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Home My WebLink About20162698.tiffCOLORADO Department of Public Health & Environment AUG 18 ?lL Dedicated to protecting and improving the health and environment of the people of COtorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 August 15, 2016 Dear Sir or Madam: On August 18, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Ft Gas, LLC - Downtown Habitat 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 8 Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, 1 /i ` r 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. Hickenfooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer PubIicview (SN/ +CO cc.-PLCmm/TP) PuJ CE.R/Ckl / J'rn/ CK) r 2016-2698 ih7h Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, LLC - Downtown Habitat Production Facility - Weld County Notice Period Begins: August 18, 2016 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: Downtown Habitat Production Facility Oil and gas production facility NWNE Sec 5 T5N R65W Weld County The proposed project or activity is as follows: Applicant will vent gas to a combustor from a vapor recovery tower (VRT) when the gas is unable to be re -compressed into the sales line during vapor recovery unit downtime. 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 16WE0679 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us OLORJ.DO Permit number: Date issued: Issued to: Construction Permit Air Pollution Control Division 16WE0679 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil a Gas, LLC Downtown Habitat Production Facility 123/9D66 NWNE SEC 5 T5N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRU Bypass 006 One (1) vapor recovery tower (VRT) venting emissions to a combustor during recovery unit (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 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 www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Storage Tank Version Syn Minor 2O15-1 Page 1 of 8 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. Within one hundred and eighty days (180) after issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas vented from each VRT covered by this permit. Until the flow meter is installed, the operator shall monitor and record condensate/crude produced during VRU downtime and estimate the gas flow rate based on standard cubic feet (scf) per barrel (bbl) of 130.8 scf/bbl estimated in the permit application. 5. 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.) 6. 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 7. 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 VRU Bypass 006 -- --- 15.4 2.6 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. 8. 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.) COLORADO Air Pollution Control Division Page 2 of 8 Facility Equipment ID AIRS Point Control Device Pollutants Controlled VRU Bypass 006 Enclosed Combustor VOCs and IiAPs PROCESS LIMITATIONS AND RECORDS 9. 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 VRU Bypass 006 Volume of natural gas routed to ECDs during VRU downtime 6.29 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. 10. 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 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution COLORADO ion Control Division Page 3 of 8 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 15. Upon startup of these points, 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 O&M 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 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) 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 (NO„) 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 COLORADO Air Pollution Control Division ek .,J'uM t wn_a Page 4 of 8 commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section 11.8. 