /9F1 E/ c ave blank ,I;k-as A_PCD atreariy asigned a permit tt and APS lEd, 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 ❑ Transfer of ownership' ❑ 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: '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: 1 For new or reconstructed sources, the projected start-up date is: /TB D/ ❑ 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 days/week weeks/year Will this equipment be operated in any NAAQS nonattainment Yes ❑ No area Is this equipment located at a stationary source that is ❑ Yes No considered a Major Source of(HAP) Emissions AteCOLORADO L. APCDD 211 -P,iaturat Gas Venting,APEN .. Re 03/20)7 2 '{t Permit Number: AIRS ID Number: 123 /9F1 E bank unless A=CJ has aireaIy assiaeti pei and AIRS ID] Section 4 - Process Equipment Information ❑r Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: Gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event ❑ Other Description: 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? E Yes ❑ No Maximum Vent 7 224 6 SCF/hr Vent Gas 1 934 BTU/SCF Natural Gas Venting Rate: Heating Value: Process Parameters4: Requested: 63.29 MMSCF/year Actual: 52.74 MMSCF/year -OR- Liquid Throughput 4 Requested: Bbl/yr Actual: Bbl/yr Process Parameters4: 4 Requested values will become permit limitations. Requested limit(s)should consider future process growth Molecular Weight: VOC (mole%) 37.90 VOC (Weight%) 58.74 Benzene (mole%) 0.0651 Benzene (Weight%) 0.1493 Toluene (mole%) 0.0536 Toluene (Weight%) 0.1450 Process Properties: Ethylbenzene (mole%) 0.0034 Ethylbenzene (Weight%) 0.0107 Xylene (mole%) 0.0120 Xylene (Weight%) 0.0374 n-Hexane (mole%) 0.4416 n-Hexane (Weight%) 1.1168 2,2,4-Trimethylpentane 2,2,4-Trimethylpentane (mole%) 0.0002 (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 It n-Hexane, temperature, and pressure) y COLORADO Fort APCD-211 -Natural Gas Venting r1.1=EN- Rev 03/2011 3 iZl Permit Number: AIRS ID Number: 123 /9F1 E/ Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.27732, -104.78450 Discharge Height Operator Temp. Flow Rate Velocity Above Ground Level Stack ID No. (V). (ACFM) (ft/sec)(Feet) ECD -20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ✓❑ Upward ❑ Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑ Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): TBD ❑ Other(describe): Section 6 - Control Device Information Pollutants Controlled: Size: Make/Model: ❑ VRU: Requested Control Efficiency % VRU Downtime or Bypassed % Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: ECD Make/Model: V1 Requested Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency >98 % Minimum Temperature: TBD Waste Gas Heat Content 1934 Btu/scf Constant Pilot Light: ❑� Yes ❑ No Pilot burner Rating TBD MMBtu/hr Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested ° COLORADO Form APCD-211 l l`?_xtul'i_t Gas Vcnt n APE�I _. Re/ 03'2011 :;. �;. f�- Permit Number: AIRS ID Number: 123 /9F1 E/ i.- ,.,.Jnk unL,?-,.s APCD i pein -a1 d ".PS liJi 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? E Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency(% reduction): Overall Requested Control Pollutant Control Equipment Description Efficiency (%reduction in emissions) PM SOX NOx VOC Enclosed Combustion Device 95% CO HAPs Endosed Combustion Device 95% 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.) Emission Requested Annual Permit Uncontrolled Emission Factor Actual Annual Emissions Limit(s) Pollutant Emission Factor Source Emission Factor Units (AP-42, Uncontrolled Controlled6 Uncontrolled Controlled Mfg.etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) PM SOx NOx 0.068 lb/MMBtu AP-42 3.55 4.25 VOC 52,775.15 lb/MMscf Gas Anaysis 1,391.67 69.58 1,670.00 83.50 CO 0.31 Ib/MMBtu AP-42 16.20 19.36 Benzene 134.04 lb/MMscf Gas Analysis 3.53 0.18 4.24 0.21 Toluene 130.15 lb/MMscf Gas Analysis 3.43 0.17 4.12 0.21 Ethylbenzene 9.51 lb/MMscf Gas Analysis 0.25 0.01 0.30 0.02 Xylenes 33.58 lb/MMscf Gas Analysis 0.89 0.04 1.06 0.05 n-Hexane 1,003.06 lb/MMscf Gas Analysis 26.45 1.32 31.74 1.59 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,A.r"CL-L 1' -Natural Gas Venting APEN Rev CS/2017 5 W Permit Number: AIRS ID Number: 123 /9F1 E/ [Leave btank unless APCD has already assigned a perma F/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) Date Kathy Steerman Air Quality Coordinator Name(please print) Title Check the appropriate box to request a copy of the: Q✓ 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: For more information or assistance call: Colorado Department of Public Health and . Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B1 • 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 https://www.colorado.gov/cdphe/apcd Make check payable to: Colorado Department of Public Health and Environment Telephone: (303)692-3150 cotoaAao Form APCD-211 -Natural Gas Venting APEN Rev 03/2017 6 1 I°^ d° Hello