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Home My WebLink About20201726.tiff -rl— COLORADO g � Department of Public `°P"E Health b Environment RECEIVED MAY 0 5 2020 Weld County - Clerk to the Board 1150 0 St WELD COUNTY PO Box 758 COMMISSIONERS Greeley, CO 80632 April 22, 2020 Dear Sir or Madam: On April 23, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Extraction Oil a Gas, Inc. - Schlotthauer 4-26 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 &t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator i.:70:"\ 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe �4 Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director I fi"- $� Pubs; C ReV:et,.) CC:PL(TP),HL.(+►K),PCJ(SJt1ER/CH/cK), 2020-1726 6/15/20 0/7O") 6/O9/2.o z.f. Air Pollution Control Division aL� � y1� -E Notice of a Proposed Project or Activity Warranting Public CDPH Comment Website Title: HighPoint Operating Corporation - Park 4-63-4 NE Pad - Weld County Notice Period Begins: April 23, 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: HighPoint Operating Corporation Facility: Park 4-63-4 NE Pad EV Well Pad SENE SEC 4, T4N, R63W Weld County The proposed project or activity is as follows: Applicant is requesting individual permit coverage for the condensate tank battery and liquid loading sources at this facility, in addition to GP08 coverage for a produced water tank battery. 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 19WE0959 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/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: Ben Fischbach Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 'COLORADO 1 nepuoment of Public FSealsh b snviroomestt Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Ben Fischbach Package #: 420201 Received Date: 10/2/2019 Review Start Date: 12/11/2019 Section 01 - Facility Information Company Name: HighPoint Operating Corporation Quadrant Section Township Range County AIRS ID: 123 '"> 'iE 63 Plant AIRS ID: A094 Facility Name: Park 4-63-4 NE Pad Physical Address/Location: SENE quadrant of Section 4, Township 4N, Range 63W County: Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutant? O`c:re (NOY & VOC) Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only Permit # AIRs Point # Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks has already assigned) assigned) Permit lniti Condensate Tank Cond. TKs 19WE0959 issuance PA Tabs Hidden in this File - Sec- PA for Permit init=.. 19WE0960.CP1 Liquid Loading Liquid Loading 19WE0960 Issuance for this PA Section 03 - Description of Project Applicant is requesting individual permits for the condensate tank battery and liquid loading sources at this facility, in addition to GP08 coverage for the produced water tank battery. Applicant based all emissions calculations on site-specific emission factors which were developed for each point. Facility is classified as synthetic minor for VOC (TV and NANSR), and true minor for all other pollutants. Facility is requesting a Synthetic Minor permit, and will require Public Comment. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) J Non-Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) ■ I Non-Attainment New Source Review (NANSR) Condensate Storage Tank(s) Emissions Inventory Section 01 - Administrative Information 123 001 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Six (6) 400 bbl condensate storage tanks. Description: Emission Control Device Two (2) enclosed combustion devices (ECDs) Description: Requested Overall VOC & HAP Control Efficiency %: 95.0 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 305,000.0 Barrels (bbl) per year Requested Permit Limit Throughput = 366,000.0 Barrels (bbl) per year Requested Monthly Throughput = 31084.9 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput = 366,000.0 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2447.6 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 16.7 scf/bbl Actual heat content of waste gas routed to combustion device = 13,461.2 MMBTU per year > Requested heat content of waste gas routed to combustion device = 16,153.4 MMBTU per year > NOTE: Stock equations for cells E22-E24 were replaced with equations which take into account W&B vapors in Potential to Emit (PTE) heat content of waste gas routed to combustion device = 16,153.4 MMBTU per year > addition to Flash vapors (See technical analysis notes) Control Device Pilot Fuel Use Rate: 100 scfh 0.9 MMscf/yr Pilot Fuel Gas Heating Value: 1423 Btu/scf 1246.5 MMBTU/yr Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? MM. Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Condensate (Condensate Throughput) Throughput) VOC 1.762 0.0881 Benzene 3.694E-03 1.847E-04 .5,e''ri sc '� ( wde ^i i a..,i srf Ct u:,�.5. 4i��,. Toluene 2.630E-03 1.315E-04 :c-z0 c ; (inc, ,de fi<st} Ethylbenzene 2.025E-04 1.013E-05 E.F. UnciJetesfiAt'.r1 Xylene 6.980E-04 3.490E-05 Specific n-Hexane 3.343E-02 1.672E-03 S>,.:f4il':r: . (:r,.;usdes.; �a 224 TMP 1.830E-05 9.150E-07 Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Condensate combusted) Throughput) PM10 0.0000 PM2.5 0.0000 Combined/Overall NOx + CO Emission Factors (For Notes to Permit Holder) NOx 0.0680 0.0028 3,233E-03 lb/bbl NOx CO 0.3100 0.0127 1.474E-02 lb/bbl CO Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (Ib/MMscf) Emission Factor Source (Waste Heat (Pilot Gas Combusted) Throughput) PM10 0.0000 PM2.5 0.0000 Note: All Pilot fuel for these flares has been NOx 0.0680 96,76-t0 apportioned to this point alone. CO 0.3100 441.1300 2 of 9 K:\PA\2019\19WE0959.CP1 Condensate Storage Tank(s) Emissions Inventory • Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) VOC 322.4 258.6 13.4 322.4 16.1 2737.9 PM10 0.0 0.0 0.0 0.0 0.0 0.0 PM2.5 0.0 0.0 0.0 0.0 0.0 0.0 NOx 0.6 0.5 0.5 0.59 0.59 100.5 CO 2.7 2.3 2.3 2.70 2.70 458.1 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled abs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 1351.9 1127 56 1352 68 Toluene 962.6 802 40 963 48 Ethylbenzene 74.1 62 3 74 4 Xylene 255.5 213 11 256 13 n-Hexane 12235.8 10197 510 12236 612 224 TMP 6.7 6 0 7 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XI1.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage tank is not subject to NSPS OOOO. NSPS Subpart 0000a Storage Tank is not subject to NSPS 0000a Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, 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 use a site 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? This 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. 