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Home My WebLink About20203885.tiffCOLORADO Department of Public Health Er Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 December 21, 2020 Dear Sir or Madam: RECEIVED DEC 2 8 2020 WELD COUNTY COMMISSIONERS On December 22, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - RBF Stromberger 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 Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe Jared Potis, Governor I Jill Hunsaker Ryan, MPH, Executive Director eub(;c ReN euJ of/O2( c c : pLC -P) HL(os/ral PO(3-ra/ER/cH kw), oG(smi of/a5/2.l Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Ft Gas, Inc. - RBF Stromberger Production Facility - Weld County Notice Period Begins: December 22, 2020 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: RBF Stromberger Production Facility Exploration Ft Production Well Pad SENE SEC 22 T6N R67W Weld County The proposed project or activity is as follows: Applicant proposes the modification of the permits 18WE0137, 18WE0139, and 18WE0140, to reduce throughputs and subsequently reduce VOC emissions below new major source threshold. 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 18WE0137 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 wilt receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.Rov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co,us • Send comments to our mailing address: Christian Lesniak Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public Health B Environment Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health b Environment CONSTRUCTION PERMIT 18WE0137 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 2 Extraction Oil 8t Gas, Inc. RBF/Stromberger Production Facility 123/9F9B SENE SEC 22 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Condensate Tanks 004 Eight (8) 400 -barrel fixed -roof storage vessels used to store condensate 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. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify (Regulation 3, Part B, Section III.G.5). EMISSION LIMITATIONS AND RECORDS 2. 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 Condensate Tanks 004 -- -- 3.5 -- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Air Pollution Control Division > Public H N t ., ..i.o r elt Page 1 of 7 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. 3. 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 Condensate Tanks 004 Enclosed Flare V0C and HAP PROCESS LIMITATIONS AND RECORDS 4. 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 Condensate Tanks 004 Condensate throughput 1,138,324 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 5. 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) 6. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 7. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply with all applicable requirements of Section I and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for storage tanks; and COLORADO Air Pollution Control Division Page 2 of 7 • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) (State only enforceable) 8. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.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 II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; 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 schedule in Regulation Number 7, Part D, Section II.B.2.d. 9. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must 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 March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.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. 10. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 11. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division -approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING £t MAINTENANCE REQUIREMENTS 12. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OM) 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 atM 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 13. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 14. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 15. All previous versions of this permit are cancelled upon issuance of this permit. COLORADO Air Pollution Control Division Page 3 of 7 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 (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t 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 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. 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. !COLORADO Air Pollution Control Division Page 4 of 7 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: Christian Lesniak Permit Engineer Permit History Issuance Date Description Issuance 1 December 3, 2018 Issued to Extraction Oil a Gas, Inc. Issuance 2 This Issuance Issued as Final Approval to Extraction Oil a Gas, Inc. Reduction of throughput. Updating regulatory references COLORADO I Air Pollution Control Division Page 5 of 7 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-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 004 Benzene 71432 239 12 Toluene 108883 205 10 Ethylbenzene 100414 11 1 Xylenes 1330207 68 3 n -Hexane 110543 2117 106 2,2,4- Trimethylpentane 540841 23 1 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 004: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source V0C 0.123 6.16E-03 Promax simulation based on site specific sample 71432 Benzene 2.10E-04 1.05E-05 108883 Toluene 1.80E-04 9.00E-06 110543 n -Hexane 1.86E-03 9.30E-05 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. 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 COLORADO Air Pollution Control Division Page 6 of 7 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 Air Pollution Control Division Page 7 of 7 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer 'Christian Lesniak Package # 416197 Received Date 9/5/2019 Review Start Date 11/20/2020 Section 01 - Facility Information Company Name County AIRS ID Plant AIRS ID Facility Name Physical Address/Location County Type of Facility Extraction Oil & Gas, Inc 123 9F98 RBF/Stromberger Production Facility SENE quadrant of Section 22 Township 6N, Range 67W Weld County ,Exploration & Production Well Pad T' - What Industry segment? OIL & Natural Gas Production & Processing I Is this facility located in a NAAQS non attainment area? yes J! If yes for what pollutant? ❑ Carbon Monoxide (CO) W ParbMate Matter (PM) Section 02 - Emissions Units In Permit Application El Quadrant Section Township Range SENE 22 6N 67 Orono (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Controls Permit N Issuance # Self Cert Required? Action Engineering Remarks J 001 Natural Gas RICE COMP 001 No Action Requested Not processed here 002 Natural Gas RICE COMP 002 No Action Requested Not processed here 003 Natural Gas RICE COMP 003 No Action Requested Not processed here 004 Condensate Tank Condensate Tanks yes 18WE0137 2 yes ' Permit Modification Source has self certified Issued as FA 005 _ -Produced Water Tank Produced Water Tanks yes , 18WE0138 1 yes No Action Requested Not processed here 006 Separator Venting VRT Separator Venting yes 18WE0139 2 ` yes Permit Modification Not processed here 007 Separator Venting LP Separator Venting yes 18WE0140 ' 2 ,yes Permit Modification Not processed here Section 03 - Description of Project Modification VRT and HLP separators are controlled by VRUs, and thermal oxidizers when VRUs are not available Condensate and water tanks are controlled by enclosed flares Tanks are connected directly to oil sales line, so no loadout emissions occur Reduction in throughputs to bring facility under 50 tpy threshold to retain syn minor status r �f ' t Section 04 Public Comment Requirements Is Public Comment Required?__ yes If yes, why? 