HomeMy WebLinkAbout20182328.tiffCOLORADO
Department of Public
Health El 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
July 10, 2018
Dear Sir or Madam:
RECEIVED
JUL 16 2018
WELD COUNTY
COMMISSIONERS
On July 12, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for
Extraction Oil Et Gas, Inc. - Hester 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 Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
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2018-2328
CDPHE
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Extraction Oil & Gas, Inc. - Hester Production Facility - Weld County
Notice Period Begins: July 12, 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 & Gas, Inc.
Facility: Hester Production Facility
Oil and gas exploration and production facility
SWNW Sec 31 T7N R66W
Weld County
The proposed project or activity is as follows: Source is proposing to operate a new enclosed flare to
receive high pressure separator gas.
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):
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 18WE0199 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 wilt 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
°RAD
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Carissa Money
Package #: 375261
Received Date: 2/23/2018
Review Start Date: 6/7/2018
Section 01 - Facility Information
Company Name: Extraction Oil & Gas, Inc.
County AIRS ID: 123
Plant AIRS ID: 9F46
Facility Name: Hester Production Facility
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? Yes.
If yes, for what pollutant? Carbon Monoxide (CO)
SWNW quadrant of Section 31, Township 7N, Range 66W
Weld County
Section 02 - Emissions Units In Permit Application
Particulate Matter (PM)
❑
Quadrant
Section
Township
Range
SWNW
31
7N
66
Qzone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
013
Separator Venting
HP Separator Venting
Yes -.
18WE0199
1
---'Yes
Permit Initial.
Issuance
Section 03 - Description of Project
Source is requesting to install a new flare so that gas from the high pressure separators can be vented and routed to the flare when pipeline is unavailable.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? RepuestIng Synthetic Minor
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?
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?
If yes, explain what programs and which pollutants herf SO2
Prevention of Significant Deterioration (PSD) T
Title V Operating Permits (OP)
❑ ❑
No
NOx CO VOC PM2.5 PM10 TSP HAPs
7
Colorado Air Permitting Project
Non -Attainment New Source Review (NANSR)
Separator Venting Emissions Inventory
'Facility AIRS ID:
123
County
9F46-].._.
Plant
013
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Ventingof gas from twelve high pre
Enclosed flare
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
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98
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
MMscf per year
Requested Permit Limit Throughput
69.0 MMscf per year
Requested Monthly Throughput = MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
69 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
Description
Source is requesting to vent high pressure separator gusto an enclosed flare. 5
MW
20.5
Weight
Helium
0.00.
CO2
3.01
N2
0:91
methane
61.69
ethane
17.84
propane
11.40
isobutane
0.00
n -butane
1 30.
isopentane
0.77
n -pentane
0.98
cyclopentane
0.06
n -Hexane
0.24
cyclohexane
-.1.03
Other hexanes
/ '0.29
heptanes
:0.34
methylcyclohexane
0105
224-TMP
0.01
Benzene
:.0.02
Toluene
0.05.
Ethylbenzene
.0.02
Xylenes
0.03.
C8+ Heavies
: 0.09
Total
VOC Wt
100.00
15.65
Ib/Ib-mol
gas sample is from 6/13/2017.
Displacement Equation
Ex=Q'MW'Xx/C
Emission Factors
Separator Venting
Uncontrolled
(lb/MMscf) (lb/MMscf)
Pollutant
Controlled
(Gas Throughput)
(Gas Throughput)
Emission Factor Source
VOC
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
8463.4169
11.900
25.963
8.6544
16.227
130.90
3.2454
169.2683
0.7380
0.5193
0.1731
0.3245
2.6179
0.0649
Emission Factor Source
Pollutant
Primary Control Device
Uncontrolled Uncontrolled
(Ib/MMRtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
PM2.5
SOx
NOx
CO
0.0075
0.0075.:..:.
