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HomeMy WebLinkAbout20193971.tiffCOLORADO Department of Public Health & Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 November 19, 2019 Dear Sir or Madam: RECEIVED NOV 2 5 2019 WELD COUNTY COMMISSIONERS On November 20, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - Wake East 32-N Production Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director pubt;C Rev;eui t2.,/o9/tal CG: P(,.(i- ), Ht,.(s_is), Pw(r'- faR/c.1kw), oG(TM) tl/27/l 9 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil a Gas, Inc. - Wake East 32-N Production Facility - Weld County Notice Period Begins: November 20, 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: Wake East 32-N Production Facility Exploration Et Production Well Pad SWSE Section 32 T6N R65W Weld County The proposed project or activity is as follows: This permitting action has been separated from the other permit requests (19WE0772, 19WE0773, 19WE0775, and 19WE0776), which went to public comment 10/31/2019, as the source has requested an increase in permitted emissions for the condensate loadout. Overall, this permitting action was requesting the Downtown Habitat facility (123/9D66) and the Wake East 32N facility be separated as they do not meet co -location requirements. This facility is synthetic minor for VOC, n -hexane, and total HAPS's. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the Division has determined that public comment is warranted because: The permit is part of a project in which the project emissions are greater than 25 tpy in'the nonattainment area and the facility -wide emissions make this a synthetic minor facility for NANSR and therefore these limits, synthetic minor limits. The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0774 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: Lauraleigh Lakocy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public Health ft Environment 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: CONSTRUCTION PERMIT 19WE0774 Issuance: 1 Date issued: Issued to: Extraction Oil &t Gas, Inc. Facility Name: Wake East 32-N Production Facility Plant AIRS ID: 123/A06F Physical Location: SWSE SEC 32 T6N R65W County: Weld County General Description:', Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description Condensate Loadout 004 Truck loadout of condensate by submerged fill Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act(C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B, Section III.G.5.) Page 1 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants must not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO Condensate Loadout 004 --- --- 1.5 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 3. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 4. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled Condensate Loadout 004 Enclosed Combustion Device VOC and HAP PROCESS LIMITATIONS AND RECORDS 5. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Page 2 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Process/Consumption Limits Equipment ID AIRS Point Process Parameter Annual Limit Condensate Loadout 004 Condensate Loaded 261,146 barrels The owner or operator must calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 6. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 7. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 8. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill and emissions must be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) 9. All hydrocarbon liquid loading operations, regardless of size, must be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 10. The owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections must occur at least monthly. Each inspection must be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) must be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. Page 3 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 11. For this controlled loading operation, the owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. 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. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING £t MAINTENANCE REQUIREMENTS 12. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (0&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 0£tM plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section IIL.G. ) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 13. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 14. