The URL can be used to link to this page

Browse Search

Home My WebLink About20182639.tiffCOLORADO Department of Public Health £s Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 August 10, 2018 Dear Sir or Madam: RECEIVED AUG 14 2018 WELD COUNTY COMMISSIONERS On August 16, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - Darlene 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/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer AA. 6 I cc- R QJ 08-ao-18 CC WL ER /C'N ITM//C K)T,� P � 08 -141 -►8 2018-2639 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, Inc. - Darlene Production Facility - Weld County Notice Period Begins: August 16, 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: Darlene Production Facility Oil and gas exploration and production facility SWSW Sec 29 T12N R61W Weld County The proposed project or activity is as follows: Source is proposing to operate a new oil and gas production facility. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0219 Et 18WE0220 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 ........................ JtADO Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Carissa. Money. Package #: 375811.` Received Date: 3/2/2013 Review Start Date: 8/2/201& Section 01- Facility Information Company Name: Extraction Oil & Ga County AIRS ID: 123 Plant AIRS ID: 9FA1 Facility Name: Darlene .Production Facili Physical Address/Location: County: Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non attainment area? No If yes, for what pollutant? ❑ carbon Monoxide (CO) SWSW quadrant of Section 29, Township 12N, Range 61W Weld County Section 02 - Emissions Units In Permit Application Particulate Matter (PM) Quadrant Section Township Range SWS Ozone (NOx & VOC) 29 12N 61 AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Separator Venting LP Gas Venting Yes 1SWE0219 1 Yes -=-Perfttit Initial issuance 002 Separator Venting Sales Gas Venting Yes 18WE0220 1 Yes Permit Initial issuance Section 03 - Description of Project The source is requesting to permit equipment at a new E&P site. The source is requesting individual permits for the LP separator venting and sales gas venting and general permits for the condensate tanks, produced water tanks, condensate loading and eninges. I confirmed this site is located outside (north) of the NAA boundary. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting SyntheticMinor Pe 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. Yes 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) No -, Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? No If yes, explain what programs and which pollutants here SO2 NOx Prevention of Significant Deterioration (PSD) El ❑ CO VOC PM2.5 PM10 D ❑ ❑ TSP ❑ ❑ HAPs Colorado Air Permitting Project Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) El ❑ ❑ ❑ Separator Venting Emissions Inventory 001 Separator Venting Facility AIRS ID: 123 9541 ". 001: Plant Section 02 - Equipment Description Details Detailed Emissions Unit Description: Enclosed Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Actual Throughput = MMscf peryear IRequested Permit Limit Throughput Potential to Emit (PTE) Throughput = 15.7 MMscf per year Requested Monthly Throughput = 16 MMscf per year Equipped with a VRU Is VRU process equipment: , jj��,j Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: 1874'. Btu/sd Volume of waste gas emitted per BBL of ' liquids throughput: � /��,� scf/bbl Description Sooree used modeled througtput o€ LP separator gas from Promax andsite-sp� MW _.....3,_33.9674 Weight % Helium C02 N2 methane ethane 2 4D'. 23.78' propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies 227 457 1518 14 Total VOC Wt % 100.00 61.91 lb/lb-mol MMscf per month Displacement Equation Ex = Q. MW"Xx/C Darlene East 295-20-111 to estimate emissions. Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 55482.1181 2774.1059 Benzene Toluene 77.7934 41.9439 4.3019 8.6935 3.8897 2.0972 0.2151 0.4347 28.4555 0.0448 Ethylbenzene Xylene n -Hexane 224 TMP 569.1108 0.8962 Emission Factor Source Emission Factor Source Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 0.0875 O0075 0.0006______. 