HomeMy WebLinkAbout20180790.tiff3111
COLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
March 9, 2018
Dear Sir or Madam:
On March 15, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for
Extraction Oil Ft Gas, Inc. - Breniman Production Facility. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health a Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
i�wbLt.. john W. Hickenlooper, Governor I Larry Wolk, MD MS H, executive Director and Chief Medical Officer
e..C. ?LL I J&tTPJ, LCST) �+ W CeR/CI-1 (r (eft)
03-19-18 3-Iy-►r
2018-0790
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Extraction Oil a Gas, Inc. - Breniman Production Facility - Weld County
Notice Period Begins: March 15, 2018
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Extraction Oil a Gas, Inc.
Facility: Breniman Production Facility
Wellpad site
NENW SEC 16 T6N R67W
Weld County
The proposed project or activity is as follows: Separator venting and control
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 17WE0510 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Any such comment must be submitted in writing to the following addressee:
Timothy Sharp
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
COLORADO
1 I sw
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package 6:
Received Date:
Review Start Date: 11/7,
Tirrei
36�
Section 01- Facility Information
Company Name: Extraction Dil & Gas, Inc."
County AIRS ID: 123
Plant AIRS ID: sf27.
Facility Name: Breniman Production Facility
Physical Address/Locatio NENW quadrant of Section 16, Township 6N, Range 67W, in Weld County, Colorado
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? Don Monoxide (CO) Pa iculate Matter (PM) ®ne (NOx ® VOC)
'Weld
Quadrant
Section
Township
Range
NENW
16
6N
67
Section 02 - Emissions Units In Permit Application
AIRS Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
004
Vapor RecoveryTower(VRT)
VRT Gas Vesting
Yes
17WE0510
1
Yes
Permit In€tial
issuance
Section 03 - Description of Project
Application to permit separator venting(17WE0511) and VRT Venting(17WE0510) Both points route gas to be compressed/VRU. Permits are for gases not
compressed/recovered and sent to ECD. Combusted Sasses are monitored using f owmeter.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? It ques ng Sye
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.
y
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
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Is this stationary source a major source?
If yes, explain what programs and which pollutants here SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
No
NOx
J
TSP
❑ ❑
HAPs
❑ ❑
Separator Venting Emissions Inventory
Section 01 -Administrative Information
Facility AIRs ID:
County Plant
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Emission Control Device Description:
Umited Process Parameter
Gas meter
VRT COO
enclosed flare.
�ef "ibLtf
Section 03 - Processing Rate Information far Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
Requested Permit Omit Throughput = '3
r8 MMscf per year
S8 MMscf per year
Potential to Emit (PTE) Throughput = 6 MMscf per year
Process Control (Recycling)
Equipped with a VRU:Y
Is VRU process equipment: iY
controlled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare)
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
Displacement Equation
Ex=Q*MW •xx/C
25786 Btu/scf
MW
46 093
Weight
Helium
0.00
CO2
0x56
N2
0S7
methane
2,81
ethane
I2.12
propane
37 92.
isobutane
7.81
n -butane
24.51
isopentane
5.39
n -pentane
5.75.
cyclopentane
0.31'.
n -Hexane
0.65.
cyclohexane
0.05'.
Other hexanes
117
heptanes
0.75
methylcyclohexane
0.08
224-TMP
0.00
Benzene
:-0.05'
Toluene
005.
Ethylbenzene
-- 0 01
Xylenes
002
C8. Heavies _ _ _
0,10
Total
VOC Wt %
100.00
84.54
scf/bhl
Ib/lb-mol
3 of 6 K:\PA\2017\ 17WE0510.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)
PM10
PM2.5
500
NOx
VOC
CO
0.00
0.00
0.00
0.00
0.00
0,00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.51
0.51
0.51
0.51
0.51
298.94
298.94
14.95
298.94
14.95
2.32
2.32
2.32
2.32
2.32
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
318
318
16
318
16
354
354
18
354
18
85
85
4
85
4
113
113
6
113
6
4604
4604
230
4604
230
0
0
0
0
0
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.0.2.e
Does the company use site specific emission factors based on a gas sample to estimate emissions? N&
This sample should represent the gas outlet of the equipment covered under this AIRS ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
-A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point? Yes
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not
to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95%for a flare or combustion device? gam//
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.
