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Home My WebLink About20200323.tiffCOLORADO Department of Public Health Et Environment Weld County - Clerk to the Board 1150.0 St PO Box 758 Greeley, CO 80632 January 14, 2020 Dear Sir or Madam: On January 15, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - Ice Man 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 Potis, Governor I Jill Hunsaker Ryan, MPH, Executive Director PUbli C Rev;etJ CC',PLCrP) 4-0-0-10,QW(sn/AR/CH/C►5) Ot/2c1/2O 06(4M) OI/14/2a 2020-0323 o Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, Inc. - Ice Man Production Facility - Weld County Notice Period Begins: January 15, 2020 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Extraction Oil a Gas, Inc. Facility: Ice Man Production Facility Exploration Et Production Well Pad SWSE Section 36 T7N R67W Weld County The proposed project or activity is as follows: This group of permits is to cover an oil Et gas well pad production facility that began operation 5/16/2019. The facility processes the materials from 7 on -site wellheads. At the facility, there are condensate tanks, produced water tanks, loadout activities for condensate liquids, LP separator venting, VRT venting and 2 natural gas reciprocating internal combustion engines (both covered by GP02). The facility is synthetic minor for VOC, NOx, CO, and n -hexane. These permits have been drafted to reflect the requirements and analyses reflecting the serious nonattainment designation. 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 19WE0819 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.Rov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Lauraleigh Lakocy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public Health Er Environment eb,t, Maw/M COLORADO Air Pollution Control Division Department of PubEtc Health & Envtronment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0819 Issuance: 1 Date issued: Issued to: Extraction Oil Et Gas, Inc. Facility Name: Ice Man Production Facility Plant AIRS ID: 123/A07D Physical Location: SWSE SEC 36 T7N R67W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK 001-008 001 Eight (8) 400 barrel fixed roof storage vessels used to store condensate Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self -certification form and guidance on how to self -certify Page 1 of 9 COLORADO Aix Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I. F.4. ) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) E. ) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO,, `' V0C CO TK 001-008 001 - --- 4.4 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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. 8. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as 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 indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) Total emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of VOC. 9. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TK 001-008 001 Enclosed Combustion Device VOC and HAP PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK 001-008 001 Condensate throughput 979,798 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 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 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 13. 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 means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 14. 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.17. 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. 15. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 16. 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 17. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (0&M) plan and recordkeeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 0&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) 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 COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. The owner or operator must complete site -specific sampling including a compositional analysis of the pre -flash pressurized condensate routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. Testing must be in accordance with the guidance contained in PS Memo 05-01. Results of testing must be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants using Division approved methods. Results of site -specific sampling and analysis must be submitted to the Division as part of the self -certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 19. 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.17) Periodic Testing Requirements 20. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 21. 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 NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or Page 5 of 9 COLORADO Air Pollution Control Division Department of Public Wealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 22. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 23. 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. 24. 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 finaliauthorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 25. 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. 26. 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. 27. 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. 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 28. 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. 29. 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: Darmit Wictnras Lauraleigh Lakocy Permit Engineer Issuance ; Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Page 7 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 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 permitas 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 (b/yr) Controlled Emissions (lb/yr) Benzene 71432 472 24 001 Toluene 108883 359 18 n -Hexane 110543 2,939 147 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 V0C 0.179 8.95E-03 ProMax simulation based on a site -specific Pre liquid med sample taken upstream of the VRT 71432 Benzene 4.82E-04 2.41 E-05 108883 Toluene 3.66E-04 1.83E-05 110543 n -Hexane 0.003 1.50E-04 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, and n -Hexane, PSD True Minor Source of: CO NANSR Synthetic Minor Source of: VOC, NOx 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 6+ -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 MACT 63.1200-63.1439 63.1440-63.6175 Subpart EEE - Subpart PPP 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 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0820 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Extraction Oil Et Gas, Inc. Ice Man Production Facility 123/A07D SWSE SEC 35 T7N R67W Weld County Well Production Facility Equipment or activity subject, to this permit: Facility Equipment ID AIRS Point' Equipment Description Emissions Control Description PW-001, PW-002 002 Two (2) 400 barrel fixed roof storage vessels used to store produced water Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self -certification form and guidance on how to self -certify Page 1 of 8 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I. F.4. ) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III. E. ) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current constructionpermit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO,t VOC CO PW-001, Pw- 002 002 -- --- 0.4 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month, a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) Total emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of VOC. 9. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled PW-001, PW-002 002 Enclosed Combustion Device VOC and HAP PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum,, processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit PW-001, PW-002 002 Produced Water throughput 282,400 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 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 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The storage tank covered by this permit is subject to the emission control. requirements in Regulation Number 7, Section XVII.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and recordkeeping 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.17) Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 8 N@y3M Ntte. COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 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 - Page 5 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 ob 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: Lauraleigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Page 6 of 8 co..,ttof COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI. B. ) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/ pacific/ cdphe/ aqcc- regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Benzene 71432 1,158 58 002 Toluene 108883 819 41 n -Hexane 110543 988 49 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 0.062 3.10E-03 Flash Liberation Analysis taken 10/7/2019 and Tanks 4.0.9d Simulation 71432 Benzene 4.1E-03 2.05E-04 108883 Toluene 2.9E-03 1.45E-04 110543 n -Hexane 3.5E-03 1.75E-04 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please Page 7 of 8 .1HPR°NM COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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, and n -hexane PSD True Minor Source of: CO NANSR. Synthetic Minor Source of: VOC, NOx 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed ''below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1' -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 COLORADO Air 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: 19WE0821 Issuance: Date issued: Issued to: Extraction Oil a Gas, Inc. Facility Name: Ice Man Production Facility Plant AIRS ID: 123/A07D Physical Location: SWSE SEC 36 T7N R67W County: Weld County General Description. Well Production Facili Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description LOAD -001 003 Truck loadout of condensate by submerged fill Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self -certification form and guidance on how to self -certify Page 1 of 9 C COLORADO Air Pollution Control Division Department of Public Health 8 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 retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Reference: Regulation Number 3 Part B, Section II.A.4) Annual Limits: Equipment ID AIRS Point Tons per Year PM2.5 NO. VOC Emission Type LOAD -001' 003 0.7 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. acility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year: Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month, a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations 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 must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of VOC. 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 LOAD -001 003 Enclosed Combustion Device 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 rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference.- Regulation Number 3, Part CJ, 11 . H. Process/Consumption Limits Equipment ID AIRS Point Process Parameter Annual Limit LOAD -001 003 Condensate Loaded 97,950 barrels The owner or operator must calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month, a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each 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. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Page 3 of 9 ato COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill. (Reference: 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 (Reference: 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 pressure relief devices (PRD) annually for proper operation and replace as necessary. PROs, must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 15. For this controlled loading operation, the owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING £t MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (0&tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions Page 4 of 9 COLORADO Air Pollution Control Division Department of Public Health & £nwonment Dedicated to protecting and improving the health and environment of the people of Colorado to your O8M plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) Annually by April 30t" whenever a significant increase For any, criteria pollutant: in 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 (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO), per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • 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. 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 Page 5 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 program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 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 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 Page 6 of 9 COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Lauraleigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Page 7 of 9 COLORADO Air Pollution Control Division Department of Public Health 8 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-reps 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 (b/yr) Controlled Emissions (lb/yr) 003 n -Hexane 110543 395 20 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: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.266 1.33E-02 AP -42, Chapter 5.2 n -Hexane 110543 4.0E-03 2.0E-04 The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 7.17 psia M (vapor molecular weight) = 62 lb/lb-mol T (temperature of liquid loaded) = 524 °R 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 The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP per VOC in the vapors as calculated by the ProMax simulation based on a site -specific pressurized liquid sample taken 7/11/19 by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of 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 Operating Permit Synthetic Minor Source of: VOC, CO, NOx, and n -hexane PSD True Minor Source of: CO NANSR Synthetic Minor Source of: VOC, N0x 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 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 of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0822 Issuance: 1 Date issued: Issued to: Extraction Oil Et Gas, Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: Ice Man Production Facility 123/A07D SWSE Section 36 T7N R67W Weld County Well Production Facility Equipment or activity subjectto this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description LP Sep 004 Low Pressure Separator Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act(C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. 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.) I. F.4. ) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION! LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section iI.A.4.) Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO LP Sep 004 --- 0.9 20.1 4.3 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 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. The 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 owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: 5a tons per year of V0C., 9. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III. E.) Equipment ID AIRS Point Control Device Pollutants Controlled LP Sep 004 Emissions from the Separator are routed to an Enclosed Combustion Device V0C and HAP PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit LP Sep 004 Natural Gas Venting 14.02 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. Page 3 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 11. The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. 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) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. 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.17; 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. 15. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and recordkeeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O£tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.17) 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 30t" 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 NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 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. Wand 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 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 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. Laurateigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil £a Gas, Inc. Page 7 of 10 COLORADO Air Pollution Control Division Department. of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:'https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment ' iD AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) LP Sep 004 Benzene 71432 2,720 136 Toluene 108883 4,110 206 Ethylbenzene 100414 570 29 Xylenes 1330207 2,216 111 n -Hexane 110543 17,598 880 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. 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/MMscf) Controlled Emission Factors (lb/MMscf) Source NOx 133.3 133.3 AP -42, Chapter 13.5 CO 607.9 607.9 VOC 57,185 2859.3 Site -Specific Extended Gas Analysis taken 71432 Benzene 194 9.7 108883 Toluene 293 14.7 100414 Ethylbenzene 41 2.1 1330207 Xylene 158 7.9 7/11/2019 110543 n -Hexane 1,254 62.7 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1,' each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, and n -hexane PSD True Minor Source of: CO 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 Page 9 of 10 COLORADO Air Pollution Control Division Department a Public Health & Envtronment Dedicated to protecting and improving the health and environment of the people of Colorado 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 COLORADO Air Pollution Control Division Department of Public Health Ei Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0823 Issuance: Facility Name: Plant AIRS ID: Physical Location: County: Description: Extraction Oil £t Gas, Inc. Ice Man Production Facility 123/A07D SWSE Section 36 T7N R67W Weld County Well Production Facility Equipment or activity subject to this permit: 1 Equipment ID AIRS Point Equipment Description Emissions Control Description VRT 005 ' Vapor Recovery Tower Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the. Colorado Air Pollution Prevention and Control 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 Public Health 8 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.) 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. Part B, Section II.A.4.) Annual Limits: the following limitations. (Regulation Number 3, Equipment ID AIRS Point Tons per Year Emission Type RM2.5 NO,t VOC CO VRT 005 -- --- 9.2 1.4 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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 atztv 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 an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of VOC. 9. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits' established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled VRT 005 Emissions from the Vapor Recovery! Tower are routed to an Enclosed Combustion Device VOC and HAP PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum, processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) ) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit VRT 005 Natural Gas Venting 3.29 MMSCF Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month, a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 11. The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator must Page 3 of 10 he. NP�fM COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 12. 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) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. 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.17; 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. 15. The separator covered by this permit is subject to Regulation 7 Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (08M) plan and recordkeeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) Page 4 of 10 avtre COLORADO Aix Pollution Control Division Department of Pubic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.17) 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 (N0X) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or Page 5 of 10 C4 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 • No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 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 al) 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 Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health 8 £nveronment Dedicated to protecting and improving the health and environment of the people of Colorado 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. Lauraleigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 Issued to Extraction Oil is Gas, Inc. This Issuance 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: ihttps://www.colorado.gov/pacific/cdphe/agcc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment ' ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr)' VRT 005 Benzene 71432 939 47 Toluene 108883 649 32 n -Hexane 110543 7,738 387 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 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/MMscf) Controlled Emission Factors (lb/MMscf) Source CO 845.1 845.1 AP -42, Chapter 13.5 VOC 112,072 5,603.6 Site -specific extended gas analysis of sample taken 7/11/2019 71432 Benzene 285 14.25 108883 Toluene 197 9.85 110543 n -Hexane 2,349 117.5 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, and n -hexane PSD True Minor Source of: CO 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 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 Page 9 of 10 Nto 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 63.1440-63.6175 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 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Lauraleigh La Package #: !:414205 Received Date: 8/14/2019 Review Start Date: 10/10/2619 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: Exialoration & Production Weil Pad What industry segment?:01 & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ❑ Carbon Monoxide (CO) Extraction Oil & Gas, Inc. 123 4070 = s. Ice Man Prod SWSE quadrant of Section 36, Township 7N, Range 67W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range SWSE 7N 67 Particulate Matter (PM) [] Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit It Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate Tank TK 001-008 Yes 19WE0819 1 Yes Permlt'InitDB) Issuance 002 ProducedtfVatetTank PW-001, PW 002 Yea 19WE0820 1 Yes Permit Initial Issuance 003 Liquid Loading LOAD -001 Yes. 19WE0821; 1 -- Yes - Permit Initial Issuance 094 Separator Venting LP Separator Yes 19WE0822 1 Yes Permit[ttltial Issuance 005 Separator Venting VRTSeparator Yes 19WE0823 1 Yes Permit h2itia# issuance Section 03 - Description of Project This facility is a new exploration and production well pad that processes the materials from 7 on -site ells. The facility began production 5/16/2019. In addition to the above points, the facility: has 2 natural gas reciprocating internal combustion engines that are covered by a GP02. These permits were drafted with the Denver -Front Range 8 -hour ozone nonattainment redesignation to serious permits are Issued. The facility is synthetic minor for the pollutants listed below, Prior to issuance of these permits, the source modified the requested throughput for the LP separator leading the facility to have a facility -wide permitted level of VOC at approximately 90% of the title V major source threshold in the serious non -attainment area (So tpy), Because of this, the source will not be required to conduct annual testing, The condensate tanks wilt require site -specific sampling for the self -certification process, but the other sources submitted appropriate site -specific sampling. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? --.Greater than 25 tons per year in Nan-Attaitsmem Amp onattainment in mind as the redesignation will be in effect when these Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No Yes 502 NOx CO Is this stationary source a major source? If yes, explain what programs and which pollutants hers SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) VOC PM2.5 PM10 TSP HAPs 1i El VOC PM2.5 PM10 TSP HAPs ❑ ❑ Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AIRs ID: Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput= 40; Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating= Requested Monthly Throughput = 83216 Barrels (bbl) per month '. .$6,244 Barrels (bbl) per year Barrels (bbl) per year Potential to Emit (PTE) Condensate Throughput'. Secondary Emissions - Combustion Device(s) Heat content of waste gas = Volume of waste gas emitted per BBL of liquids produced = 3 ;�' °' :u/1 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device= Barrels (bbl) per year 2593',3 Btu/scf 3,750 MMBTU per year 4,514 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 4,514 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Condensate Tank Pollutant Benzene Toluene Uncontrolled Controlled (Ib/bbl) (Condensate Throughput) Ethylbenzene Xylene n -Hexane Pollutant NOx CO (lb/bbl) (Condensate Throughput) Section 05 - Emissions Inventory Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) .0075 .0375r 0.0080'.: 0:3100`; (Condensate Throughput) 00 Emission Factor Source Emission Factor Source Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 87.7 73.1 5.7 87.7 4.4 745 0.0 0.0 0.0 0.0 0,0 3 0.0 0.0 0.0 0,0 0.0 3 0.2 0.1 0,1 0.2 0.2 26 0,7 0.6 0.6 0.7 0.7 119 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethyibenzene Xylene n -Hexane 224 TMP 472 393 20 472 24 359 299 15 359 18 25 21 1 25 1 112 93 5 112 6 2939 2449 122 2939 147 23 19 1 23 k - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section 111.C -F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XI9.0 Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, 0, 6,1 & 6.3 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 NIPS kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HE Storage Tank is not subject to MACT Hit (See regulatory applicability worksheet far detailed analysis) 2 of 22 K:\PA\2019\19 W E0819. cp1 Condensate Storage Tank(s) Emissions Inventory Section 07- Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? t%4 If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should he considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then itmaybe appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes This source took a oressurised liquid sample;from downstre8m of the LP separatorigrrarto the. VR j an se - The source used Tanks 4.O.5dmodel to model the war kmg/brealb ng emissions, based on gasoline (RVP 13 5) The any oif as heat release was alculated::using the following calculation methodology MM9l U/yr {Uncontrolled VOC toy* 200016/tonmolar volume *heat content)/(VOC w, %x M rThis value was used to calculate the combustion -related emissions {NOc, CO,,P o model the OPT repaint confetti: of the c rodeo ion and presure step -d nstot)7e-. ate cane from the oil tank flash vapo sstream. The sampling that was provided was a nressurzed sample drawn a, the facility permitted; ho,uece , based on the guidance of PS Memo 05-G1 4-g3, the thesampte should betaken al separator outlet proceeding the condensate tank (r e. the VOT in this facility design). Because ofthis, the Pr rmri'w 11 include an mural testing conditiOxyequidng a pi essurzed liquid sample do of. the VRT &: upstream of .he -condensate tanks to re tnaf. Me emission actors requested ..r.-: rep tat ve. f facility operations_ The source requesteaono, ntroTledVOC emissions are slightly greater than those calculated base c lity inventory form with eeII ni Lhe sources requested uncontrolled emissions. G. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point 8 001 Process # 01 SCC Code on the requested emissions, howev e requested a VOC emission Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 Ib/1,000 gallons condensate throughput NOx 0.01 0 lb/1,000 gallonscondensate throughput VOC 4.3 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 0.01 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 . 0.07 95 lb/1,000 gallons condensate throughput 224 IMP 0.00 95 lb/1,000 gallons condensate throughput 3 of 22 K:\PA\2019\19W E0819.cp1 Condensate Tank Regulatory Analysis Worksheet Colorado Re • oration 3 Parts A and B -OPEN and Permit Requirements Soucce is in the Non-Attalnment Ares ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 11,0.1a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greaterthan 5 TM', NOx greater than 10 TPV or CO emissions greaterthan 10TPY (Regulation 3, Part B, Section 11.0.3)? You have irdicated that source is A: the. Nrn-A5tai:anent Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greaterthan 1 TPY (Regulation 3, Part A, Section II.D.1.e)? 2. Is the construction date (service date) priorta 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2for additional guidance on grandfather applicability)? 3. Are totalfaclllty uncontrolled VOC emissions greaterthan 2TPY, Woo greater than 5TPV.ar CO emission greaterthan 10 TPY (Regulation 3, Part B, Section 11.0.2)? ' I9qu.ece requires a permit Colorado Regulation 7, Section XII.C-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? (Storage tank Is subject to Regu€atior. 7, Section M[,C Section XI1.C1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section XII.C.2—Emission Estimation Procedures Section XILD —Emissions Control Requirements Section XII.E—Monitoring Section XII.F—Recordkeeping and Reporting Colorado Regulation 7, Section X01.5 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non-attalnment area or attainment/maintenance area? 2. Is this storage tank located eta natural gas processing plant? 3. Does this storage tank evhibit"Flash"(e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greaterthan or equal to Atom per year 0017 'Storage Tank is not subject to Ragulation 7, Svution 011.3 section XII.G.2- Emission Control Requirements Section XII.C.1 —General Requirements for Air Pollution Control Equipment— Prevention of leakage Section XIl.C.2—Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tanks located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual ' of this storage tank equal to or greaterthan 6 ton per year VOC? IStc•rage tank fsoubfact. Reeufatto, 7, SacNon XV+1, B. C.!0, C.7 Section XVII.B —General P iei osfor Air Pollution Control Equipment and Prevention of Emissions Section XVIl.C.1. Emissions Control. and Monitoring Provisions Section XVII.C3 Recordkeeping Requirements 5. Does the condensates -Wrap tank contain only 'stabilized" liquids? (Storage tank is suhfect So Repletion 7, Section k111.1.0 Section XVII.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR. Part 60. Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel cepaity greaterthan or equal to 75 cubic meters (ml) (-472 BBIs)? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a deign capacity less than or equal to 1,589.874 m° ['10,000 BBL] used for petroleum' or condensate stored,processed, or treated priorta custody transfer' as defined In 60.1116? 3. Was this condensate storage tank constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"' in 60.1116? 5. Does the storage vessel More a'volatile organic liquid (VOL)'. defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemption: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ["29.7 psi] and without emissions to the atmosphere f W.110b(d((2((7; or b. The design capacity is greaterthan 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)l7; or c. The design capacity is greaterthan or equal to 75 M5 (-472 BBL] but less than 151 ms (-950 BBL] and stares a liquid with a maximum true vapor pressures lessthan 15.0 kPa(60.110b(b))? 'Storage Tanh is not subject to NSPS gb Subpart A, General Provisions §00.2126- Emission Control Standards for VOC §60.1136 -Testing and Procedures §60.1156- Reporting and Rerordkeeping Requirements 460.1166 - Monitoring of Operations 40 CFR. Part 60. Subpart 0000. Standards of Performance far Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel looted at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definition 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tans per year? 4. Does this condensate storage vessel meet the definition of"storage vessel"' per 60.54307 5. Is the storage vessel subject to and controlled in accardanre with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HO? 'Storage. Tank is not sublet. to SOPS C„t):,' Subpart A, General Provisions per 060.5425 Table 3 400.5395- Emissions Control Standards for VOC 0605413 -Testing and Procedures 000.5305(g) - Not0atian, Reporting and Recardkeeping Requirements 060.5416(c) - Cover and Closed Vent System Monitoring Requirements 060.5417 - Control Device Monitoring Requirements [Note:. If a storage vessel Is previously determined to be subject to rasps 0000 due to emission above 6 tons per year VOC on the applicability determination date, It should remain subjectto NSPS 0000 per 60.536S(e)(2) even if potential VOC emission drop below G tons per year) 40 CFR. Part 63, Subpart MAR OH. Oil and Ges Production Facilities 1. is the storage tank located at an al and natural gas production facility that meets either of the fallowing criteria: e. Afacility that processes, upgrades or stares hydrocarbon liquids' (63.760(a[(2)); OR b. A facility that processes, upgrades or Mores 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))? 