0.0006
0.0660
0.0500
8.933
8.933
0.705
79.129
59.947
3 of 6
K:\PA\2018\18 W E0193.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
(Ibs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.31
0.00
0.00
0.31
0.3
52
0.31
0.00
0.00
0,31
0.3
52
0.02
0.00
0.00
0.02
0.0
4
2.73
0.00
0.00
2.73
2.7
364
291.99
0.00
0.00
291.99
5.8
992
2.07
0.00
0.00
2.07
2.1
351
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224TMP
321
0
0
021
16
1791
0
1
1791
36
597
0
0
597
12
1120
0
0
1120
) 22
9032
0
0
9002
101
224
0
0
224
4
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 maybe appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? PtA
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/hbl) 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 have indicated above that the monitored process parameter is natural g
ented. The following questions do
require an an
4 of 6 K:\PA\2018\18WE0199.CP1.xlsm
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
APEN does'. not specify construction date for well. Dates listed on. APENs for tanks. indicate April 2017 I'm assuming thewell was constructed after 8/1/2014.
Source is using NOX.and .CO emission factors from the control device manufacturerNo supporting information was provided in the application. The unit will be tested to confirm combustion emissions as well as combustion efficiency.
In the application and on the APEN, the source listed the control device as a thermal oxidizer.: if the device is a thermal oxidizer, then the combustion chamber temperature must be measured. Extraction has argued on previous applications
the combustion chamber temperature can't be regulated and would require retrofitting tobe able to monitor temperature. The device doesn't appear to operate as a thermal oxidizer and operates as an enclosed flare. Thus, the permit
language will use enclosed flare.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point it Process # SCC Code
013 01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 8.93 0 Ib/MMSCF
PM2.5 3.93 0 Ib/MMSCF
SOx 0.71 0 Ib/MMSCF
NOx 79.13 0 Ib/MMSCF
VOC 8463.42 98 Ib/MMSCF
CO 39.95 0 lb/MMSCF
Benzene 11.90 98 Ib/MMSCF
Toluene 25.96 98 Ib/MMSCF
Ethylbenzene 8.65 98 Ib/MMSCF
Xylene 16.23 98 Ib/MMSCF
n -Hexane 130.90 98 Ib/MM5CF
224 TMP 3.25 98 lb/MMSCF
5 of 6 K:\PA\2018\ 18WE0199.CP1.xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
ilevrce is ie the lliiu Attaiootent Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
Not enough inlOrrititieui
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)?
Yes
'Sniir cv neettirec a peiiivt
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
IScorne is eish(er:t ti ftegulatinii 2, Section
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?
[rile riv,ri vi device for this. separator is itor subject to liegt,latian 7, Section XVil.ki. af.e
Section XVII.B.2.e —Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a
rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or
any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations,
and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended to
describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air
Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Yes
Source Req
Source Req
IThe control
Permit number:
Date issued:
Issued to:
COL
RA
Air Pollution Control Division
Department of 'Public HeaLth EP Environment
DRAFT
CONSTRUCTION PERMIT
18WE0199
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Extraction Oil &t Gas, Inc.
Hester Production Facility
123/9F46
SWNW SEC 31 T7N R66W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
HP
Separator
Venting
013
Venting of gas from twelve high pressure
(HP) 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
COLORADO
Air Pollution Control Division
Page 1 of 8
DRAFT
this permit may be obtained online at www.colorado.Rov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
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 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
HP Separator
Venting
013
---
2.7
5.8
2.1
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
HP Separator
Venting
013
Enclosed flare
VOC and HAP
COLORADO
Aix Pollution Control Diviszost
Page 2 of 8
DRAFT
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
HP Separator
Venting
013
Natural Gas Venting
69.0 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
9. The owner or operator shall continuously monitor and record the volumetric flow rate of gas
vented from all separator(s) using the flow meter. The owner or operator shall use the sum of
monthly throughput records from all 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 (OEtM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
COLORADO
Air Pollution Control. Division
Page 3 of 8
DRAFT
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
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)
16. A source initial compliance test shall be conducted to measure the emission rate(s) for the
pollutants listed below in order to demonstrate compliance with the emissions limits specified
in this permit and to demonstrate a minimum destruction efficiency of 98% for VOCs. The test
shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of
the control device, which shall be used to determine the destruction efficiency during the test.
