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Home My WebLink About20181718.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Kathy Steerman KSteerman@Extraction0G.com May 23, 2018 Ref: Permit No: 18WE0096 SUBJECT: Draft Permit and Related Public Notice Dear Kathy Steerman: RECEIVED MAY 2 5 2018 COMMISSIONERS The Air Pollution Control Division has prepared a public comment package for the Extraction Oil Et Gas, Inc. - Nelson Farms 28-A. The thirty (30) day public notice period will begin on May 24, 2018. This public notice period is being provided in accordance with the Colorado Air Pollution Prevention and Control Act and Regulation No. 3, Part B, Section III.C. For thirty (30) days from the beginning of the notice period, copies will be available for public inspection at the respective county clerk's office(s). During the thirty -day period, please review your permit and call your permit engineer with any questions or concerns you may have. This application is complete and in proper form. It meets the requirements of the Colorado Air Quality Control Commission's Regulation No. 3, Part B, Section III.B. Sincerely, Bradley Eades Stationary Sources Air Pollution Control Division Enclosures 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 Re.v.x,a) o�-oy-i8 CG: PL(mm/TP), Hi -CST), PWC £R/CH/SM/CK) 0s-ag-/8 2018-1718 COLORADO Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 May 23, 2018 Dear Sir or Madam: On May 24, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - Nelson Farms 28-A. 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 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, Inc. - Nelson Farms 28-A - Weld County Notice Period Begins: May 24, 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: Nelson Farms 28-A Oil and gas well production facility NENW Section 28, T7N, R67W Weld County The proposed project or activity is as follows: Applicant proposes to control emissions from a high-pressure separator using a thermal oxidizer when the sales gas pipeline is not available. 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 18WE0096 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: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 0 D Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: iBradley-Eedes Package f!: 1374566'. ;. Received Date '2/5/2018::.,,. Review Start Date: 2/22/2018 Section 01- Facility Information Company Name: extraction Oil & Gas. Inc:. County AIRS ID: .323:, Plant AIRS ID: i9DFC Facility Name: inielson Farms 28-A Tank Battery Physical Address/Locatio NENW quadrant of Section 28, Township 7N, Range 67WW, in Weld County, Colorado Type of Facility: Exploration& Prodteuon WellPad What industry segment? Oil&,Natural.Gas.Production&'Processing Is this facility located in a NAAQS non -attainment area?-'C<.s.. If yes, for what pollutant? Weld Quadrant Section Township Range NENW ' 28 Section 02 - Emissions Units In Permit App8cation Monoxide (CO) to Matta (PM) LAY` (NOe & VOC) AIRS Point R Emissions Source Type Equipment Name Emissions Control? Permit 8 Issuance a Self Cert Required?' Action Engineering Remarks 009 i Separator Venting HPSepVent Yes, _. 18WE0096 1 Yes Permit Initial Issuance Section 03 - Description of Project Existi•ng weB production facility that receives production from eight (8j wells! Applicarit,is requesting anew point to allow for combustion ofg'as production -stream during sales line downtime:. Source is requesting.98%control, by proposedthermal oxidizer.; • Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? ilk -questing 'SyntbeticMlnorPermit a•. k.:: 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) Is this stationary source a major source? If yes, explain what programs and which pollutants hers SO2 Prevention of Significant Deterioration IPSO) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs El No' NOx CO J VOC PM2.5 PM10 TSP HAPs ❑ ❑ Separator Venting Emissions Inventory Section 01- Administrative Information 'Facility AIRs ID: 123 " • 9DFC County Plant 009 Point Section 02 • Equipment Description Details 'Venting of. gasfrormelght.