HomeMy WebLinkAbout20173691COLORADO
Department of Public
Health fs Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
October 19, 2017
Dear Sir or Madam:
OCT 232017
On October 26, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for
Extraction Oil Et Gas, Inc. - Hester Production Facility. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health 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
Po colic.
tot 3O( t?
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickentooper, Governor ( Larry Wolk, MD, MSPH, Executive Director and Chief Medical Offil
c.c t PLCrn -/ -r-o), HL C T),
PWCER/ CH/a- /C(c)
2017-3691
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Extraction Oil I* Gas, Inc. - Hester Production Facility - Weld County
Notice Period Begins: October 26, 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 a Gas, Inc.
Facility: Hester Production Facility
Oil and Gas Well Production Facility
SWNW Section 31, T7N, R66W
Weld County
The proposed project or activity is as follows: Applicant proposes to construct a new oil and gas well
production facility where 48.2 MMSCF/yr of Separator gas and 4.4 MMSCF/yr of Vapor Recovery Tower gas
will be vented to an enclosed flare.
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 analyses, and drafts of Construction Permits 17WE0722 and
17WE0723 have been filed with the Weld County Clerk's office. A copy of the draft permits and the
Division's analyses 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:
Oluwaseun Ogungbenle
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
1I AVCOLORADO
Permit number:
Date issued:
Issued to:
ADO
n Contra
lcHea
CONSTRUCTION PERMIT
17WE0722
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Extraction Oil Ft Gas, Inc.
Hester Production Facility
123/9F46
SWNW SEC 31 T7N R66W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Separator
Venting
008
High -Low Pressure Separator gas controlled
by an enclosed combustor during VRU
downtime.
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
Page 1 of 7
3. �,e _ expl ;� � �-. '' er or oper . or .` =�_ e source this perms ��°�as issued:
peration isource withi8 months
f is ice oft constron per or the date on ich such
r activ was s •uled =. commence ,s set 1, th in the permilication
ed with thi . ; (ii) "� ": ,>xys cons �`rr k " : . = 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.)
Annual Limits:
s permit s
does not c
er either,
stru •
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
Separator
Venting
008
---
2.0
10.2
8.9
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
Separator
Venting
008
Emissions from the Separators are routed to
an Enclosed Flare during Vapor Recovery Unit
(VRU) downtime
VOC and HAP
COLORADO
I Air Pollution Control Division
Page 2 of 7
8.
Process Limits
follow)
tes sh
be main
eque
ate :s listed be :''. Monthly
owner or operat : nd made
ber 3, Par
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Separator
Venting
008
Natural Gas Venting
48.2 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. Upon installation of the flow meter, 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.
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
XVI1.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
COLORADO
Air Pollution Control Division
E -i rorx≥ 1,t
Page 3 of 7
to implem • (Regulatio ;: umber 3,
COM
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)
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. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such
time that this source becomes major solely by virtue of a relaxation in any permit condition. Any
relaxation that increases the potential to emit above the applicable Federal program threshold
will require a full review of the source as though construction had not yet commenced on the
source. The source shall not exceed the Federal program threshold until a permit is granted.
(Regulation Number 3, Parts C and D).
COLORADO
Air Pollution Control Division
Page 4 of 7
19. ts must b - nd mad '=vail .le for insion upon
�,.
d to a owner he APC s provided in AQC egulation
art B, > ,";,...B. st for hip and thl 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 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:
Oluwaseun Ogungbenle
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil Et Gas, Inc.
COLORADO
Air Pollution Control Division
Page 5 of 7
Notes t• ';-rmit Hold
1) The rmit holde time forpe it. An invo for these
fee ll be issues `after t z•erml slued V e perms lder sh., .ay the invoice w s n 30 days
sue.
e inv.; _ ure_.. invoi .e. s 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
(lb/yr)
Controlled
Emissions
(lb/yr)
Separator
Venting
008
Benzene
71432
595
30
Toluene
108883
1287
64
Ethylbenzene
100414
404
20
Xylenes
1330207
809
40
n -Hexane
110543
6346
317
2,2,4-
Trimethylpentane
540841
145
7
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 008:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
N0x
81.1
81.1
AP -42
CO
369.8
369.8
AP -42
V0C
8455
422.75
ProMax
71432
Benzene
12.350
0.618
ProMax
108883
Toluene
26.708
1.335
ProMax
100414
Ethylbenzene
8.393
0.420
ProMax
1330207
Xylene
16.786
0.839
ProMax
110543
n -Hexane
131.710
6.586
ProMax
COLORADO
Air Pollution Control Division
Page 6 of 7
ollut
2 2
Trimethy pen ane
Uncontr•=ed Contr
Emission Emission
(lb/ CF) (lb/
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
The emission factors listed above are based on modeled separator temperature of 95 °F and separator
pressure of 365 psig.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: NOx, VOC, CO, n -Hexane, and total HAPs
NANSR
Synthetic Minor Source of: NOx and 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.wpoaccess.Qov/
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
Page 7 of 7
Colorado Air Permitting Project
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01 - Facility Information
Oluwaseun Ogungbenle:
365936
7/10/2017
8/31/2017
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
If yes, for what pollutant?
