HomeMy WebLinkAbout20161816.tiffCOLORADO
Department of Public
Health Es 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
June 3, 2016
Dear Sir or Madam:
RECEIVED
JUN 13 2016
WELD COUNTY
COMMISSIONERS
On June 8, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for
Extraction Oil Et Gas, LLC - Silverback 36-A Tank Battery. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickentooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
R.176c.) t'tw
/4 -
RAJ, Rt..
cD- a(- aotr,
2016-1816
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Extraction Oil Et Gas, LLC - Silverback 36-A Tank Battery - Weld County
Notice Period Begins: June 8, 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: Silverback 36-A Tank Battery
Oil and gas production facility
NENW Sec. 36 T12N R62W
Weld County
The proposed project or activity is as follows: New production facility that will operate four (4) vessels
storing crude oil with emissions routed to enclosed combustors.
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 16WE0337 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
Construction Permit
Air Pollution Control Division
16WE0337
Permit number:
Date issued:
Issued to:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Extraction Oil Ft Gas, LLC
Silverback 36-A Tank Battery
123/9E67
NENW SEC 36 T12N R62W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Crude Oil
Storage
Tanks
002
Four (4) 500 barrel fixed roof storage vessels
used to store crude oil.
Enclosed combustor(s)
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.)
- ...- - 7-- Page 1 of 7
al exp'g�: if e owners operator of the source for which this permit was issued:
do '""".t "": en - ructi."" '"' odification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
Crude Oil
Storage Tanks
002
---
---
16.6
3.1
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Compliance with the annual limits for criteria pollutants shall be determined on a rolling
twelve (12) month total. By the end of each month a new twelve month total is calculated
based on the previous twelve months' data. The permit holder shall calculate actual emissions
each month and keep a compliance record on site or at a local field office with site
responsibility for Division review.
6. 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
Crude Oil
Storage Tanks
002
Enclosed Flare(s)
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
7. 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
Crude Oil
Storage Tanks
002
Crude oil throughput
200,000 barrels
COLORADO
'.. Aix Pollution Control Division
Page 2 of 7
ompli ce awitt the rdnn t throu put limits shalt be determined on a rolling twelve (12)
month-gfal:e"d'r7d' o'i""each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shalt be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
9. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
10. 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, 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.
The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shalt install and operate air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If
a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to
the Division upon request. This control requirement must be met within 90 days of the date
that the storage tank commences operation.
12. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING & MAINTENANCE REQUIREMENTS
13. Upon startup of these points, 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
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
14. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
COLORADO
Air Pollution Control Division
Page 3 of 7
15. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
16. 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 NOx per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
17. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
18. 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.
19. 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
COLORADO
Mr Pollution Control Division
Page 4 of 7
i x
reprbseltatlbns *rade by tie owner;or operator or owner or operators agents. It is valid only
"for the"elluiPrfi ri"t ariid ePe ations tietivity specifically identified on the permit.
20. 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.
21. 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.
22. 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.
23. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Bradley Eades
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil Et Gas, LLC
COLORADO
Air Pollution Control Division
Page 5 of 7
No
r
th -t+, this "s it issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(Ib/yr)
Controlled
Emissions
(lb/yr)
002
Benzene
71432
534
27
Toluene
108883
410
21
Ethylbenzene
100414
27
1
Xylenes
1330207
109
5
n -Hexane
110543
2912
146
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 002:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
---
O.O12
CDPHE Inter -Office
Communication
CO
O.O31
V0C
3.32
1.67E-1
E8P TANK V2.0
71432
Benzene
0.003
1.34E-4
108883
Toluene
0.002
1.03E-4
110543
n -Hexane
0.015
7.28E-4
Note: The controlled emissions factors for this point are based on the enclosed combustor control
efficiency of 95%. Secondary combustion emissions are based on 0.0037 lb N0x/lbV0C and 0.0094
lb CO/lb V0C per CDPHE document 3/22/2005.