(8) 3 -phase sepamtoriwhen unable to route to sales; Detailed Emissions Unit Description: ) [Thermal Oxidizer (Questor, model: 0_5000 sn: TOD) Emission Control Device Description: ( Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates 98, jNetahol'Gaa.Verited:- `. Primary Emissions - Separator Actual Throughput =L. 181.7(MMscf per year Requested Permit Limit Throughput = ..._ , , `- 2190j MMscf per year Potential to Emit (PTE) Throughput = 218.0 MMscf per year Process Control (Recycling) Equipped with a VRU: No-. Is VRU process equipment: • Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: 1325lBtu/scf Volume of waste gas emitted per BBL of "7F M liquids throughput: sd/bbl ,Section 04 - Emissions Factors & Methodologies Description Production from eight (8) wells is received by the Inlet 3 -phase separators covered by this emission point. Gas Produced lssent to three (3) electric VRUs and 'rsales .line Cdnpressorprim to belly sent to Saks- During downtimeof the VRUs or sales compressors, gas is sent to the thermal oxidizer. Applicant has estimated emissions based on MW, HMV, and composition of asales gas sample from tite 3-phaseseparator (sampled: 7/24/17). Displacement Equation Ex=Q•MW•Xx/C 3 -Phase separators (extended gas analysis 7-26-17) IMW 22.8211b/Ib-mol Weight % Helium - 0.00 CO2 - 3.25 N2 methane 49.70 ethane 20:06 propane .. — 15.39 isobutane 1:87 n -butane 5.17 isopentane .. 11:10 n -pentane . 1.2S cydopentane 0.06 n -Hexane .. -. '0.26 cyclohexane Other hexanes 0.35 heptanes methylcyclohexane 0.07 224-TMP 0.01 Benzene 0.03 Toluene - . :- 0.06 Ethylbenzene . . ' 0.01 Xylenes 0.03 C8* Heavies .. . .0.11 Total VOC Wt % 99.97 26.28 2 of 5 K:\PA\2018\ 18WE0096.CP1Alsm Separator Venting Emissions Inventory Emission Factors Separator Venting Emission Factor Source Pollutant Uncontrolled Controlled (Ib/MMsd) (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC 15825.4000 316.5080 rr Extended gasanalyniu' Benzene 16.6785 0.3336 +%�+Extendedgasenalysis;,, Toluene 33.7534 0.6751 '. Extended gas analysis Ethylbenzene 8.6740 0.1735 ended gas analysis `- l7 - Xylem 15.3918 0.3078 ,k ins( ‘84...,W,, --- ,l../. .. .. Elttan °, ; Ertended'pa atalyds s. n -Henna 158.9973 3.1799 2241MP 5.7205 0.1144 t ;,^ E#en kd gas aoalysisd Primary Control Device Uncontaolled Uncontrolled Pollutant (Ib/MMBtu( lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 . 0.0075 9.870 ., - AP42 Table L4 2'(PMl0/PM325) PMLS `0.0075 - „ 9.870 t£'AP-42TableL4.2(PM10/PM.2.5) } ` SO: 0.0006 0.779 -' f <-AP-42 Table 1.4-2 (50:) ,' NO: ' 0.0860 - ; - 87.430 e r '. , Manufacturer y CO . : 0.0500. 66.235 , :.' Manufacturer Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions r Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) PM10 1.08 0.90 0.90 1.08 1.08 PM2.5 - 1.08 0.90 0.90 ' 1.08 1.08 SOn 0.09 0.07 0.07 - 0.09 0.09 NO: 9.53 7.94 7.94 9.53 9.53 VOC 1724.97 1437.50 28.75 1724.97 34.50 CO 7.22 6.02 6.02 7.22 7.22 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 3636 3030 61 3636 73 Toluene 7318 6132 123 7358 147 Ethylbenzene 1891 1.576 32 1891 38 Xylene 3355 2796 56 3355 67 -llenne 34661 28885 578 34661 693 224 IMP 1247_ 1039 21 1247 25 Section 06. Regulatory Summary Analysis Regulation 3, Parts A. B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.8.2.e (See regulatory appgnbllity worksheet for detailed analysis) Source requires a permit Source is subject to Regulation 7, Section XV11.B.2, G The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e 3 of 5 K:\PA\2018\ 18WE0096.CPlalsm Separator Venting Emissions Inventory Section 07 • Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gal 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? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a sitespeciflc gal 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 "Periodk 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•fiare 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 gas vented. Th`e following questions do not require an an Section 08 - Technical Analysis Notes Combustion emissions also include. 