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 15. This permit replaces the following permits and/or points, which are cancelled upon issuance of this permit. Existing Permit Number Existing Emission Point New Emission Point 18WE0890 123/9D66/011 123/A06F/004 Page 4 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 16. 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,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. 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. 17. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 18. 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. 19. 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 Page 5 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 20. 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. 21. 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. 22. 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. 23. 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 inwriting requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Lauraleigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Page 6 of 8 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) • 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed. by written notice to the Division addressing allof 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) 004 Benzene 71432 107 5 n -Hexane 110543 940 47 Note: All non -criteria reportable pot utants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: • Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.236 1.18E-02 CDPHE State Emission Benzene 71432 0.00041 2.05E-05 n -Hexane 110543 0.0036 1.80E-04 Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each Page 7 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 HAPs 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 website listed below: http://www.ecfr.Rov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart, UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Lauraleigh Lakocy Package 6: Received Date: 7/2/2019 Review Start Date: 4/11/2019 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: '5.yplor3 fion,R Prisdustip n WeA � rr What industry segment2 Ott &" Iatural bas Production 3, Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? El Carbon Monoxide (CO) Extraction Dil>& Gas,:lnc : 40 f Wake Re SWSE quadrant of Section 32, Township SN, Range 65W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range Sw5E 6N 65 Particulate Matter (PM) E✓ Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 002 ornde rs Tsnh - ". = Condensate Tanks:., . ,, S es : 19WE0772- s t. , Yes,. emit lnita —_ Issuance i , Previously permitted under_ igWEo886,:., 003 Produced V/kter Tank ProducedthfaterTanks Yes 19WE0773, `1 fi Yes initial Issuance. fxrayidi4..� y permitted der 1RWE0888 004 :; „ Liquid'Loading..:'.CondensateLoadout, ...... :� ;'; 19WE0773 1 Yes .,x,,,.:Issuance:;. ' `Permit Initial Previously.; permitted ,. under. 18WE0890 005 eparatorVenting „ ._ VRT Gas 19WE0775 1 Yes , ....'permitted. Perm€tlnitial -.. issuance Previously under . 18WE0892 006 eperatorVrbntirg 9WE0776 L' v, Yes -. "E ermitinitiaf • Issasa es,_ Previously,- permitted under':' 18WE0893 Section 03 - Description of Project This permitting action is requesting that the Downtown Habitat facility (123/9Q66) arrd the Wake East 320N facility be separated. Previously the' Wake East points.'were permittedundertheDowntown-Habitat_facili yas,thesourceanYicipatedthatthesales,ga5..pipelinewouldbeco-mingled. As that co -mingling: did not occur and the source states that thisfactk y is a separate site and per the most recent; EPA guidance should be s eparafe-The Wake East facility was previously ass{fined khe AtR5 ID 123/5B3B un?3er a different operator but so no longer ai? active site.This facility -Wan assigned new AIRS IDs This set ofpermits was'sentto public Comment 10/3112010. -After this date, the -source requested` a modification to.theloadaut emissions based on increased throughput sa the ioadout perm t: vill be re npved from -the originalpublic`commentand Wilk fie re-sent.to public comment, Because this change will not impact the regulatoryapplicabrtity of the other point's;they will remain in the original"pupalic notice'period: ending;11130/2019. "" n addition to the above requested points,the source has requested to convert a GP02 which was permitted anderthe Downtown Habitat Facility. While these points havenot physically changed,;escept fortheaddition.of new wells: it was determined thatthis package would go to public comment;as the location of this facility