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Home My WebLink About20200703.tiffpublic Rev:ew o3/O4/2O COLORADO Department of Public Health £r Environment Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 February 6, 2020 Dear Sir or Madam: RECEIVED FEB 18 2020 WELD COUNTY COMMISSIONERS On February 7, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil £t Gas, Inc. - Cito Trust Production Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director Cc: PLOP), H 1.(i -K), P H/ER/cH/G O Om) o247/a 2020-0703 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil a Gas, Inc. - Cito Trust Production Facility - Weld County Notice Period Begins: February 7, 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: Cito Trust Production Facility E&P Well Pad Site NWNW SEC 01 T4N R68W Weld County The proposed project or activity is as follows: The applicant proposes to permit a new oil and gas production facility located within the eight -hour (8 -hr) Ozone Control Area of Weld County. Emission points with this facility include condensate tanks, produced water tanks, condensate loadout, and separator gas flaring. 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): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • 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 19WE0793 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: Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 COLORADO Department of Public Health Et Environment Denver, Colorado 80246-1530 21 COLORADO Department et Public Health b Environment C4i COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0793 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Extraction Oil Et Gas, Inc. Cito Trust Production Facility 123/A076 NWNW SEC 01 T4N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS. Point Equipment. Description Emissions Control i Descripton 001 Eight (8) 400 bbl fixed roof condensate storage tanks Enclosed Combustion Devices This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I. F.4. ) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The, operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. " VOC CO 001 - --- 3.6 --- Point Nnte : SPe "Nntes 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. 7. 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. Page 2 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. 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 Equipment ID AIRS Point Control Device Pollutants Controlled --- 001 Enclosed Combustion Devices VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. 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, I1.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit 001 Condensate throughput 674,471 barrels The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits mustbe 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. 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) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This source is subject to Regulation Number 7, Section XII. The operator must comply with all applicable requirements of Section XII and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other Page 3 of 8 COLORADO Air Pollution Control Division Department of Public Health & tm*onment Dedicated to protecting and improving the health and environment of the people of Colorado means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1,' 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVIIC! 2. OPERATING £t MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 19. 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 annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions.. of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 20. 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. 21. 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. Page 5 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. 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. 24. 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 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. 25. 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. 26. 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: Christopher Kester Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Page 6 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. AIRS Point Pollutant - CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 371 19 Toluene 108883 289 14 n -Hexane 110543 2,726 136 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/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: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bb( Source VOC 0.211 0.01055 Promax simulation based on site -specific pressurized liquid sample 71432 Benzene 0.00055 0.000027 108883 Toluene 0.00043 0.000021 110543 n -Hexane 0.00403 0.000202 Note: The controlled emissions factors for this point are based on a 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 Page 7 of 8 COLORADO Aix Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP NANSR Synthetic Minor Source of: VOC, NOx PSD True Minor Source of: CO 9) Full text of the. Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part. 60, Appendixes Appendix A- Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MALT' 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 Page 8 of 8 p!�!M jGr COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0794 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Extraction Oil Et Gas, Inc. Cito Trust Production Facility 123/A076 NWNW SEC 01 T4N R68W Weld County Well Production Facility Equipment or activity subjectto this permit: Equipment ID AIRS Point Equipment Description' Emissions Control Description 002 Low pressure gas stream from seven (7) high -low pressure 3 -phase separators. Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act i(C.R.S. 25-7-101 et seq), to this specificgeneral terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - certify compliance as required by this permit may be obtained online at Page 1 of 13 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Upon commencement of operation of this emissions source, the operator must install a flow meter to monitor and record volumetric flow rate of natural gas routed to the flare from the separators covered by this permit. 5. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section 1II.E.) 6. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO --- 002 --- --- 8.4 4.1 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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. Page 2 of 13 COLORADO Air Pollution Control Division Department of Publtc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 8. 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. 9. 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.) Equipment ID AIRS Point Control Device Pollutants Controlled --- 002 Enclosed Combustion Device (Make: Questor, Model: Q5000, SN: Q5000-18-217) VOC and HAP PROCESS LIMITATIONS AND RECORDS 10. 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 Equipment ID AIRS Point Process Parameter Annual Limit --- 002 Natural Gas Venting 14.8 M1u1SCF 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. 11. Upon commencement of operation, the owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner 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. Page 3 of 13 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. On a minimum of an hourly basis, the owner or operator shall monitor the control device for the presence of a pilot light and an operational auto -igniter. These monitoring records shall be used to calculate control device downtime. During periods without the presence of a pilot light and/or an operational auto -igniter, the owner or operator shall assume a 0% control efficiency. These monitoring records must be maintained for a period of five (5) years. STATE AND FEDERAL REGULATORY REQUIREMENTS 13. 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) 14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 15. Tile combustion device covered by this permit is subject to Regulation Number 7,', Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVIl', it must bes enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the ' Division, determine whether it is operating property. This flare must be equipped with an operational auto -igniter according to the following schedule: All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 16. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions Page 4 of 13 je,4 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado to the 0&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. The owner or operator must conduct an initial source compliance test to measure the mass emission rates of the pollutants listed below, demonstrate compliance with the emissions limit in this permit, and to demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC). During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (M;) using EPA or other division approved methods; • mass emission rates of VOC at the outlet of the control device (M0) using EPA or other division approved methods; and mass emission rates of NOx and CO at the outlet of the control device using EPA or other division approved methods. Additionally, the following parameters may be required to be measured during the test: combustion chamber temperature; • gas flow rate; • supplemental fuel flow, rate; • gas heat content; and gas composition. The destruction efficiency for VOC must be calculated using DE (%) = 100*(Mi-Mo)/Mi The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) he following equation: Results of the initial compliance tests must be submitted to the Division as part of the self - certification. Periodic Testing Requirements - 19. On an annual basis, the owner or operator must conduct a source compliance test to measure the mass emission rates of the pollutants listed below, demonstrate compliance with the Page 5 of 13 COLORADO Ai: Pollution Control Division Department of Pubic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado emissions limit in this permit, and to demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC). During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (M;) using EPA or other division approved methods; • mass emission rates of VOC at the outlet of the control device (MO using EPA,or other division approved methods; and • mass emission rates of NOx and CO at the outlet of the control device using EPA or other division approved methods. Additionally, the following parameters may be required to be measured during the test: • combustion chamber temperature; • gas flow rate; • supplemental fuel flow rate; • gas heat content; and gas composition. The destruction efficiency for VOC must be calculated using DE (%) = 100*(Mi-Mo)/Mi The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to'''testing. No compliance test will be conducted without prior approval from the Division.. Within thirty (30) days following completion of the test(s), a compliance test reportmust be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with an annual emission limitation shall have the results projected up to the annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Records of the annual compliance tests must be maintained by the owner or operator and made available to the Division for inspection upon request. ALTERNATIVE OPERATING SCENARIOS 20. The control device may be replaced with a Like -kind control device in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this permit or obtaining a new construction permit. A like -kind control device shall be the same make and model as authorized in this permit. All control device replacements installed and operated as authorized by this permit must comply with all terms and conditions of this construction permit. The owner or operator shall maintain a log on -site or at a local field office to record the start and stop dates of any control device replacement, the manufacturer, model number and serial number of the replacement control device. 21. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model, and serial number of the replacement control device must be filed with the Division within 14 calendar days of commencing operation of a replacement control device under the Alternate he following equation: Page 6 of 13 Nue COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Operating Scenario provision. The APEN must be accompanied by the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an Alternate Operating Scenario and has replaced the control device. 22. Within one hundred and eighty days (180) of startup of the replacement control device in accordance with the Alternate Operating Scenario provision, the owner or operator must conduct an initial source compliance test to measure the mass emission rates of the pollutants listed below, demonstrate compliance with the emissions limit in this permit, and to demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC). During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (Mi) using EPA or other division approved methods; • mass emission rates of VOC at the outlet of the control device (M0) using EPA or other division approved methods; and • mass emission rates of NOx and CO at the outlet of the control device using EPA or other division approved methods. Additionally, the following parameters may be required to be measured during the test: combustion chamber temperature; • gas flow rate; • supplemental fuel flow rate; gas heat content; and • gas composition. The destruction efficiency for VOC must be calculated using the following equation: DE (%) = 100*(Mi-Mo)/Mi The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Records of the annual compliance tests must be maintained by the owner or operator and made available to the Division for inspection upon request. ADDITIONAL REQUIREMENTS Page 7 of 13 COLORADO Air Pollution Control Division Department of Public Health B Environment Dedicated to protecting and improving the health and environment of the people of Colorado 23. 