COLORADO
Air Pollution Control Division
Page 6 of 7
6) Ir* accordance with cr. R S 5 7114 1 each Air Pollutant Emission Notice (APEN) associated with
fnis'permiftaCfd`P2i'i' a term&live yei7Sfrom 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:
V0C
PSD
True Minor
MACT NH
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD 1
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
it Pollution Control Division
Page 7 of 7
Colorado Air Permitting Project
Version No. 1.00
Project Details
Review Engineer:
Package a:
Received Date:
Review Start Date:
Section 01 - Facility Information
Bradley Eades
344204
2/9/2016
5/20/2016
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical Address/Location:
Type of Facility:
What industry segment?
Is this facility located in a NAAQS non -attainment area? No
If yes, for what pollutant? El Carbon Monoxide (CO) D Particulate Matter (PM)
Extraction Oil & Gas, LLC
123
9E67
Silverback 36-A Tank Battery
NENW Sec 36 T12N R62W
Exploration & Production Well Pad
Oil & Natural Gas Production & Processing
Section 02 - Emissions Units In Permit Application
❑ Ozone (NOx & VOC)
AIRs Point It
Emissions Source Type
Emissions
Control?
Permit It
Issuance It
Self Cert
Required?
Action
Engineering Remarks
002
Crude Oil Storage Tank
Yes
16WE0337
1
Yes
Permit Initial
Issuance
Section 03 - Description of Project
•
This is a single -well production facility located north of the ozone non -attainment area in Weld County. The sample analysis submitted with the
application (tank sample) indicates an API gravity of 35.2 which meets the definition of crude oil. This storage tank is subject to Regulation 7 Section
XVII.C control requirements and all emissions are routed to enclosed combustors. This permit will be issued as initial approval at a synthetic minor
facility. Subsequently this facility is applying for GP07 for crude oil loadout.
Section 04 - Public Comment Requirments
Is Public Comment Required? I Yes
If yes, why?' Other (Divison Discretion)
REQUESTING NEW SYNTHETIC MINOR LIMITS
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?' No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, explain what programs and which pollutants here:
Prevention of Significant Deterioration (PSD):
Title V Operating Permits (OP) : VOC
Non -Attainment New Source Review (NANSR): N/A
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Prevention of Significant Deterioration (PSD):
Title V Operating Permits (OP) :
Non -Attainment New Source Review (NANSR):
No
Yes
No
Crude OH Storage Tank(s) Emissions Inventory
Sefton 05- Emiabnslnvem0ry
Section 01- AdminRaYrve Information
Facmry AlRs 1D:
123 9E67 CO2
County Plant Point
Section 02 -Equipment Description Details
Derailed Emissions unit Four (4) 500 banwifixed roof cudeoi nonage vessels connected via liquid manifold.
Description:
Emission Control Deuce Two (II Clmanon 46' H4 Enclosed Combustors (ECD)
Description,
Requested Overall VOC & HAP Control
Efficiency%: 95
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions- Storage Tank(s)
Actual Throughput=
Requested Permit limit Throughput
106,782 Sanely (bbl.) per year
200,000 Barrels (bbl) per year
Potential to Emit (PTE) Throughput= 200,00) Sorrels Ibbll per year
Secondary Emissions- Combustion Devke(s)
Heat content of waste gas= : 24gg Stu/sd
Volume of waste gas emitted per BBL of liquids
produced - ::1387 scf/bbl
Actual beat content of waste gas routed to combustion device
Request heat content of waste gas routed to combustion device=
Actual Crude Oil Throughput While Emissions Controls Operating=
8,998 MMBTU per year
16,854 MMBTLJ per year
Potential to Emit (PTE) beat content of waste gas routed to combustion device= 16,854 MMBTU per year
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Pollutant
PM2.5
Crude Oil Storage Tanks
Uncontrolled ES.
(lbs/bbl Crude Oil
Throughput)
\N���b�X�\�
01 0.001 ®\"".1\`XX\ Y.
rat 0.000 0.o0oEio0 V`.N.N`�"N`
Controlled E.L.
(lbs/bbl Crude
Oil Throughput)
Control Device
Uncontrolled E.F.
