HomeMy WebLinkAbout20180429.tiffCOLORADO
Department of Public
Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County- Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
February 5, 2018
Dear Sir or Madam:
RECEIVED
FEB Q72018
WELD COUNTY
COMMISSIONERS
On February 8, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for
Extraction Oil Et Gas, Inc. - Kennedy Production Facility. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health >:t 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
John W. Hickenlooper, Governor
Pub' 1 ie Rem €ii)
Okla
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
I Larry Wotk, MD, MSPH, Executive Director and Chief Medical Officer
CC: PLC MM(TP) , (-f . (TT),
PW CE fe..c
0A. -O7-1?
2018-0429
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Extraction Oil Et Gas, Inc. - Kennedy Production Facility - Weld County
Notice Period Begins: February 8, 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: Kennedy Production Facility
Oil and Gas exploration and production facility
NENE Section 18, T4N, R68W
Weld County
The proposed project or activity is as follows: Applicant proposes to construct a well production facility and
is requesting to vent 3.6 MMscf/year of produced natural gas from the 3 -phase separators and 4.6
MMscf/year of natural gas from the vapor recovery tower. Applicant also requests to vent 91.9 MMscf/yr of
sates gas before the installation of a pipeline.
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 applications.
Copies of the applications, the Division's analyses, and drafts of Construction Permits 17WE0930, 17WE0931,
and 17WE0932 have been filed with the Weld County Clerk's office. Copies of the draft permits and the
Division's analyses 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 projector 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:
Oluwaseun Ogungbenle
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
1
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE0930
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Extraction Oil Ft Gas, Inc.
Kennedy Production Facility
123/9F5C
NENE SEC 18 T4N R68W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
VRT Venting
001
Vapor Recovery Tower (VRT) gas controlled
by an enclosed combustor during VRU
downtime.
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/ 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.)
COLORADO
Mr Pollution Control Division
Department car Pte" Hen n.& E^,vlrorrrteit
Page 1 of 7
3. �'"'!' "'� ' all a r�_' �.. , e o - _.tor of r. r :� ich this per ssued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part D, -"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
Number3, Part B, Section. III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction. permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
VRT Venting
001
---
---
13.0
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month, a new twelve-month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
VRT Venting
001
Emissions from the VRT are routed to an
Enclosed Flare during Vapor Recovery Unit
(VRU) downtime
VOC and HAP
COLORADO
AixPollution Control Division
Page 2 of 7
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
VRT Venting
001
Natural Gas Venting
4.6 MMS€F' --
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month, a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
9. Upon installation of the flow meter, the owner or operator shall continuously monitor and record
the volumetric flow rate of natural gas vented from VRT 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 markedon the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation
from the outside of the enclosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating properly. This flare must be equipped
with an operational auto -igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On
or after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING a MAINTENANCE REQUIREMENTS
14. Upon startup of this point, the owner or operator shall follow the most recent operating and
maintenance (OEtM) plan and record -keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
COLORADO
Air Pollution Control Division
i kp: rert U Ritbli= HeuY.n.e EE.tivo4 ert
Page 3 of 7
are
Part B, Section IIi.G.7.
on. (Regul ,:. �- ber-3,
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
16. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. 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
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
18. Federal regulatory program requirements (i.e. 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
will 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).
COLORADO
Mr Pollution Control Division
rro'v-rmer:c
Page 4 of 7
19. This permit and any attachments must be retained and made available for inspection upon,
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the -issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD inwriting in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G_ Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy andcompleteness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the. Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Oluwaseun Ogungbenle
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil Et Gas, inc.
OLORADO
on Control. Division
Evvmrnheex
Note
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 isno exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete applicationform must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the. Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II. E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
VRT Venting
001
Benzene
71432
588
29
Toluene
108883
543
27
Ethylbenzene
100414
60
3
Xylenes
1330207
185
9
n -Hexane
110543
8270
414
2,2,4-
Trimethylpentane
540841
149
7
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 001:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
V0C
113568.94
5678.45
ProMax
71432
Benzene
128.272
6.414
ProMax
108883
Toluene
118.455
5.923
ProMax
100414
Ethylbenzene
13.089
0.654
ProMax
1330207
Xylene
40.358
2.018
ProMax,
110543
n -Hexane
1804.101
90.205
ProMax
540841
2, 2, 4
Trimethylpentane
32.504
1.625
ProMax
COLORADO
I Air Pollution Control Division
lit lYut1 6 t ;n 3 E::vnor;:rc
t are - •ntrol efficie
The emission factors listed above are based on modeled separator temperature of 95 °F and separator
pressure of 7 psig.
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 fegarding a specific expiration date call. the Division
at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
0perating'Permit
Synthetic Minor Source of: V0C and n -Hexane
NANSR
Synthetic Minor Source of V0C
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.grioaccess.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
COLORADO
I Air Pollution Control Division
Oubtc W esE.irtrme%t
Page 7 of 7
Colorado Air Permitting Project
Project Details
Review Engineer:
Package 8:
Received Date:
Review Start Date:
Section 01- Facility Information
Oluwaseun Ogungbenle
368905
9/11/2017'
12/20/2017
Company Name: Extraction Oil & Gas, Inc
County AIRS ID: 123
Plant AIRS ID: 9F5C
Facility Name: Kennedy Production tadllty
Physical Address/Location: NENE quadrant of Section 18, Township 48, Range 68W, in Weld County, Colorado
Type of Facility: Exploration &. Production .Weil "Pad
What industry segment? Oil'&.Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? yes.
If yes, for what pollutant? carbon Monoxide (CO) `Eardculate Matter (PM) zone (NOx & VOC)
Weld
Quadrant
Section
Township
Range
NENE 18 ,
4N
6
Section 02 - Emissions Units In Permit Application
AIRs Point if
Emissions Source Type
Equipment
Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
001
Vapor Recovery Tower (VRTj
VRT Gas
Venting
Yes
17WE0930
1
Yes
Permit initial
Issuance
New point
002
Separator Venting
Produced Gas
Venting
Yes
17WE0931
1
Yes
Permit Initial,
issuance
New point
003
Separator Venting
Sales Gas
Venting
Yes
17WE0932
1
Yes
Permit Initial
issuance
New point
Colorado Air Permitting Project
Section 03 - Description of Project
In addition tothe three,; em)ss
emission points condej�satg s
compressor.;englrles, acid ol�
at this facility are ,covereci
as part of thispermittirngaction Extractian'G
producer! waterstorage tank (2 400 bbl vessels)
roe: Besides the three points•coverdd by thi ng
iias is also re
truck condensate
lysis, all other equi
Emjssians d'ae to Separator, VRT d d safes gas venting;were modeled using ProMax. aperatac claims to Kaye drilled three new, rnrte horizon#aJ3 n+ells at th
facility wlthie date,of first produetic nlof 6113/2017. The:gas analysis used to caleuiate.the separator, venting emissionswas based of a p*.'t) iedfrom
o th 3 wells er ing t €s facilit
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why?
Section 05 - Ambient Air Impact Analysis Requirements
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
S02 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ ❑ O ❑
O O ❑ El O ❑ ❑ El
❑ a
SO2 NOx
❑ O
❑ ❑
CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ ❑
El ❑ O ❑ ❑ ❑
O ❑
Produced. Natural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer.
Oluwaseun Ogungbenle
Control Engineer:
Stephanie Spector
' Review Date:
12/20/2017
Application Date:
09/11/2017
Facility Information
Permit No.
17WE0930
123 Weld
9F5C
001
VRT Gas Venting
Extraction Oil & Gas, Inc.