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 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 pollutan If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 24. 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. 25. 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 Page 8 of 13 Eli COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 26. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 27. 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. 28. 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 prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act : and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 29. 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. 30. 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: Christopher Kester Permit Engineer Permit History Page 9 of 13 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil £t Gas, Inc. Page 10 of 13 COLORADO Air Pollution Control Division Department of Public Health & Enviaonment Dedicated to protecting and improving the health and environment of the people of Colorado 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/agcc-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 sources operates at the permitted limitations. Equipment D AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) --- 002 Benzene 71432 2,706 54 Toluene 108883 3,408 68 Ethylbenzene 100414 372 7 Xylenes 1330207 1,574 31 n -Hexane 110543 22,240 445 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/yr) are reportab e and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 11 of 13 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source CO 0.31 lb/MMBtu 0.31 lb/MMBtu AP -42 VOC 56,797 1,136 Gas Sample Analysis 71432 Benzene 183.44 3.67 108883 Toluene 230.97 4.62 100414 Ethylbenzene 25.12 0.50 1330207 Xylene 106.60 2.13 110543 n -Hexane 1,507.32 30.15 Note: The controlled emissions factors for this point are based on a control efficiency of 98%. 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 Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP NANSR Synthetic Minor Source of: VOC, NOx PSD True Minor Source of: CO 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU 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 Page 12 of 13 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Page 13 of 13 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0795 Issuance: 1 Date issued: Issued to: Extraction Oil Et Gas, Inc. Facility Name: Cito Trust Production Facility Plant AIRS ID: 123/A076 Physical Location: NWNW SEC 01 T4N R68W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description - 003 One Vapor Recovery Tower Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Actl(C.R.S. 25-7-101 et se.q), 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. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - certify compliance as required by this permit may be obtained online at Page 1 of 13 CEP%zo COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Upon commencement of operation of this emissions source, the operator must install a flow meter to monitor and record volumetric flow rate of natural gas routed to the flare from the separators covered by this permit. 5. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III E ) 6. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO --- 003 --- --- 9.0 3.1 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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. Page 2 of 13 COLORADO Aix Pollution Control Division Department of Public Hearth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 8. 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. 9. 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.) Equipment ID AIRS Point Control Device Pollutants Controlled --- 003 ' Enclosed Combustion Device (Make: Questor, Model: Q5000, SN: Q5000-18-217) VOC and HAP PROCESS LIMITATIONS AND RECORDS 10. 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 Equipment ID AIRS Point Process Parameter Annual Limit --- 003 Natural Gas Venting 7.9 MMSCF 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. 11. Upon commencement of operation, the owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner 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. Page 3 of 13 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. On a minimum of an hourly basis, the owner or operator shall monitor the control device for the presence of a pilot light and an operational auto -igniter. These monitoring records shall be used to calculate control device downtime. During periods without the presence of a pilot light and/or an operational auto -igniter, the owner or operator shall assume a 0% control efficiency. These monitoring records must be maintained for a period of five (5) years. STATE AND FEDERAL REGULATORY REQUIREMENTS 13. 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) 14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 15. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to controlemissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 16. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEtM) 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 Page 4 of 13 COLORADO Air Pollution Control Division Department of PublicHealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado to the OEtM 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 18. The owner or operator must conduct an initial source compliance test to measure the mass emission rates of the pollutants listed below, demonstrate compliance with the emissions limit in this permit, and to demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC). During the test, the owner or operator must measure: • • mass emission rates of VOC at the inlet of the control device (MO using EPA or other division approved methods; mass emission rates of VOC at the outlet of the control device (M0) using EPA or other division approved methods; and mass emission rates of NOx and CO at the outlet of the control device using EPA or other division approved methods. Additionally, the following parameters may combustion chamber temperature; gas flow rate; supplemental fuel flow rate; gas heat content; and gas composition.' be required to be measured during the test: The destruction efficiency for VOC must be calculated using the following equation: DE (%) = 100*(Mi-Mo)/Mi The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Results of the initial compliance tests must be submitted to the Division as part of the self - certification. Periodic Testing Requirements 19. On an annual basis, the owner or operator must conduct a source compliance test to measure the mass emission rates of the pollutants listed below, demonstrate compliance with the Page 5 of 13 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado emissions limit in this permit, and to demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC). During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (M;) using EPA or other division approved methods; • mass emission rates of VOC at the outlet of the control device (Me) using EPA or other division approved methods; and • mass emission rates of NOx and CO at the outlet of the control device using EPA or other division approved methods. Additionally, the following parameters may be required to be measured during the test: • combustion chamber temperature; • gas flow rate; • supplemental fuel flow rate; • gas heat content; and gas composition The destruction efficiency for VOC must be calculated using the following equation: DE (%) = 100*(Mi-Mo)/Mi The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test, protocol must besubmitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with an annual emission limitation shallhave the results projected up to the annual. averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Records of the annual compliance tests must be maintained by the owner or operator and made available to the Division for inspection upon request. ALTERNATIVE OPERATING SCENARIOS 20. The control device may be replaced with a like -kind control device in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this permit or obtaining a new construction permit. A like -kind control device shall be the same make and model as authorized in this permit. All control device replacements installed and operated as authorized by this permit must comply with all terms and conditions of this construction permit. The owner or operator shall maintain a log on -site or at a local field office to record the start and stop dates of any control device replacement, the manufacturer, model number and serial number of the replacement control device. 21. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model, and serial number of the replacement control device must be filed with the Division within 14 calendar days of commencing operation of a replacement control device under the Alternate Page 6 of 13 laNto COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Operating Scenario provision. The APEN must be accompanied by the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an Alternate Operating Scenario and has replaced the control device. 22. Within one hundred and eighty days (180) of startup of the replacement control device in accordance with the Alternate Operating Scenario provision, the owner or operator must conduct an initial source compliance test to measure the mass emission rates of the pollutants listed below, demonstrate compliance with the emissions limit in this permit, and to demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC). During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (Mi) using EPA or other division approved methods; • mass emission rates of VOC at the outlet of the control device (M0) using EPA or other division approved methods; and • mass emission rates of NOx and CO at the outlet of the control device using EPA or other division approved methods. Additionally, the following parameters may be required to be measured during the test: combustion chamber temperature; gas flow rate; supplemental fuelflow rate; gas heat content; and gas composition. The destruction efficiency for VOC must be calculated using the following equation: DE (%) = 100*(Mi-Mo)/Mi The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Records of the annual compliance tests must be maintained by the owner or operator and made available to the Division for inspection upon request. ADDITIONAL REQUIREMENTS Page 7 of 13 COLORADO Air Pollution Control Division Department of Publtc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 23. 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 (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual' emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of, any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 24. 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. 25. 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 Page 8 of 13 COLORADO Air Pollution Control Division Department of Public Health & Ehvfronment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 26. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 27. 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. 28. 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 prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission'(AQCC), including failure to meet, any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 29. 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. 30. 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: Christopher Kester Permit Engineer Permit History Page 9 of 13 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Page 10 of 13 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 sources operates at the permitted limitations. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) --- 003 Benzene 71432 2,460 49 Toluene 108883 1,832 37 Xylenes 1330207 496 10 n -Hexane 110543 23,520 470 Note: Ail non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportab e 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: CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source CO 0.31 lb/MMBtu 0.31 lb/MMBtu AP -42 Page 11 of 13 COLORADO Air Pollution Control Division Department of Public Health & Envirorment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source VOC 114,606 2,292 Gas Sample Analysis 71432 Benzene 314.55 6.29 108883 Toluene 234.44 4.69 100414 Ethylbenzene 14.69 0.29 1330207 Xylene 63.33 1.27 110543 n -Hexane 3,007.17 60.14 Note: The controlled emissions factors for this point are based on a control efficiency of 98%. 