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 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 08 - Technical Analysis Notes Site-specific emission factors were estimated using the flash liberation analysis method. Six (6) 400 bbl condensate storage tanks. Site-specific emission factors estimated based on a flash liberation analysis of the pressurized oil stream. Flash Analysis was performed by Alliance Source Testing on a sample which was collected on 8/9/2019 and analyzed on 8/16/2019. Sample was collected from the Park 4-63-4 facility at a pressure of 11.1 psig (with an ambient pressure of 12.5 psia) and a temperature of 88 F (with an ambient temp of 71 F). Flash liberation yielded a GOR of 16.7 scf/bbl and a flashed gas sample analysis comporistion. Flashed gas analysis composition was used in combination with GOR and Flash Liberation Excel workbook/template to verify operator-calculated emission factors. All emission factors calculated agreed with APEN values within rounding error - will therefore use APEN listed emission factors in permit. All controlled sources at this facility share a common flare bank. Therefore, pilot fuel usage for this facility has been apportioned to this AIRS point. Operator used following equation for annual waste gas heat calculations in order to account for W&B in addition to flash gas: Flash + W&B Gas (MMBTU/yr) = [ VOC Emissions (tpy) ] * [ 2000 lb/ton ] * [ 1 / VOCwt% ] * [ 1 / GasMW 1 * [ 379.41 scf/Ibmol I * [ Heating Value (Btu/scf) I * [ 1 / (10^6 Btu/MMBtu) I and used the following values: VOCwt% = 0.8054 (From flash gas extended analysis) GasMW = 46.02 (From flash gas extended analysis) The above resulted in more conservative emissions estimates than predicted by the standard PA method, and is acceptable. • 3 of 9 K:\PA\2019\19WE0959.CP1 Condensate Storage Tank(s) Emissions Inventory Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 01 PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.08 0 lb/1,000 gallons condensate throughput VOC 41.9 95 lb/1,000 gallons condensate throughput CO 0.35 0 lb/1,000 gallons condensate throughput Benzene 0.09 95 lb/1,000 gallons condensate throughput Toluene 0.06 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.02 95 Ib/1,000 gallons condensate throughput n-Hexane 0.80 95 lb/1,000 gallons condensate throughput 224 TMP 0.00 95 lb/1,000 gallons condensate throughput 4 of 9 K:\PA\2019\19WE0959.CP1 EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex = Q * MW * Xx / C GOR Conversion Check Ex = emissions of pollutant x Actual Pressure (P1) 12.5 psia Q = Volumetric flow rate/volume of gas processed Actual Temperature (T1) 530.67 Rankine MW = Molecular weight of gas = SG of gas ' MW of air Actual GOR (V1) 60.62 cf/bbl Xx = mass fraction of x in gas Standard Pressure (P2) 15.025 psia C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Standard Temperature (T2) 520.67 Rankine Standard GOR (V2) 49.48225 scf/bbl MW 46.0249 Ib/Ib-mol Throughput 366000 bbl/year Gas-to-Oil Ratio (GOR) 16.68 scf/bbl mass fraction (%) Emission Factor (lb/bbl) Emissions (lbs/year) Helium 1.45 2.923E-02 10717.41 CO2 036 1.126E-02 4122.71 N2 5.70 1.154E-01 42225.34 H2S 0.000E+00 0.00 methane 0.75 1.515E-02 5546.07 ethane 11.01 2.227E-01 81505.47 propane 35.16 7.115E-01 260408.87 isobutane 1.417E-01 51868.94 n-butane 20.40 4.128E-01 151093.83 FLASH W+B Overall EF APEN El isopentane 4.91 9.934E-02 36357.87 n-pentane 5.97 1.209E-01 44247.08 224-TMP 0.000016 1.31E-06 724TMP 0.000017 0.00002 cyclopentane 038 7.693E-03 2815.62 Benzene 0.003418 2.76E-04 Benzene 3.693E-03 0.00369 n-Hexane 133 3.093E-02 11319.48 Toluene 0.002434 1.96E-04 7:s!uene 2..630E•03 0.00263 cyclohexane 0.36 7.185E-03 2629.73 Ethylbenzene 0.000188 1.52E-05 Ethyib.enzen 2.03E-0.4: 0.000200 Other hexanes 2.40^ 5.021E-02 18377.78 Xylenes 0.000645 5.21E-05 Xylenes 6.98E-04 0.000700 heptanes 0.87 1.751E-02 6403.82 n-Hexane 0.0309276 7.03E-04 n-Hexane 3.10E-02 0.03343 methylcyclohexane 0.32 6.398E-03 2341.66 224-TMP 0.00 1.619E-05 5.92 Benzene 0.17 3.418E-03 1250.81 VOC 1.62963 0.13144 VOC 1.761071 1.76156 Toluene 0.12 2.434E-03 890.90 Ethylbenzene 0.01 1.882E-04 68.87 Xylenes 0.03 6.455E-04 236.24 CS 0.43 8.721E-03 3191.82 224 9.933E-06 C9 0.13 2.566E-03 939.03 B 0.002097105 C10 0.27 5.443E-03 1992.11 T 0.001493675 C11+ 0.000E+00 00 E 0.000115471 Total 100.00 . . Total X 0.000396078 VOC Wt % 80.54 1.6296 295.22209 C6 0.018978242 Condensate Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B - APEN and Permit Re.uirements Source is in the Non-Attainment Area 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. Is the construction date (service date) prior to 12/30/2002 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)? 1111 3. 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 11.0.3)? You have indicated that source is in the Nan-Attainment Area 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)? Yes Source Requires an APEN. Go to 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 0501 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? No Go to next question 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)? Yes Source Requires a permit Source requires a permit Colorado Regulation 7,Section XII.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? Yes _ Continue - You have indicated th 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? Yes Continue - You have indicated th 3. Is this storage tank located upstream of a natural gas processing plant? Yes _Source is subject Storage tank is subject to Regulation 7, Section X1:.C r 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 — Recordkeeping and Reporting Colorado Regulation 7,Section XII.G 1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? Yn s Continue - You have determined 2. Is this storage tank located at a natural gas processing plant? No Storage Tank is not subject to RE 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? Yes Source is subject Storage Tank is not subject to Regulation 7, Section XII.G 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? No Continue - You have indicated th 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? Yes Go to the next question • You ha 3. Is this condensate storage tank a fixed roof storage tank? Yes Go to the next question 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC? Yes Source is subject to parts of Reg 3iorage tank is subject to Regulation 7, Section XVIi, B, C 1 & C.3 Section XV1I.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? No Source is subject to all provision. Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Uquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) (-472 BBLs)? No Storage Tank is not subject NSPS 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ["10,000 BBLJ used for petroleum` or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"3 in 60.111b? 5. Does the storage vessel store a "volatile organic liquid (VOL)"s as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa (`29.7 psi) and without emissions to the atmosphere (60.11ob(d)(2))?; or b. The design capacity is greater than or equal to 151 m3 ["950 BBL) and stores a liquid with a maximum true vapor pressure6 less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M3 (-472 BBL) but less than 151 m3 (-950 BBL) and stores a liquid with a maximum true vapor pressure6 less than 15.0 kPa(60.11ob(b))? 7. Does the storage tank meet either one of the following exemptions from control requirements: a. The design capacity is greater than or equal to 151 m3 [-950 BBL) and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?; or b. The design capacity Is greater than or equal to 75 M3 (-472 BBL] but less than 151 n.3 (-950 BBL) and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa? Storage Tank is not subject to NSPS Kb 40 CFR, Part 60, Subpart 0000/0000a, Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution 1. Is 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? Yep. Continue - You have indicated th 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR. 60.2) between August 23, 2011 and September 18. 2015? No Storage Tank is not subject NSPS 3. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR. 60.2) after September 18, 2015? Yes Go to the next question 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? No Storage Tank is not subject NSPS 5. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430/60.5430a? 6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HI-I? Storage Tank is not subject to NSPS 0000a (Note: If a storage vessel is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000/0000a per 60.5365(e)(2)/60.5365a(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR!Part 63, Subpart MAR HH 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: Ye% Continue - You have indicated th 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 userz (63.760(a)(3))? 2- Is the tank located at a facility that is major3 for HAPs? No Storage Tank is not subject MAC I Does the tank meet the definition of "storage vessel"` in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60. Subpart Kb or Subpart 0000? Ste.- Tank is not subject to MACT Hh Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting RACT Review RAG 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 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 tan,"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 establish legally binding requirements in and of itself. COlORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name HighPoint Operating Corporation County AIRS ID 123 History File Edit Date I 4/15/2020 Plant AIRS ID A094 Ozone Status Non-Attainment Facility Name Park 4-63-4 NE Pad EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0 0 001 19WE0959 Six (6) 400 bbl Condensate Tanks 0 6 322.4 2.7 7 4 0.6 16.1 2.7 0.4 New 002 19WE0960 Condensate Loadout 0 1 31 0 0 2 0 7 0.1 1 .6 0.2 0.0 New 003 GP08 Two (2) 400 bbl Produced Water Tanks 0.0 2.6 0.1 0.2 _ 0.0 5.9 0.1 0.0 New 0.0, 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0 0 0.0 _ 0.0 0.0 0.0 0.0 0.0 0.0 , 0 0 0.0 FACILITY TOTAL 0.0 0.0 0.0 0.0 0.7 355.9 0.0 3.0 8.3 0.0 0.0 0.0 0.0 0.7 23.6 0.0 3.0 0.4 VOC: Syn Minor (NANSR and OP) NOx: True Minor (NANSR and OP) CO: True Minor (PSD and OP) HAPS: True Minor B, T, X, HCHO & Total HH: True Minor + affected Area 7777: True Minor Permitted Facility Total 0.0 0.0 0.0 0.0 0. 7 355.9 0.0 3.0 8.3 0.0 0.0 0.0 0 0 0.7 23.6 0 0 3.0 0.4 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0 0 0 7 23.6 0 0 3 0 Pubcom required based on requesting Syn Minor Permit Limit. Modeling Not required. Total VOC Facility Emissions (point and fugitive) 23.6 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) 23.6 Project emissions less than 25 tpy Note 1 Note 2 Page 7 of 9 Printed 4/15/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name HighPoint Operating Corporation County AIRS ID 123 Plant AIRS ID A094 Facility Name Park 4-63-4 NE Pad Emissions - uncontrolled (lbs per year) POINT PERMIT Description Fomraldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane MeOH 224 TMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0959 Six (6) 400 bbl Condensate Tanks 1352 963 74 256 12236 7.4 002 19WE0960 Condensate Loadout 130 92 7 1175 0.7 003 GP08 Two (2) 400 bbl Produced Water Tanks 143 96 6 0.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.8 0.6 0.0 0.1 6.7 0.0 0.0 0.0 0.0 8.3 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 8 19WE0959.CP1 4/15/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name HighPoint Operating Corporation County AIRS ID 123 Plant AIRS ID A094 Facility Name Park 4-63-4 NE Pad Emissions with controls 'Ibs per year' POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) `Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0959 Six (6) 400 bbl Condensate Tanks 68 48 4 13 612 0 0.4 002 19WE0960 Condensate Loadout 6 5 0 1 59 0 0.0 003 GP08 Two (2) 400 bbl Produced Water Tanks 7 5 0 1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.3 0.0 0.0 0.0 0.0 0.4 9 19WE0959.CP1 4/15/2020 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Ben Fischbach Package #: 420201 Received Date: 10/2/2019 Review Start Date: 12/11/2019 Section 01 - Facility Information Company Name: HighPoint Operating Corporation Quadrant Section Township Range County AIRS ID: 123 SENE 4 a Plant AIRS ID: A094 Facility Name: Park 4-63-4 NE Pad Physical Address/Location: SENE quadrant of Section 4, Township 4N, Range 63W County: Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutant? Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only Permit # AIRs Point # Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks has already assigned) assigned) PA Tabs Hidden in this File - See PA for Permit Initial 19WE0959.CP1 001 Condensate Tank Cond. TKs 19WE0959 r Issuance for this PA Permit Initial 002 Liquid Loading Liquid Loading 19WE0960 Issuance Section 03 - Description of Project Applicant is requesting individual permits for the condensate tank battery and liquid loading sources at this facility, in addition to GP08 coverage for the produced water tank battery. Applicant based all emissions calculations on site-specific emission factors which were developed for each point. Facility is classified as synthetic minor for VOC (TV and NANSR), and true minor for all other pollutants. Facility is requesting a Synthetic Minor permit, and will require Public Comment. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Ye , If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) J D Non-Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non-Attainment New Source Review (NANSR) Hydrocarbon Loadout Emissions Inventory Section 01 - Administrative Information 123 A094 Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Condensate loadout from storage tanks to tank trucks. Description: Emission Control Device Enclosed Combustion Devices Description: Is this loadout controlled? yes Requested Overall VOC & HAP Control Efficiency %: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = 305,000 Barrels (bbl) per year Requested Permit Limit Throughput = 366,000 Barrels (bbl) per year Requested Monthly Throughput = ; a_Q`.S Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 366,000 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2448 Btu/scf Actual Volume of waste gas emitted per year = 524577 scf/year Changed Waste Gas emission equations to reflect operator Requested Volume of waste gas emitted per year = 629493 scf/year calculations which use the actual gas MW (instead of assumed Actual heat content of waste gas routed to combustion device = 1,284 MMBTU per year value of 68 Ib/Ibmol from Gasoline RVP 8.3 properties) and also to Requested heat content of waste gas routed to combustion device = 1,541 MMBTU per year reflect VOC% of gas. Both of these alterations to equation result in slightly more conservative results, so will accept and use in Potential to Emit (PTE) heat content of waste gas routed to combustion device = 1,541 MMBTU per year permit. Control Device Pilot Fuel Use Rate: "' scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: 0 Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? c..v.„_ 'o` fjt7s':, The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors. Loading Loss Equation L = 12.46*S*P*M/T Factor Meaning Value Units Source S Saturation Factor 0.6 Aaska P True Vapor Pressure 4.06 psia AP-42 Table 7.1-2: Gasoline RVP 8.3 Properties Assumed M Molecular Weight of Vapors 68 Ib/Ib-mol AP-42 Table 7.1-2: Gasoline RVP 8.3 Properties Assumed *** RVP 8.3 Properties assumed based on Results of Flash T Liquid Temperature 512.45 Rankine AP-42 Table 7.1-2: Gasoline RVP 8.3 Properties Assumed Liberation Analysis, which shows an RVP equivalent L Loading Losses 4.02765944 lb/1000 gallons (@100F, by ASTM D6377) of 8.2 psi. Assumed RVP of 8.3 is 0.16916t696 lb/bbl more conservative, so will accept and base emission factors off of properties in table 7.1-2. **IC Component Mass Fraction Emission Factor Units Source Benzene 0.00210 0.00035475 lb/bbl Ratio of Benzene:VOC in condensate flash gas. Toluene 0.00149 0.000252673 lb/bbl Ratio of Benzene:VOC in condensate flash gas. Ethylbenzene 0.00012 1.95333E-05 lb/bbl Ratio of Benzene:VOC in condensate flash gas. Xylene 0.00040 6.70013E-05 lb/bbl Ratio of Benzene:VOC in condensate flash gas. n-Hexane 0.01897 0.003208997 lb/bbl Ratio of Benzene:VOC in condensate flash gas. 224 TMP 9.93E-06 1.68028E-06 lb/bbl Ratio of Benzene:VOC in condensate flash gas. Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Volume (Volume Loaded) Loaded) VOC 1.692E-01 8.458E-03 Benzene 3.547E-04 1.774E-0S "‘P-42: t, �pte _� r:, tr.:x kt. Toluene 2.527E-04 1.263E-05 P-42.- Char k:ci._ Ethylbenzene 1.953E-05 9.767E-07 y: ., Xylene 6.700E-05 3.350E-06 n-Hexane 3.209E-03 1.604E-04 224 TMP 1.680E-06 8.402E-08 Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) PM10 0.00E+00 PM2.5 0.00E+00 SOx 0.00E+00 NOx 0.0680 2.86E-04 AP ... -r 3:._. i., < ti`.. r# CO 0.3100 1.31E 03 `42 Tm+�.e raSL... ak .t „ .f�.i Yyy.( 2y;. r t \ .'.` Pilot Light Emissions Uncontrolled Uncontrolled Pilot light emissions are accounted Pollutant (lb/MMBtu) (lb/MMscf) Emission Factor Source for/apportioned to on point 001 at this facility. (Pilot Gas (Waste Heat Combusted) Throughput) PM10 0,0000 PM2.5 0.0000 SOx - 0.0000 NOx 0.0000 «F CO 0.0000 2 of 6 K:\PA\2019\19WE0960.CP1 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.00 0.00 0.00 0.00 0.00 0 PM2.5 0.00 0.00 0.00 0.00 0.00 0 S0x 0.00 0.00 0.00 0.00 0.00 0 NOx 0.05 0.04 0.04 0.05 0.05 9 V0C 30.96 25.80 1.29 30.96 1.55 263 CO 0.24 0.20 0.20 0.24 0.24 41 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 130 108 5 130 6 Toluene 92 77 4 92 5 Ethylbenzene 7 6 0 7 0 Xylene 25 20 1 25 1 n-Hexane 1174 979 49 1175 59 224 TMP 1 1 0 1 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACT. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? ;e yY ".I<z «':,;11h = -�� Y'.,,ik n :R.Is 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 08 - Technical Analysis Notes *** RVP 8.3 Properties assumed based on Results of Flash Liberation Analysis, which shows an RVP equivalent (@100F, by ASTM D6377) of 8.2 psi. Assumed RVP of 8.3 is more conservative, so will accept and base emission factors off of properties in table 7.1-2. *** Altered Waste Gas emission equations to reflect actual gas MW (instead of assumed value of 68 Ib/Ibmol from Gasoline RVP 8.3 properties) and also to reflect V0C% of gas. Both of these changes to equation result in slightly more conservative results, so will accept and use in permit. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 002 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred S0x 0.00 0 lb/1,000 gallons transferred N0x 0.01 0 lb/1,000 gallons transferred V0C 4.0 95 lb/1,000 gallons transferred CO 0.03 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.01 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 95 lb/1,000 gallons transferred n-Hexane 0.08 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 3 of 6 K:\PA\2019\19WE0960.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non-Attainment Area 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. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. 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)? You have indicated that source is in the Non-Attainment Area 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)? Yes; Go to next 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.O.1.1)? Yes Go to the n 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? No Go to next 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? No Go to next 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? No Go to next 6. 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)? Yes The loadou Source requires a permit 7. RACT- Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? Yes The loadou The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RAG. 