Extraction Oil & Gas, Inc.
123
9F46
Hester Production Facility
SWNW quadrant of Section 31, Township 7N, Range 66WW, in Weld County, Colorado
Exploration fk,Produuction Well Pad'
Oil & NaturafasProduction & Processing
non -attainment area? Yes
(carbon Monoxide (CO) aardculate Matter (PM)
Weld
Quadrant
Section
Township
Range
SWNW
31
7N
66W
Section 02 - Emissions Units In Permit Application
3Jzone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment
Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
008
Separator Venting
Separator
Venting
Yes
17WE0722
1
Yes
Permit Initial
Issuance.
New point
009
Vapor Recovery Tower (VR F`
VRT Venting
Yes
17WE0723
1
yes
Permit Initial >
lssuaric
New point
Section 03 - Description of Project
In addition to the two emission points covered by this analysis, as part of this permiting action, Extraction Oil & Gas is also requesting to permit the following
emission points: condensate storage tank (8-400 bbl vessels), produced water storage tank (2-400 bbl vessels), hydrocarbon liquid loading, and four natural gas-
fired compressor engines. Besides the two points covered by this analysis, all other equipment with reportable emissions at t his facility are covered under
General Permits.
Emissions due to Separator Venting and VRT venting were modeled using ProMax. There are twelve (12) HLP separators at this fa cility. The gas analysis used to
calculate the separator venting emissions was based on a sample obtained from one of the 12 wells serving thisfacility: I was concerned that sampling one of
twelve wells might not be an adequate representation of the overall gas vented from the HLP senators. To that effect, I inclu ded, in the first draft of Permit
17WE0722, a nuanced condition aimed at addressing this concern. The condition required the operator to complete an initial gas analysis for two more wells in
order to ascertain that the VOC weight percent reported for this permitting action is a conservative representation of all 12 wells at this facility. Operator,
through their consultant (Spirit Environmental), requested that this condition be removed citing the fact that they had not seen this requirement for any other
multi -well facility permits. I responded by letting them know I was amenable to removing this condition but would like to know how they intend to address this
concern: Operator, through their consultant, responded with the following statement: "We're going to have a discussion with out field/sampling team regarding
sampling additional wells at these larger sites moving forward or possibly utilizing a different sampling location at the site to get a better representation of the
produced gas as a whole." With this plan of action, l was more confortabie with my decision to remove the said condition from Permit 17WE0722.
Controlled VOC emissions from the VRT vented gas are 11:23 tpy; therefore, Permit 17WE0723 initially contained a VOC permit I imit of 11.2 tpy. !n their
comments on the draft permit, operator; through their consultant expressed concern about the remote possibility of this roun ding resulting In potential
compliance issues in the event that they go aver 11.2 tpy on a rolling 12 -month total during maximum operation. To address this concern, I changed the VOC
limit in the permit to 11.3 toy:
Section 04 - Public Comment Requirements
Colorado Air Permitting Project
Is Public Comment Required?
If yes, why? Requesti
Yes
Synthetic Mims Per
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
iyo
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 NOx CO VOC PM2.5 PM10 TSP HAPs
00000 0
02000 0 ❑ 0
0
Is this stationary source a major source? No
If yes, explain what programs and which pollutants here: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) DODO ❑ ❑
Title V Operating Permits (OP) 00000 ❑ 0 0
Non -Attainment New Source Review (NANSR) 0 0
Produced Natural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer:
Oluwaseun Ogungbenle
Control Engineer:
Stephanie Spector
Review Date:
08/31/2017
Application Date:
07/10/2017
Facility Information
Permit No.
17WE0722
123 Weld
9F46
008
Separator Venting
Extraction Oil & Gas, Inc.
Hester Production Facility
SWNW Section 31, Township 7N, Range 66W
AIRs
County #
Facility #
Point #
Facility Equipment ID
Company Name:
Source Name:
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Nonattainment
VOC
Nonattainment
CO
Attainment
Potentially Located within EAC - determine attainment status of NOx and \
Source Location:
SIC:
211111
Elevation (feet)
x
New Permit (CP1)
Modification
(Issuance #)
APEN
Required/Permit
Exempt
Transfer of
Ownership
APEN
Exempt/Permit
Exempt
Notes
Produced Natural Gas Venting/Flaring Preliminary Analysis
Eauinment Descriation
This source vents natural gas from:
a well head separator
Emissions from this source are:
routed to an enclosed flare
Colorado Department of Public Health and Environment
Air Pollution Control Division
Natural gas venting from a well head separator. Emissions from this source are routed to an enclosed flare.
