HomeMy WebLinkAbout20183545.tiff ,k CDPI+E COLORADO
Department of Public
CO w
Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
RECEIVED
Weld County - Clerk to the Board
1150 O St NfV 01
Greeley, 2018
PO Box 758
WELD COUNTY Co 80632 COMMISSIONERS
October 25, 2018
Dear Sir or Madam:
On November 1, 2018, the Air Pollution Control Division will begin a 30-day public notice period for
Extraction Oil Et Gas, Inc. - Gilbert/MSH Pad 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 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/cdphev`
John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer * ,;
RJbIiC R .,eA4J cc:PLC'rP.I. 1—li.CJ-r), Pw( RICf-I(JMtCIC)
/ / f t t t S/ l 0-
2018-3545
capHE Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Extraction Oil Et Gas, Inc. - Gilbert/MSH Pad Production Facility - Weld County
Notice Period Begins: November 1, 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: Gilbert/MSH Pad Production Facility
Oil and gas exploration and production facility
NENE Sec 36 T6N R66W
Weld County
The proposed project or activity is as follows: Source is requesting to vent low pressure separator gas to
flare at an existing site.
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 18WE0374 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Any such comment must be submitted in writing to the following addressee:
Carissa Money
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
/LOW COLO f?, ESL}
1I
C D P H E a.. ;' A D v
citi) Air � n Contraff
Dena �n Dena -ent o tic Heatt Envtrort it
'r.z'.. 4 ' �.e". ` ." 1.111-in V s vaitaitara
CONSTRUCTION PERMIT
Permit number: 18WE0374 Issuance: 1
Date issued:
Issued to: Extraction Oil &t Gas, Inc.
Facility Name: Gilbert/MSH Pad Production Facility
Plant AIRS ID: 123/9DE0
Physical Location: NENE SEC 36 T6N R66W
County: Weld County
General
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment point Equipment Description Description
ID
LP Separator 005 Venting of gas from two Low Pressure (LP) Enclosed Flare
Venting separators
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.)
DP" COLORADO
CO . Air Pollution Control Division
V r
Page 1 of 7
3. is permit s ex Ire f t4 he, '-er or o er or ni e source hi4 this permi as issued:
does not c "'tnenc oristtuction/modif Apperation ; islource withittl8 months
a4er either,4, e da f is ce of this constrt ion per p; or the date on iich such
stru • .r active= was s uled commencas set th in the permit application
associated with thi if; (ii)`8isco irfuTs consfititiiPri fPFT.OtIod of eighteen'edr 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 shalt 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 AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO, VOC CO Type
LP Separator 005 --- 3.8 81.9 17.4 Point
Venting
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Pollutants
Control Device
Equipment ID Point Controlled
LP Separator 005 Enclosed Flare VOC and HAP
Venting
cORxe COLORADO
.o If Air Pollution Control Division
Page 2 of 7
PROCES - IMITATION AND RcCOR
8. i s source s be hl ed f'` e followi processin=-rate s listed bel. . Monthly
ords of ttr . 'actual ,,_�" cessi ates sh . be main ed by a owner or operat nd made
, . aafl te$fhe Divi ominsp eque lat nber 3, Par . .)
Process Limits
Facility AIRS Process Parameter Annual Limit
Equipment ID Point
LP Separator 005 Gas Venting 62.0 MMSCF
Venting
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
9. The owner or operator shall continuously monitor and record the volumetric flow rate of gas
vented from the separator(s) to the flare using the flow meter. The owner or operator shall use
monthly throughput records to demonstrate compliance with the process limits contained in this
permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III.E.) (State only enforceable)
11. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity
for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
OPERATING Et MAINTENANCE REQUIREMENTS
13. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (OEtM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
14. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis")
within one hundred and eighty days (180) after issuance of this permit of the gas vented from
this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n-
hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission stream. Results
of the Analysis shall be used to calculate site-specific emission factors for the pollutants
referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods.
