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Address Info: 1150 O Street, P.O. Box 758, Greeley, CO 80632 | Phone:
(970) 400-4225
| Fax: (970) 336-7233 | Email:
egesick@weld.gov
| Official: Esther Gesick -
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20180791.tiff
COLORADO 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 March 9, 2018 Dear Sir or Madam: On March 15, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - Cox 22-B. 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 a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, Mr�SPH, Executive Director and Chief Medical Officer Pu.b(i a. R�vtew e.c.'• ?L C w & (Tin , i4 (IT), Pt CE RICH 3-m► .k ) 1R -c8 2018-0791 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil &t Gas, Inc. - Cox 22-B - Weld County Notice Period Begins: March 15, 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 &t Gas, Inc. Facility: Cox 22-B Wellpad site NENW SEC 22 T12N R64W Weld County The proposed project or activity is as follows: Separator venting and control The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 16WE0646 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Timothy Sharp Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us COL ADO 1 ., EMIOtelrifIAIlt Division Information Engineer: Timothy Sharp Control Engineer: Stefanie Rucker Review Date: 06/20/2016 Application Date: 05/02/2016 Facility Identifiers Permit No. 16WE0646 AIRs County# 123 'Weld Facility # 9E51 Facility Type: exploration and production facility ❑ Located in the 8 -hour non -attainment area? Administrative Information Potentially located in ozone nonattainment area Q True Minor © Synthetic Minor for: VOC NOx r'.'co Company Name: Extraction Oil & Gas, LLC Source Name: Cox 22-B Source Location: SIC: NENW SEC 22 T12N R64W 1311 Mailing Address Address 1: Address 2: ty, State Zip: Extraction Oil & Gas, LLC 370 17th St., Suite 5300 Denver, CO 80202 Person To Contact Name: Phone: Fax: Email: Josh Carlisle 000-000-0000 000-000-0000 jcarlisle@extractionog.com Requested Action Self Certification Required? Issuance Number: Yes 1 Source Description: Oil and gas exploration and production facility known as the Cox 22-B, located in the NENW SEC 22 T12N R64W, Weld County, Colorado. Point Name Type Control Action 003 ECC-30 Flare Separator Venting Flare Newly reported source One low-pressure separator controlled by one enclosed flare during VRU downtime. Flare has a minimum control 003 efficiency of 95%. Equipment Description This source vents natural gas from: Emissions from this source are: a well head separator routed to a flare Natural gas venting from a well head separator. Emissions from this source are routed to a flare. Calculations 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 Throughput (Q) MW 9284.9 67.924 scf/hr MMscf/yr Ib/Ib-mol 7753.881279 0.186093151 scf/hr MMscf/d 27.21 mole % MW lbx/lbmol mass fraction lb/hr lb/yr tpy Helium 0.00 4.0026 0.000 0.000 0.00 0.00 0.00 CO2 2.96 44.01 1.301 0.048 26.62 233207.59 116.60 N2 1.42 28.013 0.398 0.015 8.13 71245.37 35.62 methane 59.44 16.041 9.535 0.350 195.07 1708843.61 854.42 ethane 12.71 30.063 3.822 0.140 78.19 684953.35 342.48 propane 14.33 44.092 6.319 0.232 129.28 1132500.81 566.25 isobutane 1.53 58.118 0.888 0.033 18.17 159143.77 79.57 n -butane 4.96 58.118 2.883 0.106 58.99 516730.30 258.37 isopentane 0.90 72.114 0.648 0.024 13.26 116175.62 58.09 n -pentane 0.94 72.114 0.680 0.025 13.91 121810.57 60.91 cyclopentane 0.05 70.13 0.035 0.001 0.72 6347.16 3.17 n -Hexane 0.15 86.18 0.133 0.005 2.72 23831.78 11.92 cyclohexane 0.02 84.16 0.015 0.001 0.30 2669.70 1.33 Other hexanes 0.25 86.18 0.213 0.008 4.37 38257.50 19.13 heptanes 0.25 100.21 0.248 0.009 5.07 44413.93 22.21 methylcyclohexane 0.02 98.19 0.024 0.001 0.50 4346.59 2.17 224-TMP 0.00 114.23 0.000 0.000 0.00 20.47 0.01 Benzene 0.01 78.12 0.010 0.000 0.20 1750.07 0.88 Toluene 0.01 92.15 0.012 0.000 0.25 2213.01 1.11 Ethylbenzene 0.00 106.17 0.003 0.000 0.06 532.78 0.27 Xylenes 0.01 106.17 0.007 0.000 0.14 1217.77 0.61 C8+ Heavies 0.03 121.0955445 0.035 0.001 0.72 6337.17 3.17 VOC mass frac Notes Mole %, MW, and mass fractions from Cox -22B gas analysis collected 12/20/2016. Emissions are based on 8760 