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
Maximum Vent Rate I 100000 scf/hr
RequestedThroughput (Q) 48.2 MMscf/yr
5502.3 scf/hr I 0.001 MMscf/d I 4.09 MMscf/mo
% Vented I 6%
MW 20.500 Ib/Ib-mol
Component
mole %
MW
Ibx/Ibmol
mass fraction
E
lb/hr
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
1.819
44.01
0.801
0.039
CO2
11.6
101810
50.91
N2
0.668
28.013
0.187
0.009
N2
2.7
23798
11.90
methane
78.828
16.041
12.645
0.617
methane
183.6
1608125
804.06
ethane
12.164
30.063
3.657
0.178
ethane
53.1
465068
232.53
propane
5.3
44.092
2.3369
0.114
propane
33.9
297196
148.60
isobutane
0
58.118
0.0000
0.000
isobutane
0.0
0
0.00
n -butane
0.458
58.118
0.2662
0.013
n -butane
3.9
33852
16.93
isopentane
0.218
72.114
0.1572
0.008
isopentane
2.3
19993
10.00
n -pentane
0.277
72.114
0.1998
0.010
n -pentane
2.9
25404
12.70
cyclopentane
0.014
70.13
0.0098
0.000
cyclopentane
0.1
1249
0.62
n -Hexane
0.0580
86.18
0.0500
0.002
n -Hexane
0.7
6357
3.18
cyclohexane
0.0070
84.16
0.0059
0.000
cyclohexane
0.1
749
0.37
Other hexanes
0.069
86.18
0.0595
0.003
Other hexanes
0.9
7562
3.78
heptanes
0.07
100.21
0.0701
0.003
heptanes
1.0
8921
4.46
methylcyclohexane
0.009
98.19
0.0088
0.000
methylcyclohexane
0.1
1124
0.56
224 -IMP
0.001
114.23
0.0011
0.000
224-TMP
0.0
145
0.07
Benzene
0.006
78.12
0.0047
0.000
Benzene
0.1
596
0.30
Toluene
0.011
92.15
0.0101
0.000
Toluene
0.1
1289
0.64
Ethylbenzene
0.003
106.17
0.0032
0.000
Ethylbenzene
0.0
405
0.20
Xylenes
0.006
106.17
0.0064
0.000
Xylenes
0.1
810
0.41
C8+ Heavies
0.015
137.229
0.0206
0.001
C8+ Heavies
0.3
2618
1.31
Notes
VOC mass fraction: 0.1566 Total VOC Emissions (Uncontrolled)
annual limit assuming 95% control
monthly limit assuming 95% control (lb/mo.)
204.1
10.2
1733.8
Mole %, MW, and mass fractions from analysis of Hester Farms F-36HN gas sample collected 06/13/2017.
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.
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Flaring Information
Equipment Description
Flare to combust low-pressure separator gas during VRU downtime.
Manufacturer
Questpor
Model
Q5000
Serial Number
TBD
Gas Heating Value
1193
Btu/scf
Throughput
57502.6
MMBtu/yr
Combustion emission factor source:
AP -42: Chapter 13.5
0.068
lb NOx/MMBtu
0.31
lb CO/MMBtu
1.96
tpy NOx
8.91
tpy CO
Emissions Summary
1.96
tpy NOx
Uncontrolled/PTE
8.91
tpy CO
204.1
tpy VOC
Controlled
10.2
tpy VOC
Uncontrolled
Total (Ib/yr)
Scenario A
Reportable?
Controlled Total
(lb/yr)
Benzene
596
Yes
30
Toluene
1289
Yes
64
Ethylbenzene
405
Yes
20
Xylenes
810
Yes
41
n -hexane
6357
Yes
318
224-TMP
145
No
7
Emission Factors for Permit
meter installed:
Uncontrolled
NOx
81.1
Ib/MMscf natur
CO
369.8
lb/MMscf natun
VOC
8470
lb/MMscf natur
Benzene
12.367
lb/MMscf natun
Toluene
26.745
lb/MMscf naturi
Ethylbenzene
8.4040
lb/MMscf natun
Xylenes
16.8079
lb/MMscf natun
n -Hexane
131.88
lb/MMscf natun
224-TMP
3.0140
lb/MMscf natun
Controlled
NOx
81.1
lb/MMscf natur
CO
369.8
lb/MMscf natur
VOC
424
lb/MMscf natur
Benzene
0.6184
lb/MMscf natun
Toluene
1.3373
lb/MMscf natun
Ethylbenzene
0.4202
lb/MMscf natur
Xylenes
0.8404
lb/MMscf natun
n -Hexane
6.5942
lb/MMscf natur
224-TMP
0.1507
lb/MMscf natun
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
Produced Natural Gas Venting/Flaring Preliminary Analysis
Regulatory Applicability
AQCC Regulation 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
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 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions exceed one
ton per year in a nonattainment area for ozone.
Part B:
A permit is required for this -source because uncontrolled VOC emissions from this
facility exceed two tons per year in a nonattainment area for ozone.
This source is subject to Section III.D.2 (Minor Source RACT) because it is located in
a nonattainment area. RACT for this source has been determined to be the use of a
flare to control emissions.
Is public comment
required?
Public Comment Required
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, XVII.B.2
Facility Status
This facility is a synthetic minor source of NOX, VOC, CO, and HAP for Title V applicability.
This facility is a synthetic minor source of NOX and VOC for NSR applicability.