580.2 MMBtu/yr fuel use from the pilot..4 Sourcewill conduct performance testing (initial compliance test) to demonstrate compliance: with 98% destruction efficiency far VOC.: Source has indicated that control device is a "thermal oxidizer". However,, after discussions with the applicant it was determined that, In this case, the combustion chambertemperature is'not a critical operational parameter and it will not be required -to demonstrate contionous compliance with a minimum combustion chamber temperature. This decision;Is based on thefoliowing: (pindependently conducted "reference method stbck testing conducted on avery similar gas stream at the Micky %/arra Faciltiy (123/9F64) indicates >99% VOC;destruction efficiency at exhaust temperatures as low.as 80g. (ii)The gas stream being controlled in this instance is a high -btu gas streani,("1300 btu/scf). (iii)The source indicates that that there is no auxiliary fuel requirement to operate per manufacturecrecomendations (iv) The thermal oxidizer is not regenerative in nature (i.e. does not utiliie.cenmic beds or other heat transfer medium to preheatprocess er �Yei `si�:F I Applicant Indicates that the control device associated with this equipment does not receive gas from any other sources. Therefore;. source will use measured outletVOC concentration to demonstrate compliance with the emission limits in the permit (in addition to the destruction efficiency required in imtialwmpliantt test). This source is trueminor for NOx and. CO and is c 80% of the T5 major source thresholds for each pollutant.Also, source provided manufactrurer guarantees for the emission factors used for NOx and CO. Therefore, I will not be includng a requirement to test for NOx and CO. from the control device:, AIRS Point g 009 Section 09 - Inventory SCC Coding and Emissions Factors Process g SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 9.87 0 Ib/MMSCF PM2.5 9.87 0 Ib/MMSCF SOx 0.78 0 Ib/MMSCF NOx 87.43 0 Ib/MMSCF VOC 15825.40 98 Ib/MMSCF CO 66.24 0 Ib/MMSCF Benzene 16.68 98 Ib/MMSCF Toluene 33.75 98 Ib/MMSCF Ethylbenzene 8.67 98 Ib/MMSCF Kylene 15.39 98 lb/MMSCF n -Hexane 159.00 98 lb/MMSCF 224 TMP 5.72 98 Ib/MMSCF 4 of 5 K:\PA\2018\18WE0096.CP1xlsm . Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements 'Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 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 8, Section 11.0.3)? 'You have Indicated that source is in the Non -Attainment Area 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 , 'Source requires a permit 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 - 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.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..._....2I CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 1 8WE0096 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Nelson Farms 28-A Tank Battery 123/9DFC NENW Sec 28 T7N R67W 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 009 Venting of gas from eight (8) 3 -phase high- pressure separators when gas is not routed to sales. Thermal Oxidizer (Questor, model: Q5000) 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 y b t ; online ate ww gula r 3, Part B lorado.go/cdphe/airrmit-self- .G.2.) 3. s permit tl expi f the er or o ` rator of t source • which this perms as issued: doev commerce o€struication ordprat' .. is source withif &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 NOX VOC CO HP SEPARATOR VENTING 009 --- 9.6 34.5 7.3 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 009 Emissions from the Separator are routed to a Thermal Oxidizer when gas is not routed to sales. VOC and HAP COLORADO Air Pollution Control Division Page 2 of 8 8. be li ctual Di • Process Limits ed f e follows processi : ate as listed be "` . Monthly essi ates sh be main « . ed by owner or operatj .nd made insp is : ...,n eques gym. lat. .amber 3, Pare Facility Equipment ID AIRS Point Process Parameter Annual Limit HP SEPARATOR VENTING 009 Natural Gas Venting 218.00 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 natural gas vented from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records and monthly records of gas routed to sales to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COLORADO • Air Pollution Control Division Page 3 of 8 COMPLI E TESTING AND S '`. a' LI ial Testin Oequir ffi ent 15. ee own operatbrm shall demonst. to complian e with „pacity standarrdds sing EPA eference Method 2z, U L.F R Paret , Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) 16. A source initial compliance test shall be conducted on this emission point to measure the emission rate(s) for Volatile Organic Compounds (VOC) in order to demonstrate