2. Is the tank lasted at a facility that is majors for Flops? 3. Does the tank meet the definition of "storage vessel"' in 63.7617 4. Does the tank meet the definition of''forage vessel with the potential for flash emosioni° per 63.761? 5. Is the tank subject to control requirements under40 CFR Part 60, Subpart Kb or Subpart 0000? !Storage Tank is not subject to MACY Hit Subpart A, General provisions per 053.764 (a) Table 2 §63.766- Emissions Control Standards §63.773- Monitoring §03.774- Recardkeeping §63.775 -Reporting RACT Review RACT review Is required If Reguladan 7 does not apply AND if the tank is In the non -attainment area. tithe tank meets both cdteda, then review RACT requirements. • Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is note rule or regulation, end 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 oilier 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 mgulattons, and Air Quality Control Commission regulations, the language of the statute ar regulation wilt control. The use of non -mandatory language such as "recommend,""may"'should,"and 'can," is intended to desenbe APCD interpretations end recommendations, Mandatory terminology such as "must" and 'required" aria intended to describe controlling requirements under the terms of the Clean Air Act and Air Qualify Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Y n ` t4DOZA. Yes No run WVES Source Req Go to next Source Req Continue-' Coninue Source is sr. Continue-' Storage Tar Source Is so Continue-' ea to the n Ga to then Source got �Na i-: `.Source is st Continue Storage Tar "fd'A" ;nit MUM M WPM Storage Tar Continue Storage Tat Produced Water Storage Tank(s) Emissions Inventory 002 Produced Water Tank 'Facility/011s ID: County Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control DeviceEiclosedCombusti Description: Requested Overall VOC & HAP Control Efficiency °b: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput= 'Requested Permit Limit Throughput = Potential to Emit (PTE) Produced Water Throughput= Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced ="`= 21 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = er oroge:vessels Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = Barrels (bbl) per year Requested Monthly Throughput = 23985 Barrels (bbl) per month Barrels (bbl) per year Btu/scf 612 MMBTU per year 734 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 734 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Produced Water Throughput) (Produced Water Throughput) VOC s 0062 ;,jhi,,z,.: 3.10E-03 2.05E-04 1.45E-04 5.85E-06 2.50E-05 1.75E-04 0.00E t00 Benzene Toluene ai O. Ethylbenzene Xylene n -Hexane D Q035 w 224TMP 0.00l Pollutant Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (Produced (waste heat Water combusted) Throughput) PM10 0.QQ7"s-;E. PM2.5 0 0075'` 0.0000 0,0000 0.0002 0.0008 NOx CO 0:0680 D: Section 05 - Emissions Inventory Emission Factor Source Emission Factor Source Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 8.8 7.3 0.4 8.8 0.4 74 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0,0 0.0 0.0 0 0.0 0,0 0.0 0.0 0.0 4 0,1 0.1 0.1 0.1 0.1 19 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224TMP 1158 965 48 1158 58 819 682 34 819 41 33 28 1 33 2 141 118 6 141 7 988 824 41 988 49 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage Tank is not subject to Regulation 7, Section XVII Regulation 7, Section XVII.C.2 Storage Tank is not subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 (See regulatory applicability worksheet for detailed analysis) 5 of 22 K:\PA\2019\19W E0819.cp1 Produced Water Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? t4 ' If yes and if there are flash emissions, are ttoe emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), thenitmay 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 Does the company request a control device efficiency greater than 95% for a flare or combustion device? Ifyes, 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 4-03, questions 5.9 and 5.12 for additional guidance on testing. Section 08 - Technical Analysis Notes figure ma+ntain'a STEM plan irsns':'cal cua itionsi asame source. taken at the separator of the water 10/07/: Il developmeri of e mis;rons factors Even though the seemissians may he /�Pf:$3'thdt'rriafched the zlculatfoh-slteet hut did not a Irgn with the reported actual emissions. I In order tocapture slight d ffe,ences in emissions ('.e. benzene and n hexane -have the identical emis n7 Section Section 09 - Inventory SCC Coding and Emissions Factors for the tanks,iv. 2 vessels jexciteds a: tpy VOG.Thesv'urce. will AIRS Point # Process # SCC Code 002 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons liquid throughput PM2.5 0.00 0 lb/1,000 gallons liquid throughput NOx 0.00 0 lb/1,000 gallons liquid throughput VOC 1.5 95 lb/1,000 gallons liquid throughput CO 0.02 0 lb/1,000 gallons liquid throughput Benzene 0.10 95 lb/1,000 gallons liquid throughput Toluene 0.07 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.01 95 lb/1,000 gallons liquid throughput n -Hexane 0.08 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput 6 of 22 K:\PA\2019\19W E0819.cpl Compound Weight Fraction Emission Factor (lb Oxygen/Argon Nitrogen CO2 CH4 Ethane Propane Isobutane Butane Isopentane Pentane Cyclopentane n -Hexane Cyclohexane iylcyclohexane & Other Her Heptane 2,2,4-Trimethylpentane Benzene Toluene Ethylbenzene m-xylene Octane Nonane Decanes+ VOC's 0 6.21840 32.219300000 12.43670 18.6610 14.8417 1.1559 3.8992 0.58080 0.7187 0.247500 1.74660 0.26420 2.90250 0.10420 0.0000000 2.011700 1.410000 0.0579000 0.257200 0.15020 0.040400 0.076000 30.4647 0.000000 0.011883 0.061567 0.023765 0.035659 0.028360 0.002209 0.007451 0.001110 0.001373 0.000473 0.003338 0.000505 0.005546 0.000199 0.000000 0.003844 0.002694 0.000111 0.000491 0.000287 0.000077 0.000145 0.058214 0.003444 Total (W/B/Flash) Hours/Year Throughput (bbl/yr) Actual throughput VOC w/b (lb/bbl) Gas Water Ratio Gas Molar Volume @ 60 F, 14.. Gas Molecular Weight 0.000000 0.003967 0.002780 0.000114 0.000507 0.060 8760 282400 282400 0.00186 2.1 379 34.4865 Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. 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'eny criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, PartA, Section II.D.1.a)? 2. Is the operator deleting less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part e, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, Non greater than lO TM/ or C0 emissions greater than lD TPY (Regulation3, Part B, Section ll.D.3)? 'You have indicated Chet source is in lire NomAttainment Aree NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located eta non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part e, Section II.D.1.M( 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.0.2)? 'Source requires a permit Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility, natural gas compressor stations or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions°ofthis storage tank equal to or greater than 6 tons per year VOC? (Storage Tank is nn subject to Regulation 7, Section XVII Section XVII.B— General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section XVI I.C3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. (Storage Tank is not subject to Regulation 7, Section xtl€.C2 Section XVII.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution I. Is this produced water storage -vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2, Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430? 'Storage Tanis is not subject to NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 -Testing and Procedures 560.5395(g)- Notification, Reporting and Recordkeeping Requirements 100.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Moritoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tom per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5355)e(121 even if potential VOC emissions drop below 6tons per year] RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACE requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend,' may,' 'should,' and '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 WARN No Yes Yes NOME Source Req Go to next Source Reg Continue-' Continue - Go to then Storage Tat Continue-' Storage Tar Storage Tar Go to the n Hydrocarbon Loadout Emissions inventory 003 Liquid Loading Facility AIRs ID: County A070:: Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: 95.00 Requested Overall VOC & HAP Control Efficiency %: Section 03.- Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded= Requested Permit Limit Throughput= Potential to Emit (PTE) Volume Loaded = 25 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = Requested Monthly Throughput= 8319 Barrels (bbl) per month Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = C'. Barrels (bbl) per year 2593,, Btu/scf 158597 scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 -Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Loading Loss Equation L = 12.46.5`P'M/T 345 MMBTU per year 414 MMBTU per year 414 MMBTU per year Barrels (bbl) per year A site specific stabilzed hydrocarbon liquid sample must he provided to develop a site specific emissions factor. Factor Meaning Value Units Source S Saturation Factor u.5 //4w �� Y Af�d�Cfe� b�eS a=a =adieu .y .7smaf Senrice(a O5�9 P True Vapor Pressure 7.17 = ". psia AP 42, Chapter 7,Tabfa/7.1-2 rorla5olme RVP 13 extrapolated for oping temperature csl M Molecular Weight of Vapors 62 I ^:'• Ib/Ib-mol AP -42, Chapter 7, Table 7.1-2 foe Gaon line.RVP 1,3 T Liquid Temperature ."'''??5:923.67 r Rankine .Operating Temperatures - L Loading Losses 6.386326462 lb/1000 gallons Loading Lots Equation 0.266545732 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene ,,;0.002585715 0.0007166655 lb/bbl Mass Fraction of HAP/VOC of the CondensateTank Flash Vapor Stream from. ProMax Toluene a `- III 0.002042493 0.000544418 lb/bbl `lass Fraction of HAP/VOC of the Condensate. Tank Flash Vapor Stream from rrohdas Ethylbenzene 014316 -,3 3.86917E-051b/bbl Mass Pm eUon of NAP/VOC of the Condensate Tank Flash Vapor Stream frnr?FTP'clr?3 at Xylene '-≤z_' 0.000635056 ' . 0.000169272 lb/bbl :.. diiass Fraction of HAP/rl0C of the Condensate Tank Flash Vapor Stream front eroMau. n -Hexane - 0:015135999 v2 0.004034436 lb/bbl Mass Fraction of HAP/VOC of the Condensate Tank Flash Vapor Stream frail"! Pi°taloa 224 TMP 0.000128239 . 