HomeMy WebLinkAbout20170236.tiffCOLORADO
Department of Public
Health ft 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
January 11, 2017
Dear Sir or Madam:
RECEIVED
JAN 172017
WELD COUNTY
COMMISSIONERS
On January 12, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for
Extraction Oil Et Gas, LLC - Thomas 16-C Pad. 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
PvbIrc R.vrew
of fra3/17
Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
cc:PLc mmi-rPJ,k LCOa>
AujcERfcH/ rmicrc)
of/(I1
2017-0236
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Extraction Oil Et Gas, LLC - Thomas 16-C Pad - Weld County
Notice Period Begins: January 12, 2017
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, LLC
Facility: Thomas 16-C Pad
Oil and Gas Well Production Facility
NWNE of Section 16, Township 10N, Range 67W
Weld County
The proposed project or activity is as follows: Operator is requesting permit coverage for one (1) three-
phase wellhead separator and four (4) 500 barrel crude oil storage vessels at a new synthetic minor oil and
gas well production facility.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• 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 16WE0625 and
16WE0626 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:
Harrison Slaughter
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 t=
Colorado Air Permitting Project
Version No. 1.00
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
Harrison Slaughter
347303
4/27/2016
7/7/2016
*Application was put on hold until 12/06/16 while awaiting updated information for point 004.
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical Address/Location:
Type of Facility:
What industry segment?
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? LI Carbon Monoxide (CO)
Extraction Oil & Gas, LLC
123
9E82
Thomas 16-C Pad
NWNE of Section 16, Township ION, Range 67W
Exploration & Production Welt P
Oil "& aturalGas Production Prtuessing
Section 02 - Emissions Units In Permit Application
❑ Particulate Matter (PM)
❑ Ozone (NOx & VOC)
AIRS Point 4
Emissions Source Type
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering Remarks
003
Crude Oil Storage Tank
..
yes
16WE0625
1
yes
Permit Initial
Issuance
Section 03 - Description of Project
Extraction Oil & Gas, LLC submitted an application requesting individual permit coverage for crude oil storage vessels at a new synthetic minor
exploration and production facility located in the ozone attainment area. Emissions from the crude oil storage vessels were estimated using site
specific emission factors which were developed from a site specific pressurized hydrocarbon sample in conjunction with an E&P tank simulation. This
permit will require public comment because the source is requsting federally enforceable permit limits on the potential to emit to avoid other
requirements.
Section 04 - Public Comment Requirments
Is Public Comment Required?
If yes, why?"
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?2 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, explain what programs and which pollutants here:
Prevention of Significant Deterioration (P50): VOC
Title V Operating Permits (OP) : VOC
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Stationary source is classified as synthetic minor as described above.
0.;
Ye
Colorado Air Permitting Project
Version No. 1.00
Crude Oil Storage Tank(s) Emissions Inventory
Section 01- Adminstretive information
(Facility AIRs ID:
123 9E82
County Plant
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Four (4)ISOObareet B0Nlroof audoa storage vessae:connented via ifgold m.nih
Emission Control Device C411alton 48a twgoeloa«t Uas attest Gvka
Desorption:
Requested Overall VOC & HAP Control
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Throughput =
Requested Permit Umit Throughput =
Potential to Emit (PTE) Throughput =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas= 2657.14 Btu/scf
Volume of waste gas emitted per BBL of liquids
produced = 40.63 scf/bbl
Actual heat content of waste gas routed to combustion device =
Request heat content of waste gas routed to combustion device =
Barrels (bbl) per year Actual Crude Oil Throughput While Emissions Controls Operating =
Barrels (bbl) per year
59.076. Barrels (bbl) per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device=
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factor Calculations
5,315 MMBTU per year
6,378 MMBTU per year
6,378 MMBTU per year
The site specific emission factors were developed using an E&P Tank simulation that utilized a site specific pressurized hydrocarbon liquid sample as an input.
The pressurized hydrocarbon liquid sample was obtained from the Thomas 16-C fadlity on February 23, 2016. Below is a summary of the emission rates
determined by the simulation. These emission rates are utilized in the calculation of the site specific emission factors.