Results of the Analysis shall be submitted to the Division as part of the self-certification and must
demonstrate the emissions factors established through the Analysis are less than or equal to, the
emissions factors submitted with the permit application and established herein in the "Notes to
Permit Holder" for this emissions point. If any site specific emissions factor developed through
this Analysis is greater than the emissions factors submitted with the permit application and
established in the "Notes to Permit Holder" the operator shall submit to the Division within 60
at.orr a COLORADO
co 7 Air Pollution Control Division
Page 3 of 7
b
Sys, or in a ttiv fram` s to by the DtOsioVIA request f r modificati k o address
's/these ina racy z
15 e owner „opera shal(4�t onstr e comply e withiApacity standards, i sing EPA
v::':t•MferenteWthod G F.R t 6th,. .. -pendix deter tithe presenconstAbsence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
ADDITIONAL REQUIREMENTS
16. A revised Air Pollutant Emission Notice (APEN) 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.
17. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such
time that this source becomes major solely by virtue of a relaxation in any permit condition. Any
relaxation that increases the potential to emit above the applicable Federal program threshold
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
18. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
19. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cIRE COLORADO
CO *so' Aar Pollution Control Division
Page 4 of 7
ZA
not be gra d un he o Lion or act 'ty mences a ,y4 a en verified the APCD
conformin all r e ith the co the per n " self-certifi ion of all
F
nts has be evie and roved by e Dwisi it will p ide written docu tation of
g '`to operate are to ed in the
�, �h-f��n onzati s��Detail qtr obta in final a ti onzati mm � 3
tegi irements to Sp1r fy f, orizat n`s io i permit.
20. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
21. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
22. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self-certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Carissa Money
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Issued to Extraction Oil Ft Gas, Inc for
venting of gas from two low pressure separators
(AIRS ID 005)
caPxe COLORADO
'. Air Pollution Control Division
.. _ . Page 5 of 7
�� 1 a
Notes t•:,:- rmit Hold t the ifne permit issa nc
AY
1) The.. rmit holder., =requir ,, to p ,tees for th oroces a time fo is peii-nit. An inva for these
feestt ll be issuer fter tt permi issued pe permi +lder sha ay the invoice w - in 30 days
of. eipptgofett e invoic a lure t& . invoicei nvoi cesitilLmf estat2ArtATevocation of ili permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
Facility AIRS Uncontrolled Controlled
Equipment ID Point Pollutant CAS# Emissions Emissions
(lb/yr) (lb/yr)
Benzene 71432 8,325 416
Toluene 108883 8,086 404
Ethylbenzene 100414 597 30
LP Separator
Venting 005 Xylenes 1330207 2,086 104
n-Hexane 110543 62,277 3,114
2,2,4-
540841 39 2
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250
pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air
Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 005:
Uncontrolled Controlled
CAS# Pollutant Weight Emission Emission Source
Percent of Factors Factors •
Gas (%) (lb/MMSCF) (Ib/MMSCF)
N0x --- 119.38 119.38 AP-42, Table 13.5-1
CO --- 544.24 544.24 AP-42, Table 13.5-2
V0C 58.8 52,831 2,641.6 Extended gas
analysis
71432 Benzene 0.15 134.24 6.7119 Extended gas
analysis
108883 Toluene 0.15 130.37 6.5186 Extended gas
analysis
cah€e COLORADO
0 7 Air Pollution Control Division
Page 6 of 7
d melt;:
S� 3• 3 ,x� '�- < "n ,
�5 coolled
Weight �.E> 1Ean issiorl
# �ttiluta MSc rce
cent of Facto ctors
(%) (Ib/M I,,. SCF)
100414 Ethylbenzene 0.01 9.6206 0.4810 Extencedgas
analysis
1330207 Xylene 0.04 33.627 1.6814 Extended gas
analysis
110543 n-Hexane 1.12 1,004.1 50.207 Extended gas
analysis
540841 2,2,4- 0.001 0.6294 0.0315 Extended gas
Trimethylpentane analysis
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of:
V0C, HAPs
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.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
•
OPIHE COLORADO
0 Aix Pollution Control Division
�r► �. .: Page 7 of 7
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details
Review Engineer: Carlssa Money
Package#: 370066-'.