0.08815 13.965 13.965 1.103 127.45 581.02 SOx NOx CO 3 of10 K:\PA\2018\18 W E0219.CP1.xlsm Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Carissa Money Package #: 375811:-' Received Date: 3/2/2018 Review Start Date: 8/2/2018• Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: ,Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) Extraction Oil Gas, Inc. 125 95A1 Darlene Production facility Sw5W quadrant of Section 29, Township 12N, Range 61w Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range 12N 61 Particulate Matter (PM) ❑ Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 002, Separa ar Venting LP Gas Veritin Sale/ Gas Venting Yes Yes. 18VVE0219 E0220,', Yes Permit Initial Yes issuance Permit-brit€al . Issuance Section 03 - Description of Project source is re uestInpermit equipment ata new E&P site. The sources re u" The q' g to q esYmg Indivtdual.oermits for the LP separator venting and sales gas venting and general permits for the condensate tanks, produced water tanks, condensate loading and eninges. I confirmed this site is located outside (north) of the NAA boundary. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor' Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Yes 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 herr SO2 Prevention of Significant Deterioration (PSD) Na- 502 NOx CO VOC PM2.5 PM10 TSP HAPs � NOx CO VOCPM2.5 PM1O� TSP El ] _DODD LI ❑ ❑ HAPs Colorado Air Permitting Project Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) El DEO Separator Venting Emissions Inventory 001 Separator Venting Facility AIRs ID: Plant Point Section 02 - Equipment Description Details ,Denting RC Detailed Emissions Unit Description: ................. _. Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Actual Throughput = ' 13.1-_:MMscf per year Requested Permit Limit Throughput=' 15.71 MMscf per year Requested Monthly Throughput = 1 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VFW process equipment: 16 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies 74 Btu/scf MW 4 Helium ethane ropane isobutane n -butane iso•entane n -pentane cyclopentane n -Hexane clohexane Other hexanes he tan es meth Icyclohexane 224-TMP Benzene Toluene Eth (benzene Xylenes C8+ Heavies Emission Factors - Weight % 32.27 4.57 100.00 scf/bbl b/lb-mol Displacement Equation Ex=Q°MW"xx/C Separator Venting Uncontrolled (lb/MMscf) Pollutant Controlled (lb/MMscf) (Gas Throughput) (Gas Throughput) Emission Factor Source VOC 55492.1181 2774.1059 Benzene ' Toluene 77.7934 41.9439 4.3019 5.6935 3.8897 2.0972 0.2151 0.4347 28.4555 0.0448 Ethylbenzene Xylene n -Hexane 224 TMP 569.1108 0.8962 Pollutant Primary Control Device Uncontrolled Uncontrolled (lb/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 0'. 13.965 13.965 1.103 127.45 581.02 Sox NOx CO 00680 Emission Factor Source 3 of 10 K:\PA\2018\18 W E0219.CP1.xlsm Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.11 0.09 0.09 0.1 0.1 19 0.11 0.09 0.09 0.1 0.1 19 0.01 0.01 0.01 0.0 0.01 1 1.00 0.83 0.83 1.0 1.0 . 170 435.26 362.85 18,14 435.3 21.8 3697 4.56 3.80 3.80 4.6 4.6 774 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled tpy tpy Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 1221 1018 51 1221 61 0.61 0.03 658 549 27 658 33 0.33 0.02 67 56 3 67 3 0.03 0.00 136 114 6 136 7 0.07 0.00 8929 7444 372 8929 446 4.46 0.22 14 12 1 14 1 0,01 0.00 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source is subject to Regulation 7, Section XVII.B.2, G The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "InitialTesting 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% fora flare or combustion device? P Y qg 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 4 of 10 K:\PA\2018\ 18WE0219.CP1.xlsm Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point tt Process 8 SCC Code 001 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 13.97 0 Ib/MMSCF PM2.5 13.97 0 Ib/MMSCF 500 1.10 0 Ib/MMSCF NOx 127.45 0 Ib/MMSCF VOC 55482.12 95 Ib/MMSCF CO 581.02 0 Ib/MMSCF Benzene 77.79 95 Ib/MMSCF Toluene 41.94 95 Ib/MMSCF Ethylbenzene 4.30 95 Ib/MMSCF Xylene 8.69 95 lb/MMSCF n -Hexane 569.11 95 Ib/MMSCF 224 TMP 0.90 95 Ib/MMSCF 5 of 10 K:\PA\2018\18WE0219.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements ource 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 uncontroled VOC emissions greater than 5 TPY, NOn greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part 5, Section 11.0.3)? maga '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 ll.0.1.a)? 