'Requesting Synthetic Minor Permit _ y Section 05 - Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? no , z } 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, indicate programs and which pollutants Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non Attainment New Source Review (NANSR) Is this stationary source a major source? no SO2 NOx CO� VOC PM25 PM10 TSP HAPs D® OO O E1 O ❑❑ ❑ O J Condensate Storage Tanks) Emissions Inventory 004 Condensate Tank !Facility AIRs ID: 123 9F98 004 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Eight (8) 400 -bbl condensate storage tanks connected via liquid manifold Enclosed flares 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 948,604 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 948,604 Barrels (bbl) per year Requested Permit Limit Throughput = 1,138,324 Barrels (bbl) per year Requested Monthly Throughput = Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput= Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = 0.5055 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 1,365,989 2507 Barrels (bbl) per year Btu/scf Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? yes MMBTU per year MMBTU per year MMBTU per year Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Condensate Throughput) (Condensate Throughput) VOC 0.1232 Site Specific E.F. (includes flash) Benzene 2.10E-04 Site Specific E.F. (includes flash) Toluene 1.80E-04 Site Specific E.F. (includes flash) Ethylbenzene 1.00E-05 Site Specific E.F. (includes flash) Xylene 6.00E-05 Site Specific E.F. (includes flash) n -Hexane 1.86E-03 Site Specific E.F. (includes flash) 224 TMP 2.00E-05 Site Specific E.F. (includes flash) Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (waste heat combusted) (Condensate Throughput) PM10 PM2.5 NOx 0.0680 AP -42 Chapter 13.5 Industrial Flares (NOx) CO 0.31.00 AP -42 Chapter 13.5 Industrial Flares (CO) Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) VOC PM10 PM2.5 NOx CO Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene ; Xylene n -Hexane 224 TMP Section 06 - Re ug lato Summa Analysis Regulation 3, Parts A, B Regulation 7, Section XII.C, D, E, F Regulation 7, Section XII.G, C Regulation 7, Section XVII.B, C.1, C.3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Regulation 6, Part A, NSPS Subpart OOOO Regulation 8, Part E, MACT Subpart HH (See regulatory applicability worksheet for detailed analysis) 2of4 D:\Take Home\Current Projects\416197 (Extraction)\18WE0137.CP2 Condensate Storage Tank(s) Emissions Inventory Section 07 Initial and Penodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? ino If yes are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons V0C per year? rNo If yes the permit will contain an Initial Compliance testing requirement to develop a site specific emissions factor based on guidelines in P5 Memo 0501 Does the company use a srte specific emissions factor to estimate emissions? If yes and if there are flash emissions are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? The: sample should be considered representative which generally means site specific and ( . collected within one year of the application received date However if the facility has not been modified (e g no new wells brought on line) then it may be appropriate to use an older site specific sample Lyn_ If no the permit will contain an Initial Compliance testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05 01 Does the company request a control device efficiency greater than 955, for a flare or combustion device? trio. If yes the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling 1 Section 08 Technical Analysis Notes __ _ _ _ No change in emission factor Reduction in throughput From previous issuance Pressurized liquid sample collected from RBG Stromberger (site-specific)1/19/2018 I verified the oil temp pressure and composition input m ProMax simulation and it agrees with the sample Promax simulation also included a bubble point analysis to verify sample integrity Section 09 Inventory SCC Coding and Emissions Factors I Uncontrolled Emissions AIRS Point it Process q SCC Code Pollutant Factor Control A Units 004 01 40r0Cf1:1 Fixed Roof Tank Condenxa]e,Working+breathino+?lashmglosses*, „,,, PM10 000 0 Ib/1000 gallons condensate throughput PM25 000 0 lb/1000 gallons condensate throughput N0x 000 0 16/1000 gallons condensate throughput i V0C 29 95 16/1000 gallons condensate throughput CO 001 0 Ib/1000 gallons condensate throughput .-- Benzene 001 95 16/1000 gallons condensate throughput Toluene 000 95 Ib/1000 gallons condensate throughput Ethylbenzene 000 95 Ib/1000 gallons condensate throughput Xylene 000 95 Ib/1000 gallons condensate throughput n Hexane 004 95 16/1000 gallons condensate throughput 224 TMP 0 00 95 Ib/1000 gallons condensate throughput 3 of 4 D \Take Home \Current Projects \416197 (Extraction)\18WE0137 CP2 Condensate Tank Regulatory Analysis Worksheet Colorado ReguladOn 3 Part A and B - APEN and Perrnit Requirements NON-ALLAINI11 f�T 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2.002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? ye: Colorado Regulation 7. SSctiortXll.C-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas dnp station? 3. Is this storage tank located upstream of a natural gas processing plant? Yes Section XII.C.1 --General Requirements for Air Pollution Control Equipment - Prevention of leakage Section XII.C.2 • Emission Estimation Procedures Section XII.D Emissions Control Requirements Section XII.E Monitoring Section XII.F Recordkeepmg and Reporting Colorado Regulation 7, sectfon_)(11 _G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? yr. Section XII.G.2 • Emissions Control Requirements Section XII.C.1 General Requirements for Air Pollution Control Equipment - Prevention of leakage Section XII.C.2 Emission Estimation Procedures Colorado Regulation 7. Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility`, natural gas compressor station' or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? YfS VM Section XV11.8 -- General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Pmvisions Section XVII.C.3 Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? Section XVII.C.2 • Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 Cat,_Part 60, Subpa(00A Standards of_Performance for Volatile Organic LiquidStorage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) [-472 B13tsj? 1 40 CFR. Pmt 60. Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production. Transmission and Distribution 1. ts this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstnicted, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September _8, 2015? 40 CFR, Part 63, Subpart MALT NH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(aX3))? 2. Is the tank located at a facility that is major' for HAPs? no Source Reg Go to next Source Reg Continue - Continue - Source is St Continue - Storage Tai Continue - Go to the n Go to the n Source is Si 'Continue - Storage Tai RACT Review RACT review Is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act its implementing regulabons, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situatron based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable In the event of any conflict between the language of this document and the language of the Clean Air Act.. its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend." "may," "should." and "can." is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to descnbe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally 5inding requirements in and of itself. Continue - no 1 Storage Tai Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health 5 Environment CONSTRUCTION PERMIT 18WE0139 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 2 Extraction Oil Et Gas, Inc. RBF/Stromberger Production Facility 123/9F9B SENE SEC 22 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT Separator Venting 006 Emissions from Vapor Recovery Tower (VRT) during VRU bypass conditions Questor Q5000 Enclosed Combustion Device 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 This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify (Regulation 3, Part B, Section III.G.5). EMISSION LIMITATIONS AND RECORDS 2. 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 'COLORADO Air Pollution Control Division Page 1 of 7 VRT Separator Venting 006 -- -- 1.7 -- 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. 3. 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 Separator Venting 006 Emissions from the VRT are routed to an enclosed combustion device during Vapor Recovery Unit (VRU) bypass VOC and HAP PROCESS LIMITATIONS AND RECORDS 4. 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 VRT Separator Venting 006 Natural gas routed to enclosed combustion device 0.71 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. 5. 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 6. 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) COLORADO Air Pollution Control Division Page 2 of 7 7. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 8. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section 11.6.2. 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 II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; 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 schedule in Regulation Number 7, Part D, Section II.B.2.d. 9. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. 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 commencement of operation 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. 10. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado - must submit a single annual report that includes actual emissions and specified information in the Division -approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Et MAINTENANCE REQUIREMENTS 11. 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 0£tM 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 12. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 13. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 14._ All previous versions of this permit are cancelled upon issuance of this permit. 15. 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: COLORADO Air Pollution Control Division Page 3 of 7 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,t 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 16. 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. 17. 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. 18. 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. 19. 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. 20. 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 COLORADO Air Pollution Control Division Page 4 of 7 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. 21. 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. 22. 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: Christian Lesniak Permit Engineer Permit Histo Issuance Date Description Issuance 1 December 3, 2018 Issued to Extraction Oil a Gas, Inc. Issuance 2 This Issuance Issued as Final Approval to Extraction Oil Et Gas, Inc. Reduction of throughput. Updating regulatory references. Reduction of requested control efficiency from 98% to 95%. Removing requirement to stack test per reduction of control efficiency. Correction of control device from "thermal oxidizer" to enclosed combustion device. [COLORADO Air Pollution Control Division Page 5 of 7 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-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 (Ib/yr) Controlled Emissions (Ib/yr) VRT Separator Venting 006 Benzene 71432 205 10 Toluene 108883 175 9 Ethylbenzene 100414 13 1 Xylenes 1330207 49 2 n -Hexane 110543 1584 79 2,2,4- Trimethylpentane 540841 1 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportab a 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 (Ib/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 169.93 169.93 AP -42 Chapter 13.5 Industrial Flares CO 774.69 774.69 VOC 94,090 1881.8 Site specific extended gas analysis 71432 Benzene 289.00 5.78 108883 Toluene 246.00 4.92 1330207 Xylene 69.00 1.38 110543 n -Hexane 2231.0 44.62 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. COLORADO Air Pollution Control Division Page 6 of 7 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: VOC, n -hexane NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 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 Permlttmg Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer Package # Received Date Review Start Date Christian Lesniak 416197 12/9/2020 11/20/2020, Section OS - Facility Information Company Name Extraction Oil &Gas Inc County AIRS ID 123 Plant AIRS ID ' Facility Name Physical Address/Location County Type of Facility Exploration & Production Well Pad �- _ e— -'1Y What industry segment? Oil & Natural Gas Production & Processing .. Is this facility located in a NAAQS non attainment area..?`_ ,.� yes 2 „is__ 4"...1 If yes for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) 9F96 RBF/Stromberger Production Facility SENE quadrant of Section 22 Township 6N Range 67W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range SENE r22 6N 67 Ozone (NOx a. VOC) AIRS Point # 1 Emissions Source Type Equipment Name Emissions Control? Permit ft Issuance ti Self Cert Required? Action Engineering _ Remarks v '-001q" ,'Natural Gas RICE COMP 001 " ' =� No Action Requested Not processed here - 002 : NaturalGas`RICE-r COMP 002, NoActiorh, Requested ` Not processed here , 003 _ / < . Natural Gas RICE` COMP 003 - No Action Requested Not processed here s J , ' 004 _ +- ,, ' _ CondensateTank, , Condensate Tanks -` yes ,r 18WE0137 2 ` ,, no < Permit- ' Modification Not processed here �„ 005 - _ ;,-,Produced Water Tank ` Produced Water Tanks , yes - 18WE0138 t _ ---",No Action, Requested Not processed here , 006 , ,' - -Separator Venting VRT Separator Venting _ ,yes-- 18WE0139 2 = - _ — -no= � ' -- F' _f- - Permit = Modification ' Source has nothing left to self certify to - Issued as FA 007 - , T Separator Venting- LP Separator Venting _ _ „ yes s 18WE0140 2 no Permit, Modification Not processed here ' Section 03 - Description of Project rModification VRT and HLP separators are controlled by VRUs ECD when VRUs are not available Condensate and water tanks are controlled by enclosed flares Tanks are connected directly to oil sale"s line, so no loadout emissions occur { Reduction innthroughputs to bring facility under 50 tpy threshold to retain syn minor status" i 1 j Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? `Requesting Synthetic 14imor,P re mite Section 05 Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? no If yes for what pollutants? , If yes, attach a copy of Technical Services Unit modeling results summary -yes Section 06 Facility -Wide Stationary Source Classification 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) Is this stationary source a major source? 502 NOx CO VOC PM25 PM10 TSP HAPs ❑ ❑ ❑ ❑ ❑ O i Separator Venting Emissions inventory 006 Separator Venting 'Facility AIRS ID: 123 County 9F9B Plant 006 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: (1) Vapor Recovery Tower (VRT) Emission Control Device Description: Thermal oxidizer during VRU bypass conditions Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Natural Gas Vented Gas meter Yes, meter is currently installed and operational Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 059 MMscf per year Requested Permit Limit Throughput = 0.71 MMscf per year Requested Monthly Throughput = Mlvlscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: MMscf per year Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Section 04 - Emissions Factors & Methodologies Description 2287 Btu/scf MW and composition of gas from site -specific VRT gas sample, collected 1/19/2018 at 6.9 psig and 56 deg F. MW lb/lb mol Displacement Equation Ex=Q*MW*Xx/C Weight Helium u.^'' CO2 I N2 0.1:1 methane ethane 13.31. propane 31. isobutane 6.5, n -butane 20.36 isopentane 5.36 n -pentane cyc opentane •. u..;i. n -Hexane 191 cyclohexane 0.51 Other hexanes 3..1 heptanes methylcyclohexane t' 224-TMP Benzene U.2 Toluene 0.21 Ethylbenzene is ' Xylenes 0.0. C8+ Heavies 0.93 Total VOC Wt % Emission Factors Separator Venting Emission Factor Source Pollutant Uncontrolled Controlled (lb/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Pollutant Primary Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 SOx NOx 0.0680 CO - Operator Calculations Uncontrolled (Ib/Mscf) % differnce from (Gas Throughput) engineer talcs 93.289 -0.13% 0.289 -0.05% 0.246 -0.07% 0.018 -0.51% 0.069 0.19% 2.231 -0.12% 0.001232 -4.05% D:\Take Home\Current Projects\416197 (Extraction)\18WE0139.CP2 Separator Venting Emissions Inventory Section OS Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) '' PM10 PM2 5 SOx NOx VOC CO 0 00 0 00 0 CO 0 00 0 CO 0 0 00 0 00 0 00 0 00 0 09 0 _ 0 00 0 00 0 CO 0 00 0 00 0 0 06 0 05 0 05 0 06 0 06 9 33 l0 27 56 1 38 33 12 1 7 28_ 0 25 0 21 0 21 0 25 0 25 w3 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (_Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year_) (_Ibs/year) Benzene Toluene Ethylbenzene Xylene n Hexane 224 TM P 205 171 9 205 10 175 145 7 175 9 13 11 1 13 1 49 41 Z 49 _ 1586 1718 66 1584 79 1 1 0 1 0 Section 06 Regulatory Summary Analysis Regulation 3 Parts A B Regulation 7 Section XVII B G Regulation 7 Section XVII B 2 e (See regulatory applicability worksheet for detailed analysis) Sour, requires a aernut Source is subject is Reeulation 7 Section XVII 0 2 G Tie con rol device or this sera ator is no subiert to P.4ulauon 7 Section nil B 2 e n Section 07 Initial and Penodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions, Yes Are facility wide permitted emissions of V0C greater than or equal to 90 tons per year? Ro Will the operator have a meter installed and operational upon startup of this point, res Does the company request a control device efficiency greater than 95/ for a flare or combustion device? If yes the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section OS Technical Analysis Notes _ _ _ _ _ _ _ _ _ _ T i Emissions based on VRT gas analysis collected from RBF