E&P Tank Throughput
Basis: 49230 bbl ear
Pollutant
Uncontrolled Emission Rata
VOC
112.785
ton/year
Benzene
0.131
ton/year
Toluene
0:09
ton/year
Ethylbenzena
0.01
ton/year
Xyian
0.027.
ton/year
n-Hosane
0.843
ton/year
2,2,4 TMP
..0.162
ton/year
Section 05 - Emissions Inventory
Pollutant
PM10
PM2.5
Crude Oil Storage Tanks
Uncontrolled E.F. Controlled E.F.
)Ibs/bbl Crude Oil )Ibs/bbl Crude
Throughput) Oil Throughput)
Control Device
Uncontrolled E.F.
(Ibs/MMBtu
west. heat
combusted)
Uncontrolled
E.F. )Ibs/bbl
Crude Oil
Throughput)
75 0.0008
Emissions Factor Source Citation
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
PM10
PM2.5
NO5
VOC
CO
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.50
0.50
0.50
0.42
0.42
135.34
135.34
6.77
112.79
5.64
1.27
1.27
1.27
1.06
1.06
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year(
Actual Emissions
Uncontrolled Controlled
(tons/year( (tom/year)
Benzene
Toluene
Ethylb.nz.ne
Xylene
n -H
224 TMP
1.6E-01
1.6E-01
7.9E-03
1.3E-01
6.6E-03
1.1E-01
1.1E-01
5.4E-03
9.0E-02
4.5E-03
1.2E-02
1.2E-02
6.0E-04
1.0E-02
5.0E-04
3.2E-02
3.2E-02
1.6E-03
2.7E-02
1.4E-03
1.0E+00
1.0E+00
5.1E-02
8.4E-01
4.2E-02
1.9E-01
1.9E-01
9.7E-03
1.6E-01
8.1E-03
Section 06 - Regulatory Summery Analysis
Regulation 3, Parts A,B
Regulation 7, Section XVII.B, C.1, C.3
Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb
Regulation 6, Part A, NSPS Subpart 0000
Regulation 8, Part E, MACT Subpart HH
(Sae regulatory applicability worksheet for detailed analysis)
Source requires a permit
Storage tank is subject to Regulation 7, Section 0011, B, C.1 & C.3, as provided 1
Storage tank is subject to Regulation 7, Section XVII.C.2, as provided below
Storage Tank is not subject to NSPS Kb
Storage Tank is not subject to NSPS 0000
Storage Tank Is not subject to MACT HH
Requested Permit Limits
Uncontrolled
(Ibs/year)
314.40
216.00
24.00
64.80
2023.20
388.80
Controlled
(Ibs/year)
15.72
10.80
1.20
3.24
101.16
19.44
3 of 6 K:\PA\2016\16WE0625.CP1.olsm
Crude Oil Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Semolina and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03
Does the company use a site specific envisions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the
facility being permitted?
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
N/A - source eakulated emissions using she specific emissions factors
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and intlal compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technkel Analysis Notes
1. The uneOntroged NOe and CO emission factors represent approved values from the CDPNE tmer•OfficeCommunketlenon 2005-03.22 multiplied by the VOC emissionUsing the emission
resulted in a conservative estimate of emissions when compared to using the GOR and heatvalue oakulated by the E&P.Tank simulation along with the ARAI Chapter 13.5 emission faders for NO4 and CO:
result, they were determined to be acceptablefor estimating the emission associated with NOxand CO. For oomperetive purposes, the (404 emissions calculated using the data from E&PTank andAJM2 ar
follow: Not (toy). (40.63 sof/bbl)"(59706bbl/year)'(2657.14Btu/acf)`(1� MMBtu/1,WO,000BT').".066 lb NOx/MMRtti)`(lton/20061b)=0.22 tpy
2. The permit will net contain emission factors for %OO and CO because they are below APENreporsing thresholds.
3. The operator was provided with a draf penntt prierto public commerst. The operatorraviewed the Permit and presided oem
Deny Ipiies run we changethewordingto read"Enclosed Flare(s)', rather than specifying the number Of flares for this source?
ems The comments are as follow: (1)':First table, under
I) Section 7- Is it possible to remover a number of flare
My response was asfOdows: irttmnsof removing thenumber of flares, is there concern that by Listing the comber both will need to be inuxat all.times?is thefacilitydesigned such that bee
operating: in order to handle the emissions teem the crudeoil tanks? Is one ofthe gores simply used as a badeup? Ifthis is the case, the language maybeupdated to indicate that onlyone bars .-�-
operatlonatall timesaisd.thalone is simply used as a backup. The reason the number offlares Is listed into iefam our iespecu9nof theactual equipmdmoersite.