2. Are total facility uncontroled VOC emissions from the greater than 2 TPY, 500 greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part 8, Section 11.D.2)? 'You have indicated that source is in the Attainment Area Colorado Regulation 7, Section )(VII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,2014? 'Source is subject to Regulation 7, Section XVII.B.2, Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.R.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 fads 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„ ifs 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 tens 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 Rey The control Separator Venting Emissions Inventory 002 Separator Venting Facility AIRS ID: 9F41 Plant Point pressure separator zi elevated flare? Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Actual Throughput= 3.i IMMscf per year Requested Permit Limit Throughput = :25.2 MMscf per year Requested Monthly Throughput= 2 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 25 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBLu liquids throughput: Section 04 —Emissions Factors & Methodologies Description Soars., Used CXpei alesgasand site.specific eXteoded gas s Weight % Helium CO2 N2 methane ethane -17 propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane yclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies ?17.43 7440- 0 0.40 9 .75 0.09 0.00 0.04 - "0.02 010. Total VOC Wt% 100.00 33.62 Ib/Ib-mol Displacement Equation Ex=a MW'Xx/C Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 21281.6011 1064.0801 Benzene Toluene 22.7902 34.8183 6.9637 9.4959 1.1395 1.7409 0.3482 0.4748 12.5979 0.0000 Ethylbenzene Xylene n -Hexane 224 TMP 251.9582 0.0000 Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 10.074 10.074 0.795 91.939 419.13 0 50x NOx CO imbwOtk Emission Factor Source Emission Factor Source 7 of 10 K:\PA\2018\18 W E0219.CP1.xlsm Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.13 0.02 0.02 0.1 0.1 22 0.13 0.02 0.02 0.1 0.1 22 0.01 0.00 0.00 0.0 0.01 2 1.16 0.17 0.17 1.2 1.2 197 268.15 38.31 1.92 268.1 13.4 2277 5.28 0.75 0.75 5.3 5.3 897 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled fibs/year) llbs/yearl Requested Permit Limits Uncontrolled Controlled (ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled tpy tpy Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TM P 574 82 4 574 29 0.29 0.01 877 125 6 877 44 0.44 0.02 175 25 1 175 9 0.09 0.00 239 34 2 239 12 0.72 0.01 6349 907 45 6349 317 3.17 0.16 0 0 0 0 0 0.OD 0.00 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source is subject to Regulation 7, Section XVII.B.2, G The control device for this separator is subject to Regulation 7, Section XVII.B.2.e Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if thefacility 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? 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 hay indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answe T! 8 of 10 K:\PA\2018\18WE0219.CP1.xlsm Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes The source requested to use NOX and CO emission factors based onthe flare manufacturer. I asl<ed for documentation of these factors. The CO factor is muchlower than AP -42 (0 05 lb CI ce provided a revises O&M Plan and emission calculations on. 812/2010. The source,agreed to use AP.42 emission factors for the open flare. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # 5CC Code 002 01 3-10-001-60 Flares Btu vs 0.31 lb CO/M Pollutant PM10 PM2.5 Sox NOx VOC CO Benzene Toluene Ethylbenzone Xylene n -Hexane 224 TMP in AP -42) The Uncontrolled Emissions Factor Control % Units 10.07 0 lb/MMSCF 10.07 0 lb/MMSCF 0.80 0 lb/MMSCF 91.94 0 lb/MMSCF 21281.60 95 Ib/MM5CF 419.13 0 lb/MMSCF 22.79 95 lb/MMSCF 34.82 95 lb/MMSCF 6.96 95 lb/MMSCF 9.50 95 lb/MMSCF 251.96 95 lb/MMSCF 0.00 95 Ib/MMSCF 9 of 10 K:\PA\2018\18 W E0219.