Stmmberger 1/19/2018 Source has not requested a modification to the emission factor The analysis is site specific and collected within one year of ongmal application submittal I I therefore there are no initial sampling requirements t I Source initially asked for 979' control for this flare however submitted an APEN redline to bong requested efficiency to 95% Source also had called the control device a thermal oxidizer in the previous permit issuance I have corrected this to Enclosed Combustion Device Questor 05000 As source is no longer requesting over 959' control I have removed the stack testing requirement As the stack testing requirement was the only outstanding part of the self @ certification I am now issuingthis permit as Final Approval f Section 09 Inventory SCC Coding and Emissions Factors AIRS Point p 006 Process p KC Code 01 3 10 001 60 Flares J Uncontrolled Emissions Pollutant Factor Control 9' Units PM10 000 0 Ib/MMSCF PM25 000 0 In/MMSCF 5Ox 000 0 Ib/YIMSCF NOx 1555 52 0 Ib/MMSCF VOC 93.108 74 e5 Ib/MMSCF CO 709 97 0 Ib/MMSCF Benzene 26914 95 Ib/MMSCF Toluene 24618 95 II /MIv15CF Ethylbenzene 18 09 95 Ib/MMSCF Xylene ES 37 95 Ib/MI.ISCF n Hexane 2233 71 95 Ib/MMSCF 224 TMP 128 95 In/MMSCF 3 of 4 D \Take Home \Current Projects \416197 (Extraction)\18W E0139 CP2 Separator Venting Regulatory Analysis Worksheet Colorado ReXulation 3 Parts A and B - APEN and Permit Requirements NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Sectioi II.D.S.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Ves Colorado Regulation 7, Section XVII I. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? yes Section XVII.B.2 - General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? Section XVII.B.2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law. regulation, or any other legally binding requirement and is not legally enforceable In the event of any conflict between the language of this document and the language of the Clean Air Act., its implementing regulations. and Air Quality Control Commission regulations. the language of the statute or regulation will control The use of non -mandatory language such as "recommend." 'may.' "should," and 'can, "is intended to describe APCD interpretations and recommendations Mandatory terminology such as "must" and 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not estabFsh legally binding requirements in and of itself yes Source Req Source Req Source is st The contro Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health & Environment CONSTRUCTION PERMIT 18WE0140 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 2 Extraction Oil Et Gas, Inc. RBF/Stromberger Production Facility 123/9F96 SENE SEC 22 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LP Separator Venting 007 Emissions from low pressure (LP) separator during VRU bypass conditions Questor Q5000 Enclosed Combustion Device 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 This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify (Regulation 3, Part B, Section III.G.5). EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO,t VOC CO COLORADO Aix Pollution Control Division r,.artrn¢ a Page 1 of 7 LP Separator Venting 007 -- -- 11.8 2.4 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. 3. 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 LP Separator Venting 007 Emissions from the LP separator are routed to an enclosed combustion device during Vapor Recovery Unit (VRU) bypass V0C and HAP PROCESS LIMITATIONS AND RECORDS 4. 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 LP Separator Venting 007 Natural gas routed to thermal oxidizer 9.0 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. 5. 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 6. 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) COLORADO Air Pollution Control Division Page 2 of 7 7. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 8. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section 11.6.2. 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 II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; 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 schedule in Regulation Number 7, Part D, Section II.B.2.d. 9. The separator covered by this permit is subject to Regulation 7,. Part D, Section II.F. 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 commencement of operation 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. 10. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division -approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING £t MAINTENANCE REQUIREMENTS 11. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (0l*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 oam 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 12. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 13. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 14. All previous versions of this permit are cancelled upon issuance of this permit. 15. 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 COLORADO Air Pollution Control Division N71,,ittrnent Er.virvnment Page 3 of 7 For volatile organic compounds (VOC) and nitrogen oxides sources (NO,t) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t 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 16. 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. 17. 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. 18. 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. 19. 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. 20. 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. COLORADO Air Pollution Control Division Page 4 of 7 21. 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. 22. 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: Christian Lesniak Permit Engineer Permit History Issuance Date Description Issuance 1 December 3, 2018 Issued to Extraction Oil a Gas, Inc. Issuance 2 This Issuance Issued as Final Approval to Extraction Oil a Gas, Inc. Reduction of throughput. Updating regulatory references. Reduction of requested control efficiency from 98% to 95%. Removing requirement to stack test per reduction of control efficiency. Correction of control device from "thermal oxidizer" to enclosed combustion device. COLORADO Air Pollution Control Division Page 5 of 7 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-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) LP Separator Venting 007 Benzene 71432 1203 60 Toluene 108883 1168 58 Ethy(benzene 100414 86 4 Xylenes 1330207 301 15 n -Hexane 110543 8997 450 2,2,4- Trimethylpentane 540841 6 0 Note: All non-criter'a 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 007: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source N0x 130.63 130.63 AP -42 Chapter 13.5 Industrial Flares CO 595.51 595.51 V0C 53,140 1062.8 Site -specific extended gas analysis 71432 Benzene 134 2.68 108883 Toluene 130 2.60 100414 Ethylbenzene 10 0.20 1330207 Xylene 34 0.68 110543 n -Hexane 1003 20.06 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. COLORADO Air Pollution Control Division Page 6 of 7 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: VOC, n -hexane NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 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 PRELIMINARY ANALYSIS - PROJECT SUMMARY A Project Details Review Engineer :Christian Lesniak, >a Package # 416197 Received Date 12/9/2020 - v i Review Start Date 11/20/2020 - o- e' Section 01 Facility Information Company Name County AIRS ID Plant AIRS ID Facility Name Physical Address/Location County Type of Facility aExploration & Production Well Pad - - �-- ' Y _ � What industry segment%Oil & Na'ttural Ga Production & Processing Is this facility located in a NAAQS non attainment area? _ _ —yes s If yes for what pollutant? ElCarbon Monoxide (CO) ❑ Particulate Matter (PM) Extraction Oil & Gas, Inc _ 123 9F9B - ,RBF/Stromberger Production Facility SENE quadrant of Section 22, Township 6N Range 67W Weld County Section 02 Emissions Units In Permit Application Quadrant Section Township Range SENE 22 6N 67 Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? i Permit # Issuance II Self Cert Required', Action Engineering Remarks 001 ' - - Natural Gas RICE COMP 001 r - No Action Requested : Not processed here 002 * _,-Natural Gas RICE ' COMP 002 _ - ' - lio Action . Requested Not processed here ` _ i 003 ` 7 s Natural Gas RICE - COMP 003 - - -� ' - -' No Action —Requested Not processed here / , 004 , Condensate Tank Condensate Tanks , yes -°' 18WE0137 2 '} no _ , = Permit .,-, Moaiflcation, Not processed here 005, Produced Water Tank; Produced Water Tanks - y es ,� 18WE0138 1 yes NO Action Requested Not processed here r ' 006 " _ ,� Separator Venting VRT Separator Venting yes " 18WE0139 2 v '-no - <- `Permit"' , Modification Not processed here- _. ' 007 ' .