/,-
4 of
K:\PA\2017\17W E0510.CP1.xlsm
Separator Venting Emissions Inventory
Section 08 -Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point
Process IS SCC Code
004 01 3-10-001-90 Flares
Uncontrolled
Emissions -
Pollutant Factor Control % Units
PM10 0.00 0 Ib/MMSCF
PM2.5 0.00 0 lb/MMSCF
500 0.00 0 Ib/MMSCF
NOx 175.28 0 Ib/MMSCF
VOC 102816.58 95 Ib/MMSCF
CO 799.09 0 Ib/MMSCF
Benzene 54.73 95 Ib/MMSCF
Toluene 60.81 95 Ib/MMSCF
Ethylbenzene .14.59 95 Ib/MMSCF
Xylene 19.46 95 Ib/MMSCF
n -Hexane 791.73 95 lb/MMSCF
224 TMP 0.00 95 Ib/MMSCF
5 of 6 K:\PA\2017\ 17WE0510.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 B, Section II.D.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)?
'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.
;y i
Ye* • a
Source Req
Source Req
A1Source is 5L
The control
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE0510
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Extraction Oil Et Gas, Inc.
Breniman Production Facility
123/9F27
NENW SEC 16 T6N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
VRT Gas
Venting
004
Vapor Recovery Tower with Vapor Recovery
Unit
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall be demonstrated to
the Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
COLORADO
Air Pollution Control Division
1 DepArtment Jt VuMi_ tlft th fj Ewno inert
Page 1 of 7
3.
s permit s
does not c
er either,
stru •
expi
enc
e da+
r active
er or oper
tion/modif'
ce of t
constr
commen
e source
• peration
on per
.s set
this permi
ource withi
or the date on
s issued:
8 months
ich such
uled h in the permi ' s • • lication
with the (ii) • `s cons r . • - iod of eigh - • 'ths 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 I I .A.4. )
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
VRT Gas
Venting
004
---
---
15.0
2.4
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
VRT Gas
Venting
004
Emissions from the VRT are routed to an
Enclosed Flare during Vapor Recovery Unit
(VRU) downtime
VOC and HAP
COLORADO
Air Pollution Control Division
bL Heil"n n E rrrrmr±vr:t
Page 2 of 7
8.
be followi processi s listed be . Monthly
ctual cessi . tes sh = be main ed by fir; owner or operat : nd made
he Di insp:. eque . l ber 3, Par .)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
VRT Gas
Venting
004
Natural Gas Venting
5.9 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 to demonstrate compliance with the process limits contained in this
permit and to calculate emissions as described in this permit.
10. The owner or operator shall continuously monitor and record Vapor Recovery Unit (VRU)
downtime while emissions are routed to the control device.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. 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)
12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
13. 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.
14. 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
COLORADO
Air Pollution Control Division
I Dept<r'terd Rib ii_ lieekie. C, Ee^vvanntent
Page 3 of 7
15.
owner or
M) ecord kee
plia !;- on a +going b
are suba
ection III.
shall folio a - if .st recent o ating and
t approv •y e Division, order to
equire is of this permit. visions to
m.tem .tion. (Regulatio umber 3,
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
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.
COLORADO
Air Pollution Control Division
r. Pcthtt� } 1eelth v Er-.,uvnrtent
Page 4 of 7
20. •cific at final a o ion has b: ..reed, then th emainder
is no •p le. Otherwi'.- ance of t rs con ruction per does not
thori ` or t' : ctivity • u;;. peratif this so .`: e. Final authori . on of the
e secu from APCD:, ` writing i ccorda with the provisi of 25-7-
(a) C.R.S. � C R-•� ember _ •` III.G. Finzation
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
his permit
this conditi
vide "fina
mit
By:
Timothy Sharp
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil Et Gas, Inc.
COLORADO
Mr Pollution Control Division
F pet777erd d Pubes HeOh's t;vbonmert
Page 5 of 7
Notes tpermit iss
1) The ! rmit holde equi to • ees for th `:. time fo s pe it. An invo for these
fees ; ll be lss =fter t ..:.ermi slued. ` e permi lder sh •ay the invoice w _:n 30 days
e inv.': ure, invoi a-, . _:' evocation ermit.