is Because . the source has provided aself-certification ' on the' initial permits issued, 2 of the permits will'be issued without. any self certification requirements -The condensatee tanks and: the separator venting (points 005, 006) Will require. initial testing — Section Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting synttrefid ht7inor.PerizF Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. •5740 Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Colorado Air Permitting Project 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) 5O2 Isthis stationary source a major source? If yes, explain what programs and which pollutants here 5O2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment. New Source Review (NANSR) NOx NOx CO VOC PM2.5 PM10 CO VOC PM2.5 PMS0 TSP TSP HAPs ❑ El HAPs ❑ ❑ Hydrocarbon Loadout Emissions Inventory 004 Liquid Loading Facility AIRS ID: county Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: 95.00 Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Limit Throughput= Potential to Emit (PTE) Volume Loaded = Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = Requested Monthly Throughput = 23.180 Barrels (bbl) per month 417;&21 Barrels (bbl) per year is Barrels (bbl) per year Secondary Emissions- Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Barrels (bbl) per year 244&; Btu/scf 359353 scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Faders & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? Emission Factor Pollutant Hydrocarbon Loadout Uncontrolled Controlled (Ib/bbl) (Volume Loaded) Benzene 4. Toluene Ethylbenzene Xylene n -Hexane 224 TMP Iltl .00E 0E (lb/bbl) (Volume Loaded) 01 1.18E-0: B. 3.801183 S..BltE-04 0.00E+00 0 005.00 Control Device Uncontrolled Pollutant (Ib/MMBtu) (waste heat combusted) PM10 NOx CO ..�,. _,...., Uncontrolled 748 MMBTU per year 898 MMBTU per year 898 MMBTU per year Emission Factor Source (lb/bbl) Emission Factor Source (Volume Loaded) 56t: 0 2.50E-oS onu factors may be used to estimate emissions. 3 of 7 K:\PA\2019\19 W E0772.CP1 Hydrocarbon Loadout Emissions inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tans/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 0,00 0.00 0.00 0.00 000 1 0.00 000 0.00 0.00 0A0 O,011 0.00 0.00 0,00 0.00 0 0,03 0.03 0.03 0.03 0.03 5 30.82 25.58 1,28 30.82 16.4 262 0.14 0.12 9.12 0.14 0.14 24 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224TMP 107 80 4 107 0 0 0 0 - 0 0 0 0 0 0 0 0 0 0 0 940 783 30 940 47 If 0 0 It 9 Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT- Regulation 3, Part B, Section III.D.2.a (See regulatory applicability worksheet for detailed analysis) Section 07- Initial and Periodic Sampling and Testing Requirements The loudest most be operated with submerged All ₹o satisfy PACT. Does the company request a control device efficiency greater than 95% for a flare or combustion device? „ffi e,aA' If yes, the permit will contain and Initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes This source is utilizing state emission factors. AIRS PointB 004 Section 09 - Inventory SCC Coding and Emissions Factors Process It 01 SCC Code 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 lb/1,000 gallons transferred VOC 5.6 95 lb/1,000 gallons transferred CO 0.03 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.00 9S lb/1,000 gallons transferred Ethylbenzene 0.00 05 lb/1,000 gallons transferred Xylene 0,00 95 lb/1,000 gallons transferred mcHexane 0.09 85 lb/1,000 gallons transferred 224 TMP 0,00 95 lb/1,000 gallons transferred 4 of 7 K:\PA\2019\19WE0772.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Re- lotion 3 Parts A ands - APEN and Permit Requirements I5ourca IS in. the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions front any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, PartA, Section title)? 2. Is the loadout located at en exploration and production site (e.g., well pad) (Regulation 3, Part B,Section 11.0.1.1(7 3. is the loadout operation loading less than 10,000 gallons (238 giLs) of crude oil per day on an annual average basis? 4. Is the ioadout 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? E. Are total facility uncontrolled vOC emissions greater than 5TPY, NOx greater than 1OTPY or CO emissions greater than lO TPY (Regulation 3, Part 8, Section 11.0.3(7 (Von have indicated that tourcn is in the Non-Atteinment Arca NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than l TPY (Regulation 3, PartA, Section il.D.1.a)? 