In response se myquestions, the operator eapresxdthat "Eatraeaioneaaie ants apemtenal pg0t lighbdn boats ECos, hosnayer, nMy one ECU ienba peimaryoentrel fortttetoMd dudngtnrsntb operating
Inr'sPora." After thistgscussion the operator expressed thefoliewing:."Thank you fur thediscussier lastweek. Please movaforwrderitEs afse penssifs est eyaee,and: let me knowifyou have any questions."
In summary, there aretwo enclosed comhustlondeyicee (ECU) at the site to control emissions fmmthe audeoil tangs. Dudngnormal operating condhtons,only one ECO ousel as alto prknaryconirol for the
collle the secondECG isused as a bads-Up.The use of a single ECD is sufhoientfor handling the volume ofuseategate emitted tom the=deoil tanks. it was determmedthatthepermit should contain langstega
indicetingthere ere two (Os at the featyferthis soured to inform the inspectonof actual equipment onloation. However, the operator will maintahtcomplfance with the permit if one ECD is operategat ail
times to control emissions from the crude og tanks. The operator agreed with this assesment and expressed they had no lurUsr comments prierto public comment.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point a
003
Process 0 5CC Code
01
Definitions for Drop Down lists
Storage Tank Emissions Factor Options
State Default E.F. (includes flash)
Other (Documented In Technical Analysis Notes)
Site Specific E.F. (Includes flash)
Site Specific EPA TANKS E.F. Working and Breathing Only
Qualifiers
No
Yes
Not applicable - stabilized tank
Control Devices
Enclosed Flare
Open Flare
Vapor Recovery Unit (VRU)
Control Device Combustion Emissions Factor Options
AP -42 Chapter 13.5 Industrial Flares (NOx/CO)
TNRCC Flare Emissions Guidance (NOx/CO)
AP -42 Table 1.4-2 (PM10/PM.2.5)
APCD Inter -office Memo 2005-03-22 (Units of lb/lb VOC)
SCC Codes - Storage Tank Emissions
4-04003-12 Fixed Roof Tank, Crude Oil, workingebreathingeflashing losses
4-04-003-02 Fixed Roof Tank: Working & Breathing Losses
4-04-003-22 External Floating Roof Tank, Crude Oil, working+breathingaflashing
404-003-06 External Floating Roof Tank: Working and Breathing Losses
404-003-32 Internal Floating Roof Tank, Crude Oil, workingebreathingaflashing
4-04-003-07 Internal Floating Roof Tank: Working and Breathing Losses
SCC Codes - Flaring Combustion Emissions
3-10-001-60 Flares
Pollutant
PM10
PM2.5
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Arlene
n -Hexane
224 TMP
Uncontrolled
Emissions
Factor
0.02
0.02
0.40
109.1
1.03
0.13
0.09
0.01
0.03
0.82
0.16
Control % Units
95
0
95
95
95
95
95
95
b/1,000 gallons crude oil throughput
b/1,000 gallons crude oil throughput
b/1,000 gallons crude oil throughput
b/1,000 gallons crude oil throughput
b/1,000 gallons crude oil throughput
b/1,000 gallons crude oil throughput
b/1,000 gallons crude oil throughput
b/1,000 gallons crude oil throughput
b/1,000 gallons crude oil throughput
b/1,000 gallons crude oil throughput
b/1,000 gallons crude oil throughput
4 of 6
K:\PA\2016\16W E0625.CP1.xlsm
Crude Oil Storage Tank Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B. APED and Permit Requirements
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. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)?
2a. If answer to #2 is yes, is the crude oil throughput less than 40,000 gallons per year?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, PartB, Section 11.0.31?
(Source requires a permit
NON -ATTAINMENT "This facility is located in the ozone attainment area. As a result. all questions of this section are listed as N/A.
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. Is the construction date prior t04/14/2014 and not modified after4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)?
2a. If answer to #2 Is yes, is the crude oil throughput less than 40,000 gallons per year?
3. 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 I I.D.2)?
'Not enough information
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this crude oil storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant?
3. Is this crude oil storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions'of this storage tank equal to or greater than 6 tons per year VOC?
'Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3, as provided below
Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1- Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5. Does the crude oil storage tank contain only "stabilized" liquids? If no, the following additional provisions apply.