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 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. COLORADO Air Pollution Control Division Page 5 of 8 DRAFT By: Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil & Gas, LLC COLORADO Air Pollution Control Division �lJ:rrlF'u 3f Koh,: ll'SC'1 (7 rr.Dor4: am Page 6 of 8 Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-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) 006 Benzene 71432 1819 91 Toluene 108883 1863 93 Ethylbenzene 100414 63 3 Xylenes 1130207 428 21 n -Hexane 110543 12477 624 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 006: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source N0x 175.16 AP 42 Chapter 13.5-1 CO --- 798.56 V0C 97598.21 4879.91 ProMax 4.0 71432 Benzene 289.32 14.46 108883 Toluene 296.35 14.81 1330207 Xylene 68.11 3.40 110543 n -Hexane 1984.53 99.22 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. Emissions are based on an estimated 5% annual VRU downtime. COLORADO Air Palliation Control Division Page 7 of 8 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, n -Hexane NANSR Synthetic Minor Source of: VOC MACT HH 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 [lotion Control Division ,ubiz Flea tr 5 inrvomm: nt Page 8 of 8 Colorado Air Permitting Project Version No. 1.00 Project Details Review Engineer: Package it: Received Date: Review Start Date: Section 01 - Facility Information Bradley Eades 348958 5/18/2016 7/21/2016 Company Name: Extraction Oil & Gas, LLC County AIRS ID: 123 Plant AIRS ID: 9D66 Facility Name: Downtown Habitat Production Facility Physical Address/Location: NWNE Sec 5 T5N R65W Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) 2 Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application AIRS Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 006 Vapor Recovery Tower (VRT) Yes 16WE0679 1 Yes Permit Initial Issuance Assuming 5% annual VRU downtime Section 03 - Description of Project This permit application is to reflect the addition of twelve new wells to an existing oil & gas production facility (most recent date of first production is March 2016). Permit 16WE0679 is a new permit for venting of natural gas captured in the Vapor Recovery Tower (VRT) that bypasses the vapor recovery unit (VRU) during an estimated 5% annual downtime of the unit. Concurrently with the issuance of this permit, Extraction is cancelling three engines (AIRS 004, 005 & 006) which have been replaced by electric engines. Also, Extraction has submitted APEN updates for condensate tanks (GP01), truck loadout (GP07), and produced water tanks (GP05). Extraction has agreed to install and operate a gas meter to directly monitor the flow of gas to the combustor to demonstrate compliance with the limits in this permit. Section 04 - Public Comment Requirments Is Public Comment Required? Yes If yes, why?' Requesting Synthetic Minor Permit 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 (PSD): Title V Operating Permits (OP) : VOC, HAPs Non -Attainment New Source Review (NANSR): VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: No Yes One (1) vapor recovery tower (VRT) controlled by enclosed combustion devices (ECDs) during downtime of the gas gathering 006 system. ECDs have a minimum control efficiency of 95%. Equipment ID: VRU Bypass Equipment Description This source vents natural gas from: Emissions