(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
(Ib/yr)
Controlled
Emissions
(lb/yr)
VRT Gas
Venting
004
Benzene
71432
318
16
Toluene
108883
354
18
Ethylbenzene
100414
85
4
Xylenes
1330207
113
6
n -Hexane
110543
4604
230
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 004:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
CO
0.31001b/MMbtu
AP -42
V0C
102816.5782
5140.8289
Source (Promax)
71432
Benzene
54.7278
2.7364
Source (Promax)
108883
Toluene
60.8087
3.0404
Source (Promax)
110543
n -Hexane
791.7294
39.5865
Source (Promax)
Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency
of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
COLORADO
Air Pollution Control Division
nt
• 6nyrient
Page 6 of 7
the
ass
at
7) T
determin
questions r
assifie
expirati
specific
each emir - •ns point
date call Division
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, nHexane
PSD or NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
Depertme t or Public Pica th 6 6worn-menc
Page 7 of 7
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Timothy: Sharp`.
Package #: 363259
Received Date: 5/16/2017
Review Start Date: 11/7/2017
Section 01- Facility Information
Company Name: Extraction Oil & Gas, Inc.
County AIRS ID: 123
Plant AIRS ID: 9f27
Facility Name: Breniman Production Facility
Physical Address/Locatio NENW quadrant of Section 16, Township 6N, Range 67W, in Weld County, Colorado
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? Don Monoa,de (CO) ❑iculate Matter (PM) Ene (NOx & VOC)
Weld
Quadrant
Section
Township
Range
NENW
16
6
67
Section 02 - Emissions Units In Permit Application
AIRS Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
-405
- Separator Venting -
Produced Gas Venting
Yes
17WE0511
1
Yes --
Permit Initial
issuance
Section 03 - Description of Project
Application to permit separator venting(17WE0511) and VRT Venting(17W €0514), Both points route gas
compressed/recovered and sent to ECD. Combusted gasses are monitored using flowmeter.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Syr
e compressed/VRU, Permits are for gases not
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.
Y
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)
SO2
Is this stationary source a major source?
If yes, explain what programs and which pollutants here SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
NOx
NOx
CO VOC PM2.5 PM10 TSP HAPs
44:❑ ❑
CO VOC
PM2.5
PM10 TSP HAPs
❑ ❑
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE0511
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Extraction Oil Et Gas, Inc.
Breniman Production Facility
123/9F27
NENW SEC 16 T6N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Produced
Gas Venting
005
Low pressure separator venting and
combustion when unable to be compressed.
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall be demonstrated to
the Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
COLORADO
Air Pollution Control Division
^Eepi,itvleiv Heath b E*::rrorar er t
Page 1 of 7
3. expi. ' er or oper e source this permi as issued:
tion/modif ' -; ,' •peration is ource !withi 8 months
e da i f is , ce of t . constrL 'on per or the date on ich such
r activ was s • uled commen • s set th in the permit • • lication
. • _ `- - e• with thi. :�. ; (ii) r -s cons r .�. iod of eigh �. � the or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
.A.4. )
s permit s
does not c
er either,
stru •
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
Produced Gas
Venting
005
---
---
2.6
1.3
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
Produced Gas
Venting
005
Emissions from the separator are routed to an
Enclosed Flare during compressor or pipeline
downtime
VOC and HAP
COLORADO
Air Pollution Control Division
u partme. t Pu§ i<t 1-leaficil {s Eavironrtea
Page 2 of 7
8.
be li ed .e followi
ctual 'cessi tes sh be main
he Di ' insp ,, , v eque
Process Limits
ate'°°`'':s listed be Monthly
owner or operat nd made
ber 3, Par
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Produced Gas
Venting
005
Natural Gas Venting
5.9 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 to demonstrate compliance with the process limits contained in this
permit and to calculate emissions as described in this permit.
10. The owner or operator shall continuously monitor and record Vapor Recovery Unit (VRU)
downtime while emissions are routed to the control device.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. 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)
12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
13. 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.
