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Home My WebLink About20201462.tiffa COLORADO Department of Public Health b Environment Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 April 21, 2020 Dear Sir or Madam: RECEIVED APR 2 4 2020 WELD COUNTY COMMISSIONERS On April 22, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - Merlin 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 Public Req:et.J cc: p p) Hl-6.34vw(sn1Ea/cH/cig O6 6314 5/i2 -/2o 5 (t '/2o 2020-1462 a Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, Inc. - Merlin Production Facility - Weld County Notice Period Begins: April 22, 2020 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Extraction Oil Et Gas, Inc. Facility: Merlin Production Facility Oil and gas production facility SWNW Sec 29, T6N, R67W Weld County The proposed project or activity is as follows: Source proposes to operate new well production facility including condensate storage tanks, produced water tanks, condensate loadout, and flaring of gas from gas - liquid separators. 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 19WE0931 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: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 jt. COLORADO Department at Public Health b Environment Colorado Air Permitting Project .. PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only • Review Engineer: Timothy$harp Brad Eades as of 3/25/20 Package#: 419020 s - Received Date: : 04.10.2{319 Review Start Date: 18/38/2019;= L �,.,.. Section 01-Facility Information - _Company Name: Eytrattieit Oil&gas,Ent. I'. Quadrant Section Township Range County AIRS ID: .1?.3 - - swarm Plant AIRS ID: '.AOWE Facility Name: !IMERuuld PRODUCTION FAC€LITY • s iisiggasYseTeasieggYetglieseissie - _ " Physical -- - Address/Location: swnw quadrant of Section 29,Township 6N,Range 67W - - - County:Type of Facility ,1 p(w.rabw,n ',tfin70ap"'tr. . s f " ' t ,g^' t' ^$ - - - - What industry segment�it <.$� turdja``Ij 'aPrskst`ligxIs this facility located in a NAAQS non-attainment area? 1ra :<:, Yex`, t"r' is - - - If yes,for what pollutant? �y4 Qk'$r,A'C ; Section 02-Emissions Units In Permit Application - - - - - - - - - . - • - - - Leave Blank-For Division Use-Only Permit# • AIRS Point# -. _ - - • -Emissions (Leave blank unless Issuance Self Cert - Engineering - - - - (Leave blank unless APCD Emissions Source Type Equipment Name Control? - APCD has already # Required? Action _ Remarks -has already assigned) assigned) i I I Permit$r tell r%E t Coilc7ensa.e Tank Opt TQr;.l:s l Yes ?StsVYO°?1 CP.1 Yes- Issuance I Permit Initial • Proda+:ed a,a.er Tuek P' Te'vks Y 090 1S932 CPS-. Yes 55305cc - - r 's I _ . � Perms Initial . .... �a = O03 s 'r0 Liquid Loading= - -Lveddaut ?e0 19W00033 Ce1 Yes c-uasee -- - • Permit Initia} O04 Separator Venting 1RT.., -Yes I 19WE0934. .:.CPS Yes ' I Issuance - ... 1 Permit initial ..,005- - Separate,'Venting, -- LP Separator - YeS • --LSWEOR3a" -UP? t°es, Issuance -- - I L • Section 03-Description of Project nsl.4tiro cs��x T n Y New well Production 4-ec:i ty xd Q6}ror,.;ontaPv�e;is. -_ '' = — � z'a"'"u raPa( ",' ` ra it � 5 - F u ax tmo-n Sections 04,05&06-For Division Use Only • Section 04-Public Comment Requirements Is Public Comment Required? Ygs�Gi If yes,why? • Section 05-Ambient Air Impact Analysis Requirement - • Was a quantitative modeling analysis required? n r' Sra• If yes,for what pollutants? Vggs4T w t'(nn',gzsai' If yes,attach a copy of Technical Services Unit modeling results summary. " Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? 2.57eIryier^ . If yes,indicate programs and which pollutants: 5O2 NOx CO VOC PM2,5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) Title V Operating Permits(OP) J [4— Non-Attainment Nev/Source Review(NANSR) Is this stationary source a major source? If yes,indicate programs and which pollutants: 3O2 NOR -CO VOC--7PM2:5 PM10 TSP HAPs preventiontlVOperating t Deterioration(PSD), Title V Operating Permits(OP) [JF Non-Attainment New Source Review(NANSR) • Condensate Storage Tank(s)Emissions Inventory Section 01-Administrative Information Facility AIRS ID: RO$E 002., County I Eades as of 3/2! Point Section 02-Equipment Description Details • Detailed Emissions Unit . rite$ `a�it" `taf � f� t "fr'�k�,� Description: �e...a1. a≥' as,:.._ Vstgw .aes n _ _w_a,. ......._... Emission Control Device } —'. Description: R � � � ��ri a�x r° a - p I ^....-� a Requested Overall VOC Si HAP Control Efficiency%: t€.E HEztlftl1-1 Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Condensate Throughput= a � E Barrels(bbl)per year Requested Permit Limit Throughput= ;, ff Barrels(bbl)per year Requested Monthly Throughput= 49044.5 Barrels(bbl)per month Potential to Emit(PTE)Condensate s, A - Throughput= pa�I1;: - •Barrels(bbl)per year Secondary Emissions-Combustion Device(s) k k, Heat content of waste gas= ' 16211°Btu/scf Volume of waste gas emitted per BBL of liquids produced= ,• ..` 'scf/bbl 0.2544382€c4 mmBTU/hr Actual heat content of waste.gas routed to combustion device= 2,22823 MMBTU per year Requested heat content of waste gas routed to combustion device= 2,674,7 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 2,674.7 MMBTU per year Control Device Pilot Fuel Use Rate: scfh S-to MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf 0:0 MMBTU/yr • Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? r:')( Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Condensate (Condensate Throughput) Throughput) VOC MIA41447411. 0,0074 r luW Benzene �'>IUdfh. 0.0000 ' Toluene I kdto1 ..°°1tad 0.0000 i'illtelfrNIAFfictfattitOrt Ethylbenzene to0f 9 .- 0.0000 >.,; Xylene 00�� 1"�...."'; 0. 00 �e;..... n-Hexane3 0.0001 224 TMP SOU? 0.0000 - -, ,V> Control Device _ Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (fb/bbl) Emission Factor Source (waste heat (Condensate combusted) Throughput) PM10 - 0.0000 PM2.5 - O-0000 NOx 00680--1 0.0000 a' 4 �3^ CO 4,z?().3100: _ 0.0000 Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/MMscf) Emission Factor Source (Waste Heat (Pilot Gas Combusted) Throughput) PM10 "d;'xA f :! 0.0000 PM2.5 0. sa 1 % 0,0000 PV,DeitPXI NO. _ .,.rI $`:!.a '0.0000 -.. CO = `s 0.0000 -' .... -. .,.. - Section 05-Emissions InvenSory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year). (tons/year) (lbs/month) VOC 42.9 35.8. 1.8 42.9 2.1 364.5 PM10 0,0 0.0 0.0 0.0 -0.0 0.0 PM2.5 0,0 0.0 0.0 0.0 '' 0.0 0.0 NOx 0.1 0.1 0.1 0.1 0.1 15.4 CO 0.4 0.3 0.3 0,4 0.4 70.4 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 138.9 116 6 138.9 . - 6.9 Toluene 105.6 88 4 105.6 5.3 Ethylbenzene 9.9 8 • 0 9.0 0.5 Xylene 34.0 28 1 34,0 '1.7 n-Hexane 1374.4 1145 57 1374.4 68.7 224 TMP 8.1 7 - 0 8,1 0.4 C:\Users\beades\Desktop\RetrhBe Work\TJs Packages\PubCom Packages\419620 Extraction\19WE0931.19WE0932.19WE0933.19WE0934.19WE0935.CP1 Condensate Storage Tank(s)Emissions Inventory - - Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B - Source requires a permit Regulation 7,Section XI I.C,D,E,F Storage tank Is subject to Regulation],Section XII.C-F Regulation 7,Section XII.G,C Storage Tank is not subject to Regulation 7,Section XII.G - - - Regulation 7,Section XVII.B,Cl,C.3 Storage tank Is subject to Regulation 7,Section XVII,B,C.1&C.3 Regulation 7,Section XVII.C.2 Storage tank is subject to Regulation 7,Section XVII.C.2 Regulation 6,Part A,NSPS Subpart Kb Storage Tank is not subject to NSPS Kb - - Regulation 6,Part A,NSPS Subpart 0000 Storage tank is not subject to NSPS 0000. - NSPS Subpart 0000a - Storage Tank is not subject to NSPS 00000 Regulation B,Part E;MACT Subpart HH Storage Tank-is not subject to.MACT Hff (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? ' If yes,are the uncontrolled actual or requested emissions'estimated to be greater than or equal toSS tons VOC per year? If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specificaemissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? $; -- If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the iiiik -facility being permitted?Thissample should be considered representative which generally means ate-specific and •collected within one year of the application received date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older site-specific sample. . - If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. E Does the company request a control device efficiency greater than 95%for a flare or combustion device? 3 ,, If yes,the permit will contain and initial compliance test condition to demonstrate the destructionefficiency of the combustion device based on inlet and outlet concentration sampling Section 08-Technical Analysis Notes _ ., ra xr n- ..„u c rria attg. 3 " .y"`s` � -: g # ° `, —"u z -7i .,"r te^ 'sr.»v •. ≥ '"z "_ �rW,. a'zt„ -s. _-'>r'E4'ili 0 R s` � ' .. § Section 09-Inventory SCC Coding and Emissions Factors - - Uncontrolled • - - - - Emissions AIRS Point N Process g SCC Code - Pollutant Factor Control% Units . 001 01 F X 7 YS tjA rlr �do v` ,,,, PM10 0.00 0 lb/1,000 gallons condensate throughput. PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.01 0 lb/1,000 gallons condensate throughput VOC 3.5 95 lb/1,000 gallons condensate throughput' CO 0.03 0 lb/1,000 gallons condensate throughput Benzene 0.01 95 lb/1,000 gallons condensate throughput Toluene 0.00 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput - - Xylene 0.00 -95 lb/1,000 gallons condensate throughput n-Hexane 0.06 95 lb/1,000 gallons condensate throughput. 224 TMP 0.00 95 lb/1,000 gallons condensate throughput • C:\Users\beades\Desktop\3tefrtae Work\TJs Packages\PubCom Packages\419620 Extraction\19WE0931.19WE0932.19WE0933.19WE0934.19WE0935.CP1 • • • Condensate Task Regulatory Analysis Worksheet • The regulatory requirements below are determined based on requested emissions. Brad fades as of 3/25/20 Colorado Re:ulation 3 Parts A and'B-APES and Permit Requirements • fSaurce Oslo the Nun-Attainment Area • I ATTAINMENT • 1. Are uncontrolled actual emissions from any Criteria pollutants from this individual source greater then 2T®'(Regulation 3,Part A,Section II.O.1.a)? 2, Is the construction date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 03-OS Definitions 1.12 and1,14 and Section 2 for additional guidance on grandfather applicability)? . 3. Are total facilitµuncontrolled VOGemksions greater than 5 Ton,NOx greater than 10 TPY or CO emissionsgreater than 10 TOY(Regulation 3,Part B,Section 11.0.3)? IYou8uve indicated that source Is In the Non-Attainment Area NON-ATTAINMENT . 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater then 1TPY(Regulation 3,Part A.Section ll.D.S.a? Source Requires an APEN.Go to a al 2. Is the construction date(service date)prior to 12/30/2002 end not modified after 32/31/2002(See Ps Memo 05-01 Definitions 1.12 and1.14 and Section 1'f&additional guidance on grandfather applicability)? Go to next question 3. Are total facility,uncontrolled VOC emissions greater than 2TPY,NO]]greater than 5TPY or CO emissions greater than lO TPA(Regulation 3,Part B,Section 11.0.2)? -'l Source Requires a permit Souse requires a.permit - - C ldrade Reeototiea 7,Sealer XII.C-F 1. 'sthisitarage tank located in the B-hr ozone control area Ar any ozone non-attainment area or ettainmentllmainn nce area? Yes Continue-You have Indicated th 2. Is this storage tank located at an oil and gas exploration ant production operation',natural gas compressor station or natural gas drip station? Yes Continue-You have Indicated th 3. Is thls storage tank located upstream of a natural gas processing plant? a,�ii l Source its subject I Storage tank is subject to Regulation 7,Section all-C-F Section XII.C1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Section XII.C.2—Emission Estimation Procedures - - Section%ILO—Emissions Control Requirements Section BILE—Monitoring Section%ILF—Recordkeeping and Reporting - - - • Colorado Regulation 7,Section XII.G ' 1. Is this storage tankloated in the 8-hr ozone control area or any ozone non-attainment aree orattainmentainaintenence area? Yes Continue-You have determined - - 2. Is this storage tank located ate natural gas processing plant? No Storage Tank is not subjectto Re _ 3. Does this storage tank exhibit"Flash"(e.g.storing non-stabilized liquids)emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOL? UM,Source is subject 'Storage Tank N not subject to Regulation 7,Section%n.G Section 011.0.2-Emissions Control Requirements 3ectianXll.C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage . Section XII.C.2—Emission Estimation Procedures Colorado Regulation 7,Section XVII - 1. Is this tank located ate transmission/storage facility? No Continue=You have indicated th 2. is this condensate storage tank'located at an of and gas exploration and production operation,well production facility',natural gas compressor station"or natural gas processing plant? yes Go to the next question-You ha 3. Is this condensate storage tank a fixed roof storage tank? kr,sV41 Go to.thehextquestion 4. Are uncontrolled actual emissions of this storage tank equal to or reefer than 6 tons per year VOC? s Source is subject to parts of Regi- - Storage tank is subject to Regulation 1,Section XVII,B,C.1&C.3. . Section WILD—General Provisions for Air Potshot Cantrol.Equipment and Preventionof Emissions Suction%VII.C1-Emissions Control and Monitoring Provisions Section ttV11.C3 Recordkeeping Requirements 4 5. Does the condensate storage tank canton only esehibzed liquids? ri :'MIsource is subject to all provision] ' (Storage tank is subject to Regulation 7,Sectlon XVtt.C.2 Section Xvii.C.i-Capture and Monitoring for Storage Tanks feted with Air 0002005 Control Equipment . 