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Home My WebLink About20193771.tiffa COLORADO Department of Public Health b Environment Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 July 23, 2019 Dear Sir or Madam: RECEIVED JUL 262019 WELD COUNTY COMMISSIONERS On July 25, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - Rinn Valley 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: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director Pvbtic aview O /aCa(19 cc : PLCTP), £HCJT), OGCSM) Pw(ynn/£R/CH/CK) (jfl4/l9 2019-3771 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil a Gas, Inc. - Rinn Valley Production Facility - Weld County Notice Period Begins: July 25, 2019 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Extraction Oil Et Gas, Inc. Facility: Rinn Valley Production Facility Oil Et Natural Gas Production Et Processing NWSW Quadrant of Section 17, Township 2N, Range 68W - Weld County Weld County The proposed project or activity is as follows: Extraction Oil Et Gas, Inc. has drilled 19 new horizontal wells that serve the Rinn Valley Production Facility via buried flowline into 19 Vertical High/Low Pressure separator vessels. Through this permitting action, Extraction Oil Et Gas, Inc has requested to permit the emissions associated with the condensate storage tanks, the produced water storage tanks, condensate loadout and VRT/separator venting during compression unavailability. 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 Permits 19WE0256.CP1, 19WE0257.CP1, 19WE0258.CP1, 19WE0259.CP1 and 19WE0260.CP1 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: James Ricci Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 (COLORADO Department of Public Health 6 Environment Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: James Ricci 394748 3/15/2019 5/2/2019 Section 01 - Facility Information Company Name: Extraction Oil & Gas, Inc. County AIRS ID: 123 Quadrant Section Township Range NWSW 17 2N 68 Plant AIRS ID: Facility Name: Location: County: Type of Facility: What industry segment? A035 Rinn Valley Production Facility NWSW Quadrant of Section 17, Township 2N, Range 68W Weld County Exploration & Production Well Pad Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? I Section 02 - Emissions Units In Permit Application Carbon Monoxide (CO) Yes Particulate Matter (PM) J Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit tt Issuance ti Self Cert Required? Action Engineering Remarks 001 Condensate Tank - Yes 19WE0256.CP1 1 Yes Permit Initial Issuance 002 Produced Water Tank - Yes 19WE0257.CP1 1 Yes Permit Initial Issuance 003 Liquid Loading - Yes 19WE0258.CP1 1 Yes Permit Initial Issuance 004 Separator Venting Yes 19WE0259.CP1 1 Yes Permit Initial Issuance 005 Separator Venting - Yes 19WE0260.CP1 1 Yes Permit Initial Issuance 006 Natural Gas RICE NONROAD-001 Yes 19WE0261.XP1 1 No Cancellation 007 Diesel RICE NONROAD-002 No 19WE0267.XP1 1 No Cancellation Package 394898 Section 03 - Description of Project Extraction Oil & Gas, Inc. has drilled 19 new horizontal wells that serve the Rinn Valley Production Facility via buried flowline into 19 Vertical High/Low Pressure separator vessels. The date of first production was 12/15/2018. • The low pressure oil from the separators will flow to two Vapor Recovery Towers (VRT)where dissolved gas is flashed off. The oil from the VRTs discharge into the condensate storage tanks and the gas discharges to the sales line via dedicated VRU. The vapor from these tanks (working, breathing, andflash emissions) is routed to ECDs. • The low pressure water from the separators flows via below -ground dump line to a battery of two atmospheric water tanks. Vapors from the two water tanks are controlled via ECD. • The low pressure gas flows from the separator gas outlet and is then compressed into the sales gas line with dedicated compressors. There is a jumper line from the low pressure gas collection system to the enclosed combustors to combust gas when compression is not available. The VRT gas flows from the VRT gas outlet and is then compressed into the sales gas line with dedicated compressors. Under high-pressure situations, a jumper line from the VRT gas collection system may open to allow the excess gas to be combusted. The condensate tank liquid load out lines include a Lease Automated Custody Transfer (LACT) unit. Truck loading controls have been installed and vapors are routed into a dedicated vapor line. This line is a closed system with dedicated enclosed combustion devices to keep it separate from the tank battery vapor collection system. Two non -road classified engines supply the facility with electricity while grid power is being installed. Update: The two non -road engines were cancelled in May 2019 and removed from this facility before processing of these points was complete. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Yes Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? 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 SO2 NOx CO VOC J PM2.5 PM10 TSP HAPs 1 ❑ J Colorado Air Permitting Project Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No SO2 NOx CO VO PM2.5 PM10 TSP 1 I HAPs Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AIRs ID: 123 County A035 Plant 001 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Eight (8) 400 barrel fixed roof storage vessels used to store condensate Enclosed Combustor, Manufacturer Guaranteed Control Efficiency of 98% 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = 2,711,518 3,253,822 3,253,822 Secondary Emissions - Combustion Device(s) Heat content of waste gas= 2542 Volume of waste gas/bbl of liquid= 1.26 Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = PTE heat content of waste gas routed to combustion device = Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year Section 04 - Emissions Factors & Methodologies Will this tank emit flash emissions? Yes Btu/scf scf/bbl Actual Condensate Throughput While Emissions Controls Operating = 2,711,518 Requested Monthly Throughput = 276352 Barrels (bbl) per month 8,715 MMBTU per year 10,458 MMBTU per year 10,458 MMBTU per year Emission Factors Condensate Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Condensate Throughput) (Condensate Throughput) VOC 1.18E-01 5.88E-03 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Benzene 1.75E-04 8.75E-06 Toluene 1.93E-04 9.67E-06 Ethylbenzene 9.51E-06 4.76E-07 Xylene 8.82E-05 4.41E-06 n -Hexane 2.14E-03 1.07E-04 224 TMP 8.47E-06 4.23E-07 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 7.45E-03 2.39E-05 AP -42 Table 1.4-2 (PM1O/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 7.45E-03 2.39E-05 NOx 6.80E-02 2.19E-04 CO 3.10E-01 9.96E-04 Section 05 - Emissions Inventory Barrels (bbl) per year Flash 2521.12 BTU/scf 3.11821 MSCFD W&B 2549.8 BTU/scf 8.15338 MSCFD ProMax Throughput 8914.58 bbl/d Flash (lb/hr) 12.1924 0.0249937 0.0264688 0.0012337 0.01058025 0.22854 0.0009348 W&B (lb/hr) 31.4837246 0.0399948 0.0453407 0.00230016 0.02219853 0.565029 0.002211 Total (lb/bbl) 0.11758579 0.00017496 0.00019333 9.5139E-06 8.8248E-05 0.00213646 8.4692E-06 3253822 bbl/yr 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 191.3 159.4 8.0 191.3 9.6 1625 0.0 0.0 0.0 0.0 0.0 7 0.0 0.0 0.0 0.0 0.0 7 0.4 0.3 0.3 0.4 0.4 60 1.6 1.4 1.4 1.6 1.6 275 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 569 474 24 569 23 Toluene 629 524 26 629 31 Ethylbenzene 31 26 1 31 2 Xylene 287 239 12 287 14 n -Hexane 224 TMP 6952 5793 290 6952 348 28 23 1 28 1 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MALT HH (See regulatory applicability worksheet for detailed analysis) 3 of 23 C:\Users\ja ricci\Desktop\S\19 W E0256.C P1 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? 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. No NIA Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Pressurized Liquid Sample Used in ProMax Model: Sampled 2/4/19, Analyzed 2/5/19 Sample ID: East N-17-20-14N(N), Rinn Valley Taken at 48.1 psig (Probe) and 123 deg F (Probe) Sample input into ProMax 5.0 and modeled through a VRT before entering the atmospheric tanks. W&B Stencil used to estimate W& B losses. A 700 600 500 400 300 200 100 x- -200 0 200 400 600 80O Temperature 'F Process Stream t P O7f! Senor 0 % line 100%tine Critical Point R -Current Condition Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 001 Process # 01 SCC Code 4-04-003.11 Fixed Roof Tank, Condensate, working+breathing+flashing losses Uncontrolle d Emissions Pollutant Factor Control % Units PM10 0.00 0 Ib/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.01 0 Ib/1,000 gallons condensate throughput VOC 2.8 95 Ib/1,000 gallons condensate throughput CO 0.02 0 Ib/1,000 gallons condensate throughput Benzene 0.00 95 lb/1,000 gallons condensate throughput Toluene 0.00 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.00 95 lb/1,000 gallons condensate throughput n -Hexane 0.05 95 Ib/1,000 gallons condensate throughput 224 TMP 0.00 95 lb/1,000 gallons condensate throughput 4 of 23 C:\Users\jaricci\Desktop\S\19WE0256.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B • APEN and Permit R uirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Source requires a permit Yes No 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 Regulation 7, Section XII.C•F Yes Section XII.C.1 — General Requirements for Air Pollution Control Equipment — Prevention of Leakage Section XII.C.2 — Emission Estimation Procedures Section XII.D — Emissions Control Requirements Section XII.E — Monitoring Section XII F — Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? Storage Tank is not subject to Regulation 7, Section XII.G Yes Yes No Section XII.G1 - Emissions Control Requirements Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII.C.2 - Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions` of this storage tank equal to or greater than 6 tons per year VOC? Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? Storage tank is subject to Regulation 7, Section XVII.C.2 Yes No Yes Yes Yes Section XVII.C2 - 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 capacity greater than or equal to 75 cubic meters (m') ['472 BBLs]? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ["10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"' in 60.1116? 5. Does the storage vessel store a 'volatile organic liquid (VOL)"s as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa [-29.7 psi) and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m3 (`950 BBL) and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.1:ob(b))?; or c. The design capacity is greater than or equal to 75 M' (`472 BBL) but less than 151 m3 [-950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))? Storage Tank is not subject to NSPS Kb No NA NA NA NA NA Source Req Go to next Source Req Continue -' Continue -' Source is st Continue -' Storage Tar Source is sr Continue-' Go to then Go to then Source is st Source is sr Storage Tar Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 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 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? Storage Tank is not subject to NSPS 0000 NA NA NA Yes No No NA Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements 460.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel Is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even If potential VOC emissions drop below 6 tons per year] 40 CFR. Part 63, Subpart MACT HH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user; (63.760(a)(3))7 2. Is the tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of "storage vessel"' in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? NA Yes No NA NA NA Storage Tank is not subject to MAC? HH Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting RACT Review RACT review is required if Regulation 7 does not apply AND If the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing 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 Continue -' Storage Tar Storage Tar Continue - • Storage, 1 at Produced Water Storage Tank(s) Emissions Inventory 002 Produced Water Tank Facility AIRs ID: 123 County A035 002 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 Produced Water Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = 985,840 1,183,008 1,183,008 Secondary Emissions - Combustion Device(s) Heat content of waste gas = 822 Volume of waste gas/bbl of liquid= 0.8 Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = PTE heat content of waste gas routed to combustion device = Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year Section 04- Emissions Factors & Methodologies Will this tank emit flash emissions? Yes Btu/scf scf/bbl Two (2) 400 barrel fixed roof storage vessels used to store produced water Enclosed Combustor, Manufacturer Guaranteed Control Efficiency of 98% Actual Produced Water Throughput While Emissions Controls Operating = Requested Monthly Throughput = 100475 Barrels (bbl) per month From Flash Liberation Analysis From Flash Liberation Analysis 648 778 778 MMBTU per year MMBTU per year MMBTU per year Emission Factors Produced Water Tank Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (Ib/bbl) (Produced Water Throughput) (Produced Water Throughput) VOC 1.83E-02 9.13E-04 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Benzene 1.67E-03 8.33E-05 Toluene 1.18E-03 5.88E-05 Ethylbenzene 3.13E-05 1.56E-06 Xylene 2.80E-04 1.40E-05 n -Hexane 5.24E-04 2.62E-05 224 TMP 0.00E+00 0.00E+00 Pollutant Control Device Emission Factor Source Uncontrolled Uncontrolled (lb/MMBtu) (lb/bbl) (waste heat combusted) (Produced Water Throughput) PM10 7.45E-03 4.90E-06 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.S) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 133 Industrial Flares (CO) PM2.5 7.45E-03 4.90E-06 NOx 6.80E-02 4.47E-05 CO 3.10E-01 2.04E-04 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) VOC 10.8 9.0 0.4 10.8 0.5 92 PM10 0.0 0.0 0.0 0.0 0.0 0 PM2.S 0.0 0.0 0.0 0.0 0.0 0 NOx 0.0 0.0 0.0 0.0 0.0 4 CO 0.1 0.1 0.1 0.1 _ 0.1 20 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 1970 1642 82 1970 99 Toluene 1392 1160 58 1392 70 Ethylbenzene 37 31 2 37 2 Xylene 332 276 14 332 17 n -Hexane 619 516 26 619 31 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis 985,840 Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO (See regulatory applicability worksheet for detailed analysis) 6 of 23 C:\Users\jaricci\Desktop\S\19W E0256.