(Ibs/MMbtu
waste heat
combusted)
02075
0.0075
Uncontrolled
EE(lbs/bbl
Crude 011
mrougnput)
Emissions Factor Source Chatlon
Uncontrolled
(Ib/IbVOC)
60037
02094
00006
0.6
Uncontrolled
EE (Ibs/bbl
Grade 0
Through p.
at
Emissions Factor Source Citation
Criteria Pollutants
Potential t0 Emit
Uncontrolled
(cons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
PM10
PM2.5
Non
VOC
CO
0.1
00
00
oil
1.2
332.0
332.0
16.60
177.3
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) Upns/year)
Requested Permit Limits Ilk/yr)
Uncontrolled Controlled
Actual Emissions(Ib/yrl
Uncontrolled Controlled
Benzene
Toluene
Etnybenzene
Xylem
n -Hexane
224 TMP
0.267
0.205
0.014
0.055
1.456
0.000
0.267
0.205
0.014
0.055
1.156
0.000
0.013
0.010
0.001
0.003
0.073
0.000
0.143
0.109
0.007
0029
0.777
0.007
0.005
0.000
0001
0.039
534
410
27.34
109.38
2912
26.7
20.5
1.367
5.468
145.6
285.11
218.90
14.60
5840
14.26
10.95
0.73
2.92
77.74
0.00
1554.75
Section 06- Regulatory Summary Analysis
Regulation 3, Parts Ail
Spence requires a permit
Regulation 7, Section XVII.B, C.l, C.3
Storage tank is subject to Regulation 7, Section XVII, B. C.1 & C.3, as provided
Regulation 7, Section XVII.C.2 2
Storage tank is subject to Regulation 2, Section tlm.C 2, as provided below
Regulation 6, Part A, NIPS Subpart Kb
Storage rank is not subject. to NSPS Kb
Regulation 6, Part A, NIPS Subpart 0000
Storage Tank is not sullied to NsPS 0000
Regulation B. Part E, MAR Subpart NH
Storage Tank is not subject to MAC' NH
See regulatory applicability worksheet for d
ana
106,792
2 of7
K:\PA\ E033] CP1.xlsm
Crude Oil Storage Tank(s) Emissions Inventory
Section 07 • Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions? iii Y:gu WiSiii
if yes. are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year?
if yes, the permit will contain an "Initial Compliance' tesano requirement to develop a site specific emissions fatter based on guidelines in PS Memo 14-171
Does the company use a site specific emisions factor to estimate emissions?
K • es and if there are flash emissions. are the emissions'actors based on a pressurized liouid sample of crude oil drawn at the • • •-
facility being permitted?
3yi: _::i_ u:an:l�'?E:"' ....,.
if no, the permit will contain an "Initial Compliance' testing requirement to develop a site spec.-flc emissions factor based on guidelines In PS Memo 14-03.
....tat;_._..; .;:i....................
a t: :.,
Does the company reouest a control device efficiency greater than 95%fora flare a combustion device?
R yes, the permit will contain and mtfal compliance test condition to demonstrate the destruction efficiency of the combustion device based on Inlet and outlet concentration sampling
Section Of - TachnlcafAnandellptes
Application submitted February 9, 2016 originally contained emission calculations using the State default emission factors for crude oil. Since a site -specific sample analysis was included in the application, an E&P
TANK model was run using the data from the sample collected from the LPO-Separates Skid -1440-010616 at Silverback 36-4 Pad. The model results were presented to the applicant who agreed on the newly
developed emission factor . Asa result, the OPEN was redlined to reflect the site -specific emission factors. Also, the requested permit limit was left blank on the OPEN and the apphcam communicated via email
that Extraction Oil & Gas, Lit would like a permit limn of 200.000 bbl/yr based on variable production for the first S months of production. The redlined APEN was sent to the applicant and agreed upon on
5/25/2016.