40 CFR.Part 6O.Subpart Kb,Standards of Performance for Volatile Organic Liquid Storage Vessels • 1 Is the individual storage vessel capacity greater than or equal to 75 cubic meters(m)["472 BBLs]? `8 sz MLR Storage Tanks not subject NSPS 2. Does the storage vessel meet the following exemption in 6O111b(d)(4)? 5rp LR • a.Does the vessel has a design capacity less than or equal to 1,589.874 ms["10,000 BBL]used forpetroleum'or condensate stored,processed,or treated priorto custody transfer'as defined in 60.1115? - 3. Watt hit condensate storage tank constructed,reconstructed,or modified(see definitions 40 CFR,60.2).afterJuly 23,1984? y7 4. Does the tank meet the definition of"storage vessel"'in 60.1115? 5, Does the stdrage vessel store a"volatile organic liquid(VOL)"s as defined in 60.1116? Wag 6. Does the storage vessel meet any one of the following additional exemptions: t"'"Tp'" ` • a.Is the storage vessel a pressure vessel designed to operates excess of 204.9 kPa["29.7psi]and without emissions to the atmosphere 160.110b(d)(2)17;or Wot`'t+n i'a e/ b.The design capacity is greater than or equal to 151 ms["950 geL]and stores a liquid with a maximum true vapor pressure'less than 3.5 kPa(e0,110h(b))?;or tm "")(,s • c.The design capacity is greater than or equal to 75 M3 r.472 BBL]but less than 151 ma I'"950883]and stores a liquid with a maximum true vapor pressure'less than 15.0 kPa(60.110h(b))? 4o "°'l'°° 7. Does the storage tank meet either one of the following exemptions tram control requrements egraPELM a The design capacity Is greater than or equal to 151mI^950 BBL]and stores a liquid with a maxmum true vapor pressure greater than or equal to 35kna but less than 52kPa?,or - lippflaa.47fs" b.The design capacity is greater than or equal to 75 M5[-472 BBL]but less than 101 m'('"950 Boll and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kna but less than 27.6 kPa? Storage Tank is not subject to NSPS Kb 40 CFR.Part 60,Subpart 0000/13000a,Standards of Performance for Crude Oil and Natural Gas Preductienjransmission and Distribution 1. Is this condensate storage vessel located at ofacility in the onshore oil and natural gas production segmen>rnatural gas processing segment or natural gas transmission and storage segment of the industry? Yes Continue-You haw Indicated th 2. Was this condensate storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)Between August 23,2011 and September 18,2015? S storage Tank is not subject NSPS 3. Was this condensate storage vessel constructed,reconstructed or modified(see definitions 40 CFR,60.2)after September 18,2015? �sy�sp 5 Go to the next question 4. Are potential VACemissans'from the individual storage vessel greater than or equal to 6 tons per year? AQ Stoage Tanks not subject NSPS • 5. Does thscondeasate storage vessel meet the definition of"storage vessel"'per 605430/60.5430a? Own' 6. Is the storage v sal subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb men CFR Part 63 Subpart NH? gri).. 1.n 'Storage Tank is not subject to SOPS 0000e • • [Note:If a storage vessel is previously determined to be subjectto NSPS 0000/0000e due to emissionsaobove 6 tons ear Year VOC on the applicability determination date,it should remain subject to NSPS 0000/0000a per 60.5365(e)(2l/68,5365a(e)(2)even if potential VOC emissions drop below 6 tons per year] 40 CFR.part 60,Subpart MAR 00,Oil and Gas Production Facilities 1. Is the storage tank located atan oil and natural gas production facility that meets either of the following crwria: Ines IContinue-You haw indicated th • a.A fadlity that processes,upgrades or stares hydrocarbon liquids(63.76ola(2));OR • b.Afadllty that processes,upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user'(63.760(a)(3)1? aa 2 Is the tank located at a facility that is majors for HAPs? tip'5k §Storage Tank is not subject MAC 3, Does the tank meet the definition of"storage vessel"'in 63/61? ren?¢:Lrfs°'a 4. Does the tank meet the definition ofstorage vessel with the Went eiforflash emssions"s per 63.761? rue' 5, 'stile tank subject to control requirements under 40 CFR Part 60,Subpart Kb or Subpart 0000? - '181 'Storage Tank is not subject to MACY HN • Subpart A,General provisions per§63.764(a)Tablet §63.766-Emissions Control Standards §63.773-Monitoring • §63.774-Recordkeeping 463.775-Reporting - RACT Review RACE review is required if Regulation 7 does not apply AND it the tank Is in the non-attainment area.If the tank meats bath criteria,then review RACT requirements. , Disclaimer • • Thisdocument assists operators with determining applicability of certain requirements akthe Clean Air AM,its implementing regulations,and Air Quality Control Commission regulations.This document is note rule car regulation,and the analysis it contains may not apply to a particularsduatioe based upon the individual facts and circumstances.This document does not change or substitute for any law, reg lotion,orany other legally binding requirement and is not legally enforceable.In theeuent ofany aontlict between the language ofthis document and the language of the Clean AirAcl„its implementing • regulations,and Alr Quality Control Commission regulations,the language of the statuteeor regulation will control.The use of non-mandatory language such as'recommend," "can,"is - intended to describe APCO interpretations and recommendations.Mandatory terminalogysuch as"must,and"required"are intended m describe controlling•requirements under the terns of the dean Air Acl and Air Quality Control Commission regulations,but this document does not esfablieh legally binding requirements in and of$self, . I Produced Water Storage Tank(s)Emissions Inventory Section 01-Administrative Information . - -- County Brad Ead s as of 3/25/2i Point Section 02-Equipment Description Details ' Detailed Emissions Unit • =U � sr� ""' '- �„°� Description: r. ..iolt:0 `nL.I rsr 3'' -Emission Control Device' 'o' . ��a a r a '''� Description: -i,�.,<,,...,6=.�r� 5fA `l,"� � _._ y fa4 �..>..,, wnxtts ..�.use...�.. ,..,.,: ....n. _ - - - - - - Requested Overall VOC&HAP[antral Efficiency/ tam;..--- 47.,' Section 03-Processing Rate Informationfor Emissions Estimates Primary Emissions-Storage Tank(s) Actual Produced Water Throughput-= 13420 Barrels(661)per year Requested Permit Limit Throughput= 400,000..Barrels(bbl)per year Requested Monthly Throughput= 33973 Barrels(bbl)per month Potential to Emit(PTE)Produced Water Throughput; ' _ 400,000'.Barrels(bbl)per year - - Secondary Emissions-Combustion Device(s) Heat content of waste gas= - "°°� k"' 'Btu/scfi - - - Volume of waste gas emitted per BBL of liquids q k"'fi produced= ,0140,T4"'r rm „scf/b61 Actual heat content of waste gas routed to combustion device= 42.2 MMBTU per year Requested heat content of waste gas routed to combustion device= 135.2 MMBTU per year - Potential to Emit(PTE)heat content of waste gas routed to combustion device= 135.2 MMBTU per year Control Device 4 Pilot Fuel Use Rate: , ,,,An2°'i scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: a o':c,:. ni( iw,m§Btu/scf 0.0 MMBTU/yr - - Section 04-Emissions Factors&Methodologies tl Will this storage tank emit flash emissions? »ka., Emission Factors Produced Water Tank - - Uncontrolled Controlled - Pollutant (lb/bbl) (lb/b61) Emission Factor Source (Produced Water (Produced Water ' Throughput) Throughput) • • VOC 1RS4E>t r 3.80E-04 r °".-_,.' 7.'. Benzene RE S„@110i100020‘, 0:0000 Toluene p(4°4>d s0,R000-}° r5 0.0000 ' Ethylbenzene • anFvc2a);IO;f50t' 111,3t'""*,'; •0,0000 - .Xvlene 's' .."Paa04(051rD _A 0.0000 J ?. n-Hexane r .01102,WAM 0.0000 5.;n mi) m 224TMP .,0 11g a i15 0! 0.0000- x.t 4! ,., `0: 0_ Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/bbl) Emission Factor Source (waste heat (Produced Water combusted) Throughput) PM10 y 400149.: # 0.00000 M:` t y,. PM2.5 '':." `: r`T', 0.00000 z'f a NOx li ;r6000AINT 0.00002 r co iAtIGIVAtI4i0iligin 0,00010 O.,. ,s , Pilot Light Emissions Uncontrolled - Uncontrolled - Pollutant (lb/MMBtu) Ib/MMscf Emission Factor Source - - - - ' (Waste Heat Combusted) (Pilot Gas Throughput) PM10 '''' 0.0000 V t.1j�° b.. .. _ .. . PM2.5 000 0.5 i NOx 00000: 0.0090 ' CO 0.3100 0.0000 "i-.:� U. . vi:e .. 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) (tons/year)' (tons/year) (tons/year) (lbs/month) VOC - 1,5 - 0.5 - 0.0 - 1.5: 0.1 12.9 PM10 0.0 '0.0 0.0 0.0. 0.0 0.1 - PM2.5 0.0 0.0 0.0 0.0 0.0 0.0 - NOx 0.0 0.0 0.0 0.0- 0.0 0,8 CO 0.0 0.0 0.0 0.0 0.0 3.6 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 232.4 72 4 2323 11.6 Toluene 133.6 ' 42 2 133.6 6.7 Ethylbenzene 7.6 2 0 7-67 0.4 Xylene 21.6 7 • 0 21.6 -1.1 - n-Hexane 77.2 24 1 77.2 3.9 - 224 IMP - ' 0.0 0 0 0.0: .0.0 . C:\Users\beadeADviS8op\Remote Work\TJs Packages\PubCom Packages\419620 Extraction\19WE0931.19WE0992.19WE0933.19WE0934.19WE0935.CP1 Produced-Water Storage Tank(s)Emissions Inventory Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B - Not enough information - - - Regulation 7,Section XVII.B,C.1,C.3 Storage Tank Is not subject to Regulation 7,Sect'[onllVli Regulation 7,Section XVII.C.2 - Storage Tank is not subject to Regulation 7,Section-XVII,C.2 Regulation 6;Part A,NSPS Subpart Kb Storage Tank is not subject to NSPS Kb - - - - - Regulation6,Part A,NSPS Subpart 0000 Storage Tank is not subject to HOPS 0000. - - -. - - - NSPS Subpart 0000a - Not enough information - (See regulatory applicability worksheet for detailed analysis) - - Section 07-Initial and Periodic Sampling and Testing Requirements, - - - Does the company use a site specific emissions factor to estimate emissions? - P • If yes and if there are flash emissions,are the emissions factors based on apressurized liquid water sampledrawn at the facility - _ being permitted and analyzed using flash liberation analysis?This sample should be considered representative which.generally :if;means site-specific and collected within one year of the application received date.However,if the facility has not been modified e _ - (e.g,no new wells brought on-in),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%for a flare or combustion device? -If yes,the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling - - Section 08 Technical Anal Mot s rgIJE5 IN5.1� ,mot,.: .. 4 t" :r�"'q,"3'tl7pf� 7 u r it tan 'P1„"aTtS .1 ERMkT.,.., � tdry �" ' C& t>8" � iret ��x � n4 ` (1�z i... - . P sa g3r�"dpEli'e*d�t,loy dit. trf�,6.��tlddRiid __ mere pji orodu iFiato ,n ?S'�7A��1'.-,,• rza irt�l is•it z"�� arm: /a nc „w ra"tl Ya P s, Smi s ,rte y as tr{r 1 r SSl�tt1" �. �a�aq' cngirrg1 p"f - . � �. a s st a�nrr ,rr4,6 ," *t ral a ; ~yam 1 rrrat r k �y ism`eurfCa off_ — �`=x ii i prrt k,^r� ssRap _ r p,�a,i* ,^�, je P<iu vn�v p s � ' rz as3+- rp uc»r ri lFZ2 x� ra s'p'^ircr',cbl:3b(�i,4 a P .an. : x` _ t2a 2 j. r rq°i �i a `" R azar h '4F8N 9'ii Mii' Apr ya da.,..,.,. i a Y'"S.^ 2 1 G i T p( 3 `2 ` 41;177a " x i,^t, q#S> ' ..' {i x a:'^ rt y ae rtigrr G r 1 3` 1 M�8 ka a_. s t - s &' ff. -- tPfr d3h r a nz - " a r(eu a pi7 ap4 b . ' asr .Ali-, `a` "P p. • 1 tt � rams 9t i ii - "'ilA� lar rd"i 4.451h.01% - _Section 09-Inventory SCC Coding and Emissions Factors - - - Uncontrolled .. - Emissions AIRS Point it Process it SCC Code Pollutant -Factor Control%Units 002 01 4-04-003-15 Fixed Roof Tank,Produced Water,working+breathing+Flashing losses - PM10 0.0001 0.0 lb/1,000 gallons liquid throughput - - _ - - PM2.5 0.0000 5.0 lb/1,000 gallons liquid throughput - .. 505 - 0.0005 0.0 15/1,000 gallons liquid throughput - . VOC 0.1808 •95.0 lb/1,000 gallons liquid throughput CO 0.0025- 0.0 1b/1,000 gallons liquid throughput - Benzene 0.0138. 