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements 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 lO TPY or CO emissions greater than 10 TPY (Regulation3, 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 (Regulation3, Part A, Section Il.D.1.al? 2. Are total facility uncontrolled VOCemissions from the greater than 2 TPY, NOx greater than 5 TPY or CO - emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)2 You have indicated that source is in the Attainment Area 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 XVII.B.2, G Section XVII.B.2— General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - EmissionsControl Alternative Emissions Control (Optional Sectionl 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 subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e —Alternative emissions control equipment Disclaimer This document' assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Coetrol 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 contra/. The use of non -mandatory language such as "recommend,"°may,""should,"and ban,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the ferret of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in andofitself Source Req Source Req The control Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health b Environment. DRAFT CONSTRUCTION PERMIT 18WE0219 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Ft Gas, Inc. Darlene Production Facility 123/9FA1 SWSW SEC 29 T12N R61 W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LP Gas Venting 001 Venting of gas from two low pressure (LP) separators 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 Pollution Control Divisiota €r.�rertr, Few r• a4U: Er Ft roue rt Page 1 of 7 DRAFT 3. This permit shalt expire if the owner or operator of the source for which this permit was 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 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 LP Gas Venting 001 --- --- 21.8 4.6 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. 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 LP Gas Venting 001 Enclosed flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 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 LP Gas Venting 001 Gas Venting 15.69 MMSCF COLORADO Air Pollution Control Division DM.Vte!,-nt PPu,tu; H4AW1 Er Fat*_^ror:}tng: Page 2 of 7 DRAFT 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 all low pressure separator(s) using the flow meter. The owner or operator shall use the sum of monthly throughput records from all low pressure separators vented to the flare 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.17; 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 the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING 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.17) OLORADO itxstion Control Division Page 3 of 7 DRAFT 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 (NOX) 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. 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 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. 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, COLORADO Air Pollution Control Division L' arm`xru fPu,:C W.:?ARP,b F14 arr: ttttti::: Page 4 of 7 DRAFT 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 Extraction Oil a Gas, Inc for venting of gas from two low pressure separators (AIRS ID 001) COLORADO I .Air Pollution Control Division impattr,vre...,A .4tm.tnbtro.,,V771, ;e Page 5 of 7 DRAFT Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) LP Gas Venting 001 Benzene 71432 1,221 61 Toluene 108883 658 33 Ethylbenzene 100414 67 3 Xylenes 1330207 136 7 n -Hexane 110543 8,929 446 2,2,4- Trimethylpentane 540841 14 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 001: CAS # Pollutant Weight Percent of Gas (%) Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source N0x --- 127.45 127.45 AP 42, Table 13.5-1 CO --- 581.02 581.02 AP -42, Table 13.5-2 V0C 61.9 55,482 2,774.1 Extended gas analysis 71432 Benzene 0.09 77.793 3.8897 Extended gas analysis COLORADO Aix Pollution Contn3l Division Page 6 of 7 DRAFT 108883 Toluene 0.05 41.944 2.0972 Extended gas analysis 100414 Ethylbenzene 0.005 4.3019 0.2151 Extended gas analysis 1330207 Xylene 0.01 8.6935 0.4347 Extended gas analysis 110543 n -Hexane 0.64 569.11 28.456 Extended gas analysis 540841 2'2'4-0.001 Trimethylpentane 0.8962 0.0448 Extended gas 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 Requirement Status Operating Permit Synthetic Minor Source of: VOC PSD 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 Dmavt,tora,NF'triii:Crt £r Emlor`x.m Page 7 of 7 Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health & Environment DRAFT CONSTRUCTION PERMIT 1 8WE0220 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Darlene Production Facility 123/9FA1 SWSW SEC 29 T12N R61 W 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 002 Venting of sales gas from two high pressure (HP) separators Elevated open 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 (JPw.nrvat v Ru C 3z s: N "trwOrmfmt, Page 1 of 7 DRAFT 3. This permit shall expire if the owner or operator of the source for which this permit was 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 submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section I II. 