Received Date: 3/266/2718
Review Start Date: 10/2/2018
Section 01-Facility Information
Company Name: Extraction Oil&Gas,Inc. Quadrant Section Township Range
County AIRS ID: 123 NENE 36'.`. 6N 66
Plant AIRS ID: 5080
Facility Name: Gilbert/MSH Pad Production Facility
Physical
Address/Location: NENE quadrant of Section 36,Township 6N,Range 66W
County: Weld County Type of Facility: Exploration&Production Weil Pad
What industry segment?Oil&Natera)Gas Production&Processing
Is this facility located in a NAAQS non-attainment area? Yea^•
If yes,for what pollutant? Carbon Monoxide(CO) D Particulate Matter(PM) r ' Ozone(NOx&VOC)
Section 02-Emissions Units In Permit Application
Emissions Self Cert Engineering
AIRS Point it Emissions Source Type Equipment Name Permit 6 Issuance ft Action
Control? Required? Remarks
PerrnitJnitiafr
005 Separator Venting LP Separator Venting Yes. .• 18WE0374 1 Yea Issuance •
•
Section 03-Description of Project
The source is requesting to permit equipment at an existing E&P site.The source is requesting to flare LP separator gas.
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? iteatentiiarf 2Sitona:peryear.in Non-Attainment Area '..
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No.
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? 2 ,Dl,
is this stationary source a synthetic minor? Yes ...;..
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) �
Title V Operating Permits(OP) J ^ El IJ
Non-Attainment New Source Review(NANSR) J
IS this stationary source a major source? 'No
If yes,explain what programs and which pollutants herE SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) Q
Title V Operating Permits(OP) Q _
Colorado Air Permitting Project
Non-Attainment New Source Review(NANSR) — - n .�
Separator Venting Emissions Inventory
004 Separator Venting
' T ,..,.'.�.ES.�-3k•,.,..,., .r..9PR,.in 3 ,,,,..13ia1311: 10.5.4262P
Facility AIRS ID:
County Plant Point
Section 02-Equipment Description Details
ndga a tukaimrreesuresparaYgrs INN MM: Illl3l lli
Detailed Emissions Unit Description: t ' �'�d l
,� � �1i3i113 i a_ �r P a a7y
�.�.,..� �.�,� :�, h ".... n.3k..�H,�,.._.u.,II ,,,, � i::.:wn�,�w� ::r.Gt a
'�nduc₹'fi1a ,AMMINISMANTIMINNamwDile.gigniigiMMMIHIVESMIngirriM
Emission Control Device Description: E„titqiqilginnaRRNg'gR:lrnlftgAM!PggggntfMEMRRREPEVIIIVqigE -'liggEigiaagTM
Requested Overall VOC&HAP Control Efficiency%: 31�k
Limited Process Parameter � u� �x,
Gas meter
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Separator
Actual Throughput=7` -„I MMsd per year
Requested Permit Limit Throughput=E--ERNigningiiozit MMscf per year Requested Monthly Throughput= 5 MMscf per month
Potential to Emit(PTE)Throughput= 62 MMscf per year
Process Control(Recycling)
Equipped with a VRU:'VIBE
I y
Is VRU process equipment:
Secondary Emissions-Combustion Device(s)for Air Pollution Control
Separator Gas Heating Value: 1756<.Btu/sd
Volume of waste gas emitted per BBL of
liquids throughput: �:"� r /; scf/bbl
Section 04-Emissions Factors&Methodologies
Description f�
Source used estimate of 1P'separatprgas volume and an extended gas sample of.LP separator gas selected 1/29/2018 at a nearby site,805 stromberger,to estimate emissions,
MW �,.... 134,0767.Ib/Ib-mol Displacement Equation
Ex=CI•MW•Xx/C
Weight%
Helium
CO2
N2
methane 16-
ethane
propane 29'124.
isobutane
n-butane 12 65:
isopentane 2 46
n-pentane
cyclopentane
n-Hexane 1.12.
cyclohexane 0.29.