'Storage tank is subject to Regulation 7, Section XVII.C.2, as provided below
Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m) ["472 BBLs]?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4(?
a. Does the vessel has a design capacity less than or equal to 1,589.874 ms ("10,000 BBL' used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111k?
3. Was this condensate storage tank constructed, reconstructed, or modifed (see defnitions 40 CFR, 60.2) after July 23, 1984?
4. Does the tank meet the definition of"storage vessel"' in 60.111k?
5. Does the storage vessel store a "volatile organic liquid (VOW' as defined in 60.111b?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ["29.7 psi] and without emissions to the atmosphere (60.1I0b(d)(2)1?; or
b. The design capacity is greater than or equal to 151 m' ["'950 BBL] and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.110b(b))?; or
c. The design capacity is greater than or equal to 75 M' ('"472 BBL] but less than 151 ms ("950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))?
'Storage Tank is not subject to NSPS Kb
Subpart A, General Provisions
§60.1120 - Emissions Control Standards for VOC
§60.113b - Testing and Procedures
§so.115b - Reporting and Recordkeeping Requirements
§60.116b - Monitoring of Operations
40 CFR. Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Was this crude oil storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after August 23, 2011?
2. Does this crude oil storage vessel meet the definition of "storage vessel"' per 60.5430?
3. Is this crude oil storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year?
yes
NA t
141 .........::...
NA
NA.......
NA
Source Req
Go to next I
Source Req
Go to next i
Go to the n.
Go to then
Source is su
Go to the n
Storage Tar
Too
Yes
Yes
Go to then
Go to the n
Go to then
'Storage Tank is not subject to NSPS 0000
Subpart A, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§60.5395(g) - Notification, Reporting and Recordkee ping Requirements
§60.5416(c) - Cover and Closed Vent System Monitoring Requirements
§60.5417- Control Device Monitoring Requirements
[Note: N a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365)e))2)
even If potential VOC emissions drop below 6 tons per year]
40 CFR, Part 63, Subpart MAR HH, Oil and Gas Production Facilities
1. Is the tank located at a facility that is major' for HAPs7
2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR
b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end users 163.760(x)(3117
3. Does the tank meet the definition of -storage vessel.' in 63.761?
0. Does the tank meet the definition of"storage vessel with the potential for flash emissions"s per 63.7617
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
(Storage Tank is not subject to MACE He
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitoring
§63.774- Recordkeeping
§63.775 - Reporting
RACT Review
RACE review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. Ifthe tank meats both criteria, then review RACT requirements.
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.
-; Storage Tar
Permit number:
Date issued:
Issued to:
DO
on trot Division
Department of Public Health & Environment
CONSTRUCTION PERMIT
16WE0625
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Extraction Oil Et Gas, LLC
Thomas 16-C Pad
123/9E82
NWNE SEC 16 T10N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Oil Storage
g
Tanks
003
Four (4) 500 barrel fixed roof storage vessels
connected via liquid manifold used to store
crude oil
Two (2) Enclosed
Flares
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 the
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
Storage Tank Version Syn Minor 2015-1
Page 1 of 7
.c or =o.•Wv/p. ific dphe/. -permit-self-certification. (Regulation Number 3, Part B,
ecti•"" `.G.
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
Oil Storage
Tanks
003
---
---
6.8
---
Point
Note: See "Notes to Permit Holder" for information on emission
limits.
Compliance with the annual limits, for criteria 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
Oil Storage
Tanks
003
Two (2) Cimarron 48" HV Enclosed Flares
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
COLORADO
Air Pollution Control Division
FDe gr.Yncr. .J uutAz I fec <.h. b a'rc xccnrr;ent
Page 2 of 7
•„_
ude hroughput
59,076 barrels
The owner or operator shall monitor monthly process rates based on the calendar month.
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.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shalt be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. 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.
12. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate 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 except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to
the Division upon request. This control requirement must be met within 90 days of the date
that the storage tank commences operation.
13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING & 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.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
COLORADO
Air Pollution Control Division
Page 3 of 7
15. o '= a •r per• •r all de nstrate compliance with opacity standards, using EPA
2 ." .R. P. •0, 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
16. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 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.
18. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4).
GENERAL TERMS AND CONDITIONS
19. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
'COLORADO
Air Pollution Control Division
Dmaubbr cur Public P1buith 5'cr≤i-onrii ric
Page 4 of 7
this ac pity or operation of this source. Final authorization of the
ec ."' the D 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.