The throughput of gas vented from the HP separators, supplemental fuel flow rate and
combustion chamber temperature shall be monitored and recorded during the test.
The test protocol must be in accordance with the requirements of the Air Pollution Control
Division Compliance Test Manual and shall be submitted to the Division for review and approval
at least thirty (30) days prior to testing. No compliance test shall be conducted without prior
approval from the Division. Any compliance test conducted to show compliance with a monthly
or annual emission limitation shall have the results projected up to the monthly or annual
averaging time by multiplying the test results by the allowable number of operating hours for
that averaging time. (Regulation Number 3, Part B., Section III.G.3)
• Volatile Organic Compounds using EPA approved methods
• Oxides of Nitrogen using EPA approved methods
• Carbon Monoxide using EPA approved methods.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 1OO 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 1OO 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 1OO 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
COLORADO
Air Pollution Control Division
Page 4 of 8
DRAFT
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
18. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such
time that this source becomes major solely by virtue of a relaxation in any permit condition. Any
relaxation that increases the potential to emit above the applicable Federal program threshold
will require a full review of the source as though construction had not yet commenced on the
source. The source shall not exceed the Federal program threshold until a permit is granted.
(Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
19. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in alt respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
COLORADO
Air Pollution Control Divisic,,
Page 5 of 8
DRAFT
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 twelve high pressure separators (AIRS ID
013)
COLORADO
Air Pollution Control Divisor,
Page 6 of 8
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)
HP Separator
Venting
013
Benzene
71432
821
16
Toluene
108883
1,791
36
Ethylbenzene
100414
600
12
Xylenes
1330207
1,120
22
n -Hexane
110543
9,032
181
2,2,4-
Trimethylpentane
540841
224
4
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 013:
CAS #
Pollutant
Weight
Percent
of Gas
(%)
Uncontrolled
Emission Factors
(lb/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
N0x
---
79.129
79.129
Manufacturer
CO
---
59.947
59.947
Manufacturer
V0C
15.65
8,463.4
169.27
Extended gas
analysis
71432
Benzene
0.02
11.900
0.2380
Extended gas
analysis
COLORADO
Aix Pollution Control Division
Page 7 of 8
DRAFT
108883
Toluene
0.05
25.963
0.5193
Extended gas
analysis
100414
Ethylbenzene
0.02
8.6544
0.1731
Extended gas
analysis
1330207
Xylene
0.03
16.227
0.3245
Extended gas
analysis
110543
n -Hexane
0.24
130.90
2.6179
Extended gas
analysis
540841
2'2'4-0.01
Trimethylpentane
3.2454
0.0649
Extended gas
analysis
Note: The controlled emissions factors for this point are based on the flare control efficiency of 98%.
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:
NOx, CO, VOC, HAPs
NANSR
Synthetic Minor Source of:
NOx, 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
An' Pollution Control Division
Page 8 of 8
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/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:
AIRS ID Number: 123 /9F461 I (3
Company equipment Identification: HP Separator Venting
[Provide d 0 t.� :l n : tt now := s ,
vt i.s.. t.�.'�ilt, Equipmentt.i .,sr�. i.. .i`'.: r._n,.:'t; tFJ'. CP,.t�� .ti: ?..:?�.�,.: <A �.s₹t
Section 1 - Administrative Information
Company Name': Extraction Oil & Gas, Inc.