� i ' _ - , a ' Separator Venting LP Separator Venting �. _ yes , SSWE0140 2 - - .--, — no ' _ _.» . Permit ,Modification Source has nothing left to, self certifyto- Issued as FA Section 03 Description of Project r Modification VRT and HLP separators are controlled by VRUs ECD when VRUs are not available Condensate and water tanks are controlled by enclosed flares Tanks are"connected directly "to oil sales line so no loadout emissions occur 1 ' Reduction in throughputs to bring facility under 50 tpy threshold to retain syn minorstatus Section 04 Public Comment Requirements Is Public Comment Required? _ yes r If yes why? 4Regaestin_g Sy-rAet%c Minor Permit Section 05 Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? If yes, for what pollutants? s 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, indicate programs and which pollutants Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non Attainment New Source Review (NANSR) Is this stationary source a major source? -no , SO2 NOx CO VOC PM25 PM10 TSP HAPs CI CI CIOCI CI LIB O13 ❑ ❑❑o J Separator Venting Emissions Inventory 007 Separator Venting II aulity 1M, ID 123 County 9F9B Plant Section 02 - Equipment Description Details Detailed Emissions Unit Description: LP gas from 19 HLP separators Emission Control Device Description: Thermal oxidizer during VRU bypass conditions Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Natural Gas Vented Yes, meter is currently installed and operational Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 7.5 MMscf per year 007 Paint Requested Permit Limit Throughput = 8.96 MMscf per year Requested Monthly Throughput = MMscf per month 1 Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Yes Is VRU process equipment: Yes 8.96 MMscf per year Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: 1754 Btu/scf Section 04 - Emissions Factors & Methodologies Description MW and composition of gas from site -specific LP separator gas sample, collected 1/29/2018 at 45 psig and 92 deg F. MW 34.0767 1.b/1.b-mol Displacement Equation Weight % Helium 0.00 CO2 2.5508 N2 4.5021 methane ethane n7, propane ≥9.1.43: isobutane 4.513' n -butane 12.6484 isopentane 2.9572 n -pentane 3.726; cyclopentane 0.272-1 n -Hexane 1.116 cyclohexane 0.293' Other hexanes 1.760£> heptanes 0.384:,. methylcyclohexane 0.3303 2 24 -TM P 0.000: Benzene 0.149 Toluene 0.145i` Ethylbenzene 0.010; Xylenes 0,037-1 C8+ Heavies " ;68r Total VOC Wt % Ex=Q•MW•Xx/C Emission Factors Separator Venting Uncontrolled Controlled Pollutant (lb/MMscf) (lb/MMscf) Emission Factor Source (Gas Throughput) (Gas Throughput) VOC Extended gas analysis Benzene Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Toluene Ethylbenzene Xylene n -Hexane Extended gas analysis Extended gas analysis 224 TMP Pollutant Primary Control Device Emission I actor S murce Uncontrolled Uncontrolled (lb/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 AP -42 Chapter 13.5 Industr al Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 SOx NOx 0.0680 CO 0.3100 Operator Calculations Uncontrolled (lb/Mscf) % differnce from (Gas Throughput) engineer talcs 53.14 0.58% 0.134 -0.18% 0.13 -0.29% 0.01 3.94% 0.034 1.11% 1.003 -0.11% 0.0006 -4.67% D:\Take Home\Current Projects\416197 (Extraction)\18WE0140.CP2 Separator Venting Emissions Inventory Section 05 Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limns Controlled (Ibs/month) PM10 PM25 SOx NOx VOC CO 0 00 0 00 0 00 0 00 0 00 0 000 000 C00 000 000 0 0 00 0 00 C 00 0 00 0 00 0 0 53 0 44 0 44 0 53 0 53 9. 23668 19706 394 23668 118 2010 2 44 2 03 2 03 2 14 2 44 414 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n Hexane 224 TMP 1203 1001 20 1203 60 1168 973 19 1168 58 86 72 1 86 4 301 251 5 301 15 8997 7491 SO 8997 450 6 5 0 6 0 Section 06 Regulatory Summary Analysis Regulation 3 Parts A B Regulation 7 Section XVII B G Regulation 7 Section XVII B 2 e (See regulatory applicability worksheet for detailed analysis) Source squires a perm t Source is subject to Regulation 7 Section XVII 3 2 G The control device for this separator's not sublect to Regulation 7 Section 6VII 82e Section 07 Initial and Periodic5ampling and Testing Requirements Using Gas Throughput to Monitor Compliance r ` Does the company use sites specific emission factors based on p pay p gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AlRs ID and should have been collected within one year of the application received date However if Are facility wide permitted emissions of VOC greater than or equal to 90 tons per year? no; ' . 4 Will the operator have a meter installed and operational upon startup of this point? Yes Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes the permit will mntain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 -Technical Analysis Notes ( Emissions based on LP separator gas analysis collected from RBF Stromberger 1/29/2018 The analysis is site specific and collected within one year of application submittal therefore there are no initial sampling requirements i Source initially asked for 97% control for this flare however submitted an APEN redline to bring requested efficiency to 95% Source also had called the control device a thermal oxidizer in the previous permit issuance I have corrected ' this to Enclosed Combustion Device Questor Q5000 As source is no longer requesting over 95% control I have removed the stack testing requirement As the stack testing requirement was the only outstanding part of the self certification I am now issuingthis permit as Final Approval Section 09 Inventory SCC Coding and Emissions Factors AIRS Point p 007 Process p SCC Code 01 3 10 001 60 Flares Uncontrolled Emissions Pollutant Factor Control% Units PM10 000 0 ib/rAM5CF PM25 000 0 Ib/MMSCF SOx 000 0 lb/MNISCF NOx 11927 0 Ib/f 1M5rF VOC 5283120 98 Ib/NIMSCF CO 543 74 0 Ib/MNISCF Benzene 13024 98 Ib/MPi5CF Toluene 1,037 98 Ib/rd MSCF Ethylbenzene 962 98 avr1MSCr Xylene 3363 48 b/MM5CF n Hexane 300411 )8 Ib/MMS,F 224 TMP 0 03 98 lb iMM5C- 3 of 4 D \Take Home \Current Projects \416197 (Extraction)\18W E0140 CP2 Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 "PY (Regulation 3, Part B, Section II.D.2)? Y e5 Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? yes Section XVII.B.2 - General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section! a Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is no• enclosed? yes Section XV11.B.2.e - Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act. its implementing regulations. and Air Quality Control Commission regulations This document is not a rule or regulation. and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances This document does not change or substitute for any law. regulation, or any other legally binding requirement and is not legally enforceable In the event of any conflict vetween the language of this document and the language of the Clean Air Act,, its implementing regulations. and Air Quality Control Commission regulations. the language of the statute or regulation MI control The use of non -mandatory language such as "recommend," 'may." -should." and -can.- is intended to describe APCD interpretations and recommendations Mandatory terminology such as 'must and 'required.' are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not estabfsh legally binding requirements in and of itself Source Req Source Req Source is si The contra RECEIVED SEP - 5 1019 Condensate Storage Tank(s) ADEN Form APCD-205 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. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). 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 and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. 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: 18WE0137 AIRS ID Number: 123 9F9B / 004 Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: RBF/Stromberger Production Facility Site Location: SENE SEC 22 T6N R67W Mailing Address: (Include Code, 370 17th Street, Suite 5300 Denver, CO 80202 Site Location County: Weld APCD Stationary Sources NAiCS or SIC Code: 211111 Contact Person: Phone Number: Jon Torizzo (303) 396-6051 E -Mail Address`: air extractionog.com 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 the APCD via e-mail to the address provided. 205 Tank ay�r .. _ J1 3 416193 �.. COLORADO Permit Number: 18WE0137 AIRS ID Number: 123 / 9F9B / 004 Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit ;check each box beiow chat (.