Kennedy Production Facility
NENE Section 18, Township 4N, Range 68W
AIRs
County #
Facility #
Point #
Facility Equipment ID
Company Name:
-"Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment -
SOx
Attainment
NOx
Nonattainment
VOC
Nonattainment
CO
Attainment
Potentially Located within EAC - determine attainment status of NOx and \
Source Name:
Source Location:
SIC:
211111
Unknown
Elevation (feet)
x
New Permc (CP1)
Modification
(Issuance #)
APEN
Required/Permit
Exempt
Notes
Transfer of
Ownership
APEN
Exempt/Permit
Exempt
Condensate from the high -low pressure (HLP) separators flows to the Vapor Recovery Tower (VRT)
where dissolved gas is flashed off. Flash em ssions from the. VRT are routed to an onsite vapor recovery
unit (VRU) during normal operation. Emissions from the VRT are routed to an enclosed combustor during
VRU downtime or when the VRT is overpressunzed. There is a gas flow meter that tracks the volume of
VRT gas being combusted.
Produced Natural Gas Venting/Flaring Preliminary Analysis
Eauioment Description.
This source vents natural gas from:tlseparator
Emissions from this source are:
outo`anenclosed flare
Colorado Department of`Public Health and Environment
Air Pollution Control Division
Natural gas venting from a well head separator. Emissions from this source are routed to an enclosed flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q*MW*Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas- processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Maximum Vent Rate I
3000 scf/hr
RequestedThroughput (Q)
4.6 MMscf/yr
523.3 scf/hr I 0.000 MMscf/d I 0.39 MMscf/mo
% Vented I
17%
MW 48.860
Ib/Ib-mol
Component
mole %
MW
Ibx/Ibmol
mass traction
E
lb/hr
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
0.4075
'
44.01
0.179
0.004
CO2
0:2
2169
1.08
N2
1.7599
28.013
0.493
0.010
N2
0.7
5963
2.98
methane
1.8287
16.041
0.293
0.006
methane
0.4
3548
1.77
ethane
15.9089
30.063
4.793
0.098
ethane
6.6
57847
28.92
propane
41.4911
-
44.092
18.2943
0.374
propane
25.3
221269
110.63
isobutane
6.0471
58.118
3.5145
0.072
isobutane
4.9
42507
21.25
n -butane
20.3085
58.118
11.8029
0.242
n -butane
16.3
142756
71.38
isopentane
3.9697
72.114
2.8627
0.059
isopentane
4.0
34624
17.31
n -pentane
4.6733
72.114
3.3701
0.069
n -pentane
4.7
40761
20.38
cycbpentane
0.2341
70.13
0.1642
0.003
cyclopentane
0.2
1986
0.99
n -Hexane
0.7944
86.18
0.6846
0.014
n -Hexane
0.9
8280
4.14
cyclohexane
0.0874
84.16
0.0736
0.002
cyclohexane
0.1
890
0.44
Other hexanes
1.12
86.18
0.9652
0.020
Other hexanes
1.3
11674
5.84
heptanes
1.0438
100.21
1.0460
0.021
heptanes
1.4
12651
6.33
methylcyclohexane
0.0975
98.19
0.0957
0.002
methylcyclohexane
0.1
1158
0.58
224-TMP
0.0108
114.23
0.0123
0.000
224-TMP
0.0
149
0.07
Benzene
0.0623
78.12
0.0487
0.001
Benzene
0.1
589
0.29
Toluene
0.0488
92.15
0.0450
0.001
Toluene
0.1
544
0.27
Ethylbenzene
0.0047
106.17
0.0050
0.000
Ethylbenzene
0.0
60
0.03
Xylenes
0.0144
106.17
0.0153
0.000
Xylenes
0.0
185
0.09
C8+ Heavies
0.0869
128.501
0.1117
0.002
C8+ Heavies
0.2
1351
0.68
Notes
VOC mass fraction: 0.8824 Total VOC Emissions (Uncontrolled)
annual limit assuming 95% control
monthly limit assuming 95% control (lb/mo.)
260.7
13.0
2214.3
Mole %, MW, and mass fractions from analysis of Kennedy Pad VRT gas sample collected 07/24/2017.
Emissions are based on 8760 hours of operation per year.
I calculated the average MW of C8+ based on the average MW on the analysis for the gas.
Produced Natural Gas Venting/Flaring Preliminary Analysis
Flaring Information
Equipment Description
Flare to combust VRT gas during VRU downtime.
Manufacturer
Model
Serial Number
Gas Heating Value
Throughput
Questor
Q3000
TBD
2725
12491.4
Btu/scf
MMBtu/yr
Combustion emission factor source: AP -42: Chapter 13.5
0.068
lb NOx/MMBtu
0.31
lb CO/MMBtu
0.42
tpy NOx
1.94
tpy CO
Emissions. Summary
0.42
tpy NOx
Uncontrolled/PTE
. 1.94
tpy CO
260.7
tpy VOC
Controlled
13.0
tpy VOC
Colorado Department of Public Health and Environment
Air Pollution Control Division
Uncontrolled
Total (lb/yr)
Scenario A
Reportable?
Controlled Total
(Ib/yr)
Benzene
589
Yes
29
Toluene
544
Yes
27
Ethylbenzene
60
No
3
Xylenes
185
No
9
n -hexane
8280
Yes
414
224-TMP
149
No
7
Emission Factors for Permit
meter installed:
Uncontrolled
NOx
185.3
lb/MMscf natun
CO
844.8
lb/MMscf natun
VOC
113751
lb/MMscf natun
Benzene
128.414
lb/MMscf natun
Toluene
118.652
lb/MMscf natun
Ethylbenzene
13.1662
lb/MMscf natun
Xylenes
40.3390
lb/MMscf natun
n -Hexane
1806.37
lb/MMscf natun
224-TMP
32.5510
lb/MMscf natun
Controlled
NOx
185.3
lb/MMscf natun
CO
844.8
lb/MMscf natun
VOC
5688
lb/MMscf natun
Benzene
6.4207
lb/MMscf natun
Toluene
5.9326
lb/MMscf natun
Ethylbenzene
0.6583
lb/MMscf natun
Xylenes
2.0169
lb/MMscf natun
n -Hexane
90.3185
Ib/MMsd natun
224-TMP
1.6276
lb/MMscf natun
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
Produced Natural Gas Venting/Flaring Preliminary Analysis
Regulatory Applicability
AQCC Regulation 1
Colorado Department of Public Health and: Environment
Air Pollution Control Division
This source is subject to the opacity requirements for flares in Section II.A.5:'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.'
AQCC Regulation 2
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of
odorous air contaminants from any single source such as to result in detectable odors which are measured in
excess of the following limits: For areas used predominantly for residential or commercial purposes it is a
violation if odors are detected after the odorousair has been diluted with seven (7) or more volumes of odor free
air:.,
AQCC Regulation 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions exceed one
ton per year in a nonattainment area for ozone.
Part B:
A permit is required for this source because uncontrolled VOC emissions from this
facility exceed two tons per year in a nonattainment area for ozone.
This source is subject to Section III.D.2 (Minor Source RACT) because it is located in
a nonattainment area. RACT for this source has been determined to be the use of a
flare to control emissions.
Is public comment
required?
Public Comment Required
AQCC Regulation 7
Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
yes
This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, XVII.B.2
Facility Status
This facility is a synthetic minor source of VOC and HAP for Title V applicability.
This facility is a synthetic minor source of VOC for NSR applicability.
COLORADO DEPARTMENT OF PUBLIC HEALTH ENVIRONMENT
AIR POLUTION CONTROL DIVISION
INVENTORY
AIRS (County/Plant) 123/9F5C
Permit No. 17WE0930
Date 12/20/2017
Point #
'
Seg '
SCC
Pollutant or CAS
Fug
Dust
Uncontrolled Emission
Factor
Emisison Factor Source
Controlled
Actual
Emissions
(tpy)*
Controlled
Requested
Emissions
(tpy)*
PTE (tpy)*
Ctrl.