95.0 'lb/1,000 gallons liquid throughput - - - - - Toluene 0.0080 95.0 lb/1,000 gallons liquid throughput Ethylbenzene 0.0005 95.0 lb/1,000 gallons liquid throughput - - Xylene - 0.0013 95.0 lb/1,000 gallons liquid throughput' n-Hexane 0.0086 95.0 lb/1,000 gallons liquid throughput 224TMP _ 0.0000 95.0 lb/1,000 gallons liquid throughput : I C:\Users\beadog oiSIRop\Remote Work\TJs Packages\PubCom Packages\419620 Extraction\19WE0931.19WE0932.19WE0933.19WE0934.19WE0935.CP1 • Produced Water Storage Tank Regulatory Analysis Worksheet • The regulatory requirements below ore determined based on requested emissions. • Oral Eades as of 3/15/20 • Colorado Regulatimr3 Parts A and B-APEN and Permit Requirements Source isIn the Non-Attainment Area ATTAINMENT 1. Are uncontralledactual emissions from any criteria pollutants from this individual source greater thaw 2 TPY(Regulation 3,Part A,Section ll.D.1.a)? 2. Is the operatprdalrning less than ltd crude oil and is the tank located at.anon=commercial facility for processing oil and gas wastewater?(Regulation.3,Part B,section ll.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TP?,Nov greater than 1OTPY or C0 emissions greater than 1OTPY(Regulation 3,Part B,Section 11.0.317 you have indicated that source is in the Non-Attainmem Area • NON ATTAINMENT 1. Areuncontrolledemissons from any criteria pollutants from the individual source greater than rTPY(Regulation 3,Parts,Section Il.D1.a)? ' 2. Is the operatorclaming less than 111 crude oil and the tank located ate non-commercial facility for processing oil and gas wastewater?(Regulation 3,Part 0,Section ll.D.1.M( ${,` Go to next question 3. Are total facility uncontrolled VOC emissions greater than 2TPY,NOx greater than 5TPY or CO emissams greater than SOTPY(Regulation 3,Part B,Section lI.D.2(3• r„,,,„ °sMS Source is APEN-requirr INotenough information .. - Colorado Regulation 7,Section XVII - 1. lithis tank located ate transmission/storage facility? No 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 station'or natural gas processing plant? Yes Continue-You have in 3. Is this produced water storage tank a fixed roof storage tank? Yew,'4� Go to the nextquestio 4. Are uncontrplied actual emissions of this storage tank equal to or greater than 6 tons per year VOC3 Storage Tank is not Sul 'Sterne Tank is net subject to Regulation 7,Section XVII , Section XVII.0-General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1-Emissions Control and Monitoring Provisions section XVII.C.3-Recardkeepfng Requirements - 5. Does the produced water storage tank contain only"stabilized"liquids?If no,the following additional provisions apply. 15Aggpai Storage Tank is not sot • Ist rage Tank Is not subject to Regulation 7,Section XVII,C.2 Section XVII.C.2—Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment • 40 CFR.Part 60,Subpart Rb.Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters(ma)["472 BBLs]? r -Storage Tank Is not sul 2. Does the storegevessei meet the following exemption In 60.111b(d)(4)? „ a.Dees the vessel has a design capacity less than or equal to 1,589874 m5[M.0,000 BBL]used for petroleum'or condensate stored,processed,or treated prior to custody transfer'as defined in 60.111b? - - • 3. Was this condensate storage tank constructed,reconstructed,or modified(see definitions 40 CFR,69.2)after July 23,1984? s "&, •, 4. Does the tank meet the definition of"storage vessel"'in 60111b? „ 5. Does the storage vessel store a"volatile organic liquid(VOL)"t as defined in 60.111b? 6. Does the storagevessel meet any one of the following additional exemptions: i- • • a.Istle storage vessel a pressure vessel designed to operate In excess of 2049 kPa["29.7 psi]and without emissions to the atmosphere(6011Db(d)(2))?:or b.Thedesign capacity Is greater than or equal to 151 m'[-950 BBL]and stores a liquid with a maximum true vapor pressure'less than 3.5 kPa(60.110b(b))7,or c.Thedesign capacity is greater than or equal to 75 M5["472 BBL]but less than 151 m'["950 BBL]and stores a liquid with a maximum true vapor pressure'less than 15.0 kPa(60.110b(b))? 7. Does the storagetank meet either one of the following exemptions from control requirements: f: x a.Thedesign capacity is greater than or equal to 151 m'("950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?;or b.Thedesign capacity is greater than or equal to 75 M5['"472 BBL]but less than 151 ma[^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 bra? Storage.Tank Is notsubject to NSPS Kb • • • 40 CFR,Part 60.Subpart 0000/0000a,Standards of Performance for Crude Oil and Natural Gas Prediction.Transmission and Distribution • 1. Is this produced water storage vessel located ata 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 hays 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 sul 3. Was this produced water storage vessel constructed,reconstructed,or modified(see definitions 40€FR,60.2)after September 18,2015? • 4. Are potential MC emissions'from the fndivfdbal storage vessel greater than or equal to 6 tons per year? - 5. Does this prod,4red water storage vessel meet the definition of"storage vessel"'per 60.5430/60.543ga? she 6. Is the storage vessel subject to and controlled In accordance with requirementsfor storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? .f"a Not.enough information • • • )Note:if a storage vessel is previously determined to be subject to NSPS 0000/0O00a due to emissions above 6 tons per year VOC on the applicability determination date,it should remain subject to NSPS 0000/0000a per RACE Review • BALE review isaequired if Regulation 7 does not apply AND if the tank is in the non-attainment area.If the tang meets both criteria,then review RACT requirements. • Disclaimer • Tors 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 nate 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 orsubsOtute for any law, • ' • regnlatbn,or any otherlegaly 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 APPAct„its implementing regulations,end Air Quality Control Commission regulations,the language of the statute or regulation will control The use of non-mandatory language such as"recommend,"'may," "should,"and"can,"is Intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must"and"required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. • • • Hydrocarbon Loadout Emissions Inventory Section 01-Administrative Information Facility AIRS ID: F" `°"" �6�"€"s.^₹ x^S ,,.f' "r�€ ' County 1Eades as of 3/2! Point Section 02-Equipment Description Details Detailed Emissions Unit -�1� i� € ��µ, sJr %r Tie t�€ i. t rfmw„r�„L^„l x �.t i <t rt€, €..+_ s a:;� Description €.: c" .Tr � fY;1' r,�Egg .. gbs :kb'a di 2�a €to MS M Emission Control Device ^, '' . , T-g . .€k s€ssss r;..s ` s,,3 _m' .4,0*. . e .„..._,... �,▪ rr Description: ..,c. �" a .v X.��_..._..,..▪. rs.^.,..FA...-W. Is this loadout controlled? Requested Overall VOC&HAP Control Efficiency%: Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Hydrocarbon Loadout Actual Volume Loaded= €ti'hi$i '.Barrels(bbl)per year 'Requested Permit UmitThroughput= _-_ Y2J381 Barrels(bbl)per year Requested MonthlyThroughput= 2410 Barrels(bbl)per month Potential to Emit(PTE)Volume Loaded= J39;3$Y!'.Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= �Btu/scf 0.006211315 MMBTU/BBL Actual Volume of waste gas emitted per year= 32545 scf/year Requested Volume of waste gas emitted per year= 39054 scf/year Actual heat content of waste gas routed to combustion device= 147 MMBTU per year Requested heat content of waste gas routed to combustion device= 176 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 176 MMBTU per year Control Device I I I Pilot Fuel Use Rate: i ss scfh 0.0 MMscf/yr ME Pilot Fuel Gas Heating Value: „xa„+n ca¢≥„,,,,,.J Btu/scf 0.0 MMBTU/yr Section 04-Emissions Factors,&Methodologies Does the company use the state default emissions factors to estimate emissions? tir F.rgu"`t3,„a Does the hydrocarbon Ilquid loading operation utilize submerged fill? '„g; t; ,,fs The state default emissions factors maybe used to estimate emissions. Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Volume (Volume Loaded) Loaded) VOC - 2.36E-OS 1.18E-02 Benzene 4.10E-04 2.05E-OS - , Toluene 0.00E+00 0.00E+00 - - - Ethylbenzene 0.00E+00 0,00E+00 ,- - Xylene 0.00E+00 0.00E+000.4.42,4144:=404.4844'3*.', n-Hexane 3.60E-03 1.00E-04 S~) 224 TMP 0.00E+00 0.00E+00 .Ih,- r -"- <1 Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) PM10 = 0.00E+00 ,. .' ¢. ,' '€ PM2.5 0.00E+00 gaMtiVattatilMaftr. sox 0.00E+00 NOx 0:0680 „,,c` 2.46E-04 ;0 CO 4.3'+00 1.12E03 * -., Pilot Light Emissions -- Uncontrolled Uncontrolled Pollutant (lb/MM Btu) (Ib/MMscf) Emission Factor Source (Pilot Gas (Waste Heat Combusted) Throughput) PM10 0.0000 .�t, =t4a PM2.5 s 0.0000 i ,914 SOx 0.0000t !zgo.. NOx AA680 OA000 �""' CO „q,3100 0.0000 i,� se .,, y - „ C:\Users\beades\DeiktdOi emote Work\TJs Packages\PubCom Packages\419620 Extraction\19WE0931.19WE0932.19WE0933.19WE0934.19WE0935.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) - ]tans/year) (tons/year) (lbs/month) PM10 0.00 - 0.00 0.00 0.00 0.00 0 PM2.5 0.00 PA0 0.00 0.00 0.00 - 0 sox 0.00 0.00 0.00 0.00 0.00 0 NOx 0.01 - 0.00 0.00 0.01 0.01-' '1 VOC 3.35 - 2.79 0.14 3.35 0.17 28 CO - 0.03 - 0.02 0.02 0.03 0.03 5 Potential to Emit = Actual Emissions Requested Permit Limits - _ Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) Ohs/year) (Ibs/year) (Ibs/year) (Ibs/year) Benzene 12 10 0 12 1 Toluene - 0 0 - 0 - 0 0 Ethylbenzene - 0 0 0 0 -" 0 Xylene i 0 0 0 0 n-Hexane 102 85 4 - 102 5 224TMP 0 - - 0 .. '0 0 - 0 Section06-Regulatory Summon/Analysis - - - Regulation 3,Parts A,B Source requires a permit RACE Regulation 3,Part B,Section III.D.2.a The loadout must be operated with submerged fill to satisfy RACT. (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95%for a flare or combustion deviceIf 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 Analyse Notes _ -E M NSFORPERIQDsoFLACC DOWNTIME at s _ - _ .� r '= - v� -STATE DEFAULT EMISSION FACTORS ARE CONSE)1VATIVE f N ( 4 ' S'' mot°. .�. n Section 09-Inventory SCC Coding and Emissions Factors - - - - - Uncontrolled Emissions AIRS Point P Process if - -'SCC Code Pollutant Factor Control%. Units 003 01 4.06.001-32 Crude CIA Submerged Loading Normal Service(S=0.6) - PM10 0.00 0 lb/1,000 gallons transferred - - - - PM2.5 0.00 0 lb/1,000 gallons transferred - - SOU 0.00 . 0 lb/1,000 gallons transferred NOx 0.01 0 lb/1,000 gallons transferred VOC 5.6 95 lb/1,000 gallons transferred CO 0.05 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred - - Toluene 0.00 . 95 lb/1;000 gallons transferred - - - - - Ethylbenzene 0.00- 95 lb/1,000 gallons transferred _ Xylene 8.00 95 lb/1,000 gallons transferred n-Hexane 0.04 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred C:\Users\betides\Deslcofp'etemote Work\Tln Packages\PubCom Packages\419620 Extraction\19WE0931.19WE0932.19WE0933.19WE0934.19WE0935.CP1 • Hydrocarbon loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissicros. Brad Eadesas of 3/75/28 Colorado Regulation 3 Parts A and B-APEN and Permit Requirements - Source is In the Non-Attainment Area - • ATTAINMENT - • ' ' 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY(Regulation 3,Part&,Section II.O.l.a)? 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section((D.i ll? 3. Isihe loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per-Say on an annual average basis? y 4. Isihe loadout operation loading less than 6,750 hbis per year of condensate via splash fill? ',. 5. Isihe loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? yyry 6, Are total facility uncontrolled VOC emissions greater than 5 TPV,NOx greater than 1OTPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.3)? 9// IYou have indicated thatsaurce is in the Non-Attainment Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria p lI t nts from this individual source greater tharTTPY(Regulation 3,Part A,Section tlD.l.a)? e Go to next, 2 Is the loadou€located atom exploration and p d ut site(e.g.,well pad)(Regulaton 3,Part Er,Section 11011)2 h .Go to then 3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per B y on an annual average basis? Into next, 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? -. Go.to next 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? /-Go to neat 6. Are total facility uncontrolled VOC emissions from the greater than 2TPY,NOx greater than STEN or CO emissions greater than 1OTPY(Regulation 3,PartB,Sectionll.D.2)?. " `Theloadou (Source requlresa permit • . 