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,""should,"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must"and "required"am intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name HighPoint Operating Corporation County AIRS ID 123 History File Edit Date 4;1512020 Plant AIRS ID A094 Ozone Status Non-Attainment Facility Name Park 4-63-4 NE Pad EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 19WE0959 Six (6) 400 bbl Condensate Tanks 0.6 322.4 2 7 , 7.4 0.6 16.1 2.7 0.4 New 002 19WE0960 Condensate Loadout 0 1 31 .0 0 2 0.7 0.1 1 .6 0.2 0.0 New 003 GP08 Two (2) 400 bbl Produced Water Tanks 0.0 2.6 0.1 0.2 0.0 5.9 0.1 0.0 New 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.0 0.0 0.0 0.0 0.7 355.9 0.0 3.0 8.3 0.0 0.0 0.0 0.0 0.7 23.6 0.0 3.0 0.4 VOC: Syn Minor (NANSR and OP) NOx: True Minor (NANSR and OP) CO: True Minor (PSD and OP) HAPS: True Minor B, T, X, HCHO & Total HH: True Minor + affected Area 7777: True Minor Permitted Facility Total 0.0 0.0 0.0 0.0 0.7 355.9 0.0 3.0 8.3 0.0 0.0 0.0 0.0 0.7 23.6 0.0 3.0 0.4 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 0.7 23.6 0.0 3.0 Pubcom required based on requesting Syn Minor Permit Limit. Modeling Not required. Total VOC Facility Emissions (point and fugitive) 23.6 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) 23.6 Project emissions less than 25 tpv Note 1 Note 2 Page 5 of 6 Printed 4/15/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name HighPoint Operating Corporation County AIRS ID 123 Plant AIRS ID A094 Facility Name Park 4-63-4 NE Pad Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0959 Six '6' 400 bbl Condensate Tanks 1352 963 74 256 12236 7.4 002 19WE0960 Condensate Loadout 130 92 7 1175 0.7 003 GP08 Two (2) 400 bbl Produced Water Tanks 143 96 6 0.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.8 0.6 0.0 0.1 6.7 0.0 0.0 0.0 0.0 8.3 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 IMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 _ 0 0 0 0 0 0 0 0 0.0 001 19WE0959 Six (6) 400 bbl Condensate Tanks 68 48 4 13 612 0 i 0.4 002 19WE0960 Condensate Loadout 0 59 0 0.0 003 GP08 Two (2' 400 bbl Produced Water Tanks 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy t 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.3 0.0 0.0 0.0 0.0 0.4 6 19WE0960.CP1 4/15/2020 IF WED SEP 25 2019 1 PCD onary 'A C,�1 E Gas Venting APEN - Form APCD-211 CO ♦ Air Pollutant Emission Notice (APEN) and Application for Construction Permit Ali 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 wilt not satisfy your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at: www.colorado.ttovlcdphe/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: 18WE0338 AIRS ID Number: 123 /9A22 /004 Section 1 - Administrative Information Company Name': Extraction Oil &Gas, Inc. Site Name: Schlotthauer 4-26 Production Facility Site Location Site Location: SWSW SEC 23 T6N R67W Weld County: NAICS or SIC Code: 211111 Mailing Address: 370 17th Street, Suite 5300 (include zip Cadet Denver, Colorado 80202 Contact Person: Jon Torizzo Phone Number: (303) 396-6051 E-mail Addressz: 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 wilt require additional paperwork. 2 Permits,exemption letters.and any processing invoices will be issued by the APED via e-mail to the address provided. 419924 t jay COLOR a D9 ;Thrrr APE) 21 1 CAS Ve no APEN Ree,Islor' 3 2�,19 I Ask) Permit Number: 18WE0338 AIRS ID Number: 123 /9A22 J 004 Section 2 - Requested Action O NEW permit OR newly-reported emission source -OR- El MODIFICATION to existing permit itheci e x h box below that apphlesl O Change fuel or equipment O Change company name' O Add point to existing permit ❑1 Change permit limit O Transfer of ownership' O 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: Updating throughput in order to maintain synthetic minor permitting status with serious non-attainment thresholds. 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 Company equipment Identification No. (optional): For existing sources,operation began on: 03/2018 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 hours/day days/week weeks/year Operation: Wilt this equipment be operated in any NAAQS Yes O No nonattainment area? Is this equipment located at a stationary source that is ❑ Yes ❑ No considered a Major Source of(HAP)Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Yes ❑ Na agf COLORADO AP may '*^r ti _. p . ;'o' 3 2019 Permit Number: 18WE0338 AIRS ID Number: 123 /9A22 /004 Section 4 - Process Equipment Information • Gas/Liquid Separator o Well Head Casing O Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scfihr/gist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event • Other Description: 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? Q Yes O No Vent Gas ' 1754 BTIl/SCF Gas Venting Heating Value: Process Parameters5: Requested: 22.74, MMSCF/year Actual: 18.95 MMSCF/year -OR- Liquid Throughput I Requested: bbl/year Actual: 1 bbltyear Process Parameters5: Molecular Weight: 34.09 VOC (Weight%) 58.74 Benzene(Weight%) 0.15 Vented Gas Toluene(Weight%) 0.14 Properties: Ethytbenzene(Weight%) 0.01 Xytene(Weight%) 0.04 n-Hexane(Weight%) 1.12 2.2,4-Trimethylpentane(Weight%) 0.0007 Additional Required Information: O Attach a representative gas analysis(including BTEX Et n-Hexane, temperature, and pressure) 1-7-1 pressure) a representative pressurized extended liquids analysis(including BTEX Et n-Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested timit(si should consider future process growth. ATP COea.ao 11 -3 v. ADEN epic 3r 3 _�iq 3 I. t Permit Number: 18WE0338 AIRS ID Number: 123 /9A22 /004 Section 5 - Stack information Geographical Coordinates (Latitude/Longitude or UTM) 40.552646, -104.86685 Discharge—Height • O Temp. nO R41 to tetvclty€ .. , Above i:10nd i eve! , ECD I —15 TBD TBD TBD Indicate the direction of the stack outlet: (,heck,ine) Upward Q Downward 0 Upward with obstructing raincap 0 Horizontal Q Other(describe): Indicate the stack opening and size: fcheck one? ®Circular Interior stack diameter(inches): 48" o Other(describe): Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Size: Make/Model: [ VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: ECDs Make/Model: (2) IES 48" Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD Waste Gas Heat Content: 1 754 Btu/scf Constant Pilot Light: ✓i Yes 0 No Pilot burner Rating: TBD MMBtu/hr Pollutants Controlled: O Other: Description: Requested Control Efficiency: CPl©�7ADO Permit Number: 18WE0338 AIRS ID Number: 123 /9A22 [004 Section 7- Emissions Inventory Information Attach alt 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'µ.reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency (%reduction in emissions) PM SO. NO,, Cl? VOC ECD 95 HAPs ECD 95 Other: '18 From what year is the following reported actual annual emissions data? 9 Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions6 Emissions Emissions