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:
Harrison Slaughter
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil a Gas, LLC
Permit for crude oil storage vessels at a new
synthetic minor oil and gas exploration and
production facility.
COLORADO
I Air Pollution Control Division
'ubLc f-ltr.,
Page 5 of 7
No
th-. 3.' this • it issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
003
Benzene
71432
315
16
Toluene
108883
216
11
Ethylbenzene
100414
24
2
Xylenes
1330207
65
4
n -Hexane
110543
2,024
102
2,2,4-
Trimethylpentane
540841
389
20
Note: All non -criteria reportable pollutants in the tablea ove with uncontrolled emission rates above 250 pc
per year ( b/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 003:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
V0C
4.58
2.29x1O'
E&P Tank
71432
Benzene
5.32x10"'
2.66x10-4
E8P Tank
108883
Toluene
3.65x10-3
1.82x10"4
EftP Tank
100414
Ethylbenzene
4.06x10-4
2.03x10"'
EaP Tank
1330207
Xylene
1.09x10"3
5.48x1O'
EEtP Tank
110543
n -Hexane
3.42x10"`
1.71x10-3
EaP Tank
540841
Trimethylpentane lane
6.58x10-3
3.29x10-4
EaP Tank
COLORADO
Air Pollution Control Division
tee„ rr mtn Public } {e,'r:1'E^.' orrr:<nC
Page 6 of 7
this point are based on the enclosed flare control efficiency of
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 permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A)
when applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
PSD
Synthetic Minor Source of: VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
9) 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
Aix Pollution Control Division
Puitc
Page 7 of 7
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Denver, Colorado
Phone Number: (720) 481-2372
Fax Number:
Section 03 — General Information
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Application sta
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Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) I
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API Number
05 - 123 - 42285
APForm-APCD-2IO-CrudeTankAPEN.doc
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Permit Number:
Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM)
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aration Technolo
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Section 01 — Administrative Information
Request for NEW permit or newly reported emission source
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Request to limit IIAPs with a Federally enforceable limit on PTE
370 17th Street, Suite 5300
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Volume II, Chapter 10 -
Section 03 — General Information
For new or reconstructed sours
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(Tons/Year) (Tons/Yearl
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11 Natural Gas Venting APEN
Colorado Air Permitting Project
Version No. 1.00
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
Harrison Slaughter
347303
4/27/2016
7/11/2016
*Updated APEN received 12/06/2016
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical Address/Location:
Type of Facility:
What industry segment?
Is this facility located in a NAAQS non -attainment area? No
If yes, for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM)
Extraction Oil & Gas, LLC
123
9E82;
Thomas 16-C Pad
NWNE of Section 16, Township 10N, Range 67W
Explora on & Production Well Pad.
Oil & Natural' Gas Production & Processing
Section 02 - Emissions Units In Permit Application
❑ Ozone (NOx & VOC)
AIRS Point #
Emissions Source Type
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering Remarks
004_
Separator Venting .
', Yes "_
16WE0626
1
Yes
Permit Initial
Isst,{erlce ,:-
Section 03 - Description of Project
Extraction Oil & Gas, LLC submitted an application requesting individual permit coverage for natural gas venting at a new synthetic minor exploration
and production facility located in the ozone attainment area. Emissions from the three-phase heated separator are controlled by an enclosed
combustor. Emissions from this source were estimated using a site specific gas analysis from Thomas 16-C pad taken on October 31; 2016. This
permit will require public comment because the source is requsting federally enforceable permit limits on the potential to emit to avoid other
requirements.
Section 04 - Public Comment Requirments
Is Public Comment Required?
If yes, why?"
Yes
Requesting Synthetic Mini
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?2
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
No
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, explain what programs and which pollutants here:
Prevention of Significant Deterioration (PSD): VOC
Title V Operating Permits (OP): VOC
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Stationary source is classified as synthetic minor as described above.
No
Yes
Colorado Air Permitting Project
Version No. 1.00
One three-phase heated separator controlled by one enclosed flare. Enclosed flare has a minimum
004 control efficiency of 95%.
Equipment Description
This source vents natural gas from:
Emissions from this source are:
a three-phase well head separator
Natural gas venting from a three-phase well head separator. Emissions from this source are routed to a flare.