-ppi!es) ❑ Change in equipment ❑ Change permit limit ❑ Change company name3 ❑ Transfer of ownership4 -OR - ❑ Other (describe below) ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info i3 Notes: Actual rolling12 throughput update to retain synthetic minor permitting status with serious non -attainment designation utilizing previously approved site -specific emission factors. 3 For company name change, a completed Company Name Change Certification Form (Form APCD 106) must be submitted. `1 For transfer of ownership, a compteted Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Eight (8) 400 -bbl condensate storage vessels 11/14/2017 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s)located at: hours/day 7 daysiweek 52 weeks /year ❑✓ Exploration Ei Production (EaPI site ❑ Midstream or Downstream in:on E&Pi site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes No ■ j Are Flash Emissions anticipated from these storage tanks? Yes No 0 ■ Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbt/day? 0 Yes ❑ No If "yes", identify the stock tank gas -to -oil ratio: 0.0003 m3/titer Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No 0 ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ ATcoioR.aa Permit Number: 18WE0137 AIRS ID Number: 123 / 9F9B i 004 Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) ICondensate Throughput: 948.604 From what year is the actual annual amount' Average API gravity of sales oil: 45.9 degrees Tank design: C] Fixed roof ❑ Internal floating roof 2018-2019 1,138, 324 RVP of sales oil: 11.2 ❑ External floating roof Storage Tank ID !f of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbt) Installation Date of Most Recent Storage Vessel in Storage Tank(monthlyeor) Date of First Production (month/year) -e.-Jo, - T -OCR 8 3.200 11/2017 11/2017 Wells Serviced by this Storage Tank or Tank Battery6 (EEO' Sites On ) API Number Name of Well Newly Reported Well See Addendum (Form APCD-212) ■ ■ ■ ■ ' Requested values wilt become permit limitations. Requested limit(s) should consider future growth. 5 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (latitude/Longitude or UTM) 40.474235, -104.870861 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECD -15 TBD TBD TBD Indicate the direction of the stack outlet (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (::heck one) 0 Circular ❑ Square/rectangle ❑ Other (describe): 5 ❑ Upward with obstructing raincap Interior stack diameter (inches): 48 Interior stack width (inches): Interior stack depth finches): nsate. Storage ranktPEra 3 :1019 433,V"H r,T4v D 0 Permit Number: 18WE0137 AIRS ID Number: 1 23 i 9F9B / 004 Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion J Device: Pollutants Controlled: Rating: Type: VOC/HAPs TBD ECD Requested Control Efficiency: MMBtu!hr c Q Make/Model: I ES - 48 95 Manufacturer Guaranteed Control Efficiency: >99 Minimum Temperature: TBD Waste Gas Heat Content: 2,507 Btu/scf Constant Pilot Light: Yes ❑ No Pilot Burner Rating: TBD b1MBtu /hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —5 psig Describe the separation process between the well and the storage tanks: HLP separator to VRT to condensate storage tanks leir COLORADO Permit Number: 18WE0137 AIRS ID Number: 123 / 9F9B / 004 Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form7. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency r" reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) NO, CO HAPs _co 9s . Other: From what year is the following reported actual annual emissions data? 2018-2019 Criteria Pollutant Emissions Inventory Pollutant Emission Factor' Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc. ) Uncontrolled Emissions (tons/ ear Y 1 Controlled Emissionse (tons/year) Uncontrolled Emissions tons/ ear ( Y ) Controlled Emissions (tons/ ear Y ) VOC 0.123 lb/bbl Perm,! t3f,Eo' 7 58.43 2.92 70.12 3.51 NOx 0.068 IbiMMBtu AP -42 0.10 0.10 0.12 0.12 CO 0.31 Ib/MMBtu AP -42 0.47 0.47 0.56 0.56 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor' Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (poundsiyear) Controlled Emissions8 (poundsiyear) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane i 110543 0.002 lb/bbl Permd'8A-E13- 1.768 88 2,2,4- Trimethylpentane 540841 { 5 Requested values will become permit limitations. Requested limit(s1 should consider future growth. ' Attach condensate liquid laboratory analysis, stack test results. and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees wilt be based on actual controlled emissions reported. If source has not yet started operating. leave blank. j �� coioR.'oo 5 Permit Number: 18WEO137 r AIRS ID Number: 123 / 9F9B / 004 an unless APCD has already assigned a permit % and .AIRS ID' Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signattitge of Legally Author 3 ed Person (not a vendor or consultant) Date Jonathan Torizzo Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) 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. Send this form along with $191.13 and the General Permit For more information or assistance tail: registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-81 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Small Business Assistance Program (303) 692.3175 or(303)692.3148 APCD Main Phone Number (303)692-3150 Or visit the APCD website at: Form APCD-2O5 Condensate Storage Tank(s) APEN - Revision 3/2019 eoionAao 6 veir�, RECEIVED SEP - 5 1019 ApcD suitlonary Sources Gas Venting 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. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-2OO) 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/cdphelapcd. 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: 18WE0139 AIRS ID Number: 123 / 9F9B /006 Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: RBF/Stromberger Production Facility Site Location: SENE SEC22 T6N R67W Mailing Address: 370 17th Street, Suite 5300 ilnclude Zip Coder Denver, CO 80202 Site Location County: Weld NAILS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address?: alr@extractionog.com Jon Torizzo (303) 396-6051 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 invo ces will be issued by the APCD via e-mail to the address provided. 416195 Aviv GOLORna0 1 L7,1 Permit Number: 18WE0139 AIRS ID Number: 123 9F98 006 Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source -OR - ❑✓ MODIFICATION to existing permit Icneck e c box belo, tr.a arc%;esi ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit Q Change permit limit ❑ Transfer of ownership` ❑ Other (describe below) -OR - ❑ APEN submittal for update only (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 8 Notes: Request to update emiss on omits using current actuals and 97% control efficiency for the thermal oxidizer. ' For company name change. a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 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: Vapor Recovery Tower (VRT) Venting Emissions Company equipment Identification No. (optional): For existing sources, operation began on: 11/14/2017 For new, modified. or reconstructed sources, the projected start-up date is: El Check this box if operating hours are 8,760 hours per year: if fewer. fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hoursiday Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? 3 _ .19 days week weeks/year Yes Yes Yes ❑ No Q No ❑ No Ing COLORADO 2 I Permit Number: 18WE0139 AIRS ID Number: 123 / 9F9B / 006 Section 4 - Process Equipment Information Ei Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters: Liquid Throughput Process Parameters5: Vented Gas Properties: Q Yes ❑ No Vent Gas Heating Value: 2,287 BTU /SCF Requested: 0.71 MMSCF/year Actual: 0.59 MMSCF/year -OR- Requested: I bbl/year Actual: i bbl/year Molecular weight: 44.24 VOC (Weight %) 8O.O2% Benzene (Weight %) 0.25% Toluene (Weight %) 0.21% Ethylbenzene (Weight %) 0.02% Xylene (Weight %) 0.06% n -Hexane (Weight %) 1.91a/c 2,2,4-Trimethylpentane (Weight %) 0.001% I Additional Required Information: Q 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) ' Requested values will become permit limitations. Requested limit(s) should consider future process growth ,.