hours of operation per year. 0.447 Total VOC (Uncontrolled) 1089.15 16WE0646.CP1.xlsm One low-pressure separator controlled by one enclosed flare during VRU downtime. Flare has a minimum control 003 efficiency of 95%. Flaring Information Equipment Description Flare to combust low-pressure separator gas during VRU downtime. Manufacturer Model ECD Serial Number TBD Gas Heating Value 1549 Btu/scf Throughput 105214.276 MMBtu/yr meter installed: 1,000 bbl/yr 81335.7 seNbbl VRU Information Equipment Description NA Make _ TBD Model TBD Requested Control - Annual Bypass Tim - Backup Flare Overall Control 95.00% Combustion emission factor source: 0.07 llb NOX/MMBtu Emissions Summary Table AP -42: Chapter 13.5 0.31 Ilb CO/MMBtu Pollutant 'Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source V0C 32070 lb/MMscf 1603.48 lb/MMscf 1089.1 tpy 54.5 tpy Gas Analysis Nox 0.07 Ib/MMBTU 0.07 Ib/MMBTU 3.6 tpy 3.6 tpy AP -42 CO ° 0.31 lb/MMBTU 0.31 lb/MMBTU 16.3 tpy 16.3 tpy AP -42 Benzene 25.77 lb/MMscf 1.29 lb/MMscf 1750 lb/yr 88 lb/yr Gas Analysis n -Hexane 350.86 lb/MMscf 17.5430 Ib/MMscf 23832 lb/yr 1192 lb/yr Gas Analysis Toluene 32.581 lb/MMscf 1.6290 lb/MMscf 2213 lb/yr 111 lb/yr Gas Analysis Xylenes 17.928 lb/MMscf 0.8964 lb/MMscf 1218 lb/yr 61 lb/yr Gas Analysis Ethylbenzene 7.844 lb/MMscf 0.3922 lb/MMscf 533 lb/yr 27 lb/yr Gas Analysis Regulatory Applicability AQCC Regulation 1 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 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, Section XVII.B.2 16WE0646.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? Source requires a permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? Not enough information Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? 'Source is subject to Regulation 7, Section XVIl,B.2, G Section XV11.B.2 —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section} a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator is not subject to Regulation 7, Section XVRa8.2,e Section XVII.B.2.e — Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Source Req Source Req The control C0PHE Permit number: Date issued: Issued to: ADO n Contro is Healt CONSTRUCTION PERMIT 16WE0646 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Ft Gas, Inc. Cox 22-B 123/9E51 NENW SEC 22 T12N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description FLARE -001 003 Low Pressure Separator Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of 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 Air Pollution Control Division DeptutNr_=rt of PubV _ t ieatth E Environment Page 1 of 7 3. er or oper or e source .u' this permi . s issued: tion/modif •peration is;;,'ource withi 8 months f is ice of t . constron per or the date on `' ich such was suled comment . s set th in the permit `' • i lication with thi _ (ii) . • r -s cons ' r • ` • ` • - °'od of eigh - - •' the or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) s permit s does not c er either, stru • Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO FLARE -001 003 --- 16.0 54.4 3.5 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled FLARE -001 003 Emissions from the Separator are routed to an Enclosed Flare VOC and HAP COLORADO . Air Pollution Control Division Depart ft a o! Public He, fm C, Eniironmee:C Page 2 of 7 8. s source s , be li ed to r e followi cessi -tes sh be main he Diinspeque Process Limits ate s listed be .., . Monthly owner or operat : nd made ber 3, Par.. Facility Equipment ID AIRS Point Process Parameter Annual Limit FLARE -001 003 Natural Gas Venting 68.0 MMSCF Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. 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 these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to ,COLORADO Air Pollution Control Division ^2mr *rant ct Pubi z 17 Environment Page 3 of 7 to implem . '. (Regulatio umber 3, nay is esting Requiremen" s 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 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. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold 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). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation COLORADO Air Pollution Control Division X mint e t of kohl I e, th Ervironmtrtt Page 4 of 7 nsfer of and the s " ittal of a 20. his erm ecific stat at fin : uthoriza granted, then th " emainder P on is .,_".:', A 'cab , the v • " nstruction f es 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: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. COLORADO Air Pollution Control Division pat? :t of IVA 6iettuh 6 Emirorr'xi'1:t Page 5 of 7 (Regulation Number 3, Part A, Section VI.B.) permit iss ees for th. - time fo '.,'s pe it. An invo for these ermi ssued. e permi lder sh +ay the invoice n 30 days ure invoi eA. evocation ermit. 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (Ib/yr) FLARE -001 003 Benzene 71432 1760 88 Toluene 108883 2200 110 Ethylbenzene 100414 540 27 Xylenes 1330207 1140 57 n -Hexane 110543 62020 3101 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 003: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 0.31 AP -42 CO 0.068 AP -42 VOC 32.04 1.602 Source (Promax) 71432 Benzene 0.026 0.0013 Source (Promax) 108883 Toluene 0.032 0.0016 Source (Promax) 100414 Ethylbenzene 0.008 0.0004 Source (Promax) 1330207 Xylene 0.017 0.00085 Source (Promax) 110543 n -Hexane 0.913 0.04565 Source (Promax) Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. COLORADO Air Pollution Control Division 1 1> £nf ^b: A i p aN _ Heti t.h & Envponmemt Page 6 of 7 based on del 'Separator t_a Herat e of XX F separator 6) In a =rdance w' - .R.S. -7-11 each A' ollutantce (APEN) associ • with d for . �� _ fiv he da - - •, by the Divi • • vised 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; nHexane PSD or 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 'npartine is Fu6ii^_ MlesF,h. & E;,irormti:t Page 7 of 7 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Natural Gas Venting' Permit Number: HP (A.)-01.0q b Facility Equipment ID: Flare - 001 Section 01— Administrative Information [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 123 Company Name: Source Name: Source Location: Mailing Address: Extraction Oil & Gas, Inc. Cox 22-B [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] NENW Sec22, T12N, R64W Grover, CO 370 17th Street, Suite 5300 Denver, CO Person To Conrad' Mr. Josh Carlisle E-mail Address: jcarlisle(uextractionog.com Section 03 — General Information For existing sources, operation began on: Normal Hours of Source Operation: General description of equipment and purpose: NAICS, or SIC Code: 211111 County: Weld Elevation: 5,556 Feet ZIP Code: 80202 Phone Number: 720-481-2372 Fax Number: N/A 12 / 04 / 2015 24 hours/day 7 Combustion of gas from separator. Will this equipment be operated in any NAAQS nonattainment area? (http://www.colorado.gov/cdphe/attainment) Section 04 — Processing Equipment Information Description of Source: ❑ Well Head Casing O Gas/liquid Separator ❑ Pneumatic Pump: Make: O Compressor Rod Packing Make: O Blowdowns: # of events: O Other: Description: Model: Model: Volume: days/week 9E51 / 003 Section 02 — Requested Action (check applicable request boxes) O Request for NEW permit or newly reported emission source ❑ Request MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name O Change permit limit O Transfer of ownership ❑ Request to limit I-IAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) O Revision to actual calendar year emissions for emission inventory ❑ Update 5 -Year APEN term without change to permit limits or previously reported emissions Additional Emissions Calculated -using ProMax engi Info. & Notes: - For new or reconstructed sources, the projected startup date ism -1L. 52 weeks/year O Yes 0 No Serial //: # of pistons: MMscf/event Capacity: Leak rate: Don't know gal./min. Scf/hr/pist. Maximum Vent Rate (scf/hr) Actual Volume (MMscf/yr) Requested Volume (MMscf/yr) Vent Gas Heating Value (Btu/scf) Process Parameters: 9,284.9 56.60 67.924 1262.26 Molecular Wt.', VOC (mole %) Benzene (mole %) Toulene (mole %) Ethylbenzene (mole %) Xylene (mole %) n -Hexane (mole %) Vented Gas Properties: 27.21 23.47 0.013 0.013 0.003 0.006 0.402 PI Submit a representative gas analysis (including BTEX & n -Hexane) to support calculations You will he charged an additional APEN fee if APEN is filled out incorrectly or missing information and requires re -submittal. 