Calculations
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q`MW*Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas *MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Actual Throughput
Requested
Throughput (0)
MW
21.96
MMscf/yr
26.4
MMscf/yr
lb/lb-mol
3013.69863
scf/hr
27.15
0.072328767
MMscf/d
mole %
MW
Ibx/Ibmol
mass fraction
lb/hr
lb/yr
tpy
Helium
0.00
4.0026
0.000
0.000
0.00
0.00
0.00
CO2
2.60
44.01
1.145
0.042
9.11
79779.28
39.89
N2
2.35
28.013
0.658
0.024
5.23
45838.02
22.92
methane
': 60.13
16.041
9.645
0.355
76.69
671838.63
335.92
ethane
11.50
30.063
3.458
0.127
27.50
240896.68
120.45
propane
14.04
44.092
6.192
0.228
49.23
431292.63
215.65
isobutane
1.59
58.118
0.922
0.034
7.33
64190.24
32.10
n -butane
4.92
58.118
2.857
0.105
22.72
199007.56
99.50
isopentane
0.97
72.114
0.700
0.026
5.56
48725.47
24.36
n -pentane
0.94
72.114
0.681
0.025
5.42
47454.59
23.73
cyclopentane
0.05
70.13
0.036
0.001
0.29
2540.22
1.27
n -Hexane
0.16
86.18
0.140
0.005
1.11
9730.93
4.87
cyclohexane
0.02
84.16
0.019
0.001
0.15
1342.47
0.67
Other hexanes
0.26
86.18
0.224
0.008
1.78
15631.92
7.82
heptanes
0.29
100.21
0.294
0.011
2.34
20508.20
10.25
methylcyclohexane
0.04
98.19
0.040
0.001
0.32
2804.24
1.40
224-TMP
0.00
114.23
0.000
0.000
0.00
0.00
0.00
Benzene
0.02
78.12
0.013
0.000
0.10
919.63
0.46
Toluene
0.03
92.15
0.025
0.001
0.20
1765.20
0.88
Ethylbenzene
0.01
106.17
0.010
0.000
0.08
665.59
0.33
Xylenes
0.02
106.17
0.018
0.001
0.15
1272.02
0.64
C8+ Heavies
': 0.06
126.633
0.072
0.003
0.57
4983.80
2.49
MW
VOC mass fracl
27.150
0.451
Total VOC (Uncontrolled)
426.42
Notes
Mole %, MW, and mass fractions from the Thomas 16-C Pad gas analysis collected 10131/2016.
Emissions are based on 8760 hours of operation per year.
I calculated the average MW of C8+ based on the average MW on the analysis for the gas.
16WE0626.CP1.xlsm
One three-phase heated separator controlled by one enclosed flare. Enclosed flare has a minimum
004 control efficiency of 95%.
Flaring Information
Equipment Description
Enclosed flare to combust separator gas.
Manufacturer
Project
Consultants, LIZ
Model
TED
Serial Number
TBD
Gas Heating Value
1512.271
Btu/scf
Throughput
39923.9544
MMBtu/yr
VRU Information
Equipment Description
This facility does not utilize a VRU.