Mfg„etc.) (tau/year) (tons/year) (tons/year) (tonslyear) PM SOS NO„ 0.068 lb/MMBtu AP-42 1.1 1.1 1.4 1.4 CO 0.31 ib/MMBtu AP-42 5.2 5.2 6.2 6.2 VOC 52.77 lb/Mscf Eng.Est. 500.0 25.0 600.0 30.0 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions6 Number Basis Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 0.134 ` lb/Mscf Eng.Est. 2.540 127 Toluene 108883 0.13 lb/Mscf Eng,Est. 2,466 123 Ethylbenzene 100414 Xylene 1330207 0.034 lb/Mscf Eng,Est. 636 32 n-Hexane 110543 1.003 lb/Mscf Eng.Est. I 19,006 950 2,2,4- 540841 Trimethylpentane Other: 5 Requested values will become permit limitations. Requested timitts)should consider future process growth. t Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. , caLoe:ao Permit Number: 18WE0338 AIRS ID Number: 123 /9A22/004 Leave bunk mess APCD bas al-rady assigned a permit;and AIRS 10j Section 8-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. qI2 3// Sign re of Legally horized ersori(not a vendor or consultant) Date Jon rizzo Air Quality Coordinator Name(please print) Title Check the appropriate box to request a copy of the: Q Draft permit prior to issuance ID 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: For more information or assistance call; Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B1 4300 Cherry Creek Drive South APCD Main Phone Number Denver,CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment htt s:/Jwww.coicrado.sgov='cdphe aped � ' pa...Y.r.en! Form CD ;11 Gas L'e ti g�4PEt - Revision 3/2019 6 co-tCa"°�' E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form' Company Name: Extraction Oil&Gas,Inc. Source Name: Schlotthauer 4-26 Production Facility Emissions Source AIRS ID2: 123-9A22 Wells Serviced by this Storage Tank or Tank Batter(E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-34774 Schlotthauer# 13-23 O 05-123-34775 Schlotthauer#3-26 O 05-123-34776 Schlotthauer#4-26 O 05-123-34777 Schlotthauer# 14-23 O O O O O ❑ O O O O O O O Footnotes: t Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly reported source that has not been assigned an AIRS ID by the APCD,enter NA Form APCD-212 Form APCD-212 E&P Storage Tank APEN Addendum-Ver.7-29-2014 CDPHE COLORADO CO vo' Air Pollution Control Division Department of Public Health&Environment CONSTRUCTION PERMIT Permit number: 18WE0338 Issuance: 2 Date issued: Issued to: Extraction Oil Ft Gas, Inc. Facility Name: Schlotthauer 4-26 Production Facility Plant AIRS ID: 123/9A22 Physical Location: SWSW SEC 23 T6N R67W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Equipment Description ID Point Description LP Separator Venting of gas from one Low Pressure (LP) Venting 004 separator during times of vapor recovery unit Enclosed Flare (VRU) downtime 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 Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) CO COLORADO Air Pollution Control Division Ueix"-mttent e+Raft:H a Lex,T onmen,^. Page 1 of 7 Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NOX VOC CO Type LP Separator 004 --- 1.4 30.0 6.2 Point Venting 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 must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must'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 owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice(APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 4. The emission points in the table below must 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 AIRS Pollutants Control Device Equipment ID Point Controlled LP Separator Enclosed Flare during Vapor Recovery Unit Venting 004 (VRU) downtime VOC and HAP PROCESS LIMITATIONS AND RECORDS 5. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must 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 AIRS Process Parameter Annual Limit Equipment ID Point LP Separator 004 Gas Venting during VRU 22.7 MMSCF Venting downtime Compliance with the annual throughput limits must 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 must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 6. The owner or operator must continuously monitor and record the volumetric flow rate of gas vented from the separator(s) to the flare during VRU downtime using the flow meter. The owner COPHE COLORADO CO Air Pollution Control Division - 1 Dew rrIrrIt F147It:'tearwe-Etvennment Page 2 of 7 or operator must 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 7. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 8. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 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 a MAINTENANCE REQUIREMENTS 11. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance ,((D&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 OZtM 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) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO„ per year,a change in +, C P COLORADO CO Air Pollution Control Division 4 Depa.,me,t “e:th#Env.rnnmen. Page 3 of 7 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. 16. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). 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 operators 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. 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 must constitute a rejection of the entire permit and upon such occurrence, this permit must 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 CDPHE. 1 COLO R A D O CO ter" Air Pollution Control Division 4 D88x8nentaPubt:)488,1bxw41re mane Page 4 of 7 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: DRAFT Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 November 26, Issued to Extraction Oil Et Gas, Inc for venting of 2018 gas from one low pressure separator (AIRS ID 004) Issuance 2 This Issuance Issued to Extraction Oil Et Gas, Inc. Updated permit limits and emission factors. �DPHE COLORADO CO Air Pollution Control Division 1 Jctw:rnene GI C+u :1,eer£Evw,Tanr nt 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 must 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 must 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 AIRS Uncontrolled Controlled Equipment ID Point Pollutant CAS# Emissions . Emissions (lb/yr) (lb/yr) Benzene 71432 ,. 