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? If yes and if there are flash emissions, are the 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), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. ISM Yes 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 No Section 08 - Technical Analysis Notes Pressurized Liquid Sample Used Flash Liberation Analysis: Sampled 2/4/19, Analyzed 2/6/19 Sample ID: Rinn Valley Taken at 46 psig (Probe) and 129 deg F (Probe) i?5�7x��'T. f."Y�'V'4t,: ?4'!fF'iK 4�3�vt�li?'+5 �T; y. x> :'_^.Sr•:,�:tf`�l..ti{i ��. • .�d. x....r '.x �C! �L'.'..� i:.':M?Sv_•1Ft}'rv::_F'y'"�ca.i�a . -�J::�.{�z. 7"r ♦�.. O <"`... `h->._ ...::.] � IIY:..L'7.: �'i;27s?vfiN�ytl ' iSYr !��11 �(�X l�• �I,Y y ' i� RI4, tint( ' .7(14;4,1 y (�,1in .. . v. -. N +... � .. . ��a - �'C 'ill .: v •'r . /.. �. ..ii .1dA'S.. ,$1 C17.diiL' ;el 4vC9a`d:-:..Y.:cS..-'.u-S.:E. . r;.X-.• - ,t. .b,..c..,x:.. 'Kvx.tbi. <.�r,Y. .. ,ti .:C�4...K �'�"� a•:.�.�S�X'3d'.c!is�2l:u.lrtv.u}�'.:.i��.aeti�r.-.mix--tz-�>»3't�"`:%Mv�.t.k:.I�..�i:: The pressurized liquid sample was flashed from 46 psig and 129 deg F to 12.2 psia and 60 deg + F. Base conditions were assumed to be 14.65 psi and 60 deg F. Since GWR was reported as SCF, k•+'ft' it was w,x,t. q P P„,,...max. assumed that the GWR was already converted to standard conditions Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 002 Process # SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Pollutant PM10 PM2.5 NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP it iv' Y• Uncontrolled Emissions Factor 0.00 0.00 0.00 0.4 0.00 0.04 0.03 0.00 0.01 0.01 0.00 Control % 0 0 0 95 0 95 95 95 95 95 95 Units lb/1,000 gallons liquid throughput lb/1,000 gallons liquid throughput lb/1,000 gallons liquid throughput Ib/1,000 gallons liquid throughput lb/1,000 gallons liquid throughput Ib/1,000 gallons liquid throughput lb/1,000 gallons liquid throughput lb/1,000 gallons liquid throughput lb/1,000 gallons liquid throughput lb/1,000 gallons liquid throughput lb/1,000 gallons liquid throughput 7 of 23 C:\Users\jaricci\Desktop\S\19WE0256.CP1 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 Re ulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section I1.0.3)? You have indicated that source is in the Non -Attainment Area Yes 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 at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, 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.D.2)? No Yes 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 station3 or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC? • Yes Yes Yes Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. No Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. 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 August 23, 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? Yes No No NA Storage Tank is not subject to NSPS OOOO Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons 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 RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict betwee.i 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 sucn 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 Source Req Go to next Source Req Continue -' Continue - Go to the n Source is st Source is st Continue - Storage Tar Storage Tar EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW*Xx/C Ex = emissions of pollutant x Q= Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm MW 33.9569 Ib/Ib-mol bbl/year scf/bbl Throughput 1 Gas -to -Oil Ratio (GOR) 0.8 mass fraction (%) Emission Factor (lb/bbl) Emissions (lbs/year) Helium 0.00 0.000E+00 0.00 CO2 22.95 1.643E-02 0.02 N2 34.82 2.492E-02 0.02 H2S 0.00 0.000E+00 0.00 methane 6.16 1.412E-03 0.00 ethane 10.57 7.562E-03 0.01 propane 10.25 7.337E-03 0.01 isobutane 1.55 1.112E-03 0.00 n -butane 4.37 3.128E-03 0.00 isopentane 0.80 5.721E-04 0.00 n -pentane 0.93 6.635E-04 0.00 cyclopentane 0.22 1.595E-04 0.00 n -Hexane 0.73 5.2353E-04 0.00 cyclohexane 0.27 1.947E-04 0.00 Other hexanes 0.96 6.868E-04 0.00 heptanes 0.25 1.765E-04 0.00 methylcyclohexane 0.21 1.469E-04 0.00 224-TMP 0.00 0.000E+00 0.00 Benzene 2.33 1.66556E-03 0.00 Toluene 1.64 1.17675E-03 0.00 Ethylbenzene 0.04 3.128E-05 0.00 Xylenes 0.39 2.802E-04 0.00 C8 0.21 1.531E-04 0.00 C9 0.14 9.713E-05 0.00 C10 0.21 1.521E-04 0.00 C11+ 0.00 0.000E+00 0.00 Total VOC Wt % 100.00;% ,�� f% :.p 25.51 0.0183 0.000G1 n -Hexane 224-TMP Benzene Toluene Ethylbenzene Xylenes Total GOR Conversion Check Actual Pressure (P1) 1 psia Actual Temperature (T1) 1 Rankine Actual GOR (V1) 1 cf/bbl Standard Pressure (P7) 1 psia Standard Temperature (T7) 1 Rankine Standard GOR (V2) scf/bbl 87.52 8.754E+01 Hydrocarbon Loadout Emissions Inventory 003 Liquid Loading 'Facility AIRs ID: 123 County A035 Plant 003 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Loadout of condensate by submerged fill, into tank trucks Emission Control Device Enclosed Combustor, Manufacturer Guaranteed Control Efficiency of 98% Description: Is this loadout controlled? Yes Collection Efficiency: 100.0 Control Efficiency: 95 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 = 2,711,518 3,253,822 3,253,822 Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2549.8 Btu/scf Volume of waste gas emitted per year = 7292810 scf/year Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 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*S*P*M/T Actual Volume Loaded While Emissions Controls Operating = 2,711,518 Barrels (bbl) per year Requested Monthly Throughput = 276352 Barrels (bbl) per month Based on 19.9803 MSCFD from ProMax 15,496 MMBTU per year 18,595 MMBTU per year 18,595 MMBTU per year The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors. Factor Meaning Value Units Source S Saturation Factor 0.6 P True Vapor Pressure 9.797 psia ProMax Tank Loss Stencil M MW of Vapors 45.12 Ib/Ib-mol ProMax Tank Loss Stencil T Liquid Temperature 514.84 Rankine ProMax Tank Loss Stencil L Loading Losses 6.41970 lb/1000 gallons AP -42 Liquid Loss Equation L Loading Losses 0.269627 lb/bbl L (VOC) Loading Losses 0.207712 lb/bbl ProMax Tank Loss Stencil converted to standard conditions, VOC ONLY Component Emission (lb/hr) Emission Factor Units Source Benzene 0.098010 0.000264 lb/bbl ProMax Tank Loss Stencil Toluene 0.111110 0.000299 lb/bbl ProMax Tank Loss Stencil Ethylbenzene 0.005637 0.000015 lb/bbl ProMax Tank Loss Stencil Xylene 0.054399 0.000146 Ib/bbl ProMax Tank Loss Stencil n -Hexane 1.384640 0.003728 lb/bbl ProMax Tank Loss Stencil 224 TMP 0.005418 0.000015 lb/bbl ProMax Tank Loss Stencil Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled Emission Factor Source (lb/b131) (lb/bbl) (Volume Loaded) (Volume Loaded) VOC 2.08E-01 1.04E-02 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Benzene 2.64E-04 1.32E-05 Toluene 2.99E-04 1.50E -0S Ethylbenzene 1.52E-05 7.59E-07 Xylene 1.46E-04 7.32E-06 n -Hexane 3.73E-03 1.86E-04 224 TMP 1.46E 05 7.29E-07 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.0075 4.26E-05 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (SOx) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 4.26E-05 SOx 0.0006 3.36E-06 NOx 0.0680 3.89E-04 CO 0.3100 1.77E-03 1!Cot. C:\Users\jaricci\Desktop\S\19WE0256.CP1 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) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.1 0.1 0.1 0.1 0.1 12 0.1 0.1 0.1 0.1 0.1 12 0.0 0.0 0.0 0.0 0.0 1 0.6 0.5 0.5 0.6 0.6 107 337.9 281.6 14.1 337.9 16.9 2870 2.9 2.4 2.4 2.9 2.9 490 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 859 715 36 859 43 973 811 41 973 49 49 41 2 49 2 477 397 20 477 24 12129 10108 505 12129 606 47 40 2 47 2 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a The loadout must be operated with submerged fill to satisfy RACT. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion 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 The liquid loading stencil in ProMax was applied to the tank inlet stream. ProMax estimated the TVP, bulk loading temperatureand the molecular weight of the vapors. Using these values inputted into the AP -42 equat on, the total gas emission factor resulted in 0.269 lb/bbl. This is based on oil loadout temperature of 55.17 deg F. The ProMax model is based on a throughput of 8914.58 bbl/day, this is based on standard conditions. The liquid loading stencil estimated 98.99521b/hr emissions. Using this emission rate and the standard throughput, the total gas emission factor resulted in 0.266 lb/bbl. According to the applicant (who checked with ProMax support), this slight difference between the two values is due to standard vs actual conditions. . .Si4:�>Y'4,�_."?k?elvi'1'! r.�.�ra�S'i1Lwe`yS.4S�,j°e . Y -,- ::, ...- .,u ,..,: ... ,, v. ., ., .. ,f ef',a?'Ychu.:P�ic ProMax was able to spectate the loading losses into individual constituents and estimated a lb/hr emission rate of the respective components. The lb/hr emission rates estimated by the stencil were Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 003 Process # SCC Code 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.01 0 Ib/1,000 gallons transferred VOC 4.9 95 lb/1,000 gallons transferred CO 0.04 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.01 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 95 lb/1,000 gallons transferred n -Hexane 0.09 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 11 of 23 C:\Users\jaricci\Desktop\S\19WE0256.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Source requires a permit Yes. Yes: No No. Yes'' 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? No The loadout must be 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 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. Go to next Go to the n Go to next Go to next Go to next The loadou The loadou Separator Venting Emissions Inventory 004 Separator Venting Facility AIRs ID: 12.3 County A035 Plant 004 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Vapor Recovery Tower (VRT) Emission Control Device Description: Gas from the VRT is routed to a Questor Q5000 Enclosed Combustor when compression is unavailable Requested Overall VOC & HAP Control Efficiency %: 98 Limited Process Parameter Natural Gas Vented Gas meter Yes, meter is currently installed and operational Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: rif 7.2 9.0 i MMscf per year MMscf per year MMscf per year 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 Btu/scf scf/bbl Requested Monthly Throughput = 0.8 MMscf per month A sample of VRT Gas was taken on 2/4/2019 from the Rinn Valley Facility, Sample ID Rinn Valley. The sample was taken at 6psig and 74 deg F. The gas was analyzed on 2/5/2019 by Alliance who provided an extended gas analysis. The Weight % from this analysis can be found below. MW 47.959 lb/lb-mol Displacement Equation Ex = Q * MW * Xx / C Weight % Helium 0.09 CO2 0.47 N2 0.28 methane 1.64 ethane 10.45 propane 34.90 isobutane 9.50 n -butane 23.80 isopentane 6.34 n -pentane 6.71 cyclopentane 0.31 n -Hexane 1.40 cyclohexane 0.32 Other hexanes 2.51 heptanes 0.54 methylcyclohexane 0.21 224-TMP 0.00 Benzene 0.13 Toluene 0.07 Ethylbenzene 0.00 Xylenes 0.01 C8+ Heavies 0.29 Total 100.00 VOC Wt % 87.06 Emission Factors Separator Venting Emission Factor Source Uncontrolled Controlled Pollutant (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 110080.6 2201.6 Extended gas analysis Extended gas analysis : . ,v Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Benzene 1.70E+02 3.40E+00 Toluene 9.02E+01 1.80E+00 Ethylbenzene 1.90E+00 3.79E-02 Xylene 1.48E+01 2.96E-01 n -Hexane 1.78E+03 3.55E+01 224 TMP 5.06E-01 1.01E-02 Primary Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 20.5 AP -42 Table 1.4-2 (PM10/PM.2 5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (SOx) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 20.5 SOx 0.0006 1.6 NOx 0.0680 137.2 CO 0.3100 853.4 13 of 23 C:\Users\jaricci\Desktop\S\19WE0256.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 0.1 0.1 0.1 0.1 0.1 16 0.1 0.1 0.1 0.1 0.1 16 0.0 0.0 0.0 0.0 0.0 1 0.8 0.7 0.7 0.8 0.8 143 495.4 397.3 7.9 495.4 9.9 1683 CO 3.8 3.1 3.1 3.8 3.8 652 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 1532 1229 25 1532 31 Toluene 811 651 13 811 16 Ethylbenzene 17 14 0 17 0 Xylene 133 107 2 133 3 n -Hexane 15987 12824 256 15987 320 224 TMP 5 4 0 5 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? 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 Vet have indicated above that the rnnni•nrori rnrncc arameter is natural vat vented The fnhlnwino n.inctinnc an nnt ren,,iro an P P • ancwnr i 14 of 23 C:\Users\jaricci\Desktop\S\19WE0256.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes The VRT gas sample was used as the basis for calculating the emission fators. The point is serviced by a dedicated combustor. Because venting will only occur when compression is unavailable, it is expected there will be a constant flow of gas when venting occurs and little fluctuations that may cause a reduction in DRE. The gas meters have been installed and operational from the date of first production. Though emissions from this facility are below 80 tpy, the applicant has agreed to daily monitoring of these combustors since 98% DRE was requested. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point $t 004 Process P 01 SCC Code 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 20.51 0 lb/MMSCF PM2.5 20.51 0 Ib/MMSCF SOx 1.62 0 lb/MMSCF NOx 187.21 0 Ib/MMSCF VOC 110080.55 98 lb/MMSCF CO 853.44 0 lb/MMSCF Benzene 170.19 98 lb/MMSCF Toluene 90.15 98 lb/MMSCF Ethylbenzene 1.90 98 lb/MMSCF Xylene 14.79 98 lb/MMSCF n -Hexane 1776.36 98 Ib/MMSCF 224 IMP 0.51 98 lb/MMSCF 15 of 23 C:\Users\jaricci\Desktop\S\19WE0256.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Sectior II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes Yes Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes Source is subject to Regulation 7, Section XVII.B.2, G Section XVll.