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 Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP NANSR Synthetic Minor Source of: VOC, NOx PSD True Minor Source of: CO 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.Qov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU 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 Page 12 of 13 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 13 of 13 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0796 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Extraction Oil &t Gas, Inc. Cito Trust Production Facility 123/A076 NWNW SEC 01 T4N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point' Equipment ' Description Emissions Control Description - 004 Truck loadout of condensate Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C. R. S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Reference: Regulation Number 3, ''Part B, Section II.A.4) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO --- 004 --- --- 0.5 --- Point ote: 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. 6. 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. Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. 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.) Equipment ID AIRS Point Control Device Pollutants Controlled --- 004 Enclosed Combustion Device VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Equipment ID AIRS Point Process Parameter Annual Limit --- 004 Condensate Loaded 67,447 barrels The owner or operator must calculate monthly process rates based on the calendar month. 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 monthand keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. Condensate loading to truck tanks must be conducted by submerged fill. (Regulation Number 3, Part B, III.E) STATE AND FEDERAL REGULATORY REQUIREMENTS 10. 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.) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Page 3 of 10 COLORADO Air Pollution Control Division Department of PublicHealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill and emissions must be controlled by a flare. (Regulation 3, Part B, III.D.2) 13. All hydrocarbon liquid loading operations, regardless of size, must be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 14. The owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Regulation Number 3, Part B, III.E): a. The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections must occur at least monthly. Each inspection must be documented in a log available to the Division on request. All compartment hatches at the facility (including thief hatches) must be closedand latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 15. For this controlled loading operation, the owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado OPERATING £t MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OIM) 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 your O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic. Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) Annually by April 30' 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 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. 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 Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 20. 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. 21. 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 wilt 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. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation ; and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. 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. 24. 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 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. 25. 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 Page 6 of 10 40 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado in writing requesting a cancellation of the permi . Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provis ons of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC ay result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (e forcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Permit History Date Issuance Description Issuance 1 This Issuance Issued to extraction Oil It Gas, Inc. Page 7 of 1 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled. Emissions (lb/yr) n -Hexane 110543 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: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source V0C 0.2720 0.0136 AP -42 n -Hexane 110543 0.00519 0.00026 The uncontrolled V0C emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado P (true vapor pressure) = 7.26 psia M (vapor molecular weight) = 62 lb/lb-mol T (temperature of liquid loaded) = 519.67 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 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 fiveyears 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 Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP NANSR Synthetic Minor Source of: VOC, NOx PSD True Minor Source of: CO 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http: / /www. ecf r. Roy / Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU 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 Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Page 10 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0015 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Extraction Oil Et Gas, Inc. Cito Trust Production Facility 123/A076 NWNW SEC 01 T4N R68W Weld County Well Production Facility Equipment or activity subjectto this permit: Facility Equipment ID I AIRS Point •Emissions Equipment Description Control Description 008 Two (2) 400 bbl fixed roof produced water storage tanks Enclosed Combustion Devices This permitis granted subject to all rules and regulations :of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 8 COLORADO Air Pollution Control Division Department of PublicHealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current constructionpermit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point . Tons per Year Emission Type PM2.5 NO. VOC CO 008 - --- 0.6 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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. 7. The owner or operator must use the emission factors found in "Notes to Permit" 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. Page 2 of 8 C° COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. 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 Equipment ID AIRS Point Control Device Pollutants Controlled --- 008 Enclosed Combustion Devices VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. 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 Equipment ID AIRS Point Process Parameter Annual Limit 008 Produced Water throughput 196,594 barrels The owner or operator must monitor monthly process rates based on the calendar month. 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. 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) 11. 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.) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means Page 3 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.C.1..d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O£tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. 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 Page 4 of 8 COLORADO Air Pollution Control Division Department of PublicHealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 20. 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. 21. 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. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. 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. 24. 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 Page 5 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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. 25. 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. 26. 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. Bv: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Page 6 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 008 n -Hexane 110543 ' 1,543 77 Note: Alt non -criteria reportable; pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/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: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.1182 0.0059 Flash liberation sample analysis 110543 n -Hexane 0.0079 0.0004 Note: The controlled emissions factors for this point are based on a 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 permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. Page 7 of 8 COLORADO Air Pollution Control Division Department of Publtc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP NANSR Synthetic Minor Source of: VOC, NOx PSD True Minor Source of: CO 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU 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 Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Christopher&ester,,. Package#: 403503,&423263 -; Received Date: 8/2/2019&12/17/2019 Review Start Date: 1/9/2019 ._. , Section 01-Facility Information Company Name: Ex tractiarrstht&$i5slinc ' Quadrant Section Township Range County AIRS ID: 123 a 0, sr Plant AIRS ID: gD76 it t f Facility Name: , .. a� - 4i1N!';[Tiglif Physical Address/Location: Section,Township,Range W County: Weld County Type of Facility: Exptaratian,&Production Well Pad _-- - - What industry segment?088s Natur-at as Prsduc ion44Processing, Is this facility located in a NAAQS non-attainment area? Yes:' If yes,for what pollutant? Ozone 640x&VOC). Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only Permit# AIRS Point# Emissions (Leave blank unless Issuance Self Cart (Leave blank unless APCD Emissions Source Type Equipment Name Action Engineering Remarks Control? APCD has already # Required? has already assigned) assigned) Permit Initial 001 Condensate Tank Yes 19WE0793 1 Yes Issuance, Permit Initial LP Separator&98% 002 Separator.Venting Yes 19WE0794 1 Yes issuance = requested Permit initial. VR T&98'% 003 Separator Venting Yes 19WE0795-_ 1 Yes Issuance requested Permit Initiate, 004 4 Liquid Loading Yes 19WE0796 1 Yes issuance Permit Initial. 008 PrOdiled Wafer Tank Yes 20WE0015-. 1 ',Yes issuance- - • Section 03-Description of Project New Synthetic minor permit in non attainment area.Permit is<50tpy and will he synthetic minor when issued r• Sections I04,OS&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? 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: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD)- Title V Operating Permits(OP) J ✓ ✓ E Non-Attainment New Source Review(NANSR) ✓ ✓ •Is this stationary source a major source? f A)cr Colorado Air Permitting Project '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) El El Non-Attainment New Source Review(NANSR) Instructions(See'mouse-over'comment) Data for Drop Down Lists Facility Type List Exploration&Production Well Pad Natural Gas Compressor Station Natural Gas Processing Plant Produced Water Injection Facility Produced Water Management Facility Oil Stabilization(Exploration&Production) Oil Storage and Pipeline Injection Natural Gas Storage Other(Describe facility type in Section 03) Emission Point List Amine Unit Condensate Tank Crude Oil Tank Dehydrator Diesel RICE Fugitive Component Leaks Liquid Loading Maintenance Blowdowns Natural Gas RICE NG Heater Pneumatic Pump Process Flare Produced Water Tank Produced Water Pond Separator Venting Turbine Other(Explain) Emissions Control List Enclosed Flare Leak Detection and Repair Program Non-Selective Catalytic Reduction(NSCR) • Open Flare Oxidation Catalyst Thermal Oxidizer -Vapor Recovery Unit to fuel system header Vapor Recovery Unit to plant inlet Permit Action Types APEN Exempt APEN Required/Permit Exempt Permit Initial Issuance Colorado Air Permitting Project Permit Modification Cancellation No Action Requested Facility Classifications • N/A Major Synthetic Minor True Minor Qualifiers No Yes Public Comment Requesting Synthetic Minor Permit Greater than 25 tons per year in Non-Attainment Area. Greater than 50 tons per year in an Attainment Area Alternative Control per Reg 7,Sec XII.D.2.b.(ii) Other(Division Discretion) NAAQS Pollutants Carbon Monoxide(CO) Particulate Matter(PM] Ozone(NOx&VOC) Industry Segment Oil&Natural Gas Production&Processing Natural Gas Transmission&Storage Condensate Storage Tank(s)Emissions Inventory Section 01-Administrative Information - - Facility AIRs ID: -`3,"-- .. ! 78,•,,,, 001:'County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit flight(0)41!11 lab!coniltn0ate storagey nliyF _ e� Z� '�v !: Description: Y �_ Emission Control Device E )f gedxCombu,46fake,'x r ' Description: s » kct � .,...,.. ©,,.� Requested Overall VOC&HAP Control Efficiency%: 9,Sri1,' Section 03-Processing Rate Information for Emissions Estimates _ Primary Emissions-Storage Tank(s)Actual Condensate Throughput= •• 'S62,BS1,'4!Barrels(bbl)per year Requested Permit Limit Throughput= 674,4?14 Barrels(bbl)per year Requested Monthly Throughput= 57293.3 Barrels(bbl)per month Potential to Emit(PTE)Condensate Throughput= 674$710,1 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) gym Heat content of waste gas= 'R 2405,4.'Btu/scf Volume of waste gas emitted per BBL of iy liquids produced= ' scf/bbl Actual heat content of waste gas routed to combustion device= 3,660.2 MMBTU per year Requested heat content of waste gas routed to combustion device= 3,660.2 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 3,660,2 MMBTU per year Control Device Pilot Fuel Use Rate: iscfh OA MMscf/yr Pilot Fuel Gas Heating Value: q"m :`:Btu/scf 0.0 MMBTU/yr Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? BEMIZEMME Uncontrolled Controlled Emission Factor Source Pollutant (lb/bbl) (Ib/hhl) - (Condensate (Condensate Throughput) Throughput) •0:`70 0 3/3 0.010000 0 001!64& /) 0.000027 - - B,DBtr422 ,'l 0.000021 Igtta- oititibicif5M 0.00000'1 0.000100% 0.000005 0,004030 ii> '�. dig 0;00461 0.000001 - Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Condensate ombostedl Throughput) i c 0.0070.:?,',", 0.0000 rd/>y 0.0076 0.0000 x r 0.0680 0.0008 t,i<l,k,d r..