from this source are: a well head separator muted to a flare Natural gas venting from a well head separator. Emissions from this source are routed to a flare. Emission Calculation Review A pressurzed liquid sample was collected from the 14567 LPO Martinez facility on 4/29/16 from the outlet of the 3 -phase separator (upstream of the VRT 62 psig/84 F). A ProMax model was run using the sampled composition and conditions at the inlet of the VRT and modeled emissions from the VRT VRT vapor to VRU" based on a liquid througpm of 2632 bbl/d. The mass fractions of the emission stream from the VRT as calcualted by ProMax are represented in the table below. The throughput used in the table below is based 5% of the total expected volumetric flow from the VRT which is being permitted as AIRS 006 for venting during VRU downtime. Calculations Emission Calculation Method EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=O*MW*Xx/C Ex = emissions of pollutant x O = 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-moll at 60F and 1 atm Throughput (0) MW 6 287 45 77 MMscf/yr lb/lb-mol 717 6940639 0.017224658 scf/hr MMscf/d mass fraction lb/hr lb/yr MY Helium 0000 000 0.00 0.00 CO2 0.006 0.53 4674.14 2.34 N2 0.003 028 2419.37 121 methane 0 024 2.09 18314.26 9.16 ethane 0.157 1364 119499.98 59.75 propane 0316 27.36 23983820 119.82 isobutane 0.109 9.43 8263836 41.32 n -butane 0.209 18.10 158523.18 79 26 isopentane 0.063 5.48 48019.41 24.01 n -pentane 0042 366 3205867 16.03 cyclopentane 0.027 2.32 2030462 10.15 n -Hexane 0 016 1.42 12478]7 6.24 cyclohexane 0.000 000 000 000 other hexanes 0000 0.00 0.00 0.00 heptanes 0.014 122 10712.80 5.36 memytcyclohexane 0000 0.00 000 0.00 224-TMP 0.001 0.06 562.95 028 Benzene 0002 0.21 181897 091 Toluene 0002 0.21 1863.16 0.93 Ethylbenzene 0000 001 62.58 0.03 Xylenes 0001 005 428.22 0.21 C8+ Heavies 0007 0.80 5237.23 282 VOC mass fraction: 0.809 Total VOC (Uncontrolled) 307.17 Cal ulated by applicant 308.8 Notes .. Mass Fractions from ProMax 4.0 modeled vapor stream VRT to VRU" based on pressunzed liquid analysis collected 4/29/2016. Emissions are based on 8760 hours of operation per year. (requested process rate is based on 438 hr/yr of VRU downtime) 15WE0679 cf1. dsm One (1) vapor recovery tower (VRT) controlled by enclosed combustion devices (ECDs) during downtime of the gas gathenng 006 system. ECDs have a minimum control efficiency of 95%. REQUESTED LIMITS Total gas from VRT: collection system downtime' Throughput during downtime: 125.740 MMscf/yr 5%3 VRU downtime) 6.287 Mscf/yr Flaring Information Equipment Description I nree (3) Enclosed comourslors to control separator gas Gunn Manufacturer TBD Model TBD Serial Number TBD Control Efficiency 95.00% Gas HHV 2576.00 Btu/scf 'Heat Throughput 16195.31 MMBtu/yr g collection system downtime. Combustion emission factor source' AP -42 Chapter 13.5-1 0.0660 llb NOXMMbtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontroled Emissions Controlled Emissions Source vOC 97598.2191Ib/MMscf 4879.91093 Ib/MMsd 306.80 tpy 15.34 tpy ProMax Nox 175.168 lb/MMscf 175.168 lb/MMscf 0.55 tpy 0.55 tpy AP -42 CO 798.560 Ib/MMsd 798.560 Ib/MMsd 2.51027 tpy 2.51 tpy AP -42 Benzene 289.322 lb/MMscf 14.46610 lb/MMsd 1,818.97 lb/yr 91 lb/yr ProMax Toluene 296.352 lb/MMsd 14.81758 lb/MMsd 1,863.16 lb/yr 93 lb/yr ProMax Ethylbenzene 9.970 lb/MMscf 0.498503 lb/MMscf 62.68 lb/yr 3 lb/yr ProMax xylenes 68.112 lb/MMscf 3.40558 lb/h4Mscf 428.22 lb/yr 21 lb/yr ProMax n -Hexane 1984.534 lb/MMsd 99.22670 Ib/MMsd 12,476.77 lb/yr 624 lb/yr ProMax 0,3100 _ lib CO/MMbtu 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, 