2. Is the loadout located at en exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1(? 3, Is the loadout operation loading less than 10,000 gallons (230 Otis) 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? E. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPV or C0 emissions greater than SOTPY (Regulation 3, Part B, Section 11.0.2(7 (source requires a permit 7. RACT- Are uncontrolled VOC emissions from the loadout operation greater than 20 spy (Regulation 3, Part B, Section lll.D.2.al? trenta (The loadout must be operated with submerged Mil to satiety Rdor. 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 S rule or regulation, and the analysis it contains may not apply to a particular situation based upon the Individual fads 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 regulabons, 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 Me 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 then Go to next Go to next. Go to next The loadou COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Extraction Oil & Gas, Inc. 123 AO6F Wake East 32-N Production Facility History File Edit Date Ozone Status 1108/2019 Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 D.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - See Note 1 Previous Permitted Facility total 0.0 0.0 0.0 0.0 . 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 GP02 Caterpillar 400 HP 4SRB RICE 50.6 3.9 50.6 0.2 7.7 3.9 15.5 0.2 Newly requested point 002 19EW0772 Condensate Tanks (8 - 400 bbl) 0.3 135.5 1.2 3.5 0.3 6.8 1.2 0.2 Newly requested point 003 19WE0773 Produced Water Tanks (2-400 bbl) 7.6 1.8 0.4 0.1 Newly requested point 004 19WE0774 Condensate Loadout 30.8 0.5 1.5 0.0 Newly requested point 005 19WE0775 VRT Venting - 0.4 246.4 1.9 5.1 0.4 12.3 1.9 0.3 Newly requested point 006 19WE0776 LP Separator Gas Venting 0.8 384.9 3.5 14.6 0.8 19.2 3.5 0.7 Newly requested point 0.0 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 0.0 Fugitives 0.7 0.0 0.7 0.0 Separator Heaters 0.1 1.4 0.1 1.2 0.0 0.1 1.4 0.1 1.2 0.0 Combined for Inventory Form only Pilot Gas 0.2 1.5 0.7 0.0 0.2 1.5 0.7 0.0 Combined for Inventory Form only FACILITY TOTAL 0.1 0.0 0.0 0.0 53.7 810.7 0.7 59.1 25.9 0.1 0.0 0.0 0.0 10.8 45.7 0.7 24.0 1.5 VOC: Syn Minor (NANSR and OP) NOx: True Minor (NANSR and OP) CO: True Minor (PSI) and OP) HAPS: Syn Minor (n -hexane, Total HAPs) Permitted Facility Total 0.0 0.0 0.0 0.0 52.1 809.1 0.0 57.2 25.8 0.0 0.0 0.0 0.0 9.2 44.11 0.0 22.1 1.5 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 9.2 44.1 0.0 22.1 Pubcom required (see PA). Modeling not required based on division guidelines. Note 1 Total VOC Facility Emissions (point and fugitive) )A) Change in Total Permitted VOC emissions (point and fug live) 46.4 Facility is eligible for GP02 because < 90 tpy Project emissions not less than 25 tpy 44.1 Note: This facility is collocated (the same facility) as 123-981 B. There are no active points at 9B1 B, so this AIRS ID assignment was not changed once it was discovered that the facility already had an AIRS ID. Note 2 Page 6 of 7 Printed 11/10/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Extraction Oil & Gas, Inc. 123 A06F Wake East 32-N Production Facility Emissions - uncontrolled (Ibs oer year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02 Caterpillar 400 HP 4SRB RICE 464 0.2 002 19EW0772 Condensate Tanks (8 - 400 bbl) 448 665 22 287 5654 15 3.5 003 19WE0773 Produced Water Tanks (2-400 bbl) 1262 1390 55 655 326 3 1.8 004 19WE0774 Condensate Loadout 107 940 0.5 005 19WE0775 VRT Venting 799 556 18 115 8715 2 5.1 006 19WE0776 LP Separator Gas Venting 2458 3860 159 1688 21003 4 14.6 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 Fugitives 3 7 2 9 10 6 0.0 Separator Heaters 0.0 Pilot Gas 0.0 TOTAL (tpy) 0.2 0.0 0.0 2.5 3.2 0.1 1.4 18.3 0.0 0.0 0.0 0.0 25.9 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs er year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02 Caterpillar 400 HP 4SRB RICE 464 0.2 002 19EW0772 Condensate Tanks (8 - 400 bbl) 22 33 1 14 283 1 0.2 003 19WE0773 Produced Water Tanks (2-400 bbl) 63 69 3 33 16 0 0.1 004 19WE0774 Condensate Loadout 5 47 0.0 005 19WE0775 VRT Venting 40 28 1 6 436 0 0.3 006 19WE0776 LP Separator Gas Venting 123 193 8 84 1050 0 0.7 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 Fugitives 3 7 2 9 10 6 0.0 Separator Heaters 0.0 Pilot Gas 0.0 TOTAL (tpy) 0.2 0.0 0.0 0.1 0.2 0.0 0.1 0.9 0.0 0.0 0.0 0.0 1.5 7 19WE0772.CP1 11/18/2019 11°V I P 4 2019 A\' CD ld(7opD ,. Sources .. Hydrocarbon Liquid Loading APEN Wake East 32-N Liquid Loadout APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/aped. 