•�,1','I & INIMMIEMM 0.310&,- - 0,0000 w Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu( (lb/MMscf) Emission Factor Source (Waste Heat (Pilot Gas Combusted) Throughput) ®' _ 0.0000 0,0000 ylyi ®' 0,0000 4,0000 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) (Ibs/month) VOC 71.2 59,3 3.0 71,2 3.6 604.3 PM10 0.0 0.0 0.0 0,0 0,0 2..3 PM2.S 0,0 0,11 0.0 0,0 0.0 2.3 NOx 0.1 0.1. 0,.1 t₹,.I. 0,1 21.1 CO 0.6 0.6 0.6 0,6 0.6 96.4 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 370,0. 300,3 15,4 370,0 185 Toluene 284,6 237.2 11.0 284.6. 14.2 Ethylbenzene 14,2 - 11.9 0.6 14.2 0.7 Xylene 71,2 59,3 3.0 71.2 3.6 n-Hexane 2710.2 2265.2 113.3 2718.2 135.9 224 TMP 14,2 .11.9 0.6 .14.2 0,7 4 of 22 K:\PA\2019\19WE0793.CP1 Condensate StorageTank(s)Emissions inventory Section 06-Regulatory Summary Analysis Regulation 3,Ports A,B Source requires a permit Regulation 7,Section XII.C,D,E,F Storage tank is subject to Regulation 7,Section tlll.C-F _ Regulation 7,Section Xll.G,C Storage Tank is not subject to Regulation 7,Section X11,0 Regulation 7,Section XVII.%C.1,C.3 Storage tank is subject to Regulation 7,Section XVII,B,C.1&C.3 Regulation 7,Section XVII.C2 Storage tankis subject to Regulation 7,Section XVO.C.2 Regulation 6,Part A,NSPS Subpart Kb Storage Tank is nut subject to N5PS Kb Regulation 6,Part A,NSPS Subpart 0000 Storage tank is not subject to NSPS 0000. NSPS Subpart OOOOa Storage Tank is not subject to N5PS 0000a Regulation 8,Part E,MACrsubpart HI-I Storage Tank is not subject to MACC 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 greaterthan or equal in 80 tans VOC per year? If yes,the permit will contan an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. rawrgignirffirrwl 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 nY� T' new wells brought on-line),then it maybe 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 M:7_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-T hnlcal AnalY rs Not • d Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point# Process H SCC Code Pollutant Factor Control% Units ., �.�.., 001 01 • PM10 0.00 8 16/1,000 gallons condensate throughput PM2.5 0.00 0 Ib/1,000 gallons condensate throughput NOx 0.01 0 Ib/1,000 gallons condensate throughput VOC 5.0 95 lb/1,000 gallons condensate throughput CO 0.04 0 lb/1,000 gallons condensate throughput Benzene 0.01 95 lb/1,000 gallons condensate throughput Toluene 0.01 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 Ib/1,000 gallons condensate throughput Xylene 0.00 9.5 Ib/1,000 gallons condensate throughput n-Hexane 0.10 95 :ph/10 gallons condensate throughput 224 TMP 0.08 95 lb/1,000 gallons condensate throughput 5 of 22 K:\PA\2019\19WE0793.CP1 • • • • Condensate Tank Regulatory Analysis Worksheet The regulatory requirements-below are determined based on requested emissions. Colorado Raeo selee 3 Pere A and IS-ADEN and Permit Requirements Scurce is in the Nan:Attainmenf Area ATTAINMENT L Are uncontrolled actual emftsionstrots any criteria pollutants from this lndMdual source greOerthan 2 TPY(Regulation 3,Part A,Section ll.D.La)? 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 2for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5TPY,NOx greater than 1OTPY or 00 emissions greater than SO TM'(Regulation 3.Part B,Section 11.03)? lyou ham indicated that macro is in Me Non.ACtainment Area NON-ATTAINMENT e� 1 Are uncontrolled emissions from any criteria pollutants from this individual soumegreaterfhan 1TPY(Regulation 3,Part A,Section 5.0.1.a)? ''"' F Source Requires an OPEN.Go to 1051 2. Is the construction date(servicedate)priorto 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)? nit i/1, Go to next quertlon 3. Are 8atal facility uncontrolled VOC emissions greater than 2TPY,NOe greater than 5TPV or CO emissions greater than lO TPY(Regulation 3,Part B,Section 11.1.2)7 /ii tiv Source Requires a permit I5::urre requires a pr_ndt • Colorado Regulation 7.Section XII.C-F L is this storage tank located in the&hr ozone control area or any ozone non-attainment area or attainment/maintenance area? Yes Continue-You have indicated ttit2. Is this storage tank located at an oil and gm exploration and production operation',natural gm compressor station or natural gas drip station? Yes Continue-You have indicatedth 3. Isthie storage tank located upstseam of a natural gas processing plant?' MI5 Source Is subject 'Storage tank is s:rnlrut Lit Rennie:don?,5ectian YII.C-F Section XII.Gt—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Section XII.C.2—Emission Estimation Procedures Section XII.D—Emissions Control Requirements Section Xll.E—Monitoring Section Xll.F—Remrdkeeping and Reporting Colorado Regulation 7,Section 011.0 1. Is this storage tank located in the e-hr clone control area tar any axone non-attainment area or attainment/maintenance area? - Continue-You have determined 2. b this storage tank located at a natural gas processing plant? No Storage Tank is not subject to Re 3. Does this staragetank exhibit'Flash"(e.g.storing non-stabilized liquids)emissions and have uncontrolled actual emissions greater than or equal to 280ns per veer VOC? ISturave Tank is not subject to Regulation 7,0µ::10n 00.0 Section XIl.G.2-Emissions Contra)Requirements Section 01.51—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Section)01.C.2—Emission Estimation Procedures Colorado Regulation 7.Section XVI I 1. Is this tank located at a transmission/storage facility? N0 Continue-You have indicatedth 2, Is thiscondensee storage tank'baited at an oR and gas exploration and production operation,well production facility',natural gas compressor stations or natural gas processing plant? Yes Go to the next question-You ha 3. I this condensatestarage tankafoed roof storage tank? fp3o Go to the next question 4, Areuncentrolled actual emissions'of this storage tank equal tour greaterfhan Goons peryear'VOC? "ljluy,) Source Is subject to parts of Reg, (Storage tank Is subject.Regulation 7.Seddon;Pill.B.C.1&C.3 Section 1MI.B—General Provisions for Air Pollution Contml Equipment and Prevention of Emissions Section XVIl.C.1-Emissions Control and Monitoring Provisions anntoe053I.C.3-RecordkeepinmOequlrements S. Does the condensate Aar etank centaln oral"A bilized"ii uids7 /i;:i...j.�Source is subject to all provision .Sturare tank.Iauihleci.Ragule;lor.7,Section XVg.C.7. Section JMI.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR,Part 60.Subpart Kb.Standards of Performance far Volatile Organic Donk(Storage Vessels 1. Is the individual storage vessel capacitygreaterthan or equal to 75 cubic meters(me)1-472 natal? Storage Tank's not subled NSPS • 2. Dees the storage vessel meet₹hefollowing exemption in 60.111b(d)1417 a.Does the vessel has a design capacity less than or equal to 1,509.874 me[^10,000 BBL]used for petroleum'or condensate stored,processed,or treated prior to custody transfer'as defined In 60.111b? 3. Westhk Condensate storage tank camtructed,reconstructed,or modified(see dermitiom 40 CFR,60.2)after July 23,1984? 4. Does the tank meet the definition of"storage vessel'in 60.111b? S. Does the storage vessel store a"volatile organic liquid(VOL)"'as defined in 60.111b? AMMO • 6. Does the storage vessel meet anyone of thefollowing additional exemptions: ms's a.Is the storage vessel a pressure vessel designed.operate in excess of 2049 hra["29.7 psi]and without emissions t0 the atmosphere(60.110b(d)(2()7;or b.The design capacity its greater than or equal to 151 me['150 BBL]and stores a liquid with a maximum true vapor pressures less than 3.5 kPa(60.11ob(b))?;or c.The design capacity is greaterthan or equal to 75 Ms[^472 BBL]but less than 151 ms[`950 BBL]and stores a liquid with a mximum true vapor pressure'less than 15.0 kPa(60.130b(b))7 Ing."Ittatj 7. Does the storage tank meet either one of the following exemptions from control requirements: l a.The design capacity is greater than or equal to151me(`950 BBL]and stores a liquid with a maximum true vapor pressure greaterthan or equal to 3.5 kPa but less than 5.2 kPa7;or p_: b.The design capacity is greater than or equal to 75 M5(-472 BBL]but less than 151 ms[-950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 line but less than 27.6 k's? [storage rank is MIS Sti m m te NSPS 00 • 40 CFR.Part 60.Subpart 0000/0000x,Standards of Performance for Crude Oll and Natural Gas Production,Tran amislon and Distribution _ 1. Is this condensate rtorage 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? Yes Continue-You have lndicatedth 2 Was this condensate storage vessel constructed,reconwtruded or modified(see definitions 40 CFR,60.2)between August 23,2011 and September 18,2015? [ion s Storage Tank is not subject NSPS 3. Was this condensate storage vesselconstm<fed,recornstructed,or modified(see definitions 40 CFR,60.2)after september 18,2015? /7/20 Go to the next question 4. Are potential VOCemissions'from the lndnidual storage vessel greater than or equal to goons per year? _ 1tt i,Storage Tank is not subject NSPS 5. Doe this condensatestorage vessel meet the definition of"storage vessel"z per 60.5430/605430a? IMAM 6. Is the storage vessel subfectm and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb er 40 CFR Part 63 Subpart HH? 'Steno,rank is,vst suilactto NSPS 0W05 • (Note:If a storage vessel Is prerasly determined to be subject to N5P5 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination dam,It should remain subject.NSPS 0000/0000a per 6D5365(e)(2)/60.5365a(e](1)even If potential VOC emissions drop below 60ns per year] 40 CFR.Part 63,Subpart MALT HH,Wand Gas Production Facilities 1. Is thestarage tank located at an oil and natural gas production facility that meets either of the following criteria: Inc Continue-You have indicatedth a.Afacility that processes,upgrades or stores hydroarbon liquids'(63.760(a)(2));OR b.Afacllity that processes upgrades customs natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to afloat end userx(63.760(a)(3)1? 2. Is the tank located at a facility that is majore for HAPs7 naME.Storage Tank is not subject MAC 3. Does the tank meet the definition of'storage vessel"In 63.761? :ROW 4. Does the tank meet the der Inition of"storage vessel with the potential for flash emissions"s per 63361? S. Is the tank subject to Contml requsements under 40CFR Part 60,Subpart Kb or Subpart 0000? .,..>.r...�: 'Storage Tank is rut subject.MALT MR Subpart A,General provisions per§63.764(a)Table 2 §63.766-Emissions Control Standards 363.775-Monitoring 563.774-Recardkeeping §63.775-Reporting RACT Beufew PACT.review Is required if Regulation 7 does oat apply AND If the tank is In the non-attainment area.If the tank meets both criteria,then review PACT 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 arule or regulation,and the analysis it contains may not apply to a partioulersituation based upon the individual reds and drcurratances 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 ofeny conflict-between the language of this document and the language of the Clean Air Act„its inplementing regulations,and Air QualityControl Commission regulations,the language of the statute or regulation will control.The use of non-mandatary language such as'recommend,' and'can,'is intended to describe APCD interpretations and recommendations.Mandatary terminology such as'Must"and'required"are intended fo describe controlling requirements under the farms of the Clean Air Ad and Air Quality Control Commission regulations,but this docunent does not establish legally binding requirements in and of itself. Separator Venting Emissions Inventory Section 01-Administrative Information (Facility AIRS ID: 123 4076;'- ,... .'r� 1002;M A County Plant Point Section 02-Equipment Description Details Low pressure gas stream from 7 hlgtElpx�,u'a saw-3 L+m ,SAs a Detailed Emissions Unit Description: 3..:i. ,,. ior, , . » flt..,t'ggdr:x...,MW-; T.Kg:. ..,ld ..mot: at, _ „•,.rc.ZiA<rg, ,t .Epcloaed Combustm{T e 2 ians'tor QF04b ' � ,c y- "' - - Emission Control Device Description: Requested Overall VOC&HAP Control Efficiency W. Limited Process Parameter „< Gas meter Section 03-Processing Rate Information for Emissions Estimates - - Primary Emissions-Separator Actual Throughput=Actual Throughput 7,6•. .1*..:48'14iii3i.,MMscf per year Requested Permit Limit Throughput=,- „-_,,,, -3A-.B MMscf per year Requested Monthly Throughput= 1.3 MMscf per month Potential to Emit.(PTE)Throughput= .14.8 MMscf per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 177750,Btu/scf Volume of waste gas emitted per BBL of liquids throughput: scf/bbl Control Device Pilot Fuel Use Rate: 2110;scfh 2.2 MMscf/yr Pilot Fuel Gas Heating Value_ '- 2632 Btu/scf Section 04-Emissions Factors&Methodologies Description 'Gas5ample kn lysis 2 1�'`�^ ,� mm MW ': ,35.316/16-mol Displacement Equation Ex=Q'MW'Xx/C Weight% Helium .'-941050 CO2 ,, 2:1037.. methane ,', 15:7214 ethane 114:2230 propane 24.3994 isobutane :`4;11022':: n-butane 13.7429 isopentane t.3.5988> n-pentane 4,4140. cyclopentane -?9.3924 n-Hexane cyclohexane. • 'i 5:4654 Other hexanes • k 2.42931 heptanes i.1.2509. methylcycluhexane 03151 224-TM P ;,;'4(0011. Benzene :;0;2372 Toluene • is 0.2483 Ethylbenzene 11.0270 Xylenes C8+Heavies F„ :1"•i.;;,696S Total 99.4207 VOCWt% 51.1023 7 of 22 K:\PA\2019\l19 W E0793.CP1 Separator Venting Emissions Inventory Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (Ib/MMsef) (Ib/MMsef) 1.1MIIMINIII56838.1678 1135.7644 VrI _ - . n 3.0688 i�,BI?