Eff%
NCRP =
reportable
?
001
31000205
NOx
n
185.3 Ib/MMscf
AP -42:: Chapter 13.5
0.4
0.4
0%
CO
n
844.75 Ib/MMscf
AP -42: Chapter 13.5
1.9
1.9
0%
VOC
n
113750.987 Ib/MMscf
Engineering Calcs
13.0
260.7
95%
71432
Benzene
n
128.413615 lb/MMscf
Engineering Calcs
29
589
95%
Yes
108883
Toluene
n
118.652243 lb/MMscf
Engineering Calcs
27
544
95%
Yes
100414
Ethylbenzene
n
13.1662005 Ib/MMscf
Engineering Calcs
3
60
95%
No
1330207
Xylene
n
40.3389974 lb/MMscf
Engineering Calcs
9
185
95%
No
110543
n -Hexane
n
1806.36918 lb/MMscf
Engineering Calcs
414
8280
95%
Yes
540841
224-TMP
n _
32.551029 lb/MMscf
Engineering Calcs
7
149
95%
No
NOTES
*Emissions of criteria are reported in tons/yr; emissions of NCRPs are in lb/yr.
You can copy each row into the permit history file for a facility -wide summary.
Thefirst row can be copiedinto the Criteria tab.
The second and third rows can be copied into the HAPs tab.
Be sure to do Edh, Paste. Special, Values to avoid creating links back to this PA in the history file.
Controlled Emissions
Uncontrolled Emissions
POINT
001
PERMIT
17WE0930
Description
Produced natural gas venting
NOx
0.4 '
VOC
13.0
Fug VOC
Controlled Emissions
Formaldehyde
CO
1.9
Reportable
HAPs
Total
HAPs
NOx
0.4
VOC
260.7
Fug VOC
CO
1.9
Reportabl
e HAPs
POINT
001
PERMIT
17WE0930
Description
Produced natural gas venting
Acetaldehyde
Benzene
29
Acrolein
Toluene
27
Eb y benzene
3
Xylene
n -Hexane
414
2,2,4 -Trim[
7
Methanol
1,3-6utadiene
Uncontrolled
Forrnaldetape
POINT
001
PERMIT
17WE0930
Description
Produced natural gas venting
A¢ acehyde
Benzene
589
Acrolein
Toluene
544
Ehylbereene
60
Xylene
185
n -Hexane
8280
2,2;4 -Trims
149
Methanol
1,3 -Butadiene
Total
HAPs
Produced Natural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer:
Oluwaseun Ogungbenle
Control Engineer
Stephanie Spector
Review Date:
12/20/2017
Application Date:
09/11/2017
Facility Information
Permit No.
17WE09131
123 Weld
9F5C
002
Produced Gas Venting
Extraction Oil & Gas, Inc.
Kennedy Production Facility
NENE Section 18, Township 4N, Range 68W
AIRs
County #
Facility #
Point #
Facility Equipment ID
Company Name:
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Nonattainment
VOC
Nonattainment
CO
Attainment
Potentially Located within EAC - determine attainment status of NOx and \.
Source Name:
Source Location:
SIC:
211t11
Unknown
Elevation (feet)
x
New Permit (CP1)
Modification
(Issuance #)
APEN
Required/Permit
Exempt
APEN
Exempt/Pemtit
Exempt
Transfer of
Ownership
Notes
The low-pressure gas streams from the HLP separators are captured with a vapor recovery unit (VRU)
under normal operating conditions. During VRU downtime, emissions from the low pressure sides of the
HLP separators are routed to an erclosed combustor. The high-pressure gas streams are sent directly to
two 2 -phase separators; outlet gas from the 2 -phase separators is then compressed into the sales gas
line.
Produced Natural Gas Venting/Flaring Preliminary Analysis
Equipment Description
This source vents natural gas from:
wellhead separator
Emissions from this source are:
auied tos enclosed flare
Colorado Department of Public Health and Environment
Air. Pollution Control Division
Natural gas ventingfrom a well head separator. Emissions from this source are routed to an enclosed flare.
Emission Calculation Method
EPA. Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q*MW*Xx/C
Ex = emissions of pollutant x
Q'= Volumetric flow rate/volume of gas -processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Maximum Vent Rate I 1000 scf/hr
RequestedThroughput (Q) 3.6 MMscf/yr
411.0 scf/hr 0.000 MMscf/d I 0.31 MMscf/mo I
% Vented 1 41.10%
MW 23.870 Ib/Ib-mol
Component
mole %
MW
Ibx/Ibmol
mass fraction
E
Ib/hr
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
1.6001
44.01
0.704
0.030
CO2
0.8
6689
3.34
N2
0.7361
28.013
0.206
0.009
N2
0.2
1959
0.98
methane
68.0203
16.041
10.911
0.457
methane
11.8
103641
51.82
ethane
14.4272
30.063
4.337
0.182
ethane
4.7
41198
20.60
propane
10.0482
44.092
4.4305
0.186
propane
4.8
42083
21.04
isobutane
0.9521
58.118
0.5533
0.023
isobutane
0.6
5256
• 2.63
n -butane
2.8034
58.118
1.6293
0.068
n -butane
1.8
15476
7.74
isopentane
0.4556
72.114
0.3286
0.014
isopentane
0.4
3121
1.56
n -pentane
0.5422
72.114
0.3910
0.016
n -pentane
0.4
3714
1.86
cycbpentane
0.0251
70.13
0.0176
0.001
cycbpentane
0.0
167
0.08
n -Hexane
0.0849
86.18
0.0732
0.003
n -Hexane
0.1
695
0.35
cyclohexane
0.0101
84.16
0.0085
0.000
cyclohexane
0.0
81
0.04
Other hexanes
0.119
86.18
0.1026
0.004
Other hexanes
0.1
974
0.49
heptanes
0.1208
100.21
0.1211
0.005
heptanes
0.1
1150
0.57
methylcyclohexane
0.0134
98.19
0.0132
0.001
methylcyclohexane
0.0
125
0.06
224-TMP
0.0015
114.23
0.0017
0.000
224-TMP
0.0
16
0.01
Benzene
0.0078
78.12
0.0061
0.000
Benzene
0.0
58
0.03
Toluene
0.01
92.15
0.0092
0.000
Toluene
0.0
88
0.04
Ethylbenzene
0.0011
106.17
0.0012
0.000
Ethybenzene
0.0
11
0.01
Xylenes
0.0021
106.17
0.0022
0.000
Xylenes
0.0
21
0.01
C8+ Heavies
0.0185
119.596
0.0221
0.001
C8+ Heavies
0.0
210
0.11
Notes
VOC mass fraction: 0.3231 Total VOC Emissions (Uncontrolled)
annual limit assuming 95% control
monthly limit assuming 95% control (lb/mo.)
36.6
' 1.8
311.0
Mole %, MW, and mass fractions from Kennedy 2 (N) Production gas analysis collected 07/24/2017.
Emissions are based on 8760 hours of operation per year.
I calculated the average MW of C8+ based on the average MW on the analysis for the gas.
Produced Natural Gas Venting/Flaring Preliminary Analysis
Flaring Information
Equipment Description
Flare to combust low-pressure separator gas. ?roduced gas) during VRU downtime.
Manufacturer
Model
Serial Number
Gas Heating Value
Throughput
Questor
Q3000
TBD
1378.09
4961.124
Btu/scf
MMBtu/yr
Combustion emission factor source: AP -42: Chapter 13.5
0.068 lb NOx/MMBtu
0.31
lb CO/MMBtu
0.17
tpy NOX
0.77
tpy CO.