Section 09- Inventory 5CC Coding and Emissions Faders
AIRS Point II
002
Process a SCE Code
£
Uncontrolled
Emissions
Pollutant Factor Control% Units
PM10 0.01 0 lb/1,000 gallons nude oil throughput
0M2.5 0.01 0 l b/1,000 gallons crude oil throughput
NO2 0.29 0 lb/1,000 gallons crude oil throughput
VOC 79.0 95 112/1,000 gallons crude oil throughput
CO 0.7A 0 16/1,000 gallons crude oil throughput
Benzene 0.06 90 16/1,000 gallons crude oil throughput
Toluene 0.05 95 lb/1,000 gallons crude oil throughput
Ethylbenaene 0.00 95 lb/1,000 gallons crude oil throughput
Xylene 0.01 95 11,/1,000 gallons crude oil lhrougnput
n Hexane 0.39 95 16/1,000 gallons crude oil throughput
224 TMP 0.00 95 11,11,000 gallons crude oil throughput
3 of 7 k.\PA\2016\16WE0331 CP1.alsm
Crude Oil Storage Tank Regulatory Analysis Worksheet
Colorado Reanlation 3 Parts a and B. nosh and Permit Reoviremenb
ATTAINMENT
1. Are tolled actual emissions horn any criteria pollutants from this individual source greater than ] TPY {Regulation 3, Par A, section II D.1 a1?
E. Is conatrvctian date prior to 4/14/]014 and not modified after 4/14/14 Wee Memo 14-03 for additional guidance ongrandfather applicability)?)?
2a. If answer o 42 loves, is crude oh throughput less than 40,0.00 gallons per year?
3. Are tot al facility uncontrolled VCC emissions greater than 5 TPt, Nay greater than 10 TAY or CO emissions greater than 10 TOY 10egulation 3.Part n Section 11.0.3)?
'source re,,r.,a enroll
NONAlTAINM ENT
1. Are uncontrolled emissions lram any criteria pollN tshthis individual source greater than l CPT (Regulation 3, Pan A, Section II.D.1.a)?
2. Is the construction date prior to 4(14/3014 and notm modified after 4/14/14 (See PS Memo 14-03 for additional guidons, on grandfather applicability)??
2a. If answer tp 07 is yes, is the crude oil throughput less han 40,003 gallons per year?
3. Are total fachiry uncontrolled WPC emissions from the greater than 3 WY, NOY greater than 5 TOY or CO emissions greater than 5 TOY (Regulation S. Pan B. Section I LD.3)?
INa a augb lnbrm alien
Colorado Rest.Oan 7 Section XVII
1. Is this tank located at atranam isnion/storage facility]
3. Is this nude oil storage tank' located at an oil and gas exploration and production opera!ors, Well produalonfaddy ',natural gas compressor station' or natural gas processing plant?
3. Is this crude ollatorage tank aPeed rwtetorage tank]
4. Are uncontrolled anualemissioni ofth isstolagetankequal tear greater than tons per year VOC?
'Storage tank Is to hieet to tensions on l.Yrtinn XVII. BCl IC O. 33 3rnTidad
Settlpn%VII.O- General Provisions for Alt Pollution Control Equipment and Prevention of Emlisians
Section%MI.CA. Emissions Control and Monitoring Provisions
.. Record keeping Requirements
5. Otee�e cruude oil storage tank contain only /stabilized. liquids? N na. Ma following aMNonal provisions apply.
[Storage tank A subjects° Regulation 7 Section XVII C 7 as provided below
Deetion%NI,C3 • Capture and Monitoring for Storage Tanks fitted with Air Pollution Control EquIpment
40 E.G. Subpart oh. Standards of Performance for Volatile Moran Pn c Liquid n Vassal
1. iBPart
vessel capacity greater than at equal to IS cubic meters lm'li4R 00Lsl]
2. Does the storage vessel meat the Muowmg exemption In 00.11151d114p
a. Does the vessel has a design Capacityless [honor equal to 1,589.8'14 m° 1'1009 BBL{ used for petroleum or condensate stored. processed, or treated pelosto custodytranihr' as defined In 00.1115?
3. Was this omen rage tank constructed, reconstructed, or modified Dee definitions 40 CFR, 60.31 after 23.1984?
4. Does the tank meet the definition oitonage vesserin60,111p?
Doestnesmrage vessel stone a'volatile organic Rqu.d lWLis as deuced in Gawp?
6. Does the storage vessel m any one anise following additional exemptions:
a. Is storage vessel a pressure vessel designed toape•r@ in excess of 304.9 kPa{'207 poll and without emissions to thp atmosphere lrn. ohldll31l?;oe
5. The design capacity is m greater than or equal to 151 '1'950 BBL] and stores a Squid with a maximum true vapor pressure Ins than 3.5 kPa IC0.1106lbllii or
c. The design capacity is greater than or equal to 75 Mt i4?3081{ but less than 151 mtI-950 hedland stores a liquid with a maximum true vapor pressure° less than 15.0 Sha{60. 110h{h)1?