�c- - ,L. somwertenmaszami 30,].464 . 0,9205sl - Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MM Btu) Ib/MMsef Emission Factor Source (Waste Heat Combusted) (Gas Throughput) 0-0075 13.2404 IxFB0006 t, ,tj 006 MIIIIIIMMIll , 00W I1 120.936© • - Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) Ib/MMsef Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) 00075&. , 110075 A' 0,0006 r.� 0;0680 a ,0, 178.0765 _ c a `4.31013". L t r '•' -- ,.r ''.tc mtlusua aSQs 4 ...fir.. 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 0.1 - 0.1 II.I 11,1. tl,.L 2.0 PM2.5 0.1 0.1 0.1 0.1 0.1 20 SOx 0.0 0.0 0.0 0.0 0.0 2 NOx 1.1 0,3 0.7 1.1 1.1 185 VOC 410.8 349.8 7,0 416,8 8.4 1426 CO 0.0 4.3 3,4 5.0 5.0 843 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 2700 2258 45 2709 54_ s Toluene 3811 2843 -. 57 3411 65 Ethylhenzene 371 309 6 371 7 Xylene 1575 1312 26 1575 31 n-Hexane 2228.3 16555 371 22263 445 224 TM 15 13 0 15 5 Section 06-Regulatory Summary Analysis Regulation 3,Parts.A,B Source requires permit Regulation 7,Section XVII.B,G Source In subject to Regulation 7,Section XV11.0.2,G Regulation 7,Section XVII.B.2.e The control device for this separator is not subject to Regulation 7,Section XVII.B.2..o (See regulatory applicability worksheet for detailed analysis) 8 of 22 K:\PA\2019\19W E0793.CP1 • 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 en 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? y,?? 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 aflare 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 net require an answer. ar Yl l/ 40 io r riot 1,,t /Emr'f i /'^' o. �� :s ./..., : ��f" 'y f,s"' � Oij'`ItleyAstile*N/:" / / a/�.'- :L/ is �/g,q ° 7 mr �ik"//,��'.<t z` r �� ids, Section 08-Technical Analysis Not .- R� I �i /i 3 f -y z fq. r� ... -_ d F v -W 444444,044.. .4,44.1,644U40•414-44=e1- 4444,4404W41,40•44', 4HIV 2.141470 3 �`�' f y/,44 3 L c u ,4440,44--,444m ` ." r �4,4-44,444444,.,04o;44-4144i } ' � � a s 'i _-No- .. - .S,'h- i y ✓e 'r`+ y,. "w �bR� . d Section 09-Inventory SCC Coding and Emissions Factors AIRS Point 0 Process0 SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 002 01 3-10-001-60 Flares • PM10 13.2 0 lb/MMSCF SCC coding withpilot PM2.5 13.2 0 IblMMsCF emissions in Ibs diuc SOx 1.0 0 lb/MMSCF NOx 120.8 0 lb/MMSCF VOC 56938.2 98 lb/MMSCF CO 550.9 II €h/MMSCF Benzene 183A 98 Ib/MiviSCF Toluene 231.0 98 lb/MMSCF Ethylbenzene 25.1 98 lb/MMSCF Xylene 106.6 98 Ib/MMSCF n-Hexane 1507.3 98 lb/MyitSCF 224 TMP 1.0 98 ib/MMSCF • 9 of 22 K:\PA\2019\19WE0793.CP1 • Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Re p latlon 3 Parts Aend B APEN and Permit Requirements ISomrce is in the Nan-Attainment Arm ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants front this individual source greater than 2 TPY(Regulation 3,Part A,Section 11.0.1.x)7 /#/#,'%;r 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOB greater than 10 TPY or CO emissions greater than 10 TRY(Regulation 3,Part B,Section ll.D.31? (You hate indicated that source is In the Non-Attainment Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from thls individual source greater than 1 TPY(Regulation 3,Part A,Section lI.D.1.a)? YRe;i„ %'.source Re 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOB greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.21? .i (hSource Re (Source requites a permit Colorado Regulation 7,Section XVII 1. Was the well newly constructed,hydraulically fractured,or recampleted on or after August 1,20147 ISMISource is: (Source is subject to Regulation 7,Section 0511.0.2, Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G-Emissions Control Alternative Emissions Control(Optional Sealant a. Is this separator controlled by a back-up or alternate combustion device(I.e.,not the primary control device(that is not enclosed? lro5,;.,,n lThe cant, 'The control de)co lorthis separator Is not subject to Regulation 7,Section XVil.f1-2.s 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,"shomld"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 terns of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself Separator Venting Emissions Inventory Section 01-Administrative Information ...744'1'41: .-s;..,.. A070 ..s;,fis ' ',.003, s,';::r:: Facility AIRs ID: County Plant Point Section 02-Equipment Description Details """"99.90-9-9790-;" Detailed Emissions Unit Description: FhdYasod'C'q�m4esemarDetince giiestot1 95000 '� •��*. �`�S� ,f ._.-'w Emission Control Device Description: Requested Overall VOC&HAP Control Efficiency%: or 98 Limited Process Parameter 7,xk8 v8 ¢7tKe. _ xx Gas meter Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= 9.5 MMscf per year Requested Permit Limit Throughput= f 7.8 MMscf per year Requested Monthly Throughput= 9.7 MMscf per month Potential to Emit(PTE)throughput= 7.8 MMscf per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 4,5, , ,„ 25521 Btu/scf Volume of waste gas emitted per BBL of r z liquids throughput: o 'scf/bbl Control Device Pilot Fuel Use Rate: p,y 56h 0.0 MMscf/yr Pilot Fuel.Gas Heating Value: 'k '«1 1105u/scf Section 04-Emissions Factors&Methodologies Description - ,k ct" N,'§'^2 MW I •49.711b/16-mot Displacement Equation Ex=Q MW°Xx/C Weight% Helium 0,0000 CO2 0,4903 N2 0.5550 methane 1.5379 ethane 9;099 propane3,14599, iaobutane 7.4220 n-butane 240384 isupentaoe - 5.7980 n-pentane R 9223 cyclopentane 1.5584 n-Hexane2 2985 cyclohexane ::c 05530 Other hexanes ;..-. 3.091 heptanes 1.2907 methyicyclohexane 224-TMP D,S013'. Benzene _y_... ,.;:'i+it 2399 Toluene v4 ,-i Q1790 Ethylbenzene Xylenes '++0-0483' Cg+Heavies ,, .7.0503 Total 99.7790 VOCWt% 87.48840 • 11 of 22 K:\PA\2019\19WE0793.CP1 Separator Venting Emissions Inventory Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) Ci ' =IEGMgMtIMIEit - A XI't,O.6 -41O:-- Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) 0,0075 0,0075 t -a b1`' jP •_ 0.0006 IEDMIM 3A?42,P.c 0:0580 173.8760 ' , .2. • 0,31p0 .< r *la .. Pilot Light Emissions o., Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) Ib/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) 0..0000 ] y�� 4'-r"4'-r"" 4" y':. 0-0000 ,an'',, 0,0000 */ 4 ".j� 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 0,1 0,1 0,.1 0,1 0.1 13 PM2.5 0.1. 0,.1 0.1 0.1 0.1 13 000 0.0 0,0 0,0 0.0 0.0 1 NOx 0.7 0,6 0.0 0,7 0,7 110 VOC 449.1 374,3 7.5 4.49.1 9.0 1526 . CO 0.0 2.6 2.6 3,1 r 3.1 527 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 2403 2054 41 _ 2463 49 Toluene 1836 1531 31 1836 37 Ethylbenzene 115 36 2 115 2 Xylene 496 414 8 496 10 n-Hexane 23540 10637 39.3 23546 471 224 TM 13 11 0 13 0 Section 06-Ii.gg, torvSummary Analysis Regulation 3,Parts A,B Source requires a permit Regulation 7,Section XVII.0,G Source is subloct to Regulation 7,Section 5V11.0.2,G Regulation 7,Section XVII.B.2.e thin control device for tids separator is not sob)act to Regulations 7,Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) ,. 12 of 22 K:\PA\2019\19 W E0793.CP1 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 Allis 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 ennssions of VOC greater than or equal to 90 tons per year? mm If yes,the permit wig 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 wilt 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 nor require an answer. x L 3'F /, `/ kr, /ate i ,/ { z ,`tu ,,z / (�' �j iii r5'.' ��' f / i ;�-N Y Section 08 Technical Analysis Notes e h r� - e F a fie.""`' yy.•t c, 44* .�� ,. . '45,; 'F .:~^/y<ay '' .''`� s r,1 r. .- �y Nib// k Section 09-Inventory SCC Coding and Emissions Factors AIRS Point It Process 0 SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 003 - 01 3-10-001-60 Flares PM10 19.1 0 Ib/MMSCF SCC coding withpilot PM2.5 19.1 0 ib/MMSCF emissions in lhs divic SOx 1.5 0 ib/MMSCF NOx 173.9 0 lb/MMSCF VOC 114706.0 98 Ib/MMSCF CO 792.7 0 €b/MMSCF Benzene 314.6 98 lb/MMSCF Toluene 234.4 98 Ib/MMSCF Ethylbenzene 14.7 98 lb/MMSCF Xylene 63.3 98 ib/MMSCF n-Hexane 3007.2 98 Ib/MMSCT 224 TMP 1.7 98 Ib/MMSff • • 13 of 22 K:\PA\2019\19WE0793.CP1 • • Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Re•ulatlon 3 Parts A and B-APEN and Permit Requirements ISpurca is in the Non-Attainment Arne ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section ll.D.1.a)7 • 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10TP(or CO emissions greater than SO TPY(Regulation 3,Part B,Section 11.0.317 �p IYou have indicatedthatsource is In the Non-Attainment Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3,Part A,Section II.D1ai? y99 15 ce Re 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY,NOx greater than S IPY or CO emissions greater than lO TPY(Regulation 3,Part B,Section 11.0.2)? yes: I Source Re Insures requires a permit Colorado Reculation 7,Section%VII —' 1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? ,L'rt!IS urea is, ISourseis subject to Regulation 7,soclion wli.B.2,C section JMI.0.2-General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII,G-Emission's 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? rt' AThe contr, (The cornea(device Warns separator is not suh)ect to Regulation 7,Section%VR,B.2.e Section XVILB.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 3 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 tw/l control.The use of non-mandatory language such as"recommend,"may,"'should,"and'can,"is intended to describe APCD interpretations and recommendations.Mandatary 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. Hydrocarbon Loadoot Emissions inventory Section 01-Administrative Information 'Facility AIRs ID: a 123 3976 County Plant Plant Point Section 02-Equipment Description Details Detailed Emissions Unit Trsack losdmg%vYtenssles�Ip'ehne is dower ae,S s, . l 1`a< Description a .�' - ,,,,,,„.. ..,,ran,,.,•. '' , .,__-;q P,.,. -�a.� ,' ', Emission Contr I D vice nciExsad cgmUusttUnstevice. 4 i"� ,y Description: s ,x.-.. � � ,�L;-.z..:,k.. �..:.. : .�� . ,. Is this loadout controlled? Requested Overall VOC&HAP'Control Efficiency%: Section 03-Processing Rate Information for Emissions Estimates Primary Emissions,Hydrocarion Loadout Actual Volume Loaded= 'pia$6EY9;Barrels(bbl(per year Requested Permit Limit Throughput= i3 .e 57447 Barrels(bbl)per year Requested Monthly Throughput= 5720 Barrels(bbl)per month I Potential to Emit(PTE)Volume Loaded `at\.-47 94 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= Actual Volume of waste gas emitted per year= 93444 scf/year Requested Volume of waste gas emitted per year= 122132 scf/year Actual heat content of waste gas routed to combustion device= 243 MMBTU per year Requested heat content of waste gas routed to combustion device= 292 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 292 MMBTU per year Control Device I I I Pilot Fuel Use Rate: - ,._ .scm 0,0 MMscf/yr Pilot Fuel Gas Heating Value: --:i 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? - :__ j^ The stab0€aed hydrocarbon liquid camp€e is valid for developing site specific emissions factors. Loading Loss Equation L=12.4sosapeM/r Factor Meaning Value Units Source 5 Saturation Factor 0.5 a--' /�i,' `AU _ etg�ilesii' 'd��sfiaak� P True Vapor Pressure ;;'- 6 ..�;:p I 'I ,a4_ e yyw f• '+ M Molecular Weight of Vapors Ib/Ib-m I _ T Uquid Temperature ,a..523:57i„,.,, Rankine .:: - -<h 5„, ,✓.. ,, L Loading Losses 6.475410036 Ib/1000 g II ns = 0.271969901 lb/bbl Component Mass Fraction Emission Factor Units Source Benzenetk0 0-000'707129 lb/bbl is Tank flash analysis Toluene 5,090543930 lb/bbl - Tank flash analysis Ethylbenzene 2.71968E-05 lb/bbl Thai aash aaaiys. %yiene „ ,,,,,h:,06,00t"5 ''" 0,000135984 1b/bhl lankfi snr alt'srs n-Hexane A:,fw!0:41§ 5.095194695 lb/bbl Tank flash analysis 224TMP ••t1;A0p5 i'gv 2.71959E-US lb/bbl Tank damn analysis EMOSCRIM Hydrocarbon Loadout Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (volume (Volume Loaded) Loaded) u 5-140,44 lot,). �. r 6,60E—ffi 9+ vlsVi 2.60E-04 - silt'6#(. Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu( (lb/bbl) Emission Factor Source (Volume (waste heat comhusted) Loaded) IIMINEFEQ 0375 M' I ° 9I"i( _ ff,t.73 '.® ,i - IIMMEMEMill 0..9680 ° 0;3120 _:° _ Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source (Pilot Gas (Waste Heat Combusted) Throughput) • 1" '®. 15 of 22 K:\PA\2019\19WE0y93,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) (ton,/year)- i (lbs/month) PM10. 0.00'. 0.00 0.00- 0470 9.09. 0 PM2.5 0.00 0.00 0.00 0.00 9.00 0 SOS 0.00 0.00 0.00 0.00 0.00 0 NOx 0.01 0.01 0.01 0.01 0.01 2 VOC 9.17 7.64 0.30 9.17 0:48 - 78 CO 0,05 0.04 0.04 0.05 0,05 8 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled llhs/year) (Ibs/year) Ilbs/year) (Ibs/year) (lbs/year) Benzene -48 40 2 48 2. Toluene 37 31 0 ..37 2 Ethylbenzene 2 2 0 7 0 Xylene 9 0 0 0 0 n-Hexane 350 252 15 350 18 224TMP 2 2 0 2 0 Section 06-Regulatory Summary Ana lys_ Regulation 3,Parts A,B Source requires a permit RACT-Regulation 3,Part B,Section III.D.2.a The loadout must be operated with submerged fill to satisfy RACE. (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements - s 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 kVirK# `,€ �.ry,a„p 0 , 44- : -:_.� x ai. Ot-≥s ef,..: 'fey zwefi,3 k,-; .sW I r - _,t r�-: r :s s z c�;? .:: 'S `�'�;,, R a �. s s 1� ��-��Y ti'µ""r'"f��u lot $<i+�� '°,.