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 002 --- --- 13.4 5.3 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. 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 002 Elevated open flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 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 002 Gas Venting 25.2 MMSCF >oLORADO z Pollution Control Division cx .ac resat&From: mon Page 2 of 7 DRAFT 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 all high pressure separator(s) using the flow meter. The owner or operator shall use the sum of monthly throughput records from all high pressure separators vented to the flare 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 open flare covered by this permit has been approved as an alternative emissions control device under Regulation Number 7, Section XVII.B.2.e. The open flare must 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 open flare, or by other convenient means approved by the Division, determine whether it is operating properly. This open 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 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 the OEM 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 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.17) COLORADO zr Pollution Control Ditrisicn Page 3 of 7 DRAFT 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 (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. 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 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. 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, COLORADO' Air Pollution Control Dneisit n Lei: .«-wni x r *mac r rc,meg c Page 4 of 7 DRAFT 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 Extraction Oil Et Gas, Inc for venting of gas from two high pressure separators (AIRS ID 002) COLORADO Air Pollution Control D visioae Page 5 of 7 DRAFT Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-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 (lb/yr) Controlled Emissions (lb/yr) Sales Gas Venting 002 Benzene 71432 574 29 Toluene 108883 877 44 Ethylbenzene 100414 175 9 Xylenes 1330207 239 12 n -Hexane 110543 6349 317 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 Weight Percent of Gas (%) Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx --- 91.939 91.939 AP 42, Table 13.5-1 CO --- 419.13 419.13 AP -42, Table 13.5-2 VOC 33.6 21,281 1,064.1 Extended gas analysis 71432 Benzene 0.04 22.790 1.1395 Extended gas analysis 108883 Toluene 0.06 34.818 1.7409 Extended gas analysis COLORADO Air Pollution Con tmi Mtns' n Page 6 of 7 DRAFT 100414 Ethylbenzene 0.01 6.9637 0.3482 Extended gas analysis 1330207 Xylene 0.02 9.4959 0.4748 Extended gas analysis 110543 n -Hexane 0.40 251.96 12.598 Extended gas 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 Requirement Status Operating Permit Synthetic Minor Source of: V0C PSD 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 COLORADO Itution Cokttrol Division Page 7 of 7 Darlene East 29N LP 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: ( g(l: D2_ G AIRS ID Number: a� /9f10, -/O(..) [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: LP 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. Darlene Production Facility Site Location: SWSW Sec 29 T12N R61 W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 E -Mail Address2: ksteerman@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 '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 COLORADO Ek,atmmlot Fublle IMWht,Ewlrvnwra l Darlene East 29N LP 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) O Change fuel or equipment O Change company name O Add point to existing permit O Change permit limit O Transfer of ownership3 O 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 LP 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: Combustion of LP separator gas. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 12 / 2 / 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 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 days/week weeks/year O Yes O No O Yes ❑✓ No Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 'COLORADO u.r..emmmrmo� I flMl1ki EnMKnMM Darlene East 29N LP Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ! 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? ❑✓ Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 3500 SCF/hr Vent Gas Heating Value: A859.52`-BTU/SCF Requested: 15.69 MMSCF/year Actual: 13.08 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: 33.9674 lb/lbmol VOC (mole %) 40.770 voC (Weight %) 62.000 Benzene (mole %) 0.038 Benzene (Weight %) 0.087 Toluene (mole %) 0.017 Toluene (Weight %) 0.047 Ethylbenzene (mole %) 0.002 Ethylbenzene (Weight %) 0.005 Xylene (mole %) 0.003 Xylene (Weight %) 0.010 n -Hexane (mole %) 0.250 n -Hexane (Weight %) 0.635 2,2,4-Trimethylpentane (mole %) 0.000 2,2,4-Trimethylpentane (Weight %) 0.001 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 COLORADO Darlene East 29N LP Gas Venting APEN Permit Number: AIRS ID Number: [Leave b[ank unless APCD has already assigned a permit # and AIRS Section 5 - Stack Information 40.97406, -104.22718 Opera � � to � ocit N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) O 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: Requested Control Efficiency VRU Downtime or Bypassed Make/Model: ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC, HAPs ECD Requested Control Efficiency: MMBtu/hr Make/Model: 95% % Manufacturer Guaranteed Control Efficiency 98% % Minimum Temperature: Constant Pilot Light: ❑ Yes ❑ No Pilot burner Rating Waste Gas Heat Content Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 COLORADO Depeasauera Pubtic Vw�.R6 tnNluvmwnl Darlene East 29N LP 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? ❑✓ Yes ❑ No ease describe the control equipment AND state the overall control efficiency (% reduction): [Pollutant Q control Equipment DescriPtaon x ,. Qverall ltequested Cdntroh EY ciency l'oreslu taon in emissions) PM sox NO„ VOC ECD 95% CO HAPs ECD 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: \ Pollutant Uncontrolled Emission Factor Emission Factor _ Units til*I n- Factor~ Source A -42 3=``etch � �-:,,,,,,,,,,,T., � nal E►nss Pew -��» E s��en�t(s� Uncontrolled (Tons7year� Controlde ; (Tons!yeac controlled` (T ns/yearsTons/year�, Controlled PM sox NO„ VOC 55.640 IbVOC/MSCF Promax 363.782 18.189 436.539 21.827 CO 0.310 IbC0/MMBtu AP -42 3.769 3.769 -4y..i: .4r5 -24311,t; Benzene 0.078 IbBenzene/MSCF Promax 0.508 0.025 0.610 0.030 Toluene 0.042 IbToluene/MSCF Promax 0.274 0.014 0.329 0.016 Ethylbenzene Xylenes n -Hexane 0.568 Ibn-Hexe e/MSCF Promax 3.716 0.186 4.460 0.223 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. � 4t` =501'1 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 5 I COLORADO nep.samrw,uc Permit Number: Darlene East 29N LP Gas Venting APEN 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. Signature of Legally Authorized Person (not a vendor or consultant) Catie Nelson Name (please print) Check the appropriate box to request a copy of the: (] Draft permit prior to issuance Draft permit prior to public notice Date Air Quality Engineer Title (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: (3O3) 692-315O Form APCD-2O5 -Natural Gas Venting APEN Rev 03/2017 For more information or assistance call: Small Business Assistance Program (3O3) 692-3175 or (3O3) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Ai COLORADO 6 1 Darlene East 29-N Sales Gas Venting APEN • ;VED i = M iii 2 2018 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: AIRS ID Number: 2— j / gFR-l/ OC)2, [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': Site Name: Extraction Oil & Gas, Inc. Darlene Production Facility Site Location: SWSW Sec 29 T12N R61W Mailing Address: (Include Zip code) 370 17th St. Suite 5300 Denver, CO 80202 E -Mail Address2: ksteerman@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 '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 ♦. CO s COLORADO Daysrtmmdd AubDe iwnb6oMronmeN Darlene East 29-N Sales Gas Venting APEN Permit Number: AIRS ID Number: ,,k [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) O Change fuel or equipment 0 Change company name 0 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 Sales Gas Venting. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. ,I, Section 3 - General Information General description of equipment and purpose: Combustion of sales gas when line pressure is too high. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 12 / 2 / 2017 O 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 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 days/week weeks/year ❑ Yes ❑ Yes ❑ No ❑✓ No Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 I ;COLORADO Oepenmou al Heath Y tmlgnn,en. Darlene East 29-N Sales Gas Venting APEN Permit Number: AIRS ID Number: / / [Leave dank unless APCD has already assigned a permit f and AIRS ID] 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? ❑✓ Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 8500 SCF/hr Vent Gas Heating Value: 1.34474- BTU/SCF Requested: 25.200 MMSCF/year Actual: 3.600 MMSCF/year -OR- Requested: N/A Bbl/yr Actual: NtA Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: 23.993 VOC (mole %) 15.530 VOC (Weight %) 33.670 Benzene (mole %) 0.011 Benzene (Weight %) 0.036 Toluene (mote %) 0.014 Toluene (Weight %) 0.055 Ethylbenzene (mole %) 0.002 Ethylbenzene (Weight %) 0.011 Xylene (mole %) -9 Xylene (Weight %) _gam$ p , CC n -Hexane (mole %) 0.111 n -Hexane (Weight %) 0.398 2,2,4-Trimethylpentane (mole %) 0.000 2,2,4-Trimethylpentane (Weight %) 0.000 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX & n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX a n -Hexane, temperature, and pressure) Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 COLORADO Math b CmNtoeusta :a Darlene East 29-N Sales Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 5 - Stack Information 40.97406, -104.22718 'z �� \ �'-�\� .�, - �� \'z\,�� `tea , , mate -,,- .'�\ \tea 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 s Control Device Information ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency VRU Downtime or Bypassed ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hri I✓ C L,� Type: � }Make/Model: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: 95% % 98% % Waste Gas Heat Content Constant Pilot Light: ✓❑ Yes ❑ No Pilot burner Rating Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 4 ;COLORADO Deyas>sientu(PuLUc Heath I, Urv4anment Darlene East 29-N Sales Gas Venting APEN Permit Number: AIRS ID Number: / / [Leave blank uriess APCD has already assigned a permit n 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 f yes, please describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description ; Overall Reuested Control- Efficiency {%-re duction rrf emissions), PM SOX NOx VOC ..EGD- On .ti - c lL ( . 95% CO HAPs _E -O G 0— i \ I c" —re- 95% Other: From what year is the following reported actual annual emissions data? t Projected Use the following table to report the criteria pollutant emissions from source: Pollutant Uncontrolled Emission Factor Emission Factor tlnfts Em�ss <on�� Fac or Source 4aP d2 .MJg =etc �� Acta� - -miss � � �si —,ues- r> Ems �- � IJncontroiled` {T ns/ ear , , Controlled ,; Tons/ ear, IJticontrotled ons/ear , Controlled Tons/ ear) PM SOx NOx 0.QL° -0.066- Ib61ox/MMBtu 0.160 0.160 ►, 4148- r' -1-9-18 —Mfg. VOC 21.31 IbVOC/MSCF Promax 38.358 1.918 268.506 13.425 CO 0, 11 126 /111,111311— Al ' ti j, c,". -) 6- j Benzene 0.023 lb Benzene/MSCF Promax 0.041 0.002 0.290 0.015 Toluene 0.034 lbTaluene/MSCF Promax 0.062 0.003 0.434 0.022 Ethylbenzene Xylenes n -Hexane 0.252 Ibe-Hexane/MSCF Promax 0.453 0.023 3.173 0.159 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. .01°- N t' g A. I iX201 APCD-205 -Natural Gas `den��n, APEN - Rev 0� / �� 17 5 COLORADO ^•of� ttuith bvs.tron.nem Permit Number: Darlene East 29-N Sales Gas Venting APEN 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. cq-,-6 y-, (z/z0(8 Signature of Legally Authorized Person (not a vendor or consultant) Date Catie Nelson Name (please print) Air Quality Engineer Title Check the appropriate box to request a copy of the: 0✓ Draft permit prior to issuance ID 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/aped caLQRAoc Hello