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? No The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e — Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend," 'may,"'should, " and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requiremerts in and of itself Source Req Source Req Source is si The contro Separator Venting Emissions Inventory 005 Separator Venting Facility AIRs ID: 123 County A035 Plant 004 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: unavailable Requested Overall VOC & HAP Control Efficiency %: Vertical High/Low Pressure Separators Low Pressure Gas from the Vertical High/Low Pressure Separators is routed to a Questor Q5000 Enclosed Combustor when compression is Limited Process Parameter Gas meter Yes, meter is currently installed and operational Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = 10.6 13.0 Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: MMscf per year MMscf per year MMscf per year 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 1982 Btu/scf scf/bbl 98 Requested Monthly Throughput = 1. t MMscf per month A sample a LP Gas was taken on 2/11/2019 from the Rinn Valley Facility, Sample ID East N17-20-11N(N). The sample was taken at 27psig and 76 deg F. The gas was analyzed on 2/12/2019 by Alliance who provided an extended gas analysis. The Weight % from this analysis can be found below. MW 34.628 Weight % Helium 0.01 CO2 2.25 N2 0.04 methane 15.13 ethane 22.41 propane 28.94 isobutane 5.82 n -butane 14.12 isopentane 3.66 n -pentane 4.03 cyclopentane 0.19 n -Hexane 0.85 cyclohexane 0.19 Other hexanes 1.47 heptanes 0.35 methylcyclohexane 0.14 224-TMP 0.00 Benzene 0.09 Toluene 0.05 Ethylbenzene 0.00 Xylenes 0.01 C8+ Heavies 0.25 Total 1Gv.uu VOC Wt % 60.162 Ib/Ib-mol Displacement Equation Ex=Q*MW*Xx/C Emission Factors Separator Venting Pollutant Uncontrolled Controlled Emission Factor Source (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 54925.1 1098.5 Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Benzene 8.29E+01 1.66E+00 Toluene 5.00E+01 1.00E+00 Ethylbenzene 1.46E+00 2.92E-02 Xylene 1.06E+01 2.12E-01 n -Hexane 7.75E+02 1.55E+01 224 TMP 2.74E-01 5.48E-03 Primary Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 14.8 AP -42 Table 1.4-2 (PM10/'M.2.5) AP -42 Table 1.4-2 (PM10/'M.2 5) AP -42 Table 1.4-2 (SOx) AP -42 Chapter 13.5 industrial Flares (N0x) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 14.8 SOx 0.0006 1.2 NOx 0.0680 134.8 CO 0.3100 614.5 17 of 23 C:\Users\ja ricci\Desktop\S\19W E0256.CP1 Separator Venting Emissions Inventory Section OS - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 0.1 0.1 0.1 0.1 0.1 16 PM2.5 0.1 0.1 0.1 0.1 0.1 16 SOx 0.0 0.0 0.0 0.0 0.0 1 NOx 0.9 0.7 0.7 0.9 0.9 149 VOC 357.0 290.8 5.8 357.0 7.1 1213 CO 4.0 3.3 3.3 4.0 4.0 679 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 1078 878 18 1078 22 Toluene 650 530 11 650 13 Ethylbenzene 19 15 0 19 0 Xylene 138 112 2 138 3 n -Hexane 10077 8209 164 10077 202 224 TM P 4 3 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 XVII.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) 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 im 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. az.< - •mac` x -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 You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer. 18 of 23 C:\Users\jaricci\Desktop\S\19WE0256.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes The low pressure gas sample was used as the basis for calculating the emission fators. There is no case that high pressure gas could be vented at the facility. The facility would have to shut in in the case that the sales line were unavailable. The point is serviced by a dedicated combustor. Because venting will only occur when compression is unavailable, it is expected there will be a constant flow of gas when venting occurs and little fluctuations that may cause a reduction in DRE. The gas meters have been installed and operational from the date of first production. Though emissions from this facility are below 80 tpy, the applicant has agreed to daily monitoring of these combustors since 98% DRE was requested. "�tF`sQd'w;r4 1� .��i�! 1iK.\t',rt n't�d' F5�jf 'mQ�iiSiSc;i(drit'3e^F' r[L� Sii;!.w�K'I'el�'4�F i�fFrr f ��• U ..4 zj l �'• N��' "its l�k nr74 w!i ��yiy _ti .+ 0; '`.(.% v Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 004 Process # SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 14.77 0 Ib/MMSCF PM2.5 14.77 0 lb/MMSCF SOx 1.17 0 Ib/MMSCF NOx 134.80 0 Ib/MMSCF VOC 54925.07 98 lb/MMSCF CO 614.53 0 lb/MMSCF Benzene 82.89 98 lb/MMSCF Toluene 50.03 98 lb/MMSCF Ethylbenzene 1.46 98 Ib/MMSCF Xylene 10.59 98 lb/MMSCF n -Hexane 775.17 98 lb/MMSCF 224 TMP 0.27 98 lb/MMSCF 19 of 23 C:\Users\jaricci\Desktop\S\19WE0256.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes Yes Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes;. Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e — Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Source Req Source Req Source is st The control RICE Emissions Inventory Section 01 - Adminstrative Information Facility AIRs ID: 123 9ACB County Plant 009 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: (1) Waukesha 15794GSI (SN: 5283703114) 1380hp at 1200RPM 45RB TA Spark Ignition Natural Gas Engine used for Primary/Peaking Power GE Supplied 3 -way catalyst rated at 0.5 g/hp-hr of Nox + air/fuel rM Requested Control Efficiency (%) NOX 94.81% VOC 0.00% CO 85.71% HCHO 98.79% Eng Manufacture Date: ine Information 10/1/201' Wauk Manufacturer: Model Number: Ir Serial Number: Engine Function Pricy* Derating <9 r ltrol 1380 ..d for calcuations: 1380 %Load from GE Spec Sheet `r 100% Load (btu/hp-hr): 8860 ;JI, 100% Load, HHV from GE Saec Sheet .rd BSCF @ 100% load (btu/hp-hr): 8860 Other Parameters En .. ape ¢5RB Aspiration i rurbotbarged Electrical Generator Max Site Rating (kw) 0 Requested Hours of Operation 8760 PTE Hours of Operation 8760 Actual Hours of Operation 8760 Section 03 - Processing Rate Information for Emissions Estimates Fuel Use Rate @ 100% Load 11987.0E scf/hr Actual Annual Fuel Consumption 105.007 MMscf/yr Requested Annual Fuel Consumption 105.007 MMscf/yr Requested Fuel Heating Value 1020 btu/scf Actual Fuel Heating Value 1020 btu/scf Section 04 - Emissions Factors & Methodologies Emission Factors Pollutant Uncontrolled SI RICE Engine Units (Natural Gas Consumption) Controlled Ur" NOx CO VOC 13.500 g/hp-hr 10.500 g/hp-hr (Natural Gas Cone 0.700 g/hp-hr PM" 1.941E-02 lb/MMBTU PMI0 SO2 Formaldehyde 1.941E-02 5.880E-04 2.050E-02 Acetaldehyde Acrolein !.790E-03 2.630E-03 Methanol 3.060E -Q?' 1.5fe Benzene Toluene Ethylbenzene Xylene n -Hexane 2,2,4-TMj, 1,3 -Butadiene Section OS - Emissions Jr, lb/MMBTU Ib/MMBT' lb/M' .,v1B .o/MMB .c1 TU , TU lc -04 a ,t�TU c -1ntrolled ., Controlled Source GE Spec Sheet, Engine Out GE Spec Sheet, Engine Out ,ec Sheet + Buffer, Engine Out .2-3: 4 -Stroke Rich -Bum Engines .ale 3.2-3: 4 -Stroke Rich -Burn Engines Table 3.2-3: 4 -Stroke. Rich -Burn Engines Table 3.2-3: 4 -Stroke Rich -Burn Engines Table 3.2-3: 4 -Stroke Rich -Burn Engines / A(MMBTU I b/MMBTU Table 3.2-3: 4 -Stroke Rich -Burn Engines Table 3.2-3: 4 -Stroke Rich -Burn Engines Ib/MMBTU Table 3.2-3: 4 -Stroke Rich -Burn Engines lb/MMBTU Table 3.2-3: 4 -Stroke Rich -Burn Engines /_:480E -0S Ib/MMBTU Table 3.2-3: 4 -Stroke Rich -Burn Engines 1.950E-04 0.000E+00 0.000E+00 6.630E-04 Ib/MMBTU Table 3.2-3: 4 -Stroke Rich -Bum Engines lb/MMBTU lb/MMBTU Table 3.2-3: 4 -Stroke Rich -Bum Engines Table 3.2-3: 4 -Stroke Rich -Burn Engines lb/MMBTU Table 3.2-3: 4 -Stroke Rich -Burn Engines Criteria Pollutants Pot, 'rialto Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) NOx CO VOC PM2s PM10 SO2 179.9 179.9 9.3 179.90 9.33 139.9 139.9 20.0 139.92 19.99 9.3 9.3 9.3 9.33 9.33 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 0.0 0.0 0.0 0.0 0.v Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled Ps/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Formaldehyde Acetaldehyde Acrolein 2196 2196 27 2196 27 299 299 299 299 299 282 282 282 282 282 Methanol 328 328 328 328 328 Benzene 169 169 169 169 169 Toluene 60 60 60 60 60 Ethylbenzene 3 3 3 3 3 Xylene 21 21 21 21 21 n -Hexane 0 0 0 0 0 2,2,4-TMP 0 0 0 0 0 1,3 -Butadiene 11 71 71 71 19WE0256.CP1 COLORADO Air Pollution Control Division Department of Public Heath & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0256 Extraction Oil Ft Gas, Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Rinn Valley Production Facility 123/A035 NWSW Quadrant of Section 17, Township 2N, Range 68W Weld County Well Production Facility Equipment or activity subject to this permit: AIRS Point Equipment Description Emissions Control Description 001 Eight (8) 400, barrel fixed roof storage vessels used to store condensate Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to 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 shall 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 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 compliance as required by this permit may be obtained online at www.colorado.Rov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall 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 shall 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 shall 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 shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: AIRS Tons per Year Emission Point VOC CO Type 001 9.6 1.6 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) AIRS Point Control Device Pollutants Controlled 001 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4) Process Limits AIRS Point Process Parameter Annual Limit 001 Condensate Throughput 3,253,822 barrels Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and Page 3 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 • 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) 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 shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall 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 shall 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 shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the Ot'tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. The owner or operator shall 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 Page 4 of 10 COLORADO Air Pollution Control Division Department of Pubirc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) 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) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOn) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions - tons per year Facility Equipment ID AIRS Point Equipment Description Pollutant Current Threshold Permit Limit 19WE0256.CP1 001 Condensate Tank 9.6 19WE0257.CP1 002 Produced Water Tank 0.5 VOC 100 tpy (NANSR) 19WE0258.CP1 003 Liquid Loading 16.9 19WE0259.CP1 004 Separator Venting 9.9 19WE0260.CP1 005 Separator Venting 7.1 GENERAL TERMS AND CONDITIONS 22. 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. 23. 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. 24. 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. 25. 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. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express 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 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. 27. 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. 28. 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. DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. for condensate storage at a synthetic minor facility in the non -attainment area. Page 7 of 10 COLORADO Air Pollution Control Division Department of Public Health Et 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 shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working ''day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https:/ /www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 569 28 Toluene 108883 629 31 Ethylbenzene 100414 31 2 Xylenes 1330207 287 14 n -Hexane 110543 6952 348 2,2,4-Trimethylpentane 540841 28 1 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 Fubhc Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 2.19 x 10"4 AP -42 Chapter 13.5 CO 9.96 x 10-4 VOC 1.18 x 10.1 5.88 x 10-3 ProMax 5.0 with a site specific liquid pressurized put sample input 71432 Benzene 1.75 x 10-4 8.75 x 10.6 108883 Toluene 1.93 x 10"4 9.67 x 10.6 100414 Ethylbenzene 9.51 x 10.6 4.76 x 10-' 1330207 Xylene 8.82 x 10"5 4.41 x 10-6 110543 n -Hexane 2.14 x 10"3 1.07 x 10-4 540841 2,2,4-Trimethylpentane 8.47 x 10-6 4.23 x 10"' 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 shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Total HAP PSD True Minor Source NANSR Synthetic Minor Source of: VOC MACT HH Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http: //ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Heath & Environment Dedicated to protecting and improving the health and environment of the people of Colorado NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0257 Date issued: )OC Issued to: Issuance: Extraction Oil a Gas, Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: 1 Rinn Valley Production Facility 123/A035 NWSW Quadrant of Section 17, Township 2N, Range 68W Weld County Well Production Facility Equipment or activity subject to this permit: AIRS Point Equipment Description Emissions Control Description 002 Two (2) 400 barrel fixed roof storage vessels used to store produced water Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C. R. S. 25-7-101 et seq), to 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 shall 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 10 COLORADO Air Pollution Control Division Department of Public Heath & 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 shall 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 shall 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 shall 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 shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.` Annual Limits. AIRS Point ' VOC (tons per year) Emission Type 002 0.5 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) AIRS Point Control Device Pollutants Controlled 002 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits AIRS Point 002 Process Parameter Produced Water Throughput Annual Limit 183,008 barrels Compliance with the annual throughput imits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. 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 shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means Page 3 of 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 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. 13. 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 shall 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 shall 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. 14. 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 15. Upon startup of these points, theowner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 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 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Heath Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of V0C or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions - tons per year Facility Equipment ID AIRS Point Equipment Description Pollutant Current Threshold Permit Limit 19WE0256.CP1 001 Condensate Tank 9.6 19WE0257.CP1 002 Produced Water Tank 0.5 VOC 100 tpy (NANSR) 19WE0258.CP1 003 Liquid Loading 16.9 19WE0259.CP1 004 Separator Venting 9.9 19WE0260.CP1 005 Separator Venting 7.1 GENERAL TERMS AND CONDITIONS 22. 