�ci5L, 3 fiat/ COLORADO Permit Number: 18WE0139 AIRS ID Number: 123 / 9F9B / 006 Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.474235, -104.870861 Operator Stack iD Fiu. Discharge Height Above Ground Level (Feet) Ted. (7) Flow Rate (ACFM) Velocity {jt)sec) O5000 --30' TBD TBD TBD Indicate the direction of the stack outlet: (check one) Q✓ Upward El Horizontal 0 Downward ❑ Other (describe): Indicate the stack opening and size: rchec k one, p Circular Other (describe): Interior stack diameter (inches): 0 Upward with obstructing raincap TBD Section 6 - Control Device Information Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECD MMBtui hr Make/Model: Questor/Q5000 Requested Control Efficiency: 97 Manufacturer Guaranteed Control Efficiency: >99 Minimum Temperature: TBD Waste Gas Heat Content: 2,287 Btu/scf Constant Pilot Light: Q Yes 0 No Pilot burner Rating: TBD MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: o� eoiaRAoo iJ. Permit Number: 18WE0139 AIRS ID Number: 123 )9F9Br006 Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency C-•• reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SO,, NO. CO VOC O5000 97% HAPs Q5000 97 r,. Other: From what year is the following reported actual annual emissions data? 2018-2019 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Source Units (AP -42, ( mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions° (tons/year) Uncontrolled Emissions (torts/year) Controlled Emissions (tons/year) PM SO t NO, 0,068 Ib/MMBtu AP -42 0.05 0.05 0.06 0.06 CO 0.310 Ib/MMBtu AP -42 0.21 0.21 0.25 0.25 VOC 93.289 Ib/Mscf I Eng. Est. 27.43 0.82 32.91 0.99 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg-, etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions ° (pounds/year) Benzene 71432 Toluene 108883 i Ethylbenzene i 100414 I - -- — — — ----._ Xylene -- --- — -- 1330207 I I ---- - -- n -Hexane 110543 I 2.231 I Ib/Mscf Eng. Est 1,312 39 2,2,4- Trimethylpentane I 540841 Other: I t 5 Requested values will become permit limitations. Requested timit(s) should consider future process growth. F Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. n 3 2 19 �® COLORADO 5 I., Permit Number: 180/E0139 AIRS ID Number: 123 / sF9B / 006 [Leave blank un-:ess A€,C�7 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, dnd correct. r. l� �', Signatur) of Legally Aut zed Person (not a vendor or consultant) Jon Torizzo Name (please print) Date Air Quality Coordinator 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) 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. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303)692-3175 or(303)692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: Form APCD-211 Gas Venting APEN - Revision 3/2019 6 I A COLORADO I xa.�..� Gas Venting 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. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). 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: 18WE0139 AIRS ID Number: 123 / 9F9B /006 [Leave blank unless APCD has already assigned a permit # and AIRS )01 Section 1 - Administrative Information Company Name: Site Name: Site Location: Extraction Oil & Gas, Inc. RBF/Stromberger Production Facility SENE SEC22 T6N R67W Mailing Address: 370 17th Street, Suite 5300 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Jon Torizzo Phone Number: (303) 396-6051 E -Mail Address: air@extractionog.com 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 the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 3/2019 1I COLORADO Permit Number: 18WE0139 AIRS ID Number: 123 /9F9B/006 [Leave biank 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 name3 ❑ Add point to existing permit ❑✓ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) - OR ❑ APEN submittal for update only (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 & Notes: Request to update emission limits using current actuals and 97% control efficiency for the thermal oxidizer. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. ' 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: Vapor Recovery Tower (VRT) Venting Emissions Company equipment Identification No. (optional): For existing sources, operation began on: 11/14/2017 For new, modified, or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 3/2019 days/week weeks/year Yes Yes Yes ❑ No ❑✓ No ❑ No VCOLORADO Permit Number: 18WE0139 AIRS ID Number: 128 / 9F9B / 006 [Leave blank unless APCD has already assigned a permit Y and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pint MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas9 Heating Value: 987 r—) $— BTU/SCF Requested: 0.71 MMSCF/year Actual: 0.59 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 44.24 VOC (Weight %) 80.02% Benzene (Weight %) 0.25% Toluene (Weight %) 0.21% Ethylbenzene (Weight %) 0.02% Xylene (Weight %) 0.06% n -Hexane (Weight %) 1.91% 2,2,4-Trimethylpentane (Weight %) 0.001% 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) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 3/2019 + COLORADO 3 I amvat E a rs. ry .a .,, Permit Number: 18WE0139 AIRS ID Number: 123 /9F96/006 [Leave blank unless APCD has aeready assigned a permit # and AIRS ID Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.474235, -104.870861 Operator . Stack ID No. Discharge Height b ve Ground Level (Feet) Temp, (°F} Flow Rate CFM) Yelbcity (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) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap TBD Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: ECD Make/Model: Questor/Q5000 Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: >99 Minimum Temperature: TBD Waste Gas Heat Content: 2,287 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: TBD MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 Gas Venting APEN - Revision 3/2019 AmpRy eoLoRaoo 4 of FLh;� Permit Number: 18WE0139 AIRS ID Number: 123 /9F9B/006 [Leave blank unless APCD has already assigned a permit g and AIRS ID1 Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency; (% reduction in emissions) PM SO. NO. CO VOC Q5000 95% HAPs Q5000 95% Other: From what year is the following reported actual annual emissions data? 2019 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOx NO. 0.068 Ib/MMBtu AP -42 0.05 0.05 0.06 0.06 CO 0.310 Ib/MMBtu AP -42 0.21 0.21 0.25 0.25 VOC 93.289 Ib/Mscf Eng. Est. 27.43 1.37 32.91 1.65 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, M etc. Mfg., ) Uncontrolled Emissions (pounds/year) (p Y ) Controlled Emissions6 (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2.231 Ib/Mscf Eng. Est. 1574 79 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 3/2014 A,- COLORADO 5 I �., Permit Number: 18WE0139 AIRS ID Number: 123 / 9F9B / 006 [Leave blank ;unless APCD has already assigned a permit # and AIRS ID1 Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature of Legally Authorized Person (not a vendor or consultant) Date Kathy Steerman Air Quality Manager 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) 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. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: For more information or assistance call: Small Business Assistance Program (303) 692-3175 or(303)692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.govicdphe/aped Form APCD-211 - Gas Venting APEN - Revision 3/2.19 �oao 6 I eoc. 7.f2 o gEP . 51019 ArC-1) SttttiowarY �h�rq�9 Gas Venting 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. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal wilt require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission -unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). 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.cotorado.govlcdohe/aped. 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: 18WE0140 AIRS ID Number: 123 f 9F9B /007 Section 1 - Administrative Information Company Name: Site Name: Site Location: Extraction Oil & Gas, Inc. RBF/Stromberger Production Facility SENE SEC22 T6N R67W Mailing Address: 370 17th Street, Suite 5300 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Jon Torizzo Phone Number: (303) 396-6051 E -Mail Address': air@extractlonog.com I 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 wilt be issued by the APCD via e-mail to the address provided. 