7. RACE-Are uncontrolled VOC emissions from the laadout operation greater than 20 tpy(Regulalon 3,Part B,Section Ill.D.2.a)? - Gtax(WIThe loadou IThe loadout must be operated with submerged fill to satisfy RACE. Disclaimer This document assists operators with determining applicability of certain requrrements 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 otihe statute or regulationwill control.The use of non-mandatory language such as hecommend,"°may,""should,"and can,"is intended to describe APCD interpretations and recommendations.Mandatoryeterminology 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 apt establish legally binding requirements in and of itself. Separator Venting Emissions Inventory Section 01-Administrative Information - - FacilityAlRsIS' .123: A0SE. 004: g`..-:8 - - - -County Brad Eades as of 3/25/20 Point Section 02-Equipment Description Details VRT VENTINCO DURING COMPRESSOR DOWNTIME 1,511; ��y "„" 4ag �ta" sz`y Detailed Emissions Unit Description: -I 5 `" '� xi ... .2s_""`�...��,,.-..,_-- des a ECD 4. ..e a _ ,z..a ^�¢ a tti z �' - H Emission Control Device Description: ac,Ix a ° 15,4,10,114; Requested Overall VOC&HAP Control Efficiency%: 95 • Limited Process Parameter Gas meter Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= 2.4 MMscf per year Requested Permit Limit Throughput=': 4.8 MMscf per year Requested Monthly Throughput= 0.4 MMscf per month - - Potential to Emit(PTE)Throughput= 4.8 MMscf per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 2449.4 Btu/scf Volume of waste gas emitted per BBL of;. ! liquids throughput: •scf/bbl Control Device - Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: 2449.4 Btu/scf Section 04-Emissions Factors&Methodologies Description s po Applicant pulled a gas sample from the VRT at 3 psig 100F an 7/19/19.Composition is reflected below. MW I 42.ojlb/lb-mol Displacement Equation EX=A*MW*Xx/C Weight% Helium ':0.0 CO2 1.2 N2 0.1 methane 7.8 - - ethane _ 13.0 - - propane 28.2 - - isobutane - 6 • n-butane 1.9.9 isopentane 0.8 - - - - n-pentane 7.3 cyclopentene 0.6 n-Hexane 0,6 cyclohexane C.6 Other hexanes 3.5 heptanes '2.9 -methylcyclohexane 0.6 - - 224-TMP 0.0. Benzene 0. Toluene AZ _- Ethylbenzene ti_.Xylenes 0.1. .-:CS*Heavies 1.₹ Total VOC Wt% 77 9 C:\Users\beades\Desktop5Reafirab Work\TJS Packages\PubCom Packages\419620 Extraction\19WE0931.19WE0932.19WE0933.19WE0934.19WE0935.CP1 Separator Venting Emissions Inventory Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (Ib/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC 88059.7153 4402.9858 Benzene ' 327.3558 16.3678 - ; ^w Toluene 276.0191 13.8010 Y Ethylbenzene 19.1099 0,9555 ""`s Xylene 60.2696 3.0135 n-Hexane 674.6129 33.7305 224 TMP 1.5831 0.0792 Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) Ib/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10- , �5 z ?. 18,2504 +. - - - PM2.5 'ao-,...vidolguigt -18.2504 SOx `.L,°...x0.0688g'of 1.4406 4H.a. NOx °°0 869 ph 156.5592 - ipr CO 3}.3130-,r,. _ 759.3140 oliatiwrit Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) Ib/MMscf - Emission Factor Source (Waste Heat . Combusted) - (Pilot Gas Throughput) - - PM10 ,---....---'404016,!,M-4 18.2504 *2 i PMZ.S ,41g,rd e;, Y 18.2504 s a.. 50x ..:s..mii0,0d06."(a: .1.4408 ¢ NOx ..tee.0.0850 166.5592 - ' CO - ti0.310O*M,`- 759.3140 Section 05-Emissions.Inventory Potential to Emit Actual Emissioes Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 ' 0.0 - 0.0 0.0 0.0 0.0 . 7 PM2.5 0.0 0.0 - 0.0 0.0 0.0. -7 SOx _ 0,0 0.0 0.0 0.0 0.0 1 NOx -0.4 0.2 0.2 0.4 '03 68 .. VOC 211.3 105.7 5.3 211.3 10.6 - 1795 CO 0,0 0.9 0.9 1.8 1.8 310 . . 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 1571 786 - 39 1571 79 Toluene 1325 662 33 1325 66 . Ethylbenzene 92 46 2 92 5 Xylene. 280 145 7 289 14 n-Hexane 3238 1619 81 - 3238 162 224TMP . 8 4 . 0 8 0 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Source requires a permit Regulation 7,Section XVII.B,G Source is subject to Regulation 7,Section XVII.B.2,0 Regulation 7,Section XVII.B.2.e The control device for this separator is not subject to Regulation 7,Section XVILO.2.e (See regulatory applicability worksheet for detailed analysis) C:\Uonrs\beades\DesktopXBesfiSW Work\TJs Packages\PubCom Packages\419620 Extraction\19WE0931.19WE0932.19WE0933.19WE0934.19WE0935.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'f . 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 oldersite-specific sample. • If no,the permitwitl 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 with5his application. - - Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year? ,' - 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 armual 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? , P� � If yes,the permit will contain compliance testing requirements to demonstrate the destulction efficiency of the combustion device based on • inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented.The following questions do not require an answer. y,. ,a s y' t r Section 08-Technical Analysis Notes A dedicated combustor is used for LP separator(Point 005)and VRT(Point 004) Section 09-Inventory SCC Coding and Emissions Factors AIRS Point 8 Process44 SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 004 01. 3.10-001-60 Flares . PM10 18.3 0 IbjMMSCF . - PM2.5 18.3 0 lb/MMSCF SOx 1.4 0 lb/MMSCF NOx 166.6 0 I6/MMSCF VOC 88059.7 95 Ib/MMSCF • CO . 759.3 0 lb/MMSCF Benzene- 327.4 - - 95 Ib/MMSCF Toluene 276.0 • 95 lb/MMSCF ' • Ethylbenzene 19.1 95 lb/MMSCF Xylene - 60.3 95 ib/MMSCF • • J n-Hexane 674,6 95 lb/MMSCF . 224 TMP 1.6 95 • Ib/MMSCF • • • • • • C:\U.3ers\beades\Desktop50eoflS .Work\TJs Packages\PuhC6m Packages\41 W 9620 Extraction Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. - Brad Hades as of 3/25/20 Colorado Regulation 3 Parts A and a-APES and Permit Requirements - Source is In the Non-Attainment Area ATTAINMENT �� 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section ll.D.1.a)? "'// 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section lI.D.3)? � LYou have indicated that source is in the Nan-Attainment Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than TPY(Regulation 3,Part A,Section ll.D.1.a)? W.-Tn.,n.,Source Re 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY,NOx greater than 5TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section lI.D.2)? R it a-Surce Re (Source requires a permit Colorado Regulation 7,Section XVII 1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2B141 kr�.<'a',',_lj5ource iss I5ouice is subject to Regulation 7,Section XV31.8.2,G Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G-Emissions Control Alternative Emissions Control(Optional Section( a. Is this separator controlled bye back-up or alternate combustion device(Le,not the primary control device)that is not enclosed? �g5 The contn ITheconirol devise for this separator is not subject to Regulation 7,Section XVIl.0.2.e Section XVII.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicebilityof certain requiinments 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 ofihe statute or regulation will control.The use of non-mandatory language such as recommend,'"may,""should,"and can,"is intended to describe APCO interpretations and recommendations.Mandatory'erminology such as must"end"required"are intended to describe controlling requirements under the terms ofthe Clean Air Act and Air Quality Control Commission regulations,but this document does root establish legally binding requirements in and of itself. • Separator Venting Emissions Inventory Section 01-Administrative Information Facility AIRS ID; County Brad E d s as of 3/25/20 Point Section 02-Equipment Description Details 9CPS£PASIPTpii:PINT DURIfi10 COMPIfSIlOS 'E Detailed Emissions Unit Description: - _ - __ _ - -, Emission Control Device Description: �₹ ;;s� 1 x��,� � g; ...: .......... .„„;.;. Requested Overall VOC&HAP Control Efficiency%: Limited Process Parameter )°' Gas meter9 Section 03-Processing Rate Information far Emissions Estimates Primary Emissions-Separator Actual Throughput MMscf per year Requested Permit Limit Throughput= *-i'&,,a: MMscf per year Requested Monthly Throughput= 1.6 MMscf per month Potential to Emit(PTE)Throughput= 19.2 MMscf per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 2022.9 Btu/scf Volume of waste gas emitted per BBL of r liquids throughput: ` scf/bbl Control Device Pilot Fuel Use Rate: <.scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf Section 04-Emissions Factors&Methodologies Description �'Cg ':t kx.s`�nr$�'»':i»"f.,.r'r.,ati.tss�. .:a�...�,�� .:. .r.r,,. »:.a..:,.r ::r>*„� »'a;•:�;:.::.:s„:..'�.' .... ter., Fyn .,r� r; 1" x.r. .. r z„.,„ a„, S�te� 1�x n t a ;s° ..: aglpt7;frat4Lfli.�c .b5,sr .:23.Fun;€(1:924: am�butait � - 'd-TMsf �, ✓ -� aj t f xs r`.:atS"�,7,4rs`, 1, _"".' r�'.ar� fc �.':'r -„x -' �1'` u......... 4.t .�5a=�.{'ak... MW r I; -.ts- ': .... ti-Ib/Ib-mot Displacement Equation Ex=CI*MW*Xx/C Weight% Helium CO2 " .: "a^=;":'.11 N2 methane ethane 20.4 propane " `278. isobutane 4 2. n-butane 12 2'. isopentane 2.7:. n-pentane cyclopentane 0,2. n-Hexane 14 cyclohexane Other hexanes heptanes methylcyclohexane 224-IMP Benzene TolueneOragla;g4t-'1)4 Ethylbenzene Xylenes x5;5 Cal-Heavies Total 100.0 UOCWt% 55.7 C:\Users\beades\DesktopXReafi0&Work\TJs Packages\PubCom Packages\419620 Extraction\19WE0931.19WE0932.19WE0933.19WE0934.19WE0935.CP1 Separator Venting Emissions Inventory Emission Factors Separator Venting Uncontrolled Controlled Pollutant (Ib/MMscf) (Ib/MMscf) Emission Factor Source (Gas Throughput) (Gas Throughput) VOC 48361.9570 2418.0979 ag..gin Benzene 113.3660 5.6683arOtrA ,,"4. Toluene 116.4909 5.8245 Z.,:.t.44kbe OK,licrk- aprotovioly„a, Ethylbenzene 15.0171 0.7509 - Xylene 50.6067 2.5303 _ n-Hexane 842.0852 42.1043 224 TMP 0.5208 0.0260 r .r. Primary Control Device Uncontrolled Uncontrolled Pollutant )Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.007 r - 13.5824 Nt PM2.5 0.0075 - 13.5824_ SOx 0.0006 1.0723 -41Table 2.4-2(50x} NOx 09680 123.9572 apter 13.5 Industrial Flares(NOxj CO. 0.3100 5659990 P4P,13 Chapter 13.51cdustrial Flares(CO) Pilot Light Emissions Uncontrolled -Uncontrolled Pollutant (Ib/MMBtu) Ib/MMscf Emission Factor Source (waste Heat Combusted) (Pilot Gas Throughput)PM10 0.0000 6r,,,,Viga p . PM2.5 0.0000 4 Zikwie"SOx 0.0000 ,1414- t:, NOx 0.0680 0.0000 s ..! e co 0.3100 = 0.0000 .g.s-. 4.-:0-:,,...! 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 22 PM2.5 0.1 0.1 0.1 0.1 0.1 22 SOx 0.0 0.0 0.0 0.0 0.0 2 NOx 1.2 0.6 0.6 1.2 1.2 202 VOC 464.3 232.1 11.6 464.3 23.2 3943 CO 0.0 2.7 2.7 5.4 5.4 921 Potential to Emit Actual Emissions Requested Permit Limits.Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (Ibs/year) (Ibs/year) (Ibs/year) Benzene 2177. 1088 54 2177 109 Toluene 2237 1118 56 2237 112 Ethylbenzene 288 144 7 288 14 Xylene 972 486 24 972 49 n-Hexane 16168 8084 404 16168 808 224TMP 10 5 0 10 0 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Source requires a permit Regulation 7,Section XVILB,G Source is subject to Regulation 7,Section XVil.B.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.e (See regulatory applicability worksheet for detailed analysis) C/,Users\beades\Desktopl8ee66&Work\TJs Packages\PubCom Packages\419620 Extraction\19WE0931.19WE0932.19WE0933.19WE0934.19WE0935.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 maybe appropriate to use an older site-specific sample. If no,the permit wil contain an"Initial Testing Requrement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year? r „. 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 estabished 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 estabished with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no,the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational(not to exceed 180 days).This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03. Does the company request a control device efficiency greater than 95%for a flare or combustion device? . If yes,the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented.The following questions do not require an answer. ea, gri i y�,4 j ffi i , ,91r .iez-,3-a ",� awe �d, m ", "." : F ,,, g. fr Section 08-Technical Analysis Notes s, ... 