COLORADO DEPARTMENT OF PUBLIC HEALTH ENVIRONMENT
AIR POLUTION CONTROL DIVISION
INVENTORY
N
O N r
m.
n
CD LLI '
M
N M
• c0
O
z f0
E
0 O
O
U
.7t
Co
II
at
Ct O
O
Z 22O•
Co
}}}}}Z
Co
Co
Co
0
.„,9
o- w
0
p
..„9.
p
0
rn
0
LC)
e
LC)
0
CO
0
CO
0
CO
0
rn
T
�-p
LLJ
I-
0_
N
O
=
a
O
O
O
O4 O4
O
O
O
6357
LO
Controlled
Requested
Emissions
(tpY)*
O
Cs/
CD
c0
N
O
30
64
O
N
41
318
C --
Controlled
Actual
Emissions
(tpY)*
Emisison Factor Source
AP -42 Chapter 13.5
AP -42• Chapter 13.5
Engineering Calcs
Engineering Calcs
-- ---- -----
Engineering Calcs
[Engineering Calcs
[Engineering Calcs -
Engineering Calcs
Engineering Calcs
Uncontrolled Emission
Factor
81.124 lb/MMscf
369.83 lb/MMscf
8470.36533 lb/MMscf
12.3672823 lb/MMscf
26.7453826 lb/MMscf
8.40395778 Ib/MMscf
16.8079156 lb/MMscf
131.88496 Ib/MMscf
3.01398417 lb/MMscf
C73 N
u_ 0c
c
c
c
c
c
cc
c
Pollutant or CAS
xON
0
U
>
Benzene
Toluene
Ethylbenzene
o
X
n -Hexane
a
H
v
N
71432
108883
100414
1330207
M
v
La
O
540841
0
0
U)
31000205
C)
m
#
cam
O
a
O
p
C
Co
to
a
U
Z
0
N
C
O
N
E
A)
T
y
O
C_
O
O
O
Co
`7
f0
Co
0
w
c
O
N 'en
w en
E
O w
Z w
You can copy each row into the permit history file for a facility -wide summary.
The first row can be copied into the Criteria tab.
The second and third rows can be copied into the HAPs tab.
Be sure to do Edit, Paste Special, Values to avoid creating links back to this PA in the history file.
Controlled Emissions
POINT
PERMIT
Description
NOx
VOC
Fug VOC
CO
008
17WE0722
Produced natural gas venting
2.0
10.2
8.9
Controlled Emissions
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Benzene
Acrolein
008
17WE0722
Produced natural gas venting
30
Uncontrolled
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Benzene
Acrolein
008
17WE0722
Produced natural gas venting
596
Uncontrolled Emissions
Reportable
HAPs
Total
HAPs
NOx
VOC
Fug VOC
CO
Reportabl
e HAPs
Total
HAPs
2.0
204.1
8.9
Toluene
Ethylbenzene
Xylene
n -Hexane
2,2,4 -Trim€
Methanol
1,3 -Butadiene
64
20
41
318
7
Toluene
Ethylbenzene
Xylene
n -Hexane
2,2,4 -Trim€
Methanol
1,3 -Butadiene
1289
405
810
6357
145
Produced Natural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer:
Oluwaseun Ogungbenle
Control Engineer:
Stephanie Spector
Review Date:
08/31/2017
Application Date:
07/10/2017
Facility Information
Permit No.
17WE0723
123 Weld
9F46
009
VRT Venting
Extraction Oil & Gas, Inc.
Hester Production Facility
SWNW Section 31, Township 7N, Range 66W
AIRs
County #
Facility #
Point #
Facility Equipment ID
Company Name:
Source Name:
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Nonattainment
VOC
Nonattainment
CO
Attainment
Potentially Located within EAC - determine attainment status of NOx and \
Source Location:
SIC:
211111
0
Elevation (feet)
x
New Permit (CP1 )
Modification
(Issuance #)
APEN
Required/Permit
Exempt
Transfer of
Ownership
APEN
Exempt/Permit
Exempt
Notes
Produced Natural Gas Venting/Flaring Preliminary Analysis
Equipment Description
This source vents natural gas from:
a well head separator
Emissions from this source are:
routed to an enclosed flare
Colorado Department of Public Health and Environment
Air Pollution Control Division
Natural gas venting from a well head separator. Emissions from this source are routed to an enclosed flare.