IDtorage Tank is not suhuoct to NW'S Ma
Same Rep
GO to neat I
Go to nett,
Source Pep
Go to neli
Go to then
Go to then
Source is
Go to the n
Storage Tar
Subpart A. General Provisions
360.113b- Emissions Control Standards for VOC
469113b -Tenting and rettedures
480.115b • Reporting and necordkee ping Requirements
4W.tl6b- Monitoring of Operations
4a CFR. Part 60. subpart 0000. Standards of Performance for Crude Crude and Natural Gm Production. Transmission and OiNMrtin
1. Was this crude oil storage vessel constructed, reconstructed. or modified see definitions 40CFR, 6O.2'after August 33.3011?
2. Dues this crude oil storage vessel meet the definition of "storage Vessel" per 60.5430?
3. s this crude oil storage vessel located at a facility in she onshore oiland natural gar production segment,natural gas processing segment or natural gas transmission and storage segmetoftke industry]
4. Are potential VOC emissions' from the individual Sterne vesael greater than Orequalto 6 tons per year?
Go to the n
Go to the n
Go to the n
Ho .
Subpart A. General Pr•.Hsions per 552.5425 table
460 Control Standar. for MCC
450.5413- teeing a ro>rmaaves
46D5395(3) Notification, Reporting and Remmeeenmg Requirements
660.5416)6216Icl -Co. and Clmed Vent Uystem Monitoring Requirements
iw o, Device
(No storage vessel
eprevlausspreviouslydetermined to be subject to NSP50000 due to emissions above 6 tinyear
s per yr VOC on the applicability determination [ate, it should remain ruble, to 6559. 0000 per 60.5365[6)(2)
even d potential VOC emrtsions drop below 6 tons per year]
40 GM, art 63 Subpart, ROil and Gas Productionfatilities
I Is r n aed atM3013that .5 major' for FAPsi
is she storage tank located at an oil and satmal gas production facility that meets enhe'or—e'chewing tr feria
a A !amity that processesupgrades or sores hydrocarbon '35,dcs 153.166131(2!]: 03
b..334 :ty that processes 3536333.054 3363r natural gas pro dine port at whim -aortal gas esters the natural gastransn scion and storage sourceat_gory oris delivered to ainal end users (63.'E01a113jis
3, Does te an meetthe deflnistorage of rage' .sel�"in ..611
4 Dom me ant meet me tert'Vlon of"storage vessel with potential tor fash emissions63 761,
S. 's the 5ank sybjea m conical requiremectsPartW. Suopart Kb or Subpar 00002
1St. -nh le nor winiect tn
Subpart A, General procs:onspes 46.7641al Mole
463Control Standards
463.773 Monitoring
463.779 RecordkeeDing
363.775 -Reporting
PACT Review
RAM review is required if Regulation 3 does not apply AND if the tank is in Gasman -attainment area. )(the 3436 meets both criteria. then review RAM requirements.