Emissions Summary
0.17
tpy NOx
Uncontrolled/PTE
0.77
tpy CO
36.6
tpy VOC
Controlled
1.8
tpy VOC
Colorado Department of Public Health and Environment
Air Pollution Control Division
Uncontrolled
Total (lb/yr)
Scenario A
Reportable?
Controlled Total
(Ib/yr)
Benzene
58
No
3
Toluene
88
No
4
Ethylbenzene
11
No
1
Xylenes
21
No
1
n -hexane
695
Yes
35
224-TMP
16
No
1
Emission Factors for Permit
meter installed:
Uncontrolled
NOX
93.7
lb/MMscf natur
CO
427.2
lb/MMscf natur
VOC
20346
lb/MMscf natur
Benzene
16.077
lb/MMscf natur
Toluene
24.314
lb/MMscf natur:
Ethylbenzene
3.0815
lb/MMscf nature
Xylenes
5.8828
lb/MMscf natur:
n -Hexane
193.05
lb/MMscf naturs
224-TMP
4.5210
lb/MMscf naturs
Controlled
NOx
93.7
lb/MMscf natur:
CO
427.2
lb/MMscf natur
VOC
1017
lb/MMscf nature
Benzene
0.8039
lb/MMscf natur:
Toluene
1.2157
lb/MMscf naturs
Ethylbenzene
0.1541
lb/MMscf natur:
Xylenes
0.2941
lb/MMscf natur
n -Hexane
9.6526
Ib/MMsd natur
224-TMP
0.2260
lb/MMscf natur
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
Produced Natural Gas Venting/Flaring Preliminary Analysis
Regulatory. Applicability
AQCC Regulation 1
Colorado Department of Public Health and Environment
Air Pollution Control Division.
This source is subject to the opacity requirements for flares in Section II.A.5:'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.'
AQCC Regulation 2
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of
odorous air contaminants from any single source such as to result in detectable odors which are measured in
excess of the following limits: For areas usedpredominantly for residential or commercial purposes it is a
violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free
air."
AQCC Regulation 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions exceed one
ton per year in a nonattainment area for ozone.
Part B:
A permit is required for this source because uncontrolled VOC emissions from this
facility exceed two tons per year in a nonattainment area for ozone.
This source is subject to Section III.D.2 (Minor Source RACT) because it is located in
a nonattainment area. RACT for this source has been determined to be the use of a
flare to control emissions.
Is public comment
required?
Public Comment Required
AQCC Regulation 7
Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
yes
This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, XVII.B.2
Facility Status
This facility is a synthetic minor source of VOC and HAP for Title V applicability.
This facility is a synthetic minor source of VOC for NSR applicability.
COLORADO DEPARTMENT OF PUBLIC HEALTH ENVIRONMENT
AIR POLUTION CONTROL DIVISION
INVENTORY
AIRS (County/Plant) 123/9F5C
Permit No. 17WE0931
Date 12/20/2017
Point #
Seg *
SCC
Pollutant or CAS
Fug
Dust
Uncontrolled Emission
Factor
Emisison Factor Source
Controlled.
Actual
Emissions
(tpy)*
Controlled
Requested
Emissions
(tpy)*
PTE (tpy)*
Ctrl.
Eff%
NCRP =
reportable
?
002
31000205
NOx
n
93.71012 lb/MMscf
AP -42: Chapter 13.5
0.2
0.2
0%
CO
n
427.2079 lb/MMscf
AP -42: Chapter 13.5
0.8
0.8
0%
VOC
n
20346.1922 lb/MMscf
Engineering Calcs
1.8
36.6
95%
71432
Benzene
n
16.077467 lb/MMscf
Engineering Calcs
3
58
95%
No
108883
Toluene
n
24.3139842 lb/MMscf
Engineering Calcs
4
88
95%
No
100414
Ethylbenzene
n
3.08145119 lb/MMscf
Engineering Calcs
1
11
95%
No
1330207
Xylene
n
5.88277045 lb/MMscf
Engineering Calcs
1
21
95%
No
110543
n -Hexane
n
193.052296 lb/MMscf
Engineering Calcs
35
695
95%
Yes
540841
224-TMP
n
4.52097625 lb/MMscf
Engineering Calcs
1
16
95%
No
NOTES
*Emissions of criteria are reported in tons/yr; emissions of NCRPs are in lb/yr.
You. can copy each rowinto the permit history file for a facility -wide summary.
Thefirst row can be copied into the Criteria tab.
The secondand third rows can be copied into the HAPs tab.
Be sure to do Edit, Paste Special, Values to avoid creating links back to this PA in the history file.
Controlled. Emissions
Uncontrolled Emissions
POINT
002
PERMIT
17WE0931
Description
Produced natural gas venting.
NOx
0.2
VOC
1.8
Fug VOC
Controlled Emissions
Formaldehyde
CO
0.8
Reportable
HAPs
Total
HAPs
NOx
02
VOC
36.6
Fug VOC
CO
0.8
Reportable.
e HAPs
POINT
002
PERMIT
17WE0931
Description
Produced natural gas venting
Arelatdehyde
Benzene
3
Acrolein
Toluene -
4
Elhylbenzene
1-
Xylene
n -Hexane
35
2,2,4 -Tame
Methanol
38utedie l
Uncontrolled
Formaldehyde
POINT
002
PERMIT
17WE0931
Description
Produced natural gas venting
Acetaldehyde
Benzene
58
Acrolein
Toluene
88
Elhylbenzene
11
Xylene
21
n -Hexane
695
2,2,4 -Trims
16
Methanol
l.3 -Butadiene
Total
HAPs
ProducedNatural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer.
Oluwaseun Ogungbenle
Control Engineer.
Stephanie Spector
Review Date:
12/20/2017
Application Date:
09/11/2017
Facility Information
Permit No.
17WE0932
123 Weld
9F5C
003.
Sales Gas Venting
Extraction Oil & Gas, Inc.
Kennedy Production Facility
NENE Section 18, Township 4N, Range 68W
AIRs
County*
Facility #
Point #
Facility Equipment ID
Colorado Department of Public Health and Environment"
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Nonattainment
VOC
Nonattainment
CO
Attainment
Potentially Located within EAC -determine attainment status of NOx and \
Company Name:
Source Name:
Source Location:
SIC:
211111
Unknown
Elevation (feet)
x
New Permit (CP1 )
Modification
(Issuance #)
APEN
Required/Permit
Exempt
Transfer of
Ownership
APEN
Exempt/Permit
Exempt
Notes
As of the time of application submittal, operator claimed to have been flaring 100% of the sales gas
produced at this facility since the day of first production (6/13/2017). Operator futher claimed that a sales
gas pipeline was projected to be installed on 09/22/2017 and the sales gas would be compressed into the
pipeline from that point onward. Therefore, operator submitted a permit application for the venting of the
sales gas pending the installation of the pipleline. Consequently, this emission point would cease
operation as of 09/22/2017. There is a gas flow meter that tracks the volume of sales gas being
combusted. The gas analysisused to calculate VOC and HAP emissions for this point is based on a
sample obtained from the produced gas (low pressure separator gas) stream. This is deemed a
conservative moveby the operator since the VOC content of this stream tends to be higher than that of
the sales gas (high pressure separator gas) stream. Operator initially calculated NOx and CO emissions
for this emission point using manufacturer -recommended emission factors. However, after one or two
correspondences about the COemissionfactor being much lower than the corresponding AP -42 emission
factor, operator decided to calculate NOx and CO emissions using AP -42 emission factors. This is a
conservative move on the operators part.
Produced Natural Gas Venting/Flaring Preliminary Analysis
Eauioment Description
This source vents natural gas from:
uveltl.head separator
Emissions from this source are:
rotted Ibatt eklGlosed flare
Colorado Department of Public Health and Environment
Air Pollution Control Division
Natural gas venting from a well head separator. Emissions from this source are routed to an enclosed flare.