Make
Model
Requested Control
Annual Bypass Time
Backup
NIA
N/A
WA
WA
Overall Control
95.00%
Combustion emission factor source:
0.07 jlb NOX/MMBtu
led
AP -42: Chapter 13.5
0.31 llb CO/MMBtu
Pollutant
Uncontrolled Emission Factor
Controlled Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
VOC
32304.346
lb/MMscf
1615.217 lb/MMscf
426.42 tpy
21.32 tpy
Gas Analysis
NOx
102.834
lb/MMscf
102.834 lb/MMscf
1.36 tpy
1.36 tpy
AP -42
CO
468.804
lb/MMscf
468.804 lb/MMscf
6.19 tpy
6.19 tpy
AP -42
Benzene
34.835
lb/MMscf
1.742 lb/MMscf
919.6 lb/yr
46.0 lb/yr
Gas Analysis
n -Hexane
368.596
lb/MMscf
18.430 lb/MMscf
9730.9 lb/yr
486.5 lb/yr
Gas Analysis
Toluene
66.863
lb/MMscf
3.343 lb/MMscf
1765.2 lb/yr
88.3 lb/yr
Gas Analysis
Xylenes
48.183
lb/MMscf
2.409 lb/MMscf
1272.0 lb/yr
63.6 lb/yr
Gas Analysis
Ethylbenzene
25.212
lb/MMscf
1.261 lb/MMscf
665.6 lb/yr
33.3 lb/yr
Gas Analysis
2,2,4-TMP
0.000
lb/MMscf
0.000 lb/MMscf
0.0 lb/yr
0.0 lb/yr
Gas Analysis
Pollutant
Uncontrolled Emission Factor
Controlled Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
VOC
32304.346
lb/MMscf
1615.217 lb/MMscf
354.70 tpy
17.74 tpy
Gas Analysis
NOx
102.834
Ib/MMscf
102.834 lb/MMscf
1.13 tpy
1.13 tpy
AP -42
CO
468.804
lb/MMscf
468.804 lb/MMscf
5.15 tpy
5.15 tpy
AP -42
Benzene
34.835
lb/MMscf
1.742 lb/MMscf
765.0 lb/yr
38.2 lb/yr
Gas Analysis
n -Hexane
368.596
lb/MMscf
18.430 lb/MMscf
8094.4 lb/yr
404.7 lb/yr
Gas Analysis
Toluene
66.863
lb/MMscf
3.343 lb/MMscf
1468.3 lb/yr
73.4 lb/yr
Gas Analysis
Xylenes
48.183
lb/MMscf
2.409 lb/MMscf
1058.1 lb/yr
52.9 lb/yr
Gas Analysis
Ethylbenzene
25.212
lb/MMscf
1.261 lb/MMscf
553.7 lb/yr
27.7 lb/yr
Gas Analysis
2,2,4-TMP
0.000
lb/MMscf
0.000 lb/MMscf
0.0 lb/yr
0.0 lb/yr
Gas Analysis
Regulatory Applicability
AQCC Regulation 1
This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other
flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess
of 30% opacity.'
AQCC Regulation 2
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits:
For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air
has been diluted with seven (7) or more volumes of odor free air."
AQCC Regulation 7
Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
Yes
This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, Section XVII.B.2
16WE0626.CP1.xlsm
One three-phase heated separator controlled by one enclosed flare. Enclosed flare has a minimum
004 control efficiency of 95%.
Additional Notes:
1. The operator expressed that the natural gas vented from the three-phase separator is currently tracked using a flow meter. As a result, the permit will contain a
condition indicating compliance with the process limit in the permit will demonstrated through the use of a flow meter.
2. In the initial application, the operator calculated emissions from this source using a gas analysis that was inadequate for the emission estimate. The gas analysis was
not sufficient because it lacked information pertaining to n -Hexane, BTEX, and components heavier than C6. This fact was expressed to the operator. The operator
agreed with this assessment and expressed they would obtain a new sample. The new site specific sample used to estimate emissions was provided by the operator on
December 06, 2016.
3. The operator was provided with a draft permit to review prior to public comment. The operator reviewed the draft and provided the following comment: (i) Section
7- Is it possible to remove the brand name (Project Consultants, LLC), again for operational flexibility.
The following is my response to the comment: "Similar to above, the brand name is listed in the permit to inform the inspector of the actual equipment on -site. Is
there a reason that removing this will allow for operational flexibility? I would like to point out that if a control device is changed, an updated APEN and permit
modification would be required for the source."
The operator provided the following response: "Thank you for the discussion last week. Please move forward with the permits as they are, and let me know if you
have any questions."
Since the operator agreed with my explanation, this permit was finalized and submitted to public comment.
16WE0626.CP1.xlsm
AIRS (County/Plant) 123/9E82
Permit No. 16WE0626
Date 7/11/2016
Point #
SCC
Pollutant or CAS
Uncontrolled Emission
Factor
Emisison Factor Source
Controlled
Actual
Emissions
(tpy)*
Controlled
Requested
Emissions
(tpy)*
PTE (tpy)*
Ctrl.
Eff%
NCRP =
reportable
?