2'€'i u z r mm rsr. T ` Fr.. "" er', w a pt a rl s'`t ;s to £ I s Jss �s. ., ads' t�'tir s {s"a ra1"as $,,q [ y is gg Section 09-Inventory SCC Coding and Emissions Factors AIRS Point 9 Process 0 SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 005 01 3-10-001-60 Flares PM10 13.6 0 ib/MMSCF PM2.5 13,6 0 lb/MMSCF 5ox 1.1 0 lb/MMSCF NOx 124.0 0 lb/MMSCF VOC 48362.0 95 Ib/MMSCF CO 565.1 0 Ib/MMSCF Benzene 113.4 95 ib/MMSCF Toluene 116.5 95 lb/MMSCF Ethylbenzene 15.0 95 lb/MMSCF Xylene 50.6 95 lb/MMSCF n-Hexane 842.1 95 Ib/MMSCF 224 TMP 0.5 95 lb/MMSCF C:\Users\beades\DesktopyResfid9a Work\TJs Packages\PubCom Packages\419620 Extraction\19WE0931.19WE0932.19WE0933.19WE0934.19WE0935.CP1 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below ore determined based on requested emissions. Brad Eades as of 3/25/20 Colorado Regulation 3 Parts A and B-APEN and Permit Requirements • Source is lnthe Non-Attainment Area ATTAINMENT • - 1. Are uncontrolled actual emissions from any criteria pollutants from this individual sourcegreater than 2 TPY(Regulation 3,Part A,Section 11.0.1.0)7 / 2. Are total facility uncontrolled VOC emissions greaterthan 5TPY,NOx greater than 10TPY or Cremissions greater than to TPY-(Regulation 3,Part B,Section 11.03)7 //x 'You have indicated that source is inthe Noe-Attainment Area • NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 11 TPY(Reguletlon3,Part A,Section Il.D.1.a)? yes .'Source Re 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY,NOx greater than 5 TPA'or CO emissions greater than 10 117Y(Regulation 3,Part e,Section 11.0.2)7 Yes Source Re 'Source requires a permit Colorado Regulation 7,Section XVII 1. Was the well newly constructed,hydraulically fractured,or recompleted on orafterAugust 1,20147 • • 'Source Is subject to Regulation 7,Section HVll.a.2,G - • Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emaslons • • • - Section XVII.G-Emissions Control Alternative Emissions Control(Optional Section) a. Is this separat trolled by a hack-up or alternate combustion device(i.e:,not thwprimary control device)that is not enclosed? 47Yo..... ;'The canto, IThecontrol device for this separator is not Subject toRegulation 7,Section XVII.B.2.e Section XVII.B.2.e—Alternative emissions control equipment Disclaimer • This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is _note rule or regulation,and the analysis it contains may not applyte 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 Ccminission regulations,the language of the statute or regulation will control.The use of non-mandatory language such as"recommend,"may,"should,'and"can/is intended to describe APCD interpretations and recommendations.Mandatory terminology such as'must and"required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does rot establish legally binding requirements In and of itself. 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. 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 wilt 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.$ovlpacificicdphe/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: ( W E P 9 3) AIRS ID Number: i Z3 44 0$El d 0 Merlin Condensate Tank APEN RrC.4.f Condensate Storage Tank(s) APEN t /Intl) i7a rc [Leave black unless APCD has already assigned a permit t." and AIRS ID) Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Merlin Production Facility Site Location: SWNW Sec 29 T6N R67W Mailing Address: (Include Zip code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld 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 wilt 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-2O5 Condensate Storage Tankis) APEN Revision 7/2018 419612 ®V COLORADO AAA. Merlin Condensate Tank APEN Permit Number: AIRS ID Number: / [leave blank unless APCD has already „sciened a pelmit and AIRS ID] Section 2 - Requested Action Q NEW permit OR newly -reported emission source Q Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 0 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 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership's 0 Other (describe below) OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) ADDITIONAL PERMIT ACTIONS - 13 APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info k Notes: Please issue individual permit for Condensate Tanks. 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: Storage of Condensate at E&P Facility. For new or reconstructed sources, the projected start-up date is: 06/19/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: 0 Exploration & Production (E&P) site weeks/year 0 Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? r4 Yes ■ No Are Flash Emissions anticipated from these storage tanks? ❑✓ Yes • No is the actual annual average hydrocarbon liquid throughput a 500 bbl/day? t7 Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 0.00026 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 GI ■ Are you requesting a 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions a 6 ton/yr (per storage tank)? ❑ Yes No ■ Form APCD-2O5 Condensate Storage Tank(s) APEN - Revision 7/2018 CCZCYRw DO r� P Merlin Condensate Tank APEN Permit Number: AIRS ID Number: f 1 [Leava blank unless APCD has .ready assIgned a pera$i ,.r and AiR5 ID] Section 4-Storage Tank(s) information i al Amtunt Requ ed ai Per ( t� afar? . - (bbl/err 481,217 577,460 From what year is tte actual annual amount? Projected Average API gravity of sales oil: 48.2 degrees RVP of sakes oil: 13.5 Tank design: a Fixed roof ❑ Internal floating roof ❑ External floating roof 114-4104;',i4443.0.44.'4*, pate of Ff� Ta►4 l$ ossei i �� fLl, . S r ge " k(mon/ f..,, f n r/ ar;,'.: lY 4 N/A 4 x 400 bbls 1600 Before 6/2019 6/2019 See Attached O O O i� 5 Requested values will become permit limitations.Requested limits)should consider future growth. 6 The E&P Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all welts that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information l dinars 40.458723, -104.92514 art ` to k I c 0,440 ht ove amp. Ot kk x Flow Rate I ity N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet:(check one) 0 Upward ❑Downward 0 Upward with obstructing raincap 0 Horizontal 0 Other(describe): Indicate the stack opening and size: (check one) Circular Interior stack diameter(inches): Unknown Q Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): x catoraAoa Form APC -205- Condon=fate Storage Tank(s) APEN RPv'isican 712018 3 i f .., Merlin Condensate Tank APEN Permit Number: AIRS ID Number: / / [Lew,c,hank unless APC0 has a;easy a,,s!Qi1 d a;oern it r and AIRS iD,i 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 Size: Make/Model: O Recovery Unit (VRU): Requested Control Efficiency: VRU Downtime or Bypassed(emissions vented): Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: ECD Make/Model: Q Combustion Requested Control Efficiency: 95% Device: Manufacturer Guaranteed Control Efficiency: 98% Minimum Temperature; Waste Gas Heat Content: 2627.8 Btu/scf Constant Pilot Light: 0 Yes O No Pilot Burner Rating: MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: HLP separator,Vapor Recovery Tower C©�4T�Ai�J Form APCD-205 Cord,nsate Storage Tankis) APEN. - Revision 7:2018 4 �� Merlin Condensate Tank APEN Permit Number; AIRS ID Number: ! ! !Leave btanit awnless ARCii bias alt ,y assigned a permit `and IRS 4D) 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):gSNZMROAV;tflijiWi4 r { ion VOC ECA 95% NOx CO HAPs - Eca 95% Other: From what year is the foilcs'iing reported actual annual eniissioris data'- Projected an � a � A utt Ujoh-,''ot-ittia414dik$5:Mt'lInictiary 'AY AR ft 11**Willing***4:1In _ ..;. Wa ,.__ l etc)....F. s/y 3 tttOti/ 1. i / t.. /.y+) VOC 0.149 lb/bbl site spy sampmg 35.8 1.79 42.9 2.15 NOx CO ii .tnr Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.002380 Ib/bbl SP.ak Pqn 1,145.4 57.3 2,2,4- 540841 Trimethylpentane 5 Requested values wilt 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. a Annual emissions fees wilt be based on actual controlled emissions reported. If source has not yet started operating,leave blank. Colo AAO0 Form APE-2O5 Condensate Storage Tank(s)APEN• Revision 7/2018 5 I AtiaV Merlin Condensate Tank APEN Permit Number: AIRS iD Number: / / 'Leak hark unless APCD has a o a v assi ned a permit and AIRS 1D1 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 GPO1 or GP08, I further certify that this source is and will be operated in full corn liance with each condition of the applicable General Permit. q(PAII Signature of Legally Autho zed 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: QQ 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/ear term;or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.).See Regulation No. 3, Part A, II.C.for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable,to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148. Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.govrcdphe!avcd p COLORADO Form APCD•2O5 Condensate Storage Tanic(st APEN - Revision 7/'2018 6 l MY ,r N. E&P Storage Tank Air Pollutant Emissions Notice(APEN) Addendum Form' _Company Name: Extraction Oil&Gas,Inc. Source Name: Condensate Storage Tanks Emissions Source AIRS ID2: / / Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-47464 Merlin 29E-10-1C 05-123-47466 _ • Merlin 29E-10,2C 05- 123-47465 Merlin 29E-10-3C 05-123 47467 Merlin 29E-I0-4N EZI 05-123-47468 Merlin 29E-10-5N OS-123-47469 Merlin 29E-10-6N - - 0 _ a - - - 0 0 - r Footnotes: Attach this addendum to associated APEN form when needed to report additional wells. If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 Condensate Tank Addendum.docx 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. 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: 19W E0932 AIRS ID Number: 123 / AO8E / 002 [Leave blank unless APCD has already assigned a permit . and AIRS ID} Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Merlin Production Facility Site Location: SWNW Sec 29 T6N R67W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Jon Torizzo 303-396-6051 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-207 - Produced Water Storage Tank(s) APEN - Revision 12/2019 (COLORADO 1 Na&tRbBntironaio�l Permit Number: 1.9W E0932 AIRS ID Number: 123 / A08E /002 [Leave blank unless APCD has already assigned a permit # 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 0 GP05 0 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 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership4 0 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 €t Notes: Please issue individual permit for produced water tanks. 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: Storage of Produced Water at E&P Facility. Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 6/19/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: 0 Exploration €t Production (E&P) site ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? 12 Yes ■ No Are Flash Emissions anticipated from these storage tanks? Ed Yes ■ No Are these storage tanks located at a commercial facility that accepts oil productionIII wastewater for processing? Yes No &I Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ■ Yes 12 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 M Fl Are you requesting a 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions a 6 ton/yr (per storage tank)? Yes No • Fl Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 12/2019 21 SO COLORADO uw.emadtuwr Permit Number: 19WE0932 AIRS ID Number: 123 /A08E/002 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbllyear) Produced Water Throughput: 124,707 400,000 From what year is the actual annual amount? Projected Tank design: ❑✓ Fixed roof ❑ Internal floating roof 0 External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(month/year) (month/year) N/A 2 x 400 bbls 800 Before 6/2019 6/2019 Wells Serviced by this Storage Tank or Tank Battery('(E&P Sites Only) API Number Name of Well Newly Reported Well See Attached ❑ - - ❑ 0 O - ❑ 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 6 The E£tP 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 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.458723,-104.92514 O Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec) N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Downward O Upward with obstructing raincap ❑Horizontal O Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): Unknown ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): Asik COLORADO Form APCD-207- Produced Water Storage Tank(s) APEN - Revision 12/2019 3 II awN p"� Permit Number: 19WE0932 AIRS ID Number: 123 / A08E / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID) Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: ECD MMBtu/hr Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: Waste Gas Heat Content: 676.1 Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: O 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)? psig Describe the separation process between the well and the storage tanks: HLP separator Form APCD-2©7 - Produced Water Storage Tank(s) APEN - Revision 12/2019 4 I no COLORADO Permit Number: 19WE0932 AIRS ID Number: 123 /A08E/002 t.,ave urdE2SS APCD z as Already assigned a permit f and AIRS!Di Section 8 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form7. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes O No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Collection Efficiency Control Efficiency Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured by control equipment) emissions) VOC ECD 100% 95% NOx CO HAPs ECD 100% 95% Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: Emission Factor? Requested Annual Permit Actual Annual Emissions Emission i-i[nit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Basis Units (AP"42' Emissions Emissions$ Emissions Emissions Mfg etc etc•) (tons/year) (tons/year) (tons/year) (tons/year) VOC 0.008 Ib/bbl Site Specific Sampling 0.473 0.024 1.518 0.076 NOx Co 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APEN5,including APEN updates. 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. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria Yes ❑✓ No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant (HAP)emissions from source: Chemical Emission Factor' Actual Annual Emissions Abstract Source Uncontrolled Controlled Chemical Name Uncontrolled Service (CAS) Units (AP-42, Emissions Emissions8 Number Basis Mfg.,etc.) � (lbslyear) (lbs/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 2,2,4-Trimethylpentane 540841 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. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. (COLORADO Fcrr i AI CD-2v7- P coduced Water Storage Fanic(s)APEN - Revision 12/2019 5 11=7,1==, Permit Number: 19WE0932 AIRS ID Number: 123 / A08E /002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 10 - Applicant Certification I hereby certify that alt 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. 3/25/2020 Signature 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: ❑ 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 For more information or assistance call: 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 Small Business Assistance Program (303) 692-3175 OR (303) 692-3148 APCD Main Phone Number (303) 692-3150 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 12/2019 61 * beparrevadetPulatie COLORADO Nm1U.b EnvYenmort Merlin Liquid Loading APEN OCErSilD SEP 1 6 2419 Hydrocarbon Liquid Loading APEN Form APCD-208 d.►,+ca Air Pollutant Emission Notice (APEN) and Application for Construction Permit Alt sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. 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.govtcdphelapcd. 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: 9WEf/33 AIRS ID Number: I23 //IVY/ 603 [Leave blank unless APCD has a ready assigned a permit and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Merlin Production Facility Site Location: SWNW Sec 29 T6N R67W Mailing Address: (include zip code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAKCS or SIC Code: 211111 Contact Person: Jon Torizzo Phone Number: 303-396-6051 E -Mail Address?: 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 e-mail to the address provided. 419614 COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 7/2018 Merlin Liquid Loading APEN Permit Number: AIRS ID Number: ave blank unless APCD has already assigned a permit a and AIRS ID} Section 2 - Requested Action O NEW permit OR newly -reported emission source 0 Request coverage under construction 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' ❑ 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 a Notes: Please issue individual permit for liquid loadout. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer o€ ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Loading of condensate liquid onto tanker trucks for transport. Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 6/19/2019 Witt this equipment be operated in any NAAQS nonattainment area? Yes No GI ■ Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes 0 No • Does this source load gasoline into transport vehicles? Yes No ■ 0 Is this source located at an oil and gas exploration and production site? Yes No GI ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annualGI average? Yes No ■ Does this source splash fill less than 6750 bbl of condensate per year? 0 Yes O No Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ GI COLOIIAOO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 7/2018 Merlin Liquid Loading APEN Permit Number: MRS ID Number: 1 / (Leave blank unless APCD has already assigned a permit and AIRS ID] Section 4 - Process Equipment Information Product Loaded: 0 Condensate 0 Crude Oil 0 Other: if this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 28,381 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") 23,651 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: N/A Average temperature of bulk liquid loading: N/A F True Vapor Pressure: N/A Psia @ 60 ' F Molecular weight of displaced vapors: NIA Lb/lb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: N/A bbl/year Actual Volume Loaded: N/A bbl/year Product Density: N/A lb/ft3 Load Line Volume: N/A ft3/truckload Vapor Recovery Line Volume: N/A ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. From APCD-208 Hydrocarbon Liquid Loading APEN Revision 7 / 2018 REW COLOR DO mn�» � NrY* Merlin Liquid Loading APEN Permit Number: AIRS ID Number: f LL ve btan1,Lmi sa APCD has&:r acv assigned a pe ig anti AIRS iii Section 5 - Stack Information 40.458723,-104.92514 N/A Unknown Unknown Unknown Unknown indicate the direction of the stack outlet: (check one) 0 Upward ❑Downward 0 Upward with obstructing raincap 0 Horizontal O Other(describe): Indicate the stack opening and size: check one) Circular Interior stack diameter(inches): ❑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. O Loading occurs using a vapor balance system: Requested Control Efficiency: Used for control of: VOC,HAPs Rating: MMBtu f hr Type: ECD Make/Model: rn Combustion Device: Requested Control Efficiency: 95% Manufacturer Guaranteed Control Efficiency: 95% Minimum Temperature: F Waste Gas Heat Content: 2628.5 Btufscf Constant Pilot Light: ® Yes 0 No Pilot Burner Rating: MMBtufhr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: A COLORADO Form APCD-208 Hydrocarbon liquid Loading APEN Revxs:on 712011/8 4x . 'n- Merlin Liquid Loading APEN Permit Number: AIRS ID Number: I / [Leave Mani unless APCD has alreadyassigned a permit a 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): �e eques •: trip on of+ ng l t� } en PM SOX NO. CO VOC ECD 95% HAPs I ECD 95% Other: 0 Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane 0 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 • Ct itei ia.l oll ;Emissio ' Req�ted tnnual P n =i.' i11iS5iot! ctt# cll81 J�nnuaiti7f 5 • ii fln � 12{S P liutant �tratroitec# Source Uncontrolled C h i Uncontrt fed Cep 1� Units € 2,, nissians: Emissions6"z Emi x Emtssi� 1 S•, .) (tcr�sryear) tr+ slyertf),; (t 3 +),,.. trtons/ r)` PM SO. NO,, Co VOC 0.236 Ibibbi PS Memo 14-02, 2.791 0.140 3.349 0.167 i riteria Reportable Pollutant C11Ye Chemical Ep Factor f Actual Annual En e3 Chemical Nam tract Uncon lled r e U cord st Cont o Service{ Unnits :u (� , Ems Emii � iicai r_ B _ ,etc), (P s ). (potwsjsJye r) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limits)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. IEW COLORADO Form APCD-208 Hydrocarbon Llquid Loading APEN Revision 7/2018 5 i Merlin Liquid Loading APEN 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 full compliance with each condition of General Permit GP07. Signature d Legally Authorize Person (not a vendor or consultant) Jon Torizzo 601Date �15 Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: BDraft 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/aped Form APCD-2O8 Hydrocarbon Liquid Loading APEN Revision 7/2018 AVCOLORADO twx�at Merlin VRT Gas Venting APEN Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit AU sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.cotorado.govicdphedapcd. 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, I1.C. for revised APEN requirements. Permit Number: 9ivEoc 3`f [Leave blank unless APCD has already assigi AIRS ID Number: 12-3 gE / co.f. a perrmt 4 and MRS ID; Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Merlin Production Facility Site Location: SWNW Sec 29 T6N R67W Mailing Address: (include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Jon TOrizz0 Phone Number: 303-396-6051 E -Mail Address: air@extractionog.com ' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 419615 Farts APCD-211 Gas Venting APEN - Revision 7/2018 FClasry So liCe ti Merlin VRT Gas Venting APEN Permit Number: AIRS ID Number: / [Leave blank unless APCD has already ascicnpermit r and AIRS ID} Section 2 - Requested Action O NEW permit OR newly -reported emission source -OR- Q MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name3 ❑ Changepermit limit O Transfer of ownership4 OR Q 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) Add point to existing permit O Other (describe below) Additional Info & Notes: Please issue individual permit for VRT gas venting. 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 of VRT Gas when compression is unavailable. Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 6/19/2019 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment bated 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 7/2018 days/week weeks/year 0 Yes O Yes O Yes Q No No Q No AYCOL onADO Merlin VRT Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit a and AIRS ID] Section 4 - Process Equipment Information Gas/Liquid Separator ❑ Well Head Casing o Pneumatic Pump Make: Model: Serial #: Capacity: gal/min o Compressor Rod Packing Make: Model: # of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events # of Events/year: Volume per event: MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? 0 Yes Gas Venting Process Parameters$: Liquid Throughput Process Parameterss: Vented Gas Properties: O No Vent Gas Heating Value: 2449.4 BTU/SCF Requested: 4.800 MMSCF/year Actual: 2.400 MMSCF/year -OR- Requested: N/A bbl/year Actual: N/A bbt/year Molecular Weight: 42.8559 VOC (Weight %) 77.877 Benzene (Weight %) 0.2895 Toluene (Weight %) 0.2441 Ethylbenzene (Weight %) 0.0169 Xytene (Weight Si 0.0533 n -Hexane (Weight %) 0.5966 2,2,4-Trimethylpentane (Weight %) 0.0014 Additional Required Information: 0 Attach a representative gas analysis (including BTEX &n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX & n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Farm APCD 211 Gas Venting APEN - Revision 7:2018 3 I AYCOLORADO =-m4:t., Merlin VRT Gas Venting APEN Permit Number: AIRS ID Number: I t [Least 1)1w-tic ue.fess t'P D i s atrt-ac'ty assIgnod a perm t r;and Aq6 dJ. Section 5 Stack Information SeagraPhical-Coordin4e5 40.458723,-104.92514 4 ,g • ssaa•'a b; 're rF x �$ �^a '', ^`�' c i Y 3f �r a'i g,. 9 N/A Unknown Unknown Unknown Unknown indicate the direction of the stack outlet: (check one) 0 Upward O Downward O Upward with obstructing raincap Horizontal Ei Other(describe): Indicate the stack opening and size:(check one) Q Circular Interior stack diameter(inches): Unknown Other(describe): Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Size: Make/Model: O VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: ECD Make/Model: rn Combustion Requested Control Efficiency: 95°!0 Li Device: Manufacturer Guaranteed Control Efficiency: 98% Minimum Temperature: Waste Gas Heat Content: 2449.4 Btu/scf Constant.Pilot Light: L✓ Yes O No Pilot burner Rating: MMBtu/hr Pollutants Controlled: ® Other: Description: Requested Control Efficiency: avr Eom APED-211 Gas Venting APEN ` Revision 7/2018 4 Merlin VRT Gas Venting APEN Permit Number: AIRS ID Number: / 1 [Leave Nark unto5s APCD has already assigned 1 permit»and n S 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): Overall Ret led PM SO. NO. CO VOC ECO 95% HAPs EC0 95% Other: From what year is the following repotted actual annual emissions data( Projected ,-zk.t.,„ittcnitpt'l,,Fe. ,,I,';-r -,:#0.-:;iti:ti, c,.,:' v C�a Polls an mis io ill ry W - " f F.i - !# r • ',, fir-z'h rte �a-:.t�i�* �p Slur' O��led 0 � � ��ed ttrolleed PM SOx NO,, CO 0.310 lb/MMBtu AP-42Chapter 13,5 0,911 0.911 1.82 1.82 VOC 88,059.9 ' Ib/MMscf siwsntsns 105.7 5.28 211.3 10.6 � ; � t tnt Emissi as Inventory mi a x I �i Fact1ot t l E t �� it � � 1i ' w dumber �,Eeb r1> r)' 39.3 Benzene 71432 327.4 Ib/MMscf Site sP ..sna Toluene 108883 276.0 lb/MMscf simsw.n=sung 662.4 t 33.1 • Ethylbenzene 100414 Xylene 1330207 60.2 lb/MMscf Site SPeaw SamPling 144.5 7.23 n-Hexane 110543 674.6 Ib/MMscf sit.s„ .