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 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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REGION 8
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1595 Wynkoop Street
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Denver, CO   80202-1129
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Phone 800-227-8917
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		http://www.epa.gov/region080




Ref: 8P-AR					

Edward T. Winters						
Environmental, Health, and Safety Coordinator		
Cobra Oil and Gas Corporation
2201 Kell Boulevard
Wichita Falls, Texas 76308	
	
      Re: Final Part 71 Operating Permit, Permit #V-UO-002002-2017.00, Cobra Oil and Gas Corporation, Wolf Flat Tank Battery
      
Dear Mr. Winters:

This is regarding the initial 40 CFR part 71 Title V operating permit (Part 71 permit) for Cobra Oil and Gas Corporation (Cobra), Wolf Flat Tank Battery. The public comment period for the draft of this permit action ended on October 19, 2018. The EPA received one comment letter from you on       October 17, 2018. We have reviewed the comments and provided responses in "Enclosure 1  -  Response to Comments Document." We have made revisions to the permit in response to the comments.

Based on the information provided in Cobra's Part 71 permit initial application, subsequent application updates, and public comments on the draft permit, the EPA hereby issues the enclosed final initial     Part 71 permit for the Wolf Flat Tank Battery. The new permit number is V-UO-002002-2017.00.

Please review each condition carefully and note any restrictions placed on this source. Procedures for appealing this permit can be found in 40 CFR 71.11(l). A petition to the Environmental Appeals Board (EAB) must be filed within 30 days of receipt of this final permit action. The permit will be effective on November 28, 2018, provided there are no appeals filed with the EAB.


If you have any questions concerning the enclosed final permit, please contact Colin Schwartz, of my staff, at (303) 312-6043.   

							Sincerely,
                                          
							Monica Mathews-Morales
                                    Director, Air Program
                                    Office of Partnerships and Regulatory Assistance


Enclosures 

cc:	Minnie Grant, Air Coordinator, Energy, Minerals and Air, Ute Indian Tribe
	Bruce Pargeets, Director, Energy, Minerals and Air, Ute Indian Tribe (w/o enclosures)
































Enclosure 1  -  Response to Comments Document

Responses to Comments from Mr. Ed Winters of Cobra Oil and Gas Corporation on the Draft Air Quality Operating Permit for the Wolf Flat Tank Battery Pursuant to the Title V Operating Permit Program at 40 CFR Part 71.

Comments on Draft Part 71 Permit

 III. National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities - 40 CFR Part 63, Subpart HH
      
"Comment #1: Cobra requests to update the permit to include the compliance requirements for a small dehydrator under National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart HH. The current draft of the permit only reflects `Large Dehydrator' compliance requirements of NESHAP Subpart HH. The dehydrator at the facility is currently defined as a `Small Dehydrator' because actual natural gas throughput through the `Small Dehydrator' is less than 85,000 m[3]/day (3.00 MMScfd). The dehydrator will comply with the `Small Dehydrator' compliance requirements under NESHAP Subpart MACT HH until the throughput and emission levels of a `Large Dehydrator' are achieved."

EPA Response: Based on the information provided by Cobra, we have revised the permit to accurately reflect applicable requirements for the dehydrator operations at the facility, specifically to include requirements for both small and large dehydrators.