Emission Calculation Method -
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex= Q" MW*Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas ` MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm
Maximum Vent Rate I 46894.2 scf/hr
RequestedThroughput (Q) 91.9 MMscf/yr
10492.0 scf/hr
I 0.002 MMscf/d I 7.81 MMscf/mo
% Vented I 22.37%
MW 23.870 lbllb-mol
Component
mole %
MW
lbx/Ibmol
mass fraction
E
lb/hr
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
1.6001
44.01
0.704
0.030
CO2
19.5
170774
85.39
N2
0.7361
28.013
0.206
0.009
N2
5.7
50006
25.00
methane
68.0203
16.041
10.911
0.457
methane
302.1
2646023
1323.01
ethane
14.4272
30.063
4.337
0.182
ethane
120.1
1051812
- 525.91
propane
10.0482
44.092
4.4305
0.186
propane
122.6
1074414
537.21
isobutane
0.9521
58.118
0.5533
0.023
'
isobutane
15.3
134189
67.09
n -butane
2.8034
58.118
1.6293
0.068
n -butane
45.1
395111
197.56
isopentane
0.4556
72.114
0.3286
0.014
isopentane
9.1
79676
39.84
n -pentane
0.5422
72.114
0.3910
0.016
n -pentane
10.8
94821
47.41
cyclopentane
0.0251
70.13
0.0176
0.001
cyclopentane
0.5
4269
2.13
n -Hexane
0.0849
-
86.18
0.0732
0.003
n -Hexane
2.0
17743
8.87
cyclohexane
0.0101
84.16
0.0085
0.000
-
cyclohexane
0.2
2061
1.03
Other hexanes
0.119
86.18
0.1026
0.004
Other hexanes
2.8
24870
12.44
heptanes
0.1208
100.21
0.1211
0.005
heptanes
3.4
29356
14.68
methylcyclohexane
0.0134
98.19
0.0132
0.001
methylcyclohexane
0.4
3191
1.60
224 -IMP
0.0015
114.23
0.0017
0.000
224 -IMP
0.0
416
0.21
Benzene
0.0078
78.12
0.0061
0.000
Benzene
• 0.2
1478
0.74
Toluene
0.01
92.15
0.0092
0.000
Toluene
0.3
2235 -
1.12
Ethylbenzene
0.0011
106.17
0.0012
0.000
Ethylbenzene
0.0
283
0.14
Xylenes
0.0021
106.17
0.0022
0.000
Xylenes
0.1
541
0.27
C8+ Heavies
0.0185
119.596
0.0221
0.001
C8+ Heavies
0.6
5366
2.68
Notes
VOC mass fraction: 0.3231
Total VOC Emissions (Uncontrolled)
annual limit assuming 95%control
monthly limit assuming 95% control (lb/mo.)
935.0
46.8
7941.2
Mole %, MW, and mass fractions from Kennedy 2 (N) Production gas analysis collected 07/24/2017.
Emissions are based on 8760 hours of operation per year.
I calculated the average MW of C8+ based on the average MW on the analysis for the gas.
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Flaring Information
Equipment Description
Flare to combust low-pressure separator gas (sales as prior to pipeline installation.
Manufacturer
Questor
Model
Q5000
Serial Number
TBD
Gas Heating Value
1378.09
Btu/scf
Throughput
126660.2519
MMBtu/yr
Combustion emission factor source:
AP -42: Chapter 13.5
0.068
lb NOx/MMBtu
0.31
lb CO/MMBtu
4.31
tpy-NOx
19.63
tpy CO
Emissions Summary
4.31
tpy NOx
Uncontrolled/PTE
19.63
tpy CO
935.0 -
tpy VOC
Controlled
46.8
tpy VOC
Uncontrolled
Total (Ib/yr)
Scenario A
Reportable?
Controlled Total
(Ib/yr)
Benzene
1478
Yes
74
Toluene
2235
Yes
112
Ethylbenzene
283
Yes
14
Xylenes
541
Yes
27
n -hexane
17743
Yes
887
224-TMP
416
Yes
21
Emission Factors for Permit
meter installed:
Uncontrolled
NOx
93.7
lb/MMscf natun
CO
427.2
lb/MMscf natun
VOC
20346
lb/MMscf natun
Benzene
16.077
lb/MMscf natun
Toluene
24.314
lb/MMscf natun
Ethylbenzene
3.0815
lb/MMscf natun
Xylenes
5.8828
lb/MMscf natun
n -Hexane
193.05
lb/MMscf natun
224-TMP
4.5210
lb/MMscf natun
Controlled
NOx
93.7
lb/MMscf natun
CO
427.2
lb/MMscf natun
VOC
1017
lb/MMscf natun
Benzene
0.8039
lb/MMscf natun
Toluene
1.2157
lb/MMscf natun
Ethylbenzene
0.1541
lb/MMscf natun
Xylenes
0.2941
lb/MMscf natun
n -Hexane
9.6526
lb/MMscf natun
224-TMP
0.2260
lb/MMscf natun
I gas vented
I gas vented
I gas vented:
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
Produced Natural Gas Venting/Flaring Preliminary Analysis
Regulatory Applicability
AQCC Regulation 1
Colorado Department of Public Health and Environment
Air Pollution Control ivision
This source is subject to the opacity requirements for flares in. Section II.A.5:'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.'
AQCC Regulation 2
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of
odorous air contaminants from any single source such as to result in detectable odors which are measured in
excess of the following limits: For areas used predominantly for residential or commercial purposes it is a
violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free
air."
AQCC Regulation 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions exceed one
ton per year in a nonattainment area for ozone.
Part B:
A permit is required for this source because uncontrolled VOC emissions from this
facility exceed two tons per year in a nonattainment area for ozone.
This source is subject to Section III.D.2 (Minor Source RACT) because it is located in
a nonattainment area. RACT for this source has been determined to be the use of a
flare to control emissions.
Is public comment
required?
Public Comment Required
AQCC Regulation 7
Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
yes
This separator is subject to Reg 7, Section X\/II.G. and control requirements of Reg 7, XVII.B.2
Facility Status
This facility is a synthetic minor source of VOC and HAP for Title V applicability.
This facility is a synthetic minor source of VOC for NSR applicability.
COLORADO DEPARTMENT OF PUBLIC HEALTH ENVIRONMENT
AIR POLUTION CONTROL DIVISION
INVENTORY
AIRS (County/Plant) 123/9F5C
Permit No. 17WE0932
Date 12/20/2017
Point #
Seg *
SCC
Pollutant or CAS
Fug
Dust
Uncontrolled Emission
Factor
Emisison Factor Source
Controlled
Actual
Emissions
(tpy)*
Controlled
Requested
Emissions
(tpy)*
PTE (tpy)*
Ctrl.
Eff%
NCRP
reportable
?
003
31000205
NOx
n
93.71012 lb/MMscf
AP -42: Chapter 13.5
4.3
4.3
0%
CO
n
427.2079 Ib/MMscf
AP -42: Chapter 13.5
19.6
19.6
0%
VOC
n
20346.1922 lb/MMscf
Engineering Calcs
46.8
935.0
95%
71432
Benzene
n
16.077467 lb/MMscf
Engineering Calcs
74
1478
95%
Yes
108883
Toluene
n
24.3139842 lb/MMscf
Engineering Calcs
112
2235
95%
Yes
100414
Ethylbenzene
n
3.08145119 lb/MMscf
Engineering Calcs
14
283
95%
Yes
1330207
Xylene
n
5.88277045 lb/MMscf
Engineering Calcs
27
541
95%
Yes
110543
n -Hexane
n
193.052296 lb/MMscf
Engineering Calcs
887
17743
95%
Yes
540841
224-TMP
n
4.52097625 lb/MMscf
Engineering Calcs
21
416
95% ,
Yes
NOTES
*Emissions of criteria are reported in tons/yr; emissions of NCRPs are in lb/yr.