compliance with the emission limits in this permit. The operator shall also demonstrate the thermal oxidizer (TO) achieves a minimum destruction efficiency of 98% for VOC. The operator shall measure and record, using EPA approved methods, VOC mass emission rates at the thermal oxidizer inlet and outlet to determine the destruction and removal efficiency of the thermal oxidizer (process models shall not be used to determine the flow rate or composition of the high pressure gas vented to the TO for the purposes of this test). The natural gas vented and thermal oxidizer combustion chamber temperature shall be monitored and recorded during this 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, in units of lb VOC/MMSCF separator gas, by the allowable separator gas volume for that averaging period as indicated in the process limits section of this permit. (Regulation Number 3, Part B., Section III.G.3) 17. The owner/operator shall complete an initial site -specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. 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 COLORADO Air Pollution Control Division e- Page 4 of 8 pounds (V nitrogen ources (N in ozone itting less A, ons of V '' or X per year, change in ctual issio f one (1 on per «r or mo or five percent, 'chever is r, abov e leve orte+ +n the last 'u N, or or sources i g 10b e& p- year o a -, a in actual e i i 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. 20. 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 21. 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. 22. 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. 23. 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. 24. 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. 25. 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 COLORADO Air Pollution Control Division Page 5 of 8 any time pr BCD) on gra ality Contra to s ert ion and fin, aut ization by Air ollution Co l Division ids se r the Colora.'ffit 'ty Contr cd regulatiof the Air tom on ( C), inclung failur meet express term or dition of e Div s n dens d nermt conditio osed - on a permit are tested by mµ1 ,_r._w" wner or operator, if t e Division re'/o' s a pe i , e owner`'"or operator art§ u e may request a hearing before the AQCC for review of the Division's action. 26. 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. 27. 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: Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas Inc. COLORADO Air Pollution Control Division Page 6 of 8 the - . permit iss 'rmit holde ui w to tt' q ees for th.A .. - ® time for: , �s pe�rni 1) There t. An mvo w for these fees ll be issu - . fter t . erml 'ssued. e permi lder sha ay the invoice w; 3 g n 30 days e invoi «' ure invoice sue evocation ofermit. (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 (Ib/yr) HP SEPARATOR VENTING 009 Benzene 71432 3,636 73 Toluene 108883 7,358 147 Ethylbenzene 100414 1,891 38 Xylenes 1330207 3,355 67 n -Hexane 110543 34,661 693 2,2,4- Trimethylpentane 540841 1,247 25 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 009: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 87.430 87.430 Manufacturer CO 66.235 66.235 VOC 15825.40 316.51 Extended Gas Analysis 71432 Benzene 16.679 0.334 108883 Toluene 33.753 0.675 100414 Ethylbenzene 8.674 0.174 1330207 Xylene 15.392 0.308 110543 n -Hexane 158.997 3.180 COLORADO Air Pollution Control Division Page 7 of 8 S # ollut Uncontred Emission (lb/ MA+ SCF) Contra` i Emission c o (lb/ L F) S• ce Trimethy pentane Note: The controlled emissions factors for this point are based on the thermal oxidizer 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: VOC, HAP PSD or NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63A-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 Page 8 of 8 Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit Alt 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: 18WE0096 AIRS ID Number: 1 23 / 9DFC/ 009 cave l yank antes APCD as already d a pennit „ and AIRS ,d_i Company equipment Identification: HP Separator Venting [Prode ra e is<_1 y Eor,3:1; m4Y".. aP, to identtfy 'w ths. equipment is referenced within your orgaftizatron Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Nelson Farms 28-A Tank Battery Site Location: NENW SEC28 T7N R67W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 E -Mail Address': cnelson@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Catie Nelson Phone Number: (720) 354-4579 'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that wilt 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. APCD-211 9 N. Form ��.r �..0 r..1 3 - +-i�t€.t€c1i Gas Venting 2017 � C4LORA0Sz Permit Number: 1 8WE0096 AIRS ID Number: 123 /9DFCi 009 Section 2- Requested Action ❑ NEW permit OR newly -reported emission source - OR - E MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ✓❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) - OR - ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: ' 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: 01 / 27 / 2018 / / ❑ 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 ❑ No ❑ Yes ❑✓ No °LORRA 130 fir`; Ventmg PEN - Permit Number: 18WE0096 .PCD has )ixe AIRS ID Number: 123 / 9DFC / 009 a permit zinc URS 'D': 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? Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑✓ Yes ❑ No Maximum Vent Rate: 24 886 SCF/hr Vent Gas Heating Value: 1 325 BTU/SCF Requested: 218.00 MMSCF/year Actual: 181.67 MMSCF/year -OR- 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: 22.82 VOC (mole %) 11.858 VOC (Weight %) 26.314 Benzene (mole %) 0.0081 Benzene (Weight %) 0.0277 Toluene (mole %) 0.0139 Toluene (Weight %) 0.0560 Ethylbenzene (mole %) 0.0031 Ethylbenzene (Weight %) 0.0143 Xylene (mole %) 0.0055 Xylene (Weight %) 0.0257 n -Hexane (mole %) 0.0700 n -Hexane (Weight %) 0.2644 2,2,4-Trimethylpentane (mole %) 0.0019 2,2,4-Trimethylpentane (Weight %) 0.0094 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX & n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX & n -Hexane, temperature, and pressure) 0 Form APCD-211-Nawwra Gay `Venting Rev 03/2017 3 a i Permit Number: 18WE0096 APED AIRS ID Number: 123 / 9DFC i 009 D.' Section 5 - Stack Information Geographical Coordinates (LatitudelLongitude or UTM) 40.552256°, -104.903337° Operator Stack ID No Discharge Height Above Ground Level (Feet) Temp. (' Plow Rate (ACFM) Velocity Questor TO —20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) E Upward ❑ Horizontal ❑ Downward ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): TBD ❑ Other (describe): Section 6 - Control Device Information ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency % VRU Downtime or Bypassed ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC/HAPs TBD Thermal Oxidizer Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: TBD MMBtu/hr Make/Model: Questor 98 % >99 % Waste Gas Heat Content 1,325 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating TBD MMBtu/hr Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 OLO- AOC ,APCD-211- Venting APES 4I Permit Number: 1 8WE0096 <<. hi. =,1,, APCD has rslrea AIRS ID Number: 123 / 9DFCi 009 ri 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 Thermal Oxidizer 98% CO HAPs Thermal Oxidizer 98% Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual Annual Emissions Requested Annual Emission Limit(s}s Permit Uncontrolled (Tons/year) Controlled6 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NO. 0.066 Ib/MMBtu Mfg. 7.94 9.53 VOC 15,825.40 lb/MMscf Gas Analysis 1,437.47 28.75 1,724.97 34.50 CO 0.05 lb/MMBtu Mfg. 6.02 7.22 Benzene 16.68 lb/MMscf Gas Analysis 1.51 0.03 1.82 0.04 Toluene 33.75 Ib/MMscf Gas Analysis 3.07 0.06 3.68 0.07 Ethylbenzene 8.67 lb/MMscf Gas Analysis 0.79 0.02 0.95 0.02 Xylenes 15.39 lb/MMscf Gas Analysis 1.40 0.03 1.68 0.03 n -Hexane 159.00 lb/MMscf Gas Analysis 14.44 0.29 17.33 0.35 2,2,4-0.52 Trimethyipylpentane 5.72 lb/MMscf Gas Analysis 0.01 0.62 0.01 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. AAnnual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form ArCD-21' actual Ga5 V ..,in? PEN Ra`, 0,3/2017 corogAoa 5 I W, Permit Number: 18WE0096 AIRS ID Number: 123 / 9DFC / 009 [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 ( Date Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: ❑r Draft permit prior to issuance 0 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 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 Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 6 I COLORADO w Hello