14. 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
COLORADO
IAir Pollution Control Division
I De pJyrent IVAlC 11Cu'^tUE'TVROfT3t₹r'
Page 3 of 7
15.
owner or
ecord kee
going b
a
shall folio u st recent o ,E ating and
t approv •y e Division, ¢,: order to
equire is of this permitvisions to
m • tern ation. (Regulatio = .;- umber 3,
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
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.
COLORADO
Air Pollution Control Division
j tx;p✓invert ,t Pubii_ Redt n E; zUorrrie, t
Page 4 of 7
20.
his permit
this conditi
vide "fina
mit
-cific
is no
thori
e secu
(a) C.R.S.
.p
for t
from
at final a
e. Otherwi
ctivity
APCD
perati •
writing i
ember
on has b
ance of t
f this s
ccorda
ed, then th
con ruction per
e. Final authori
with the provisi
• III.G. Fin•
emainder
does not
on of the
of 25-7-
zation
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Timothy Sharp
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil Et Gas, Inc.
COLORADO
Air Pollution Control Division
ep✓i+41c 3 cr Gutiti. I tet; th ewironrnent
Page 5 of 7
permit iss
ees for th . '. - time fo s pe it. An invo - for these
ssued. e permi lder sh• •ay the invoice n 30 days
e inv.' ure invoi e- evocation ermit.
(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
(Ib/yr)
Controlled
Emissions
(lb/yr)
Produced Gas
Venting
005
Benzene
71432
104
5
Toluene
108883
207
10
Ethylbenzene
100414
50
2
Xylenes
1330207
75
4
n -Hexane
110543
1207
60
224 TMP
293
15
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 005:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
CO
0.3100 Ib/MMbtu
AP -42
VOC
17805.3802
890.2690
Source (Promax)
110543
n -Hexane
207.5534
10.3777
Source (Promax)
224 TMP
50.3532
2.5177
Source (Promax)
Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency
of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
COLORADO
Air Pollution Control Division
^.zpx: lene:: t at Public Health n E.^;nanrhert
Page 6 of 7
APE
the
ass
at
hall be sub
st recent a
ted with t
-69 -
7) This facility is classified as follows:
30 days b five-year a Sires. Pleas fer to
o determi expiratie:' •a a �•r each emi tins point
uestions `' aardinQ • ecific ` = iration date call Division
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, nHexane
PSD or NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
' ruar•`mem or PutAlz Health v Environment
Page 7 of 7
Breniman VRT Gas APEN-
RECEIVED
16 2311
Gas/Liquid Separator APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and SL6.1onarl
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 Gas/Liquid Separators only. If your emission unit does not fall into this cat ry,
may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is availab e if t
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be founcn the
Air Pollution Control Division (APCD) website at: www.colorado.Rov/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: / 7 L1/ AIRS ID Number: /Z3 19Fz1/Ooh
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: VRT Gas Venting
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Extraction Oil & Gas, Inc.
Site Name: Breniman Production Facility
Site Location: NENW Sec 16 T6N R67W
Mailing Address:
(Include Zip Code)
370 17th St. Suits 5300
Denver, CO 80202
E -Mail Address2: ksteerman@extractionog.com
Site Location
County: Weld
NAICS or SIC Code: 211111
Permit Contact: Kathy Steerman
Phone Number: 720-974-7765
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
363257
Form APCD-211 - Gas/Liquid Separator APEN - Rev 02/2017
Department of Pub.
COLORADO
Breniman VRT Gas APEN
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
❑r NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment 0 Change company name 0 Add point to existing permit
O Change permit limit 0 Transfer of ownership3 ❑ Other (describe below)
OR -
O 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 Ft Notes: Please issue permit for VRT gas venting.
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Gas from VRT will be corn busted with ECD
when VRU is down. Volumes are monitored via flowmeter.