You can copy each rowinto the permit history file for a facility -wide summary.
Thefirst row can be copied into the Criteria tab.
The second and third rowscan be copied into the HAPs tab.
Be sure to do Edit, Paste Special, Values to avoid creating links back to this PA in the history file.
Controlled Emissions
Uncontrolled Emissions
POINT
003
PERMIT
17WE0932
Description
Produced natural gas venting
NOx
4.3
VOC
46.8
Fug VOC
Controlled Emissions
Formaldehyde
CO
19.6
Reportable
HAPs
Total
HAPs
NOx
4.3
VOC
935.0.
Fug VOC
CO
19.6
Reportabl
e HAPs
POINT
003
PERMIT
17WE0932
Description
Produced natural gas venting
AcetekleIhrde
Benzene
74
Acrolein
Toluene
112
Ethylbenzene
14
Xylene
27
n -Hexane
887
2,2,4-Trimt
21
Methanol
1,3 -Butadiene
Uncontrolled
r4„r.wnMe
POINT
003
PERMIT
17WE0932
Description
Produced natural gas venting
Acetaldehyde
Benzene
1478
Acrolein
Toluene
2235
Elhvibenzene
283
Xylene
541
n -Hexane
17743
2,2,4 -Trims
416
Methanol
r.3-auaaene
Total
HAPs
Point 001
Point 002
Point 003
Q (MMscf/yr) Pollutant
VOC
Benzene
Toluene
4.584 Ethylbenzene
Xylenes
n -Hexane
2,2,4 -TM P
Emission factors (Ib/MMsd
Uncontr. emissions (lb/yr) controlled emissions (Ib/yr) Uncontrolled Controlled
520600 26030 113568.94 5678.45
588 29 128.272 6.414
543 27 118.455 5.923
60 3 13.089 0.654
185 9 40.358 2.018
8270 414 1804.101 90.205
149 7 32.504 1.625
Emission factors (Ib/MMscf)
Q (MMscf/yr) Pollutant Uncontr. emissions (Ib/yr) controlled emissions (Ib/yr) Uncontrolled Controlled
VOC 73182 3659 20328.33 1016.42
Benzene 58 3 16.111 0.806
Toluene 87 4 24.167 1.208
3.6 Ethylbenzene 11 1 3.056 0.153
Xylenes 21 1 5.833 0.292
n -Hexane 694 35 192:778 9.639
2,2,4-TMP 16 1 4.444 0.222
Emission factors (lb/MMscf)
Q (MMscf/yr) Pollutant Uncontr. emissions (Ib/yr) controlled emissions (Ib/yr) Uncontrolled Controlled
VOC 1868378 93419 20328.34 1016.42
Benzene 1476 74 16.059 0.803
Toluene 2232 112 24.285 1.214
91.91 Ethylbenzene 283 14 3.079 0.154
Xylenes 540 27 5.875 0.294
n -Hexane 17720 886 192.797 9.640
2,2,4-TMP 415 21 4.515 0.226
Department of Public Health £t Environment
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE0931
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Extraction Oil Et Gas, Inc.
Kennedy Production Facility
123/'9F5C
NENE SEC 18 T4N R68W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Produced
Gas Venting
002
High -Low Pressure Separator gas controlled
by an enclosed combustor during VRU
downtime.
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/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 shalt 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.)
COLORADO
Air Pollution Control Division
₹ Pub€ e 4eru h'v ErvV rr;vertC
Page 1 of 7
it sha if th ° �t � , perat•..- s' . which this as issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this permit
and submilltie ,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
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,t
VOC
CO
Produced Gas
Venting
002
---
---
1.9
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month, a new twelve-month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
Produced Gas
Venting
002
Emissions from the Separators are routed to
an Enclosed Flare during Vapor Recovery Unit
(VRU) downtime
VOC and HAP
COLORADO
Air: Pollution Control Division
2iy'a; e, t C?r Pctb€, 4 tee 6 L. --4v "inert
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, ILA.4.)
Process Limits
Facility
Equipment ID
AIRS
Point.
Process Parameter
Annual Limit
Produced Gas
Venting
002
Natural Gas Venting
3.6 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month, a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
Upon installation of the flow meter, the owner or operator shall continuously monitor and record
the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The
owner or operator shall use monthly throughput records to demonstrate compliance with the
process limits contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten -digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation
from the outside of the enclosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating properly. This flare must be equipped
with an operational auto -igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On
or after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING Et MAINTENANCE REQUIREMENTS
14. Upon startup of this point, 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
COLORADO
Air Pollution Control Division
Page 3 of 7
plan tation. (Re
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen -minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
16. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. 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 (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
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.
18. Federal regulatory program requirements (i.e. 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
will 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).
Pollution Control Division
;r.t-art ut. Pbuti_ Yteu;4. , Env tvirirrief
19. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission fAQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner mustnotify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Oluwaseun Ogungbenle
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil Et Gas, Inc.
COLORADO
Air Pollution Control Division
_ranent Riblic 1,6,66!1 6 £rrivornurt,
Page 5 of 7
older a •' issua
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 tht permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and: emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to, the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions, The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E:1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-reps
The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
Produced Gas
Venting
002
Benzene
71432
58
3
Toluene
108883
87
4
Ethylbenzene
100414
11
1
Xylenes
1330207
21
1
n -Hexane
110543
694
35
2,2,4-
Trimethylpentane
540841
16
1
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:
CAS # -
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
VOC
20328.33
1016.42
ProMax
71432
Benzene
16.111
0.806
ProMax
108883
Toluene
24.167
1.208 '
ProMax
100414
Ethylbenzene
3.056
0.153
ProMax
1330207
Xylene
5.833
0.292
ProMax
110543
n -Hexane
192.778
9.639
ProMax
540841
2,2,4
Trimethylpentane
4.444
0.222
ProMax
0 iI A A t
ion Control Division
at Public big uh er,if- nme,,t
Page 6 of 7
ontrol point . �e control ef; ' a�;a 95%.
The emission factors listed above are based on modeled separator temperature of 120 °F and separator
pressure of 161 psig.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC and n -Hexane
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
COLORADO
Air Pollution Control Division
4 }≥c r€r 4efa$?!
Department of Public Health & Environment
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE0932
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Extraction Oil Et Gas, Inc.
Kennedy Production Facility
123/9F5C
NENE SEC 18 T4N R68W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Sales Gas
Venting
003
Sales gas controlled by an enclosed
combustor.
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/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.
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.)
COLORADO
Air Pollution Control Division
Deparawnt er Puxte thsaY t. ex Er Mronr e S
Page 1 of 7
3 .s. " " it sha - if t � atperat. s which this ,•; as issued:
(i) does not commence construction/modification or operation of this source within. 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth inthe permit application.
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section III.E.)
5 The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
pM2.5
NO.
VOC
CO
Sales Gas
Venting `
003
---
4.3
46.7
19.6
Point
,Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month, a new twelve-month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
Sales Gas
Venting
003
Sales gas emissions are routed to an Enclosed
Flare
VOC and HAP
OLORADO
izPollution Control Division
4 & tr:vrrorpl nt
Page 2 of 7
8. This source shall be limited to the following maximum processing rates as listed. below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, .II.A.4. )
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Sales Gas
Venting
003
Natural Gas Venting
91.9 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month, a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
9. Upon installation of the flow meter, the owner or operator shall continuously monitor and record
the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The
owner or operator shall use monthly throughput records to demonstrate compliance with the
process limits contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten -digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shalt be marked on the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation
from the outside of the enclosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating properly. This flare must be equipped
with an operational auto -igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped 'with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On
or after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be.
routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING £t MAINTENANCEREQUIREMENTS
14. Upon startup of this point, 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
COLORADO
AirPoilution Control Division
Veep r r +tar P bt-s. Heath G E';vireh rte:;C
Page 3 of 7
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen -minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
16. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
18. Federal regulatory program requirements (i.e. 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
will 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).