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
Maximum Vent Rate I 5058.2 scf/hr
RequestedThroughput (Q) 4.4 MMscf/yr
502.3 scf/hr I 0.000 MMscf/d I 0.37 MMscf/mo
% Vented I 10%
MW 46.148 lb/lb-mol
Component
mole %
MW
Ibx/Ibmol
mass fraction
E
lb/hr
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
0.702
44.01
0.309
0.007
CO2
0.4
3587
1.79
N2
2.335
28.013
0.654
0.014
N2
0.9
7594
3.80
methane
6.286
16.041
1.008
0.022
methane
1.3
11706
5.85
ethane
18.918
30.063
5.687
0.123
ethane
7.5
66027
33.01
propane
37.063
44.092
16.3418
0.354
propane
21.7
189720
94.86
isobutane
5.927
58.118
3.4447
0.075
isobutane
4.6
39991
20.00
n -butane
18.368
58.118
10.6751
0.231
n -butane
14.1
123933
61.97
isopentane
3.452
72.114
2.4894
0.054
isopentane
3.3
28900
14.45
n -pentane
4.066
72.114
2.9322
0.064
n -pentane
3.9
34041
17.02
cyclopentane
0.186
70.13
0.1304
0.003
cyclopentane
0.2
1514
0.76
n -Hexane
0.6460
86.18
0.5567
0.012
n -Hexane
0.7
6463
3.23
cyclohexane
0.0690
84.16
0.0581
0.001
cyclohexane
0.1
674
0.34
Other hexanes
0.893
86.18
0.7696
0.017
Other hexanes
1.0
8935
4.47
heptanes
0.713
100.21
0.7145
0.015
heptanes
0.9
8295
4.15
methylcyclohexane
0.082
98.19
0.0805
0.002
methylcyclohexane
0.1
935
0.47
224-TMP
0.009
114.23
0.0103
0.000
224-TMP
0.0
119
0.06
Benzene
0.055
78.12
0.0430
0.001
Benzene
0.1
499
0.25
Toluene
0.064
92.15
0.0590
0.001
Toluene
0.1
685
0.34
Ethylbenzene
0.02
106.17
0.0212
0.000
Ethylbenzene
0.0
247
0.12
Xylenes
0.031
106.17
0.0329
0.001
Xylenes
0.0
382
0.19
C8+ Heavies
0.114
114.008
0.1300
0.003
C8+ Heavies
0.2
1509
0.75
Notes
VOC mass fraction: 0.8340 Total VOC Emissions (Uncontrolled)
annual limit assuming 95% control
monthly limit assuming 95% control (lb/mo.)
223.4
11.2
1897.5
Mole %, MW, and mass fractions from Hester Farms VRT gas analysis collected 06/13/2017.
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.
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Flaring Information
Equipment Description
Flare to combust VRT gas during VRU downtime.
Manufacturer
Model
Serial Number
Gas Heating Value
Throughput
Questor
Q5000
TBD
2564
11281.6
Btu/scf
MMBtu/yr
Combustion emission factor source: AP -42: Chapter 13.5
0.068
lb NOx/MMBtu
0.31
lb CO/MMBtu
0.38
tpy NOx
1.75
tpy CO
Emissions Summary
0.4
tpy NOx
Uncontrolled/PTE
1.7
tpy CO
223.4
tpy VOC
Controlled
11.2
tpy VOC
Uncontrolled
Total (lb/yr)
Scenario A
Reportable?
Controlled Total
(Ib/yr)
Benzene
499
Yes
25
Toluene
685
Yes
34
Ethylbenzene
247
No
12
Xylenes
382
Yes
19
n -hexane
6463
Yes
323
224-TMP
119
No
6
Emission Factors for Permit
meter installed:
Uncontrolled
NOx
174.4
lb/MMscf natun
CO
794.8
lb/MMscf natun
VOC
101555
lb/MMscf natun
Benzene
113.367
lb/MMscf natun
Toluene
155.609
lb/MMscf natun
Ethylbenzene
56.0264
Ib/MMscf natur.
Xylenes
86.8409
lb/MMscf natun
n -Hexane
1468.93
lb/MMscf natun
224-TMP
27.1259
lb/MMscf natun
Controlled
NOx
174.4
lb/MMscf natun
CO
794.8
lb/MMscf natun
VOC
5078
lb/MMscf natun
Benzene
5.6683
lb/MMscf naturs
Toluene
7.7805
lb/MMscf natun
Ethylbenzene
2.8013
lb/MMscf natun
Xylenes
4.3420
lb/MMscf natun
n -Hexane
73.4463
lb/MMscf natun
224-TMP
1.3563
lb/MMscf natun
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
I gas vented
Produced Natural Gas Venting/Flaring Preliminary Analysis
Regulatory Applicability
AQCC Regulation 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
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 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions exceed one
ton per year in a nonattainment area for ozone.
Part B:
A permit is required for this source because uncontrolled VOC emissions from this
facility exceed two tons per year in a nonattainment area for ozone.
This source is subject to Section III.D.2 (Minor Source RACT) because it is located in
a nonattainment area. RACT for this source has been determined to be the use of a
flare to control emissions.
Is public comment
required?
Public Comment Required
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, XVI1.B.2
Facility Status
This facility is a synthetic minor source of NOX, VOC, CO, and HAP for Title V applicability.
This facility is a synthetic minor source of NOX and VOC for NSR applicability.
COLORADO DEPARTMENT OF PUBLIC HEALTH ENVIRONMENT
AIR POLUTION CONTROL DIVISION
INVENTORY
M
O N Is
LL O O
W N
Cl N N-
T- T- 03
C Z
a)
U
CID
NCRP =
reportable
7
)
owo
iizriz
(I)
N
as
N
43
O
Owoc'C
o
o
e
o
CC)C))C))C))C))rn
0
al
0
to
0
in
0
ul
0
al
W
I--
CL
O
N
d
685
247
M,-
01
Controlled
Requested
Emissions
(tPY)'
NI.