3,048 152 Toluene 108883 2,960 148 F ; LP Separator Ethylbenzene 100414 241 12 004 Venting Xylenes 1330207 764 38 n-Hexane 110543 22,807 1,140 2,2,4- 540841 14 1 Trimethylpentane 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: Uncontrolled Controlled CAS# Pollutant Emission Factors Emission Source (lb/MMSCF) Factors (lb/MMSCF) NOx 119.27 119.27 AP-42, Table 13.5-1 CO 543.74 543.74 AP-42, Table 13.5-1 VOC 52,770 2,638.5 Extended gas analysis 71432 Benzene 134.04 6.702 Extended gas analysis 108883 Toluene 130.15 6.5075 Extended gas analysis 100414 Ethylbenzene 10.59 0.5296 Extended gas analysis 1330207 Xylene 33.60 1.6800 Extended gas analysis coP 1COLORADO CO „r Air Pollution Control Division "t I tkpoirt,c,ni ri Palo.Hevsra h Env;onment Page 6 of 7 Uncontrolled Controlled CAS# Pollutant Emission Factors Emission Source (lb/MMSCF) Factors (lb/MMSCF) 110543 n-Hexane 1,003 50.15 Extended gas analysis 540841 2, 0.6294 0.6294 0.0315 Extended gas analysis Trimethylpentane 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 must 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 Status Requirement Operating Permit Synthetic Minor Source of: V0C, HAPs NANSR Synthetic Minor Source of: V0C 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 * come COLORADO ; CO �� i Air Pollution Control Division tmente4v 2xx Heath a ttivvonment Page 7 of 7 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Ben Fischbach Package It: 419926 Received Date: 9/25/2019 Review Start Date: 2/27/2020 Section 01 - Facility Information Company Name: Extraction Gil & Gas, Inc. Quadrant Section Township Range County AIRS ID: 123 Plant AIRS ID: 9A22 Facility Name: Schlotthauer 4-26 Production Facility Physical Address/Location : SESE quadrant of Section 23, Township EN, Range 67W County: Weld County Type of Facility: ExpIoraLion & Production We i i zu What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutant? Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only Permit # AIRS Point # Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks has already assigned) assigned) Permit Separator Verituig LP Separator Venting 18WE0338 codification Section 03 - Description of Project Applicant is requesting to lower throughput limit for this source in order to maintain synthetic minor facility status given re-designation of DMNFR NAA status. As this is a request for a new synthetic minor permit limit wrt NANSR/TV thresholds, a public comment period is required. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? RequestsngSynthet�c;_M►nor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) ✓ 1-51 Non-Attainment New Source Review (NANSR) ✓ Is this stationary source a major source? If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) ■ . Non-Attainment New Source Review (NANSR) __ Separator Venting Emissions Inventory Section 01 - Administrative Information Facility AIRs ID: 123 _ ? 004 County Plant Point Section 02 - Equipment Description Details Low Pressure Separator Venting Detailed Emissions Unit Description: ECD Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: 95 Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 19.0 MMscf per year Requested Permit Limit Throughput = 22.7 MMscf per year Requested Monthly Throughput = 1.9 MMscf per month Potential to Emit (PTE) Throughput = 22.7 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: 1754.0 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: scf/bbl Control Device Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf Section 04 - Emissions Factors & Methodologies Description Emission factors are mostly based off of a gas sample collected from a LP separator at a nearby site (RBF Stromberger) to estimate emissions (same basis as CP1 of this permit). However, emission factors for VOC, n-Hexane, and Ethylbenzen have been revised (see technical analysis notes section). Old MW r 22.3 Ib/Ib-mol Displacement Equation 34.0767 Ex = Q * MW * Xx / C Weight % Weight % Helium 1.0 0.1246 CO2 3.0 2.5508 N2 4.7 0.5021 methane 52.8 16.3969 ethane 14.4 21.667 propane 11.0 29.1431 isobutane 1.6 4.5137 n-butane 4.9 12.6484 isopentane _ 1.3 2.9572 n-pentane 1.6 3.7267 cyclopentane 0.2 0.2724 n-Hexane 0.5 1.1168 cyclohexane 0.2 0.2935 Other hexanes 1.0 1.7606 heptanes 0.5 0.9845 methylcyclohexane 0.3 0.3303 224-TMP 0.0 0.0007 Benzene 0.1 0.1493 Toluene 0.1 0.145 Ethylbenzene 0.0 0.0107 Xylenes 0.1 0.0374 C8+ Heavies 0.8 0.6684 Total 100.0 100.0001 VOC Wt % 24.0 58.7587 2 of 8 K:\PA\2018\18WE0338.CP2 Separator Venting Emissions Inventory Emission Factors Separator Venting Operator/APEN/Permit Values Uncontrolled Controlled Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) (lb/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) (Gas Throughput) (Gas Throughput) VOC 14162.8348 708.1417 52770 2638.5 Benzene 60.1011 3.0051 Extended gas analysts 134.04 6.702 Toluene 69.8823 3.4941 Extended gas analysis 130.15 6.5075 Ethylbenzene 10.5927 0.5296 - Extended gas analysis 10.5927 0.529633446 Xylene 33.0556 1.6528 Extended gas analysis 33.6 1.68 n-Hexane 315.6489 15.7824 Extended gas analysis 1002.95 50.1475 224 TMP 0.4125 0.0206 ' ±rndi.40s 4t y k. 0.6294 0.03147 Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) P M 10 - 0.0000 PM2.5 0.0000 _ SOx 0.0000 NOx 0.0680 119.2720 CO 0.3100 543.7400 Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM 10 0.0000 PM2.5 0.0000 SOx 0.0000 N O x 0.0000 CO 0.0000 Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.0 0.0 0.0 0.0 0.0 0 PM2.5 0.0 0.0 0.0 0.0 0.0 0 SOx 0.0 0.0 0.0 0.0 0.0 0 NOx 1.4 1.1 1.1 1.4 1.4 230 VOC 600.0 500.0 25.0 600.0 30.0 5096 CO 0.0 5.2 5.2 6.2 6.2 1050 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 3048 2540 127 3048 152 Toluene 2960 2466 123 2960 148 Ethylbenzene 241 201 10 241 12 Xylene 764 637 32 764 38 n-Hexane 22807 19006 950 22807 1140 224 TMP 14 12 1 14 1 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is not subject to Regulation 7, Section XV1I.B.2, G Regulation 7, Section XVI I.B.2.e The control device for this separator is not subject to Regulation 7, Section XVI1.B.2.e (See regulatory applicability worksheet for detailed analysis) 3 of 8 K:\PA\2018\18WE0338.CP2 Separator Venting Emissions Inventory Section 07 - Initial and Periodic 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? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been 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. If no, the permit will contain an "Initial Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year? 111111111 If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer. Section 08 - Technical Analysis Notes Original issuance of this permit utilized emission factors which were based on an extended gas sample analysis of LP separator gas collected 1/29/2018 at the nearby RBF Stromberger site. Operator submitted a self-certification package on 10/25/2019 which included a site-specific gas analysis. While the analysis demonstrated that most of the originally permitted emission factors were conservative, the originally estimated emission factor for Ethylbenzene was less than the Ethylbenzene emission factor calculated from the new gas sample analysis (i.e. Ethylbenzene was originally permitted at too low of an emission factor). I discussed the situation with the operator, who agreed to revise the ethylbenzene emission factors for this second issuance to match the emission factor predicted by the most current analysis. At that same time, the operator voiced some concerns about the originally permitted emission factor for VOC, as it disagreed with their historical records for permitting this point. After some research into the previously issued permit and its associated PA, we came to the conclusion that this difference in emission factors was due to a slight difference in the calculations (Division uses 379 scf/Ibmol while operator uses 379.48 scf/lbmol when estimating emission factors). As both of these values are commonly accepted, and considering that the difference in the two emission factors results in a negligible difference in emissions, will revise VOC emission factor on this permit to reflect a standard gas volume of 379.48 scf/lbmol. Similar situation occurred with n-Hexane, so I again revised that emission factor on this next permit issuance. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code Pollutant Uncontrolled Emissions Factor Control % Units 004 01 3-10-001-60 Flares PM10 0.0 0 lb/MMSCF SCC coding withpilot PM2.5 0.0 0 Ib/MMSCF emissions in lbs divic SOx 0.0 0 lb/MMSCF NOx 119.3 0 lb/MMSCF VOC 14162.8 95 Ib/MMSCF CO 543.7 0 Ib/MMSCF Benzene 60.1 95 lb/MMSCF Toluene 69.9 95 Ib/MMSCF Ethylbenzene 10.6 95 Ib/MMSCF Xylene 33.1 95 Ib/MMSCF n-Hexane 315.6 95 lb/MMSCF 224 TMP 0.4 95 Ib/MMSCF 4 of 8 K:\PA\2018\18WE0338.CP2 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B- APEN and Permit Requirements [Source is in the Non-Attainment Area 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)? You have indicated that source is in the Non•Attalnment Area 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)' Yes " Source Re 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)? Yes Source Re Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? No ' Source is i Source is not subject to Regulation 7, Section XViI.B.2, G 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? :`:•" S The contri p s� The control device for this separator is not subject to Regulation 7. Section XVII.B.2.e 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 establish legally binding requirements in and of itself. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name , Extraction Oil & Gas, LLC County AIRS ID 123 History File Edit Date 9/26/2018 Plant AIRS ID 9A22 Ozone Status Non-Attainment Facility Name Schlotthauer 4-26 Tank Battery EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.4 0.4 0.0 0.0 3.8 1 .691 .2 0.0 17.2 45.3 0.4 0.4 0.0 3.8 87.8 0.0 17.2 2.3 Existing Facility. The May 2015 tab incorrectly listed the Previous Permitted Facility total 0.4 0.4 0.0 0.0 3.8 1,691.2 0.0 17.2 45.3 0.4 0.4 0.0 0.0 3.8 87.8 0.0 17.2 2.3 controlled emissions at 39 tpy for Pt 001 . Since it is a GP08, contolled emissions should be 5.9 tpy 001 GP08 4-300 bbl condensate tanks 53.5 4.6 5.9 0.2 No change 002 12WE2747.CN Truck loadout 0.0 0.0 PTS: CANCELLATION NOTICE REC'D 5/1/2015 003 15WE1448.XP.CN 46 blip Compressco GJ230 Engine 0.0 0.0 Cancellation notice received 8/16/2018 004 18WE0338 LP separator venting during VRU 1 .4 600.0 6.2 14.9 1 .4 30.0 6.2 0.7 A PEN Moo - Updating Throughput downtime , 0.0 0.0 0.0 0.0 0.0 0.0, APEN Exempt/lnsignificants 0.0 0.0 XA Produced Water Storage Tanks 0.4 0 0 0.4 0.0 From APCD-102 Form XA Truck Loading 0.50 0.0 0.50 0.0 From APCD-102 Form XA Combustion Device Pilot Lights 0.1 0.50 0.2 0.0 0.1 0.50 0.2 0.0 From APCD-102 Form XA Separator Heater 0.2 0.00 0.2 0.0 0.2 0.0 0.2 0.0 From APCD-102 Form XA Fugitives 0.2 0.0 0.2 0.0 From APCD-102 Form 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.0 0.0 0.0 0.0 1.7 654.9 0.2 6.6 19.6 0.0 0.0 0.0 1.7 37.3 0.2 6.6 1.0 VOC: Syn Minor (NANSR and OP) NOx: True Minor (NANSR and OP) CO: True Minor (PSD and OP) HAPS: Syn Minor Permitted Facility Total 0.0 0.0 0.0 0.0 1.4 653.5 0.0 6.2 19.5 0.0 0.0 0.0 0.0 1.4 35.9 0.0 6.2 1.0 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions -0.4 -0.4 0.0 0.0 -2.4 -51.9 0.0 -11.0 Pubcom recuired. Modeling not required Total VOC Facility Emissions (point and fugitive) 37.5 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) -51 9 Project emissions less than 25/50 tpy Note 1 Note 2 Page 6 of 8 Printed 4/17/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Extraction Oil & Gas, LLC County AIRS ID 123 Plant AIRS ID 9A22 Facility Name Schlotthauer 4-26 Tank Battery Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP08 4-300 bbl condensate tanks 1602 7621 4.6 002 12WE2747. CN Truck loadout 0. 0 003 15WE1448.XP.CN 46 bhp Compressco GJ230 Engine 0.0 004 18WE0338 LP separator venting during VRU downtime 3053 2965 765 22834 14.9 0.0 0.0 0.0 APEN Exempt/Insignificants 0.0 XA Produced Water Storage Tanks - 0.0 XA Truck Loading 0.0 XA Combustion Device Pilot Lights 0.0 XA Separator Heater 0.0 XA Fugitives 0.0 0.0 0.0 0.0 TOTAL (tpy) _ 0.0 0.0 0.0 2.3 1 .5 0.1 0.4 15.3 0.0 0.0 0.0 0.0 19.6 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 7 18WE0338.CP2 4/17/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Extraction Oil & Gas, LLC County AIRS ID 123 Plant AIRS ID 9A22 Facility Name Schlotthauer 4-26 Tank Battery Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP08 4-300 bbl condensate tanks 80 381 0.2 002 12WE2747.CN Truck loadout 0. 0 003 15WE1448.XP.CN 46 bhp Compressco GJ230 Engine 0. 0 004 18WE0338 LP separator venting during VRU downtime 153 148 I 38 1142 0.7 0.0 0.0 0.0 APEN Exempt/Insignificants 0.0 XA Produced Water Storage Tanks 0.0 XA Truck Loading L 75 0.0 XA Combustion Device Pilot Lights 15 0.0 XA Separator Heater 0.0 XA Fugitives 2 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.1 0.1 0.0 0.0 0.8 0.0 0.0 0.0 0.0 1 .0 8 18WE0338.CP2 4/17/2020 aM�M?M Air Pollution Control Division �YtM1 Notice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: Extraction Oil £t Gas, Inc. - Schlotthauer 4-26 Production Facility - Weld County Notice Period Begins: April 23, 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: Schlotthauer 4-26 Production Facility Exploration a Production Well Pad SWSW SEC 23 T6N R67W Weld County The proposed project or activity is as follows: Applicant proposes a reduction in throughput in order to maintain synthetic minor facility status with serious non-attainment thresholds. 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 18WE0338 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/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: Ben Fischbach Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 (COLORADO 1 I ge Department of Public Health 8 Environment Hello