COLORADO
Air Pollution Control Division
Page 4 of 7
19. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does, not
provide "final" authority for this activity or operation of this source. - Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section IIi.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Oluwaseun Ogungbenle
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil a Gas, Inc.
'COLORADO
Air _Pollution Control Division
::zpsst tat Pub€';, He th & Evwir r rtent
Page 5 of 7
1)
older e • ,; issua
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 VhB.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumptionxates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(Ib/yr)
Controlled
Emissions
(lb/yr)
Sales Gas
Venting
003
Benzene
71432
1476
74
Toluene
108883
2232
112
Ethylbenzene
100414
283
14
Xylenes
1330207
540
27
n -Hexane
110543
17720
886
2,2,4
Trimethylpentane
540841
415
21
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.
The emission levels contained in this permit are based on the following emission factors:
Point 003:
CAS #
Pollutant
Uncontrolled
Emission Factors
(Ib/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
N0x
93.7
93.7
AP -42
CO
427.2
427.2
AP -42
V0C
20328.34
1016.42
ProMax
71432
Benzene
16.059
0.803
ProMax
108883
Toluene
24.285
1.214
ProMax
100414
Ethylbenzene
3.079
0.154
ProMax
1330207
Xylene
5.875
0.294
ProMax
110543
n -Hexane
192.797
9.640
ProMax
COLORADO
Air Pottution Control Division
Page 6 of 7
CAS #
Pollutant
troller-
Emission Factors
(lb/MMSCF)
ed
Emission Factors
(lb/MMSCF)
Source
540841
2'2'4
Trimethylpentane
4.515
0.226
ProMax
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
The emission factors listed above are based on modeled separator temperature of 120 °F and separator
pressure of 161 psig.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from, the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC and n -Hexane
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.epoaccess.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
COLORADO
Air Pollution Control Division
Hez kh n ^svxm eht
Page 7 of 7
;
Kennedy VRT Venting APEN
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: (w Qvl3o AIRS ID Number: 123 /tWJSUao,
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: VRT Gas Venting
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Extraction Oil & Gas, Inc.
Site Name: Kennedy Production Facility
Site Location: NENE Sec 18 T4N R68W
Mailing Address:
(Include Zip code) 370 17th St. Suite 5300
Site Location
County: Weld
NAICS or SIC Code: 211111
Denver, CO 80202 Permit Contact: Kathy Steerman
Phone Number:
E -Mail Address2: ksteerman@extractionog.com
720-974-7765
368898
1Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017
COLORADO
1 I A n,e .
H` u�iNrt 6 Fnv�innmon.
1
Kennedy VRT Venting APEN
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
✓❑ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: Please issue individual permit for VRT Gas Venting.
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Venting of VRT gas to ECD.
This occurs when VRU is down or VRT is overpressured. Volumes monitored by flowmeter.
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
6 / 13 / 2017
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
Yes
❑ Yes
❑ No
O No
®� COLORADO
2 l mane PaEU[
Nu1N 6 [navnnma.0
. re,
Kennedy VRT Venting APEN
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID] lia
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
El Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑r Yes
o 1X 02- ' y.0.5
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
3
SCF/hr
Vent Gas
Heating Value:
2725.0
BTU/SCF
Requested:
4.584
MMSCF/year
Actual:
3.056
MMSCF/year
-OR-
Requested:
N/A
Bbl/yr
Actual:
N/A
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
48.86
VOC (mole %)
80.095
VOC (Weight %)
88.230
Benzene (mole %)
0.062
Benzene (Weight %)
0.100
Toluene (mole %)
0.049
Toluene (Weight %)
0.092
Ethylbenzene (mole %)
0.005
Ethylbenzene (Weight %)
0.010
Xylene (mole %)
0.014
Xylene (Weight %)
0.031
n -Hexane (mote %)
0.794
n -Hexane (Weight %)
1.401
2,2,4-Trimethylpentane
(mole %)
0.011
2,2,4-Trimethylpentane
(Weight %)
0.025
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
:COLORADO
3 1 aD:rfrg.7:.`r.fs,`r.
Kennedy VRT Venting APEN
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.317732, -105.038096
Operator.
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp.,
CF)
-
Flow Rate ::
(ACFM)
Velocity
(ft/sec)
N/A
Unknown
Unknown
Unknown
Unknown
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑r Circular Interior stack diameter (inches):
❑ Other (describe):
0 Upward with obstructing raincap
Unknown
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed %
❑ Combustion
Device:
Pollutants Controlled: VOC. HAPs
Rating:
Type: ECG
MMBtu/hr
Make/Model:
Requested Control Efficiency: 95% %
Manufacturer Guaranteed Control Efficiency 98% %
Minimum Temperature:
Constant Pilot Light: ❑✓ Yes 0 No Pilot burner Rating
auz,t-i-r/C)3O-n
Waste Gas Heat Content
Btu/scf
Oitl�Vr'�
1) -91_1..C -6141:T
w
MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
COLORADO
4 I AV .,==.,
H �I�h Y Uvwxnvn.
Kennedy VRT Venting APEN
AIRS ID Number:
Permit Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
ioment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOx
NOx
VOC
ECD
95%
CO
HAPs
ECD
95%
Other:
From what year is the following reported actual annual emissions data?
2017
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
Requested Annual Permit=
e Emission Limit(s)5 _r
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
sox
NOx
VOC
113.57
IbVOC/MSCF
Promax
173.555
8.678
260.333
13.017
CO
Benzene
0.128
IbBenzene/MSCF
Promax
0.196
0.010
0.294
0.015
Toluene
0.118
IbToluene/MSCF
Promax
0.181
0.009
0.272
0.014
Ethylbenzene
Xylenes
n -Hexane
1.804
Ibn-Hexane/MSCF
Promax
2.757
0.138
4.135
0.207
2,2,4-
Trimethylpentane
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
®V COLORADO
5j
Permit Number:
Kennedy VRT Venting APEN ; 3
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
9/11/2017
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:
2 Draft permit prior to issuance
❑r Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
6 I AVCOLORADO
L'71;7:7 °Z,Z
Kennedy Produced Gas Venting
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.Rov/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: 31 ti E O Ct 3 � AIRS ID Number: I23 MF50/QOZ
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: Produced Gas Venting
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name':
Site Name:
Extraction Oil & Gas, Inc.
Kennedy Production Facility
Site Location: NENE Sec 18 T4N R68W
Mailing Address:
(Include Zip code) 370 17th St. Suite 5300
Site Location
County: Weld
NAICS or SIC Code: 211111
Denver, CO 80202 Permit Contact: Kathy Steerman
Phone Number:
E -Mail Address2: ksteerman@extractionog.com
720-974-7765
368899
1Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017
COLORADO
1 I Mr,H !th ne,
Nea!�T bEnv�ronmeM
Kennedy Produced Gas Venting
I
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
r❑ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
❑ Change permit limit El Transfer of ownership3 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes: Please issue individual permit for Produced Gas Venting.
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Venting of produced gas to ECD.
This occurs when gas cannot be compressed off of the LP separator into the gas pipeline.