O
1.7
11.2
41
N
34
CV
cn
Cl
CA
M
O
Controlled
Actual
Emissions
(tPY)*
Emisison Factor Source
AP -42: Chapter 13 5
AP -42: Chapter 13.5
Engineering Calcs
Engineering Calcs
Engineering Calcs
Engineering Calcs
Engineering Calcs
Engineering Calcs
Engineering Calcs
Uncontrolled Emission
Factor
174.352 lb/MMscf
794.84 lb/MMscf
101554.857 lb/MMscf
113.366755 lb/MMscf
155.609499 lb/MMscf
56 0263852 lb/MMscf
86.8408971 lb/MMscf
1468.92559 lb/MMscf
27 1258575 lb/MMscf
O) 7
u_ 0
Pollutant or CAS
XON
O
U
VOC
Benzene
Toluene
Ethylbenzene
Xylene
a)
C
Ca
x
a)
I
C
224-TMP
71432
108883
100414
1330207
110543
540841
0
0
U)
31000205
C)
a)
C
O
a
C)
O
o
5
C
a)
<O
a
CC
0
Z
0
w
C
O
N
CO
E
C
O
C
a)
a)
O
C.
a)
as
a)
a)
U
O
U)
C
O
W
z
You can copy each row into the permit history file for a facility -wide summary.
The first row can be copied into the Criteria tab.
The second and third rows can be copied into the HAPs tab.
Be sure to do Edit, Paste Special, Values to avoid creating links back to this PA in the history file.
Controlled Emissions
POINT
PERMIT
Description
NOx
VOC
Fug VOC
CO
009
17WE0723
Produced natural gas venting
0.4
11.2
1.7
Controlled Emissions
POINT
PERMIT
Description
Produced natural gas venting
Formaldehyde
Acetaldehyde
Benzene
Acrolein
009
17WE0723
25
Uncontrolled
POINT
PERMIT
Description
Produced natural gas venting
Formaldehyde
Acetaldehyde
Benzene
Acrolein
009
17WE0723
499
Uncontrolled Emissions
Reportable
HAPs
Total
HAPs
NOx
VOC
Fug VOC
CO
Reportabl
e HAPs
Total
HAPs
0.4
223.4
1.7
Toluene
Ethylbenzene
Xylene
n -Hexane
2,2,4-TrimE
Methanol
1,3 -Butadiene
34
12
19
323
6
Toluene
Ethylbenzene
Xylene
n -Hexane
2,2,4-TrimE
Methanol
1,3 -Butadiene
685
247
382
6463
119
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE0723
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Extraction Oil Et Gas, Inc.
Hester Production Facility
123/9F46
SWNW SEC 31 T7N R66W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
VRT Venting
009
Vapor Recovery Tower (VRT) gas controlled
by an enclosed combustor during VRU
downtime.
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
Page 1 of 7
3.
s permit s
does not c
er either,
stru •
er or oper . e source
tion/modif `,peration
f is ce of t constron per
was suled commence ..s set
; (ii) . : ` " r =s cons
this perms . s issued:
ource withi N n 8 months
or the date on ich such
th in the perms •.lication
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.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
VRT Venting
009
---
---
11.3
---
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
VRT Venting
009
Emissions from the VRT are routed to an
Enclosed Flare during Vapor Recovery Unit
(VRU) downtime
VOC and HAP
COLORADO
Air Pollution Control Division
s nr �tPUb t^. o E., v_grrwr
Page 2 of 7
Process Limits
e followi
tes sh
ate s listed be . Monthly
owner or operat nd made
ber 3, Par
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
VRT Venting
009
Natural Gas Venting
4.4 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. Upon installation of the flow meter, the owner or operator shall continuously monitor and record
the volumetric flow rate of natural gas vented from VRT 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.
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 a MAINTENANCE REQUIREMENTS
14. Upon startup of this point, the owner or operator shall follow the most recent operating and
maintenance (OEM) plan and record -keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
COLORADO
Air Pollution Control Division
Page 3 of 7
to implem •:_ (Regulatio" umber 3,
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)
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. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such
time that this source becomes major solely by virtue of a relaxation in any permit condition. Any
relaxation that increases the potential to emit above the applicable Federal program threshold
will require a full review of the source as though construction had not yet commenced on the
source. The source shall not exceed the Federal program threshold until a permit is granted.
(Regulation Number 3, Parts C and D).
COLORADO
Air Pollution Control Division
Dec>::rx�v rt!�f hub'., He h n E'*,ner rner•.l
Page 4 of 7
19. permit any ts must b - -nd mad.vail •le for insion upon
rmit be rei d to a s provided in AQC egulation
; art B, .B.hip and th l 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 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:
Oluwaseun Ogungbenle
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil a Gas, Inc.
COLORADO
Air Pollution Control Division
Page 5 of 7
Notes t• -rmit Hold t the( - • permit iss
�r
1) The rmit holde to • ees for th
fee IL be issu % after t a,≥≥•ermi E. ssued.
e invure
(Regulation Number 3, Part A, Section VI.B.)
s peit. An invo for these
e permi lder sh = •ay the invoice w n 30 days
invoi .# a evocation 3 ermit.