Disclaimer
Trs document as65's operators withd ring appfipao ly of radar requirements of the Clem Air Apt ifs gliplerteandg.feguiatirtrt MC. Nr Quety rtOrtral Commismon regulations Trts documents
a acre. Pr 330131one0 theca rt may not apply to a oertrd ta[ionhased up h instances hs document does nd[Change or subs[tute for any law
rgoat,onoo yother :egaly binding q legally enforceable rithe :ve.t3`any between ,heaa3guage olrhs 3ocunen[end the :anguage of'he Clean ArA2.il6
muremenreng regblatrons 3n4A✓p40y Control Commssronregulanon, he'aoguege Of satutearegulafmn will sar..Trol The use of ranmandabry language SUCh erd"'may
ould'and 'can 3 hle ded !a le5cribe Ar_l]nleryrelalons and re,,mendalws. Mandatcryter,nclogy such as MUSt and egure tl" oed to aescidge controlling.egur ccsunder[he
.vms oRhe Cean /,Act an2A✓ Cuasy control Comm..., "eg1133mn; but15ls 31cument 3333303 eoahfah legally hnding requirements nand oll5all
COlOMOO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS I0
Plan AIRS. IO
Facility Name
Extraction Oil & Gas LLC
123
0F67
Sllverback 36-A Tank Battery
History File Edit Date
Ozone Status
512012016
Attainment
EMISSIONS - Un ontrollod ltons per yea
EMISSIONS With Controls tons per bar
PONT
AIRS
O
PERMIT
Description
PM10
PM2.5
H25
502
NOT[
VOC
F09
VOC
CO
Total
HAN
PMIO
PM25
H25
SO2
NOx
VOC
Fog
VOC
CO
Total
HAP,
REMARKS
Prem..ACILePTOTPL
00
0.0
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
0o
New Famlty- rvo Previous Total
Pmvpus Penn/Ned Facan Iota,
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
001
GPO]
Crude oillRa0out
Sts
0.1
10.0
0
New GPoT
002
167/00337
a- 50000Crude oil Tanks
212.7
20
12
166
3.1
DI
NSW CP
0 0
B.0
0 0
0. .5
e 0
0.0
0.0
0.0
00
00
60
00
60
00
0.0
00
00
B.0
00
B.0
FACIU r TOTAL
0.0
0.0
0.0
0.0
0.0
2163
0.0
0.0
2.1
0.0
0.0
0.0
0.0
1.2
26.6
0.0
3.1
0.2
VOC: Syn Minor (OP)
Non: Minor IPSO and OP)
CO: Minor (PS0 and OP)
HAPS: Minor
HH: Minor
7777: Minor
Psrmded FacleV Total
00
00
0.0
0.0
00
2183
00
00
2.1
00
00
00
00
1.2
266
00
3.1
02
ExH.des unls exem7A frompamds/APENs
IAICHa Sell Permitted Emissions
00
00
00
00
12
266
00
3.1
PUCwm 9madeing (not) required based on I0
change in emissions)
Note 1
Total VOL Facility Emissions (pant and lugdve)
l0l Coanzeln Total Pe tutted VOC emissions poi tend fugitive)
26A
Faollly in ellpse tor GF02 because r 00 Spy
Prcleal emissions less than 25/50 @y
266
Putrom is required since pellet 16WE0337 has new synihet c minor limits for the crude oil tank
Note 2
Page6 oil
Punted 5/25/2016
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Extraction Oil & Gas LLC
County AIRS ID 123
Plant AIRS ID 9E67
Facility Name Silverback 36-A Tank Battery
Emissions - uncontrolled (Ibs per year
POINT
PERMIT Description
=ormaiuence
Asetaldedyde
Acrolein
Benzene
Toluene
Ethyl benzene
Xylenes
n -Hexane
MCOH
224 OAF
H2S
TOTAL fee
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
C
0.0
C01
GP07
Crude oil loadout
171
0.1
CO2
16WE0337
4- 50obbl Crude oil Tanks
534
410
a
`09
2912
2.0
0.0
0.0
0.0
0.0
0.0
00
0.0
0.0
0.0
CO
TOTAL (tpy)
0.0
0.0
0.0
0.3
0.2
0.0
0.1
1.5
0.0
0.0
0.0
0.0
2.1
'Total Reportable e all HAPs where uncontrolled emissions> de minimus values
Red Test: Lncontrolled e1115sions s de mimmjs
POINT PERMIT Description
Fsmaldeny0e
Acetaldehyde
Acrolem
Benzene
Toluene
Ethyl benzene
Xylenes
n -Hexane
McCH
224 LWH2S
TOTAL Spy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
2
0
0
0.0
001
GP07
Crude oil loadout
19
171
0.1
002
t6WE0337
4- 500661 Crude oil Tanks
27
21
1
5
146
0.1
0.0
0A
00
0.0
Oro
0A
0.0
0.0
0.0
0.0
TOTAL Itpyl
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.2
0.0
0.0
0.0
0.0
0.2
7
16W E0337. CP1.xlsm
5/25/2016
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Permit Number:
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization.]
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Section 01— Administrative Information
N
Extraction Oil & Gas, LLC
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370 17th Street, Suite 5300
coo
APEN Submittal for update only (Please note blank APEN's will not be accepted)
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For new or reconstructed sources, the projected startup date is:
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Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above.
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