'Only one source type may be reported per APEN. 'Requested values will become permit limitations. Requested level shall be a "rot to exceed value". "vnitr- Other 1€ if Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc Mail this form along with a check for 5152.90 to: Colorado Department of Public Health & Environ APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division: (303) Small Business Assistance Program (SBAP): (303) 692-3148 or (303) 692-3175 APEN forms:http://www.colorado.gov/cdphe/oilgaspermits Application status:http://www.colorado.gov/cdphe/permitstatus ent 1 ` Q Check box to request copy of draft permit prior to issuance. Check box to request copy of draft permit prior to public notice. FORM APCD-211 Page 1 of 2 FormAPCD-2 I I-NaturalGasVentingAPEN-Ver. I0-14-2013.docx AIR POLLUTANT EMISSION NOTICE (ADEN) & Application for Construction Permit — Natural Gas Venting' Permit Number: 11Q to bte"{ L, Section 05 — Stack Information (Combustion stacks must be listed here) Operator Stack ID No. Stack Base Elevation (feet) Stack Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Moisture (%) 001 5,556 32' unknown unknown unknown unknown Direction of stack outlet (check one): Vertical O Vertical with obstructing rainca Exhaust Opening Shape & Size (check one): Circular: Inner Diameter (inches) = 36" Section 07 — Control Device Information Emission Source AIRS ID: 123 / 9E51 / Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Horizontal Datum (NAD27, NAD83, WGS84) UTM Zone (12 or 13) UTM Easting or Longitude (meters or degrees) UTM Northing or Latitude (meters or degrees) Method of Collection for Location Data (e.g. map, GPS, GoogleEarth) NAD 83 -104.535017 40.998623 GPS Location Horizontal LI Down Other (Describe): O Other: Length (inches) = Width (inches) = ■ VRU used for control of: I9 Combustion Device used for control of: Rating: MMBtu/hr 98 % Size: Make/Model: Type: Make/Model/Serial 1: 95 Requested VOC & HAP Control Efficiency: % % VOC & HAP Control Efficiency: Requested: % Manufacturer Guaranteed: Annual time that VRU is bypassed (emissions vented): The VRU recycles venting emissions to: Minimum temp. to achieve requested control: °F Waste gas heat content: Btu/scf MMBtu/hr Constant pilot light? 0 Yes ■ No Pilot burner rating: ■ Describe Any Other: Section 08 — Emissions Inventory Information & Emission Control Information Attach any emission calculations and emission factor documentation to this APEN form. 0 Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput above (e g 201171• Pollutant Control Device Description Overall Collection Efficiency Control Efficiency (% Reduction) Emission Factor . 1 LVIV Actual Calendar Year Emissions° Requested Permitted Emissions Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled (Tons/Year) ( ) Controlled (Tons/Year) Uncontrolled Tons/Yeruj ( Controlled (Tons/Year) VOC ECD N/A 95% <1;2.4014 lb VOC/MSCF 106 .(9‘ (-{ 6111 1_O1,1') 5ii 141) ProMax NO,t N/A N/A 0.31 lb NOx/MSCF ( 3. (3, 2.6 (5.a( 154/ ProMax CO N/A N/A 0.068 IbCO/MSCF a,'(o odd/ 111 3, yi ProMax SOX Benzene ECD N/A 95% O,,o ,_ (o lb BENZ/MSCF )4113_ (�. l 0.04 b. gg 601 ProMax Toulene ECD N/A 95% 0.03_ lb TOL/MSCF 0,(5 -.(do (9. (fib ProMax ECD N/A 95% bonEthylbenzene � 6,4 l7 lb EB/MSCF _6,3. b.OI n,4-4- ().0 ProMax Xylene ECD N/A 95% lbXYL/MSCF Q ((R 00 ,Da a5-1- 0.03 ProMax n -Hexane ECD N/A 95% 01 13 lb HEX/MSCF g_g(i 1,' LD, I ( , 0 1.55 ProMax Please use the APCD Non -Criteria Reportable Air Pollutant Addendum i Youwtll b I d dd PE f 'f P N form to report pollutants not listed above. e c large an a iuonal A N ee i A E is filled out incorrectly or missing information and requires re -submittal. moo` 11 ' 'Annual emission fees will be based on actua emissions reported here. -J I ), ) _o i Section n 09 t�tilicant Certificath i' by certify that all information contained herein and information submitted with this application is complete, true and correct. Sjgilatt rt' o Ters n Legally Authorized to Supply Data Date Josh Carlisle Name of Legally Authorized Person (Please print) Title EHSR Manager FORM APCD-211 Page 2 of 2 FormAPCD-2 1 1 -NaturalGasVentingAPEN-Ver. 1 0- 1 4-2013.docx
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