�i' '��*'f,#„S:._ � �'�' z e r"'€ �, u"� .� �" .w„� r'„'fr�' 9 t� N* " ' t . L' 'l is, „ o v' b+ i ;f r s s o^r ,� •;K,:,,-.,„,i; -r',� s "' y r k. i� i.. , �. ss � � �r: � � Y 2 ', � 7 t � .* e fie` s x �'a a $, � s v � 4 n r y � � � � -"�. � r,C�: ifs `'tik yi� � i ' L '4Y _ t« „, •.Y i t 1.�`,,'".' �- .;a4, ¢A tali ,., ,�`$ 'sk h i L^Jigii '4O.1O-414-14 H��4n Yy �..e ��u '.�+^ � `�'�L Lr. �� ' f� ,r`.,� 'Y.r '�tt� �z ;.x5'° z ,,�L.��`rg,� ,°�"� } �fi`�yy", �q �''tFs`) i '. 4k , �' ,-:3�4&^ ;*s, rt f i`.,'a- l4 yy ':4,,,4s $yam d 1 3 Sr",.- ,f0 a.r �. `s �'rf q ,.::!.000,„-;e: '<... 4< T sss `' °r �' a.▪ �' � - ., 'cm- cv a~LT )k� �� ,a� � s ,,ty �� s�� '��, � '� � v��t �� x�+f ar � • „aA• �r' w � f+9a s s' f'€y"4:45se '' s 7-v o,y,.,bar -r`t4,e4-p. a '`:.„!.-° s',3*t , ^.a'', ,y „„g,4-r t._ s f,A- `€" n' " 2- "�, `.- Frfe. ff ,,x.l r� 3v 3°S ,ad w,-"'.€. ,�s�`��urs :r7 t x V -, `c a _ z 2: �t �' u�� o-� (�^'.rr �'� �ws` �� '�` `� r&:� `€^E F 0 '`- "+ 5 s"" .� 'EI �.n¢'r .. & 4 t i 'ti+c ' .N t'40#,P r ,.- ... f` r `z�"�x s A m'c x* .,i : `e`ro`',€. r. ,31 a4 >a"�s*,v.3,i 3. '��x., sr ,ya a '€-s € '' i —.,,`1 .:4, `P/1' "' ,`a ry^' 4 & ` 4 ^r~.';54r ¢5 AA 44,,, • a % ,:,y ,0 a, � s ,;? „T r`^v t � ��3' �s s �rh s� y y i '� ��`,.�r^€:�"��`>a`s cfii-€ �`g rrg s�'₹;'�a�,1� ,>'�-"1;�;��3 e �� P�4��s k s .�" �▪ "�"} �,v ..� � ��a: x rti{44 ;a4 '3 e,� iii- &, '«� `� i ki,, -e ,ol _ Ka ti. a z x- r `� a, rho r. - € e 1 -t a � `X N, IL a t " ,,' 'h`"y"r �' �^' .s.k+,�. .,x��t�3�e.t�:s1`x✓� �,,�s�"^,� 3. ..�r..- ,..... , � S. z`'�`>'l��x1.,- �'a �`�a^��#,�.-. aXah �' ss° ., Section 09-Inventon/SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point(! Process ff 5CC Code Pollutant Factor Control% Units too of 4-06-001-32 Crude Oil:Submerged Loading Normal Service(S1.6) PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0,00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.01 0 lb/1,000 gallons transferred VOC 6.5 95 - lb/1,000 gallons transferred CO 0.03 9 lb/1,000 gallons transferred Benzene 0102 05 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 0.12 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 16 of 22 K:\PA\2019\19WE0793.CP1 • • • • Hydrocarbon Loadout Regulatory Analysis Worksheet The regulptory requirements below are determined based on requested emissions. Colorado Reeulation 3 Perim and B-APEN and Permit Requirements • 'Sown,Is in the,Non:Attainment.Area ATTAINMENT , 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TRY(Regulation 3,Part A,Section ll.0.1.el? 2. Is the loadoutfocated at an exploration and production site(e.g.,well pad)(Regulation 3,Part @,Section 11.0.1.1)? s >! 5 '.��...r 3. Is 1fie loadout opeRtlan loading less than 10,000 gallons(238.BBLs)of crude ail par 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 lessthan 16,308 bbls per year of condensate via submerged fill procedure? ,lalS" 6. Are total facility uncontrolled VOC emissions greater than TPY,NOx greater than 1O TPY or CO emissions greater than lO TPY(Regulation 3,Part B,Section 11.0.317 lam"+. Ho have indicated shot source is€n the Nam Attalontent Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater litanT TPY(Regulation 3,Part A,Section 113.1.8? ₹s`;N/',':Go to next 2. Is the loadout located at an exploraton and production site(e.g.,well pad)(Regulation 3,Part8;5eetion 11.0.1.1)7 Mfr Go to the n 3. Is the loadout operation loading less than 10,000 gallons(238 BBLsI of crude of per day on an annual average bas's? h¢ Go to next 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via sp lash fill? - PO:fa Go to next 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? rib',<.«,ri<-Go to next 6. Are total facility uncontrolled VOC emissionsfrom the greater than 2 TRY,NOx greater than 5TPY Or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.21? y-5-lk'.."(r The loedou ISoerce requires a permit 7. RACY-Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy(Regulation 3,Part e,Section 111.0.2.01? f1%%(/The'loadou ION loadout must be operated with submerged fill to satisfy RACT, Disclaimer This document assists operators with determining applicability of certain requaaments 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 enforceet'e.In the event of any conflict between the language of this document and the language of the Clean kr'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'Pan,'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 of3self • • • • • • • Produced Water Storage Tank(s)Emissions Inventory • Section 01-Administrative Information 'Facility AlRsID: Affe.tt. 123'_. 41)76 008 F County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit nn yea `I F'✓ •+a' - Tava 30Oh#rl Produced+Net t ggtgqks a �a, Description: %✓/�,.�,,, .. ., �a�yy •,,,,,,,,,,,,.., ,.3'��; ,..,,.c...•�.�z- .,c°�, Emission Control Device f� tiff y - �i Descri tian: `,,F'��M(r 'ANZ on DevACe' '1 _, Requested Overall VOC& ;i��.�.�F� �.� '�, / 7:, q71(4004'"131(0140014-.114W-;',W _.. ..P Avg' HAP Control Efficiency,6 y> P',,, 95, 0 Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Produced Water Throughput= +,. >�,�°1G39Y0Y Barrels(bbl)per year Requested Permit Limit Throughput= -'0 ,yg6,5006 Barrels(bbl)per year Requested Monthly Throughput= 16097 Barrels(bbl)per month Potential to Emit(PTE)Produced Water Throughput IV, g; 196'574'.:Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 1 t Q..Btu/scf Volume of waste gas emitted per BBL of liquids s"�'"'` Ko4 produced= ,. ,;3,3)scf/bbl Actual heat content of waste gas routed to combustion device= 590.9-MMBTU per year Requested heat content of waste gas routed to combustion device= 829.1 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 029.1 MMBTU per year Control Device y. Pilot Fuel Use Rate: �``�� 33 scfh 0,0 MMscf/yr Pilot Fuel Gas Heating Value: 1,, ..,.,_'Btu/scf 0.0 MMBTU/yr - - Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank - Uncontrolled Controlled Emission Factor Source Pollutant IIh/bbl) (lb/bbl) (Produced Water (Produced Water Throughput) Throughput) W&B emission factor VOC 0.1182 0.0059 Sot ee"Nj"ct44/4-its 0.002 Benzene 0.0032 0:0001 itfId P(att14., 30eoIt 0.0000162 Toluene 0000& O.0000 �dC,dio&F(aktudes flash 0.0000103 Ethylbenzene 30000 0.O0o0 0.�.6:_n�Nrtfu � / 0,000000552 Xylene 0.0002 0.0000 �gaitt ttP' e^.G• 0.00000258 n-Hexane 0.0079 0.0004 '3'A� z / 0.000103 224TMP .' 00000 0.0000 fI z�x ',ilk:,.... .... .. ��„-;,,;; 2.64E-0B Control Device Uncontrolled Uncontrolled Pollutant )lb/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Produced Water combusted) Throughput) PM10 0.00745 0,00002 W 0,14VP* __ PM2.5 0.00745 0.UN101 Nth, 0.06900 0.001)29 �2 5 E� - - CO ' 0.31000 0.00131 ieik s/� 1y.+` .F l (t₹35 ..." Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MFa tu) Ih/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) ' PM2.5 00000 NOR 0.0000 Section OS-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) (tans/year) (tons/year) (tons/year) (lbs/month) VOC 11.6 9.7 0.5 11.6. 0.6 98.7 PM10 0.0 0.0 0.0' 0,0 0.0 0.5 PM2.5 0.0 0.0 0.0 0,0 0.0 0.5 NOx 0.0 0.0 0.0 0.0 0.0 4.0 CO 0.1 0.1 0.1 0.1 0.1 21,8 Potential bo Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled - Uncontrolled Controlled Uncontrolled Controlled (lbs/year) fibs/year) (Ibs/year) (lbs/year) (lbs/year) ' Benzene 243.0 203.0 10.1 243.6 12.2 Toluene 154.3 129.1 6,5 154.9 7.7 Ethylbenzene 8.2 6.8 0,3 8.2 0.4 Xylene 38.6 32.2 1.6 33.6 1.9 n-Hexane 1543.4 - 1286.2 04.0 1543.4 77.2 224 TMP _ U.S 0.4 0.0 0.5 0-0 18 of 22 K:\PA\2019\19W E0793,CP1 Produced Water Storage Tank(s)Emissions Inventory Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Source requires a permit Regulation 7,Section XVII.B,Cl,C.3 Storage tank is subject to Regulation 7.Section XVII,8.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's not subiect to NSPS Kb Regulation 6,Part A,NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000. NSPS Subpart OO00a Storage Tank is not subject to NSPS OOOO0 [See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements f Does the company use a site specific emissions factor to estimate emissions? =s; Ifyes and if there are flash emissions,are the emissions factors based an a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis?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 an-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.See PS Memo 14-03,Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95%fora 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 Section 08-Technical Analysis Notes • • • • Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point if Process 6 SCC Code Pollutant Factor Control%Units 008 01 4-04-003-15 FNed Roof Tank,Produced Water,working+breathing+flashing losses PM10 0.0007 0.0 lb/1,000 gallons liquid throughput PM2.5 0.0007 0.0 lb/1,000 gallons liquid throughput NOx 0.0068 0.0 lb/1,000 gallons liquid throughput VOC 2.0153 95.0 lb/1,000 gallons liquid throughput CO 0:0311 0.0 lb/1,000 gallons liquid throughput Benzene 3.0295 95.0 lb/1,000 gallons liquid throughput Toluene 0.0188 95.0 lb/1,000 gallons liquid throughput Ethylbenzene 0.0010 95.0 lb/1,000 gallons liquid throughput Xylene 0.0040 95.0 lb/1,000 gallons liquid throughput n-Hexane 0.1969 95.0 lb/1,000 gallons liquid throughput 224 TMP 0.0001 95.0 lb/1,000 gallons liquid throughput 19 of 22 K:\PA\2019\19WE0793.CP1 • • • Produced Water Storage Tank 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 A In the Non.Attainment Area - I ATTAINMENT _ 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY(Regulation 3,Part A,Section 11.015)7 2. Is the operator claiming less than 1%crude oil and is the tank located of a non-commercial facility for processing all and gas wastewater?(Regulation 3,Part El,Section li.D.1.M] 3. Are total facility uncontrolled VOC emissions greater than 5TPY,NOx greater than SDTPY or CO emissions greaterthan 10TPY(Regulation3,Part B,Section 11.0.31? IYqu have indicated that source Is in the Nan-Attainment Area NON-ATTAINMENT 1 Are uncontrolled'emissions fern any criteria pollutants from this Individual source greater than ITPY(Regulation 3,Part A,Section 11015(7 Source Requires an AP 2. Is the operator claiming has than 1%crude oil and Is the tank located at a non-commercial facility for prorrssing MI and gas wastewater?(Regulation 3,Part B,Section ll.D.LM) '�''=.6 neat question 3. Are natal facility uncontrolled VOC emissions greater than 2TPY,NOx greater than STPV or CO emissions greater than 30 TPV(Regulation 3,Part 8,Section 11.0.217 yosii/ Source Requiresa pert I6aarce requires a permit Colorado Regulation 7,Section XVII • 1. Is this tank located at a transmission/storage facility? 'Fs Continue-You have in 2. Is this produced water storage tank'located at an oil and gas exploration and production operation,well production facility',natural gas compressor stations or natural gas processing plant? You Continue-You have in 3. I hi prod datater storage tank a fixed roof storage tank? NeS4A'7 Go to the next questio 4. Are uncontrolled actual omissions of this storage tank equal to or greater than 6 tons per year VOC? :scan y;ij Source is subject'.Pa 'Storage tank is anklets to Regulation 7,.Section XVII,0,C.1&C.s Section=LB—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1-Emissions Control and Monkodng Provisions Section XVII.C.3 Recordkeeping Requirements [[ 5. Does the produced water storage tank contain only stabiliaed"liquids?if no,the following additional provisions apply. Stiff _]Source is subject to all 'Storage rank is xehject to Regulation 7,Suction XVII.C.2 Section XVR.C.2-Capture and Monitoring for Storage Tanks fated with Air Pollution Control Equipment 40 CFR.Part 60.Subpart icb,Standards of Performance far Volatile Organic Liquid Storage Vessels 1. Is the indiu dual storage vessel opacity greater than or equal to 75 cubic meters MI)]-472 BBLs]? t_s Storage Tank is not sit 2. Does the storage vessel meet the following exemption In 60.111b(d)(4)7 _% • a.Does the vessel has a design capacity less than or equal to 1,589.874 m3["10,000 BBL]used for petroleum'or condensate stored,processed,or treated pdorte custody transfer'as defined in 60.1116? 3. Was this condensate storage tank constructed,reconstructed,or modified(see definitions 40 CFR,60.2)afterluiy 23,1984? km-04 4. Does the tank meet the definition of"storage vessel"'in 60.111b? 5. Does the storage vessel store a"volatle organic liquid(VOL).'as defined in 60.111b? 6. Do.