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 23. 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. 24. 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. 25. 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. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express Page 6 of 10 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 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. 27. 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. 28. 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. : DRAFT James Ricci Permit Engineer Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. for produced water storage at a synthetic minor facility in the non -attainment area. 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 shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in, this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set, forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Benzene 71432 1970 99 002 Toluene 108883 1392 70 Ethylbenzene 100414 37 2 Xylenes 1330207 332 17 n -Hexane 110543 619 31 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/bbl Controlled Emission Factors lb/bbl Source NOx 4.47 x 10"5 AP -42 Chapter 13.5 CO 2.04 x 10-4 VOC 1.83x10-2 9.13x10"4 Flash Liberation of a site specific 71432 Benzene 1.67 x 10-3 8.33 x 10-5 108883 Toluene 1.18 x 10-3 5.88 x 10-5 100414 Ethylbenzene 3.13 x 10-5 ` 1.56 x 10-6 pressurized liquid sample 1330207 Xylene 2.80 x 10"4 1.40 x 10-5 110543 n -Hexane 5.24 x 10"4 2.62 x 10-5 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 shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Total HAP PSD True Minor Source NANSR Synthetic Minor Source of: VOC MACT HH Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMMA MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0258 Extraction Oil &t Gas, Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Rinn Valley Production Facility 123/A035 NWSW Quadrant of Section 17, Township 2N, Range 68W Weld County Well Production Facility Equipment or activity subject to this permit: AIRS Point Equipment Description Emissions Control Description 003 Truck loadout of condensate by submerged fill into tank trucks Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution, Prevention and Control Act (C.R.S. 25-7-101 et seq), to 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 shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall 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 shall not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: AIRS Point Tons per Year _ Emission Type VOC CO 003 16.9 2.9 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits for criteria pollutants OR for both criteria and hazardous air pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 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 emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 10 COLORADO Air Pollution Control Division Department of Pubiac Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado AIRS Point Control Device Pollutants Controlled 003 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits AIRS Point Process Parameter Annual Limit 003 . Condensate Loaded 3,253,822 barrels The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall 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.) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill and emissions shall be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) 12. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 13. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): 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 a. The owner or operator shall 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 shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall 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. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall 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. 14. For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOGs to the atmosphere including, but not limited to, (Reference: Regulation 3, Part B, 11I.D.2): Install and operate the vapor collection andreturn equipment to collect vapors during loading of tank compartments of outbound transport trucks. Include devices to prevent the release of vapor from vapor recovery hoses not in use. 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 & MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M 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 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 10 COLORADO Air Pollution Control Division Department of Pubic Heath 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (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. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Page 5 of 10 COLORADO Air Pollution Control Division Dena tment of Public Health & Eneironment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions - tons per year Facility Equipment ID AIRS Point Equipment Description Pollutant Current Threshold Permit Limit 19WE0256.CP1 001 Condensate Tank 9.6 19WE0257.CP1 002 Produced Water Tank 0.5 VOC 100 tpy (NANSR) 19WE0258.CP1 003 Liquid Loading 16.9 19WE0259.CP1 004 Separator Venting 9.9 19WE0260.CP1 005 Separator Venting 7.1 GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and 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 regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. DRAFT James Ricci Permit Engineer Permit History Date Issuance Description This Issuance Issued to Extraction Oil &t Gas, Inc. for condensate loadout at a synthetic minor facility in the non -attainment area. 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 shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable airpollutants 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 859 43 003 Toluene 108883 973 49 Ethylbenzene 100414 49 2 Xylenes 1330207 477 24 n -Hexane 110543 12129 606 2,2,4-Trimethylpentane 540841 47 2 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: Point 003: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 3.89 x 10-4 AP -42 Chapter 13.5 CO 1.77 x 10-3 VOC 2.08 x 10-' 1.04 x 10-2 ProMax 5.0 Liquid Loading Stencil run on the tank oulet with a site specific Cow pressure liquid sample input 71432 Benzene 2.64 x 10-4 1.32 x 10"5 108883 Toluene 2.99 x 10"4 1.50 x 10-5 100414 Ethylbenzene 1.52 x 10"5 7.59 x 10-' 1330207 Xylene 1.46 x 10'4 7.32 x 10-6 ' 110543 n -Hexane 3.73 x 10'3 1.86 x 10;4 540841 2,2,4-Trimethylpentane 1.46 x 10" 5 7.29 x 10- , The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2 Equation 1 (version 1/95) using the following values and an ProMax calculated loadout vapor stream containing 77.94% VOC: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 9.797 psia M (vapor molecular weight) = 45.12 lb/lb-mol T (temperature of liquid loaded) = 514.84 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were estimated using the ProMax liquid loading stencil. 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 shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Total HAP Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado PSD True Minor Source NANSR Synthetic Minor Source of: VOC MACT HH Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http: //ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 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: 19WE0259 Issuance: 1 Date issued: )0( Issued to: Extraction Oil Et Gas, Inc. Facility Name: Rinn Valley Production Facility Plant AIRS ID: 123/A035 Physical Location: NWSW Quadrant of Section 17, Township 2N, Range 68W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit. AIRS Point Equipment Description Emissions Control Description 004 Two (2) Vapor Recovery Towers Questor Q5000 Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - certify compliance as required by this permit may be obtained online at Page 1 of 11 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. 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: AIRS Point Tons per Year VOC CO Emission Type 004 9.9 3.8 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 Page 2 of 11 COLORADO Air Pollution Control Division Department of Public Heath & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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.) AIRS Point Control Device Pollutants Controlled 004 Gas from the VRTs is routed to a dedicated Questor Q5000 Enclosed Combustor during compression unavailability. VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or, operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits AIRS Point Process Parameter Annual Limit 004 Natural Gas Venting 9.0 MMSCF Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. Page 3 of 11 COLORADO Air Pollution Control Division Department of Public Heath & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.) I. E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto igniter upon installation of the combustion device; All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING a MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) Page 4 of 11 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) 17. A source initial compliance test must be conducted to measure the emission rate for volatile organic compounds (VOC) in order to demonstrate compliance with a minimum destruction efficiency of 98% for VOCs. The test must determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which must be used to determine the destruction efficiency during the test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test must be conducted without prior approval from the Division. (Regulation Number 3, Part B., Section III.G.3) Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or Page 5 of 11 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 For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or No later than 30. days before the existing APEN expires. 20. The ` requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Facility Equipment ID AIRS Point Equipment Description Emissions - tons per year Pollutant Threshold Current Permit Limit 19WE0256.CP1 001 Condensate Tank 19WE0257.CP1 002 Produced Water Tank 19WE0258.CP1 003 Liquid Loading 19WE0259.CP1 004 Separator Venting 19WE0260.CP1 005 Separator Venting VOC 100 tpy (NANSR) 9.6 0.5 16.9 9.9 7.1 GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. Page 6 of 11 COLORADO Air Pollution Control Division Department of Public Heath Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operators 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 an 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. Page 7 of 11 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado By: DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. for venting gas from the VRTs during compression unavailability at a synthetic minor facility in the non -attainment area. Page 8 of 11 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 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. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 004 Benzene 71432 1532 31 Toluene 108883 811 16 Ethylbenzene 100414 17 0 Xylenes 1330207 133 3 n -Hexane 110543 15987 320 2,2,4-Trimethylpentane 540841 5 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 9 of 11 COLORADO Air Pollution Control Division Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Controlled Emission Factors lb/MMscf Source NOx 187.2 AP -42 Chapter 13.5 CO 853.4 VOC 110080.6 2201.6 Site Specific VRT Gas Sample 71432 Benzene 1.70 x 102 3.40 x 10° 108883 Toluene 9.02 x 101 1.80 x 10° 100414 Ethylbenzene 1.90 x 10° 3.79 x 10-2 1330207 Xylene 1.48 x 101 2.96 x 10-1 110543 n -Hexane 1.78 x 103 3.55 x 101 540841 2,2,4-Trimethylpentane 5.06 x 10-1 1.01 x 10;2 Note: The controlled emissions factors for this point are based on a control efficiency of 98%. The emission factors listed above are based on modeled separator separator pressure of 6 psig. temperature of 74 °F and 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 3O days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Total HAP PSD True Minor Source NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU Page 10 of 11 COLORADO Air Pollution Control Division Department of Pubtc Heaith & Environment Dedicated to protecting and improving the health and environment of the people of Colorado NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 11 of 11 COLORADO Air Pollution Control Division Department of Public Heath & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0260 Date issued: Issued to: Issuance: 1 )a Extraction Oil a Gas, Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: Rinn Valley Production Facility 123/A035 NWSW Quadrant of Section 17, Township 2N, Range 68W Weld County Well Production Facility Equipment or activity subject to this permit: Emissions Control Description AIRS Point Equipment Description 005 Nineteen (19) Vertical High/Low Pressure Separators Questor Q5000 Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act;(C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - certify compliance as required by this permit may be obtained online at Page 1 of 11 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 www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification,' with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. 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: AIRS Point Tons per Year VOC CO Emission Type 005 7.1 4.0 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 Page 2 of 11 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 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 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.) AIRS Point Control Device Pollutants Controlled Low-pressure gas from the vertical high/low pressure separators is routed to a dedicated Questor Q5000 Enclosed Combustor during compression unavailability. PROCESS LIMITATIONS AND 9. This source must be limitedto 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 AIRS Point Process Parameter Annual Limit 005 Natural Gas Venting 13.0 MMSCF Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. Page 3 of 11 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 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) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING &t MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) Page 4 of 11 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 16. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) 17. A source initial compliance test must be conducted to measure the emission rate for volatile organic compounds (VOC) in order to demonstrate compliance with a minimum destruction efficiency of 98% for VOCs. The test must determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which must be used to determine the destruction efficiency during the test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test must be conducted without prior approval from the Division. (Regulation Number 3, Part B., Section III.G.3) 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 (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or Page 5 of 11 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or No later than 30 days before the existing APEN expires. 20. The requirements of Colorado Regulation No. 3� Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established `after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation. (Reference: Regulation Number 3, Part D, V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed thefollowing threshold levels: Facility Equipment ID AIRS Point Equipment Description Emissions - tonsliper year Pollutant Threshold Current Permit Limit 19WE0256.CP1 001 Condensate Tank VOC 100 tpy (NANSR) 9.6 19WE0257.CP1 002 Produced Water Tank 0.5 19WE0258.CP1 003 Liquid Loading 16.9 19WE0259.CP1 004 Separator Venting 9.9 19WE0260.CP1 005 Separator Venting 7.1 GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. Page 6 of 11 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 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid, only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and' is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. Page 7 of 11 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 By: DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. for venting low-pressure gas from the vertical high/low pressure separators during compression unavailability at a synthetic minor facility in the non -attainment area. Page 8 of 11 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the, criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (lb/yr) 005 Benzene' 71432 1078 22 Toluene 108883 650 13 Ethylbenzene 100414 19 0 Xylenes 1330207 138 3 n -Hexane 110543 10077 202 2,2,4-Trimethylpentane 540841 4 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 9 of 11 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 134.8 AP -42 Chapter 13.5 CO 614.5 VOC 54925.1 1098.5 Site Specific LP Gas Sample 71432 Benzene 8.29 x 101 1.66 x 10° 108883 Toluene 5.00 x 101 1.00 x 10° 100414 Ethylbenzene 1.46 x 10° 2.92 x 10-2 1330207 Xylene 1.06 x 10' 2.12 x 10-' 110543 n -Hexane 7.75 x 102 1.55 x 101 540841 2,2,4-Trimethylpentane 2.74 x 10-' 5.48 x 10"3 Note: The controlled emissions factors for this point are based on a control efficiency of 98%. The emission factors listed above are based on modeled separator temperature of 76°F and separator pressure of 27 psig. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-yearterm 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 aclity is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Total HAP PSD True Minor Source NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU Page 10 of 11 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 11 of 11 Rinn Valley Condensate Tank APB` N,, MAR 1 51019 Condensate Storage Tank(s) APENS Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condenSate associated with oil and gas industry operations. If your emission source does not fall into this category, theire 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: 1 9 IVE 02-54, AIRS ID Number: (23 /4035 / ®®1 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Site Name: Extraction Oil & Gas, Inc. Rinn Valley Production Facility Site Location: NWSW Sec17 T2N R68W Mailing Addrede) 370 17th St. Suite 5300 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Catie Nelson 720-354-4579 cnelson@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. 39474I. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 1 I otoaADC* Rinn Valley Condensate Tank APEN 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 ❑ GP01 0 GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - 12 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: Please issue individual permit for Condensate Tanks. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: if Storage of Condensate at E&P Facility. For new or reconstructed sources, the projected start-up date is: 12/15/2018 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: ✓❑ Exploration Et Production (EEtP) site 0 Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? O Yes • No Are Flash Emissions anticipated from these storage tanks? • Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? SI Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: .00023 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 U • Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No O I Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 21 COLORADO. Rinn Valley Condensate Tank APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 4 - Storage Tank(s) Information nnua Condensate 2,711,517.98 3,253,821.58 From what year is the actual annual amount? Projected Average API gravity of sales oil: 50.8 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof RVP of sales oil: 12.9 ❑ External floating roof Stara l'ani� li3 X01 Lt dMa a lcitora a f mo Vessels t # tr�age< Tanker taiatone of orage Tan � nstallation :Date. of Mos �� cent Storage Vesse n �� -,P„ Date o� rst rod coon 137011 137Onhyea N/A ._.��ibtotageat° 8 x 400 bbls 3200 Before 12/2018 12/2018 i elks Serviced by its Storage Tank or Tan1 Battery EE P Site C3�ai ... Relzorted e l API Numbe et. 1Ne _, �.a -Newly See Attached ■ ■ ■ - ■ ■ 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 40.137738, -105.035532 y c . erato�Stack��` Q -Y Ill tFlYla siA4�2 - -�„'�m2' Flo Rate�� 3/eloci �,"`_ Se N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) Upward ❑ Horizontal ❑ Downward ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑� Circular Interior stack diameter (inches): Unknown ❑ Square/rectangle Interior stack width (inches): ❑ Other (descrte): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 3 I Masa Rinn Valley Condensate Tank APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: ECD Make/Model: Requested Control Efficiency: 95% Manufacturer Guaranteed Control Efficiency: 98% Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 2541.9 Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: HLP separator, Vapor Recovery Tower Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 troreamsami Rinn Valley Condensate Tank APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS I0] 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 eduction): ,Po _tam ,� ay,�.. clop izrot�rol ad; �� -``� 'a _ '� ,...: �z— , _� .� Aii cae c� r�I tIIJSAl4l5 VOC ECD 95% NOx CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected � , 4,44 ��i ertaolul ��Emisslo actor' � � ar E'missnns„�r ctua nnual E issio � � .,:Emission � �� Limits :. � cont{p Basis -it Source U controlle (guns Contrd7 �Uncontrolled on gr � ins ra! _ o le d z°? VOC 0.1176 °✓ lb/bbl site Specific sampling 159.437 / 7.972 / 191.325 / 9.566 ✓ NOx CO 0.31 Ib/MMBtu AP -42 Chapter 13.5 1.351 1.351 1.621 1.621 �-44 l'�C�ssTiv o s lnnlEts �A Et ofE fission fie ica a C° _ it ourcUncontrolled e c m scion PtiuS ea £t fled ''0 ah ounds__yea : Benzene 71432 0.0001750 , lb/bbl sitespedficsampiing 474.516 / 23.726 ✓ Toluene 108883 0.000193 / lb/bbl Site Specific Sampling 524.136 / 26.207 ✓ Ethylbenzene 100414 Xylene 1330207 0.00008.82 ✓ Ib/bbl sitespe<ifics.mpling 239.156 ✓ 11.958 / n -Hexane 110543 0.002136 ✓ lb/bbl SkeSpecificSampling 5,791.802 ✓ 289.590 ✓ 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 7/2018 5 I COLORADO} MeirlimmtWftilft, Rinn Valley Condensate Tank APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit 11 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. 1}-k( 3(i -2-t/ (cl Signature of Legally Authorized Person (not a vendor or consultant) Date Catie Nelson Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance ✓❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.Rov/cdphe/apcd CO-CORkDOI Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form1 Company Name: Extraction Oil & Gas, Inc. Source Name: Rinn Valley Condensate Tanks Emissions Source AIRS ID2: i 2?' /43 5/ OCR Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 47317 RINN VALLEY EAST 17N -20-01C /1 05 - 123 - 47316 RINN VALLEY EAST 17N -20-02N /1 05 - 123 - 47318 RINN VALLEY EAST 17N -20-03N 4 05 - 123 - 47315 RINN VALLEY EAST 17N -20-04C ., // 05 - 123 - 47313 RINN VALLEY EAST 17N -20-05N - /1 05 - 123 - 47319 RINN VALLEY EAST 17N -20-06N - /1 05 - 123 - 47320 RINN VALLEY EAST 17N -20-07C - ►1 05 - 123 - 47314 RINN VALLEY EAST 17N -20-08N - - _ �I 05 - 123 - 47174 RINN VALLEY EAST 17N -20-09N // 05 - 123 - 47179 RINN VALLEY EAST 17N -20-10C ►1 05 - 123 - 47176 RINN VALLEY EAST 17N -20-11N ►/ 05 - 123 - 47178 RINN VALLEY EAST 17N -20-12N ►/ 05 - 123 - 47173 RINN VALLEY EAST 17N -20-13C ►/ 05 - 123 - 47177 RINN VALLEY EAST 17N -20-14N• _ /1 05 - 123 - 47175 RINN VALLEY EAST 17N -20-15C 05 - 123 - 47473 RINN VALLEY EAST 17N -20-16N ' ►1 05 - 123 - 47474 RINN VALLEY WEST 18N -20-02C ►1 05 - 123 - 47471 RINN VALLEY WEST 18N -20-03N /1 05 - 123 - 47481 RINN VALLEY WEST 18N -20-04N /1 - - ❑ Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 Condensate Tank Addendum.docx Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/pacific/cdphe/air-permits. Rinn Valley Produced Water Tanks RECENED MAR 1 5 2019 Otioacti Sources This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: f g v.JEOz5 7 AIRS ID Number: i2` / 35' [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Extraction Oil & Gas, Inc. Rinn Valley Production Facility Site Location. NWSW Sec17 T2N R68W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Catie Nelson 720-354-4579 cnelson@extractionog.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 354744 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 1 I Rinn Valley Produced Water Tanks 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 ❑ 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 ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Please issue individual permit for produced water tanks. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Storage of Produced Water. at E&P Facility. For new or reconstructed sources, the projected start-up date is: 12/15/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week ❑✓ Exploration Et Production (EEtP) site 52 weeks/year ❑ 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 ✓ co-aRxpd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 2I ISopmlnomereftillw- Rinn Valley Produced Water Tanks Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information 985,840 1,183, 008 From what year is the actual annual amount? Tank design: Fixed roof Projected ❑ Internal floating roof ❑ External floating roof rage ank ID i an li � - o s i trotaura�t esse t©Ta 3 F dotal 1/olume o � � V 7 e; tan bbl n3 ate-- ost�� Is atio D - Nl �Recen t agei sse(� ora 3�3 many / y r Date � f Firsf � 1 £ic uctio MOHr eat . 12/2018 N/A 2 x 400 bbls 800 Before 12/2018 ��® aegE� i' syu. 0�'�i"a ST�Y`zv�` s �t � s St geiTank or k at e E&Les,Only) ��: "may"�, utnb i �. - a '-§: air y'-�,. `°z° c . �� 'lame of Wel � � � � v � � `i+m-.sue Newt Fie orted l�lel - See Attached ❑ 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 40.137738, -105.035532 N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) O Upward ❑ Horizontal ❑ Downward ❑Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ['Circular Interior stack diameter (inches): Unknown ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 3 C0O)* ADA DaturfaalgotdIRENE- Rinn Valley Produced Water Tanks Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: MMBtu/hr Make/Model: 95% % 98% % Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 821.6 Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: HLP separator eatokAoo Form APCD 207 Produced Water Storage Tanks) APEN Revision 7/2018 • 4 IUtgalimiatIMM Rinn Valley Produced Water Tanks 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 -, � ,011p, nt nek � �n� ese o o trot e } �k.�� k xm it Res r�este4 r � Ef�c1e c -z e ucon<>.eml__S_ VOC ECD 95% NOx CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected t23DttUi aiF17Ii5S7E ttO�_� POItUtdrit �� a , eSte Yif.Cl. ] led 1iCb r0 O1 �� 42 � -c" . Uncontrolled issi n of e t it ns d nCoCeyn m o n ns/�ear ` �o red on it nsI�ear VOC 0.018267 f lb/bbl Site specific Sampling 9.004 ✓ 0.450 / 10.805 0.540 / NOx CO 70 � � �7#P I3�rR1 6 m ca am v � . e jt Emission or � U t = ss d�4 x : s K rs '� P 2, Uncontrolled �ol Emissions 11-t; sio �� ✓ Benzene 71432 0.001667 ✓ lb/bbl Site Specific Sampling 1,642.923 ✓ 82.146 Toluene 108883 0.001177 1 lb/bbl sitespecifcs.mpling 1,160.734 / 58.037 Ethylbenzene 100414 Xylene 1330207 0.000280 ✓ lb/bbl SiceSpeeificsampling 276.406 / 13.820 1 n -Hexane 110543 0.000524 ✓ lb/bbl Site Specific Sampling 516.445 1 25.822 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. tdal.,04AD* Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 5 I Rinn Valley Produced Water Tanks Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit ft and AIRS !D) 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. I 14 Al 6 Signature of Legally Authorized Person (not a vendor or consultant) Dat Catie Nelson Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: ❑✓ 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 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 COLORAod Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 6I E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: Extraction Oil & Gas, Inc. Source Name: Rinn Valley Produced Water Tanks Emissions Source AIRS ID2: 123 //1.35/ 662 - Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 47317 RINN VALLEY EAST 17N -20-01C ►/ 05 - 123 - 47316 RINN VALLEY EAST 17N -20-02N .1 05 - 123 - 47318 RINN VALLEY EAST 17N -20-03N /1 05 - 123 - 47315 RINN VALLEY EAST 17N -20-04C ►/ 05 - 123 - 47313 RINN VALLEY EAST 17N -20-05N -1 05 - 123 - 47319 RINN VALLEY EAST 17N -20-06N I1 05 - 123 - 47320 RINN VALLEY EAST 17N -20-07C r 05 - 123 - 47314 RINN VALLEY EAST 17N -20-08N /1 05 - 123 - 47174 RINN VALLEY EAST 17N -20-09N ►/ 05 - 123 - 47179 RINN VALLEY EAST 17N -20-10C r 05 - 123 - 47176 RINN VALLEY EAST 17N -20-11N 05 - 123 - 47178 RINN VALLEY EAST 17N -20-12N 1 05 - 123 - 47173 RINN VALLEY EAST 17N -20-13C ►1 05 - 123 - 47177 RINN VALLEY EAST 17N -20-14N .1 05 - 123 - 47175 RINN VALLEY EAST 17N -20-15C // 05 - 123 - 47473 RINK VALLEY EAST 17N -20-16N /1 05 - 123 - 47474 RINN VALLEY WEST 18N -20-02C ►/ 05 - 123 - 47471 RINN VALLEY WEST 18N -20-03N ►1 05 - 123 - 47481 RINN VALLEY WEST 18N -20-04N ►1 Footnotes: I Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 PW Tank Addendum.docx Rinn Valley Liquid Loadout APEk,,. 