For existing sources, operation began on: / /
For new or reconstructed sources, the projected
start-up date is:
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
2 /17 /2017
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
❑✓ Yes ❑ No
O Yes 0 No
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
COLORADO
cap.�nc d nwn�
l N�alU 6Env�rnnm.n�
Breniman VRT Gas APEN
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
If you are requesting uncontrolled VOC emissions greater than 100 tpy you must use Natural Gas Venting as a process
parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? 2 Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
2O94.7
SCF/hr
Vent Gas
Heating Value:
2577.7
BTU/SCF
Requested:
5.815
MMSCF/year
Actual:
3.877
MMSCF/year
-OR-
Requested:
N/A
Bbl/yr
Actual:
N/A
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
46.093
VOC
(mole %)
74.04
VOC
(Weight %)
84.54
Benzene
(mole %)
0.026
Benzene
(Weight %)
0.045
Toluene
(mole %)
0.025
Toluene
(Weight %)
0.050
Ethylbenzene
(mole %)
0.005
Ethylbenzene
(Weight %)
0.012
Xylene
(mole %)
0.007
Xylene
(Weight %)
0.016
n+lexane
(mole %)
0.348
n -Hexane
(Weight %)
0.651
2,2,4-
Trimethylpentane
0.0002
2,2,4-Trimethylpentane
(Weight %)
0.0005
Additional Required Information:
❑ Attach a representative gas analysis (including BTEX 8 n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX it n -Hexane, temperature, and
pressure)
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
COLORADO
3
Breniman VRT Gas APEN
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit #t and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.492519, -104.900208
r��
r
tt
Unknown
Unknown
Unknown
Unknown
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑� Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
Unknown
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating:
Type:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
MMBtu/hr
Make/Model:
95
98
%
Waste Gas Heat Content
Constant Pilot Light: ❑r Yes D No Pilot burner Rating
Btu /scf
MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
4 IMF COLORADO
md�
HwYtli 6 Ewvlmnnvw.
Breniman VRT Gas APEN
PM
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 1 Yes O No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Overall tequested Control '`
iciency ,..
%reduction in emissions
SOX
NO),
VOC
ECD
95%
CO
HAPs
ECD
95%
Other:
From what year is the following reported actual annual emissions data? 2017
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Emission
Factor ..!
Emission
Factor
Units
Emission
�'�Factor�
Source
,
�„ u
��
E tssi•
"``
(AP -42,
Mfg. etc)
Uncontrolled
- (Tons/year)
Controlled6
(Tons/year) - -
Uncontrolled
-_' (Tons/year) v
Controlled
(Tons/year)�i
PM
SOX
NO„
VOC
102.69
Ib/MSCF
Promax
199.06
9.95
298.59
14.93
CO
0.31
lb/MMBtu
AP -42
1.549
1.549
2.324
2.324
Benzene
0.054
Ib/MSCF
Promax
0.105
0.005
0.118
0.006
Toluene
0.061
Ib/MSCF
Promax
0.118
0.006
0.177
0.009
Ethylbenzene
Xylenes
n -Hexane
1.657
Ib/MSCF
Promax
1.534
0.077
2.301
0.115
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.
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
COLORADO
5 A
XWN6U
Breniman VRT Gas APEN
Permit Number:
AIRS ID Number:
/ /
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
Date
Si: ature of . y Authorized Person (not a vendor or consultant)
Josh Carlisle
EHSR Manager
Name (please print)
Title
Check the appropriate box to request a copy of the:
(] Draft permit prior to issuance
Q 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-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to :
Colorado Department of Public Health and Environment
Telephone: (303) 692.3150
F.orm APCD-?11-Gas'uaJid 5epara::
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
61
AY
COLORADO
Breniman Produced Gas P,PEN
Gas/Liquid Separator 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, includi PEN
updates. An application with missing information may be determined incomplete and may be returne lt in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Gas/Liquid Separators only. If your emission unit does not fall into this categoph, th
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 7'. ir
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:
17w5.0511 AIRS ID Number: 1Z3 / gFz1 / ads
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: Produced Gas Venting
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Extraction Oil & Gas, Inc.
Site Name: Breniman Production Facility
Site Location: NENW Sec 16 T6N R67W
Mailing Address:
(Include Zip code) 370 17th St. Suite 5300
Denver, CO 80202
E -Mail Address2: ksteerman@extractionog.com
Site Location
County: Weld
NAICS or SIC Code: 211111
Permit Contact: Kathy Steerman
Phone Number: 720-974-7765
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
32-5 F
Form APCD-211 - Gas/Liquid Separator APEN - Rev 02/2017
1 l ��COLORADO
"�" ,
Breniman Produced Gas APEN
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
2 NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment O Change company name ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: Please issue permit for Produced Gas Venting.