� 1,618.9 80.9 2,2,4- Trimethylpentane ' 540841 Other: 5 Requested values will become permit limitations.Requested timit(s)should consider future process growth. Annual emissions fees will be based on actual controlled emissions reported. lfi source has not yet started operating,leave blank. Aver col.oriAr)o Form APCD-211 Gas Venting APEN- Revision 7/2018 5 I k:,° `t ,. Merlin VRT Gas Venting APEN 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 alt information contained herein and information submitted with this application is complete, true, and correct. Signature of I y Authorized Person (not a vendor or consultant) Date Jon Torino Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: Q Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-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.Qov/cdphe/apcd Form APCD-Z11 Gas Venting APEN Revision 7/2018 6] AV COLORADO 1440 G.,nr.r.w' Merlin LP Gas Venting APREC`E,ivED SEP 1 6 2019 APCi) Gas Venting APEN - Form APCD-2111= Air Pollutant Emission Notice (APEN) and Application for Construction Permit AU sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. 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.govtcdphetapcd. 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: 6 AIRS ID Number: 1 Z 3 /,4 &E/ oG S ve blank unless APCD has already assigned a permit k and AIRS IDJ Section 1 - Administrative Information Company Name: Extraction Oil & Gas, Inc. Site Name: Merlin Production Facility Site Location: SWNW Sec 29 T6N R67W Mailing Address: 370 17th St. Suite 5300 (Include lip Code) Denver, CO 80202 Site Location Weld County: NAICS or SIC Code: 211111 Contact Person: Jon Torizzo Phone Number: 303-396-6051 E Mail Address2: 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. My changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices wilt be issued by the APCD via e-mail to the address provided. v 419616 COLORADO Fnrm APED -211 Gas Venting APEN - Revision 712018 1 i ')=7.7.= Merlin LP Gas Venting APEN Permit Number: MRS ID Number: Ie s APCD has already assigned a permit 2i and AIRS ID; Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source - OR - O 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 O Transfer of ownership4 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional info & Notes: Please issue individual permit for LP gas venting. 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 of LP Gas when compression is unavailable. Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 6/19/2019 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? is this equipment subject to Colorado Regulation No. 7, Section XVILG? days/week weeks/year O Yes O Yes Q Yes Form APCD 211 Gas Venting APEN - Revision 712018 2 I ❑ No Q No ❑ No AyCOLOR ADO Merlin LP Gas Venting APEN Permit Number: AIRS ID Number: (Leave blank unless APCD has already assigned a per a' and MRS !D] Section 4 - Process Equipment Information Gas/Liquid Separator Well Head Casing Pneumatic Pump Make: Model: Compressor Rod Packing Make: Model: Blowdown Events # of Events/year: Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? El Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: 1822.9 BTU/SCF Requested: 19.200 MMSCF/year Actual: 9.600 MMSCF/year -OR- Requested: N/A bbl/year Actual: N/A bbl/year Molecular Weight: 32.8987 VOC (Weight %) 55.714 Benzene (Weight %) 0.1306 Toluene (Weight %) 0.1342 Ethylbenzene (Weight %) 0.0173 Xytene (Weight %) 0.0583 n -Hexane (Weight %) 0.9701 2,2,4-Trimethylpentane (Weight %) 0.0006 Additional Required Information: Attach a representative gas analysis (including BTEX 8 n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX i3 n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. m APCD-211 Gas Venting APEN - Revision 7/2018 �� COLORADO Merlin LP Gas Venting APEN Permit Number: AIRS ID Number: / :tr-iave blank a ik s5 APCD has already,assigned a permit: and AIRS ID) Section 5 - Stack Information 40.458723,-104.92514 N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one{ 0 Upward ❑Downward ©Upward with obstructing raincap Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): Unknown []Other(describe): Section 6- Control Device Information El 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: MMBtu/hr Type: EC() Make/Model: rn Combustion Requested Control Efficiency: 95% Device: Manufacturer Guaranteed Control Efficiency: 98% Minimum Temperature: Waste Gas Heat Content: 1822.9 Btu/scf Constant Pilot Light: ID Yes ❑ No Pilot burner Rating: MMBtu/hr Pollutants Controlled: 0 Other: Description: Requested Control Efficiency: % csstcsaa�A Form APCD-211 Gas Venting APEN- Revision 7/2(118 4 f� : 1 I Merlin LP Gas Venting APEN A AIRS ID Number: Permit Number:1 [ I / Leaave Monk a iess AP has&r ead assig ed a per c i' . and i ;;fit i 1 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): 1ue� F ug t i scrims o +n l� � # � PM sox NOx CO VOC ECD 95% 10 HAPs ECD 95 Other: Tram what year is the following reported cctual annual emissions data? Projected €. a=e, s fir n P W ual �� -v Z*! : P�t�� ti o` w S x , �' l � F �� I PM SOx NOx 0.068 IbfMMBtu AP•42 Chapter t3.s 0.595 0.595 9.19 1.19 CO 0.310 Ib/MMBtu AP-s2cno%918r,3.5 2.71 2.71 5.43 5.43 VOC 48,361.818 Ib/MMscf ashes r.s t 232.1 _ 11.6 464.3 23.2 t Crit Ri~ tle Polltutaa sr l ��tor# , y dt 3 { .i b 1 l P FY' scat r , Emiss�F� � ��,i�� - �� r � e. x, 17e 6 Benzene 71432 153.3 IbfMMscf src�sae samq�a 1,08$.0 544 Toluene 108883 116.5 Ib(MMscf sus r�s�wag 1,118.6 55.9 Ethylbenzene 100414 15.0 Ib/MMsc# a s� 144.2 7.21 Xylene- S 330207 50.6 1b/MMsc# s e 4$5.8 24.3 n-Hexane 110543 842.1 Ib/MMscf s _� 84,085.8. ,084.3 404.2 2,2,4- 540841 Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(sI 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. Avg cocostnOO • Form APCD-211 Gas Venting APEN . Revision 7/ 01 5 I >. ., Merlin LP Gas Venting APEN Permit Number: AIRS ID Number: [Leave btank unless APCD has already assrgned a permit 4 au<i 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. Signatur •f ally `horize erson (not a vendor or consultant) Jon Torizzo Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: EDraft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.cotorado.gov/cdphe/apcd Form APCD-211 Gas Venting APEN - Revision 7(2018 61 AY COLORADO COLORADO Air Pollution Control Division Department of Pubic Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0931 Issuance: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Extraction oil Ft Gas, Inc. Merlin Production Facility 123/A08E SWNW SEC 29 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Equipment Description Point Description Emissions Control Condensate Tanks 001 Four (4) 400 barrel fixed roof storage vessels used to store condensate Enclosed Flare This permit: is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. 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 9 a 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.) 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 NOX VOC CO Condensate Tanks 001 - --- 2.2 --- 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 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 9 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 Condensate Tanks 001 Enclosed Flare 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 Condensate Tanks 001 Condensate throughput 577,460 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. 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 9 COLORADO Air Pollution Control Division Department of Public Health & Environment 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 b.y 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 b 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 £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. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Page 4 of 9 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone onattainment 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. 20. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 21. 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. Page 5 of 9 COLORADO Air Pollution Control Division Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 22. 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. 23. This permit is issued in reliance upon the accuracy and completeness ofinformation 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_ 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessaryto assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. 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.inito. 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 ermit are °Contested by the owner or operator, or the Division revokes a permit, the owner or aerator of a source may request a hearing before the AQCC for review of the Division's action. 26. 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. 27. 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: Timothy Sharp Permit Engineer Page 6 of 9 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil and Gas, Inc. Page 7 of 9 4%0 COLORADO Aix Pollution Control Division Department of Public Health b 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 (I.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) Thezfollowing 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 116 6 Toluene 108883 88 4 Ethylbenzene 100414 8 0 Xylenes 1330207 28 1 n -Hexane 110543 1145 57 2,2,4- Trimethylpentane 540841 7 0 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/bbl Source VOC 1.49E-01 7.40E-03 Source 110543 n -Hexane 2.38E-03 Source Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Page 8 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx MACT HH Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http: -//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 9 of 9 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: 19WE0932 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: ,Description: Issuance: 1 Extraction oil a Gas, Inc. Merlin Production Facility 123/A08E SWNW SEC 29 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control. Description Produced Water Tanks 002 Two (2) 400 . barrel fixed roof storage vessels used to store produced water Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. 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 9 a 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.) 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 permits .This construction permit alone does not providefinal 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 O. VOC CO Produced Water Tanks 002 --- -- 0.1 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. 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 9 a 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 TILE.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Produced Water Tanks 002 Enclosed Flare VOC and HAPs 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 400,000 barrels Produced Water Tanks 002 Produced Water throughput The owner or operator must monitor monthly process rates based on the calendar month. Compliance Vsiith 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 eachk'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 9 a COLORADO Air PoUution Control Division Department of Public Health & Environment 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 inspectionsfor 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 £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. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Page 4 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone nattainment 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; • 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. 20. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 21. 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. Page 5 of 9 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. 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. 23. 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. 24. 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. 25. 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. 26. 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. 27. 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: Timothy Sharp Permit Engineer Page 6 of 9 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil and Gas, Inc. Page 7 of 9 aFa•A�. g COLORADO Air Pollution Control Division Department of Public Health ft 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) 002 Benzene 71432 62 3 Toluene 108883 35 2 Ethylbenzene 100414 2 0 Xylenes 1330207 6 0 n -Hexane 110543 20 1 2,2,4- Trimethylpentane 540841 0 0 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: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 7.59E-03 3.80E-04 Source 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 Page 8 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx MACT HH Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.Rov/ 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 9 COLORADO Air Pollution Control Division Department al Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0933 Issuance: 1 Date issued: Issued to: Extraction oil a Gas, Inc. Facility Name: Merlin Production Facility Plant AIRS ID: 123/A08E Physical Location: SWNW SEC 29 T6N R67W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description Liquid Loading 003 Truck loadout of condensate by submerged fill Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. 