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 E0774 AIRS ID Number: 123 / AO6F / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Wake East 32-N Production Facility Site Location: SWSE Sec 32 T6N R65W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Jon Torizzo 303-396-6051 air@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 COLORADO 1 I - A�-�Fnesnei.w�� Wake East 32-N Liquid Loadout APEN Permit Number: 19WE0774 AIRS ID Number: 123 / A06F / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action 0 NEW permit OR newly -reported emission source ❑ Request coverage under construction permit 0 Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or 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 - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Please issue permit modification 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: 5/11/2018 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Yes No p • Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • p Does this source load gasoline into transport vehicles? Yes No • Fl Is this source located at an oil and gas exploration and production site? Yes No Fl • If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • p Does this source splash fill less than 6750 bbl of condensate per year? Yes No • [g Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ p Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 COLOR A DO 2 I .. of n�, ,C Wake East 32-N Liquid Loadout APEN Permit Number: 19WE0774 AIRS ID Number: 123 /A06F/004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: 0 Condensate ❑ Crude Oil El Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 261,146 bbl/year This product is loaded from tanks at this fad ity into: (e.g. "rail tank cars" or "tank trucks") Actual Volume Loaded: Tank Trucks 217,621 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: N/A Average temperature of bulk liquid loading: N/A °F True Vapor Pressure: N/A Psia ® 60 °F Molecular weight of displaced vapors: N/A lb/lb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: N/A bbl/year Actual Volume Loaded: N/A bbl/year Product Density: N/A lb/ft3 Load Line Volume: N/A ft3/truckload Vapor Recovery Line Volume: N/A ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 COLORADO 3 1 AV; H+g[Ihc Gtnr,cn Permit Number: 19WE0774 Wake East 32-N Liquid Loadout APEN AIRS ID Number: 123 I A06F / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.43718, -104.68394 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (`F) Flow Rate (ACFM) Velocity (fusee) N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ✓❑ Upward O Horizontal ❑ Downward O Other (describe): Indicate the stack opening and size: (check one) p Circular Interior stack diameter (inches): ❑ Other (describe): O 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. O Loading occurs using a vapor balance system: Requested Control Efficiency: O 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: Constant Pilot Light: 0 Yes O No Pilot Burner Rating: 2497.99 Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: COLORADO Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 Wake East 32-N Liquid Loadout APEN Permit Number: 19WE0774 AIRS ID Number: 123 / A06F / 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' -. Description of Control Methods) :. Overall eques. e . • :' Control Efficiency .. - (% reduction in emissions) - PM SOX NO. CO VOC ECD 95% HAPs ECD 95% Other: ❑✓ Using State Emission Factors (Required for GP07) VOC ❑✓ Condensate 0.236 Lbs/BBL O Crude 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Projected . . ` Criteria Pollutant Emissions Inventory • :.•. ° •-: :... - .. Pollutant' �•� ° _• Emission' Factor•-..`.::• '. Actual Annual Emissions.' :•: . .... • R• equested.Annual Permit.: _ ,.5.`.:,:::�_:. Emission Limit(s)., .... Uncontrolled:...: -.�5 .' ,,Basis ..:. ^•; ... . I Units��••.:::•(• s Source:,' •' • . AP -42.: " ,Mfg:, etc. � Uncontrolledv .. .. Emissions: s� (tons/year) �:. � - Controlled,: io b >..�� Emissions,:.. � � (tons%year) � � Uncontrolled'' ._.. .i Emissions �• �(tonslyear) � �:: . Controlled _ :. - . ..:... ,- ,.`; .Emissions,.�.� �(Eons'7year)�:' PM SOX NO. CO VOC 0.236 lb/bbl PS Memo 14-02 25.679 1.284 30.815 1.541 -...Non-Criteria m Reportable Pollutant Eissionvs Inentory • . . . _ . _ : Chemical Name .: .._ , . -.-• Chemic•al: . . Abstract.: Service CAS ... ) :•. — Number .: - - Emission Factor :. • :— Actual Annual Emissions :. Uncontrolled , : B.