2014'2 Yes This separator is subject to Reg 7. Section XVI I.G. and control requirements of Reg 7. Section XVII.B.2 NOTES: ••Confirmed with applcant that two (2) wellserviced by this VRT (separator) began producing after August 1, 2014. (.Therefore this equlpmpent is currently subject to XVII.G. control requirements. ••Confirmed with applicant that Extraction Oil & Gas has agreed to install and operate a flow meter to measure the volume of gas directed to the combustor. The meter will be located such that it only measures the gas going to the combustor from the VRT. "Applicant requested 98% control originally, however applicant eventually requested to maintain 95% control to avoid additional testing requirements. "An initial testing requirement for gas compoisition from the VRT is not being requited. The emissions are based on a press urized liquid sample which is an acceptable method for modeling emissions from VRTs. "Applicant reviewed permit prior to public notice and requested no changes to the draft permit 18/12/2016). 16W E0679.CP1.xlsm COLORADO DEPARTMENT OF PUBUC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS in pant AIRS ID Facility Name Extraction Orl B Gas, LLD 123 9068 Downtown Pad Hbtty File Edit Date Ozone Status 1113012015 Non-Analnmenl EMISSIONS -Uncontrolled (tons serves EMISSIONS With Controls( tons Der POINT AIRS ID PERMIT Description PM10 PM2.5 H25 SO2 NOa VOC Fug VOC CO Total HAPs PM10 PM2.5 H15 502 NON VOC Fog VOC CO Total HMO REMARKS Previous FACILITY TOTAL Powono Pennied P0084 total 001 GP01 Condensate tanks r 2499 5 0 0 9 39 0 24 02 Sleapeabc EFe updated uplatethronnput to 002 GPO] Loadout 530 09 100 00 Update tMou0Nput to reflect addeon of 10 wells 003 GPo5 Produced Water Tat 125 14 100 Cl Update throughout to reflect addbon orl0walla 006 I8WE06]9 VRU Byras(VRT venting during VRU downtime) 00 3068 25 03 05 153 25 04 New syn minor source 0 0 90 0 0 90 00 90 90 90 00 O0 00 00 FACILITY TOTAL 0.0 0.0 0.0 0.0 0.6 622.4 0.0 2.5 15.6 0.0 0.0 0.0 0.0 1.5 74.3 0.0 4.0 08 VOC'. Son Minor IPSOMANSR and OP) NO. Syn Minor (P5mNANSR and OP) CO: Son Minor (PSO and OP) HMS: Syn Minor n-Heaane.Total HH: arHH. area source regs NA 7777:NA Permitted FacAv Total 00 0.0 00 00 0.6 6224 00 25 156 00 00 00 00 15 )4.3 00 4.9 08 Excludes anis exempt frompwmdofAPENn (D)CIIa gem Permaled missions 00 00 00 00 15 74 00 4.9 Pubcom 3nwdtling (not( renulrec eased on 10 change in emission) Note1 Total VOC Facility 0lons(point and hob ssions Loa t end lupdael w (Cl Chanin Total Pe mated VOC emissions e) Facility eligible for GP03 because P PO too Pralect emissions lees than 25150 PH 774 43 ]I 3 Note2 Page 4 o(5 Printed B/12/2016 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPS Company Name Extraction Oil 8. Gas, LLC County AIRS I0 123 Plant AIRS ID 9D66 Facility Name Downtown Pad Emissions - uncontrolled (Ibs per year POINT PERMIT Descrption rormedehyae Acetaldehyde Acrolein Benzene Toluene Ethyibenzene Xylenes n -Hexane McOH 224 TARP H25 TOTAL lied Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 a 0 0 0 0.0 001 GPO1 Condensate tanks 944 854 7821 315 5.0 002 GP07 Loadout 184 1618 0.9 003 GP05 Produced Water Tanks 676 2124 1.4 0.0 0.0 006 16WE0679 VRU Bypass (VRT venting during VRU downtime) 1819 1863 53 428 124]] 8.3 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL(tpy) 0.0 0.0 0.0 1.8 1.4 0.0 0.2 12.0 0.0 0.2 0.0 0.0 15.6 'Total Reportable = all HAPs where uncontrolled emissions> de minimus values Ree Text uncontrolled emissions= 0eminimus Emissions with controls (Ibs per year POINT PERMIT Description