3.41816E-05 lb/bbl Ma ss Fraction of HAP/VOC of the CondensateTank Flash Vapor Stream from Emission Factors Hydrocarbon Loadout_ Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) 1.33E-02 3.58E-05 2.72E-05 1.93E-06 8.46E-06 2.02E-04 1,71E-06 Emission Factor Source VOC 2.57E-01 7.17E-04 5.44E-04 3.87E-05 1.69E-04 4.03E-03 3.42E-05 Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Pollutant Control Device Uncontrolled Uncontrolled (lb/MMBtu) (lb/bbl) Emission Factor Source (waste heat combusted) (Volume Loaded) 3.15E-05 3.15E-05 2.49E-06 2.87E-04 1.31E-03 PM10 PM2S tAROW0.007:5-VOMW.M 0.0075_ 0..0 0.0680' s ✓✓" at SOB NOx CO 9 of 22 K:\PA\2019\19 W E0819. cp 1 Hydrocarbon Loadout Emissions inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tans/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 sox NOx VOC CO 0.00 0.00 0.00 0,00 0.00 0 0.00 0.00 0,00 0.00 0.00 0 0.00 0.00 0.00 0.00 0,00 0 0.01 0.01 0.01 0.91 0.01 2 13,05 10,65 0,54 13,05 0.65 111 0.06 0.05 0.05 0,06 0.06 31 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 70 58 3 70 4 53 44 2 53 3 4 3 0 4 0 17 14 1 17 1 39.5 329 16 395 20 3 3 0 3 0 Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a (See regulatory applicability worksheet for detailed analysis) The loudest must be operated with submerged fill to satisfy RACT. Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08- Technical Analysis Notes _ _ _ ___ _ _ _ _ __ ijeat content provided for the combustion emissions is more conservativethan the statec ndensate heatingyalue. This value camefrom the "Gross Ideal Gas Heatnng'V (ue"ofthe;gpnt)ensate antclt5 i- the PrvMax simulation.;'. Tde source is not required to complete annualsamphng f the loadoutto confirm emissions,factors, because the only component that could change from sampling would be the HAP missions„�tottft? )is basedontihc>,'�'AP 42 to methodology. Because the controlled emissionsfocthe HAPs is of close₹oa₹#ireshold,this`testing is not required. If the sourco needs to modifyoperatmg parameter Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point if 003 Process II 01 SCC Code 4-06-00142 Crude Oil: Submerged Loading Normal Service (S=0.6) Pollutant PM10 PM2.5 SOx NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Uncontrolled Emissions Factor Control % Units 0.00 0 lb/1,000 gallons transferred 0.00 0 lb/1,000 gallons transferred 0.00 0 lb/1,000 gallons transferred 0.01 0 lb/1,000 gallons transferred 6.3 95 lb/1,000 gallons transferred 0.03 0 lb/1,000 gallons transferred 0,02 95 lb/1,000 gallons transferred 0.01 95 lb/1,000 gallons transferred 0.00 95 Ib/1,000 gallons transferred 0,00 95 lb/1,000 gallons transferred 0.10 95 lb/1,000gallons transferred 9.00 95 lb/1,000 gallons transferred 10 of 22 K:\PA\2019\19 W E0819.cp1 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and 0 - APEN and Permit Requirements (Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants front this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I(? 3. . Is the loadout operation loading less than 10,000 gallons (238 eels) of crude oil per day on an annual average basis? 4. A the loadout operation loading less than 6,750 hbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Aretotal facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10TPY (Regulation 3, Part B, Section II.D.3)? [You have radiated that source is in the NorrAtteinment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and productionsite (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)? Is the loadout operation loading less than 10,000 gallons (238 BBIs) of crude oil per day on an annual average basis? '4. Is the loadout operation loading less than 6,750 bhls per year of condensate vla splash fill? 5. ' Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are'total facility uncontrolled VOC emissions from the greater than 2TPV, N05 greater than 5 TPY or CO emissions greater than 10TPY (Regulation?, Part B, Section 11.D.2)? [Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? IT€ a loadout most he operated with submerged fill to satisfy RACT. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceab/e. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend,' 'may," 'ohauid,'atid 'can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required' are intended todescribe 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. Th WEN Rama WOJELM Y?S, Go to next Go to then Go to next Ga to next. Da to next The loadou :v The loadou Separator Venting Emissions Inventory 'amr venting stream 7/11/2019 at Displacement Equation Ex=Q'MW'Xx/C Emission Factor Emission Factor Source 004 Separator Venting Facility AIRS ID: 123 County A47F7 Plant 004... Point Section 02 - Equipment Description Details Low Pres5u Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Separato Actual Throughput- ... e (Que1A0g06000) MMscf per year Requested Permit Limit Throughput = 14:4{ MMscf per year Requested Monthly Throughput = MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 14 MMscf per year Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04- Emissions Factors & Methodologies Description h/lb-mol Oxygen/Argon CO2 N2 methane ethane propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224 -TM P Benzene Toluene Ethylbenzene Xylenes C8+ Heavies Total VOCWt% Weight % 1:oa 4.71' 20.59 27,61 12.50 3.21: 0»2 A' 043 0:. 0:65 0.00 0.21:. 0'. .04 033171 632 14;0-.01 61.07 Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) (Gas Throughput) Benzene 194, Toluene 293.1584 Ethylbenzene 40.6618 Xylene 158. n -Hexane 224 TMP 1.49 (Gas Throughput) 750 Primary Control Device Pollutant PM10 PM2.5 t7.OD75 Uncontrolled Uncontrolled Ilb/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) 4. psi:and a sample tempers 12 of 22 K:\PA\2019\19W E0819.cp1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.10 0.09 0.09 0.10 0.10 17 0.10 0.09 0.09 0.10 0.10 17 0.01 0.01 0.01 0.01 0.01 1 0.93 0.78 0.78 0.93 0.93 159 401.12 334.46 16.72 401.12 20.06 3407 4.26 3.55 3.55 4.26 4.26 724 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 2720 2268 113 2720 136 4110 3427 171 411.0 206 570 475 24 570 29 2216 1:848 92 2216 111 17598 14673 734 17598 890 21 18 1 21 1 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source Is subject to Regulation 7, Section XVll.8.2, G The control device for this separator is not subject to Regulation 7, Section ovll.B.2.e Does the company use site specific emission factors based on a gm sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling 13 of 22 K:\PA\2019\19WE0819.cp1 Separator Venting Emissions Inventory Section 08 -Technical Analysis Notes AIRS Point # 004 Section 09 - Inventory SCC Coding and Emissions Factors Process # SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 14.61 0 Ib/MMSCF PM2.5 14.61 0 Ib/MMSCF SOx 1.15 0 lb/MMSCF NOx 13335 0 lb/MMSCF VOC 57221.45 95 Ib/MMSCF CO 607.91 0 Ib/MMSCF Benzene 194.03 95 Ib/MMSCF Toluene 293.16 95 IWRIMSCF Ethylbenzene 40.66 95 Ib/MMSCF Xylene 158.06 95 Ib/MMSCF n -Hexane 1255.18 95 Ib/MMSCF 224 TMP 1.50 95 Ib/MMSCF .14 of 22 K:\PA\2019\19WE0819.cp1 Separator Venting Regulatory Analysis Worksheet 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 A, Section II.D.1.e)? 2. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.D.3)? 'You have indicated that source is in the Non-Attainmeai Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than IOTPY (Regulation 3, Part B, Section 11.0.2)? 'Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, orrecompleted on or after August 1, 2014? 'Source is settled to Regulation 7, Section XVII.BT, G Section XVII.B.2 —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section). a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator is not subject to Regulatmri 7, Section X VlI.5.2.e Section XVI1.B.2.e — Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend,"'may,"'should,' and 'can,'is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'muse 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 ,Source Req Source Req rplialIAThe control N Separator Venting Emissions Inventory 005 Separator Venting Facility AIRs ID: 123 ; A07O I;. County Plant 005 Point Section 02 - Equipment Description Deals Detailed Emissions Unit Description: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Requested Permit Limit Throughput = Pt MMscf per year Requested Monthly Throughput = 0 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 3 MMscf per year Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL o liquids throughput: Section 04 - Emissions Factors & Methodologies Description Weight % Oxygen/Argon CO2 N2 methane ethane p n4 60 propane isobutane n -butane isopentane 6.05 n -pentane cyclopentane n -Hexane cyclohexane Other hexanes hepta nes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies S 24 4 €750 0'.44 3 0 0 '10O. O.22 0 15: 401 0.04 1,05 Total VOC Wt % 1:00.42 37.23 Btu/scf scf/bbl Ib/Ib-mol Displacement Equation Ex=Q*MW*Xx/C Pollutant Separator Venting Uncontrolled (Ib/MMscf) Controlled (Ib/MMscf) .5608.7641 285.3646 IMMEMEI IMMINOTMEIMMZIMMIIMIZE 54.7838 MINIFEISMIN IMMMEMIMEMOMMI 16.8467 0.8423 Pollutant 11111117.1 r 117.5488 0.0643 Primary Control Device Uncontrolled. (Ib/MMBtu) (Waste Heat Combusted) Uncontrolled Ib/MMscf (Gas Throughput) Emission Factor Source Emission Factor Source 16 of 22 K:\PA\2019\19W E0819.cp1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tans/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 sox NOx VOC CO 0.03 0.03 0.03 0.03 0.63 6 0.03 0.03 0.03 0,03 0.03 6 0.00 0.00- 0.00 0.00 0.00 0 0.30 0.25 0.25 0.30 030 52 184.53 153.68 7.68 184.53 933 1567 1.39 1.16 1.16 139 , 1.39 236 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 939 782 39 939 47 649 _ 541 27 649 32 55 46 2 55 3 180 150 8 180 9 7738 6444 322 7738 387 4 4 0 4 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 XV0.6.2. G Regulation 7, Section XVII.B.2.e The central device for this separator Is not subject to Regulation 7, Section XVII.B.2,e ee regulatory applicability worksheet for detailed analysis Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific =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? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling process parameter is nafuai gas vented. The fol 17 of 22 K:\PA\2019\19WE0819.cp1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes e emissions factorsestablished in't Section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point # 005 Process # SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 20.31 0 lb/MMSCF PM2.5 20.31 0 ib/MMSCF SOx 1.60 0 tb/MMSCF NOx 18537 0 lb/MMSCF VOC 112175.28 95 lb/MMSCF CO 845.06 0 lb/MMSCF Benzene 285.36 95 lb/MMSCF Toluene 197.27 95 Ib/MMSCF Ethylbenzene 16.35 95 lb/MMSCF Xylene 54.78 95 Ib/MMSCF n -Hexane 235198 95 Ib/MM5CF 224 TMP 1.29 95 Ib/MMSCF 18 of 22 - K\PA\2019\19WE0819.cp1 Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements 'Seance 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 5TPY, NOx greater than 10 TPY or CO emissions greater than 10TPY (Regulation 3, Part B, Section 11.0.3)7 IYouhaveindicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1 TPY (Regulation 3, Part A, Section ll.D.1.a)7 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 11.0.2)? IS it Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,2014? 'Source subject to Regulation 7, Section 2511.0.2. G Section XVI I.B.2 General Provisions for Alr Pollution Control Equipment and Prevention of Emissions Section XVII.G- Emissions Control Alternative Emissions Control (Optional Section). a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? Source Req Source Req 1 RA Source Is sl . 