004
31000205
VOC
32304.346 lb/MMscf
Gas Analysis
17.74
21.4
426.4
95%
Yes
004
31000205
NOx
0.068 Ib/MMBTU
AP -42
1.13
1.4
1.4
0%
No
004
31000205
CO
0.31 Ib/MMBTLAP-42
5.15
6.2
6.2
0%
Yes
004
31000205
Benzene
34.835 lb/MMscf
Gas Analysis
38.2
46
920
95%
Yes
004
31000205
n -Hexane
368.596 lb/MMscf
Gas Analysis
404.7
487
9731
95%
Yes
004
31000205
Toluene
66.863 lb/MMscf
Gas Analysis
73.4
89
1766
95%
Yes
004
31000205
Ethylbenzene
25.212 Ib/MMscf
Gas Analysis
27.7
34
666
95%
Yes
004
31000205
Xylenes
48.183 lb/MMscf
Gas Analysis
52.9
64
1272
95%
Yes
Permit number:
Date issued:
Issued to:
Co
Air Po
Depart
CONSTRUCTION PERMIT
16WE0626
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Extraction Oil Et Gas, LLC
Thomas 16-C Pad
123/9E82
NWNE SEC 16 T10N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
ECC-30 Flare
004
One (1) three-phase heated wellhead
separator.
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
•
Yt. J'::.>`a,ro?lme!t
Page 1 of 7
3. This permit shall expire i n: o •per. oft urc or which this permit was issued:
(i) does not commence cratio of this source within 18 months
after either, the date = •an - - co- .. n p 't 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.)
F.4. )
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
ECC-30 Flare
004
---
1.4
21.4
6.2
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods us
limits.
Compliance with the annual limits, for criteria 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
ECC-30 Flare
004
Project Consultants, LLC Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
ECC-30 Flare
004
Natural Gas Venting
26.4 MMSCF
;COLORADO
Mr Pollution Control Division
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Page 2 of 7
Compliance with the an
month total. By the end
previous twelve months'
keep a compliance record
review.
det mined on a rolling twelve (12)
ont total is calculated based on the
T e -olcal e throughput each month and
on site or at a local field office with site responsibility, for Division
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 shalt use
monthly throughput records to demonstrate compliance with the process limits contained in
this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
11. 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 this point, the owner or operator shall follow the most recent operating and
maintenance (O&M) 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 O8M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
'COLORADO
Air Pollution Control Division
ubl c 1 ica'cth 6 ?:curirr;c:}t
Page 3 of 7
Periodic Testing Require
16. This source is not requi c�idrioc t ling, u less otherwise directed by the
Division or other state or e•eral requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30`h 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.
18. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4).
GENERAL TERMS AND CONDITIONS
19. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in 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
COLORADO
Air Pollution Control Division
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Page 4 of 7
of such final authorizatio
the Requirements to Se
�r •tai
r nal
fin a thor
riz i sec
ation to operate are located in
on of this permit.
21. This permit is issued in re lance upon t e 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:
Harrison Slaughter
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil Et Gas, LLC
Permit for one (1) three-phase heated wellhead
separator at a new synthetic minor oil and gas
exploration and production facility.
COLORADO
Air Pollution Control Division
S:E,pzn,nerai cli Public Heakti, v .4 ^,r<onrr _ nt
Page 5 of 7
Notes to Permit Holder at the ti
1) The permit holder is requir- - may -s = e = = eking ti for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
004
Benzene
71432
920
46
Toluene
108883
1,766
89
Ethylbenzene
100414
666
34
Xylenes
1330207
1,272
64
n -Hexane
110543
9,731
487
Note: All non -criteria reportable pollutants in the tablea o ds
per year ( b/yr) are reportable and may result in annual emission f7es 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
NOx
102.83
102.83
AP -42
CO
468.8
468.8
AP -42
VOC
32,304.34
1615.21
Gas Analysis
71432
Benzene
34.83
1.74
Gas Analysis
108883
Toluene
66.86
3.34
Gas Analysis
100414
Ethylbenzene
25.21
1.26
Gas Analysis
1330207
Xylene
48.18
2.4
Gas Analysis
110543
n -Hexane
368.59
18.43
Gas Analysis
Note: The uncontrolled VOC and HAP emissions factors for this point were calcu ated using the October 31,
2016 analysis of a gas sample collected from the Thomas 16-C Pad. The controlled emissions
factors for this point are based on the enclosed flare control efficiency of 95%.
COLORADO
Air Pollution Control Division
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Page 6 of 7
6) In accordance with C.R.S. 25- -114 c it P. l ant lion otice (APEN) associated with
this permit is valid for a term •f fiv y. r om ate as r eived by the Division. A revised
APEN shall be submitted no - - an .. - -for- - e -ye rm expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
PSD
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
616580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
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