Formaidehyce Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes ndelexane McOH 224 TrkP H2S TOTAL Opyl Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 Condensate tanks 47 43 391 16 02 002 GPO] Loadout 9 81 00 003 GP05 Produced Water Tanks 34 106 0.1 00 0.0 006 16WE0679 VRU Bypass (VRT venting during VRU downtime) 91 93 3 21 624 0.4 0.0 00 0.0 0.0 0.0 00 TOTALLtpy) 0.0 0.0 0.0 0.1 0.1 0.0 0.0 0.6 0.0 0.0 0.0 0.0 0.6 5 16WE0679. CP 1.xlsm 8/12/2016 M [[save blank unless APCD has already as nee N [Provide Facility Equipment ID to m nested Action (check applicable request boxes) Section 02 — Re Section 01 — Administrative Information L Request to limit IIAPs with a Federally enforceable limit on PTE C 0 O 'v o De C c o C n w 0 - E E - v o z O o0 c a c 0 y E s U -E -2 • ° o 0 n o c o Cl 4 O at O a, up E• 2 r w C 9 ,C Z o y a) d ro t Q .6 n a C C C ❑ ❑ O h 9 6 C 9 Q � Z 9 an N — a c aO. co O V ti v) o a .� 0 U Q O U G z� N Extraction Oil & Gas, LLC Downtown Habitat Production Facility Denver, CO Phone Number: (720) 481-2372 c Fax Number: Section 03 — General Information N For new or reconstructed sources, the projected startup date is: n device as needed o `o cv u.zo Y 3 aO y 00 F N _co O C av Z U o a a Q L n v O G .E 00O E" °. 0r0 c L 0 N z ro 3 E E > V ag • — 3 C c > 7, 6.o O C` o • ` 0 • C C h^ tc O at E o -a r W .. c, O Z L E. a E:. 'O 00 X 0 he i Q N 0 O Re M t S g a, V .O CJ •'0 G o m COLa a o 00 5 3 s` w E 'y n' 0 - O >© O '� v 3 DL c C° S p, E E dl o f� 3 r s ! g¢ a E n— U m o U y n „`o, OC i-O u 0 c o s 9 h r U v 0, Co ,� 7RO° d E z U Oo ie Op C a 4U O. a. Ox v, tr. er r M P a 0 re, o CL g - -- m uinment Information W Section 04 — Processin J O 5 O V > S C V Y Y ▪ to �0 � F c0 y Lie .2 v c. A o m C. y �. • ,c 7,3 O. " v aoi OLD z O U � p, O 9 9 E h aCi O ie tip p Q a) A C -. O .C • 3 U a u E o LIDDED N CL vd Ct a C E o S v 5 Process Parameters: O • V O 0 — e v L) = o C r F O 0 xe N O ® ❑ O_ N 6 N v m E 0 00 Molecular W re 0 re �e y c teE a 0 .. p E o • E CC) 5 X : 0O m• z Of F N w qua FORM APCD-211 Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Section 05 — Stack Information (Combustion stacks must be listed here) z 12) n�0 • ae 0' Google Earth N b 0 -104.682996° C0o 7 N v N 00 C o 0 - E° F It El a o0 t J ❑ • N O a r G O ✓ n _V t o A O r o ' - • co nC _ 0 0 O C O V � • u Section 07 — Control Device Information Section 08 - Emissions Inventory Information & Emission Control Information 0 N N 00 0 m a 021 a 0 0 o t 0 Z el d < ) W L r O W 2� Ad E 5 p -o 0 C '0 W C e c O m i Ej V 5 U O 37, o a E 0 y o n cc u cc Estimation Method or Emission Factor Source ProMax Calc t4 a ¢ ti a ¢ ¢ Z ProM ax Cale II ProM ax Cale ProMax Calc ProMax Cale ProMax Cale Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) -1 �. 4D V en tai w N a - _ N .-. Q> c . 0 0 F m O NI I to It m--- N Z P O O. O O O N O N O Actual Calendar Year Emissions° Controlled (Tons/Year) 2.87 o. N= ¢ Z EEEE .C E a .C 6E t`o .C a .C E a` o o Uncontrolled (Tons/Year) '0 ^O^ N e Z 0er. O O 0 O O O N N Emission Factor Units v. V) 7.0 Lz CA Li. V> 7 k. h 7 {r. h 7 LT. h 7 Ib/MMSCF. Li. h i Li. h 7 Uncontrolled Basis r, r^, T_ ce goccaz c f `y Fr... -`1 , co C M11 °' . b,^N r , -- Control Efficiency (% Reduction) O a ¢ Z O a O 0 O a 00 0 O 0 Overall Collection Efficiency e Ca ¢ 2 0 0 0 0 0 0 0 0 0 0 Control Device Description cc 7_ 0 0 h I cc 9 0_ ECD ¢ Z 0 IUsI ❑ LUr7 0 LL0 ECD ECD m 0. U x x o o= 0] O F 9 see c em c a c 0 e. y 0 C Cd C 0 ted with this application is complete, true and correct. U )nn-APCD-21 I C. G a co co a. c En G % O R 0 d N 0 -c cc v 0 v E '0 0 Z N N 0. FORM APCD-211 Hello