'The control device for this separator is not subject to Regulation 7, Section X 5ll.B.2.e Section XVII.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as'recommend,"may,"should,' and 'can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must and 'required° are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself The control COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Extraction Oil & Gas, Inc. County AIRS ID 123 Plant AIRS ID 4WD Facility Name Ice Man Production Facility History File Edit Date Ozone Status 1/13/2020 Non -Attainment Last Edited By: Lauraleigh Lakocy EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 19WE0819 Condensate Tanks (8-400 bbl) 0.2 87.8 0.8 2.0 D.2 4.4 0.8 D.1 Newly requested point 002 19VVE0820 Produced Water Tanks (2-400 bbl) 0.0 8.7 0.1 1.6 0.0 0.4 0.1 0.1 Newly requested point 003 19WE0821 Condensate Loadout 0.0 13.1 0.1 0.3 0.0 0.7 0.1 0.0 Newly requested point 004 19WE0822 LF' Separator Venting 0.9 401.0 4.3 13.6 0.9 20.1 4.3 0.6 Newly requested point 005 19WE0823 VRT Separator Venting 0.3 184.1 1.4 4.8 0.3 9.2 1.4 0.2 Newly requested point 006 GP02 Caterpillar 400 HP 4SRB NGRICE 0.3 0.3 50.6 2.7 50.6 0.4 0.3 D.3 3.9 2.7 7.7 0.4 Serial # WWF00283 007 GP02 Caterpillar 400 HP 4SRB NGRICE 0.3 0.3 50.6 2.7 50.6 0.4 0.3 0.3 3.9 2.7 7.7 0.4 Serial # WWF00241 0.0 0.0 APEN Exempt/Insignifican Emissions 0.0 0.0 Combustion Control Devices (IES) 0.1 0.5 0.2 0.0 0.1 0.5 0.2 0.0 Combustion Control Devices (05000 0.1 0.9 0.4 0.0 0.1 0.9 0.4 0.0 I-ILP Separator Burners (7) 0.2 0.2 2.3 0.1 1.9 0.0 0.2 0.2 2.3 0.1 1.9 0.0 From Form APCD-102 Fugitives 0.6 0.0 0.6 0.0 From Form APCD-102 (Verified) FACILITY TOTAL 0.8 0.8 0.0 0.0 105.0 701.6 0.6 110.5 23.0 0.8 0.8 0.0 0.0 11.6 41.7 0.6 24.7 1.8 VOC: Syn Minor (NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (OP), True Minor (PSD) HAPS: Syn Minor n -hexane Permitted Facility Total O.6 0.6 0.0 0.0 102.6 700.1 0.0 107.9 23.0 0.6 0.6 0.0 0.0 9.2 40.2 0.0 22.1 1.8 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.6 0.6 0.0 0.0 9.2 40.2 0.0 22.1 Pubcom required because of facility emissions/syn minor limits. Modeling not required based on Division guidelines. Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Pe mitted VOC emiss ons (point and fugitive) 42.3 Facility is eligible for GP02 because -s 90 tpy Project emissions NOT less than 25 tpy - requires pubcom. 40.2 Note 2 2 Page 20 of 22 Printed 1/13/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Extraction Oil & Gas, Inc. County AIRS ID 123 Plant AIRS ID A07D Facility Name Ice Man Production Facility Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0819 Condensate Tanks (8-400 bbl) 472 359 25 112 2939 23 2.0 002 19WE0820 Produced Water Tanks (2-400 bbl) 1158 819 33 141 988 0 1.6 003 19WE0821 Condensate Loadout 70 53 4 17 395 0.3 004 19WE0822 LP Separator Venting 2720 4110 570 2216 17598 21 13.6 005 19WE0823 VRT Separator Venting 939 649 55 180 7738 4 4.8 006 GP02 Caterpillar 400 HP 4SRB NGRICE 464 83 78 47 91 0.4 007 GP02 Caterpillar 400 HP 4SRB NGRICE 464 83 78 47 91 0.4 0.0 APEN Exempt/Insignificant Emissions 0.0 Combustion Control Devices (IES) 0.0 Combustion Control Devices (Q5000) 0.0 HLP Separator Burners (7) 0.0 Fugitives 0.0 TOTAL (tpy) 0.5 0.1 0.1 2.7 3.0 0.3 1.3 14.8 0.1 0.0 0.0 0.0 23.0 otal Keportaole = all I1AI's w ere uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0819 Condensate Tanks (8-400 bbl) 24 18 1 6 147 1 0.1 002 19WE0820 Produced Water Tanks (2-400 bbl) 58 41 2 7 49 0 0.1 003 19WE0821 Condensate Loadout 4 3 0 1 20 0.0 004 19WE0822 LP Separator Venting 136 206 29 11 880 1 0.6 005 19WE0823 VRT Separator Venting 47 .32 3 9 387 0 0.2 006 GP02 Caterpillar 400 HP 4SRB NGRICE 464 83 78 47 91 0.4 007 GP02 Caterpillar 400 HP 4SRB NGRICE 464 83 78 47 91 0.4 0.0 APEN Exempt/Insignificant Emissions 0.0 Combustion Control Devices (IES) 0.0 Combustion Control Devices (Q5000) 0.0 HLP Separator Burners (7) 0.0 21 19WE0819.cp1 1/13/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Extraction Oil & Gas, Inc. County AIRS ID 123 Plant AIRS ID A07D Facility Name Ice Man Production Facility Fugitives 0.0 1.8 TOTAL (tpy) 0.5 0.1 0.1 0.2 0.2 0.0 0.0 0.7 0.1 0.0 0.0 0.0 22 19WE0819.cp1 1/13/2020 Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit ',PD -r- ;\\ / All sections of this APEN and application must be completed for both new and existing facilities, including APEN S' updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require - payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: (23 /4m7P / aot [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Extraction Oil & Gas, Inc. Ice Man Production Facility Site Location: SWSE SEC 36 T7N R67W Mailing Address: (Include Zip Code) 370 17th Street, 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-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 414197 COLORADO 1 I A ;mot NwllhbFl.Wrcnrno�.1 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source O Request coverage under traditional construction permit O Request coverage under a General Permit O GP01 O 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 ❑ Change company name3 ❑ Change permit limit O Transfer of ownership4 O 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 Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Eight (8) - 400 bbl condensate storage vessels TK 001-008 For new or reconstructed sources, the projected start-up date is: 05/16/2019 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks /year Exploration a Production (EaP) site O Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? 12 Yes ■ No Are Flash Emissions anticipated from these storage tanks? p Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? Yes No ig • If "yes", identify the stock tank gas -to -oil ratio: 2.72E-05 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 2 I COLORADO Is Fi:e M...Er"' e P,*U NaaUh6 rim.unnrl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) Condensate Throughput: 816,249 979,798 From what year is the actual annual amount? Projected Average API gravity of sales oil: 48.0 degrees ❑ Internal floating roof Tank design: 0 Fixed roof RVP of sales oil: 13.3 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TK 001-008 8 3200 5/2019 5/2019 Wells Serviced by this Storage Tank or Tank Battery6 (EEtP Sites Ony) API Number Name of Well Newly Reported Well See Form APCD-212 ■ ■ ■ ■ ■ s Requested values will become permit limitations. Requested limit(s) 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 wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.525993/-104.840448 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECDs -20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) 0 Upward O Horizontal ❑ Downward O Other (describe): Indicate the stack opening and size: (check one) 0 Circular ❑ Square/rectangle O Other (describe): 9 Upward with obstructing raincap Interior stack diameter (inches): TBD Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 COLORADO 3jHealthbEnvinmm�l Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOCs/HAPs Rating: TBD Type: ECDs MMBtu/hr Make/Model: I ES 48" Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD Waste Gas Heat Content: 2,593 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —5 psig Describe the separation process between the well and the storage tanks: (7) HLP separators, to VRT, to (8) condensate storage tanks Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 COLORADO 4 I r:of Pcbtx Haa.IhbEnvleanm:c� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECDs 95 NOx CO HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, M etc.) Uncontrolled Emissions tons/ ear (tons/year) ) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) ( ns/year) Controlled Emissions (tons/year) VOC 0.179 lb/bbl ProMax 73.20 3.66 87.84 4.39 NOx 0.068 lb/MMBtu AP -42 0.14 0.14 0.17 0.17 CO 0.31 Ib/MMBtu AP -42 0.64 0.14 0.77 0.77 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis 5.O..F.-q‘ Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled 8 Emissions8 (pounds/year) Benzene 71432 -0.001- lb/bbl ProMax 394 20 Toluene 108883 ' lb/bbl ProMax 300 15 -4.82E 4 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.003 lb/bbl ProMax 2,216 111 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 ®® ;COLORADO 5 l _......-.00� N�allfi tr Evv:r .1 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit r and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 861 Signat re 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: r❑ Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 6I COLORADO nuZU,b nQTcue HenO�EEnvtmnmenl - -JAL: \;� 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 C' 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-2OO) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: /91NE o szp AIRS ID Number: 123 1,407Df b OZ [Leave blank unless APCD has already assigned a permit fr and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Extraction Oil & Gas, Inc. Ice Man Production Facility Site Location: SWSE SEC 36 T7N R67W Mailing Address: (Include Zip Code) 370 17th Street Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: Jon Torizzo (303) 396-6051 E -Mail Address2: air@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 414158 'COLORADO 1 I ®' . o.-,.,.a.'v r'a HaallhtrFrvfeaiunn:l Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP05 O 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 ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Two (2) - 400 bbl Produced Water Storage Vessels PW-001, 002 For new or reconstructed sources, the projected start-up date is: 05/16/2019 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week ❑✓ Exploration Et Production (EEtP) site 52 weeks/year O Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? Yes ❑ No ✓ Are Flash Emissions anticipated from these storage tanks? / Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No / Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes No / Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes ❑ No ✓ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes ❑ No ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 �� < :COLORADO 2 I e n= of c MAUI. Fr En:mnvironzreml Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbl /year) 235,333 Requested Annual Permit Limits (bbl/year) 282,400 From what year is the actual annual amount? Tank design: ✓❑ Fixed roof Projected ❑ Internal floating roof ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) Pw 001-002 2 800 5/2019 5/2019 Wells Serviced by this Storage Tank or Tank Battery6 (MP Sites On y) API Number Name of Well Newly Reported Well SEE ATTACHED FORM APCD-212 ❑ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.525993/-104.840448 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECDs -20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ✓❑ Upward ❑ Horizontal ❑ Downward El Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Square/rectangle ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap TBD Interior stack width (inches): Interior stack depth (inches): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 AW COLORADO 3 I �_- Hulfl+b En .t Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOCs/HAPs Rating: TBD Type: ECDs MMBtu/hr Make/Model: I ES 48" Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD 0/0 Waste Gas Heat Content: 424 Btu/scf Constant Pilot Light: ✓❑ Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —40 psig Describe the separation process between the well and the storage tanks: HLP Separator, Produced Water Storage Tanks Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 COLORADO 4 I �n:01u . Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECDs 95 NOx CO HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.021 lb/bbl FLA Analysis 2.45 0.12 2.94 0.15 NOx 0.068 lb/MMBtu AP -42 0.01 0.01 0.01 0.01 CO 0.31 lb/MMBtu AP -42 0.04 0.04 0.04 0.04 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions8 (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 COLORADO 5 Mne1lT bEnvirorvnerl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signatur? 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 Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 I COLORADO 6 I A. Kea.. .vffa:�nnnl !; IC, Produced Water Storage Tank(s) APEN Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: (LC CAIRS ID Number: t, , r=';�1 c::(1,. C. [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Ice Man Production Facility Site Location: SWSE SEC 36 T7N R67W Mailing Address: (Include Zip Code) 370 17th Street Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Jon Torizzo Phone Number: (303) 396-6051 E -Mail Address2: air@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 ®y COLORADO 1 I Mea nrn N sP ¢ Neallh E F.nvlronm�n� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP05 ❑ 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 ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source O Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Two (2) - 400 bbl Produced Water Storage Vessels PW-001, 002 For new or reconstructed sources, the projected start-up date is: 05/16/2019 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year El Exploration Ft Production (E&P) site O Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes ❑ No Are Flash Emissions anticipated from these storage tanks? ✓ Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No ✓ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes ✓ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes ❑ No ✓ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes ❑ No ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 2 I AvCOLORADO moth E. Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbl/year) 235,333 Requested Annual Permit Limits (bbl/year) 282,400 From what year is the actual annual amount? Tank design: ❑✓ Fixed roof Projected O Internal floating roof ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most. Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) Pw 001-002 2 800 5/2019 5/2019 Wells Serviced by this Storage Tank or Tank Battery6 (MP Sites Only) API Number Name of Well Newly Reported Well SEE ATTACHED FORM APCD-212 ❑ - ❑ - - ❑ - - ❑ s Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EEP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.525993/-104.840448 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECDs —20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Horizontal 0 Downward 0 Other (describe): El Upward with obstructing raincap Indicate the stack opening and size: (check one) p Circular Interior stack diameter (inches): TBD ['Square/rectangle Interior stack width (inches): Interior stack depth (inches): O Other (describe): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 ®V COLORADO 3 I . rR o �:�� ' H atlF bEnvl,nnmrr.l Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOCs/HAPs Rating: TBD MMBtu/hr Type: ECDs Make/Model: I ES 48" Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 1,129 TBD Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: D 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)? —40 psig Describe the separation process between the well and the storage tanks: HLP Separator, Produced Water Storage Tanks Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 ®'.COLORADO AIRS ID Number: Permit Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECDs 95 NOx CO HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basin Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions ` (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.062 lb/bbl FLA Analysis/tanks 409d 7.28 0.36 8.74 0.44 NOx 0.068 Ib/MMBtu AP -42 0.02 0.02 0.02 0.02 CO 0.31 Ib/MMBtu AP -42 0.09 0.09 0.1 0.1 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract . Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions 8 (pounds/year) Benzene 71432 0.004i lb/bbl FLAAnalysts/tanks 409d 960 48 Toluene 108883 0.0032? i lb/bbl FLAAnalysls4anks409d 673 34 Ethylbenzene 100414 Xylene 1330207 ,�.C(Cr5 1v)(11:\I n -Hexane 110543 -0:004 r lb/bbl FLA Analysis/tanks 409d 834 42 2,2,4- Trimethylpentane 540841 ,_s `", -) 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 ANCOLORADO �, 5 <a:anPut, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 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: ✓0 Draft permit prior to issuance 0 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 Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: For more information or assistance call: Small Business Assistance Program and Environment (303) 692-3175 or (303) 692-3148 Colorado Department of Public Health and Environment APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 61 AV rtrrsrn COLORADO of h:[Uc Ftaleh.a Envieavun.nl Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit a 1 All sections of this APEN and application must be completed for both new and existing facilities, including AA „O-) updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if,it is I\'•�t-0c filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will requiici-c.es,l payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options wilt not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 4V obAJE ag21 AIRS ID Number: I-2,3//vim)/6,03 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Namei: Extraction Oil & Gas, Inc. Site Name: Ice Man Production Facility Site Location: SWSE SEC 36 T7N R67W Mailing Address: (Include Zip Code) 370 17th Street Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Jon Torizzo Phone Number: (303) 396-6051 E -Mail Address2: air@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 4.14199 ®® COLORADO Nvahhb F1.v44onmml Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ❑✓ Request coverage under 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) 0 Change fuel or equipment 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership' 0 Other (describe below) OR - • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ID Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info E Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Truck loading when sales pipeline is down Company equipment Identification No. (optional): LOAD -001 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 05/16/2019 Will this equipment be operated in any NAAQS nonattainment area? p Yes • No Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • 1 Does this source load gasoline into transport vehicles? Yes No • p Is this source located at an oil and gas exploration and production site? Yes No SI ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • I2 Does this source splash fill less than 6750 bbl of condensate per year? Yes No • p Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ p Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 �/J�� :COLORADO 2 I �i�. , t r Huhn tr El,vira:lm -.1 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate 0 Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 97,950 bbl/year This product is loaded from tanks at this facility into: (e.g. "rail tank cars" or "tank trucks") Actual Volume Loaded: 81,625 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 6 ^ 4 F True Vapor Pressure: 7.17 Psia ® 60 `F Molecular weight of displaced vapors: 62 lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 ® COLORADO 3I ®Erattormat Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit .' and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.525993/-104.840448 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. F (° ) Flow Rate ACFM ( ) Velocity t/sec (f ) ECDs -20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑� Upward O Horizontal O Downward 0 Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular 0 Other (describe): 0 Upward with obstructing raincap Interior stack diameter (inches): TBD Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. 0 Loading occurs using a vapor balance system: Requested Control Efficiency: ❑ Combustion Device: Used for control of: VOC/HAPs Rating: TBD Type: 1 B15 ECt� Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: TBD F MMBtu/hr Make/Model: I ES 48" 95 >98 Waste Gas Heat Content: 2593 Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: TBD Btu/scf MMBtu/hr 0 Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 4 I m COLORADO fHealth kr Env .1 Permit Number: AIRS ID Number: [Leave blank unless .APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SO. NO. CO VOC ECDs 95 HAPs ECDs 95 Other: ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions tons/ ear (tons/year) J Controlled Emissions6 (tons/year) Uncontrolled Emissions tons/ ear (tons/year) ) Controlled Emissions (tons/year) tons/ ear ) PM SOx NOx 0.068 lb/MMBtu AP -42 0.02 0.02 0.02 0.02 CO 0.31 lb/MMBtu AP -42 0.09 0.09 0.10 0.10 VOC 0.266 lb/bbl AP -42 10.87 0.54 13.05 0.65 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions 6 (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.004 lb/bbl AP -42 329 16 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 COLORADO 5 1 AV ,d Nu111.8 Envuonmcnl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit 4' 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. Legally Sig Authorized Person (not a vendor or consultant) Date Signature Jon Torizzo Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance E✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 COLORADO 6 I AV �,:�aMer Nea�lVlh hFivlmnmenl C:CC:LCt-acv'1 t-ccr CLck ,3?C:f <( Gas Venting APEN - Form APCD-211---- Air Pollutant Emission Notice (APEN) and CIO t �r 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 rs filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: I9WI=oc-22 AIRS ID Number: !23 /44 'T /Ooy-, [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Mailing Address: (Include Zip Code) Extraction Oil & Gas, Inc. Ice Man Production Facility SWSE SEC 36 T7N R67W 370 17th Street, Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Jon Torizzo Phone Number: (303) 396-6051 E -Mail Address2: air@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 3/2019 414200 COLORADO 1 I A lo/ NnLLIh6E,vurovnml Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit ` and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info t Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Low