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
VRT Venting
009
Benzene
71432
502
25
Toluene
108883
689
34
Ethylbenzene
100414
248
12
Xylenes
1330207
384
19
n -Hexane
110543
6500
325
2,2,4-
Trimethylpentane
540841
120
6
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 009:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
N0x
174.4
174.4
AP -42
CO
794.8
794.8
AP -42
V0C
101419.5
5070.97
ProMax
71432
Benzene
113.202
5.660
ProMax
108883
Toluene
155.391
7.770
ProMax
100414
Ethylbenzene
55.949
2.797
ProMax
1330207
Xylene
86.730
4.337
ProMax
110543
n -Hexane
1466.984
73.349
ProMax
'.COLORADO
Air Pollution Control Division
`L'A£it Y. .t4t V'cibl Ili Y= 13 hr tt ,me^C
Page 6 of 7
ollut
2,2
Trimethy pen ane
Uncontr • ed Contr
Emission Emission
(lb/CF) (lb/
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
The emission factors listed above are based on modeled separator temperature of 90 °F and separator
pressure of 7 psig.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: NOx, VOC, CO, n -Hexane, and total HAPs
NANSR
Synthetic Minor Source of: NOx and 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.Qpoaccess.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
G "iUaYti>x�^':t
Page 7 of 7
Gas/Liquid Separator APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and Jl f_ i 2';
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 category, there
may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options wilt not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.cotorado.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: /7 N/E�'JZZ AIRS ID Number: /z3 PC/Fig/ UQF
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Company equipment Identification: Separator Venting
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name':
Site Name:
Extraction OH & Gas, Inc.
Hester Production Facility
Site Location: SWNW Sec. 31 T7N R66W
Mailing Address:
(Include Zip Code) 370 17th Street, Suite 5300
Deny4r, Colorado
E -Mail Address': ksteDrinan@extractionog.com
Site Location
County: Weld
NAICS or SIC Code: 211111
Permit Contact: Kathy Steerman
Phone Number: 720-974-7765
tPlease 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.
365 -93. -
Form APCD-211 - Gas/Liquid Separator APEN - Rev 02/2017
j� COLORADOinM•a ircav4x:en: '. hEic
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit. and AIRS ID
Section 2- Requested Action
❑✓ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ 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 -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Separator Venting Emissions from HLP
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
i
2Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source dperation: 24 hours/day 7 days/week 52 weeks/year
c
9
l ;n
Will this equipment be operated in any NAAQS nonattainment Yes ❑ No
s' .a
area c
Is this equipment locatedkAt a stationary source that is ❑ Yes 0 No
considered a Major Source of (HAP) Emissions
/
/
04 /10 /2017
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
COLORADO
;A KUMrt£Fs'er�a
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:
❑ No
Maximum Vent
Rate:
100,000
SCF/hr
Vent Gas
Heating Value:
1 193
,
BTU/SCF
Requested:
48.2
MMSCF/year
Actual:
43.4
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
20.4996
voc
(mole %)
6.522
VOC
(Weight %)
15.65
Benzene
(mole %)
0.006
Benzene
(Weight %)
0.023
Toluene
(mole %)
0.011
Toluene
(Weight %)
0.049
Ethylbenzene
(mole %)
0.003
Ethylbenzene
(Weight %)
0.016
Xylene
(mole %)
0.006
Xylene
(Weight %)
0.031
n -Hexane
(mole %)
0.058
n -Hexane
(Weight %)
0 244
2,2,4-
%!i Trimethylpentane
t:+
0.001
2,2,4-Trimethylpentane
(Weight %)
0.006
Additional Required Infor nation:
Attach a representative gas analysis (including BTEX a n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX a n -Hexane, temperature, and
pressure)
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
ibla H.1.
Amy COLORADO
AIRS ID Number:
Permit Number:
(Leave blank unless APCD has already assigned a permit. # and AIRS ID
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.532450/-104.831694
erator
StackID No
Dischar a Height
Above Ground Level "
(Feet)
Temp
( F
Flow Rates
(ACFM)
Yelcs�. ty
(ftisec)
Q5000
—30'
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
0 Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
✓❑ Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
TBD
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
%
❑ Combustion
Device:
fP'allutants Controlled:
Rating:
Type:
VOC/HAPs
TBD
ECD
Requested Control Efficiency:
Ma it facturer Guaranteed Control Efficiency
Minimum Temperature:
Constant Pilot Light: ❑r Yes ❑ No
MMBtu/hr
Make/Model: Questor/Q5000
95
%
>99 %
Waste Gas Heat Content 1,193 Btu/scf
Pilot burner Rating
TBD MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
Ay COLORADO
4 I AyC,partaxM, PaL is
r?e,re� s ar.�:,aan�.ri
PM
Permit Number:
AIRS ID Number:
I I
[Leave blank unless APCD has already assigned a permit # and AIRS ID
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? Yes ❑ No
he overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SO„
NO„
VOC
ECD
95
CO
HAPs
ECD
95
Other:
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions 1 rom source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Controlled'
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year):,,,
Uncontrolled
(Tons/year)
SOX
NO„
0.068
Ib/MMBtu
AP -42
1.76
1.95
VOC
8.4550
lb/Mscf
Promax
183.31
9.17
203.68
10.18
CO
lb/MMBtu
AP -42
8.02
8.91
Benzene
0.0124
lb/Mscf
Promax
0.27
0.01
0.30
0.01
Toluene
0.0267
lb/Mscf
Promax
0.58
0.03
0.64
0.03
Ethylbenzene
Xylenes
'6 0084
0.0168
lb/Mscf
lb/Mscf
Promax
Promax
0.18
0.36
0.01
0.02
0.20
0.40
0.01
0.02
n -Hexane
0.1317
lb/Mscf
Promax
2.86
0.14
3.17
0.16
2,2,4-
Trimethylpentane
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 APO -211 -Gas/Liquid Separator APEN - Rev 02/2017
COLORADO
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
/7a.Edre
7/9/2017
Signature of Legally Authorized Person (not a vendor or consultant)
Kathy Steerman
Date
Air Quality Coordinator
Name (please print)
Title
Check the appropriate box to request a copy of the:
0 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)
6.1,
t
r,a
Send this form along with 052.90 to:
Colorado Departihent 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
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
a COLORADO
6 l a& =;:;.