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(60.110b(d)(2)(?;or b.The design capacity Is greater than or equal to 151 run(-950 BBL]and stores a liquid with a maximum true vapor pressures less than 3.5 6Pa(60.110b(h))?;or c The design capacity is greater than or equaltq 75 M'('472 BBL]but less than 151es]'950 BBL]and stores a liquid with a maximum true vapor pressures less than 15.0 kPaISOllob(b))7 7. Does the storage tank meet ether one of the fallowing exemptions from Cntrol requirements Rea 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 car equal to 3.5 kPa but less than 5.2 kPa?;or b.The design capacity Is greater than or equal to 75 Mt("472 BSLJ but less than 151 m3("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? f7 'Storage Tank b notsublect to AMPS Kb -1 40 CPR.Part 60,Subpart 0000/0000a.Standards of Performance for Crude 011 and Natural Gas Production,Transmission and Distribution 1. Is this produced water storage vessel located at afacility in the onshore oil and natural gas production segment,natural gas processing segment or natural gas transmission and storage segment of the industry? Yes Continue-You have In 2. Was this produced water storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2]between August 23,2011 and September 18,2015? -Storage Tank is not sun 3, Was this produced water storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.21 after September 18,20157 °§1:.Go to the nextquestlo 4. Are potential VOC emissions'from the individual storage vessel greater than or equal to 6 tons per year? ' Storage Tank is notsul 5. Does this produced wafer 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 or40 CFR Part 63 Subpart HH7 'Storage Tank isnot isahieny to NSP5 00000 [Note:If a storage vessel Is previously determined to be subject to SOPS 0000/0000e due to emissions above 6 tons per year VOC an the appiabili y determination date,it should remain subject no SOPS 0000/0000a per RACE Review RACE review Is required If Regulation 7 dons not apply AND Nthe tank is in the nen-attainment area.1f the tank meets bath criteria,then review RACT requirements, Disclaimer • This document assists operators will determining applicability of certain requirements of the Clean Air Act is inplementing regulations,and Air Quaky Control Commission regulations.This document A not a rule or regulation,and the analysis i contacts 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 soy other legally binding requirement and is not legally enforceable.In the event of any coriftd between the language of this document and the language of the Clean Air Act„On 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," 'should,"and'can,"Is intended to describe APCD interpretations and recommendations.Mandatory terminology such as'must"and'required'are intenrlad t0 describe controfmg requirements under the terms of the Clean Air Ad and Al Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. Separator Venting Emissions Inventory Section 01-Administrative Information Facility Allis ID: - 000 County Plant Point Section 02-Equipment Description Details Praduceh#i oWrWSn iberatianAmalyxfs , Detailed Emissions Unit Description: - -. Endosedtombusfiatxtteuite Emission Control Device Description: '" ' • Requested Overall VOC&HAP Control Efficiency%: OS Limited Process Parameter Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= •-'->:1538Y8;1S.earrels(bbl)per year Requested Permit Limit Throughput= :f-ff196,S9#:ft-Barrels(bbl)per year Requested Monthly Throughput= 16697,0 Barrels(bbl)per month Potential to Emit(PTE)Throughput= 39111584.0 Barrels(bbl)per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 27&0 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: :a;3≤3 suf/bbl Control Device Pilot Fuel Use Rate: scth 0.0 MMscf/yr Pilot Fuel Gas Heating Value: - Btu/scf Section 04-Emissions Factors&Methodologies Description fiasb:ilberatlongassamplesjr tg3is MW �: 34;316/16-mel Displacement Equation Ex=Q*MW"Xx/C Weight% Helium 0;0000 CO2 173102. N2 12.0540- methane ..113020 ethane 13:,7315 propane 18;4050 isobutane >"3,8680. n-butane C3920 isopentane ='1.2321'. n-pentane 1:6713 cyclopentene 0.3385 n-Hexane -2.8911- cyclohexane 0:3720 Other hexanes - 3_28423 heptanes -0.7024 methylcyclohexane .- 03722 224-TMP ----5.0000: Benzene ",GY:41l97 Toluene •- 3;2055: .. ... ... Ethylbenzene � 0,0135] Xyienes • ' .---0:0540 C8+Heavies -0.9731 Total 1G_^.0000 VOCWt% 38.0470 21 of 22 K:\PA\2019\19WE0793.Elc1 Separator Venting Emissions Inventory. Emission Factors Separator Venting Uncontrolled Controlled Pollutant (16/661) (16/661) Emission Factor Source (Liquid Throughput) (Liquid Throughput) VOC 0,116238 0.905832 nafysfs Benzene 0.001223 0.000001 nafysis Toluene i},000778 0.00£}039 - lys4s.- Ethylhenzene O.OOQ041. 1100{}iH}7 Ell,./ xt O k si% Xylene 0.0001+34 O.OOQ010 n-Hexane 0.0077048 0.000387 224 TMP 0000402 O.ar30000 :_ Ay/ ., aii4-4s - „/ Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) 16/661 Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 4#0075 0.0400 tY PM2.5 a -003.s 0.0000 , sox #s#©i(s a.4m#n 3„I NOx #0$# 0.0003 CO 9 8 4#,„, 0.6013 Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0000 "�//' " PM2.5 0.QQ00 .. SOx 0.0000 NOx 0.0000 CO .'an'; 0.00004, 1,0'.0°,'''''' Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Omits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tans/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.0 0.0 0.0 0.0 0.0 1 PM2.5 0.Q 0.0 0,0 0.0 0.0 1 SOx 0.0 4<0 0.0 0.0 0.0 0 NO% 4:Q 0.0 0.0 0.0 0.0 S VOC 11,4 9,5 0.5 11.4 0.6 97 CO 0.11 4B..1 0.1 0.1 - 0.1 22 Potential to Emit Actual Emissions Requested Permit Limits --. Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (16s/year) (Ibs/year) (Ihs/year) (16s/year) Benzene 240 200 10 246 12 Toluene 353 117 6 1113 0 Ethylhenzene 5 7 0 N i} Xylene :3&B 32 2 :B8 2 n-Hexane 1523 1169 53 1523 76 224 TMP 0 0 0 0 0 22 of 22 K:\PA\2019\19WE0793.CP1 Condensate Storage Tank(s) APEN 1 � Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of alt available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: l qww.P793 [Leave blank unless APCD has already assigned a permit # and AIRS ID] AIRS ID Number: 1 Z3 1A0 / CO I RL:C(illii. 'X-22019 1PCD Stationary s ry . Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Cito Trust Production Facility Site Location: NWNW SEC 01 T4N R68W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Jon Torizzo Phone Number: (303) 396-5051 E -Mail Address2: air@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 403555 COLORADO 1 °`"'" Heal bEnvlmnmwnl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit tt and AIRS ID] Section 2 - Requested Action El NEW permit OR newly -reported emission source El Request coverage under traditional construction permit O Request coverage under a General Permit O GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment O Change company name3 ❑ 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 - El APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 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: Company equipment Identification No. (optional): For existing sources, operation began on: Eight (8) - 400 bbl Condensate Storage Tanks For new or reconstructed sources, the projected start-up date is: 05/4/2019 Normal Hours of Source Operation: 24 hours/day 7 Storage tank(s) located at: ❑ Exploration Et Production (Ef&P) site days/week 52 weeks/year O Midstream or Downstream (non Ef&P) site Will this equipment be operated in any NAAQS nonattainment area? ra Yes • No Are Flash Emissions anticipated from these storage tanks? a Yes • No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? GI Yes • No If "yes", identify the stock tank gas -to -oil ratio: 1.03E-05 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No 0 ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 COLORADO 2 I Alr Heat.b EnNron•unl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl /year) Condensate Throughput: 562,059 From what year is the actual annual amount? 2019 Average API gravity of sales oil: 50.2 degrees ❑ Internal floating roof Tank design: Fixed roof 674,471 RVP of sales oil: 13.6 ❑ External floating roof Storage Tank ID - # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) 8 3200 11/2018 5/2019 Wells Serviced by this Storage Tank or Tank Battery6 (EEtP Sites Only) API Number Name of Well Newly Reported Well See Form APCD-212 ■ ■ ■ ■ ■ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EaP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.346453/-104.960122 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) -20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) O Upward D Horizontal o Downward ❑ Other (describe): 0 Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑� Circular Interior stack diameter (inches): TBD 0 Square/rectangle 0 Other (describe): Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 'COLORADO 3 I AV' � HW11.6 EnWmeunvl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECD MMBtu/ hr p Make/Model: (3) I ES 48" Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD Waste Gas Heat Content: 2605 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —5 psig Describe the separation process between the well and the storage tanks: Hydrocarbon liquids flow from the seven (7) HLP separators, to one (1) VRT, and then to the eight (8) condensate storage tanks. COLORADO Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 4 I gr H""'°`"`""`t. Nvat�l+b Env4o�.n�n1 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (%reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) V0C ECDs 95 NOx CO HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Pollutant Emission Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg-, etc.) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.211 lb/bbl Eng. Est. 59.38 2.97 71.25 - 3.56 — NOx 0.068 Ib/MMBtu AP -42 0.10 0.10 0.12 " 0.12 CO 0.31 lb/MMBtu AP -42 0.47 0.47 0.57 0.57 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor7 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, ' Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions8 (pounds/year) Benzene 71432 0.001 lb/bbl Eng. Est. 309 — 15 ' Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.004 lb/bbl Eng. Est. 2,271 -- 114 '- 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 COLORADO 5 I ler',°�°^ ,.�,. xnusenv�nNn.n� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Sign tii a of Legally Authorized Person (not a vendor or consultant) Date Jon Torizzo Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 COLOR ADO 6 1 •Vim Hm:u.6 EnNro„unenl E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Extraction Oil & Gas, Inc. Source Name: Cito Trust Production Facility Emissions Source AIRS ID2: Wells Serviced by this Storage Tank or Tank Batter (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-43579 Cito Trust HC #01-119HN ■ 05-123-43580 Cito Trust #1E -10-7N ■ 05-123-43581 Cito Trust #1E -10-5N ■ 05-123-43582 Cito Trust HC #01-159HC ■ 05-123-43583 Cito Trust #1E -10-1N ■ 05-123-43584 Cito Trust #1E -10-2N ■ 05-123-43585 Cito Trust #1E -10-4N ■ 05-123-43586 Cito Trust #1E -10-3C ■ 05-123-43587 Cito Trust HC #01-122HN ■ 05-123-43588 Cito Trust #1E -10-6C ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ Footnotes: 1 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 RECEIVED AUG-22019 APCD r Stationary / Gas Venting APEN - Form APCD-92:-II/ Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 19/60 794 AIRS ID Number: X2.3 /A076/Ot Z [Leave blank unless APCD has already assigned a permit r and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Mailing Address: Extraction Oil & Gas, Inc. Cito Trust Production Facility NWNW SEC 01 T4N R68W (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Site Location Weld County: NAICS or SIC Code: 211111 Contact Person: Jon Torizzo Phone Number: (303) 396-5051 E -Mail Address2: air@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 3/2019 403556 .COLORADO 1 I Ay' Departmental Putiic xdw,envltomum, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action • NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Low pressure ("LP") separator venting emissions Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 5/4/2019 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 3/2019 days/week weeks/year Yes Yes No No 0 Yes O No .COLORADO 2 I ®'V o�wtu� ' Hu1NbEnvlmvnvnl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator O Welt Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ Yes ❑ No Vent Gas Heating Value: 1777 BTU/SCF Requested: 14.77 MMSCF/year Actual: 12.31 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 35.26 VOC (Weight %) 61.10% Benzene (Weight %) 0.20% Toluene (Weight %) 0.25% Ethylbenzene (Weight %) 0.03% Xylene (Weight %) 0.11% n -Hexane (Weight %) 1.62% 2,2,4-Trimethylpentane (Weight %) 0.001 % Additional Required Information: ✓❑ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested: values will become permit limifations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 3/2019 COLORADO 3 1 .... V= Hu:A1b En Inv.meel Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permitA and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.346453/-104.960122 •Discharge Height Operator Temp Flow Rate Velocity Above Ground Level F ACFM t/sec Stack ID No .(°_ (Feet -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ®Upward ❑Downward ❑ Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): TBD ❑Other (describe): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Size: Make/Model: ❑ VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: ECD Make/Model: Quester/Q5000 Combustion Requested Control Efficiency: 98 .1=1 Device: Manufacturer Guaranteed Control Efficiency: >99 Minimum Temperature: TBD Waste Gas Heat Content: 2605 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: TBD MMBtu/hr Pollutants Controlled: Other: Description: Requested Control Efficiency: - - 1E ;COLORADO Form APCD-211 - Gas Venting APEN - Revision 3/2019 4 I Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the rot efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC ECD 98 HAPs ECD 98 Other: Projected From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOx NOx 0.068 Ib/MMBtu AP -42 0.74 0.74 0.89 - 0.89 CO 0.31 lb/MMBtu AP -42 3.39 3.39 4.07 - 4.07 VOC 56.80 lb/Mscf Eng. Est. 349.63 6.99 419.55 — 8.39 .— Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract (CAS) Service CAS Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions 6 (pounds/year) Benzene 71432 0.18 lb/Mscf Eng. Est. 2,256 ,- 45 Toluene 108883 0.23 lb/Mscf Eng. Est. 2,840 .' 