416194 I AV COLORADO Permit Number: 1$WE0140 AIRS ID Number: 123 / 9F9i3 / 007 Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source -OR - 0 MODIFICATION to existing permit !check each ooK beiow that acpilesi ❑ Change fuel or equipment ❑ Change company name 3 ❑ Add point to existing permit Q Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR ❑ APEN submittal for update only (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 8 Notes: Request to update emission luinits using current actuals and 97% control efficiency for the thermal oxidizer. For company name change. a completed Company Name Change Certification Form (Form APCD- 106i must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted_. Section3 - General Information General description of equipment and purpose: LOW Pressure ("LP") Separator Venting Emissions Company equipment Identification No. (optional): For existing sources, operation began on: 11/14/2017 For new, modified, or reconstructed sources, the projected start-up date is: 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: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Q dayslweek weeks/year Yes Yes Yes No ❑✓ No No AlIFIV COLORADO 2 1 afIV Permit Number: 18WE0140 AIRS ID Number: 123 / 9F9B / 007 Section 4 - Process Equipment Information Q Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Compressor Rod Packing Make: Model ❑ Blowdown Events x of Events/year: ❑ Other Description: Serial #: of Pistons: Volume per event: Capacity: gal /min Leak Rate: Scfihripist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: Q Yes ❑ No Vent Gas 1,754 Heating Value: BTU/SCF Requested: 17.91 MMSCF/year Actual: 14.93 MMSCF/year -OR- Requested: I I bbl/year Actual: ! bbl/year I Molecular Weight: 34.09 VOC (Weight %) 58.74% Benzene (Weight %) 0.15% Toluene (Weight %) 0.14% Ethylbenzene (Weight %) 0.01°/o Xylene (Weight %) 0.04% n -Hexane (Weight %) 1.12% 2,2,4•Trimethylpentane (Weight %) 0.001% 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) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. a_UC D-2 11 eta > _ Revision3 Q 9 Isr caaRa°o 3 Permit Number: 18WE0140 AIRS ID Number: 123 /9F9Bf007 Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.474235, -104.870861 Opefator Stack ll} No. Discharge Height Above Ground Levet (Feet) tee. {'F} Plow Rate (ittFhl) Velocity (ft/set} 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: Knock one) E] Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap TBD Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model a Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: MMBtu/hr Make/Model: Questor/Q5000 97 >99 Minimum Temperature: TBD Waste Gas Heat Content: 1 754 Btu/scf Constant Pilot Light: Q Yes ❑ No Pilot burner Rating: TBD MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Amy COLORADO Permit Number: 18WE0140 AIRS ID Number: 123 /9F9B/007 Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency r reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM 5O, NO. CO VOC O5400 97% HAPs Q5000 97% Other: From what year is the following reported actual annual emissions data? 2018-2019 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions° (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM i SOx NO. 0.068 Ib/MMBtu `I` AP -42 0.89 0.89 1.07 1.07 CO 0.310 Ib/MMBtu { AP -42 4.06 4.06 4.87 4.87 VOC 52.766 i Ib/Mscf Eng. Est 393.84 11.82 472.61 14.18 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions ° (pounds/year) Benzene 71432 0.134 Ib/Mscf Eng. Est. 2..001 60 Toluene 108883 i 0.130 Ib/Mscf Eng. Est 1,944 58 Ethylbenzene Xylene 100414 0.034 lb/Mscf 501 15 1330207 ! Eng. Est. n -Hexane 110543 1 1.003 I lb/Mscf Eng. Est. 14,972 449 2,2,4- Trimethylpentane 540841 Other: i 5 Requested values will become permit limitations. Requested limitisI should consider future process growth. 5 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating. leave blank. .. AiPC _) Amy COLORADO 5 I a., Permit Number: 18WE0140 AIRS ID Number: 123 / 9F9B / 007 [Leave bunk ['Mess APCD has already assigned a permit .1 and A''RS ID) Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature of Legally Autho • erson (not a vendor or consultant) Jon Tonzzo Date Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: 1p Draft permit prior to issuance ❑r Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) 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. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303)692-3150 Or visit the APCD website at: Form APCD-211 - Gas Venting APEN - Revlsicn 3/2019 Amer,coLonActo 6R400,6o rw Gas Venting 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. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). 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/aped. 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: 18WE0140 AIRS ID Number: 123 /9F9B /007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: RBF/Stromberger Production Facility Site Location: SENE SEC22 T6N R67W Mailing Address: 370 17th Street, Suite 5300 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address: Jon Torizzo (303) 396-6051 air@extractionog.com 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 the APCD via e-mail to the address provided. COLORADO Form APCD-211 - Gas Venting APEN - Revision 3/2019 Permit Number: 18WE0140 AIRS ID Number: 123 i9F9Bi007 [Leave blank unless A?CD has already assigned a permit :# and AIRS `e] 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 name3 ❑ Add point to existing permit ❑✓ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) OR ❑ APEN submittal for update only (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: Request to update emission limits using current actuals and 95% control efficiency 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 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: LOW Pressure ("LP") Separator Venting Emissions Company equipment Identification No. (optional): For existing sources, operation began on: 11/14/2017 For new, modified, or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 3/209 days/week weeks/year Yes Yes Yes ❑ No ❑✓ No ❑ No 11,1 > COLORADO Permit Number: 18WE0140 AIRS ID Number: 123 / 9F9B / 007 [Leave blank unless APCD has already assigned a permit r and AIRS D] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ Yes ❑ No Vent Gas Heating Value: 1,754 BTU/SCF Requested: 8.96 MMSCF/year Actual: 7.46 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 34.09 VOC (Weight %) 58.74% Benzene (Weight %) 0.15% Toluene (Weight %) 0.14% Ethylbenzene (Weight %) 0.01% Xylene (Weight %) 0.04% n -Hexane (Weight %) 1.12% 2,2,4-Trimethylpentane (Weight %) 0.001% 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) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form AkD-211 - Gas Venting ADEN - Revision 312019 3 �COLORADO Permit Number: 18WE0140 AIRS ID Number: 123 /9F9B/007 [Leave blank unless APCD has already assigned a permit # and AIRS !D] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.474235, -104.870861 operator Mack E�scl�aige ethf Above Grourideyel Temp l? tow i a Velocity 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) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap TBD Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: % % ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECD MMBtu/hr Make/Model: Questor/Q5000 Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: >99 Minimum Temperature: TBD Waste Gas Heat Content: 17754 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: TBD MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting ADEN - Re=vision 3/2019 ADO 41 Permit Number: 18WE0140 AIRS ID Number: 123 /9F9B/007 [Leave btan'k unless APCD has already assigned a permit and AIRS i2] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested' Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC Q5000 95% HAPs Q5000 95% Other: From what year is the following reported actual annual emissions data? 2019 Criteria Pollutant Emissions Inventory Emission Factor ;, Actual Annual Emissions Requested Annual Permit 5 Emission Limit(s) Pollutant Uncontrolled Basis Units Source (AP -42. Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissionsb (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOx NO. 0.068 Ib/MMBtu AP -42 0.45 0.45 0.54 0.54 CO 0.310 Ib/MMBtu AP -42 2.03 2.03 2.44 2.44 VOC 52.766 Ib/Mscf Eng. Est. 196.92 9.85 236.31 11.82 Non -Criteria Reportable PollutantEmissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP 42, Mfg:, etc.) Uncontrolled Emissions (poundslyear) Controlled Emissions 6 ' (pounds/year) Benzene 71432 0.134 Ib/Mscf Eng. Est. 1201 60 Toluene 108883 0.130 Ib/Mscf Eng. Est. 1166 58 Ethylbenzene 100414 Xylene 1330207 0.034 Ib/Mscf Eng. Est. 301 15 n -Hexane 110543 1.003 Ib/Mscf Eng. Est. 8983 449 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APC©-211 - Gas Venting APEN - Revision 3%2019 ' COLORADO 5 == Permit Number: 18WE0140 AIRS ID Number: 123 /9F9Bi007 [Leave blank untess APCD has already assigned a permit + and AIRS !D] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature of Legally Authorized Person (not a vendor or consultant) Date Kathy Steerman Air Quality Manager Name (please print) Title Check the appropriate box to request a copy of the: E✓ 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) 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. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303)692-3150 Or visit the APCD website at: https: / /www.colorado. goy /cdphe /apcd ADO Form APCD-211 vas Venting APEN - Revision 3/2019 6I Hello