JUL. 10 2017
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, 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 category, there
may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: (1 141 J 6-0723 AIRS ID Number: J 13 /Via/ 609
[Leave blank unless APCD has already assigned a permit % and AIRS ID]
Company equipment Identification: VRT Venting
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name':
Site Name:
Extraction Oil & Gas, Inc.
Hester Production Facility
Site Location: SWNW Sec. 31 T7N R66W
Mailing Address:
(Include Zip Code) 370 17th Street, Suite 5300
Denver, Colorado
rca
E -Mail Address': ksteerman
extractionog.com
Site Location
County: Weld
NAICS or SIC Code: 211111
Permit Contact: Kathy Steerman
Phone Number: 720-974-7765
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
325c73,
Form APCD-211 - Gas/Liquid Separator APEN - Rev 02/2017
COLORADO
AV
1
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
0 NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment El Change company name El Add point to existing permit
❑ Change permit limit Cl Transfer of ownership3 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
II Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Ft Notes:
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Venting emissions from VRT
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
04/10 /2017
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation:
N/A hours/day N/A 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
0 Yes
❑ Yes
N/A
weeks/year
❑ No
No
®Y COLORADO
n«+nr.,�m _�i r+nor
H�+Irh b En�vrnnmiinr
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:
❑ No
Maximum Vent
Rate:
5 058.2
,
SCF/hr
Vent Gas
Heating Value:
2 564
BTU/SCF
Requested:
4.4
MMSCF/year
Actual:
4.0
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
46.148
(mole
71.76
(WeigVOC
83.4
Benzene
(mole %)
0.055
Benzene
(Weight %)
0.093
Toluene
(mole %)
0.064
Toluene
(Weight %)
. 8
0 12Q
Ethylbenzene
(mole %)
0 020
Ethylbenzene
(Weight %)
0.046
Xylene
(mole %)
0.031
Xylene
(Weight %)
0.071
n -Hexane
(mole %)
0.646
n -Hexane
(Weight %)
.
1206
2,2,4-
Trimethylpentane
0.009
22,4-Trimethylpentane
,
(Weight %)
0 022
Additional Required Information:
❑ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
3 .�COLORADO
H a10L Enecu.nnni
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit g and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.532450/-104.831694
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp.
CF)"
Flow Rate
(ACFM)
Velocity
(ft/sec)
Q5000
—30'
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
0 Circular
❑ Other (describe):
Interior stack diameter (inches):
❑ Upward with obstructing raincap
TBD
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
%
❑ Combustion
Device:
Pollutants Controlled:
Rating:
Type:
VOC/HAPs
TBD
ECD
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
MMBtu/hr
Make/Model: Questor/Q5000
95 %
>99 %
Waste Gas Heat Content 2,564 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating
TBD MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
COLORADO
4 I Aviv
� Hca!�bE v e nnen
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
ribe the control equipment AND state the overall control efficiency (% reduction):
Polictant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOx
NO„
VOC
ECD
95
CO
HAPs
ECD
95
Other:
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
.
Actual Annual Emissions
Requested Annual Permit
e
Emission Limit(s)5
Uncontrolled
(Tons/year)
Controlled'
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SOx
NOx
0.068
lb/MMBtu
AP -42
0.35
0.39
VOC
101.4195
Ib/Mscf
Promax
202.22
10.11
224.69
11.23
CO
0.31
Ib/MMBtu
AP -42
1.58
1.76
Benzene
0.1132
Ib/Mscf
Promax
0.23
0.01
0.25
0.01
Toluene
0.1554
Ib/Mscf
Promax
0.31
0.02
0.34
0.02
Ethylbenzene
Xylenes
0.0867
Ib/Mscf
Promax
0.17
0.01
0.19
0.01
n -Hexane
1.467
Ib/Mscf
Promax
2.93
0.15
3.25
0.16
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
5 ��COLORADO
�N�4� ,', n.n t,
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
14"/"."1-1 avvc —
8/31/2017
Signature of Legally Authorized Person (not a vendor or consultant) Date
Kathy Steerman
Air Quality Coordinator
Name (please print)
Title
Check the appropriate box to request a copy of the:
❑✓ Draft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-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
Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
6 I AVCOLORADO
Z.f,T, nt!:n .-„ t
Hello