57 Ethylbenzene 100414 0.03 lb/Mscf Eng. Est. 310 ' 6 Xylene 1330207 0.12 lb/Mscf Eng. Est. 1,312 i 26 n -Hexane 110543 1.50 lb/Mscf Eng. Est. 18,534 ,- 371 . 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 3/2019 WI COLORADO 5 j A x.ssmtrenwmnmen� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. (? 73( /7 Signatu—Mkegally Authori erson (not a vendor or consultant) Date Jon Torizzo Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Iealth and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 3/2019 COLOR ADO 6 I �� „�n.ofw Nu. fe Enrtrenm.N r' r; BUG -22019 Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: ici E077S AIRS ID Number: /23 140761 603 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Extraction Oil & Gas, Inc. Cito Trust Production Facility NWNW SEC 01 T4N R68W Mailing Address: 370 17th Street, Suite 5300 (Include Zip Code) Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Jon Torizzo (303) 396-5051 air@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 3/2019 403557 COLORADO 1 I Air = rm1.:t?.*b FW1hbEnvt cna,trl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) - OR • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info It Notes: 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: venting emissions Vapor recovery tower ("VRT") separator Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 5/4/2019 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 3/2019 a days/week weeks/year Yes Yes Yes ❑ No ❑✓ No ❑ No COLORADO 2 I AV Kaallh nl d RCUc HW1n b Envlronmanl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing O Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: [] Other Description: Serial #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ Yes ❑ No Vent Gas Heating Value: 2557 BTU/SCF Requested: 7.83 MMSCF/year Actual: 6.53 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 49.69 VOC (Weight %) 87.48% Benzene (Weight %) 0.24% Toluene (Weight %) 0.1 8% Ethylbenzene (Weight %) 0.01% Xylene (Weight %) 0.05% n -Hexane (Weight %) 2.29% 2,2,4-Trimethylpentane (Weight %) 0.001% Additional Required Information: ✓❑ Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Ft n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 3/2019 COLORADO 3 I Nxa:IhtrEnvfmvneT.l Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.346453/-104.960122 Operator Stack ID No Discharge Height Above Ground Level ' (Feet) Temp •�`F) Flow Rate (ACFM) Velocity (ft/sec); -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal Downward Other (describe): Indicate the stack opening and size: (check one) �✓ Circular ▪ Other (describe): Interior stack diameter (inches): 0 Upward with obstructing raincap TBD Section 6 - Control Device Information Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECD MMBtu/hr Make/Model: Questor/Q5000 Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: >99 Minimum Temperature: TBD Waste Gas Heat Content: 2605 Btu/scf Constant Pilot Light: �✓ Yes O No Pilot burner Rating: TBD MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 3/2019 COLORADO 4 I AY d. Hyot Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the ined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOx NOx CO VOC ECD 98 HAPs ECD 98 Other: Projected From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOX NOx 0.068 Ib/MMBtu AP -42 0.57 0.57 0.68 0.68 CO 0.31 Ib/MMBtu AP -42 2.59 2.59 3.10 ' 3.10 VOC 114.61 Ib/Mscf Eng. Est. 373.97 7.48 448.77 8.98 — Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract (CAS) ( ) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions 6 (pounds/year) Benzene 71432 0.31 Ib/Mscf Eng. Est. 2,050 - 41 ' Toluene 108883 0.23 Ib/Mscf Eng. Est. 1,527 '' 31 - Ethylbenzene 100414 Xylene 1330207 0.06 Ib/Mscf Eng. Est. 413 - 8 ' n -Hexane 110543 3.00 Ib/Mscf Eng. Est. 19,601 ' 392 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 3/2019 COLORADO 5 1 A_ Haalth ft Enttakr.1 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signat e):if Legally Authorizerson (not a vendor or consultant) Date Jon Torizzo Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: p✓ Draft permit prior to issuance E✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: For more information or assistance call: and Environment Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 3/2019 iCOLORADO 6 I AV IFuNT6 Fn J RECEIVED AUG-22019 A ['CD Si I ;Unary Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. 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, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: f Rt'VEO796) AIRS ID Number: 123 IAtm /Doll - [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Extraction Oil & Gas, Inc. Cito Trust Production Facility Site Location: NWNW SEC 01 T4N R68W Mailing Address: (Include Zip Cade) 370 17th Street, Suite 5300 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Jon Torizzo Phone Number: (303) 396-5051 E -Mail Address2: air@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 403553 COLORADO 1 I A , Departmentd Pub!. Haatth FnWeOnni. Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverage under constlw.lction permit 0 Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership' 0 Other (describe below) OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (EIAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Truck loading 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: Truck loading if sales pipeline is down Company equipment Identification No. Coptional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 5/4/2019 Wilt this equipment be operated in any NAAQS nonattainment area? Yes No p • Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • p Does this source load gasoline into transport vehicles? Yes No • p Is this source located at an oil and gas exploration and production site? Yes No O ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annualSI average? Yes No • Does this source splash fill less than 6750 bbl of condensate per year? Yes No SI ■ Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ p Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 (COLORADO 2 I Agfr _»...-.� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate 0 Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 67,447 bbl/year Actual Volume Loaded: This product is loaded from tanks at this facility into: Tank trucks (e.g. "rail tank cars" or "tank trucks") 56,206 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 60 F True Vapor Pressure: 7.26 Psia ® 60 'F Molecular weight of displaced vapors: 62 lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 COLORADO 3I�- N.ahh b Envi:= nnm.nl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.346453/-104.960122 Ciperator Stack ID Nod Discharge Height Above Ground Level (feet) Temp ('F) Flow Rate (ACFM) eloci (ft/sec)'' -20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Horizontal 0 Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular O Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): TBD Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: % ❑ Combustion Device: Used for control of: VOC/HAPs Rating: TBD Type: ECD MMBtu/hr / Make/Model: (3) IES 48" Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >98 % Minimum Temperature: TBD 'F Waste Gas Heat Content: 2605 Btu/scf Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: TBD MMBtu/hr O Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 COLORADO 4 iAV ""� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SO. NO. CO VOC ECDs 95 HAPs ECDs 95 Other: ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basin Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions& (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SO. NOx 0.068 Ib/MMBtu AP -42 0.01 0.01 0.02 - 0.02 CO 0.31 Ib/MMBtu AP -42 0.06 0.06 0.07 -- 0.07 VOC 0.272 lb/bbl AP -42 7.64 0.38 9.17 — 0.46 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions ear ounds/ (P Y ) Controlled Emissions6 (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.005 Ib/bbl AP -42 292 . 15 ' 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 AVIV COLORADO 5 I C pvtrag M c rag= Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in fpll compliance with each condition of General Permit GP07. Sige of Legally Authorized Person (not a vendor or consultant) Jon Torizzo Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance Ei Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 6 I AV's NuiR bFrwro'un.nl COLORADO Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 2(p (k) E KIS AIRS ID Number: r Z- /q %6 a o [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Extraction Oil & Gas, Inc. Cito Trust Production Facility Site Location NWNW Sec 1 T4N R68W County: Weld Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Jon Torizzo (303) 396-6051 air@extractionog.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via a -mail to the address provided. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 42320 1 pp COLORADO 1 I m- i Y H.Yrt.6 Fi�avmenl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action 0 NEW permit OR newly -reported emission source O Request coverage under traditional construction permit ❑ Request coverage under a General Permit 0 GP05 D GP08 If General Permit coverages requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment 0 Change company name' ❑ Change permit limit 0 Transfer of ownership4 ❑ Other (describe below) OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info rt Notes: 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: Company equipment Identification No. (optional): For existing sources, operation began on: Two (2) - 400 bbl Produced Water Storage Tanks For new or reconstructed sources, the projected start-up date is: 05/04/2019 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year 0 Exploration Er Production (EftP) site ❑ Midstream or Downstream (non EftP) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes ❑ No Are Flash Emissions anticipated from these storage tanks? ✓ Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No ✓ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes No ✓ Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No ✓ ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes ❑ No ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 21 COLORADO zxyarcntme Ps, ..&b.,fr nflsn Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbl/year) 163,828 Requested Annual Permit Limits (bbl/year) 196,594 From what year is the actual annual amount? Tank design: ✓❑ Fixed roof 2019 O Internal floating roof 0 External floating roof Storage Tank I # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) 2 800 11/2018 5/2019 Wells Serviced by this Storage Tank or Tank Battery's (E£tP Sites Only) API Number Name of Well Newly Reported Well See Form APCD-212 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EaP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.346453/-104.960122 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECD —20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) D Upward ❑ Downward O Horizontal 0 Other (describe): 0 Upward with obstructing raincap Indicate the stack opening and size: (check one) Q Circular Interior stack diameter (inches): TBD ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 COLORADO 3 I Aia.. H.aR. E FJf.b4'1RM,M Permit Number: AIRS ID Number: [Leave blank unless A.PCD has already assigned a permit #f and AIRS ID] 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: Vapor 0 Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑✓ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECD MMBtu / hr p Make/Model: (3) I ES 48' Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD Waste Gas Heat Content: Constant Pilot Light: ❑ Yes ❑ No Pilot Burner Rating: 1278 TBD Btu/scf MMBtu/hr 0 Closed Loop System Description of the closed loop system: 0 Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (EEP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —40 psig Describe the separation process between the well and the storage tanks: Hydrocarbon liquids flow from wellhead, into seven (7) HLP separators, and then into two (2) produced water storage tanks Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 COLORADO =TV' Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form7. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 95 NOx CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? 201 9 Criteria Pollutant Emissions Inventory Pollutant Emission Factory Actual Annual Emissions Requested Annual Permit 5 Emission Limit(s) Uncontrolled Basis Units Source (AP -42, ;, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.118 lb/bbl Fla lib/ tanks 409d 9.65 0.48 11.57 - 0.58 NOx 0.068 Ib/MMbtu AP42 0.02 0.02 0.03 0.03 CO 0.31 Ib/MMbtu AP42 0.11 0.11 0.13 0.13 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract (CAS) Service CAS Number Emission Factor? Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) - Controlled Emissions s (pounds/year) Benzene 71432 Toluene - 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.008 Ib/bbl Fla lib/tanks 409d 1285 64 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. $ Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 COLORADO 5 A �i.L ' �utm 6G.trnnnnh Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. j)))D))7 Signatu of egally Authorized n (not a vendor or consultant) Date Jonathan Torizzo Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: O Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.Rov/cdphe/apcd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 cotoReoo 6 I AV �o� xw+�.er,:.amm.ni Hello