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
6 / 13 / 2017
❑� Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
Yes El No
❑ Yes E No
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
2 i A�COLORADO
Department. Public
Kennedy Produced Gas Venting
Permit Number: AIRS ID Number: / / ( ii
?, iil
[Leave blank unless APCD has already assigned a permit # and AIRS ID] .im
°,4
Section 4 - Process Equipment Information
O Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
0 No
Maximum Vent
Rate:
1 000
SCF/hr
Vent Gas
Heating Value:
1378.09
BTU/SCF
Requested:
3,60
MMSCF/year
Actual:
2.40
MMSCF/year
-OR-
Requested:
N/A
Bbl/yr
Actual:
N/A
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
23.87
VOC (mole %)
15.216
VOC (Weight %)
32.311
Benzene (mole %)
0.008
Benzene (Weight %)
0.026
Toluene (mole %)
0.010
Toluene (Weight %)
0.039
Ethylbenzene (mole %)
0.001
Ethylbenzene (Weight %)
0.005
Xylene (mole %)
0.002
Xylene (Weight %)
0.009
n -Hexane (mole %)
0.085
n -Hexane (Weight %)
0.306
2,2,4-Trimethylpentane
(mole %)
0.002
2,2,4-Trimethylpentane
(Weight %)
0.007
Additional Required Information:
O Attach a representative gas analysis (including BTEX Ft n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX £t n -Hexane, temperature, and
pressure)
CI
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
COLORADO
3 I AV' 71; bl��,.
Ne..lq.b Envbnrweru
Kennedy Produced Gas Venting
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.317732, -105.038096
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp
('F)
Flow Rate
(ACFM)
xr
Velocity
(ft/sec
)
N/A
Unknown
Unknown
Unknown
Unknown
Indicate the direction of the stack outlet: (check one)
2 Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑� Circular
❑ Other (describe):
Interior stack diameter (inches):
0 Upward with obstructing raincap
Unknown
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
%
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating:
Type: ECG
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
MMBtu/hr
Make/Model:
95%
98%
%
Waste Gas Heat Content
Constant Pilot Light: (] Yes 0 No Pilot burner Rating
Btu/scf
MMBtu/hr
O Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
COLORADO
4 I AV
C,— Ctsrevri
14*-44
Kennedy Produced Gas Venting
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
he overall control efficiency (% reduction"):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOX
NOx
VOC
ECD
95%
CO
HAPs
ECD
95%
Other:
From what year is the following reported actual annual emissions data?
2017
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissionss
, ._
Requested ; Annual'Permit
Emission L�mit(s)
����. .... � ... ,
Uncontrolled
(Tons/year)
Controlled'
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
sox
NOx
VOC
20.328
IbVOC/MSCF
Promax
24.394
1.220
36.591
1.830
CO
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
0.193
lbrt-Hexane/MSCF
Promax
0.231
0.012
0.347
0.017
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.
rli
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
:COLORADO
5I AV
Kennedy Produced Gas Venting
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
9/11/2017
Signature of Legally Authorized Person (not a vendor or consultant)
Kathy Steerman
Date
Air Quality Coordinator
Name (please print) Title
Check the appropriate box to request a copy of the:
❑r Draft permit prior to issuance
✓❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
COLORADO
6 I
Kennedy Sales Gas Venting APEN
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 11 W E C g 3 2 AIRS ID Number: l Z 3 /q F5CG / 665
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: Sales Gas Venting
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Extraction Oil & Gas, Inc.
Site Name: Kennedy Production Facility
Site Location: NENE Sec 18 T4N R68W
Mailing Address:
(Include Zip Code) 370 17th St. Suite 5300
Site Location
County: Weld
NAICS or SIC Code: 211111
Denver, CO 80202 Permit Contact: Kathy Steerman
Phone Number:
E -Mail Address2: ksteerman@extractionog.com
720-974-7765
368900
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017
®V COLORADO
1jHealne�MAoTMen= ,
Kennedy Sales Gas Venting APEN
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
✓❑ NEW permit OR newly -reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment 0 Change company name ❑ Add point to existing permit
❑ Change permit limit 0 Transfer of ownership' El Other (describe below)
-OR -
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info & Notes: Please issue individual permit for Sales Gas Venting.
Sales gas venting started on the DOFP and will continue until 9/22/2017. A sales gas pipeline will be installed on 9/22/2017 and this point will cease operation.
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Venting of Sales gas to ECD. This will occur until 9/22/2017 when a sales gas pipeline will be installed.
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
6 / 13/ 2017
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
❑✓ Yes
❑ Yes
❑ No
❑✓ No
COLORADO
2 I ®,V
Kennedy Sales Gas Venting APEN
Permit Number: AIRS ID Number:
v 1��
[Leave blank unless APCD has already assigned a permit # and AIRS ID] .,;fi
Section 4 - Process Equipment Information
❑ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? I] Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
46894.2
SCF/hr
Vent Gas
Heating Value:
1378.09
BTU/SCF
Requested:
91.91
MMSCF/year
Actual:
86.96
MMSCF/year
-OR-
Requested:
N/A
Bbl/yr
Actual:
NA
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
23.87
VOC (mole %)
15.216
VOC (Weight %)
32.311
Benzene (mole %)
0.008
Benzene (Weight %)
0.026
Toluene (mole %)
0.010
Toluene (Weight %)
0.039
Ethylbenzene (mole %)
0.001
Ethylbenzene (Weight %)
0.005
Xylene (mole %)
0.002
Xylene (Weight %)
0.009
n -Hexane (mole %)
0.085
n -Hexane (Weight %)
0.306
2,2,4 Trimethylpentane
(mole %)
0.002
2,2,4-Trimethylpentane
(Weight %)
0.007
Additional Required Information:
❑ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
3 I hfCOLORADO
f etrul, Pub,.
Kennedy Sales Gas Venting APEN
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.317732, -105.038096
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp
(_
Flow Rate
(ACFM)
Velocity
(ft/sec
N/A
Unknown
Unknown
Unknown
Unknown
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
Unknown
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating:
Type: ECD
D
Requested Control Efficiency: 95% %
Manufacturer Guaranteed Control Efficiency 98%
Minimum Temperature:
Constant Pilot Light: ✓❑ Yes El No Pilot burner Rating
Waste Gas Heat Content
MMBtu/hr
Make/Model: . Q .b ��/i15 6
t�l
ItS��lB"
eoCb
Btu/scf Lczo
MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
/
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
AV:COlO RA DO
4I
Hml�le6 Envuunnon�
Kennedy Sales Gas Venting APEN
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 Yes O No
If yes. Dlease describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SO.
NOx
VOC
ECD
95%
CO
HAPs
ECD
95%
Other:
From what year is the following reported actual annual emissions data?
2017
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
Requested Annual Permit'
Emission Limit(s)5
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SO.
NOx
0. DC
IbNOx/MMBtu
Af—
L1. 07
4-D7
`-t- -31
t{--3 I
VOC
20.328
IbVOC/MSCF
Promax
883.856
44.193
934.189
46.709
CO
0.3 f
IbCO/MMBtu
f - `f2-
I 3.57
I F.57
I1-6
19.413 -
Benzene
0.016
Ib Benzene/MSCF
Promax
0.698
0.035
0.738
0.037
Toluene
0.024
IbTaluene/MSCF
Promax
1.056
0.053
1.116
0.056
Ethylbenzene
0.003
IbElylbenzenalMSCF
Promax
0.134
0.007
0.141
0.007
Xylenes
0.006
Ibxylenee/MSCF
Promax
0.255
0.013
0.270
0.013
n -Hexane
0.193
Ib n-Hexane/MSCF
Promax
8.383
0.419
8.860
0.443
z,ylp
Trimethylpentane
0.005
b i24TMP/MSCF
Promax
0.196
0.010
0.207
0.010
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
5 I®V. COLORADO
ZIT==,
Kennedy Sales Gas Venting APEN
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
9/11/2017
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:
0 Draft permit prior to issuance
✓❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
®� COLORADO
6 I
Envveruhem
Hello