4fQ,p 152018 Sza1PC Hydrocarbon Liquid Loading APEN$o ° a, Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be comnlerprl fnr hnrh .,o,. =^a existing facilities, including APEN updates. An application with missing info Lte and may be returned or result in longer application processing times. You . 'ee if the APEN is filled out incorrectly or is missing information and This APEN is to be used for hydrocarbon l there may be a more specific APEN for ye condensate storage tanks, etc.). In additi options will not satisfy your reporting ne( Control Division (APCD) website at: www. Vq-A c 3 hit does not fall into this category, it, glycol dehydration unit, )0) is available if the specialty APEN can be found on the Air Pollution This emission notice is valid for five (5) auuinission or a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emiss'ons increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: /1 E O g AIRS ID Number: 1223 /A03.5/063 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Rinn Valley Production Facility Site Location: NWSW Sec17 T2N R68W Mailing Address: (Include Zip code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Catie Nelson Phone Number: 720-354-4579 E -Mail Address': cnelson@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. 354743 Form APCD-208 - Hydrocarbon Liquid Leading APEN - Revision 7/2018 1 I Rinn Valley Liquid Loadout APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action 0 NEW permit OR newly -reported emission source 0 Request coverage under construction permit 0 Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment 0 ❑ Change permit limit Change company name3 Transfer of ownership4 0 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: Please Issue individual permit for liquid loadout. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer 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: Loading of condensate liquid onto tanker trucks for transport. Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 12/15/2018 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 • p Does this source load gasoline into transport vehicles? Yes No ■ p Is this source located at an oil and gas exploration and production site? Yes No 4 ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No Does this source splash fill less than 6750 bbl of condensate per year? Yes No Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ p LootAoce J Form APCD-208 - Hydrocarbon Liquid Loading APEN Revision 7/2018 21 Rinn Valley Liquid Loadout APEN 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 O Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: • t Requested Volume Loaded5: 3,253,822 bbl/year This product is loaded from tanks at this facility into: (e.g. "rail tank cars" or "tank trucks") Actual Volume Loaded: Tank Trucks 2,711,518 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: r 5 5 .1-i ° F True Vapor Pressure: i -1 °� d Psia @ 60 °F Molecular weight of displaced vapors: . 451249 lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: N/A bbl/year Actual Volume Loaded: N/A bbl/year Product Density: N/A lb/ft' Load Line Volume: N/A ft3/truckload Vapor Recovery Line Volume: N/A ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 I Amami iimenlumar: COC0RADd Rinn Valley Liquid Loadout APEN Permit Number: AIRS ID Number: / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal 40.137738, -105.035532 ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ 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. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: % ❑ " Combustion Device: Used for control of: VOC, HAPs Rating: Type: ECD MMBtu/hr Make/Model: Requested Control Efficiency: 95% % Manufacturer Guaranteed Control Efficiency: 98% % Minimum Temperature: °F Waste Gas Heat Content: 2549.8 Btu/scf Constant Pilot Light: ✓❑ Yes ❑ No Pilot Burner Rating: MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 I COI- GRAD* ienasansmai Rinn Valley Liquid Loadout APEN 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 combinedl control efficiency (% reduction): o lutan .ems, � � - � �pt� $5C iA� O >"Dl lee � e=__, z __ eralReuese _�= on O cie C �r0, to mfssians}:_ PM SOX NO. CO VOC ECD 95% HAPs ECD 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 Cfa e __ -,o tantjwion n e.n a i._iy o z c o t nua Ii laIwo 4 taj ' °< Sbli M et 1 s sso i;ons/year ` 5 ns7// ar COrttrll � ss pn . 41,,,,„ .-e- � r tes s t the. or PM SOX NO. CO 0.31 --/Ib/MMBtu AP -42 Chapter 13.5 2.402 2.402 ,./'2.882 2.882 '� VOC 0.2077 '/ lb/bbl Promax Modelling 281.591 0/ 14.080 ✓ 337.909 V 16.895 zra Reporb1etutaEEEtn �� s?9 a . am, ,₹�,._ iGEaisia5 -75int �' ® E - "` y auto � . 4 r _ , e _ c a ��( man aEa� ..D w ._ h aLt1 £ Till p ssla ollll e r - .__ _ Benzene 71432 0.0002639 ✓ lb/bbl Promax Modelling 715.570 / 35.778 / Toluene 108883 0.0002991 ✓ lb/bbl Promax Modelling 811.015 1 40.551 / Ethylbenzene 100414 Xylene 1330207 0.0001465 ✓ lb/bbl Promax Modelling 397.237 ✓ 19.862 1 n -Hexane 110543 0.0037277 ✓ lb/bbl Promax Modelling 10,107.726 ✓ 505.386 / 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 7/2018 5! tkeeteuest cai.ox.oa Rinn Valley Liquid Loadout APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. Signature of Legally Authorized Person (not a vendor or consultant) Date Catie Nelson Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: 0 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/cdohe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 6 1-O4140O 6/18/2019 State.co.us Executive Branch Mail - APEN Review: Extraction Rinn Valley Production Facility, AIRS ID 123/A035 (Quoted text hidden] Colin Harkins <colin@airbasicsinc.com> To: "Ricci - CDPHE, James" <james.ricci@state.co.us> Cc: Catie Nelson <cnelson@extractionog.com>, Aaron Schlabaugh <aaron@airbasics.biz> Hi James, Tue, May 7, 2019 at 5:41 PM I apologize, I have not been able to put together a full response to your questions before leaving on vacation tomorrow. I have responded below with answers in blue for the condensate tanks and loadout. We will continue to work on providing answers to the other questions. I apologize for the delay here, Extraction's air team has a number of people out on vacation currently. As for your questions regarding the engine, we just received confirmation that both nonroad generators (123-A035-006 and 123-A035-007) were disconnected from the facility. Do you still need the engine questions to be answered? Cancellation forms are being prepared for both sources and we will send these along to you as soon as they have been signed. Thanks and have a great evening! Colin Harkins I Air Basics. Inc. Cell: 916-221-0435 I Email: colin@airbasicsinc.com From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Friday, May 03, 2019 10:44 AM To: Colin Harkins <colin@airbasics.biz> Cc: Catie Nelson <cnelson@extractionog.com>; Aaron Schlabaugh <aaron@airbasics.biz> Subject: APEN Review: Extraction Rinn Valley Production Facility, AIRS ID 123/A035 Hi Colin, Below are the questions I have from the first run through of the application: Condensate Tanks: Was this the only pressurized sample taken at this facility? How much does the composition change comparing liquid samples from Nio vs Codell wells? o Only one pressurized liquid sample (Niobrara) was taken at the Rinn Valley facility. o From my experience, Codell liquid samples tend to have a slightly lower API gravity/ greater molecular weight. The production records at Rinn Valley indicate that Codell wells are producing with a slightly lower GOR than Niobrara wells. That would also indicate that the Codell produced liquids are "heavier". The LP oil taken at 48.1 psig travels through Valve 1 and is dropped to 5 psig before entering the VRT. How does Valve 1 work in the field? Is this pressure drop integrated into the VRT? Is there a valve upstream of the VRT that regulates pressure before entering the VRT? o The valves upstream of the VRT do not regulate the pressure at the inlet to the VRT. The pressure of the VRT vessel is controlled by the compressors. pulling flashed gas from the VRT. 5 psig was chosen as a nominal VRT operating pressure. In reality, the VRT pressure varies slightly over time with oil production and compressor power. Is O1 negative? Temp is dropped from 112.172 deg F to an assumed 90 deg F. Is this temperature drop due to time spent in the VRT? How did you pick 90 deg F? o O1 is negative but is not a specified value. It is the result of the 90 deg F temperature specification made on the VRT oil stream. o The conditions 90 F and 5 psig were chosen as nominal VRT operating conditions, based on our experience with vapor recovery towers. The VRT may be slightly hotter or cooler depending on a variety of factors; temperature of produced liquids from other wells, production rate (i.e. separator and VRT residence time), time of year, the use of separator heaters, use of heaters on VRT, etc. Same with Q2, what does this value represent in ProMax and how did you pick it? o O2 is also not a specified value, it is a result of the specified oil tank temperature. The specified oil tank temperature (64.04 deg F) is the AP -42 maximum liquid surface temperature. This value is the tank flashing temperature used by the promax tank losses calculator and AP -42 (also calculated by promax in the "Tank Flash Vapors" stream). Loadout: Is there a Sales Oil analysis available for this facility? I was hoping to compare the RVP of a sales oil analysis with the ProMax calculated RVP. o We did not perform a sales oil RVP analysis. Typically, low pressure liquids are the only liquids•that are sampled and analyzed. RVP of the sales oil is then calculated based on the promax analysis. TVP is listed in ProMax as 6.9558 psig but listed as psia on the APEN. When ProMax calculates TVP, is psig and psia interchangeable due to the method? o I made a mistake here. The TVP listed was TVP @ 100F and was in psig. I've attached a copy of a calculation of TVP @ 60F. Would you be able to redline this value onto the APEN? Section 3: If the facility loads 0 bbls of Crude and 0 bbls of condensate splash filled, I think we should mark those questions as "Yes." If you agree, I can redline the APEN. o I agree with you and you can redline the questions to "Yes". I originally marked these questions "No" because the facility does not splash fill any liquids, but I see how that is a confusing way to think about it. Venting: • Is there ever a case where high pressure gas would be vented at this facility? In the event that the sales line becomes unavailable, would the facility shut in? • What is the minimum flowrate required for the Q5000 to achieve 99% DRE? What happens if flowrate falls below this value? • Are there any other critical operating parameters of the 05000 that the manufacturer requires to meet 99% DRE? hthnc•//mail nnnnla rtom/mail/tt/0?ik=5517734b80&view=ot&search=all&oermthid=thread-a%3Ar-1383692554565505057&simpl=msg-a%3Ar4991512... 3/40 6/18/2019 State.co.us Executive Branch Mail - APEN Review: Extraction Rinn Valley Production Facility, AIRS ID 123/A035 Cafe Nelson From: SQL Service on VS90 (DO NOT REPLY) <dphevs90mail@state.co.us> Serrt: Wednesday, May 1, 2019 9:43 AM To: Catie Nelson <cnelson@extractionog.com> Cc: james.ricci@state.co.us Subject: [EXTERNAL] Assigned Review Engineer Colorado Department of Public Health and Environment Air Pollution Control Division Staionary Sources Program An application for an air pollution construction permit or permit modification was received on 03/15/2019 and has been assigned to the following Review Engineer or final approval self -certification coordinator: JAMES RICCI, (303) 691-4089 james.ricci@state.co.us In addition, this project has been assigned the following permit number and location: Permit Number. 19WE0256 Source Desription: RINN VALLEY PRODUCTION FACILITY - CONDENSATE TANKS EXTRACTION - RINN VALLEY PROD. FACILITY NWSW SEC17 T2N R68W WELD, CO 00000- 2 attachments 2019_0617 Rinn Valley Separator O&M Plan.pdf 239K lib Q5000 Operating & Maintainence Schedule.pdf 148K Colin Harkins <colin@airbasicsinc.com> Mon, Jun 17, 2019 at 12:32 PM To: "Ricci - CDPHE, James" <james.ricci@state.co.us>, Jonathan Torizzo <jtorizzo@extractionog.com>, Kathy Steerman <ksteerman@extractionog.com> James, I just heard back from BR&E about the loading loss calculations. It looks like I was mistaken about where promax displays the TVP and liquid temperature that it uses in the loading loss calculation. The TVP should be 9.797 psia and the average temperature of bulk liquid temperature should be 55.17 F. If you calculate the loading loss emission factor based on those values, you should come up with 0.2696 lb/bbl. This is the whole gas emission factor, calculated based on the flowrate of oil at a temperature of 55.17 F. To arrive at the emission factor we have reported, we first need to convert to the whole gas emission factor based on the flowrate of oil at standard conditions. That gives an EF of 0.2665 lb/bbl, which then needs to be converted to a VOC emission factor based on the VOC mass fraction of the loadout vapor (77.935%). Finally, that results in our reported emission factor, 0.2077 lb VOC/bbl. I've attached an excel workbook with calculations proving that the values match between AP -42 and promax. I've also included screenshots of where these values came from in promax. I appreciate your attention to detail here! Going forward, I'll make sure to report the correct values on the APEN from the get go. Please let me know if I can explain any of this further. Thanks! Colin Harkins Air Quality Engineer (916)221-0435 Air Basics, Inc. www.airbasicsinc.com From: Colin Harkins Sent: Monday, June 17, 2019 8:44 AM To: Ricci - CDPHE, James <james.ricci@state.co.us>; Jonathan Torizzo <jtorizzo@extractionog.com>; Kathy Steerman <ksteerman@extractionog.com> Subject: RE: APEN Review: Extraction Rinn Valley Production Facility, AIRS ID 123/A035 kfinc•//nrtnil r..,r,,,lo ,-nm/mailh linwr,..5A177SdhRnRviaw=nt&cnarch=all&Dermthid=thread-a%3Ar-1383692554565505057&simol=msg-a%3Ar499151... 33/40 S N?te Sttta► fie%. Pfii,`c1 t . P? t1 alastukvo. CektANA te13115 Rinn Valley VRT Gas VeACRIVED MAR 15 2079 h Gas Venting APEN - Form APCD-214 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for 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.onv/-4-` ' I This emission notice is valid for five (5) years. Submis \days prior to expiration of the five-year term, or when a reportable change is increase production, new equipment, change in fuel type, etc.). See Regul, ,,`..N 'L} 011 PEN requirements. ^L\P iv O,( ol-A-- `13 /Pr035/volt Permit Number: l� vvii X25 1 [Leave blank unless APCD has Section 1 - Administrative Information Company Name': Extraction OH & Gas, Inc. Site Name: Rinn Valley Production Facility Site Location: NWSW Sec17 T2N R68W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Catie Nelson Phone Number: 720-354-4579 E -Mail Address2: cnelson@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. 