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 9 a 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. 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. EMISSIO N 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 Liquid Loading� Loadi ng 003 - --- ; � 0.2 --- 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. 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 Page 2 of 9 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 an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 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 Liquid Loading 003 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This Sourcemust 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 Limits Equipment ID AIRS Point': Process Parameter Annual Limit Liquid Loading. 003 Condensate Loaded 28,381 barrels e 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 month and 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) Page 3 of 9 g COLORADO Air Pollution Control Division Department of Polak Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill. (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 closed and 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 pressurerelief 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. e. 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 9 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 a 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 your OftM 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. ................ .............. esting 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, I I . C. ) Annually by April 30th whenever a significant increase For any criteria pollutant: n emissions occurs as follows: 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 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. 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. Page 5 of 9 a,„ 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 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. 20. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 21. 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. 22. 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. 23. 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. 24. 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. 25. 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 Page 6 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 26. 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. 27. 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), X122 (civil penalties), --122.1 (criminal penalties), C.R.S. Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil &t Gas, Inc. Page 7 of 9 f� 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 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 theFDivision 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 003 Benzene 71432 62 3 Toluene 108883 35 2 Ethylbenzene 100414 2 0 Xylenes 1330207 6 0 n -Hexane 110543 20 1 224 TMP 540841 0 0 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. Page 8 of 9 COLORADO Air Pollution Control Division Department of Public Health 6 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: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 2.36E-01 1.18E-02 CDPHE The uncontrolled VOC emission factor is assigned based on PS -MEMO 14-02 as the State -default. 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 PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx 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.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 9 of 9 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: 19WE0934 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: Extraction oil &t Gas, Inc. Merlin Production Facility 123/A08E SWNW SEC 29 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Equipment ID ' AIRS Point Equipment Description Emissions Control Description VRT Venting 004 ". Vapor Recovery Tower Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C. R.S. 25-7-101 et seq), to this specific general terms and conditions, included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. 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 Pub ac Health b 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 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 completionof 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: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO,t VOC CO VRT Venting 004 --- 10.6 1.9 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 Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit 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 an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 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.) Equipment ID AIRS Point Control Device Pollutants Controlled VRT Venting 004 Emissions from the Separator are routed to an Enclosed Flare during Vapor Recovery Unit (VRU) downtime 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, I .A.4.) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit VRT Venting 004 Natural Gas Venting 4.8 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. 10. 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 flow meter must be calibrated and maintained per the manufacturer's specifications and schedule. 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. 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) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) Page 3 of 10 a COLORADO Air Pollution Control Division Department of Publac Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 drocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping formatapproved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 0£tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. 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 ADDITIONAL REQUIREMENTS 18. 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 orNO. per year, a change in nnual 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. lenever 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. 19. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). Page 5 of 10 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 als conforming in all respects with the conditions of the permit. Once .d 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 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. Page 6 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 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: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance .1 This Issuance Issued to Extraction Oil &t Gas, Inc. Page 7 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 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 1D AIRS Point Pollutant 71432 Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) VRT Venting 004 Benzene 786 39 Toluene 108883 662 33 Ethylbenzene 100414 46 2 Xylenes 1330207 145 7 n -Hexane 110543 1619 81 2,2,4- Trimethylpentane 540841 4 0 Note: All non-critera 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. Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Health fr 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/MM scf) Controlled Emission Factors (lb/MM scf) • Source CO 166.5592 AP -42 VOC 88059.7153 4402.9858 Source (Promax) 71432 Benzene 327.3558 16.3678 Source (Promax) 108883 Toluene 276.0191 13.801O Source (Promax) 110543 n -Hexane 674.6129 33.7306 Source (Promax) Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The emission factors listed above are based on modeled separator temperature of 100 °F and separator pressure of 03 psig. 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)-692-315O. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx 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 A/ACT 63.1-63.599 Subpart A - Subpart Z Page 9 of 10 It 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 10 of 10 a 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: 19WE0935 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Equipment or activity subject to this permit: Issuance: 1 Extraction oil Et Gas, Inc. Merlin Production Facility 123/A08E SWNW SEC 29 T6N R67W Weld County Well Production Facility Equipment ID ' AIRS Point Equipment Description Emissions Control Description LP Gas Venting 005 Low Pressure Separator Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C. R. S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. 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 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 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 construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSIO N 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: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 N NO. V0C CO LP Gas Venting 005 --- 1.2 23.2 5.5 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. Page 2 of 10 4,, 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 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. 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.) Equipment ID AIRS Point Control Device Pollutants Controlled LP Gas Venting 005 Emissions from the Separator are routed to an Enclosed Flare during Vapor Recovery Unit (VRU) downtime 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 Equipment ID AIRS Point Process Parameter Annual Limit LP Gas Venting 005 Natural Gas Venting 19.2 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. 10. 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 flow meter must be calibrated and maintained per the manufacturer's specifications and schedule. 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. 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) Page 3 of 10 a 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 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 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 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 Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (08M) 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 ()am 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 16. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) Periodic Testing Requirements Page 4 of 10 a 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 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. 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,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). 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 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. Itis 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 wilt terminate. Page 6 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 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: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance `I This Issuance Issued to Extraction Oil Et Gas, Inc. Page 7 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 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 noticeto 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 listedtoinform 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) LP Gas Venting 005 Benzene 71432 1088 54 Toluene 108883 1118 56 Ethylbenzene 100414 144 7 Xylenes 1330207 486 24 n -Hexane 110543 8084 404 2,2,4- Trimethylpentane 540841 5 0 Note: All non-criter'a 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. 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 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors (lb/MM scf) Controlled Emission Factors (lb/MM scf) Source NOx 123.9572 AP -42 CO 565.0990 AP -42 VOC 48361.818 2418.0979 Source (Promax) 71432 Benzene 113.3660 5.6683 Source (Promax) 108883 Toluene 116.4909 5.8245 Source (Promax) 100414 Ethylbenzene 15.0171 0.7509 Source (Promax) 1330207 Xylene 50.6067 2.5303 Source (Promax) 110543. n -Hexane 842.0852 42.1043 Source (Promax) 540841 2'2'4 Trimethylpentane 0.5208 0.0260 Source (Promax) Note: The controlled emissions factors for this point are basedon a control efficiency of 95%. The emission factors listed above are based on modeled separator temperature of 121 °F and separator pressure of 121 psig. 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 PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx 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 Page 9 of 10 COLORADO Air Pollution Control Division Department of Pubic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 10 of 10 Hello