Pressure ("LP") Separator Venting Emissions Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 05/16/2019 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Flours of Source Operation: TBD hours/day TBD days/week TBD weeks/year Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 3/2019 Yes Yes Yes ❑ No Q No ❑ No AV COLORADO 2 I mV HealthE Fr. Health EaroF't .1 Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information �✓ Gas/Liquid Separator ❑ Well Head Casing O Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes Gas Venting Process Parameters5: Juo,:koy EC:c':c,el Itl'2:c.;•1( . L LC.KCC 1 Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: -1844 BTU/SCF Requested: 19.22 MMSCF/year Actual: 16.02 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 35.55 VOC (Weight %) 61.05 Benzene (Weight %) 0.21 Toluene (Weight %) 0.31 Ethylbenzene (Weight %) 0.04 Xylene (Weight %) 0.17 n -Hexane (Weight %) 1.34 2,2,4-Trimethylpentane (Weight %) 0.0016 Additional Required Information: O Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. COLORADO 3 I A�' °`am t� HullM1bEnnln�unm„ Form APCD-211 - Gas Venting APEN - Revision 3/2019 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit /land AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.525993/-104.840448 Operator Stack ID No. Discharge, Height Above Ground Level (Feet) Temp. ` F> (°F) Flow Rate (ACFM) Velocity � (ft/sec) ECD -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: ❑✓ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECD MMBtu/hr Make/Model: Questor/Q5000 Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >99 % Minimum Temperature: TBD Waste Gas Heat Content: 1,814 Btu/scf Constant Pilot Light: El Yes ❑ No Pilot burner Rating: TBD MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 3/2019 COLORADO 4 I AV'` Haaf1TEF ,nfenm+ni Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOx NOx CO VOC ECDs 95 HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Basis Units (AP -42, Mfg., etc.) Emissions (tons/year) Emissions6 (tons/year) Emissions (tons/year) Emissions (tons/year) PM SOX NOx 0.068 Ib/MMBtu AP -42 --099 i ,C:3• 0:99- l.( •1-49-- ( 2- 17t9 ‘ ` CO 0.31 Ib/MMbtu AP -42 -4.51 4.Z- 4-51 Li. -5-4-1- 5. . ''21 -5:41- 5, VOC 57.185 lb/Mscf Eng. Est. 458.01 22.90 549.62 27.48 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 0.194 lb/Mscf Eng. Est 3,106 155 Toluene 108883 0.293 lb/Mscf Eng. Est 4,690 235 Ethylbenzene 100414 0.041 lb/Mscf Eng. Est 650 32 Xylene 1330207 0.158 lb/Mscf Eng. Est 2,527 126 n -Hexane 110543 1.254 lb/Mscf Eng. Est 20,081 1,004 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 3/2019 COLORADO 5 I Av M. _.ri i4atlh FEn I 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. g(It( [ Signatur f Legally Aut erson (not a vendor or consultant) Date orized P Jon Torizzo Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance Q✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 3/2019 i COLORADO 6 AV `FC _32119 Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs wilt be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: T).- / 1 < :' / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Extraction Oil & Gas, Inc. Ice Man Production Facility SWSE SEC 36 T7N R67W Mailing Address: Code) 370 17th Street, Suite 5300 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Jon Torizzo Phone Number: (303) 396-6051 E -Mail 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. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. COLORADO Form APCD-211 - Gas Venting APEN - Revision 3/2019 Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit. # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name3 ❑ Add point to existing permit O Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Low Pressure ("LP") Separator Venting Emissions Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 05/16/2019 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: TBD hours/day TBD days/week TBD weeks/year Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? ❑✓ Yes Yes Yes Form APCD-211 - Gas Venting APEN - Revision 3/2019 2 ❑ No No ❑ No COLORADO lle�+exansssut attie n.znna Enwro.s..li.n Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ 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? ❑ Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas i 9i 7 BTU/SCF Heating Value: Requested: 14.02 MMSCF/year Actual: 11.69 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 35.55 VOC (Weight %) 61.05 Benzene (Weight %) 0.21 Toluene (Weight %) 0.31 Ethylbenzene (Weight %) 0.04 Xylene (Weight %) 0.17 n -Hexane (Weight %) 1.34 2,2,4-Trimethylpentane (Weight %) 0.0016 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX It n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 3/2019 3I COLORADO D norc2:i x<:ana rnnm.,n Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Lang►tude or UTM) 40.525993/-104.840448 ECD -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) Upward 0 Horizontal O Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular 0 Other (describe): Interior stack diameter (inches): Upward with obstructing raincap 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. [� VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: Combustion Device: Pollutants Controlled: Rating: Type: VOC/HAPs TBD ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: TBD MMBtu/hr Make/Model: Questor/Q5000 95 >99 Waste Gas Heat Content: 1,917 Btu/scf Constant Pilot Light: 0 Yes O No Pilot burner Rating: TBD MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 3/2019 4 Ewsstrartsnil COLORADO Benzene PM PM Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit it 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 (9.5 reduction): Description of Control Method(s) Overall Requested Control Efficiency, (% reduction in emissions) SOX NO. CO VOC ECDs 95 HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Emission Factor Uncontrolled . Emissions (tonsl year) Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis' •,;:, lb/MMBtu Source (AP -42, Mfg., etc.) ontrolled Emissions6 (tons/year) Uncontrolled • Emissions (tons/year) Controlled Emissions (tons/year) SO. NO. 0.068 AP -42 0.78 0.78 0.94 0.94 CO 0.31 lb/MMbtu AP -42 3.55 3.55 4.26 4.26 VOC 57.185 lb/Mscf Eng. Est. 334.14 16.71 400.97 20.05 on -Criteria Reportable Pollutant Emissions Inventory Chemical Abstract Service (CAS) Number. Emission Factor Actual Annual Emissions =' Uncontrolled Basis Units Source (AP -42, Mfg., etc.) ,. Uncontrolled Emissions (pounds/year) Controlled Emissions6• (pourids/year)' 71432 0.194 lb/Mscf Eng. Est 2,266 113 Toluene 108883 0.293 lb/Mscf Eng. Est 3,422 171 Ethylbenzene 100414 0.041 lb/Mscf Eng. Est 474 24 Xylene 1330207 0.158 lb/Mscf Eng. Est 1,844 92 n -Hexane 110543 1.254 lb/Mscf Eng. Est 14,650 733 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 3/2019 cc LORADO 51 W . ne:nnt 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. 12/23/2019 Signature of Legally Authorized Person (not a vendor or consultant) Jon Torizzo Date Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance Ei Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 3/2019 s CQLQR.AD6 6 I n .m�,.es�r •:- `. xe:uns Pnwmnen.m Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit \ All sections of this APEN and application must be completed for both new and existing facilities, including APEN C updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it fib► filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will tequiC payment for a new filing fee. P `` 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.00v/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: 123 //107/7 /O0.r [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Ice Man Production Facility Site Location: SWSE SEC36 T7N R67W Mailing Address: (Include zip codes 370 17th Street Suite 5300 Site Location County: Weld NAICS or SIC Code: 211111 Denver, CO 80202 Contact Person: Jon Torizzo Phone Number: (303) 396-6051 E -Mail Address2: air@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 3/2019 414201 1 I AVW COLORADO V ...u= Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source - OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Venting Emissions Vapor Recovery Tower ("VRT") Separator Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 5/16/2019 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: TBD hours/day TBD days/week TBD weeks/year Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? ❑✓ Yes ❑ Yes ❑✓ Yes ❑ No ❑✓ No ❑ No Form APCD-211 - Gas Venting APEN - Revision 3/2019 2 I A COLORADO Depubaen,& vzau Wat.6 Envitonmeel Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] 1C\C f tt ) Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes Gas Venting Process Parameters5: as C- s i QC:ICLcCtt-,c, -- . iatt; ;-CC 1 l (zCy i l� Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: 29� BTU/SCF Requested: 3.29 MMSCF/year Actual: 2.74 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 48.78 VOC (Weight %) 87.18 Benzene (Weight %) 0.22 Toluene (Weight %) 0.15 Ethylbenzene (Weight %) 0.01 Xylene (Weight %) 0.04 n -Hexane (Weight %) 1.83 2,2,4-Trimethylpentane (Weight %) 0.001 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 3/2019 .COLORADO 3 I ,° Xo�llhb EnWon.nanl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.525993/-104.840448 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (°F) Flow Rate (ACFM) Velocity (ftlsec) ECD -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap TBD Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: ❑ Combustion Device: Pollutants Controlled: VOCMAPs Rating: TBD MMBtu/hr Make/Model: Questor/Q5000 Type: ECD Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >99 % 24 LS t',t5 Minimum Temperature: TBD Waste Gas Heat Content: -2505 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: TBD MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 -Gas Venting APEN - Revision 3/2019 COLORADO 4 jhitr�:ot •N°i(th b EminmwsleM l [?mac tttd (Pi to s_a 11,12.6 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit r and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC ECDs 95 HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOX NO. 0.068 lb/MMBtu AP -42 -0.233° `4 0.280c` 1 0:28&'. O.233 CO 0.31 Ib/MMBtu AP -42 x.063 1:063 1.276- 1.276 VOC 112.072 lb/Mscf Eng. Est. 153.398 7.670 184.078 9.204 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (Ap 42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 0.285 lb/Mscf Eng. Est. 780 39 Toluene 108883 0.197 lb/Mscf Eng. Est. 540 27 Ethylbenzene 100414 lb/Mscf Eng. Est. Xylene 1330207 lb/Mscf Eng. Est. n -Hexane 110543 2.349 lb/Mscf Eng. Est. 6,431 322 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 3/2019 5 I AV COLORADO n[otP Haatlh tr EnW nvnanl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit 1 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. Signature Legally Authorized Person (not a vendor or consultant) Jon Torizzo Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: �✓ Draft permit prior to issuance E✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 3/2019 COLORADO 6 I AV Health ft Hello