394744 Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I itINWASAMFIRG adlftheir Rinn Valley VRT Gas Venting 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 D 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 a Notes: Please issue individual permit for VRT Gas Venting. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Venting of VRT Gas when compression is unavailable. Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 12/15/2018 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? El days/week weeks/year Yes Yes Yes ❑ No / ❑✓ No ❑ No Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I CO4.ORx0O1 Rinn Valley VRT Gas Venting Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit it 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? 0 Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: 2753.028 BTU/SCF Requested: 9.700 , MMSCF/year Actual: 7,012 MMSCF/year -OR- Requested: NhA bbl/year Actual: N/A bbl/year Molecular Weight: 47.959 ✓ VOC (Weight %) 87.060 ✓ Benzene (Weight %) 0.1346 Toluene (Weight %) 0.0713 1 Ethylbenzene (Weight %) 0.0015 / Xylene (Weight %) 0.0117 / n -Hexane (Weight %) 1.4049 ./ 2,2,4-Trimethylpentane (Weight %) 0.0004 / 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. e01.0itADd Form APCD-211 - Gas Venting APEN - Revision 7/2018 . 3 I Rinn Valley VRT Gas Venting ❑✓ Upward ❑ Horizontal Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information 40.137738, -105.035532 Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Unknown. 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: Rating: Type: VOC, HAPs 200 MMBtu/hr ECD Make/Model: Requested Control Efficiency: 99% % Questor Q5000 Manufacturer Guaranteed Control Efficiency: 99.99% % Minimum Temperature: Waste Gas Heat Content: 2753.0 Btu/scf Constant Pilot Light: Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 41 Rinn Valley VRT Gas Venting 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 combined) control efficiency (% reduction ): ollutan , Description 11 00 etfiasi� �Requested -on o f icien PM SO. NO. CO VOC ECD 99% HAPs ECD 99°i° Other: From what year is the following reported actual annual emissions data? Projected PM SOx NO. CO 0.310 lb/MMBtu AP -42 Chapter 13.5 2.992 ✓ 2.992 ✓ 3.859 / 4.139 ✓ 4.139 we VOC 110, 080.552. lb/MMscf Site Specific Sampling 385.915 533.891 5.339 ✓ ton C� en4::, portable,,?flllt to pn 0 -0 emica awe ems cep fi�� n si cto _ site Specific Sampling c altA i led ss x1041. errf 1,192.904 / a �is on n roue e rcilee 15 � it Ib/MMscf SSl rn o ._, 'atm+ea: z= 11.929 / Benzene 71432 170.135 ✓ Toluene 108883 90.150 ✓ Ib/MMscf site Specific Sampling 632.087 / 6.321 ✓ Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 1,776.442 1 Ib/MMscf Site Specific Sampling 12,455.522 / 124.555 / 2,2,4- Trimethylpentane 540841 Other: F 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 7/2018 51 .. Rinn Valley VRT Gas Venting 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. Signature of Legally Authorized Person (not a vendor or consultant) Date Catie Nelson Air Quality Engineer Name (please 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 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 7/2018 6I Ceicaxu Ikzermiretithiler t.<<;,“.1, X13110% Rinn Valley VRT Gas Venting 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You maybe charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.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: 19W E0259 AIRS ID Number: 123 /A035 /004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Mailing Address: Extraction Oil & Gas, Inc. Rinn Valley Production Facility NWSW Sec 17 T2N R68W (Include Zip coded 370 17th St. Suite 5300 Site Location County: Weld NAICS or SIC Code: 211111 Denver, CO 80202 Contact Person: Catie Nelson Phone Number: 720-354-4579 E -Mail Address2: cnelson@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 7/2018 1 I 'COLORADO ne of Puaic Rinn Valley VRT Gas Venting Permit Number: 19WE0259 AIRS ID Number: 123 /A035/004 [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) O Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit O Transfer of ownership4 ❑ Other (describe below) - OR APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Please issue individual permit for VRT Gas Venting. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-1O6) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Venting of VRT Gas when compression is unavailable. Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 12/15/2018 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 Gas Venting APEN - Revision 7/2018 days/week weeks/year Yes Yes Yes ❑ No 0 No ❑ No COLORADO 2 1 .TrDeparcarsntoiPu,< Rinn Valley VRT Gas Venting Permit Number: 19WE0259 AIRS ID Number: 123 /A035 / 004 [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 #: # 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? 0 Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: 2753.028 BTU/SCF Requested: 9.000 MMSCF/year Actual: 7.219 MMSCF/year -OR- Requested: N/A bbl/year Actual: N/A bbl/year Molecular Weight: 47.959 ,/ VOC (Weight %) 87.060 ✓ Benzene (Weight %) 0.1346 ✓ Toluene (Weight %) 0.0713 Ethylbenzene (Weight %) 0.0015 Xylene (Weight %) 0.0117 ✓ n -Hexane (Weight %) 1.4049 / 2,2,4-Trimethylpentane (Weight %) 0.0004 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. Form APCD-211 - Gas Venting APEN Revision 7/2018 3 I Al COLORADO amr-sit of Public Enuiroiubipul i Rinn Valley VRT Gas Venting 0✓ Upward O Horizontal Permit Number: 19WE0259 AIRS ID Number: 123 /A035/004 [Leave blank unless APCD has already assigned a permit tt and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.137738, -105.035532 Operator Stack ID No Discharge Height ' Above Ground Level (Feet) r Temp ( Flow Rate (ACFM) Velocity (ft/sec) N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) O Downward O Other (describe): Indicate the stack opening and size: (check one) O Circular O Other (describe): Interior stack diameter (inches): O Upward with obstructing raincap Unknown 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. O VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 200 MMBtu/hr Type: ECD Make/Model: Questor O5000 Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: 99.99 Minimum Temperature: Waste Gas Heat Content: 2753.028 Btu/scf Constant Pilot Light: ✓0 Yes O No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: COLORADO oep„vnent d PIN, Nai1111 b Ewlmnrc�wll Form APCD-211 - Gas Venting APEN - Revision 7/2018 41 Rinn Valley VRT Gas Venting Benzene Permit Number: 19WE0259 AIRS ID Number: 123 I A035 / 004 [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 PM Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) SOX NO. CO VOC ECD 98% HAPs ECD 98% Other: Projected From what year is the following reported actual annual emissions data? Polluiant PM Criteria Pollutant, Emissions Inventory source (AP 42 Mfg , etc.) ncontrolled Emi=ssions „≥ (tons/year)z. ontrollec Emissions6 (tons/year) Jncontrolled Emissions (tons/year): ontrolled Emissions tons/year) SOX NO), CO 0.310 Ib/MMBtu AP -42 Chapter 13.5 3.081 3.081 ✓ 3.840 / 3.840 ✓ VOC 110,080.552✓ Ib/MMscf Site Specific Sampling 397.348 / 7.947 495.362 / 9.907 / Non -Criteria Reportable Pollutant :Emissions Inventory Chemical Abstract Service (CAS) Number 71432 mission Factor ; Uncontrolled Basis 170.135 ✓ Ib/MMscf ource (AP -42, Mfg., etc.) Site Specific Sampling Actual Annual Emissions Uncontrolled Emissions (pounds/year) 1,228.244 ✓ Controlled Emissions6 (pounds/year) 24.565 ✓ Toluene 108883 90.150 ✓ Ib/MMscf Site Specific Sampling 650.813 J 13.016 J Ethylbenzene Xylene 100414 1330207 n -Hexane 110543 1,776.442 � Ib/MMscf Site Specific Sampling 12,824.525 ✓ 256.490 ✓ 2,2,4- Trimethylpentane Other: 540841 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 7/2018 'COLORADO 5 I �r� a:ota - Hnaln. E F.m+imbunnll Rinn Valley VRT Gas Venting Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit Jl 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 of Legally Authorized Person (not a vendor or consultant) Catie Nelson 31 tit Date Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.Rov/cdphe/aped Form APCD-211 - Gas Venting APEN - Revision 7/2018 6I cotoRkUdt 6/18/2019 State.co.us Executive Branch Mail - APEN Review: Extraction Rinn Valley Production Facility, AIRS ID 123/A035 Q5000 Technical Data Sheet.pdf 676K Colin Harkins <coin@airbasicsinc.com> To: "Ricci - CDPHE, James" <james.ricci@state.co.us> Cc: Jonathan Torizzo <jtorizzo@extractionog.com>, Catie Nelson <cnelson@extractionog.com> James, Thu, May 30, 2019 at 1:20 PM I apologize for the lack of a response here! I haven't yet been able to get any information from Questor regarding the highlighted questions about separator venting. Our team was actually discussing the possibility of redlining the venting APENs to request 98% control, along with some adjustments to the requested permit limits. With the non - road engines removed from site, 99% control is not something that we would need to request. Would this be OK with you? If so, I can email over revised copies of the APENs next week, along with emissions calculations and an updated form 102. Have a great afternoon, Colin Harkins Air Quality Engineer (916)221-0435 Air Basics, Inc. www.airbasicsinc.com Please note, my email has changed to colin@airbasicsinc.com. Please update your contact information accordingly! [Quoted text hidden] Ricci - CDPHE, James <james.ricci@state.co.us> Thu, May 30, 2019 at 1:32 PM To: Colin Harkins <colin@airbasicsinc.com>, Catie Nelson <cnelson@extractionog.com>, Jonathan Torizzo <jtorizzo@extractionog.com> Thanks for the update Colin. Yes, this is fine, with me. You can email me any revised APENs and calculations next week and I will add them as an addendum to the application. I think even at 980/0, I would still be curious to see what Questor has to say about critical operating parameters. We are trying to better understand what 98% control really entails as there is very little room room for error where we are assuming DRE is this high. Thanks, James Ricci Permit Engineer ICOLORADO As Polution Control Division o-o>mme,i cr a,u-Her., a Emmo,m,m P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 james.ricci@state.co.us I www.colorado.gov/cdphe/apcd [Quoted text hidden] Colin Harkins <colin@airbasicsinc.com> To: "Ricci - CDPHE, James" <james.ricci@state.co.us> Cc: Jonathan Torizzo <jtorizzo@extractionog.com>, Kathy Steerman <ktteerman@extractionog.com> Hi James, Mon, Jun 3, 2019 at 4:24 PM I was finally able to talk to Questor about this. Questor has said that there is not a minimum flow requirement for the combustor, as shown through repeated testing. However, as with all O&G facilities, the operators are responsible for maintaining the proper operation of their combustors. As part of that, the air flow into the Q5000 can be altered to change the amount of excess air drawn in. That aids the natural draft system in maintaining high combustion temperatures throughout different gas flow rates. I'd be happy to discuss this further over the phone if you would like! I've attached redline versions of the LP and VRT gas APENs for your review. Also attached are revised emissions calculations and a revised form 102! Please let me know if you have any questions with these redlines. Thanks and have a great evening! Colin Harkins Air Quality Engineer. (916)221-0435 Air Basics, Inc. — -.n-- _ ...Pi," A. 'a Of2GC10==AGacFnCng7R.ni..,r,t-r.,ort_ue/-44rAQQ1F19 Ran 6/18/2019 State.co.us Executive Branch Mail - APEN Review: Extraction Rinn Valley Production Facility, AIRS ID 123/A035 www.airbasicsinc.00m Please note, my email has changed to colin@airbasicsinc.com. Please update your contact information accordingly! From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Thursday, May 30, 2019 1:33 PM To: Colin Harkins <colin@airbasicsinc.com>; Catie Nelson <cnelson@extractionog.com>; Jonathan Torizzo <jtorizzo@extractionog.com> Subject: Re: APEN Review: Extraction Rinn Valley Production Facility, AIRS ID 123/A035 Thanks for the update Colin. Yes, this is fine with me. You can email me any revised APENs and calculations next week and I will add them as an addendum to the application. I think even at 98%, I would still be curious to see what Questor has to say about critical operating parameters. We are trying to better understand what 98% control really entails as there is very little room room for error where we are assuming DRE is this high. Thanks, James Ricci Permit Engineer [Quoted text hidden] [Quoted text hidden] 5 attachments fill 2019_0603 Rinn Form 102 - Redline.pdf 92K .© 2019_0603 Rinn Valley LP Gas APEN - Redline.pdf 519K 2019_0603 Rinn Valley LP gas venting - Redline Emissions Calculations.pdf 288K 2019_0603 Rinn Valley VRT Gas APEN - Redline.pdf 508K •n 2019_0603 Rinn Valley VRT gas venting - Redline Emissions Calculations.pdf 288K Colin Harkins <coin@airbasicsinc.com> To: "Ricci - CDPHE, James" <james.ricci@state.co.us> Cc: Jonathan Torizzo <jtorizzo@extractionog.com>, Kathy Steerman <ksteerman@extractionog.com> James, Tue, Jun 4, 2019 at 9:52 AM I just wanted to follow up about another earlier question. You had asked about other sources that have been stack tested by Extraction. As I mentioned, the RBF Stromberger (AIRS: 123-9F9B) had a stack test performed for self -certification on 5/17/2019. That self -certification was submitted to APCD on 5/31/2019 and I've also attached an electronic copy of the document here. Thanks and have a great day! Colin Harkins Air Quality Engineer [Quoted text hidden] [Quoted text hidden] RBF_Stromberger Combined Self Cert Package.pdf 4590K Ricci - CDPHE, James <james.ricci@state.co.us> To: Colin Harkins <colin@airbasicsinc.com> Cc: Jonathan Torizzo <jtorizzo@extractionog.com>, Kathy Steerman <ksteerman@extractionog.com> Thu, Jun 6, 2019 at 2:22 PM Colin, Thanks for these updated APENs. Just a few follow-up questions: h+4ne•��rnail nnnnle nnm/mail/ii/Mik=5517734hR0&view=ot&search=all&Dermthid=thread-a°Io3Ar-1383692554565505057&simpl=msg-a%3Ar4991512... 7/40 Ste e4f %A -LW APE -'J rttGiJei. 