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Produced gas from separators will be combusted
with ECD when it cannot be compressed. Volumes are monitored via flowmeter.
For existing sources, operation began on: / /
For new or reconstructed sources, the projected
start-up date is:
2/17 /2017
Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation:
hours/day days/week
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 APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
2 Yes
❑ Yes
weeks/year
❑ No
l J No
COLORADO
wnw c u.n�rntm.n.
Breniman Produced Gas APEN
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
If you are requesting uncontrolled VOC emissions greater than 100 tpy 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:
E No
Maximum Vent
Rate:
586
SCFLhr
Vent Gas
Heating Value:
1344.6
BTU/SCF
Requested:
5.815
MMSCF/year
Actual:
3.877
MMSCF/year
-OR-
Requested:
N/A
Bbl/yr
Actual:
N/A
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
23.273 Ib/Ibmol
VOC
(mole %)
13.18
VOC
(Weight %)
28.99
Benzene
(mole %)
0.007
Benzene
(Weight %)
0.029
Toluene
(mole %)
0.015
Toluene
(Weight %)
0.058
Ethylbenzene
(mole %)
0.003
Ethylbenzene
(Weight %)
0.014
Xylene
(mole %)
0.005
Xylene
(Weight %)
0.021
n -Hexane
(mole %)(Weight
0.091
n -Hexane
%)
0338
.
2,2,4-
Trimethylpentane
0.01 7
2,2,4-Trimethylpentane
(Weight %)
0.082
Additional Required Information:
Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX R n -Hexane, temperature, and
pressure)
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
COLORADO
3 A rm�
11..IN b E..nrnnnrnr
Breniman Produced Gas APEN
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.492519, -104.900208
®a
x
x
n
, ° °tshr
i
7 '
1.
Unknown
Unknown
Unknown
Unknown
Indicate the direction of the stack outlet: (check one)
E Upward
O Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
✓❑ Circular Interior stack diameter (inches):
❑ Other (describe):
O Upward with obstructing raincap
Unknown
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating:
Type:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
MMBtu/hr
Make/Model:
95 %
98
%
Waste Gas Heat Content
Constant Pilot Light: E Yes O No Pilot burner Rating
Btu/scf
MMBtu/hr
O Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
4IA®COLORADO
l,==
PM
Permit Number:
AIRS ID Number:
Breniman Produced Gas APEN
/ /
[Leave blank unless APCD has already assigned a permit N and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 Yes 0 No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Overall Requested Control
Efficiency
(% reduction in emissions,
Control Equipment Description
SOx
NO„
VOC
ECD
95%
CO
HAPs
ECD
95%
Other:
From what year is the following reported actual annual emissions data? 2017
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Emission '
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
etc)
M
``'
. �
I
itiii,R4
Uncontrolled
(Tons/ ear
(Tons/year)
Controlled'
Tons/ ear
(Tons/year) )
Uncontrolled,
( Y ) £. h(
Tons/ ear
Controlled
Y
'Tons/ ear)mfg,
PM
SOX
NOX
VOC
17.78
Ib/MSCF
Promax
34.47
1.72
51.70
2.58
CO
0.31
Ib/MMBTU
AP -42
0.808
0.808
1.212
1.212
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
0.208
Ib/MSCF
Promax
0.402
0.020
0.604
0.020
2,2,4-0.051
Trimethylpentane ylp
lb/MSCF
Promax
0.098
0.005
0.147
0.007
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
'Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
5�v
COLORADO
my.,wmaef mm.
Permit Number:
AIRS ID Number:
Brennan Produced Gas APEN
! /
Leaves o!an,- �,ar--, APCD hay a;reacy assignee a Ge'n't , arc AI=?S !D•.
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
nature of Legally Authorized Person (not a vendor or consultant)
Josh Carlisle
Date
EHSR Manager
Name (please print)
Title
Check the appropriate box to request a copy of the:
❑� Draft permit prior to issuance
Or Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to :
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Form APCD-2. I Gas Se,
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
61
C0LOF ADC
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