-....„...... . •- .. ,i:' • � Umts'•� � -• . Source,- Sourc ��. (AP -42;,' Mfg:; et n controlled.••` U Emissions:: ..: . (pounds%year)., .: Controlled •;:.;.. • 6 = •:�- Emissions -, -,i ....;•. (pounds%year) -. Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0036 lb/bbl PS Memo 14-02 783.437 39.172 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 COLORADO 5i•a,� eop„FnU ,,,, ,n Wake East 32-N Liquid Loadout APEN Permit Number: 19WE0774 AIRS ID Number: 123 / A06F / 004 [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. 11/14/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Jon Torizzo Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 COLORADO 6 I AV;�,�,�r� HuN�fr Enr�rnMwnl t C C�L��CI [ [ ` Wake East 32-N Liquid Loadout APEN Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: i 23 /A{ F/ 4 0 II [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Wake East 32-N Production Facility Site Location: SWSE Sec 32 T6N R65W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Jon Torizzo Phone Number: 303-396-6051 E -Mail Address2: air@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 402700 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 I COLORADO H6N ut4 w111�6 GNro�unm� Wake East 32-N Liquid Loadout 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 construction permit 0 Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 0 Change permit limit ❑ Transfer of ownership' 0 Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info It Notes: Please issue individual permit for liquid loadout. Previously permitted under 18WE0890. Please cancel 18WE0890 to be replaced with this permit. 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: 5/11/2018 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Yes No p ■ Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • p Does this source load gasoline into transport vehicles? Yes No • IN Is this source located at an oil and gas exploration and production site? Yes No Fl • If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • p Does this source splash fill less than 6750 bbl of condensate per year? Yes No ■ p Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ p Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 2IAY COLORADO nn1 Pobalc Hai.r. Wake East 32-N 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: Requested Volume Loaded5: 93,984 bbl/year Actual Volume Loaded: This product is loaded from tanks at this facility into: Tank Trucks (e.g. "rail tank cars" or "tank trucks") 78,320 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: N/A Average temperature of bulk liquid loading: N/A °F True Vapor Pressure: N/A Psia @ 60 ° F Molecular weight of displaced vapors: N/A 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/ft3 Load Line Volume: N/A ft3/truckload Vapor Recovery Line Volume: N/A ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 I ICOLORADO Departmastl atp Wake East 32-N Liquid Loadout APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information 40.43718, -104.68394 5 g N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): O Other (describe): O 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. O 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: Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: 2497.99 Btu/scf MMBtu/hr O Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 COLORADO affthhic HaaMhfr Fm}ronmmi Wake East 32-N 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 combined) control efficiency (% reduction): PM SOX NO. CO VOC ECD 95% HAPs ECD 95% Other 0 Using State Emission Factors (Required for GP07) VOC ❑✓ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0 Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL Benzene n -Hexane From what year is the following reported actual annual emissions data? Projected PM SOX NO. Co VOC 0.236 lb/bbl PS Memo 14-02 9.242 0.462 11.090 0.555 Benzene 71432 Toluene 108883 Ethylbenzene Xylene n -Hexane 100414 1330207 110543 0.0036 lb/bbl PS Memo 14-02 281.953 14.098 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 51 Department _I caLORADO ate Health. ppetlflp\e Wake East 32-N Liquid Loadout APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit ft 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 Jon Torizzo 19 Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance B 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.uw/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 6I COLORADO Orya.umttatPvbbc Neal* a FnvlroMPx4 Hello