613111 Rinn Valley LP Gas Ve i FINED MAR 1 5 2019 APCD Gas Venting APEN - Form APCD-21MW Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for 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.Qov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: f vUE 0lesAIRS ID Number: 1'23 /04035/66g `[Leave blank unless APCD has already assion.,4 , kS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Mailing Address: Extraction Oil & Gas, In Rinn Valley Production NWSW Sec17 T2N R6E J`^x O©S tke f• Mi { 01�cJ� r�4N� (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 !n r. Weld NAICS or SIC Code: 211111 Contact Person: Catie Nelson Phone Number: 720-354-4579 E -Mail Address2: cnelson@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. 39474, Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I Rinn Valley LP Gas Venting 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 El 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 Et Notes: Please issue individual permit for LP Gas Venting. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Venting of LP Gas when compression is unavailable. Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 12/15/2018 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? El days/week weeks/year Yes Yes Yes Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I ❑ No ' ❑✓ No f El/ No d ;totoRxaa irmerr:. Rinn Valley LP Gas Venting 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 Pistocs: 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 Heating Value: 1982.351 BTU/SCF Requested: 16.000 MMSCF/year Actual: 10.471 MMSCF/year -OR- Requested: NhA bbl/year Actual: NhA bbl/year Molecular Weight: 34.628 ✓ VOC (Weight %) 60.162 ✓ Benzene (Weight %) 0.0908 ✓ Toluene (Weight %) 0.0548 / Ethylbenzene (Weight %) 0.0016 Xylene (Weight %) 0.0116 V n -Hexane (Weight %) 0.8491 ,f 2,2,4-Trimethylpentane (Weight %) 0.0003 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 7/2018 3I :COLORADO' o„ ,.r ce .__ Rinn Valley LP Gas Venting Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Indicate the direction of the stack outlet: (check one) 0 Upward 0 Horizontal 40.137738, -105.035532 0 Downward Other (describe): Indicate the stack opening and size: (check one) 0 Circular 0 Other (describe): Interior stack diameter (inches): 0 Upward with obstructing raincap Unknown Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: % Combustion Device: Pollutants Controlled: Rating: Type: VOC, HAPs ECD MMBtu/hr Make/Model: Requested Control Efficiency: 99% % Manufacturer Guaranteed Control Efficiency: 99.99% % Minimum Temperature: Waste Gas Heat Content: 1982.351 Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 Gas Venting APEN - Revision 7/2018 41 Rinn Valley LP Gas Venting 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 r combined control efficiency (% reduction ): mII o min echo s x. . Overalle u e-. a ter ficie ? r,reduction in q -1P Son PM SOX NO. CO VOC ECD 99% HAPs ECD 99% Other: From what year is the following reported actual annual emissions data? Projected PM c\kPaSOC-b SOx NO. 0.068 lb/MMBtu AP -42 Chapter 13.5 0.706 V 0.706 V 1.078 ✓ 1.078 7 CO 0.310 lb/MMBtu AP -42 Chapter 13.5 3.217 ✓ 3.217 4.916 ✓ 4.916 ✓ VOC 54,925.068 lb/MMscf Site Specific Sampling 287.565 / 2.876 ✓ 439.401 ✓ 4.394 ✓ 8.675 ✓ Benzene 71432 82.851 lb/MMscf Site Specific Sampling 867.544 V/ 523.940 ✓ 5.239 ✓ Toluene 108883 50.036 Ib/MMscf Site Specific Sampling Ethylbenzene Xylene 100414 1330207 n -Hexane 110543 775.176 • lb/MMscf Site Specific Sampling 8,116.993 ✓ 81.170 / 2,2,4- Trimethylpentane Other: 540841 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 7/2018 5I {tatcrtAaa Mmemeiteemmmor Rinn Valley LP Gas Venting 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. 1 f ` 3 l Signature of Legally Authorized Person (not a vendor or consultant) Dat Catie Nelson /6I') Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance �✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.Rov/cdphe/apcd kod Form APCD-211 - Gas Venting APEN - Revision 7/2018 6 I �4<<, J J W3111 Rinn Valley LP Gas Venting 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.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: 19WE0260 AIRS ID Number: 123 /A035 /005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Rinn Valley Production Facility Site Location: NWSW Sec 17 T2N R68W Mailing Address: 370 17th St. Suite 5300 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Catie Nelson 720-354-4579 cnelson@extractionog.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I iCOLORADO cepanm=ne of tic I. Hahtlt:E F.nuieenirenl Rinn Valley LP Gas Venting Permit Number: 19WE0260 AIRS ID Number: 123 /A035/005 [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) O Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit O Change permit limit ❑ Transfer of ownership4 O Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)' Additional Info £t Notes: Please issue individual permit for LP Gas Venting. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Venting of LP Gas when compression is unavailable. Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 12/15/2018 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 7/2018 days/week weeks/year Q Yes ❑ Yes O Yes ❑ No O No ❑ No {ham COLORADO 2 I AV 1=7,t,72;,, iii Rinn Valley LP Gas Venting Permit Number: 19W E0260 AIRS ID Number: 123 /A035 / 005 [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 Heating Value:. 1982.351 BTU/SCF Requested: 13.000 MMSCF/year Actual: 10.590 MMSCF/year -OR- Requested: NA bbl/year Actual: NA bbl/year Molecular Weight: 34.628 ✓ VOC (Weight %) 60.162 ✓ Benzene (Weight %) 0.0908 / Toluene (Weight %) 0.0548 f Ethytbenzene (Weight %) 0.0016 ✓ Xylene (Weight %) 0.0116 n -Hexane (Weight %) 0.8491 V 2,2,4-Trimethylpentane (Weight %) 0.0003 V 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 7/2018 3I COLORADO Deyaswent of Putac �a. „� Ev;,nm,-nl Rinn Valley LP Gas Venting Permit Number: 19WE0260 AIRS ID Number: 123 / A035 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.137738, -105.035532 Operator; Stack ID No Discharge:Height Above Ground Level (Feet) Temp ( F) Flow Rate (ACFM) .. Velocity (ft/sec) ,. . N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) 0✓ Upward O Horizontal O Downward O Other (describe): Indicate the stack opening and size: (check one) 0✓ Circular O Other (describe): Interior stack diameter (inches): O Upward with obstructing raincap Unknown 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. O VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: 0 Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 200 Type: ECD MMBtu/hr Make/Model: Questor Q5000 Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: 99.99 % Minimum Temperature: Waste Gas Heat Content: 1982.351 Btu/scf Constant Pilot Light: ✓0 Yes O No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: form APCD-211 - Gas Venting APEN - Revision 7/2018 41 COLORADO 0 0rn,nt otPuU.. f1.4111. Fnvirnnn�p:J Rinn Valley LP Gas Venting Chemical Name Benzene Permit Number: 19W E0260 AIRS ID Number: 123 / A035 / 005 [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 PM Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) SO. NO. CO VOC ECD 98% HAPs ECD 98% Other: Projected From what year is the following reported actual annual emissions data? Pollutant PM Uncontrolled Basis 0.310 Ib/MMBtu AP -42 Chapter 13.5 Criteria Pollutant Emissions Inventory Source (AP 42 _ Mfg .etc).; Actual Annual Emissions Uncontrolled Emissions (tons/year)) :ontrolled Emissions6 (tons/year) Requested Annual Permit Emission Limit(s)5 Uncontrolled.. Emissions (tons/year) ontrolled Emissions';: -(tons/year) SOX NO. CO VOC 54,925.068 Ib/MMscf Site Specific Sampling 3.254 f 290.816 ✓ 3.254 ✓ 5.816 ✓ 3.994 'i 357.013 / 3.994 7.140 ✓ Non -Criteria Reportable Pollutant Emissions Inventory Chemical. Abstract Service (CAS) Number 71432 Emission Factor Actual Annual Emissions Uncontrolled Basis 82.851 ✓ 50.036 's Units Ib/MMscf Source (AP -42," Mfg., etc.) Site Specific Sampling Uncontrolled Emissions (pounds/year) 877.353 / Controlled Emissions6 (pounds/year) 17.547 / Toluene 108883 lb/MMscf Site Specific Sampling 529.864 t/ 10.597 / Ethylbenzene Xylene 100414 1330207 n -Hexane 110543 775.176 ✓ Ib/MMscf Site Specific Sampling 8,208.766 ✓ 164.175 1 2,2,4- Trimethylpentane Other: 540841 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 7/2018 'COLORADO 5 mS7 === Rinn Valley LP Gas Venting Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID) Section 8 - Applicant Certification 1 hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. O'Llt-14 (-1k-'O11\A Signature of Legally Authorized Person (not a vendor or consultant) Dat Catie Nelson Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: El 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-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.Rov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 6I cCriOkMbd Droemmteftrgic 6/18/2019 State.co.us Executive Branch Mail - APEN Review: Extraction Rinn Valley Production Facility, AIRS ID 123/A035 Q5000 Technical Data Sheet.pdf 676K Colin Harkins <colin@airbasicsinc.com> To: "Ricci - CDPHE, James" <james.ricci@state.co.us> Cc: Jonathan Torizzo <jtorizzo@extractionog.com>, Catie Nelson <cnelson@extractionog.com> James, Thu, May 30, 2019 at 1:20 PM I apologize for the lack of a response here! I haven't yet been able to get any information from Questor regarding the highlighted questions about separator venting. Our team was actually discussing the possibility of redlining the venting APENs to request 98% control, along with some adjustments to the requested permit limits. With the Ron - road engines removed from site, 99% control is not something that we would need to request. Would this be OK with you? If so, I can email over revised copies of the APENs next week, along with emissions calculations and an updated form 102. Have a great afternoon, Colin Harkins Air Quality Engineer (916)221-0435 Air Basics, Inc. www.airbasicsinc.com Please note, my email has changed to colin@airbasicsinc.com. Please update your contact information accordingly! [Quoted text hidden] Ricci - CDPHE, James <james.ricci@state.co.us> Thu, May 30, 2019 at 1:32 PM To: Colin Harkins <colin@airbasicsinc.com>, Catie Nelson <cnelson@extractionog.com>, Jonathan Torizzo <jtorizzo@extractionog.com> Thanks for the update Colin. Yes, this is fine with me. You can email me any revised APENs and calculations next week and I will add them as art addendum to the application. I think even at 98%, I would still be curious to see what Questor has to say about critical operating parameters. We are trying to better understand what 98% control really entails as there is very little room room for error where we are assuming DRE is this high. Thanks, James Ricci Permit Engineer cove COLORADO Air Pollution Control Division P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 james.ricci@state.co.us I www.colorado.gov/cdphe/apcd [Quoted text hidden] Colin Harkins <colin@airbasicsinc.com> To: "Ricci - CDPHE, James" <james.ricci@state.co.us> Cc: Jonathan Torizzo <jtorizzo@extractionog.com>, Kathy Steerman <ksteerman@extractionog.com> Hi James, Mon, Jun 3, 2019 at 4:24 PM I was finally able to talk to Questor about this. Questor has said that there is not a minimum flow requirement for the combustor, as shown through repeated testing. However, as with all O&G facilities, the operators are responsible for maintaining the proper operation of their combustors. As part of that, the air flow into the Q5000 can be altered to change the amount of excess air drawn in. That aids the natural draft system in maintaining high combustion temperatures throughout different gas flow rates. I'd be happy to discuss this further over the phone if you would like! I've attached redline versions of the LP and VRT gas APENs for your review. Also attached are revised emissions calculations and a revised form 102! Please let me know if you have any questions with these redlines. Thanks and have a great evening! Colin Harkins Air Quality Engineer (916)221-0435 Air Basics, Inc. t,t+na //moil nnnnlc rnm/mailhi/f19ik=551773dhRDR,viaw=nt&search=all&nPrmthid=thread-a%3Ar-1383692554565505057&simDl=msa-a%3Ar4991512... 6/40 6/18/2019 State.co.us Executive Branch Mail - APEN Review: Extraction Rinn Valley Production Facility, AIRS ID 123/A035 www.airbasicsinc.com Please note, my email has changed to colin@airbasicsinc.com. Please update your contact information accordingly! From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Thursday, May 30, 2019 1:33 PM To: Colin Harkins <colin@airbasicsinc.com>; Catie Nelson <cnelson@extractionog.com>; Jonathan Torizzo <jtorizzo@extractionog.com> Subject: Re: APEN Review: Extraction Rinn Valley Production Facility, AIRS ID 123/A035 Thanks far the update Colin. Yes, this is fine with me. You can email me any revised APENs and calculations next week and I will add them as an addendum to the application. I think even at 98%, I would still be curious to see what Questor has to say about critical operating parameters. We are trying to better understand what 98% control really entails as there is very little room room for error where we are assuming DRE is this high. Thanks, James Ricci Permit Engineer [Quoted text hidden] [Quoted text hidden] 5 attachments r.� 2019_0603 Rinn Form 102 - Redline.pdf V� 92K 2019_0603 Rinn Valley LP Gas APEN - Redline.pdf 519K ,® 2019_0603 Rinn Valley LP gas venting - Redline Emissions Calculations.pdf 288K 2019_0603 Rinn Valley VRT Gas APEN - Redline.pdf 508K 2019_0603 Rinn Valley VRT gas venting - Redline Emissions Calculations.pdf 288K Colin Harkins <coln@airbasicsinc.com> To: "Ricci - CDPHE, James" <james.ricci@state.co.us> Cc: Jonathan Torizzo <jtorizzo@extractionog.com>, Kathy Steermaft ksteerman@extractionog.com> James, Tue, Jun 4, 2019 at 9:52 AM I just wanted to follow up about another earlier question. You had asked about other sources that have been stack tested by Extraction. As I mentioned, the RBF Stromberger (AIRS: 123-9F9B) had a stack test performed for self -certification on 5/17/2019. That self -certification was submitted to APCD on 5/31/2019 and I've also attached an electronic copy of the document here. Thanks and have a great day! Colin Harkins Air Quality Engineer [Quoted text hidden] [Quoted text hidden] .® RBF —Stromberger Combined Self Cert Package.pdf 4590K Ricci - CDPHE, James <james.ricci@state.co.us> To: Cohn Harkins <colin@airbasicsinc.cam> Cc: Jonathan Torizzo <jtorizzo@extractionog.com>, Kathy Steerman <ksteerman@extractionog.com> Thu, Jun 6, 2019 at 2:22 PM Colin, Thanks for these updated APENs. Just a few follow-up questions: 1,44ne.•//res,i1 ,,,,,,.,te ,.,,,-,J.,,oiU„/r19ile, 41772tF.Ar1R.1dc ntRcaarrh_ailRnarmthirt=thread-ao/AAr-13R3RQ7Frid5R5rif15f157Rcimn[_msn-a%3Art1991.ri12 7/40 Hello