Other hexanes
heptanes
methylcyclohexane
224-TMP 0,001
Benzene
Toluene
Ethylbenzene
Xylenes 0.04
C8+Heavies
Total 100.00
VOC Wt% 58.8
Separator Venting
Uncontrolled Controlled Emission Factor Source
Pollutant (lb/MMscf) (lb/MMscf)
n=1 IME=MIE
ElliMIMMTIMEMIMIIM 9.6206 0.4810 7
1004.1387 50.2069
,`
MillinEE 0.6294
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMetu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
0.0075 2: n
MIEMEIZEIEL,--- 0.0075 .•.y'{3f�je '». 9 �sy<i' �,,
0,0006 21'$
0.0686 C'::,.. "'5. .9�
•
3 of 6 K:\PA\2018\18WE0374.CP1xlsm
Separator Venting Emissions Inventory
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) . (lbs/month)
PM10 0.41 0.00 0.00 0.4 0.4 71 Includes combustion emissions from pilot gas also
PM2.5 . 0.41 - 0.00 - 0.00 0.4 0.4 71 Includes combustion emissions from pilot gas also
SOx 0.03 0.00 0.00 0.0 0.0 6 Includes combustion emissions from pilot gas also
NOx 3.70 0.00 0.00 3.8 3.8 647 Includes combustion emissions from pilot gas also -
VOC 1638.30 0.00 0.00 1638.3 81.9 13914
CO 16.88 0.00 0.00 17.4 17,4 - 2948 Includes combustion emissions from pilot gas also
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (Ibs/year) (Ibs/year) (Ibs/year) (lbs/year)
Benzene 8325 0 0 8325- 416
Toluene 8086 0 0 8086 404
Ethylbenzene 597 0 0 597 30
Xylene 2086 0 0 2086 104
n-Hexane 62277 0 0 62277 3114
224 TMP 39 0 0 39 '2
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B Source requires a permit
Regulation 7,Section XVII.8,G Source is not subject to Regulation 7,Section XVII.B.2,G
Regulation 7,Section XVII.B.2.e The control device for this separator is not subject toitegulation 7,Section XVII.B.2.e
(See regulatory applicability worksheet far detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a g_as sample to estimate emissions? ,,;`
This sample should represent the gas outlet of the equipment covered under this AIRS ID,and should have been collected within one year of the application received date.However,if
the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older site-specific sample.
If no,the permit will contain an"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year? '-' •
If yes,the permit will contain:
-An"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
-A"Periodic Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point? Yes
If no,the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational(not
to exceed 180 days).This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03.
Does the company request a control device efficiency greater than 95%for a flare or combustion device? A.;4' ,_ ,_
If yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented.The following questions do not require an answer.
41:61*-,,,,,6.,,,,ki.oltapil.--fi'gww!-4,,,r,,,g4twAof,A4:(,o,,,4f,yk,tr,,,a,,,c,gg,,,w/,h-itpy,,,,Awd,fej x,-w 4.,..
s� •:r�3';mY' - Vim rs r /�> .,,- .� ._ 7JJI�' b> .. .
4 of 6 K:\PA\2018\18WE0374.CP1.xlsm
Separator Venting Emissions Inventory
Section 08-Technical Analysis Notes
Thesource did not provide a startup date on the APEN or in the application.Based on the wells aso®ted with the condensatefank ApENs,the same four welts have been in operation since March 24114.Thisapplication:stdl onlydiscosses
four wells.Rappearsthe welts were installed in March 2014and'have notbeen recotnpleted.Thus,.theseparatots are not subject to Reg7_
Section 09-Inventory 5CC Coding and Emissions Factors
Uncontrolled
Emissions
AIRS Point it Process 9 5CC Code Pollutant Factor Control% Units
005 01 3-10-001-00 Flares PM10 13.08 0 lb/MMSCF
PM2.5 13.08 0 ib/MMSCF
5Ox 1.03 0 Ib/MMSCF
N0x 119.38 0 lb/MMSCF
VOC 52831.20 95 Ib/MMSCF
CO 544.24 0 lb/MMSCF
Benzene 134.24 95 lb/MMSCF
Toluene 130.37 95 Ib/MMSCF
Ethylbenzene 9.62 95 lb/MMSCF
Xylene 33.63 95 lb/MMSCF
n-Hexane 1004.14 95 lb/MMSCF
224 TAP 0.63 95 lb/MMSCF
5 of 6 K:\PA\2018\18WE0374.CP1.xlsm
Separator Venting Regulatory Analysis Worksheet
•
Colorado Regulation 3 Pares A and B-AP EN and Permit Requirements
'Source is in the Non-Attainment Area -
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section Il.D.1.a)7
2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOR greaten than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.317 4'
'Not enoughinformation
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section 10.la)7 Yaw, S Req
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOR greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section l 1.0.21? Yes`';:..-:Source Req
'Source requires a permit
Colorado Regulation 7,Section XVII
1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,20147 [#lid ISource ism
ISource is not subject to Regulation 7,Section XVi1.B.2,G
Section XVII.B.2—General Provisions for Alr 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(Le.,not the primary control device)that is not enclosed? OrittIlliThe control
'The control device for this separator Is not subject to Regulation 7,Section XVII.R.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 end 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. - -
CD a Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and «r 2
Application for Construction Permit
.., a
0111 CC
s
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/aped.