Site Name: Hester Production Facility
Site Location: SWNW SEC31 T7N R66W
Mailing Address:
(Include Zip Code) 370 17th Street, Suite 5300
Denver, Colorado
E -Mail Address': 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 A
Natural Gas \'entin
375258
COLORADO
Permit Number:
AIRS ID Number: 123 /9F46/
Z
Section 2- Requested Action
El 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 -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a 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:
HP Separator Venting Emissions
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
/TBD/
E 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
Form lit"CD-Li-, ...Naat€tCi Gas 'Venting Rev 031
days/week weeks/year
❑✓ Yes
❑ Yes
❑ No
No
OLORADO
Permit Number:
AIRS ID Number: 123 / 9F46 /
ank urCies_ :APCD has .::read
Section 4 - Process Equipment Information
0 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:
7,908
SCF/hr
Vent Gas
HeatinR Value:
1195
BTU/SCF
Requested:
MMSCF/year
Actual:
57.73
MMSCF/year
(i.3,,11" I l i"II 09.0 -OR-
csj.i. t cA
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
20.50
VOC (mole %)
6.52
VOC (Weight %)
15.65
Benzene (mole %)
0.006
Benzene (Weight %)
0.022
Toluene (mole %)
0.011
Toluene (Weight %)
0.048
Ethylbenzene (mole %)
0.003
Ethylbenzene (Weight %)
0.016
Xylene (mole %)
0.006
Xylene (Weight %)
0.03
n -Hexane (mole %)
0.058
n -Hexane (Weight %)
0.242
2,2,4-Trimethylpentane
(mole %)
0.00
2,2,4-Trimethylpentane
(Weight %)
006
Additional Required Information:
❑� Attach a representative gas analysis (including BTEX fx n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
Form .
al Gas V
Rcv 0312017
3
OLORADO
Permit Number:
t{_.;; A=CE:, . s aise ..
AIRS ID Number: 123 / 9F46i
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.532450/-104.831694
Operator
Stack ID No. "�
!'.
Discharge Height .
Above Ground Level
(Feet)
Temp,
('F}
Flow Rate
{ACFM)
Velocity
(ft/sec)
Questor TO
—40
TBD
TBD
TBD
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
TBD
Section 6 - Control Device Information
❑✓ VRU:
Pollutants Controlled:
Size:
Requested Control Efficiency
VRU Downtime or Bypassed
Make/Model:
❑ Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating: TBD MMBtu/hr
Type: Thermal Oxidizer Make/Model: Questor
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
TBD
98
>99
Waste Gas Heat Content 1,195 Btu/scf
Constant Pilot Light: El Yes ❑ No Pilot burner Rating
TBD MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0
COLGRA6G
APCD_2 s Natur"£al Gas Venting /WEN Ref s/z
Permit Number:
1,3t s . PC.D afteady
AIRS ID Number:
123 /9F46/
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):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOX
NO.
VOC
T-laermal-OMtzer- � n � ,ar_-t cle4;-
98%
CO
HAPs
T-herrnal-exidizer e:., -,,,,j..4., -.<O._,( t .)- l‘ -4--C_
98%
Other:
t- i ill
o_.,)_-3/ /I
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.)
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SOX
NO.
0.066
lb/MMBtu
Mfg
2.30
2.7,5
VOC
8,456.3
lb/MMscf
Gas Analysis
244.09
4.88
292.91
-58.6-'
CO
0.05
lb/MMBtu
Mfg
1.74
2.08
Benzene
12.35
lb/MMscf
Gas Analysis
0.36
0.01
0.43
0.01
Toluene
26.71
lb/MMscf
Gas Analysis
0.77
0.02
0.93
0.02
Ethylbenzene
8.39
Ib/MMscf
Gas Analysis
0.24
<0.01
0.29
0.01
Xylenes
16.79
lb/MMscf
Gas Analysis
0.48
0.01
0.58
0.01
n -Hexane
131.74
Ib/MMscf
Gas Analysis
3.80
0.08
4.56
0.09
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.
=.{PCD-7 l . -Natural Gas e=e' 03/
5
COLOR 4410
Permit Number:
AIRS ID Number: 123 / 9F46i
Ia tt3 s APCD i :� .. _ _..-{3 ,
RS
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
kaOlu stee�wran
2/23/2018
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:
❑✓ Draft permit prior to issuance
❑✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
APCD-211 -Natured Gas Venting 3LP3t'l . Rev %`312017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
COLORADO
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