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: g J 331k AIRS ID Number 123 /9DE0/
L i:ab APCD has.,.r e; ;u ,tt1 AIRS 1_t
Company equipment Identification: LP Separator Venting
Fbic,Lity ax.: r er.; ID p.)t.z_ '.si' 1/;,),,v this ..1. .,,m, ATE r .?.:ed ti- t,Yi 'yO :��..a!a1131
Section 1 - Administrative Information
Company Name': Extraction Oil & Gas, Inc.
Site Name: Gilbert/MSH Pad Production Facility
Site Location
Site Location:
NENE Sec. 36 T6N, R66W County: Weld
NAICS or SIC Code: 211111
Mailing Address:
(Include Zip Code) 370 17th Street, Suite 5300
Denver, Colorado Permit Contact: Kathy Steerman
Phone Number: 720-974-7765
E-Mail Address'-: ktteerman@extractionog.com
'Please use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
- '[i7Tzf COLORADO
Form APCD-211 NatLfra _ ApEi, _ .7
Permit Number: AIRS ID Number: 123 /9DE0/
on PS'DI
Section 2- Requested Action
❑ NEW permit OR newly-reported emission source
-OR-
MODIFICATION to existing permit(check each box below that applies)
❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership' ❑ Other(describe below)
-OR
APEN submittal for update only (Please note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
❑ Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info It Notes:
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: LP Separator Venting Emissions
For existing sources, operation began on: / /
For new or reconstructed sources, the projected TBD /
start-up date is:
✓❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Will this equipment be operated in any NAAQS nonattainment 0 Yes ❑ No
area
Is this equipment located at a stationary source that is ❑ Yes ❑✓ No
considered a Major Source of(HAP) Emissions
/ GOLORA60
2 � Aa
Form f F�. _1 ...._yet...� 4J-..,�f�=I�UT.i,�APEN �__ t�J.3/2C:€1
Permit Number: AIRS ID Number: 123 /9DE0/
.a-aatitti a anti t2,1
Section 4 - Process Equipment Information
❑r Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model: Serial#: Capacity: Gal/min
❑ Compressor Rod Packing
Make: Model: #of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
#of Events/year: Volume per event: MMscf/event
❑ Other
Description:
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes ❑ No
Maximum Vent 7 0801 SCF/hr Vent Gas 1 ,756 BTU/SCF
Natural Gas Venting Rate: . Heating Value:
Process Parameters4: Requested: 62.02 MMSCF/year Actual: 51 .68 MMSCF/year
-OR-
Liquid Throughput
Requested: Bbl/yr Actual: Bbl/yr
Process Parameters4:
4 Requested values will become permit limitations. Requested limit(s)should consider future process growth
Molecular Weight: 34.0767
VOC (mole%) 37.90 VOC (Weight%) 58.74
Benzene (mole%) 0.0651 Benzene (Weight%) 0.1493
Toluene (mole%) 0.0536 Toluene (Weight%) 0.1450
Process Properties:
Ethylbenzene (mole%) 0.0034 Ethylbenzene (Weight%) 0.0107
Xylene (mole%) 0.0120 Xylene (Weight%) 0.0374
n-Hexane (mole%) 0.4416 n-Hexane (Weight%) 1.1168
2,2,4-Trimethylpentane 0.0002 2,2,4-Trimethylpentane 0.0007
(mole%) (Weight%)
Additional Required Information:
0 Attach a representative gas analysis (incWding BTEX£t n-Hexane, temperature, and pressure)
❑ Attach a representative pressurized extended liquids analysis (including BTEX a n-Hexane, temperature, and
pressure)
A77
► COLORADO
ForFormAPCD-21 i N 1.3. .i Ca._ Venting vP cV D312017 i . . ..._
Permit Number: AIRS ID Number: 1 23 /9DE0/
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.567522, -104.885123
Discharge Height
Operator Temp. Flow Rate Velocity
Above Ground Level
Stack ID No. (°F) (ACFM) (ft/sec)
(Feet)
ECD -20 TBD TBD TBD
Indicate the direction of the stack outlet: (check one)
✓❑ Upward ❑ Downward ❑ Upward with obstructing raincap
❑ Horizontal ❑ Other(describe):
Indicate the stack opening and size: (check one)
✓❑ Circular Interior stack diameter (inches): TBD
❑ Other(describe):
Section 6 - Control Device Information
Pollutants Controlled:
Size: Make/Model:
❑✓ VRU:
Requested Control Efficiency
VRU Downtime or Bypassed
Pollutants Controlled: VOC/HAPs
Rating: TBD MMBtu/hr
Type: ECD Make/Model:
❑
Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency >98
Minimum Temperature: TBD Waste Gas Heat Content 1 ,756 Btu/scf
Constant Pilot Light: ❑� Yes ❑ No Pilot burner Rating TBD MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Control Efficiency
Requested °
Permit Number: AIRS ID Number: 1 23 /9DE0/
1
Section 7- Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
If yes, please describe the control equipment AND state the overall control efficiency(% reduction):
Overall Requested Control
Pollutant Control Equipment Description Efficiency
(%reduction in emissions)
PM
SOX
N Ox
VOC Enclosed Combustion Device 95%
CO
HAPs Enclosed Combustion Device 95%
Other:
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Emission Requested Annual Permit
Uncontrolled Emission Factor Actual Annual Emissions Emission Limit(s)
5
Pollutant Emission Factor Source
Factor Units (an-42, Uncontrolled Controlled& Uncontrolled Controlled
Mfg.etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year)
PM
SOx
NOX 0.068 lb/MMBtu Mfg. 3.19 3.81
VOC 52,775.15 lb/MMscf Gas Analysis 1,363.83 68.19 1,636.60 81.83
CO 0.31 Ib/MMBtu Mfg. 14.53 17.36
Benzene 134.04 Ib/MMscf Gas Analysis 3.46 0.17 4.16 0.21
Toluene 130.15 lb/MMscf Gas Analysis 3.36 0.17 4.04 0.20
Ethylbenzene 9.51 lb/MMscf Gas Analysis 0.25 0.01 0.30 0.01
Xylenes 33.58 Ib/MMscf Gas Analysis 0.87 0.04 1.04 0.05
n-Hexane 1,003.06 lb/MMscf Gas Analysis 25.92 1.30 31.11 1.56
2,2,4-
Trimethylpentane
Other:
5 Requested values will become permit limitations. Requested limit(s)should consider future process growth.
AAnnual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
1 co�.e,Rrpo
o >, i:1tu't GR",; fr,,PLN F.Lv'ti7.20t1
Permit Number: AIRS ID Number: 123 /9DE0/
[Leave blank unless APCD has already assigned a permit#and AIRS ID)
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
Signature of Legally Authorized Person (not a vendor or consultant) Date
Kathy Steerman Air Quality Coordinator
Name(please print) Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
❑� Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
...__..____..__..
Send this form along with $152.90 to: For more information or assistance call:
Colorado Department of Public Health and
Environment Small Business Assistance Program
Air Pollution Control Division (303)692.3175 or(303)692-3148
APCD-SS-B1
4300 Cherry Creek Drive South Or visit the APCD website at:
Denver, CO 80246-1530
https://www,colorado.gov/cdphe/apcd
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303)692-3150
Form APCD-211 -Natural APEN Rev 03/2017 6
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